Hawke

M cKeon & Sniscak LLP

Thomas J. Sniscak (717) 236-1300 x224 tjsniscak@hmslcga).com

ATTORNEYS AT LAW

100 North Tenth Street, Harrisburg, PA 17101 Phone: 717.236.1300 Fax: 717.236.4841 www.hmslegal.com

March 26,2014

Rosemary Chiavetta, Secretary Pennsylvania Public Utility Commission Commonwealth Keystone Building 400 North Street, 2 n d Floor (filing room) Harrisburg, PA 17120

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RE: Petition of Columbia Gas of Pennsylvania, Inc. for Approval of a Distribution System Improvement Charge; Docket No. P-2012-2338282; EXCEPTIONS OF THE PENNSYLVANIA STATE UNIVERSITY TO THE FEBRUARY 25, 2014 RECOMMENDED DECISION

Dear Secretary Chiavetta:

Enclosed for filing with the Commission are the Exceptions of The Pennsylvania State University ("PSU") in response to the Recommended Decision issued February 25, 2014 in the above-referenced matter. Copies of PSU's Exceptions have been served in accordance with the attached Certificate of Service, as well as upon Administrative Law Judges Mark A. Hoyer and Jeffrey Watson (via U.S. Mail).

If you have any questions regarding this filing, please do not hesitate to contact the undersigned.

Very truly yours,

Thomas J. Sniscak

Counsel to The Pennsylvania State University

TJS/WEL/bes Enclosure cc; Per Certificate of Service

Honorable Mark A. Hoyer, Administrative Law Judge (with enclosure) Honorable Jeffrey Watson, Administrative Law Judge (with enclosure) Office of Special Assistants, Pennsylvania Public Utility Commission (via electronic mail)

MAILING ADDRESS: P.O. BOX 1778 HARRISBURG, PA 17105

BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION

Petition of Columbia Gas of Pennsylvania, Inc. for Approval of a Distribution System Improvement Charge

Docket No. P-2012-2338282

EXCEPTIONS OF THE PENNSYLVANIA STATE UNIVERSITY

Before Administrative Law Judges Mark A. Hoyer and Jeffrey Watson

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Thomas J. Sniscak, Attorney l.D. 3389 Hawke McKeon & Sniscak LLP 100 North Tenth Street P.O. Box 1778 Harrisburg, PA 17105-1778 (717)236-1300 tjsniscak@hmslegal.com

Counsel for The Pennsylvania State University

DATED: March 26; 2014

INTRODUCTION AND SUMMARY OF EXCEPTION

The Pennsylvania State University ("PSU"), by its attorneys in this proceeding, Hawke

McKeon & Sniscak LLP, files these Exceptions in the above-captioned matter in response to the

February 25, 2014 Recommended Decision ("RD") of Administrative Law Judges ("ALJ") Mark

A. Hoyer and Jeffrey Watson.

Specifically, the Company excepts to the RD's adoption of the Office of Consumer

Advocate's ("OCA") Distribution System Improvement Charge ("DSIC") tariff language1

pertaining to negotiated contract or "flex" service to be included in Columbia Gas of Pennsylvania

Inc.'s ("Columbia" or "Company") tariff which leaves negotiated rate customers of Columbia with

uncertainty regarding application of the DSIC charge in the future. The Commission should reject

this recommendation and adopt the clear and unambiguous tariff language set forth in

Columbia's Main Brief and testimony - which contains clarifications proposed by PSU - and that

leaves no doubt or confusion that the DSIC charge will not apply to customers that have

negotiated rates due to competitive or potentially competitive options.

EXCEPTION

Exception No. 1. The Commission Should Reject the ALJs* Recommended Adoption of the OCA's Discretionary and Confusing DSIC Tariff Language and Adopt Columbia's Clear and Unambiguous Language that the DSIC Charge Will Not Apply to Customers that have Negotiated Rates Due to Competitive or Potentially Competitive Alternatives. RD at 75, 78

On page 75 and 78 of the RD, the ALJs recommend adoption of the OCA's proposed

DSIC tariff language to be included in Columbia's tariff addressing the application of the DSIC

to customers with competitive alternatives. Specifically, OCA's language the RD recommends

is:

