RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 1 of 80
QOGA - Gaz Métro-1
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 4 and 5
Definitions of: "Connection line"
"Receipt point"
"Interconnect point with Gaz Métro's system"
Preamble:
Gaz Métro has defined "Connection line" as "New gas system connecting
producer's facilities and linking a receipt point to an interconnect point".
Information Requests:
1.1
What is the distinction, if any in this definition, between "producer's
facilities" and a "Receipt point"?
1.2
Is the "new gas system" referred to in this definition limited to those
pipeline and related facilities (e.g. metering equipment) to be constructed
by Gaz Métro?
1.3
Is the "interconnect point" referred to in this definition the defined term
"Interconnect point with Gaz Métro's system"?
1.4
Is a "Connection line" simply the pipeline and related facilities to be
constructed by Gaz Métro which are located between a particular Receipt
point and the closest Interconnect point with Gaz Métro's system?
1.5
If the response to QOGA-Gaz Métro IR 1.4 is yes, will Gaz Métro revise
its definition of "Connection line" to conform with this understanding?
1.6
If the response to QOGA-Gaz Métro IR 1.4 is no, please provide further
clarification of the definition for "Connection line".
1.7
Does a "Connection line" always remain a "Connection line" or can it
become part of Gaz Métro's gas system at some time in the future?
1.8
If a "Connection line" can become part of Gaz Métro's gas system, please
provide a discussion of all situations where this may occur and the impact
on the calculation of the receipt rate for a Producer which was previously
utilizing a former "Connection line".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 2 of 80
QOGA - Gaz Métro-2
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 4
Definition of: "Consumer customer"
Preamble:
Gaz Métro has defined "Consumer customer" as "Customer for whom Gaz
Métro transports and distributes natural gas for consumption at his
facilities".
Information Requests:
2.1
Does "Consumer customer" include those Customers to whom Gaz Métro
sells natural gas for consumption in their facilities?
2.2
Does "Consumer customer" include those customers for whom Gaz Métro
transports natural gas which is consumed in their facilities but where Gaz
Métro does not sell gas to such customer i.e. a customer which has
arranged it own gas supply?
2.3
Will all of the Customers of Gaz Métro be either a "Consumer customer"
or a "Producer"?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 3 of 80
QOGA - Gaz Métro-3
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 4
Definition of: "Consumption zone"
Preamble:
Gaz Métro has defined "Consumption zone" as a "Geographical area
starting from the interconnect point with the TCPL/TQM system
delimiting the portion of Gaz Métro's system connected to that
interconnection".
Information Requests:
3.1
Please provide maps of each Consumption zone based on Gaz Métro's
current system configuration.
3.2
For each Consumption zone identified in Gaz Métro's response to QOGAGaz Métro IR 3.1, for each month in the periods 2008, 2009 and 2010 to
date please provide:
(a)
the total consumption volume during such month;
(b)
the average consumption volume during such month;
(c)
the maximum daily consumption volume for any day during such
month; and
(d)
the minimum daily consumption volume for any day during such
month.
3.3
Could the area of a particular Consumption zone change over time and if
so, how will Gaz Métro advise the Producers of the changes in the areas of
the Consumption zones?
3.4
If the area of a Consumption zone changed over time, please describe how
the calculation of the receipt rate for a Producer delivering gas to a
Receipt point located within such changed Consumption zone would be
effected and please provide an example.
3.5
Are there any portions of Gaz Métro's system that have more than one
Interconnect point with the TCPL/TQM system and if so, how will the
Consumption zones be established for that portion of Gaz Métro's system?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 4 of 80
QOGA - Gaz Métro-4
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 4
Definition of: "Delivery point"
(ii)
Page 18 – lines 12-14
Section 3 Receipt Rate for Natural Gas Produced in Quebec
Preamble:
In Reference (i) Gaz Métro has defined "Delivery point" as the "Physical
or geographical location where natural gas is delivered inside or outside
the territory on Gaz Métro's system". In Reference (ii) Gaz Métro has
indicated that a Producer will have a choice of two delivery points i.e.
inside or outside of the territory.
Information Requests:
4.1
In Reference (i) what is the distinction, if any in this definition, between a
"physical" location and a "geographical" location?
4.2
For a receipt rate service contract are there only two broad "Delivery
points" (as indicated in Reference (ii)), one, any point on the Gaz Métro
system where gas will be delivered for consumption within the Gaz Métro
territory and two, any interconnect point with the TCPL/TQM's system or
will it be required that specific geographical locations for the Delivery
point be identified?
4.3
What is the procedure to change a specified Delivery point in a receipt
rate service contract i.e. can a Producer, at its sole discretion, elect to
change the "Delivery point" set out in a receipt rate service contract at any
time?
4.4
Does the definition of "Delivery point" have a different meaning in the
context of day-to-day gas control matters?
4.5
Will a Producer have to nominate a particular geographical location at
which it wants its gas delivered by Gaz Métro on each particular day?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 5 of 80
QOGA - Gaz Métro-5
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 4
Definition of: "Gaz Métro transportation"
Preamble:
Gaz Métro has defined "Gaz Métro transportation" as "Transportation
function of Gaz Métro's distribution service". A local distribution
company's physical system typically consists of transmission facilities
(higher pressure facilities) and distribution facilities (lower pressure
facilities).
Information Requests:
5.1
Please confirm that the definition of "Gaz Métro transportation" refers to
service which is provided by Gaz Métro to a Customer utilizing the
transmission facilities portion of its system.
5.2
If Gaz Métro cannot provide the confirmation requested in QOGA-Gaz
Métro IR 5.1, please provide further clarification of the definition of "Gaz
Métro transportation".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 6 of 80
QOGA - Gaz Métro-6
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "Injection"
Preamble:
Gaz Métro has defined "Injection" as "Function whereby a producer
makes natural gas available in the gas system".
Information Requests:
6.1
Is "Injection" simply the "function whereby a Producer delivers natural
gas to Gaz Métro at a receipt point"?
6.2
If the response to QOGA-Gaz Metro IR 6.1 is yes, will Gaz Métro revise
its definition of "Injection" to conform with this understanding?
