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PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

ENERGY DIVISION RESOLUTION G-3302

RESOLUTION

Resolution G-3302. Pacific Gas and Electric Company (PG&E) requests to modify its deviation from General Order 58-A, "Standards for Gas Service" and its Gas Meter Performance Control Program. Approved.

By Advice Letter 2263-G, filed on September 8, 2000. __________________________________________________________

SUMMARY

This resolution approves PG&E's request by Advice Letter dated September 8, 2000, to expand its existing Gas Meter Performance Control Program (Program) under Rule 13(a) of General Order 58-A for testing and controlling gas meter performance. PG&E is requesting to expand its existing Program, which currently applies to all gas meters with capacities of up to 500 cubic feet per hour (CFH), to include all gas meters rated between 501 CFH and 1,000 CFH.

We approve PG&E's request on the basis that they have provided adequate justification to warrant a deviation from G.O. 58-A, Section 13(a) and its Program. The revision to the Program will improve the accuracy of PG&E's gas metering by using statistical meter change programs to identify inaccurate groups of meters that are more than two percent fast, thereby minimizing necessary billing corrections and credit adjustments to individual customers. The revision will save the removal and testing of over 3,000 gas meters annually that will result in estimated annual operational cost savings of approximately $450,000 per year. Finally, the savings due to reduced meter testing would be passed on to ratepayers through PG&E's General Rate Case (GRC) process. During the GRC process, future costs are estimated using recorded data. Adoption of this proposal would lower recorded costs that would eventually be used as part of that forecast process lowering costs to ratepayers in the future.

BACKGROUND

G.O. 58-A, Section 13, Periodic and Other Required Tests of Gas Meters, Paragraph a., provides that no gas meter installed after April, 1989, shall be allowed to remain in service more than ten years from the date when last tested without being retested.

G.O. 58-A, Section 13, Paragraph c., provides that, "Under certain conditions utilities may be authorized to deviate from Rule 13(a) and use a statistical meter control program based on meter performance as demonstrated by sample testing in lieu of periodic testing of each meter. Applications to deviate shall be based on accepted principles of statistical sampling."

By Res. G-1569 adopted on December 13, 1972, the Commission granted PG&E's request to deviate from the fixed 10-year testing requirement for gas meters with capacity of 300 CFH or less, based on meter performance. By Res. G-2681 of June 25, 1986, the Commission authorized expanding the Program to include meters in the range of 300 to 500 CFH. As required by these resolutions, PG&E submits a report to the Commission containing Program results for the previous year.

PG&E has requested by Advice Letter 2263-G dated September 8, 2000, to expand its existing Gas Meter Performance Control Program (Program) under Rule 13(a) of General Order 58-A for testing and controlling gas meter performance. PG&E is requesting to expand its existing Program, which currently applies to all gas meters with capacities of up to 500 CFH, to include all gas meters rated between 501 CFH and 1,000 CFH. PG&E states in this advice letter that this requested revision will allow gas meters to be utilized to their maximum potential, maintain or improve gas metering accuracy, and reduce expenses for PG&E's customers.

Attachment 1 of PG&E's Advice Letter 2263-G entitled "PG&E Gas Meter Test Results (500 CFH to 1,000 CFH) 1995-1999" presents the results of an analysis on its gas meters with capacities between 501 and 1,000 CFH, showing that this group as an aggregate is running well within the standards of performance of the Program. These standards are:

1. No more than ten percent of the meters in a statistical sample may be greater than two percent fast at the check test rate of flow, and

2. At least eighty percent of the meters in a statistical sample will be within plus or minus two percent of zero error at the check rate of flow.

Overall, this group of meters is running 90.47% accurate. A gas meter is determined to be "accurate" when it measures a volume of gas within plus or minus 2 percent of the volume that the calibrated bell prover measures. To state that a group of meters is 90.47% accurate means that 90.47% of meters tested in that group of gas meters have been verified to measure volumes of gas within plus or minus 2 percent of the certified, calibrated bell prover. The plus or minus 2 percent threshold for existing meters is established in the standards of performance of PG&E's Gas Meter Performance Control Program, as approved by the Commission. It is also the threshold specified in PG&E Gas Tariff Rule 17, which states the conditions where PG&E is obligated to make billing adjustments to customers whose gas meters have been tested outside of this accuracy range.

All diaphragm gas meters removed from service at PG&E are tested and compared to Commission certified, calibrated bell provers at the Fremont Gas and Electric Meter Plant. A bell prover is a cylindrical mechanical device that is used to test the accuracy of the gas meters.

PG&E operates a Gas Meter Performance Control Program to monitor the performance of most gas meters with a capacity of 500 CFH or less. The purpose of this program is to detect and remove from service, at the appropriate time, any group of meters whose performance does not meet the prescribed standard of performance. The program uses statistical methods to identify these meter groups, rather than using a prescribed time-based period to change out and test all meters.

