20220628Application.pdf

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Avista Corp.
l4l I East Mission, P.O.Box3727
Spokane, Washington 99220-0500
Telephone [phone]
Toll Free 800-727-9170
Jlurnle28,2022
m
" t--Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331W. ChindenBlvd
Building 8, Suite 201-A
Boise, D 83714 r*vw-&'L\43
Avista Utilities Request for Temporary Exemption from GSR 151 and 152, UCRR
203(3), and Associated Tariffs
Dear Ms. Noriyuki:
ln accordance with Idaho Code $$ 61-501 and -507, and pursuant to Rule of Procedure
(F.P) 53 (IDAPA 31.01.01.53), Avista Corporation, dba Avista Utilities ("Avista" or "Company"),
hereby submits for electronic filing with the Idaho Public Utilities Commission ("Commission")
a Petition for Temporary Exemption from provisions of Gas Service Rules 151 and 152 (IDAPA
31.31.01.151 and .152), Utility Customer Relations Rule 203 (IDAPA 31.21.01.203), and
associated Company tariffs. This request is being made so that Avista may provisionally pause its
current natural gas meter testing procedures, or Periodic Meter Changeout (PMC) Prograrn, due to
ongoing meter supply issues, as described within the Petition.
If you have any questions regarding this filing, please contact me at [phone] or
shawn.bonfi eld@ avistacorp.com.
Sincerely,
lolstarrn &ar*&
Shawn Bonfield
Sr. Manager of Regulatory Policy & Snategy
Avista Utilities
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RE
DAVID J. MEYER" Esq.
Vice President and Chief Counsel
Regulatory & Governmental Affairs
Avista Corporation
l4l I E. Mission Avenue, MSC 27
P. O.Box3727
Spokane, Washington 99220
Telephone: [phone]
d av i d. m eyer(@ avi stacorp. com
Attomey for Avista Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COM]VtrSSION
IN THE MATTER OF THE PETITION OF
AVISTA CORPORATION FOR AN
EXEMPTION FROM GAS SERVICE
RULES 15I AND 152, UTILITY
cusroMER RELATTONS RULE 203(3),
AND ASSOCIATED TARIFFS
CASE NO. AYT'.C,.L2. 03
PETITION FOR TEMPORARY
EXEMPTION
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Avista Corporation, dba Avista Utilities (o'Avista" or "Company"), in accordance with
Idaho Code 55 61-501 and -507, and pursuant to Rule of Procedure (RP) 53 (IDAPA 31.01.01.53),
hereby petitions the Idaho Public Utilities Commission ("Commission") for an order providing
temporary exemption from the provisions of Gas Service Rules (GSR) 151 and 152, IDAPA
31.31.01.151 and .152, and Utility Customer Relations Rule (UCRR) 203, IDAPA 31.21.01.203,
through December 3I,2023. GSRs 15l and 152 set forth the requirements for the periodic testing
of customer natural gas meters and standards for natural gas service, while UCRR 203 provides
stipulations regarding the issuance of corrected bills, including specifics regarding the rebilling
time period to be used in the event that the time when a billing problem began cannot be reasonably
determined. Through this Petition, Avista requests temporary exemption from these rules so that
it may provisionally pause its current natural gas meter testing procedures, or Periodic Meter
PETITION FORDGMPTION - I
Changeout (PMC) Program ("Program"), due to ongoing meter supply issues. The Company also
requests temporary exemption from Sections 24-25 of its own natural gas tariff, I.P.U.C. No. 27,
Schedule 170, as they pertain to Avista's meter accuracy and testing procedures.
ln short, because testing must occur in a controlled environment on Company premises,
diaphragm meters must be temporarily removed from service, and there are insufficient
replacement meters to temporarily install, due to supply chain issues. Avista will resume testing
of these meters prior to December 3l , 2023, if and when sufficient supply of replacement meters
is available.
Avista seryes approximately 406,000 retail electric and. 372,000 retail natural gas
customers in a 30,000 square mile service territory covering portions of Washington, ldaho, and
Oregon. Of that amount, approximately 141,000 electric and 91,000 natural gas are ldaho
customers.
