DR 98-041 Keene Gas Corporation 1998 SUMMER COST OF GAS ADJUSTMENT Order Approving the Cost of Gas Adjustment O R D E R N O. 22,916 April 30, 1998 APPEARANCES: John F. DiBernardo for Keene Gas Corporation; and Michelle A. Caraway and Stephen P. Frink for the Staff of the New Hampshire Public Utilities Commission. I. PROCEDURAL HISTORY On March 31, 1998, Keene Gas Corporation (Keene Gas or the Company) filed with the New Hampshire Public Utilities Commission (Commission) its Cost of Gas Adjustment (CGA) for the 1998 Summer period. Keene Gas's filing included the direct testimony and supporting attachments of John F. DiBernardo, ex-Assistant General Manager working on an as-needed basis. The proposed 1998 Summer CGA is a charge of $0.0251 per therm. Keene Gas informed customers and interested parties of the impending rate change by publishing a copy of the Order of Notice in the Keene Sentinel on April 12, 1998. The Order of Notice also notified the Company, its customers and interested parties that the Commission Staff (Staff) was recommending a change in the CGA mechanism that would allow Keene Gas to adjust the CGA rate on a monthly basis. Apart from the Office of Consumer Advocate (OCA) which is a statutorily recognized intervenor, there were no intervenors in this docket. A duly noticed hearing on the merits was held at the Commission on April 27, 1998. II. POSITIONS OF THE PARTIES AND STAFF Keene Gas Corporation Keene Gas witness John F. DiBernardo testified at the hearing and explained: a) the calculation of the CGA and its impact on customer bills; b) the primary reason for the reduction in the proposed rate; and c) Keene Gas's opposition to the proposed change to the current CGA mechanism. A. Calculation and Impact of the Firm Sales CGA The proposed 1998 Summer CGA charge of $0.0251 per therm was calculated by reducing the anticipated cost of gas of $125,952 by the prior period over recovery of $6,365 and related interest of $688 and dividing the resulting anticipated costs of $118,899 by projected therm sales of 259,289 to arrive at a per unit cost of gas of $0.4586 per therm, and then deducting the base summer cost of gas of $0.4335 per therm. Keene Gas's proposed 1998 Summer CGA is a charge of $0.0251 per therm for Firm Sales, representing a decrease of $0.2092 per therm from the 1997 Summer CGA charge of $0.2343 per therm. The proposed firm sales CGA rate of $0.0251 per therm will reduce an average residential heating customer's monthly gas bill by approximately $4.19 or 14 percent. B. Reason for the Reduction in the Summer CGA Rate Mr. DiBernardo testified that the primary reason for the significant decrease in the proposed 1998 Summer CGA rate as compared to the 1997 Summer CGA rate is attributable to the difference in the prior period over/under recoveries, including carrying costs. The 1997 Summer CGA calculation included an under recovery of approximately $25,000, whereas the 1998 Summer CGA calculation is designed to return approximately $7,000 of an over recovery. The $32,000 swing in the over/under collection had a significant impact on rates that are based on total projected 1998 Summer gas costs of $126,000. Mr. DiBernardo stated that the 1997 Summer CGA rate was designed to recover the under collection which occurred during the previous (1996) summer period. He also pointed out that last summer's sales were 10% greater than expected. Thus, the higher 1997 Summer CGA rate recovered more than just the previous summer's undercollection. C. Opposition to Revising the CGA Mechanism Staff recommended that Keene Gas consider a change in the CGA mechanism identical to that proposed by EnergyNorth Natural Gas, Inc. in its 1998 Summer CGA filing (Docket DR 98-015) and approved in Order No. 22,890 dated March 31, 1998. The revised CGA mechanism would enable Keene Gas to make monthly adjustments within 10% of the approved unit cost of gas based on projected over or under recoveries for the period. Keene Gas would be required to report the projected over or under recovery, with supporting schedules, five business days prior to the month end. During cross-examination, Mr. DiBernardo stated that he had reviewed the proposed change to the CGA mechanism that Staff recommended and agreed with Staff that: the revised CGA mechanism would better match gas cost revenues with actual gas costs, thereby minimizing over and under recoveries that are carried