6.3
If the response to QOGA-Gaz Métro IR 6.1 is no, please provide further
clarification of the definition for "Injection" and specifically indicate what
is meant by the phrase "makes natural gas available in the gas system".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 7 of 80
QOGA - Gaz Métro-7
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 5
(ii)
Preamble:
Definitions of:
"Injection point"
"Receipt point"
Page 43
Section 3.5.4 Composition of Natural Gas and Calorific Content
Gaz Métro has defined "Injection point" and "Receipt point" and the
QOGA is unclear as to the differences between the two especially in light
of the requirement in Reference (ii) that all natural gas to be delivered by
a Producer to Gaz Métro must meet NEB quality specifications i.e. be of
sales gas quality.
Information Requests:
7.1
7.2
7.3
Why can't an Injection point be located upstream of a Receipt point e.g. an
upstream processing facility where a Producer first processes raw gas to
meet sales gas specification?
If the location of an Injection point can only be at the Receipt point or
between a Receipt point and the interconnect point with Gaz Métro
system, please explain how this is this consistent with Gaz Métro's
requirement that all gas to be delivered by a Producer at a Receipt point
must comply with sales gas quality specifications (see Reference (ii))?
Please provide an explanation as to why there is a need for the category of
"Injection points" in addition to "Receipt points".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 8 of 80
QOGA - Gaz Métro-8
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "interconnect point with Gaz Métro's system"
Preamble:
Gaz Métro has defined "interconnect point with Gaz Métro's system" as
"Physical location where the new connection lines join Gaz Métro's
existing gas system".
Information Requests:
8.1
Will each "Connection line" have a single "interconnect point with Gaz
Métro's system" or could there be multiple "interconnect points with Gaz
Métro's system" for any particular Connection line?
8.2
If a Consumer customer is being served off of a Connection line does that
pipeline then lose its categorization as a "Connection line" and if not,
please explain why not?
8.3
Will a Producer be able to supply its natural gas to a Consumer customer
which is served by Gaz Métro off of a Connection line?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 9 of 80
QOGA - Gaz Métro-9
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "interconnect point with TCPL/TQM's system "
Preamble:
Gaz Métro has defined "interconnect point with TCPL/TQM's system" as
"Physical location where Gaz Métro's gas system joins TCPL/TQM
transmission system".
Information Requests:
9.1
Please provide a map of Gaz Metro's current gas system identifying each
interconnect point with TCPL/TQM's system.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 10 of 80
QOGA - Gaz Métro-10
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "Nomination"
Preamble:
Gaz Métro has defined "Nomination" as "Request for a quantity of natural
gas in connection with a supply or transportation service agreement".
Information Requests:
10.1
Please provide a full description of the nomination process for a receipt
rate service contract including the timing of nominations, all of the
information to be contained in a nomination, the process for Gaz Métro
confirming a nomination, the requirements for and the ability of a
Producer to change a nomination during the gas flow day.
10.2
Will the details of the nomination process be set out in Gaz Métro's
Conditions of Natural Gas Service and Tariff and if not, please explain
why not?
10.3
Will a Producer be able to use an agent to handle its day to day gas control
operational matters and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 11 of 80
QOGA - Gaz Métro-11
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "Producer"
Preamble:
Gaz Métro has defined "Producer" as "Customer who injects natural gas
into the gas system for transportation and distribution".
Information Requests:
11.1
Please confirm that the main purpose of this definition is to make a
distinction between a "Consumer customer" and a Customer which is
requesting that Gaz Métro provide service under the new receipt rate.
11.2
Even though the term "Producer" is used, please confirm that a "Producer"
is simply the party which is delivering the natural gas to Gaz Métro at a
receipt point.
11.3
If Gaz Métro can provide the confirmation requested in Gaz Métro
IR 11.2, will Gaz Métro revise its definition of "Producer" to conform
with this understanding?
11.4
Please confirm that a "Producer" does not have to be the party which
physically produced the natural gas which is being delivered by it to Gaz
Métro.
11.5
Please confirm that a "Producer" could be any party (e.g. a marketing
company) which has purchased the natural gas at any location at or
upstream of the receipt point.
11.6
Why is there a requirement in Gaz Métro's definition that the natural gas is
injected into the gas system for transportation and distribution given that
gas could be delivered at a Receipt point for delivery outside the territory
of Gaz Métro and as such, the gas would not be "distributed" by Gaz
Métro?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 12 of 80
QOGA - Gaz Métro-12
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 5
Definition of: "Receipt point"
Preamble:
Gaz Métro has defined "Receipt point" as "Physical location where the
producer's facilities join Gaz Métro's new connection lines to move the
natural gas to the existing gas system".
Information Requests:
12.1
Please confirm that a "receipt point" is simply the location on Gaz Métro's
facilities where a Producer first delivers natural gas to Gaz Métro.
12.2
If Gaz Métro can provide the confirmation requested in QOGA-Gaz
Métro IR 12.1, will Gaz Métro revise its definition of "Receipt point" to
conform with this understanding?
12.3
Please confirm that a "producer's facilities" do not have to be facilities
which are owned by the party which is delivering the natural gas to Gaz
Métro at the receipt point.
12.4
Gaz Métro is not required to build a Connection line where the Producer's
facilities connect with the existing Gaz Métro gas system. In this
situation:
(a)
would the interconnect point with the Gaz Métro system become
the "Receipt point"; and
(b)
would the Producer's receipt rate at that receipt point be established
on the basis that it would not include any amount relating to a
Category A cost and if not, please explain why not?
12.5
What is the process which will be followed between Gaz Métro and a
Producer to determine the particular physical location which will become
the Receipt point under that Producer's receipt rate service contract?
12.6
If Gaz Métro and a Producer cannot reach agreement on the particular
physical location for a Receipt point, will Gaz Métro agree to have the
Régie resolve the matter and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 13 of 80
QOGA - Gaz Métro-13
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 6
Definition of: "TCPL/TQM transportation"
Preamble:
Gaz Métro has defined "TCPL/TQM transportation" as "Transportation of
natural gas inside or outside Gaz Métro's territory between different
consumption zones via the TCPL/TQM transmission system".
Information Requests:
13.1
Please provide a full description of the term "territory".
13.2
Does the response to be provided in QOGA-Gaz Métro IR 13.1 apply to
each case where the term "territory" is used in the document B-6-Gaz
Métro-1, Document 2 (English Translation)?