I. BACKGROT'ND
While IDAPA 31.31.01 provides broad Gas Service Rules for the investor-owned utilities
in Idaho, including reference to appropriate ANSVASQ standards, there are no Federal or State
rules that further describe the specific details and nuances of a gas meter testing program. As such,
most natural gas local distribution companies (LDCs) in the industry share best practices and are
in alignment with not only one another but with ANSI Zl.9t (or its successoq when such standards
are updated over time) standards for natural gas meter testing practices. Avista is in-step with such
alignment, with the intent of the Company's PMC Program being to ensure Avista maintains a
quality control program to verifu performance of new and installed meters. Avista utilizes, and in
I The American National Standards Institute, ANSI, is a non-profit organization that promotes voluntary conformity
standards for products, services, processes, or systems in the United States (U.S.) as well as representing the U.S. in
international standards organizations, helping to create guidelines that are universally accepted in multiple industries.
PETMONFORDGMPTION.2
tum tests via its PMC Program, three primary meter types, each with a specific niche or use. These
meter types are: 1) diaphragm meters, which are the most commonly used meter type and have a
range from residential to medium commercial loads; 2) rotary meters, which are used to serve
commercial and industial loads; and 3) turbine meters, which serve industrial loads. Forpurposes
of this Petition, the Company is only requesting to temporarily pause testing of its diaphragm
meters with sizes up to 1,000 cubic feet per hour (cflr). The total population of diaphragm meters
eligible for the PMC program in the Company's Idaho service territory is approximately 59,594
meters; of these, Avista tests an average of 830 meters per year. Additionally, approximately I ,588
meters, on average, are processed as FF.2 Please see Tables 24 below formore specific estimations
of the number ofmeters potentially needed for both the PMC Program and FF retirements for 2022
and2023. All rotary and turbine meters will continue to be tested as described in Avista's Schedule
170 and corresponding Gas Standards Manual (GSM) and Standards of Procedure (SOP).
The testing process for natural gas diaphragm meters is briefly described in the Company's
natural gas tariffSchedule 170, Sec. 25(C). For new meters, this includes the meter manufacturer
factory testing and certifting each meter before it leaves the plant, followed by the Company then
inspecting each meter shipme,nt for physical damage. Any meters found to be damaged or in
damaged packaging upon arrival will be tested, repaired and/or calibrated, or returned to the
manufacturer if the Company is unable to fx the meter. After physical inspection, a sampling of
the meters are tested before the meter order is made available for use. The sample size for each
delivery varies, as it is driven by the number of meters in the order. If the meters pass the test, they
are put into inventory and made available for use by Avista. If the tests fail, the Company works
with the meter manufacturer to determine the best course to remedy the situation.
2 Information provided for both PMC and FF are based on2018-2021 averages.
PETMONFORDGMPTION.3
For existing meters already in-service, formal meter evaluations begin when a meter
reaches 10 years old. As previously noted, ANSI Zl.9 provides the basis of Avista's PMC
Program. The Program is based on calendar years, with sample meters required to be pulled and
tested within a given calendar year, then test results are analyzed to drive the protocol for the
following year. A meter family (defined as a meter size, model, and manufactured year)
automatically defaults to "normal" inspection levels when it enters into the Program. The sample
size utilized for each family's testing is dictated by the overall size of the family and the family's
historical testing results. For example, if a family of meters has been perfonning accurately for I0
years, the sample size can be changed to "reduced" in subsequent years, thus allowing fewer meters
to be pulled from that family for purposes of the PMC Program. Conversely, if a family has not
been performing well in two out of the last five years, the sample size changes to "tightened" and
more samples are required for the following year's evaluation. A meter family is considered
"failed" when a population under tightened inspection has encountered 1) three consecutive yearly
inspections that are not accepted, ond/or 2) two consecutive yearly inspections that are not
accepted, and the meters are testing fast (i.e., the indicated volume is greater than actual volume
through the meter). Once a specified meter family has been deemed as "failed'', they are referred
to as a "Failed Family" (FF) and removed from service or their lnstallation Constant updated in
the Company's Meter Data Management (MDM) system. The lnstallation Constant solution is
only suitable for meter families that are experiencing a consistent drift in accuracy; these families
will continue to be tested in the PMC Program.
