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As part of a newly filed rate case, Vectren Energy Delivery of Ohio, LLC (CenterPoint Energy Ohio) seeks to include in its tariff revised or additional requirements that new retail natural gas suppliers would need to complete to serve as a choice or SCO supplier.

Specifically, Vectren proposes to require that, within 60 days of a choice supplier’s approval to participate in the choice program, the supplier must enroll, and maintain service to, at least 100 active customers, or a sales forecast of 10,000 Mcf in annual sales. Vectren “may” take action to remove from the choice program a supplier failing to meet this threshold.

Under existing requirements, gas suppliers have 90 days from their approval into the choice program to reach these thresholds.

Also under the proposed tariff revisions, Vectren’s tariff proposes that both choice gas suppliers and SCO suppliers should be required to attend a training session on Vectren’s gas transportation program as part of qualifying as a supplier. It is worth noting that Vectren currently offers training to new suppliers, but it is not a mandated under existing tariff.

The proposed tariff also includes a qualification requirement for choice suppliers and SCO suppliers must become approved bidders on Vectren’s pipelines, and provide a DUNS number, or, to Vectren’s satisfaction, provide alternative information equivalent to a DUNS number.

The proposed tariff changes also include a new stay-out period for any choice supplier which defaults, or which otherwise has its program eligibility terminated for any other reason

Specifically, a choice supplier whose program participation was terminated by Vectren would not be eligible to participate in the choice program for 6 months.

The revised tariff would modify the Unauthorized Gas Usage Charge applicable to Pool Operators under Rate 380 Pooling Service – Large Transportation Customers. Currently, if a Pool Operator under Rate 380 delivers less gas to Vectren’s system than the Pool Customers’ collective Plant Protection Level, the Unauthorized Gas Usage Charge is $35.00 per Dth, for the under delivered volumes, in addition to OFO non-compliance charges.

Under the proposed tariff revisions, if a Pool Operator under Rate 380 delivers less gas than the Pool Customers’ collective Plant Protection Level, the Unauthorized Gas Usage Charge for the under-delivered volumes would equal the greater of (a) $35.00 per Dth or (b) a rate equal to three times the Daily Midpoint Price per Dth (as converted to Billing Ccf) reported in Platts Daily in the table “Daily Price Survey” for delivery to (1) Columbia Gas, Appalachia; or (2) Texas Gas, Zone 1; or (3) ANR, La; or (4) Texas Eastern, ELA; or (5) Panhandle, Tx-Okla; or (6) REX Zone 3, delivered, whichever is highest, plus applicable variable costs, including fuel retention, pipeline, and pipeline variable charges and applicable OFO non-compliance charges.

Vectren’s proposed tariff revisions would change the definition of Governmental Aggregator as used in the tariff and would apparently no longer exclude from the term, “a municipal corporation acting exclusively under Section 4 of Article XVIII, Ohio constitution.”

The current tariff defines Governmental Aggregator as having the definition in Ohio Revised Code (ORC) 4929.01(K)(1). In addition to limiting the definition to subpart (K)(1), the current tariff also explicitly provides that the term Governmental Aggregator, “specifically excludes a municipal corporation acting exclusively under Section 4 of Article XVIII, Ohio constitution, as an aggregator for the provision of competitive retail natural gas service.” (in contrast, ORC 4929.01(K)(2) expressly defines such an entity as a Governmental Aggregator). Section 4 of Article XVIII generally address municipalities’ authority to operate a “public utility.”

The proposed revised tariff would define Governmental Aggregator to have the meaning set forth in 4901:1-13-01 of the OAC. Under OAC 4901:1-13-01, Governmental Aggregator has the meaning set forth in ORC 4929.01. As noted above, the meaning of Governmental Aggregator under ORC 4929.01 includes, “A municipal corporation acting exclusively under Section 4 of Article XVIII, Ohio Constitution, as an aggregator for the provision of competitive retail natural gas service.”

The proposed tariff also strikes the current explicit exclusion of, “A municipal corporation acting exclusively under Section 4 of Article XVIII, Ohio Constitution, as an aggregator for the provision of competitive retail natural gas service,” from the definition of Governmental Aggregator

Order (09/19/2024)
24-0835-GA-ATA.
CenterPoint Application for tariff approval (08/27/2024)