13.3
If Gaz Metro's response to QOGA-Gaz Métro IR 13.2 is no, please
identify each situation in B-6-Gaz Métro-1, Document 2 (English
Translation) where the word "territory" would have a different meaning
and set out the different meaning which would apply in each case.
13.4
Please confirm that if a Producer has requested its gas to be delivered to a
"Delivery point" which is an interconnect point with TCPL/TQM's
system, then the Producer will be the party which will make any necessary
arrangements with TCPL/TQM to transport its gas downstream of such
location.
13.5
Does Gaz Métro's proposed definition for "TCPL/TQM transportation"
which refers to "between different consumption zones" cover the situation
referred to in QOGA-Gaz Métro IR 13.4 and if not, will Gaz Métro also
revise the definition of "TCPL/TQM transportation" to address this
situation?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 14 of 80
QOGA - Gaz Métro-14
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 6
Definition of: "Volumes delivered in territory"
Preamble:
Gaz Métro has defined "Volumes delivered in territory" as "Delivery of
natural gas to Gaz Métro's system".
Information Requests:
14.1
Please confirm that "Volumes delivered in territory" are simply those
volumes of a Producer's gas which were delivered to a Delivery point
which is on Gaz Métro's existing system within the area of its natural gas
distribution franchise which is not an interconnect point with the
TCPL/TQM system.
14.2
If Gaz Métro cannot provide the confirmation requested in QOGA-Gaz
Métro IR 14.1, please provide further clarification of the definition of
"Volumes delivered in territory".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 15 of 80
QOGA - Gaz Métro-15
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 6
Definition of: "Volumes delivered outside territory"
Preamble:
Gaz Métro has defined "Volumes delivered outside territory" as "Delivery
of natural gas to an interconnect point with the TCPL/TQM system".
Information Request:
15.1
Please confirm that this definition only covers those volumes of a
Producer's gas which were delivered for that Producer to an "Interconnect
point with the TCPL/TQM system" and not any volumes which Gaz
Métro delivers to an "Interconnect point with the TCPL/TQM system" for
transportation by Gaz Métro between different Consumption zones.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 16 of 80
QOGA - Gaz Métro-16
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 8 and 9
Section 1 Context and Opportunity of Request
Preamble:
Gaz Métro has identified several benefits related to the production of gas
in Quebec including diversification of supply sources for consumers
(page 9, lines 9-15), a positive impact on the total gas costs for all users of
gas in Quebec (page 8, lines 7-8), substitution of more polluting products
by gas (page 8, line 12), achieve objectives of Quebec's energy strategy
2006-2015 (page 8, lines 14-20) an opportunity to link portions of Gaz
Métro's system (page 9, line 9) allowing Gas Metro to access new
markets, in particular in the farming sector, and enhanced supply certainty
for Gaz Métro's customers (page 9, lines 10-15).
Information Request:
16.1
Were any of these potential benefits factored into Gaz Métro's design of
the receipt rate and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 17 of 80
QOGA - Gaz Métro-17
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 9 - lines 7 to 15
Section 1 Context and Opportunity of Request
Preamble:
Gaz Métro has indicated that the construction of pipelines to connect
producer's facilities to Gaz Métro gas system might also make it possible
to link portions of Gaz Métro's system.
Information Requests:
17.1
Please explain how a "Connection line" could link portions of Gaz Métro's
system.
17.2
If a pipeline linked portions of Gaz Métro's system, why would that
pipeline not be classified as part of Gaz Métro's system rather than a
"Connection line"?
17.3
If, in the future, a "Connection line" linked portions of Gaz Métro's
system, please describe how the receipt rate for a Producer delivering gas
to that "Connection line" would be reduced and please provide an
example.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 18 of 80
QOGA - Gaz Métro-18
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 9 - lines 22 to 23
Section 1 Context and Opportunity of Request
Preamble:
Gaz Métro has indicated that it has the expertise in building and managing
gas systems and the present regulatory framework provides an attractive
guarantee for the process of injecting natural gas into Gaz Métro's system.
Information Request:
18.1
Please explain what Gaz Métro means by the phrase "an attractive
guarantee for the process".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 19 of 80
QOGA - Gaz Métro-19
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 5
Definition of: "Producer"
(ii)
Page 10 - lines 11-12
Section 2 Connection Model and Underlying Costs
(iii)
Page 18 - line 8
Section 3 Receipt Rate for Natural Gas Produced in Quebec
(iv)
Page 24 – line 14
Section 3.3.2.1 Application
Preamble:
Reference (ii) may place a further qualification to the definition of a
"Producer" as set out in Reference (i). Reference (iii) also indicates that
the receipt rate would apply to any person who wants to inject natural gas
"produced within the territory served by Gaz Métro". Reference (iv)
indicates that the receipt rate would apply to any customer which wishes
to inject gas "produced in the territory served by the distributor".
Information Requests:
19.1
Does a Producer have to inject natural gas which is "produced in the
territory serviced by Gaz Métro" in order to be eligible for the receipt
rate?
19.2
If Gaz Métro's response to QOGA-Gaz Métro IR 19.1 is yes, then:
(a)
please explain why a Producer should not also be able to inject
natural gas which was produced from outside of the territory served
by Gaz Métro; and be eligible for the receipt rate; and
(b)
what is the procedure which would apply to allow a Producer to be
able to inject natural gas produced from outside the territory served
by Gaz Métro into Gaz Métro's system?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 20 of 80
QOGA - Gaz Métro-20
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 12 – lines 1-2
Section 2.1 Model for Connection of Production to Gas System and
Movement of Natural Gas
Preamble:
Gaz Métro has indicated that each investment request for the connection
of a natural gas producer in Gaz Métro's territory could be slightly
different from this model.
Information Requests:
20.1
Please identify possible situations where an investment request would be
treated differently from Gaz Métro's proposed model.
20.2
If a particular investment request was to be treated differently from Gaz
Métro's proposed model, does Gaz Métro propose to apply to the Régie
for specific approval of the changes to its model which would apply to
that particular situation and if not, please explain why not?
