20220913Comments.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I 133 I W CHINDEN BLVD, BLDG 8, SUITE 20 I -A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ilf.!i I
IN THE MATTER OF AVISTA
CORPORATION'S PETITION FOR A
TEMPORARY EXEMPTION FROM GAS
SERVICE RULES 151 AND 152, UTILITY
cusToMER RELATIONS RULE 203(3), AND
ASSOCIATED TARIFFS
CASE NO. AVU.G.22.O3
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the ldaho Public Utilities Commission, by and through its Attorney of
record, Riley Newton, Deputy Attorney General, submits the following comments.
BACKGROUND
On June 28,2022, Avista Corporation dlbla Avista Utilities ("Company") Petitioned the
Commission for a temporary exemption from provisions of Gas Service Rules ("GSR") 151 and
152, IDAPA 31.31.01.151-.152, Utility Customer Relations Rule ("UCRR") 203, IDAPA
3l .21 .01 .203, and Sections 24-5 of its tariff, No. 27, Schedule I 70.
GSR l5l and 152 set forth requirements for the periodic testing of customer natural gas
meters and standards for natural gas service. UCCR 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.
1STAFF COMMENTS SEPTEMBER 13,2022
The Company represents that, due to supply chain issues, there is and will continue to be
insufficient new meters for new customers and to replace out-of-specification meters for existing
customers. Since out-of-specification meters are detected by the Company's meter accuracy
verification programs, the Company proposes to temporarily pause those prograrns, thereby
reducing the attrition rate of its new-meter inventory.
STAFF REVIEW
Staff reviewed the Company's Petition, tariff, GSR 151 and 152, and UCRR 203, and
responses to its Production Requests. Staff recommends that the Commission approve the
Company's request for a temporary exemption from GSR 151 and 152, UCRR 203, and the
applicable provisions of its tariff.
Testing
Consistent with industry practices, the Company tests three types of meters, including
"diaphragm meters"(the meter type most used to serve residential loads and medium commercial
loads) to verifu performance of new and installed meters. Petition at2-3. Meters that fail to
meet the Company's standards are removed from service. Id. at4. Staff confirmed the
diaphragm meter attrition rate by reviewing the meter testing program's sampling frequency and
the resulting meter failure data for 2020,2027, and2022 (to date). When the attrition rate is
combined with the Company's spare meter inventory Staff concurs with the Company's
conclusion that the status quo cannot be sustained.
Supply Chain
The Company represents that there are only two vendors who sell a compatible meter. The
second vendor has a longer delay (70+ weeks) than the primary vendor (52 weeks). Response to
Production Request No. 2. The Company states that borrowing or buying meters from other
utilities was o'not feasible due in part to the unique badging system required for each utility's
meters." Petition at 6.
The Company has limited capacity to repair existing meters that are out-of-specification.
The Company's meter vendor claims that "repair parts are available in limited quantities,
depending on the part(s) required." Response to Production Request No. 1. Furthermore, the
2STAFF COMMENTS SEPTEMBER 13,2022
Company states that its employees qualified to make repairs have "minimal capacity to do more
work, as they are already incurring overtime to complete many of their existing responsibilities."
Response to Production Request No. 1. These employees may have more capacity if the
Company's meter verification program is suspended, so the Company should be encouraged to
pursue in-house meter repair as an additional mitigation alternative. Staff believes that
mitigation alternatives are likely insufficient, and therefore concurs with the Company's proposal
to suspend its accuracy verification programs. However, Staff also recommends that the
Company continue to fully pursue mitigation altematives.
Lastly, the Company proposes to suspend its meter accuracy verification programs
through December 3I,2023, or sooner if a sufficient supply of replacement meters becomes
available. The Company expects to receive the bulk of the replacement meters in the Spring of
2023. Because recent meter delivery dates have been missed by the Company's vendor, Staff
concurs with the Company's proposal to tentatively extend the program suspension through the
end of 2023 but end the suspension early if meters are received on time.
CSR and UCRR
The Company represents that UCCR 203(3)(a) limits the time which corrected billings can
be sent to a customer to the six months preceding the date an error in the meter is discovered.
Pausing its meter testing and replacement program, the Company indicates, will require that some
customers whose meters eventually test outside the prescribed parameters will need to be rebilled
for billings more than six months before the meter elror was discovered.
Once it resumes its testing and replacement program, the Company predicts it will discover
meters that resulted in overcharges or undercharges to customers. Thus, the Company requests
permission to extend the rebilling period for customers who have been overcharged to 18-months
from the time it resumes its testing program. Staff supports the Company's request and believes
it benefits customers. The Company explains that customers who have been undercharged will
only be rebilled for up to six months. Based on previous years' data, the Company estimates that
if an average customer is overbilled for 18 months, the customer would receive a bill credit for
$26.10.
JSTAFF COMMENTS SEPTEMBER 13,2022
Tartffs
The Company requests a temporary exemption from the rules relating to meter testing
and accuracy in Sections 24 and 25 of its natural gas tariff, Schedule 170. Staff reviewed the
Company's tariff and, in a production request, questioned if "customer-requested meter tests"
would be exempted as defined in Section25 D of tariff Schedule 170. In response, the Company
states that it "is not requesting a waiver of customer requested meter testing." Response to
Production Request No. 8. Staff believes the Company's continuation of customer requested
meter tests is in the best interest of customers.
Finally, Staff notes that the Company's Petition requests temporary exemption from the
requirement to replace meters that fail Company-initiated testing. However, Staff further notes
that the Company's Petition does not request an exemption from the requirement to replace any
non-functioning or otherwise defective meter discovered by the Company through other means,
such as a customer requested meter test.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Petition's request for a temporary
exemption from the rules and tariff schedule that concern the testing and replacement of
diaphragm meters, and require the Company to:
1) Notifu the Commission about any material changes impacting the requested
exemption.
2) Notifu the Commission, prior to the planned exemption sunset date, if the exemption
needs to be modified.
4STAFF COMMENTS SEPTEMBER 13,2022
Respectfufly submiued this l3rH day of September 2022.
Riley
Technical Staff: Kevin Keyt
Jolene Bossard
Matt Suess
Jason Talford
i:umisc/comments/avug22.3mk\[itjbms oomments
5
General
STAFF COMMENTS SEPTEMBER13,2022
CERTIFICATE OF SERYICE
I IIEREBY CERTIFY THAT I HA]/E THIS I3TH DAY OF SEPTEMBER 2022,
SERVED TrrE FOREGOING COMMENTS OF TrrE COMMTSSTON STAFf," IN
CASE NO. AW.G-22-03, BY E.MAILING A COPY TTIEREOF, TO TTIE
FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
sPoKAlrE wA9922A4727
E-MAIL : [e-mail]
dockets@avistacorp. com
DAVID J MEYER
VP & CHIEF COUNSEL
AVISTA CORPORATION
POBOX3727
SPoKAI{E WA99220-3727
E-MAIL : [e-mail]
SECRETARY
CERTIFICATE OF SERVICE