It is important to note that while Avista's electric meters can undergo such testing in the
field, natural gas meters are tested using specialized equipment that is only available in a shop
seffing. Therefore, removal of meters from service is the only way to test these meters.
PETITION FORDGMPTION - 4
Additionally, it is essential that these meters are tested in a temperature-controlled environment,
again making field testing impractical.
TI. NEED FOR TEMPORARY EXEMPTION
As experienced by many industries across the nation, the supply chain issues that continue
to plague the country as a result of the COVID-I9 pandemic have proven to be a detriment to
Avista's natural gas meter supply. Over the past two years, orders for meters have had increasingly
lengthened lead times. Moreover, as shown in Table No. I below, the pace at which these lead
times changed-from anticipated delivery in less than two months after order date, increasing to
over a year before delivery can be expected for some meter types-has made appropriate
management of inventory levels nearly impossible.
Table No. 1 - Meter Lead Times,2020-2022
Meter Lead Time (weeks)
2020 2021 2022
Meter
Sizf Ql Q2 Q3 Q4 Qr Q2 Q3 Q4 Ql Q2
AC25O 7 7 7 7 t6 t6 4t 4l 54 52
NA25 8 8 8 8 t6 t6 4t 4l 31 39
AC630 8 8 8 8 16 16 4t 4t 3l 39
Avista has sought to mitigate these supply chain issues in many ways, some even prior to
the pandemic. ln 2019, throughout the course of typical business practice improvements and
diversification (unrelated to, and prior to, COVID- I 9), Avista explored potentially ordering meters
from a second meter manufacturer. After having investigated the process, including aligning meter
specifications, badging, and system integrations-in addition to an on-site visit to the vendor's
manufacturing facility to ensure their QA/QC processes were acceptable to the Company-Avista
decided that its current meter vendor was still the best possible option for the Company to procure
PETMONFORDGMPTION. 5
its natural gas meters.3 As the supply issues became increasingly prevalent throughout the
pandemic, Avista encountered many barriers when adapting to the new lead times. For example,
the idea of borrowing or buying meters from other utilities, though considered, was found to be
not feasible due in part to the unique badging system required for each utility's meters. Further,
Avista's Encoder Receiver Transmitter (ERT) modules, which are attached to the meters by the
meter manufacturer and used to transmit meter reading data to a hand-held receiver carried by a
meter reader, are even more unique to Avista as they necessitate exclusive electronic security to
be installed to ensure that the communication path used is applicable to only the Company's
system. Because this unique communication technology is specific to a particular vendor, Avista's
ERT modules are sole-sourced. The lead times for these ERT modules is currently roughly 24
weeks. Like the lead times for the meters themselves, the ERT timing has varied over the last two
years and, at times, has been the primary issue (longest lead time) in the meter ordering process.
As an alternative to diaphragm meters, Avista has also been examining a different type of
metering technology called ultrasonic metering. This technology is not as widespread as the
existing diaphragm meters and is being used by only a handful of other utilities. The lead time is
improved with these meters; however, this approach requires much further scrutiny before the
Company can be confident that the new technology will guarantee safe and accurate measurement
of natural gas services for its customers.
Table Nos. 2 and 3 below provide data for both2022 and2023, respectively, regarding the
Company's existing meter supply count, as well as a forecast of the number of meters needed to
support general natural gas customer growth for 2022-23, the number of meters that would be
3 Comparatively, this second manufacturer has seen similar increases in lead time through the past two years and is
currently experiencing lead times up to 70 weeks.
PETMONFORDGMPTION- 6
needed for the PMC Program to continue at its usual cadence,4 and the number of meters needed
to support replacement of any FFs during the given year. For 2022,these numbers are inclusive of
anticipated meter shipments to be received in November (40 meters - AL1000) and December
(120 meters - AL425). For 2023, shipments for AC250 are expected in March (1,920), April
(1,100), and May (1,600); all other meter types are set to receive a single delivery in January. All
data provided in Table Nos. 2-5 is the best-known information as of June 9,2022.