20.3
If Gaz Métro's response to QOGA-Gaz Métro IR 20.2 is yes, will the
approval of the Régie be sought at the investment application stage or in
some other Régie proceeding?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 21 of 80
QOGA - Gaz Métro-21
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 12 – line 9
Section 2.1 Model for Connection of Production to Gas System and
Movement of Natural Gas
Preamble:
Gaz Métro has described "Connection pipelines" as new "distribution
pipelines".
Information Request:
21.1
Given that most Connection lines are likely to operate at a high pressure,
please explain Gaz Métro's categorization of a "Connection pipeline" as
being a "distribution pipeline" rather than a "transmission pipeline".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 22 of 80
QOGA - Gaz Métro-22
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 13 – Lines 11-12
Section 2.1 Model for Connection of Production to Gas System and
Movement of Natural Gas
Preamble:
Gaz Métro has indicated that the Delivery point is located within the
territory when the natural gas is delivered to all of Gaz Métro's customers.
Information Request:
22.1
If a Producer wanted to have its gas delivered to a particular Consumer
customer, please explain why that situation would not also constitute a
Delivery point within the territory?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 23 of 80
QOGA - Gaz Métro-23
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 13 – lines 14-15
Section 2.1 Model for Connection of Production to Gas System and
Movement of Natural Gas
Preamble:
Gaz Métro has indicated that if the Delivery point is within the territory,
producers will have access to the natural gas consumption market in the
consumption zone.
Information Requests:
23.1
Please confirm that a Producer which has selected a Delivery point within
the territory will have access to the gas consumption market in all
Consumption zones but may be subject to an additional charge depending
on the level of consumption within the particular Consumption zone in
which that Producer's receipt point is located.
23.2
If Gaz Métro cannot provide the confirmation requested in QOGA-Gaz
Métro IR 23.1, please explain why a Producer's access would be limited to
the natural gas market within a particular Consumption zone?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 24 of 80
QOGA - Gaz Métro-24
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 13 – line 22
Section 2.1 Model for Connection of Production to Gas System and
Movement of Natural Gas
Preamble:
Gaz Métro has indicated that the surplus gas will have to be moved via the
TCPL/TQM transportation system to another consumption zone.
Information Request:
24.1
Please confirm that "surplus gas" is the quantity of gas delivered by all
Producers to receipt points located within a Consumption zone minus the
quantities of such gas which were delivered to an Interconnect point with
TCPL/TQM for delivery outside the territory and minus the quantities of
gas which were consumed by all Consumer customers within such
Consumption zone.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 25 of 80
QOGA - Gaz Métro-25
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 14 – lines 12 – 13
Section 2.2.1 Category A costs – Distribution costs related to investments
in connection pipelines
Preamble:
Gaz Métro has indicated that the costs of the new Connection lines will
have to be recovered from the Producer through the receipt rate.
Information Requests:
25.1
Given that a Producer will be ultimately responsible for the costs of a
Connection line, will Gaz Métro consult with the Producer and provide
the Producer with an opportunity to provide input into the design,
construction and anticipated cost of a Connection line before that
Producer has to enter into any backstop agreement in respect of such
Connection line and if not, please explain why not?
25.2
If the response to QOGA-Gaz Métro IR 25.1 is that Gaz Métro will
consult and seek the Producer's input, please describe the process which
Gaz Métro will follow with the Producer to obtain such input.
25.3
In very general terms, please describe the basic design basis parameters
for any Connection line including reference to any applicable CSA
standards.
25.4
In selecting the design for any particular Connection line, how are the
future requirements of that Producer, other potential Producers and
Consumer customers to be factored into the final design?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 26 of 80
QOGA - Gaz Métro-26
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 14 – line 12
Section 2.2.1 Category A costs – Distribution costs related to investments
in connection pipelines
Preamble:
Gaz Métro has indicated that the receipt point will be connected to the
interconnect point with Gaz Métro's system using "new distribution
pipelines" constructed by Gaz Métro and the costs of those new pipelines
will have to be recovered through the receipt rate.
Information Request:
26.1
Please confirm that in this context the phrase "new distribution pipelines"
refers to "Connection lines".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 27 of 80
QOGA - Gaz Métro-27
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 14 – lines 13-15
Section 2.2.1 Category A costs – Distribution costs related to investments
in Connection lines
Preamble:
Gaz Métro has indicated that if new investments on the existing
distribution system (i.e. downstream from the interconnect point) are
required solely for producer's needs, the costs related to those investments
would also be paid by the producers.
Information Requests:
27.1
If the need for new investment on the existing distribution system is
required by the requirements of a Producer and the requirements of Gaz
Métro's Consumer customers, will the total investment costs be allocated
between the Producer and the Consumer customers?
27.2
If the answer to QOGA-Gaz Métro IR 27.1 is yes, please describe how
those investment costs will be allocated between the Producer and Gaz
Métro's Consumer customers and please provide an example.
27.3
If the answer to QOGA- Gaz Métro IR 27.1 is yes, please describe
whether the Producer's share of these new investment costs on the existing
distribution system will form part of the Producer's Category A costs or
some other category of costs.
27.4
If, at the time that a Producer entered into a receipt rate service contract,
the system investment was solely required by the requirements of that
Producer but subsequently those system facilities were also utilized to
meet the requirements of a Consumer customer, how would the Producer's
receipt rate be reduced and please provide an example?
27.5
If the need for new investments on the existing distribution system is
required by the requirements of more than one Producer, will those total
investment costs be allocated among those Producers?
27.6
If the answer to QOGA- Gaz Métro IR 27.5 is yes, please describe how
those investment costs will be allocated among the Producers and please
provide an example.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 28 of 80
QOGA - Gaz Métro-27
27.7
If, at the time that a Producer entered into a receipt rate service contract,
the system investment was solely required by the requirements of that
Producer but subsequently those system facilities were also utilized to
meet the requirements of another Producer, how would the first Producer's
receipt rate be reduced and please provide an example?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 29 of 80
QOGA - Gaz Métro-28
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 15 – lines 3-18
Section 2.2.1 Category A costs – Distribution costs related to investments
in connection pipelines
Backstop guarantees
Preamble:
Gaz Métro has indicated that it requires necessary protection to ensure that
the costs it incurred during the construction period are paid back by a
Producer if that Producer abandons its production site. Gaz Métro
therefore intends to sign backstop agreements with each Producer. Gaz
Métro is proposing that each Backstop agreement would be secured by a
bank letter of credit.