forward into subsequent periods; gas costs under both the current and proposed CGA mechanism would remain the same; and that Keene Gas had the staffing and expertise to implement the proposed change. Nonetheless, Keene Gas was opposed to implementing the proposed change to the CGA mechanism at this time. Mr. DiBernardo explained that Keene Gas was in the process of negotiating the sale of the Company and the potential buyer had requested that Keene Gas oppose any change in the CGA mechanism pending the sale. Mr. DiBernardo also pointed out that propane prices were typically less volatile during the summer months and that, due to the reduced heating load, the size of any over or under recovery would be limited. Staff Staff stated that after a thorough review of the filing and discovery, it believed the proposed 1998 Summer CGA charge of $0.0251 per therm is reasonable and should be approved. Regarding the proposed change to the CGA mechanism, Staff stated that it believed the proposed CGA mechanism allowing monthly adjustments would be in the public good and consistent with how the other New Hampshire gas companies would now be operating. Although Staff believed the proposed CGA mechanism is superior to the one currently used by Keene Gas, Staff supported the Company's request that the CGA mechanism remain unchanged for the summer period, for the reasons cited by Mr. DiBernardo. III. COMMISSION ANALYSIS We find that the projected costs, sales and adjustments to the CGA filing are consistent with those approved by the Commission in past CGA's. We find that the Company's proposed CGA of $0.0251 per therm, which is a decrease from the 1997 Summer CGA, is just and reasonable and in the public good and, accordingly, approve the proposed rate. The Commission has approved the proposed change in the CGA mechanism in 1998 Summer CGA filings for the other natural gas local distribution companies in New Hampshire, as proposed and supported by Staff, the companies and the OCA. We believe that allowing monthly adjustments provides those companies a greater opportunity to control over and under recoveries, thus reducing the impact in subsequent CGA filings of the inherent problems associated with large over and under recoveries. We believe that the proposed CGA mechanism better serves the purpose for which the cost of gas adjustment was first implemented, i.e. to more accurately reflect seasonal use patterns and costs and prevent continuous rate increase filings. We also understand that Keene Gas is currently understaffed and is in the process of negotiating a sale. Given this pending sale and the fact that greater stability in propane prices and limited sales are typically experienced during the summer period, thus reducing the potential for a large over or under collection, we will not require Keene Gas to implement Staff's proposed change to the CGA mechanism at this time. However, absent some very strong reason not to, we expect the proposed changes to the CGA mechanism to be adopted for the 1998/1999 winter period. Based upon the foregoing, it is hereby ORDERED, that Keene Gas's Twentieth Revised Page 27, superseding Nineteenth Revised Page 27, N.H.P.U.C. No. 1 - Gas tariff of Keene Gas Corporation providing for a Summer 1998 Cost of Gas Adjustment of $0.0251 per therm for the period May 1, 1998 through October 31, 1998 is hereby APPROVED; and it is FURTHER ORDERED, that Staff's proposed change to the Cost of Gas mechanism, to allow monthly adjustments, is DENIED at this time; and it is FURTHER ORDERED, that the over or under collection shall accrue interest at the Prime Rate reported in the Wall Street Journal. The rate is to be adjusted each quarter using the rate reported on the first date of the month preceding the first month of the quarter; and it is FURTHER ORDERED, that should the monthly reconciliation of known and projected gas costs deviate from the ten percent (10%) trigger mechanism, Keene Gas shall file a revised CGA; and it is FURTHER ORDERED, that Keene Gas file properly annotated tariff pages in compliance with this Order no later than 15 days from the issuance date of this Order, as required by N.H. Admin. Rules, Puc 1603. By order of the Public Utilities Commission of New Hampshire this thirtieth day of April, 1998. Douglas L. Patch Bruce B. Ellsworth Susan S. Geiger Chairman Commissioner Commissioner Attested by: Claire D. DiCicco Assistant Secretary