Table No.2 - 2022Projected Meter Supply Need (All Programs Included)
2022
Curently
In Stock
Qty Needed
Growth
Qty Needed
PMC
Qty Needed
FT'
Expected to
Deliver Meter Totals
MeterTvpe
AC25O 3,238 1"226 8ll 1,541 0 -340
NAz5 104 88 104 166 120 -134
AC63O 53 37 48 212 0 -244
ALl000 l0l t2 63 193 40 -127
Table No. 3 - 2023 Projected Meter Supply Need (Atl Programs Included)
2023
Estimated Stock At
Beginning of Year
Qty Needed
Growth
Qty Needed
PMC
Qty Needed
FF On Order MeterTotals
MeterTvpe
AC25O -340 1.889 811 529 4.620 t-052
NA25 -134 155 104 102 300 -194
AC63O -244 70 48 37 400 0
ALl000 -127 25 63 0 200 -14
For comparison pwposes, Table Nos. 4 and 5 show the same information but assumes the
temporary suspension of the PMC Program, and associated FF replacements, for 2022.
4 PMC Program forecasts include a 20%o "overpull" assumption for Idaho; a comparable assumption is included by
the Company in all of its jurisdictions.
PETITION FOREXEMPTION - 7
2022
Currrnfly
In Stock
Qty Needed
Grorvth
Qty Needed
PMC
Qty Needed
FF
Expected to
Deliver Meter Totals
Meter Type
AC25O 3.238 1.226 0 0 0 2.012
NA25 104 88 0 0 120 136
AC63O 53 37 0 0 0 16
ALl000 l0l t2 0 0 40 r29
Table No. 4 - 2022 Projected Meter Supply Need @MC and FF Excluded)
Table No. 5 - 2023 Projected Meter Supply Need (PMC and FF Excluded for 2022)
2023
Estimated Stock At
Beginning of Year
Qty Needed
Growth
Qty Needed
PMC
Qty Needed
FF On Order Meter Totals
Meter Tvpe
AC25O 2,012 1.889 811 2,070 4,620 r.863
AU25 136 155 104 268 300 -90
AC63O 16 70 48 249 400 49
ALl000 129 25 63 193 200 48
It is crucial to consider the above-referenced timeline for anticipated meter shipments when
viewing Table Nos. 2 - 5, as the month in which these deliveries are expected (and, if such
deliveries are delayed, as they have been frequently over the past two years) is paramount in
considering whether the Company will incur a meter deficit or not in a given year. For example,
until the anticipated December 2022 delivery of AL425 meters is received, Avista will be
experiencing a meter shortage of approximately 254 meters rather than the deficit of 134 meters
illustrated in Table No. 2. Likewise, even with the temporary pause of the PMC Program and FF
replacementsfor2022, as shown in Table No. 4, receipt of this shipment is imperative to reach the
136 total reflected-without it, the Company faces a deficit of approximately 16 AL425 meters.
Notably, Table No. 5 assumes resumption of the PMC Program in2023, which, if all anticipated
deliveries are received on schedule, will be when the Company aims to resume its Program.
Avista's exemption request contained within this Petition, which is proposed through December
PETITION FOREXEMPTION - 8
31,2023, is being made in an abundance of caution to accommodate the possibility that anticipated
meter delivery dates will remain unreliable. If, at any time, the Company is able to supply enough
natural gas meters to resume the Program with confidence that such supply can be consistently
maintained prior to December 31,2023, it will certainly do so.
Customer Impact and Companv Mitisation of Such Imoacts
As Avista considers temporary suspension of its PMC Program, and associated FF
replacements, the Company is cognizant of the provisions of UCRR 203(l) which require that the
utility prepare a corrected bill for a customer "whenever the billing for utility service was not
accurately determined for reasons such as meter malfunction or failure", among other reasons.
Avista strives for accuracy and reliability in providing natural gas service to all Idaho customers,
and is aware that pausing its PMC Program until such time that the supply of natural gas meters is
able to keep pace with the number of meters needed for customer growth, the PMC Program, and
FF replacement, will undoubtedly result in the need to rebill any customers whose meters do
eventually test outside of the prescribed pararneters of GSR 154(l) once the Program is reinstated.
