National Fuel Gas Distribution Files Further New York Tariff Revisions Related To Month End Storage Inventory Level Requirements Applicable To ESCOs

National Fuel Gas Distribution Corporation has filed updated tariff revisions at the New York PSC to adjust month end storage inventory level requirements applicable to energy services companies (ESCOs)

Originally, on April 1, 2019, National Fuel Gas Distribution filed tariff changes to adjust month end storage inventory level requirements applicable to energy services companies (ESCOs) serving customers under Service Classification No. 19.

In its original filing, National Fuel Gas Distribution also proposed new tariff language to permit the utility to temporarily adjust storage inventory level requirements, by posting notice to its website.

In the cover letter to the April Filing, Distribution implied that temporary adjustments to storage inventory level requirements would be limited to relaxing such requirements, i.e. that the requested tariff authority could not be used to tighten a month limit (e.g., tightening a December limit by increasing it from 71.00% to 72.00%).

Upon consultation with Department of Public Service Staff, National Fuel Gas Distribution is revising the proposed tariff language to explicitly limit the requested tariff authority to downward adjustments (relaxation) of storage inventory requirements.

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

Case 19-G-0207