PROTESTS
Advice Letters 2924 and 2925 were protested by The Utility Reform Network (TURN) on June 21, 2000.
SoCalGas responded to the protests of TURN on June 28, 2000.
TURN recommends that the Commission not grant SoCalGas' request without requiring further information to justify a deviation for AAA Glass and HF Coors. TURN also recommends that SoCalGas should be required to provide additional data related to the request: data for all core subscription contracts, an explanation of how SoCalGas will treat future customer requests for deviations, and an analysis of the impact of core subscription customers on the total amount of core ITCS cost responsibility. Without meeting the above requests for further information, TURN recommends that the Commission reject the requests in Advice Letter 2924 and 2925 as filed.
TURN protests granting the deviation from Special Condition 4 of G-CS for the two individual customers without sufficient reason other than to allow AAA Glass and HF Coors the option of an alternative gas provider. TURN expresses concern that SoCalGas has not provided adequate data or justification for allowing the deviation for the two customers, or specified whether SoCalGas will extend similar treatment to other G-CS customers. Without sufficient rationale for the requested deviation, SoCalGas would appear to be extending preferential treatment to two customers from a tariff provision other G-CS customers are subject to. Moreover, TURN is concerned that allowing the deviations for the two customers without clear and certain reason may set a poor precedent for other G-CS customers seeking similar treatment. Besides potentially resulting in the effective bypass of the contract term obligation without adequate justification, such actions could informally amend the tariff provision in Special Condition 4.
TURN points out that the reason offered by SoCalGas in ALs 2924 and 2925 to allow competitive procurement of gas by a third party, contradicts the intent of core subscription service, described in D.90-09-089 as a "reliable, premium service for noncore customers that do not seek competitive alternatives."
TURN also disputes SoCalGas' statement that the filing will not increase any tariff rate or charge, and is concerned that potential ITCS cost shifting to core rates may occur with customers leaving the G-CS rate.
In its response to TURN's protest, SoCalGas cites AL 2521 filed September 9, 19963, which authorized a prior request for early termination under G-CS for a noncore customer who opted to pay the remaining reservation charges on its contract.4 SoCalGas states it requests similar treatment in ALs 2924-A and 2925-A, proposing that the customers be allowed to terminate their G-CS contracts and take service under core rate schedules, and be held responsible for unpaid reservation charges should either customer elect noncore service. SoCalGas believes its proposal addresses TURN's concerns regarding the shifting of ITCS costs to other core customers.
SoCalGas' indicates in response to TURN's concerns regarding preferential treatment, that it is willing to make the same request for any G-CS customer who wishes the same treatment. SoCalGas adds that it does not anticipate "many, if any, of the approximately 130 remaining G-CS customers" will request release from their contractual obligations.
There were no protests filed against ALs 2924-A or 2925-A.
3 3. SoCalGas AL 2521 became effective October 30, 1996 and did not require a resolution.
4 4. The G-CS "reservation charge" is a separate charge from the ITCS surcharge. Prior to June 1, 2000 the reservation charge was a fixed monthly charge. After June 1, 2000 the reservation charge is a volumetric charge. The reservation charge is intended to recover the current interstate demand charge associated with a core subscription customer's load.