Information Requests:
28.1
28.2
28.3
28.4
28.5
28.6
28.7
28.8
Please explain why a backstop agreement would be required in all
situations as opposed to only in those cases where a substantial
construction cost is involved?
Please confirm that a backstop agreement will only required during the
period prior to the execution of a receipt rate service contract rather than
for the period "before the rate contract takes effect".
Does Gaz Métro have a standard form of backstop agreement and if so,
please provide a copy of such standard backstop agreement.
If Gaz Métro does not yet have a standard form of backstop agreement,
please indicate each of the categories of terms of a backstop agreement
that are open to negotiation between Gaz Métro and a Producer.
If a Producer and Gaz Métro cannot reach agreement on all terms of a
backstop agreement, will Gaz Métro agree to have the Régie resolve the
matter and if not, please explain why not?
Why should a Producer which has a favourable credit rating be required to
provide a bank letter of credit?
In determining whether or not a Producer is creditworthy, please explain
why standard industry credit ratings as provided by Standard & Poors or
Moodys could not be relied upon by Gaz Métro?
Is Gaz Métro proposing that a backstop agreement can only be secured by
a bank letter of credit?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 30 of 80
QOGA - Gaz Métro-28
28.9
Why would other financial instruments (e.g. parental company guarantee,
letter of payment guarantee, pledge of assets as collateral) not also be
sufficient?
28.10
If Gaz Métro is insisting on a bank letter of credit, please explain why a
letter of credit is specifically required and under what tariff provision it is
being requested.
28.11
Please confirm that the amount of the bank letter of credit will increase
during the construction period so that by the end of construction the bank
letter of credit would have to cover the entire capital cost of the
investment.
28.12
Will the bank letter of credit requirement cease once the receipt rate
service contract is executed by Gaz Métro and the Producer, and if not,
please explain why not, especially in light of Gaz Métro's ability to
request a deposit as proposed in Section 8.1.3 of the Conditions of Natural
Gas Service and Tariff?
28.13
If the response to QOGA-Gaz Métro IR 28.12 is no, then:
(a)
for what continuing amount is a bank letter of credit required;
and
(b)
at what point does the requirement to provide a bank letter of
credit cease?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 31 of 80
QOGA - Gaz Métro-29
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 15-16
Section 2.2.2 Category "B" costs – Costs of existing distribution system
Preamble:
Gaz Métro has proposed that certain of the costs of its existing system be
allocated to a Producer although throughout the referenced section the
terms "distribution system", "gas system", "transmission system",
"distribution function", "transmission pipelines", "transportation function
of the distribution system" do not appear to be used consistently.
Information Requests:
29.1
Please confirm that all costs related to the facilities and services provided
by the distribution system portion of Gaz Métro's system (i.e. low pressure
pipelines) are to be borne solely by the Consumer customers.
29.2
Please confirm that no costs related to the facilities and services provided
by the transmission system portion of Gaz Métro's system (i.e. high
pressure pipelines) are to be borne by a Producer which has selected a
Delivery point which is within the territory of Gaz Métro.
29.3
Please confirm that all costs related to the facilities and services provided
by the transmission system portion of Gaz Métro's system (i.e. high
pressure pipelines) are to be allocated between the Consumer customers
and those Producers which have selected a Delivery point which is outside
the territory of Gaz Métro, subject to the exceptions described below in
QOGA-Gaz Métro IR 29.4.
29.4
If a Connection line is constructed directly between a Receipt point and
the TCPL/TQM transmission system whereby no portion of the existing
Gaz Métro system is being utilized, please confirm that no costs of Gaz
Métro's existing system, either the distribution system portion or the
transmission system portion, will be allocated to a Producer at such a
Receipt point.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 32 of 80
QOGA - Gaz Métro-30
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 22 and 23
Section 3.2.1 Unit price by volume within the territory
Preamble:
Gaz Métro has discussed its proposal for establishing the unit price by
volume delivered within the territory.
Information Requests:
30.1
Please confirm that in establishing the delivery charges for volumes
delivered within the territory:
(a)
(b)
(c)
(d)
the costs to be charged will be the Category D category of costs;
the only Category D costs to be allocated are those costs, if any,
which are paid by Gaz Métro to TCPL/TQM to move gas from
one Consumption zone to another Consumption zone as a result of
the consumption by the Consumer customers within the original
Consumption zone being less than the quantity of gas being
injected at all receipt points located in the original Consumption
zone minus any gas being injected at such receipt points which are
to be delivered outside the territory;
the Category D costs to be allocated to any particular
Consumption zone will be allocated to each Producer that is
delivering gas to Gaz Métro at a receipt point located in that
Consumption zone other than a Producer which is delivering all of
its gas outside the territory; and
the Category D costs to be allocated to any particular Consumption
zone will be allocated on a variable or commodity charge basis to
each Producer that is delivering gas to Gaz Métro at a receipt point
located in that Consumption zone based on the quantities of gas
delivered for each such Producer for delivery inside the territory.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 33 of 80
QOGA - Gaz Métro-30
30.2
Will the "unit price by volume delivered within the territory" be
established in advance or will it only be established after the fact once the
actual Category D costs and Producer volumes are determined for a
Billing Month and please explain when Gaz Métro will make changes in
this unit price and how such changes will be communicated to the
Producers?
30.3
Does Gaz Métro agree that the "unit price for volume delivered within the
territory" would likely be different for each Consumption zone and would
vary from month to month and if not, please explain why not?
30.4
What process would Gaz Métro propose in order that the Producers which
are bearing Category D costs can be advised of Gaz Métro's particular
TCPL/TQM requirements and the arrangements to be entered into by Gaz
Métro giving rise to such Category D costs?
30.5
Will the Régie have any oversight over the prudency of any arrangements
entered into by Gaz Métro with TCPL/TQM respecting the TCPL/TQM
capacity to be contracted for by Gaz Métro to transport gas between
Consumption zones and if not, please explain why not?
30.6
If Gaz Métro is proposing to contract for TCPL/TQM capacity to transport
gas between Consumption zones based on supply and demand forecasts,
what tools will Gaz Métro utilize in order to minimize the risk associated
with contracting TCPL/TQM capacity based on forecasts and thus
minimize any unutilized demand charges on TCPL/TQM and minimize
the Category D costs?
