Public Service Company of Colorado's Response to Tiger Natural Gas Complaint

Susan L. Bailey, the Natural Gas Services Manager at Xcel Energy Services Inc., a wholly-owned subsidiary of Xcel Energy, submitted her Answer Testimony and Attachments to the Public Utilities Commission of the State of Colorado as part of the proceeding number 21F-0290G. In her testimony, Bailey responds to the Direct Testimonies of Anthony L. Cianflone, Matthew Lee, and Steve Manz, filed on behalf of Tiger Natural Gas, Inc. (Tiger).

Bailey provides an overview of Public Service's gas transportation system and services, emphasizing the importance of Primary Receipt Points in enabling the company to safely and reliably manage its natural gas system for all customers. She also addresses Tiger's concerns regarding receipt point requirements, the accuracy of Quorum data, and the company's credit security requirements.

Key Takeaways:

• Public Service Company of Colorado's (PSCo) gas transportation system and services are crucial for managing the natural gas system and ensuring safe and reliable delivery to all customers.
• Tiger Natural Gas, Inc.'s (Tiger) complaints about the established tariff balancing provisions and the Quorum System are based on incorrect assumptions and a lack of understanding of the system operations.
• The company's credit security requirements are reasonable and consistent with industry standards, and Tiger has failed to identify any harm that requires reparations or damages.
• Bailey's testimony highlights the importance of Primary Receipt Points in managing the natural gas system and emphasizes that the company's requirements for selecting in-path Primary Receipt Points are reasonable and non-discriminatory.
• Public Service's gas transportation system and services have been significantly updated in the 2019 Gas Phase II, with Tiger's full participation, and the updated tariff provisions and outcomes are controlling with respect to Tiger's claims in this proceeding.
• The company has been clear about the Quorum System's functions and has been transparent about the use of estimated data due to customer information being unavailable.
• Tiger has demonstrated the ability to balance its loads, comply with selecting in-path Primary Receipt Points, and attend to phone lines, consistent with the company's Commission-approved Gas Tariff.
• Public Service's witnesses, including Mark Breese, Robert Heacox, and Mark Almer, will provide additional testimony and respond to Tiger's Direct Testimony.

Statistics:

• 4 overarching points summarized by Bailey as she reviewed Tiger's claims:

+ 1: Multiple operational matters with which Tiger takes issue are based on established Colorado PUC No. 6 - Gas tariff provisions.

+ 2: Tiger's complaints about the established tariff balancing provisions and the Quorum System appear intended to reduce Tiger's responsibility for its own customer communications, communication line issues, and nomination obligations.

+ 3: Tiger's objection to Public Service's request to identify in-path Primary Receipt Points fails to take into account Public Service's obligation to ensure adequate system capacity and to manage costs for all customers.

+ 4: Tiger does not identify reasons why Public Service's credit security requirements are unreasonable, inconsistent with industry standards, or inconsistent with the Company's Gas Tariff.

• 10 attachments sponsored by Bailey as part of her Answer Testimony.

Sources:

• Hearing Exhibit 200, Answer Testimony of Susan L. Bailey Proceeding No. 21F-0290G
• Table SLB-A-1: Introduction of Company Witnesses
• Public Utilities Commission of the State of Colorado