HomeMy WebLinkAboutR-2008-03 Tabled/suspend effective date of CenterPoint’s rate increase for 90 days
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REQUEST FOR CITY COUNCIL AGENDA ITEM
Agenda Date Requested: March 24, 2008
Budl?:et
Requested By: Ron Bottoms
Source of Funds:
Department:
Administration
Account Number:
Report:
Resolution: "/.
Ordinance:
Amount Budgeted:
Exhibits:
Ordinance
Amount Requested:
Exhibits:
Model Staff Report
Budgeted Item: YES
NO
Exhibits
SUMMARY & RECOMMENDATION
Attached is a report and a resolution dealing with CenterPoint Energy's recent rate filing that was put together by
attorneys with Lloyd Gosselink. The report addresses some general background information and the resolution
actually suspends the effective date of Center Point's action by 90 days allowing us time to thoroughly analyze the
rate increase. Suspending the effective date does not obligate us to intervene in the rate filing.
:1/'7/00
Date
RESOLUTION NO.
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RESOLUTION OF THE CITY OF LA PORTE
SUSPENDING THE APRIL 10,2008, EFFECTIVE DATE OF
CENTERPOINT ENERGY RESOURCES CORP., D/B/A
CENTERPOINT ENERGY ENTEX AND CENTERPOINT
ENERGY TEXAS GAS (CENTERPOINT) REQUESTED
RATE CHANGE TO PERMIT THE CITY TIME TO STUDY
THE REQUEST AND TO EST ABLISH REASONABLE
RATES; APPROVING COOPERATION WITH THE GULF
COAST COALITION OF CITIES AND OTHER CITIES IN
THE CENTERPOINT AREA TO HIRE LEGAL AND
CONSULTING SERVICES AND TO NEGOTIATE WITH
THE COMP ANY AND DIRECT ANY NECESSARY
LITIGATION AND APPEALS; RATIFYING THE
SELECTION OF LLOYD GOSSELINK AS LEGAL
COUNSEL; REQUIRING REIMBURSEMENT OF CITIES'
RATE CASE EXPENSES; FINDING THAT THE MEETING
AT WHICH THIS RESOLUTION IS PASSED IS OPEN TO
THE PUBLIC AS REQUIRED BY LAW; REQUIRING
NOTICE OF THIS RESOLUTION TO THE COMPANY
AND LEGAL COUNSEL
WHEREAS, on or about March 6, 2008, CenterPoint Energy Resources Corp., d/b/a
CenterPoint Energy Entex and CenterPoint Energy Texas Gas ("CenterPoint" or "Company"),
pursuant to Gas Utility Regulatory Act S 104.102 filed with the City of La Porte a Statement of
Intent to change gas rates in all municipalities exercising original jurisdiction within its Texas
Coast Division service area effective April 10, 2008; and
WHEREAS, it is reasonable for the City of La Porte to maintain its involvement in the
Gulf Coast Coalition of Cities ("GCCC") and to cooperate with the other similarly situated city
members in conducting a review of the Company's application and to hire and direct legal
counsel and consultants and to prepare a common response and to negotiate with the Company
and direct any necessary litigation; and
WHEREAS, the Gas Utility Regulatory Act S 104.107 grants local regulatory authorities
the right to suspend the effective date of proposed rate changes for ninety (90) days; and
WHEREAS, the Gas Utility Regulatory Act S 103.022 provides that reasonable costs
incurred by Cities in ratemaking activities are to be reimbursed by the regulated utility; and
WHEREAS, on or about March 6, 2008 simultaneous with the filing with the City,
CenterPoint filed a Statement of Intent to change gas rates for the Texas Coast environs with the
Railroad Commission of Texas referred to as Gas Utility Docket ("GUD") No. 9791.
1
THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LA
PORTE, TEXAS:
1. That the April 10, 2008, effective date of the rate request submitted by
CenterPoint on or about Mach 6, 2008, be suspended for the maximum period allowed by law to
permit adequate time to review the proposed changes and to establish reasonable rates.
2. That the City is authorized to cooperate with GCCC and its member cities in the
Texas Coast Division service area to hire and direct legal counsel and consultants, negotiate with
the Company, make recommendations to the City regarding reasonable rates and to direct any
necessary administrative proceedings or court litigation associated with an appeal of a rate
ordinance and the rate case filed with the City or Railroad Commission.
3. That the selection of the law firm of Lloyd Gosselink to represent the GCCC and
its members in this matter is ratified.
4. That the City is authorized to intervene and patlclpate in GUD No. 9791,
Statement of Intent of Center Point Energy Resources Corp. D/B/A CenterPoint Energy Entex
and CenterPoint Energy Texas Gas to Increase Rates in the Unincorporated Areas of
CenterPoint's Texas Coast Division, in order to protect the interests of the City.
5. That the City's reasonable rate case expenses shall be reimbursed by CenterPoint.
6. That it is hereby officially found and determined that the meeting at which this
Resolution is passed is open to the public as required by law and the public notice of the time,
place, and purpose of said meeting was given as required.