1 RD m 75, 78.

The DSIC shall be applied equally to all customer classes, except that the Company may reduce or eliminate the Rider DSIC to any customer with competitive alternatives who are paying flexed or discounted rates and customers having negotiated contracts with the Company, i f it is reasonably necessary to do so. RD at 75, 78 (emphasis added)

The AUs believe that this gives Columbia the flexibility and discretion to decide whether

to apply the DSIC to customers with competitive alternatives. Id. However, the language "may

reduce or eliminate" and " i f it is reasonably necessary to do so" does nothing but create

confusion and uncertainty for competitive customers as to whether the DSIC will be applied to

them. In contrast, Columbia's proposed DSIC tariff language - which contains clarifications

proposed by PSU and accepted by Columbia in its Main Brief and testimony, is clear and

unambiguous that the DSIC charge will not apply to customers that have negotiated rates due to

competitive or potentially competitive alternatives. Columbia's proposed tariff language is as

follows:

The DSIC shall be applied equally to all customer classes, except that the Company shall not apply the Rider DSIC to any customer with competitive alternatives, or potential competitive alternatives, who is taking service at flexed or discounted rates and to customers having negotiated contracts with the Company, (emphasis added)

PSU Main Brief at 8; Columbia Gas Main Brief at 26.

As set forth fully in PSU's Main and Reply Briefs and below, the ambiguous DSIC

language adopted by the ALJs should be rejected because 1) it is vague and uncertain while

Columbia's proposed language is clear and unambiguous; 2) it is unsupported by the

Commission's Implementation Order;2 and 3) it fails to acknowledge the contractual reality of

competitive large business and institutional customers.

2 Final Implementation Order, Docket No. M-2012-2293611 (Order entered August 2, 2012).

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a. The OCA's tariff language adopted by the ALJs results in ambiguity and confusion because it does not accurately represent how Columbia will treat DSIC for Flex Customers.

i. Ambiguity of OCA's proposal versus certainty of the CoIumbia/PSU proposal.

The Commission has given Columbia the right to decide i f it wants the DSIC to apply to

flex customers or not. Here, Columbia in this filing and in its sworn testimony decided that it

will not apply DSIC to flex customers. Indeed, Columbia's witness and briefs in this matter

make it clear that Columbia "will not apply the DSIC" to competitive customers.4 Accordingly

and appropriately, Columbia proposed the following tariff language to clearly state its treatment

of flex vis-a-vis DSIC:

The DSIC shall be applied equally to all customer classes, except that the Company shall not apply the Rider DSIC to any customer with competitive alternatives, or potential competitive alternatives, who is taking service at flexed or discounted rates and to customers having negotiated contracts with the Company, (emphasis added)

PSU Main Brief at 8; Columbia Gas Main' Brief at 26.

First and foremost the goal of tariff language should be to inform the public, customers,

and potential customers as to how a rate or term of service will or will not apply. Here,

Columbia's sworn testimony says it will not apply DSIC to flex customers. However, the ALJs

recommend use of OCA's tariff provision that negates Columbia's decision and would not

accurately reflect how Columbia will treat DSIC relative to flex customers. Specifically, the

OCA provision the ALJs prefer provides:

The DSIC shall be applied equally to all customer classes, except that the Company may reduce or eliminate the Rider DSIC to any customer with competitive alternatives who are paying flexed or discounted rates and customers having negotiated contracts with the Company, / / it is reasonably necessary to do so. RD at 75, 78 (emphasis added)

3 Final Implementation Order-al 46. 4 Columbia Gas Main Brief al 25 (citing Columbia Statement 6 at 4:1-3).

Thus, the ALJs and OCA would improperly strip the Company of its decision, and for

purposes of this tariff provision, would have customers or potential customers believe DSIC can

apply to flex service when in sworn testimony Columbia has stated it will not. The RD's and

OCA's micromanaging of Columbia's management's judgment also violates the managerial

prerogative rule which this Commission and the appellate courts have recognized.5

Moreover, Columbia's language which accepted PSU's suggested modifications is

unambiguous using "shall not apply" language versus OCA's language "the Company may

reduce or eliminate ... i f it is reasonably necessary to do so."6 Neither OCA nor the ALJs

identified what "reasonably necessary to do so" means and what standards apply. These

subjective terms are also vague because it is unclear who will decide if "it is reasonably

necessary," or what factors or reasoning will go into that decision.

