New York PSC Approves LDC's Tariff Revisions Related To Month End Storage Inventory Level Requirements Applicable To ESCOs
July 16, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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The New York PSC approved tariff revisions at National Fuel Gas Distribution Corporation to adjust month end storage inventory level requirements applicable to energy services companies (ESCOs)
Under the tariff revisions, National Fuel Gas Distribution will reduce end of month storage inventory level requirements during the calendar months of November through January for ESCOs serving customers under SC 19.
New language also allows National Fuel Gas Distribution to temporarily adjust the storage inventory level requirements, limited to downward adjustments (relaxation) of storage inventory requirements, by posting notice on its website at least five business days prior to the last day of the first month to which an adjusted limit would apply. The tariff revisions do not authorize the utility to tighten the storage inventory level requirements under the temporary adjustment provision
In adopting the changes, the PSC said, "The proposed tariff amendments are a result of National Fuel’s best practices and an internal study that the current tariff minimum storage inventory levels that ESCOs must adhere to may be too strict in certain winter conditions. The amendments serve to level the playing field between the Company and ESCOs by allowing the ESCOs to operate under the same guidelines as the Company. We agree with National Fuel that the proposed storage inventory levels, adjusted downward for the months ending November through January, are appropriate and adequately maintain safe levels of storage inventory. ESCOs are not harmed by the adjusted levels because they are minimum levels that were reduced. The proposed tariff amendment for National Fuel to temporarily adjust the minimum storage inventory level downward provides increased flexibility for the ESCOs and will allow the ESCOs to operate under the same requirements as the Company."
The PSC said, "The Company proposes to notice the revised levels on their website. National Fuel should make clear the month(s) being revised and that the ESCOs must do what is necessary to comply with the minimum storage inventory levels for all other months according to the tariff."
The PSC noted that, "The intent of the provision to temporarily adjust the minimum storage inventory levels downward was only for the months of November, December and January, though the tariff language does not explicitly limit a temporary adjustment to these months. However, it is not necessary to limit the temporary downward adjustment to only these months in the tariff. It is possible that the minimum storage level may need to be reduced during the summer storage injection months if force majeure events occur on the pipelines that carry gas to be stored in the storage caverns."
The tariff amendments filed by National Fuel Gas Distribution Corporation shall become effective on August 1, 2019.
In its original filing, National Fuel Gas Distribution had explained that, upon advanced notice and consultation with Department of Public Service Staff, the utility tested the proposed month end storage inventory level requirements over the past two years, via tariff waiver. "During the test period, system reliability was maintained and the Company is codifying its approach for updating storage inventory level requirements in the tariff," National Fuel Gas Distribution had said
"The Company’s newly proposed tariff language makes current business practices transparent to stakeholders, without seeking an additional tariff waiver. The proposed process applies only for adjustments to November, December and January month end limits (e.g., adjusting a December limit from 71.00% to 70.00%). It cannot be used to tighten a month limit (e.g., tightening a December limit by increasing it from 71.00% to 72.00%)," National Fuel Gas Distribution had said
National Fuel Gas Distribution had reported that no concerns were raised by ESCOs during a review and discussion of this item at a spring ESCO teleconference