The Program is designed to provide accurate measurement of gas delivered to customers, and to optimize gas meter operating costs by extending the life of gas meters in service.

PG&E's gas meter testing personnel have determined through experience that larger meters generally retain an appropriate level of accuracy. Such meters are designed, built, and operated in a similar manner as the domestic gas meters currently covered by the Program. A meter group that is running outside of the acceptable accuracy limits of the program will be identified and changed out quicker, thereby improving the overall accuracy of PG&E's gas metering and ensuring that customers have quicker, more equitable billing adjustments.

Some of the meter types, especially the curb meter groups, demonstrate that they are not meeting Standard 21, above. Curb meter groups are meters that are designed for below ground installation in pits or vaults. PG&E's statistical performance control program will identify these groups earlier than once every 10 years to ensure that these groups will run more accurately in the future.

PG&E believes if its request to expand its Program to include all gas meters rated between 501 CFH and 1,000 CFH is approved, the ratepayers will benefit. First of all, PG&E believes the overall accuracy of its gas metering (by using statistical meter change programs to identify inaccurate groups of meters faster than the 10-year meter change-out program) assures that customers are billed correctly and equitably. Secondly, PG&E believes providing more accurate measurement of gas delivered to customers (by expediting the testing, adjusting, and/or removal of groups of meters that are more than two percent fast) reduces the need for any necessary billing corrections and credit adjustments to individual customers. Finally, PG&E believes the revision will extend the life of gas meters in service. Using the present method, 3,555 meters at a cost of $80 per meter would be changed out in the year 2001. This total cost would be $551,025. Using the proposed method, 650 meters at a cost of $80 per meter would be changed out at a total cost of $100,750. Thus, the revision would save the removal and testing of over 3,000 gas meters annually that would result in estimated annual operational cost savings of approximately $450,000 per year.

NOTICE

Notice of PG&E's proposed modifications was made by publication in the Commission Daily Calendar on September 13, 2000.

PROTESTS

No protests were filed.

DISCUSSION

Energy Division has reviewed PG&E's proposed changes for its deviation from G.O. 58-A and concludes that by adopting the changes, the quality of metering will not decrease and should actually improve. Since these proposed changes concern meter accuracy and not safety issues, they would not adversely affect the level of safety in the gas system. PG&E will continue to perform normal operation and maintenance procedures as scheduled to ensure safe meter operation. These include routine leak surveys for gas leaks, monitoring for atmospheric corrosion, as the routine visual inspection done by the meter readers monthly as they read the meters. The quality of metering provided to the customer should not decrease under the proposed modifications. The effect on customers should be positive given that the reduction in number of meter transactions decreases the opportunity for error and also decreases customer inconvenience due to meter change-outs.

The savings due to reduced meter testing would be passed on to ratepayers through PG&E's GRC process. During the GRC process, future costs are estimated using recorded data. Adoption of this proposal would lower recorded costs that would

eventually be used as part of that forecast process lowering costs to ratepayers in the future.

COMMENTS

This is an uncontested matter in which the resolution grants the modifications requested. The only party, PG&E, has stipulated to waive the 30-day waiting period required by P.U. Code Section 311(g)(1), and opportunity to file comments on the draft resolution. Accordingly, this matter will be placed on the Commission's agenda directly for prompt action.

FINDINGS

1. PG&E filed Advice Letter 2263-G on September 8, 2000.

2. AL 2263-G requests to expand PG&E's existing Gas Meter Performance Control Program, which currently applies to all gas meters with capacities of up to 500 cubic feet per hour (CFH), to include all gas meters rated between 501 CFH and 1,000 CFH.

3. By Res. G-1569 adopted on December 13, 1972, the Commission granted PG&E's request to deviate from the fixed 10-year testing requirement for gas meters with capacity of 300 CFH or less, based on meter performance.

4. By Res. G-2681 of June 25, 1986, the Commission authorized expanding the Program to include meters in the range of 300 to 500 CFH.

5. PG&E is proposing to expand its existing Gas Meter Performance Control Program, which currently applies to all gas meters with capacities of up to 500 cubic feet per hour (CFH), to include all gas meters rated between 501 CFH and 1,000 CFH.

6. This proposed modification will not adversely affect the level of safety in the gas system.

7. The requested change will not decrease the quality of metering and will benefit both the utility and the customer and should be approved.

8. The proposed change will result in an estimated annual operational cost savings of approximately $450,000 per year.

9. The annual operational cost savings would be passed on to the ratepayers through PG&E's GRC process.

10. PG&E's request is reasonable and should be approved.

THEREFORE IT IS ORDERED THAT:

Pacific Gas and Electric Company's Advice Letter 2263-G is approved.

This Resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on March 15, 2001; the following Commissioners voting favorably thereon:

1 1. At least eighty percent of the meters in a statistical sample will be within plus or minus two percent of zero error at the check rate of flow.

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