7. A copy of this Resolution shall be sent to CenterPoint, care of Denise Hardcastle,
Director of Regulatory Activities and Compliance, CenterPoint Energy, P.O. Box 2628,
Houston, Texas 77252-2528 and to Thomas Brocato, at Lloyd Gosselink, P.C., 816 Congress,
Avenue, Suite 1900, Austin, Texas 78701.
Alton Porter
Mayor, City of La Porte
ATTEST:
CUy At:tolLnetj
2
MODEL STAFF REPORT
CenterPoint Energy Gas has filed an application with cities retaining original jurisdiction
over rates and services to increase rates within their Texas Coast Division by $7.36 million. The
Company's application was filed with the City on March 6, 2008.
Purpose of the Resolution:
The resolution suspends the effective date of the Company's rate increase for the
maximum period permitted by law to allow the City time to evaluate the filing, determine
whether the filing complies with law, and if lawful, to determine what further strategy, including
settlement, to pursue.
The law provides that a rate request made by a natural gas utility cannot become effective
until 35 days following the filing of the application to change rates. The law permits the City to
suspend the effective date for 90 days. If the City does not take action to suspend the filing,
CenterPoint may begin charging increased rates after April 10, 2008. According to
CenterPoint, annual rates would increase by approximately $42 for residential customers.
The City has participated in prior rate matters with a coalition of cities now known as
Gulf Coast Coalition of Cities (GCCC). GCCC is a coalition of thirteen cities who have passed
resolutions authorizing GCCC to intervene on behalf of the city in numerous utility matters
pending before regulatory agencies, the Courts or the Legislature. A list of the current members
impacted by this application is attached.
Explanation of "Be It Resolved" Paral!raphs:
Section 1. The city is authorized to suspend the effective date for 90 days for any
legitimate purpose. Time to study and investigate the application is always a legitimate purpose.
Please note that the resolution refers to the suspension period as "the maximum period allowed
by law" rather than ending by a specific date. This is because the Company controls the
effective date and can extend the deadline for final city action to increase the time that the City
retains jurisdiction if necessary to reach settlement on the case. If the suspension period is not
increased by the Company, the City must take final action on CenterPoint's request to raise rates
by April 10, 2008.
Section 2. Negotiating clout and efficiency are enhanced by the City cooperating with
other GCCC cities in a common review and common purpose. Additionally, rate case expenses
are minimized when GCCC hires one set of attorneys and experts who work under the guidance
and control of the GCCC. This provision authorizes the GCCC to act on behalf of the City at the
local level in settlement discussions, and in preparation of a rate ordinance and on appeal of the
rate ordinance to the Railroad Commission and on appeal to the Courts. Any settlement
negotiated by GCCC must be approved by all GCCC member city councils through new rate
ordinances.
Section 3. Lawyers with Lloyd Gosselink have extensive experience in representing
cities and coalitions of cities in ratemaking matters. Geoffrey Gay of Lloyd Gosselink has
represented GCCC in regulatory matters for the last decade. This section ratifies the Coalition's
continued reliance on Lloyd Gosselink for legal services.
Section 4. This provision authorizes the GCCC to intervene in GUD No. 9791 at the
Railroad Commission. Because the Company is seeking uniform rates within its Texas Coast
Division and because the Railroad Commission has original jurisdiction over the rates in the
environs, simultaneous with its filing with the cities on March 6, CenterPoint also filed its rate
application with the Railroad Commission for the environs. Once the city proceedings are
finalized, it is anticipated that they will be appealed to the Railroad Commission where they will
be consolidated into the current pending case.
Section 5. Cities, by statute, are entitled to recover their reasonable rate case expenses
from the utility. Legal counsel and consultants approved by the GCCC will submit monthly
invoices to the City of Friendswood that will be forwarded to CenterPoint for reimbursement.
No individual city incurs liability for payment of rate case expenses by adopting a suspension
resolution.
Section 6. This section merely recites that the resolution was passed at a meeting that
was open to the public and where the consideration ofthe Resolution was properly noticed.
Section 7. This section provides that both CenterPoint and counsel to GCCC will be
notified of the City's action by sending a copy of the approved and signed resolution to certain
designated individuals.
HOW ARE RATE CASE EXPENSES RECOVERED
FROM CUSTOMERS IN RATE PROCEEDINGS?
1. The Gas Utility Regulatory Act ("GURA") allows a utility to recover from customers both the
reasonable rate case expenses the utility directly incurs to put on its case, as well as any
reimbursement to the municipality for its costs. 1
2. The regulatory authority (either the municipality having original jurisdiction over the utility's rates
or the Railroad Commission of Texas on appeal) only has the authority to order the recovery of rate
case expenses from customers whose rates will change as a result of the case pending before the
regulatory authority.
WHAT DOES THIS MEAN?