30.7
Prior to entering into any arrangement with TCPL/TQM to transport gas
between Consumption zones, would Gaz Métro first canvas the Producers
to determine whether any Producer may have TCPL/TQM capacity which
it could assign to Gaz Métro on either a temporary or permanent basis and
if not, please explain why not?
30.8
Has Gaz Métro identified any changes which may be required on its gas
system to allow for the transportation of gas between Consumption zones
e.g. change in piping or valves to allow a reverse flow, and if not, when
does it expect that the nature of and any necessary changes and the costs
associated therewith would be determined?
30.9
How would the costs of any changes to Gaz Métro's system to
accommodate the transportation between Consumption zones be allocated
among the various Consumption zones?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 34 of 80
QOGA - Gaz Métro-30
30.10
Would the costs of any changes to Gaz Métro's system to accommodate
the transportation between Consumption zones which are allocated to any
particular Consumption zone be allocated as a Category D cost in
accordance with the procedure described in QOGA-Gaz Métro IR 30.1(c)
and IR 30.1(d) and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 35 of 80
QOGA - Gaz Métro-31
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Pages 23-24
Section 3.3.1 Establishment of structure
(ii)
Page 21 – lines 11-16
Section 3.1.3 Components of pricing at receipt points.
Preamble:
In Reference (i) Gaz Métro has set out three formulas for establishing the
receipt rate and the billing amount at a receipt point. In reference (ii) Gaz
Métro describes the components of pricing at receipt points.
Information Requests:
31.1
In the first formula on page 23 at line 21, should "T-PLOF" be "P-DPOF"?
31.2
Please fully discuss how the "MDO price" in the second formula at page
23 line 23 will be established for each particular receipt point.
31.3
In the second formula at page 23 line 23, why is the "MDO price"
multiplied by the MCC rather than by the MDO under a particular receipt
rate service contract?
31.4
If the "MDO price" is multiplied by the MCC rather than by the MDO
under a particular receipt rate service contract, what is the distinction, if
any, between the MCC and the MDO?
31.5
Please fully describe why the concept of a MDO is required including
identifying any benefits that might accrue to a Producer if the MDO is less
than the MCC.
31.6
In the third formula at page 24 line 5, should "P-DPLOF" be "P-DPOF"?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 36 of 80
QOGA - Gaz Métro-32
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 24
Section 3.3.1 Establishment of structure
Table 1 Rate Schedule
Preamble:
Table 1 shows an example of the receipt rates.
Information Requests:
32.1
Does Gaz Métro propose to publish the specific components of the receipt
rate for each specific receipt point?
32.2
If Gaz Métro's response to QOGA- Gaz Métro IR 32.1 is yes, when and
where will the specific components of the receipt rates be published?
32.3
If Gaz Métro's response to QOGA-Gaz Métro 32.1 is no, will such
information be provided or made available by Gaz Métro to all Producers,
and if so, when and how?
32.4
Which components of the receipt rate will be established in advance and
which components will only be established after the end of a Billing
Month?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 37 of 80
QOGA - Gaz Métro-33
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 24 – line 12
Section 3.3.2 Text of receipt rate
Preamble:
Gaz Métro has indicated that the text of the receipt rate may read as set
out in the text of Section 3.3.2.
Information Requests:
33.1
Is Gaz Métro seeking the approval of the Régie, in this proceeding, of the
text for the receipt rate as set out in Section 3.3.2 at pages 24-26.
33.2
If Gaz Métro's response to QOGA- Gaz Métro IR 33.1 is no, when will
Gaz Métro be applying to the Régie for approval of the specific text of the
receipt rate?
33.3
Will Gaz Métro consult further with the Producers respecting the text of
the receipt rate prior to any filing of any further application to the Régie
and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 38 of 80
QOGA - Gaz Métro-34
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 25 – line 2
Section 3.3.2.2.1 Minimum Daily Obligation
Preamble:
Information Request:
34.1
Should the heading of Section 3.3.2.2.1 be "MDO price" rather than
"Minimum Daily Obligation"?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 39 of 80
QOGA - Gaz Métro-35
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Section 3.4.1.1 Portion of Distribution Costs not Related to Gas System
Allocated to Producers
Preamble:
Gaz Métro has proposed that the portion of distribution costs not related to
gas system allocated to Producers (Category C costs) is to be established
as 4% of the Category A costs at any particular receipt point and describes
Gaz Métro's rationale for this allocation. The QOGA wishes to determine
whether or not this is an appropriate allocation of these costs.
Information Requests:
35.1
Please provide a copy of the 2008-2009 cost of service allocation study
referred to at page 27, line 8.
35.2
Please more fully describe the process by which Gaz Métro determined
whether each particular category of cost was related to the actual gas
system or was not related to the actual gas system.
35.3
Please provide a complete listing of those categories of costs which Gaz
Métro has classified as being related to the actual gas system.
35.4
Please provide a complete listing of those categories of costs which Gaz
Métro classified as not being related to the actual gas system and are these
costs the same as those shown in Table 2 on page 29 under the column
heading "BUDGET 2008/2009".
35.5
Are the costs set out at page 27 line 21 through page 28 line 16 the costs
which are set out in Table 2 on page 29 under the column heading
"BUDGET 2008/2010 Producer"?
35.6
Please confirm that the heading of the second column of Table 2 on page
29 should be "BUDGET 2008/2009 to be Allocated" and that the amounts
in that column represent the costs which are to be allocated between the
Producers and the Consumer customers.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 40 of 80
QOGA - Gaz Métro-35
35.7
For each of the amounts set out in Column 2 of Table 2 on page 29 please
provide a further breakdown utilizing each of the categories of expenses
set out on page 27 line 21 through page 28 line 16.
35.8
Please provide a description of the allocation basis utilized by Gaz Métro
for allocating each of these cost categories referred to in QOGA-Gaz
Métro IR 35.7 between the Producers and the Consumer customers.
35.9
Please provide a full description of each of the hypothetical scenarios
referred to at page 28 line 24, and all calculations leading to Gaz Métro's
conclusion at page 28 line 28 that the ratio of costs/investments under the
various scenarios ranged between 2.8% and 5.6%.