This situation creates uncertainty for competitive customers, who will have no real notice

as to whether the DSIC will be applied to them, as they have no way to know what "reasonably

necessary" means and if they qualify under that subjective standard. This phrase is also

problematic and causes confusion given that Columbia has emphatically stated in its testimony

and briefs that it will not apply the DSIC to competitive customers. As discussed in PSU's Main

and Reply Briefs, the Final Implementation Order permits Columbia to effectuate such intent as

a rule. Thus, the adopted language is uncertain when applied by Columbia to competitive

customers.

5 To strike the proper balance between a utility's right of self-management and the Commission's duty to the public, courts and the Commission itself recognize that the Commission cannot interfere with a utility's management unless an abuse of discretion or arbitrary action by the utility has been shown. National Fuel Gas Distribution Corp. v. Pa. Pub. IJtil Comm'n, 464 A.2d 546, 559 (Pa. Cinwlth. 1983); see aha Pennsylvania Pub. 67//. Comm'n v. Philadelphia Electric Co., 71 Pa. P.U.C. 42, 45 (1989). As it is Columbia's discretionary call specifically under the Implementation Order to apply or not to apply DSIC to flex customers, Columbia's decision here not to apply it flex customers as a rule to promote its competitive ability to retain or obtain more use by the customer is clearly within its permitted managerial judgment. 6 RD at 75.

The ALJs state that they are not persuaded that, "discretionary language will result in

uncertainty and loss of customers."7 That, however, misses the point that the tariff should

accurately reflect how Columbia in sworn testimony stated it will not apply DSIC to flex

customers and that the ALJs preferred OCA language does not make that unequivocally clear. As

to the ALJs statement that there is no customer loss risk to OCA's language, that belief is a risk

(of bad consequences) that need not be taken if Columbia and PSU's more specific tariff

language is adopted.

The ALJs' statement that there is no "uncertainty" is also contradicted by the fact that

"discretion" creates "uncertainty" by its mere definition. By contrast, the words "shall not

apply" create no uncertainty at all. Accordingly, Columbia's actual intent should be given full

effect through use of the clear and unambiguous phrase "shall not apply."

ii. Potential Competitive Alternatives as referenced in the Company and PSU proposals should be retained in the tariff language.

Next, the ALJ's adopted the OCA's preferred language "with competitive alternatives"8

and rejected Columbia's language that includes the more comprehensive "potential competitive

alternatives" concept. First, inclusion of "potential competitive alternatives" better reflects the

circumstances and reality of negotiated rate agreements. The rejection of "potential competitive

alternatives" creates ambiguity and wasted time and resources. PSU Witness Crist explained that

the "with competitive alternatives" language without more clarity provided by also including "or

potential competitive alternatives" would put customers in an "untenable position of having to ...

commit to another alternative before being eligible to enter into a flex agreement with

Columbia." Moreover, PSU Witness Crist explained why natural gas utilities such as Columbia

need to be able to address "potential competitive alternatives":

7 A/. * RD at 75,78.

Customers seeking alternatives to distribution service from the Company may have several important reasons for their motivation. One such reason might be the economics of the alternative. If an alternative is or could be made available that would demonstrate attractive economics for the customer and Columbia acts prudently in offering a competitive discount in advance of the customer actually installing, constmcting or contracting for the alternative, that is an action that should be supported and promoted.

(PSU Statement No. 3 at 2:18-23)

Crucial to the customer's determination as to whether to stay with an incumbent such as

Columbia is the need for certainty at this planning stage to know with certainty if charges such as

the DSIC will apply or not; otherwise, the customer will not know what the total rate is for

service. Similarly, it is in Columbia's interest (as well as all other customers as recognized by

the Implementation Order) to retain the customer or attract new business from the customer by a

clear and unequivocal tariff provision stating that DSIC will not apply to flex rates given the

potential competitive alternative. In reality, a customervonce spending the time and effort for the

potentially competitive alternative to be identified, should not have to go to the next step and

take the nugatory and potentially liability-inducing actions of signing contracts with competitors

or to build bypass facilities. Such contracts or facilities that are initiated with the purpose of

making flex rates not subject to DSIC would then need to be respectively unwound or not

utilized to allow Columbia to retain the patronage of the customer.

