8. SSS Proposal

SSS proposes that Applicant's meter and the by-pass tee be made available for purchase by the customer. The meter and tee would then be leased back to Applicant. The purpose of this proposal is to facilitate installation of SSS's EQV.

SSS's EQV is designed to be installed between the meter and the tee. Under its proposal, the installation would be on the customer's facilities. SSS's EQV utilizes the meter coupling to simplify installation, and the tee to avoid having to shutoff the customer's gas during installation. The result is a significant installation cost savings. SSS also represents that its proposal would mitigate Applicant's market power.

SSS states that its EQV is only in prototype form. It has not found a manufacturer at this time. SSS has not determined what its proposed purchase and lease-back program would cost Applicant to implement.

Applicant opposes SSS's proposal. Applicant argues that SSS's valve is still being designed, is still pending grant of patents, may never be financed, may never find a manufacturer, has never been installed on a gas service, and has not been certified to meet industry and government standards. Applicant states that it is not apparent that its customers will benefit from allowing SSS to install its valves on Applicant's facilities.

We do not believe that it would be appropriate to require Applicant to set up a program to benefit a specific EQV. Even if we were to consider SSS's proposal, it is premature and lacks sufficient information to be considered. We will not adopt it.