Agenda Date: April 24, 1996 Item Number: DOCKET: UG-960453 Company Name: Cascade Natural Gas Corporation Staff: Phillip Popoff, Utilities Rate Research Specialist Mike Parvinen, Revenue Requirements Specialist RECOMMENDATION: Issue a Complaint and Order suspending the tariff revisions filed in Docket UG-960453 and set the matter for hearing, while allowing the rate reduction to go into effect on May 1, 1996, on a temporary basis. DISCUSSION: Cascade Natural Gas Corporation (Cascade or the Company) serves approximately 110,000 customers in various areas situated primarily along Northwest Pipeline. Washington cities served by Cascade include: Bellingham, Bremerton, Yakima, Walla Walla, Aberdeen, Anacortes, Mount Vernon, Arlington, Stanwood, Port Orchard, Poulsbo, Siverdale, Shelton, and several others. On April 1, 1996, Cascade filed to revise tariffs for changes in purchased gas costs, with an effective date of May 1, 1996. The Company's proposed purchased gas adjustment (PGA) filing would reduce the annual cost of gas by $2,108,440. This corresponds to a decrease of $0.02675/therm for sales customers. The impact on typical residential bills is a reduction of 5.09%, and a reduction of 5.54% for typical commercial customers. In this PGA filing, Cascade has proposed to increase the allocation of pipeline capacity on Northwest Pipeline to its Washington core customers, the cost of which is more than offset mainly in lower commodity gas costs. The Company also proposed a reduction in Washington's allocation of PGT capacity. Cascade has also proposed to include additional peaking supply contracts in this PGA filing. Cascade initially filed to change its PGA rate on December 29, 1995, with an effective date of February 1, 1996. Due mainly to Staff's concerns, the Company withdrew that filing, in order to give the parties time to resolve these concerns. During this time the Company was able to alleviate some of Staff's concerns; Staff's outstanding concerns are discussed below. Cascade, Public Counsel, and Staff all agree that the Company's current PGA rate is too high, but do not agree on the magnitude of the adjustment. While Staff believes the PGA rate should be lower than Cascade proposed in this filing, continued application of the current rate will continue to exacerbate the problem of accumulating excessive deferral balances, which was discussed in the Company's Docket UG-960453 April 24, 1996 Page 1 deferral filing. Therefore, Staff recommends that the Company's proposed rate decrease be implemented on a temporary basis, which may be reduced further, as a result of a Commission approved settlement or through the hearing process. Staff's main concern with the filing at this point focuses on the Company's management of costs associated with excess transportation capacity, similar to Staff's concern with Cascade's deferral filing. Comparing the Company's peak design day demand forecast for the 1995-96 heating season with the level of transportation capacity Cascade proposes to allocate to Washington core customers, reveals that Cascade is requesting to assign Washington core customers approximately 33% more capacity than these customers require; the increase in excess capacity for the 1995-96 heating season is due to Cascade's proposal to increase Washington core customer's allocation of Northwest Pipeline transportation capacity and the addition of the two bundled peaking supply contracts. This 33% excess capacity would not be needed to serve core customer demand, even under the most severe of Cascade's weather scenarios used in the Company's least cost planning process. While, Staff does not have a position regarding the prudence of this level of excess capacity, Staff is concerned that Cascade did not include any offsetting revenue from such things as capacity releases or offsystem sales, in estimating its prospecitve gas costs. With 33% more capacity than customers need, Cascade should be able to obtain offsetting revenues through capacity releases and offsystem sales, which would offset the cost of this excess capacity. Failing to include such offsetting revenue to mitigate excess capacity of this magnitude would result in PGA rates that would be higher than expected costs, and might contribute to accumulation of deferral refunds in the future. Therefore, Staff recommends that the Commission issue a Complaint and Order suspending the tariff revisions filed in Docket UG-960453 and set the matter for hearing, while allowing the rates as filed to go into effect on May 1, 1996, on a temporary basis.