The ALJ's acknowledge the foregoing in their decision yet they rejected putting that

concept in the tariff. That should be remedied. Specifically, the ALJs acknowledge at page 75

of the RD that, "[i]n a situation where a viable competitive alternative exists, even if not yet

constructed, the Company should have the ability to reduce or eliminate the DSIC for that

customer, i f necessary." Simply put, as that concept is neither disputed by the ALJ's, OCA or

the Company and PSU, then why should it not be in the tariff so it is clear to all? Notably, in the

future, maybe many years from now, when those involved seek to interpret what the tariff

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language means, they may not remember or refer to what the ALJs say could be done in the text

at page 75 of their RD. The bottom line is, the more definite the language in the tariff, as

proposed by Columbia and cited above, the better for all involved.9

b. Columbia's intent not to apply the DSIC to competitive customers is consistent with the Implementation Order and Commission policy.

Columbia's testimony that it will not apply the DSIC to flex, discount, or competitive

customers10 is supported by the Commission's implementation of the DSIC because it reflects

the same policy considerations made by the Commission in its Implementation Order - rates

should still be based on cost-causation, and application of the DSIC is contrary to contract terms

and is long-term counterproductive. For instance, negotiated rate customers who have paid for

their own infrastructure will not derive a benefit from DSIC improvements11 and Columbia has

recognized this principle through its intent not to apply the DSIC to competitive customers so

that costs are not divorced from the cost-causer. The adopted language, "the Company may

reduce or eliminate," is not as firm as Columbia's intent, as evidenced by the Company's

testimony cited above.

Specifically, the use of the word "may" does not entirely enforce the position that the

Company will not apply the DSIC to competitive customers. (PSU Statement No'. 1 at 5:1-10)

Thus, PSU advocates use of the word "shall" because it best describes Columbia's actual intent.

Columbia agrees with this modification. (Columbia Gas Statement 1-R at 7:12-16) Witness

While PSU submits that Columbia's tariff language, {containing PSU's clarifications the Company accepted in its testimony and Main BrieO is the clearest, most certain, and best represents business and market realities, PSU submits, that in the alternative, the adopted language should be modified to remove the equivocal "may" and "reasonably necessary to do so" language regarding its applicability to flex, discounted, or negotiated contract service customers, and that the phrase "competitive alternative" be better defined by adding: "A competitive ahemative shall not mean that a customer has to have installed the alternative or executed a contract for the alternative; rather, there only has to be a demonstration that the customer alternative is economic or otherwise justified by the customer's operational needs." (PSU Statement No. 3 at 5:4-10).

Columbia Statement No. 6 at 4:1-3. " PSU acknowledges that it does have other accounts with Columbia which are not competitive customer accounts. PSU does not dispute application of the DSIC to those non-competitive customer accounts.

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ICrajovic explained this modification will not change Columbia's current application or

calculation of the DSIC because Columbia currently excludes from the calculation of the DSIC

consideration of any revenues from customers with negotiated contracts. (Columbia Gas

Statement !-R at 7:18-21) Thus, "shall" best illustrates Columbia's actual intent in not applying

the DSIC. Accordingly, Columbia's tariff language regarding competitive customers will clearly

and unambiguously reflect this choice through use of the mandatory phrase "shall not apply."

Also, as PSU Witness Crist explained "[c]ompetitive customers have already been

through a negotiation with the utility to determine the rates and terms necessary to reach an

agreement... . it would not be appropriate for the utility to attempt to add additional costs of a

DSIC and burden the customer, violating the agreement." (PSU Statement No. 1 at 4:6-12)

Thus, the Commission wisely has recognized that it would be unfair to have a flex or negotiated

contract customer forego other alternatives in reliance upon a contract based rate only to face a

regulatory bait and switch. Deference to contract terms in the ratemaking process is nothing new

to regulation as it is also a policy reflected at the federal level: "rate filings consistent with

contractual obligations are valid."12

In addition, the Commission also reasoned that applying the DSIC to competitive

customers would be "counterproductive in the long-run," Final Implementation Order at 46,

because it will cause competitive customers to leave the utility. The DSIC charge is for

improvements to the rest of the utility's distribution system, which provide little to no benefit to

competitive customers. Thus, applying the DSIC will in essence tax or punish competitive

customers for deciding to stay with the utility. A policy promoting applying the DSIC to such