In Texas, a city gets the exclusive right to determine whether a rate request is reasonable for customers in that
city. It is only if the utility appeals a city's decision on rate relief to the Railroad Commission that the
Commission gains the authority to set rates for those city's customers. In contrast, if a city approves the
requested rates or lets them go into effect, the Railroad Commission has no authority to change the rates for that
city. This also means that on appeal, the Railroad Commission cannot order a surcharge on rates for recovery
of rate case expenses associated with the appeal for city customers whose rates are not at issue on appeal.
WHY?
Because the Railroad Commission does not have authority to change the rates of customers in those cities that
are not participating in the appeal case.
WHAT IS THE CONSEQUENCE OF THIS?
The consequence is that the Railroad Commission can only order the recovery of rate case expenses from those
customers who live in the cities that deny the rate change and end up in an appeal before the Railroad
Commission.
WHY HAVE ALL CUSTOMERS OF ATMOS MID-TEX PAID FOR RATE CASE EXPENSE IN THE
PAST?
Because in past cases (GUD No. 9400 and GUD No. 9670) every city served by Atmos Mid-Tex participated in
the appeal at the Railroad Commission.
HAS THE RAILROAD COMMISSION REJECTED SURCHARGING RATE CASE EXPENSES ON A
CITY NOT PARTICIPATING IN AN APPEAL?
Yes. In GUD No. 9465, the utility filed for a rate change in four cities. The utility settled with the City of Port
Arthur, Texas, agreeing to give that city most favored nation treatment from any resulting appeal. The other
three cities denied the proposed rates and litigated an appeal at the Railroad Commission. Over those three
cities' objections, the Railroad Commission surcharged rate case expenses only on the three cities involved in
the appeal and not on the settling city. Although the Commission approved a revenue increase of only $518,950
for the three non-settling, rate case expenses for the utility and the three non-settling cities exceeded $1 million,
which worked out to about $70 per person in litigation costs.
IS THERE ANY GUARANTEE THAT THE RAILROAD COMMISSION WILL ALLOW THE CITY
TO RECOUP ITS RATE CASE EXPENSES?
No. A city's recovery of rate case expense is not guaranteed. The Railroad Commission has become tougher on
the recovery of rate case expenses by both cities and utilities.
I See Railroad Commission of Texas case GUD No. 9002-9135, citing GURA S 1 03.022 and S 104.051.
W:C:\Docurnents and Settings\00061286.CNP\Local Settings\Ternporary Internet Files\Content.Outlook\JZRNJG3W\CP Revised Rate Case Expense Handout.doc
. CenlerPoinL
Energy
March 20, 2008
Mayor and City Officials
City of La Porte
La Porte, Texas
RE: Pending Statement of Intent to Change Rates
Ladies and Gentlemen:
I am writing to confirm to you that if the City of La Porte approves the rates proposed by
CenterPoint Energy in its Statement of Intent to Increase Rates filed with the city on March 6,
2008, and if the Railroad Commission of Texas shall subsequently establish a lower level of
division-wide base rates with respect to this filing for customers in CenterPoint Energy's Texas
Coast Division, or if CenterPoint Energy shall otherwise agree to implement a lower level of
base rates with respect to this filing in another city or cities in the Texas Coast Division,
CenterPoint Energy shall file such lower level of base rates with the City of La Porte
immediately on the issuance of the final, non-appealable order of the Railroad Commission
establishing such lower base rates or the filing by CenterPoint Energy of tariffs in another Texas
Coast city implementing such lower base rates.
By approving the proposed rates, the City of La Porte and its citizens will avoid
potentially substantial litigation expenses associated with proceedings undertaken by other
municipalities or coalitions of municipalities or the Railroad Commission of Texas.
If you have any questions, please contact Doug Ward at 281-342-8881.
r ruly yours,
C3~'
Richard A. Zapalac
Regional Vice President-Texas
cc: George Hepburn
Keith Wall
Doug Ward
. CenterPoint.
Energy
March 12, 2008
Mayor and City Officials
City of La Porte
La Porte, Texas
RE: Pending Statement of Intent to Change Rates
Ladies and Gentlemen:
I am writing to confirm to you that if the City of La Porte approves the rates proposed by
CenterPoint Energy and if the Railroad Commission of Texas shall subsequently establish a
lower level of division-wide base rates for customers in CenterPoint Energy's Texas Coast
Division, CenterPoint Energy shall file such lower level of base rates with the City of La Porte
immediately on the issuance of the final, non-appealable order of the Railroad Commission
establishing such lower base rates.
By approving the proposed rates, the City of La Porte and its cItlzens will avoid
potentially substantial litigation expenses associated with proceedings undertaken by other
municipalities or coalitions of municipalities or the Railroad Commission of Texas.
If you have any questions, please contact Doug Ward at 281-342-8881.
(~ly yours,
~~<-~~~.-
Richard A. Zapalac
Regional Vice President-Texas
cc: George Hepburn
Keith Wall
Doug Ward