35.10
Please provide a more complete description of the scenario used to
develop Table 2 on page 29 including how the Rate Base amount of
$45,792,000 was established.
35.11
Please fully explain why Gaz Métro is proposing to do an allocation of
Category C costs based on a simple ratio of 4% of the Category A
investment cost rather than a more detailed allocation procedure for the
allocation of Category C costs.
35.12
Is the 4% being applied to the original Category A investment cost or to
the unamortized Category A investment cost, from time to time?
35.13
If Gaz Métro's response to QOGA-Gaz Métro IR 35.12 is on the original
Category A investment cost, please explain why this is more appropriate
than basing it on the current unamortized Category A investment cost.
35.14
Please explain the linkage between the $1,850,028 of costs to be allocated
to the Producer as set out in Table 2 on page 29 and the $45,792,000
Category A investment cost for such Producer.
35.15
Please confirm that the "Distribution Allocated Costs (not related to the
actual gas system)", as described in the title of Table 2 on page 29, refer to
the costs related to both the distribution portion of Gaz Métro's system and
the transmission portion of Gaz Métro's system.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 41 of 80
QOGA - Gaz Métro-35
35.16
If a Producer which is delivering gas outside the territory is required to
pay Category A, Category B and Category C costs, please confirm that
there is no overlap e.g. double counting between any Category B cost and
any Category C cost.
35.17
If Gaz Métro cannot provide the confirmation requested in QOGA-Gaz
Métro IR 35.16, please identify each area where there is a possible overlap
e.g. double counting between a Category B cost and a Category C cost.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 42 of 80
QOGA - Gaz Métro-36
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 29 – lines 10-13
Section 3.4.1.1 Portion of Distribution Costs not Related to Gas System
Allocated to Producers
Preamble:
Gaz Métro has indicated that the 4% ratio could be modified in
subsequent rate cases depending on the evolution of the distribution costs
(not related to the actual gas system) and eventual adjustments to the
allocation methods.
Information Requests:
36.1
For what period of time is Gaz Métro requesting the Régie to approve the
4% ratio for establishing the Category C costs?
36.2
Please more fully describe the situations which would cause Gaz Métro to
apply for a different method to establish the Category C costs.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 43 of 80
QOGA - Gaz Métro-37
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 30 – line 6
Section 3.4.1.2 Establishment of Prices at Receipt Points
Preamble:
Gaz Métro is proposing that the investment costs for each project be
included in the prices at a receipt point.
Information Request:
37.1
Please confirm that no Category A investment costs will also be included
in the Rate Base for Gaz Métro's system and if not, please explain why
not.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 44 of 80
QOGA - Gaz Métro-38
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 30 – lines 10-15
Section 3.4.1.2 Establishment of Prices at Receipt Points
Preamble:
Gas Métro is proposing that the amortization period for all Connection
line facilities be based on an estimated useful life of 20 years which
reflects a 5% depreciation rate.
Information Requests:
38.1
Please explain why Gaz Métro determined that the useful life for all
possible Connection lines would always be 20 years.
38.2
Will the amortization period which results in a 5% depreciation expense
be fixed for the term of each receipt rate service contract including any
renewal term or could this be changed in the future?
38.3
How will the receipt rate be established for any particular Connection line
which is expected to have a useful life in excess of 20 years?
38.4
How will the receipt rate be adjusted for any particular Connection line if
its actual useful life proves to be in excess of 20 years?
38.5
After 20 years will the depreciation cost component of the receipt rate be
zero and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 45 of 80
QOGA - Gaz Métro-39
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 30 – lines 16-19
Section 3.4.1.2 Establishment of Prices at Receipt Points
(ii)
Page 34 – lines 5-6
Section 3.4.1.3 Breakdown of Price between MDO and Unit Price
Preamble:
In Reference (i) Gaz Métro has indicated that Gaz Métro's cost of capital
is approved by the Régie each year. In Reference (ii) Gaz Métro has
indicated that the prices at the receipt points could then be modified in
subsequent rate cases depending on the evolution of costs (rate of return,
income taxes, etc.)
Information Request:
39.1
Will the receipt rate at each receipt point automatically change each time
there is any change in any element of Gaz Métro's cost of capital (e.g. tax
rate, interest cost, cost of equity, debt/equity ratio) which has been
approved by the Régie and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 46 of 80
QOGA - Gaz Métro-40
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 31
Section 3.4.1.2 Establishment of Prices at Receipt Points
Table 3 Inputs to Revenue Requirements
Preamble:
Gaz Métro has listed as an input a "Breakeven point" of 20 years.
Information Request:
40.1
Please confirm that the "Breakeven point" is the period of time over which
the cost of service related to the Category A investment is to be averaged.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 47 of 80
QOGA - Gaz Métro-41
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 32
Section 3.4.1.2 Establishment of Prices at Receipt Points
Table 4 Calculation of Revenue Requirements
Preamble:
In Table 4 Gaz Métro has provided an example of how Category A costs
would be recovered.
Information Requests:
41.1
Please confirm that the heading for the last column of Table 4 on page 32
should be "2029 Year 20 in $".
41.2
Please confirm that Gaz Métro is proposing a uniform or levelized rate
throughout the first 20 years of the term of a receipt rate service contract.
41.3
If the term of a receipt rate service contract was extended beyond a 20
year period, how would Gaz Métro determine a toll for the Category A
costs for the period of time beyond 20 years?
41.4
What discount rate has Gaz Métro utilized to establish each of the NPV
numbers set out in Table 4 on page 32?
41.5
Is the "Revenue" amount of $7,528,718 set out in Table 4 on page 32 for
Year 1 and the $7,525,000 referred to at page 32 line 4, supposed to be the
same number?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 48 of 80
QOGA - Gaz Métro-42
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 32 – line 14 to Page 33 - line 15
Section 3.4.1.2 Establishment of Prices at Receipt Points
Preamble:
Gaz Métro has indicated that the price at a receipt point may be revised
when there are new Producers who wish to use the same connection
pipelines or if Gaz Métro connects new customers to pipelines previously
used only to connect producer's facilities to the gas system. Gaz Métro
has further indicated that any revisions would occur in the rate case
following the investment request.