1 2 Richmond Power & Light v. FPC, 481 F.2d 490, 493 (D.C. Cir. 1973) (citing Federal Power Commission v. Sierra Pacific Power Company, supra, 350 U.S. 355; United Gas Pipe Line Co. v. Mobile Gas Service Corp., 350 U.S. 332 (1956)). Deference to contractual rales is an implication of the Mobile-Sierra doctrine. Id. Mobile-Sierra is applied to FtiRC approved contracts. Here, our Commission allows natural gas utilities to offer flex and negotiated contract service and thus has approved such tarifTofferings.

customers is a poor and self-defeating one as it will encourage these customers to leave the

system or to use other alternatives, such as finding one of the many private pipeline companies to

build a by-pass facility, and not be regulated or subject to jurisdictional rates.13 If a utility such

as Columbia loses these competitive customers, it will be detrimental to all other customer

classes in the long-run because there will be no "support for infrastructure costs." Final

Implementation Order at 46. Columbia's decision that it will not apply the DSIC to competitive

customers effectuates the Commission's progressive position to avoid long term detrimental

effects to the utility and all customer classes; defer to existing contracts; and continue to assign

costs to the cost causer.

c. The ALJ's adopted language ignores the reality of Columbia's contractual relationship with competitive customers.

The ALJs agreed with the OCA that Columbia should seek to apply the DSIC whenever

possible and only give a "discount" when necessary to retain customers. RD at 75, OCA Main

Brief at 42 (citing OCA Statement No. I-R at 2). The ALJs believe, "[t]his gives the Company

flexibility and discretion." Id. This reasoning is flawed and should be rejected because it implies

the language "may reduce or eliminate" would allow Columbia the freedom or "flexibility and

discretion" to unilaterally modify its competitive customer contracts and ignores the fact that

Columbia is already recovering the amount necessary to retain these customers. Companies that

enter into contracts with energy suppliers expect those agreements to be honored, have made

business decisions and do budgets based on the contracts into which they have entered, and do

not expect that at some point in the future those contracts should be subject to additional

surcharges or modified.

1 3 Final Implementation Order at 46 (It would be "counterproductive in the long term to add costs that may induce the customer to leave the system and provide no support for infrastructure costs.").

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PSU witness Crist pointed out this language gives rise to a situation which is neither fair

to Columbia nor its'customers. He explained:

[t]he Company's first obligation in determining the amount of revenue it can obtain from a competitively situated customer is to determine the maximum amount of distribution charges that it may collect. Once determined and agreed to by the customer then the customer may elect to forgo a physical plant change, such as rerouting a gas piping system, to obtain service from the Company. To suggest that the Company then has the right to return to the customer and add on an additional amount violates [the business agreement between the Company and the customer. Such action would disparage the integrity of the Company and should not be allowed nor encouraged. (PSU Statement No. 3 at 3:16-4:8)

Since these competitive customers have negotiated contracts with Columbia, this "shall

not" language unambiguously signals to these customers, such as PSU, that Columbia will honor

its contracts. Again, in negotiating contracts Columbia has already obtained the most revenue

possible from thesei customers. Columbia Main Brief at 26. Finally, Columbia already excludes

from the calculation of the DSIC consideration of any revenues from customers with negotiated

contracts. (Columbia Gas Statement No. 1-R at 7:18-21) Thus, there is no basis to assert that

Columbia.should or could apply the DSIC to competitive customers because of the contractual

relationship between the parties. Id.

With respect to the language "potential competitive alternatives," OCA argued this

phrase is not necessary to outline those customers to which the DSIC will not be applied. The

OCA asserts, without citation or explanation, that inclusion of this phrase "does not accurately

reflect Columbia's, ongoing practices in determining to provide negotiated rates or stated

intentions regarding the collection of the DSIC from the customers." OCA Main Brief at 42-43.

The OCA also argues inclusion of this phrase is too broad and would allow Columbia to

unnecessarily waive the DSIC.

