Unaccounted-for Gas – Rider E – Rider H
AltaGas Utilities Inc. (“AUI”) applied for approval of annual adjustments to its unaccounted-for gas (“UFG”) rate riders E and H to its tariff, effective December 1, 2015.
AUI requested to adjust each of its rate riders as follows:
(a) A reduction to Rider E from 1.31 percent to 1.30 percent; and
(b) A reduction to Rider H from 1.33 percent to 1.31 percent.
AUI submitted that it did not propose any change to its previously approved methodology for calculating Rider E and Rider H using five-year arithmetic averages of UFG percentages based on system receipt volumes for Rider E, and delivery percentages for Rider H.
The AUC found that AUI’s proposed UFG rate calculations were accurate, and consistent with the previously approved calculation method in Decision 2014-291. The AUC also determined that the percentages for Rider E and Rider H were within the range of the previous five-year historical percentages.
In Decisions 2013-396 and 2014-291, the AUC directed AUI to quantify the causes of UFG, reduce its overall UFG, and take steps to minimize UFG fluctuations from month to month.
AUI, in compliance with Decision 2012-292 and Decision 2014-291, provided:
(a) Monthly data for the period from June 2010 to May 2015;
(b) An explanation for seasonal differences in UFG rates being on account of timing differences in natural gas deliveries and receipts, in addition to low flow metering in the summer months;
(c) An explanation of factors that either positively or negatively impacted UFG volumes throughout the year, including:
(i) Pipeline leaks; and
(ii) Incorrect measurements on account of worn, damaged, or failed instruments, as well as maintenance activities on measurement equipment.
The Consumers’ Coalition of Alberta (“CCA”) submitted that AUI’s future applications for UFG rate riders should contain details separated into North, South and Central regions due to the operational differences in AUI’s systems. AUI submitted that it would be amenable to providing the requested data.
The CCA also submitted that it was not satisfied with AUI’s compliance with the AUC’s prior directions regarding the quantification of UFG, as well as UFG fluctuations and overall UFG volumes, noting that AUI’s list of potential causes of UFG could be listed generically for any UFG application. The CCA therefore requested that the AUC direct AUI to document its efforts to reduce fluctuations, to allow parties to understand AUI’s actual reduction efforts.
The AUC dismissed the CCA’s request regarding the quantification of UFG, accepting AUI’s argument that it was unable to further quantify causes of UFG. The AUC held that it was satisfied with AUI’s explanations, and directed AUI to continue to quantify UFG where possible and to take appropriate actions to mitigate UFG.
With respect to AUI’s efforts to mitigate overall UFG and UFG fluctuations, the AUC found that the slight decrease in UFG was encouraging, and expected AUI’s UFG volumes to decrease in its next application. The AUC directed AUI, in its future UFG applications to:
(a) Continue to quantify the causes of UFG where possible, and explain any variances from prior years; and
(b) Continue to update its historical data set for UFG percentage losses or gains on a monthly basis.
The CCA submitted that AUI should be directed to examine the data sets that it uses for UFG as well as the time period for examining UFG, noting that the AUC first approved the May-to-June data set with a November 1st effective date over 25 years ago. The CCA submitted that it would be appropriate to re-examine the data collection period and effective date.
The AUC held that continuing the November 1st effective date and June to May data set continued to be appropriate, noting that negative UFG volumes at the start and end of the data collection period were low in relation to total UFG volumes and that changing the effective date would have no effect on the presence of month-to-month variances. The AUC therefore denied the CCA’s request to change the UFG effective date and data collection period.
In light of the above determinations, the AUC approved the proposed decreases to Rider E UFG volumes to 1.31 percent, and Rider H UFG volumes to 1.31 percent, effective December 1, 2015.
