FINDINGS
1. SoCalGas filed Advice Letters 2924 and 2925 to request authority for customers, AAA Glass and HF Coors Company, respectively, to deviate from the two-year contract term specified by Special Condition 4 of the core subscription tariff, G-CS. SoCalGas states that the request was made so that AAA Glass and HF Coors could take service under another rate schedule allowing them to procure natural gas supplies from a third party provider or marketer.
2. TURN protested Advice Letters 2924 and 2925 on June 21, 2000 on the basis that advice letters provided little information and justification to warrant a deviation, constituting preferential treatment for the two customers by SoCalGas. TURN states that granting the deviations without "a minimum amount of data and justification" may have impacts which increase the core cost allocation of the ITCS and effectively bypass the tariff provision stated by Special Condition 4.
3. TURN requests that SoCalGas be required to submit additional information regarding how it plans to treat future requests from other customers to deviate from Special Condition 4, and potential impacts to ITCS from the core subscription customers.
4. SoCalGas' responded to TURN's protest on June 28, 2000 and filed supplemental Advice Letters 2924-A and 2925-A on July 7, 2000 to address TURN's concerns regarding the ITCS obligation and future treatment of the two year requirement of G-CS. The supplemental advice letters indicate that the customers would enter service under alternative core rate schedules, under which the customers would be subject to similar reservation and ITCS charges had they remained under G-CS. In its response to TURN's protest, SoCalGas states that it would extend the same deviation to any G-CS customer with the provision that the customer pays for remaining reservation charges under its G-CS contract.
5. In ALs 2924-A and 2925-A, SoCalGas did not specify that the customers would be required to continue contributing to recovery of core ITCS costs, if the customers chose a noncore rate schedule.
6. In AL s 2924-A and 2925-A, SoCalGas no longer states the choice of an alternative gas supplier as justification for a deviation from Special Condition 4.
7. Core subscription service established in D.90-07-065 provides eligible noncore customers procurement and transportation services for those customers who wish to procure gas supplies at a high level of transportation priority from the utility. The customer's commitment on core subscription service includes a two-year contract commitment.
8. D.90-09-089 discussed the two-year commitment as an integral provision of core subscription service, the time commitment being a reasonable trade-off for premium reliable service provided by the utility. In addition to effects on the UDC's operational and financial planning, the two-year commitment has potential impacts on the level of ITCS, as described in D.90-07-065.
9. SoCalGas has not offered a reasonable rationale for a deviation from the two year contract term specified by Special Condition 4 for AAA Glass or HF Coors.
10. SoCalGas' request Advice Letters 2924-A and 2925-A should be denied.