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OCA's arguments ignore the fact that Columbia has no financial incentive to offer

discounts to customers without a viable competitive alternative. If there is no viable economic or

operational alternative, the customer has no other option than Columbia, and Columbia has no

need to offer this type of customer a negotiated or flex rate. Thus, considering the language of

the tariff requires the customer to be paying a flex, discounted, or negotiated rate for Columbia to

waive the DSIC, and in reality Columbia has no incentive to offer a flex or negotiated rate to a

customer who does not have a viable alternative energy source, the OCA's contentions are

without merit because they do not acknowledge the reality of these contracts and incentives.

For the reasons stated above, PSU's Exception No. 1 should be granted.

CONCLUSION

WHEREFORE, for the reasons set forth above. The Pennsylvania State University

respectfully requests that the Commission grant this Exception and enter an Order adopting the

tariff language proposed by Columbia and supplemented by PSU as follows:

The DSIC shall be applied equally to all customer classes, except that the Company shall not apply the Rider DSIC to any customer with competitive alternatives, or potential competitive alternatives, who is taking service at flexed or discounted rates and to customers having negotiated contracts with the Company.

Respectfully submitted.

DATED: March 26, 2014

Thomas J. Sniscak, Attorney l.D. 3389 Hawke McKeon & Sniscak LLP 100 North Tenth Street P. O. Box 1778 Harrisburg, PA 17105-1778 (717)236-1300 tisniscak(alhmslei>al.com

Counsel for The Pennsylvania Stale University

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C E R T I F I C A T E OF SERVICE

I hereby certify that I have this day served a true copy of the foregoing document

upon the parties, listed below, in accordance with the requirements of 52 Pa. Code § 1.54

(relating to servicelby a party).

VIA ELECTRONIC MAIL AND FIRST CLASS U.S. MAIL

Eric Gannon, Esquire Candis A. Tunilo, Esquire Office of Consumer Advocate 555 Walnut St., Forum Place, 5th Fl. Harrisburg, PA 17101-1923 egannon@paoca.org ctunilo(a),paoca.org

Chads Mincavage, Esquire Elizabeth P. Trinkle, Esquire McNees Wallace & Nurick LLC 100 Pine Street, PO Box i 166 Harrisburg, PA 17108-1166 cmincavage(a),mwn.com etrinkle(a), mwn.com

Regina L. Matz, Esquire Bureau of Investigation and Enforcement Commonwealth Keystone Building 400 North Street, 2nd Floor West Harrisburg, PA 17105-3265 rmatz(a),pa.gov

Steven C. Gray, Esquire Daniel G. Asmus, Esquire Office of Small Business Advocate 300 North Second St, Suite 1102 Harrisburg, PA 17101 dasmusfg).pa.gov sgrav(a),pa.gov

Michael W. Hassell, Esquire Jessica R. Rogers, Esquire Post & Schell, P.C. 17 North Second St., 12lh Fl. Harrisburg, PA 17101-1601 mhassell@postschell.com irogers@postscheil.com

James L. Crist The Lumen Group 4226 Yarmouth Dr., Suite 101 Allison Park, PA I'SlOl JLCi'ist@aol.com

Theodore J. Gallagher, Esquire Kimberly S. Cuccia, Esquire NiSource Corporate Services Company Energy Distribution Group Legal 121 Champion Way, Suite 100 Canonsburg, PA 15317 tjgallagher@nisource.com kscuccia@nisource.com

Patrick Cicero, Esquire Harry S. Geller, Esquire PA Utility Law Project 118 Locust Street Harrisburg, PA 17101 pulp@palegalaid.net

Joseph L. Vullo, Esquire Burke Vullo Reilly Roberts 1460 Wyoming Avenue Forty Fort, PA 18704 jlvullo@aol.com

Robert D. Knecht 4?

i? Industrial Economics Incorporatejv 2067 Massachusetts Ave. Cambridge, MA 02140 rdk@indecon.com

Certificate of Service Docket No. P-2012-2338282 Page Two

Thomas S. Catlin Exeter Associates, Inc. 10480 Little Patuxent Parkway Suite 300 Columbia, MD 21044 tcatlin@exeterassociatcs.com

Dated this 26th day of March 2014

Todd S. Stewart, Esquire Steven K. Haas, Esquire Hawke McKeon & Sniscak LLP 100 North Tenth Street P.O. Box 1778 Harrisburg, PA 17105-1778 tsstewart@hmslegal.com skhaas@,hmslegal.com

Thomas J. Sniscak