Currently, such billing would need to be completed in accordance with UCCR 203(3)(a), which
states:
If the time when the billing error, billing under incorrect rates, or failure to bill
(collectively referred to as "billing problem") began cannot be reasonably
determined to have occurred within a specific period, the corrected billings will not
exceed the most recent six (6) months before the discovery of the billine problem.
[Emphasis added]
While six months is an appropriate timeframe in many rebilling scenarios, the Company's
request for temporary exemption of UCCR 203 n this Petition is intended to allow Avista to
exceed this six-month limitation, instead providing up to an l8-month rebill for any customers
poturtially overcharsed during the PMC Program's suspension. Customers that may be
underchareed during this time due to a meter that tests slow upon Program resumption will only
PETINONFORHGMPTION- 9
be rebilled for up to 6 months.s The Company believes this to be a necessary protection for
customers, so that they will be appropriately compensated in the event that any of its natural gas
meters do eventually enter FF status after resumption of the Program. It is noteworthy that,
historically, in instances where a natural gas meter does fail testing, the percentages by which these
failures are outside of the 2o/ofastlslow threshold noted in GSR 154(1) are relatively low. For
example, of those natural gas meters that tested fast through PMC Program from 2020-2022,the
average percent fast was 2.7% in 2020, 2.6yo in 2021, and 2.5o/o for 2022 YTD. For purposes of
rebilling, if this information is used to assume that the average "fast" natural gas meter will be
billed at approximately 2.6%o above the customer's actual usage, this means that the average
customer6 would have been overbilled by approximately $L45 per month, or $I7.40 on an annual
basis. Thus, when resuming the PMC Program, if a customer has been overbilled as stated in this
illustrative example, they would receive a bill credit for $26.10 (18 months x $1.45 per month).
Bill credits for overbilling will only be provided to those customers whose meters actually test fast
once the Program resumes, not all customers of a FF.
II. MODIFIED PROCEDIIRE
Avista believes that a hearing is not necessary to consider the exemption requested herein
and respectfully requests that this Petition be processed under Modified Procedure; i.e., by written
submissions rather than by hearing. ^See RP 201, et seq.
5 Meters identified as "stopped" during the Program's suspension will be subject to the customary rebilling timeframes.
6 The "average" Idaho Avista customer uses 63 therms per month, or $55.86 (using Schedule l0l rates effective
February 1,2022).
PETITION FOR DGMPTION - IO
III. COMMUNICATIONS AND SERVICE OF PLEADINGS
All communications, pleadings, and orders with respect to this proceeding should be
directed to:
David J. Meyer, Esq.
Vice President and Chief Counsel
Regulatory & Govemmental Affairs
Avista Corp.
P.O.Box3727
l4l1 E. Mission Avenue, MSC 27
Spokane, Washington 99220-37 27
Telephone: [phone] I 6
E-mail: [e-mail]
Patrick Ehrbar
Director of Regulatory Affairs
Avista Corp.
P. O.Box3727
141I E. Mission Avenue, MSC 27
Spokane, Washington 99220-37 27
Telephone: [phone]
E-mail : patrick. ehrbar@avistacom. com
Avista Dockets (Electronic Only) - AvistaDockets(Eavistacom.com
VII. REOUEST FOR RELIEF
As described in greater detail above, Avista respectfully request that the Commission
approve the requested temporary exemption from the provisions of GSR 151 and 152 (IDAPA
31.31.01.151 and .152) and UCRR 203 (IDAPA 31.21.01 .203), as well as from Sections 24-25 of
the Company's own natural gas tariff I.P.U.C. No. 27, Schedule 170, through December 3t,2023,
as it relates to the testing of diaphragm meters.
DATED this 28ft day of hne2022.
Respectfu lly submitted,
Avista Utilities
By:/s/ Dryid lulqer
David J. Meyer, Vice President and Chief
Counsel for Regulatory and Govemmental Affairs
PETITION FOR DGMPTION - I I