Information Requests:
42.1
Why would the receipt rate at a receipt point not always be revised in each
of the case of the two situations described in the preamble to this QOGAGaz Métro IR 42?
42.2
For each of the situations described in the preamble to QOGA-Gaz Métro
IR 42 please describe how the receipt rate would be reduced and please
provide examples.
42.3
Please explain why Gaz Métro would not revise the receipt rate at the time
of a Régie decision on the new investment request rather than waiting for
the rate case following the investment request?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 49 of 80
QOGA - Gaz Métro-43
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 34- lines 23-26
Section 3.4.2.1 Unit Prices by Volumes Delivered Within the Territory
Preamble:
Gaz Métro has indicated that the cost of the TCPL/TQM transportation
service will fluctuate on the basis of the distance covered and that the
distance the surplus gas will have to travel from one particular
Consumption zone to other consumption zones.
Information Requests:
43.1
If one particular Consumption zone has surplus gas, will Gaz Métro
always transport such surplus gas to the next nearest Consumption zone
which has available capacity and if not, please explain why not?
43.2
If two particular Consumption zones have surplus gas, how will Gaz
Métro transport such surplus gas to each of the other Consumption zones
which have available capacity i.e. which surplus volumes would go to
each Consumption zone which has capacity?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 50 of 80
QOGA - Gaz Métro-44
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 35 – lines 3 – 8
Section 3.4.2.1 Unit Prices by Volumes Delivered Within the Territory
Preamble:
Gaz Métro has indicated that all volumes injected will be assumed to be
delivered for consumption within the territory unless the Producers have
clearly expressed their intention to contract TCPL/TQM transportation
themselves.
Information Requests:
44.1
How does a Producer clearly express their intention to Gaz Métro?
44.2
Is there any minimum period of time for which a Producer must make its
decision to have its gas delivered outside the territory or will this be done
on a day to day basis?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 51 of 80
QOGA - Gaz Métro-45
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 35 – lines 14-16
Section 3.4.2.1 Unit Prices by Volumes Delivered Within the Territory
Preamble:
Gaz Métro appears to indicate that the rates will be established based on
forecasts for the volumes to be injected daily and annually based on the
information that will be provided to it by producers.
Information Requests:
45.1
Will the "unit price by volumes delivered within the territory" be
established based on Gaz Métro's forecasts of the necessary TCPL/TQM
requirements and costs or based on Gaz Métro's actual TCPL/TQM costs?
45.2
If there is a difference between the TCPL/TQM costs used to establish the
"unit price by volumes delivered within the territory" and the actual
TCPL/TQM costs incurred by Gaz Métro, how will such difference be
accounted for i.e. will a deferral account be established by Gaz Métro to
record such difference for disposition at the next rate hearing and if not,
please explain why not?
45.3
If Gaz Métro is not planning on making any adjustments to reflect a
difference between forecasted TCPL/TQM costs and actual TCPL/TQM
costs, please explain why not.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 52 of 80
QOGA - Gaz Métro-46
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 36 – lines 1-2
Section 3.4.2.1 Unit Prices by Volumes Delivered Within the Territory
Preamble:
Gaz Métro has indicated that the price applicable to each consumption
zone will initially be established when investment requests are filed.
Information Request:
46.1
As both the amount and cost of the TCPL/TQM transportation capacity
which Gaz Métro may require also depends on the actual consumption by
Consumer customers in the Consumption zone and the specific Delivery
point selections of other Producers in that Consumption zone, how can the
rate for Category A costs be established at the time an investment request
is filed?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 53 of 80
QOGA - Gaz Métro-47
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 36-39
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro is proposing that the unit price for volumes delivered outside
the territory will be fixed at .70¢/m3.
Information Requests:
47.1
Does any gas which is to be delivered inside the territory also utilize those
Gaz Métro system facilities which have a transmission function (i.e. high
pressure pipelines)?
47.2
If Gaz Metro's response to QOGA- Gaz Metro IR 47.1 is yes, what is Gaz
Métro's rationale for proposing to only apply these Category B costs to
volumes delivered outside the territory and not also to volumes delivered
inside the territory.
47.3
As Gaz Métro is proposing that Category B costs are to be borne solely by
gas volumes which will be delivered outside the territory and not by gas
which will be delivered inside the territory, does Gaz Métro's proposal
tend to encourage a Producer to make its deliveries of gas in the territory
rather than outside the territory and if not, please explain why not?
47.4
Does Gaz Metro believe that its proposal that Category B costs are to be
borne solely by gas volumes which will be delivered outside the territory
will tend to create a market distortion in the Quebec natural gas market
and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 54 of 80
QOGA - Gaz Métro-48
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 36-39
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro has provided an elaborate explanation in Section 3.4.2.2 of the
approach Gaz Métro utilized to arrive at the unit price of .70¢/m3. The
QOGA believes that an amount of .70¢/m3 ($0.20/mcf) seems quite high
for the use of Gaz Métro's transmission pipelines to access the
TCPL/TQM system.
Information Requests:
48.1
Although Gaz Métro describes an elaborate process for establishing this
unit price, would Gaz Métro agree that the net outcome of this analysis
was simply that this unit price was set, at the same level as the amount
which would be allocated to a Rate D4 Consumer customer (excluding the
4.10 level) and if not, please explain why not?
48.2
Please explain, in greater detail, why it is appropriate for the Producers
that wish to deliver gas outside the territory to pay the same amount as the
amount which would be allocated to a Rate D4 Consumer customer?
48.3
For what period of time is Gaz Métro requesting that the Régie approve
this .70¢/m3 unit price?
48.4
Will the .70¢/m3 unit price automatically change every time there would
be a change in the amount which would be allocated to a Rate D4
Consumer customer (excluding the 4.10 level) and if not, please explain
why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 55 of 80
QOGA - Gaz Métro-49
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 36 – lines 16-17
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro is proposing that a single rate zone be established for the unit
price by volumes delivered outside the territory.
Information Requests:
49.1
Does Gaz Métro agree that the actual portion of the Gaz Métro
transmission facilities which would be utilized by any particular Producer
to have its gas delivered outside the territory would be those Gaz Métro
facilities located between the end point of that Producer's Connection line
and the closest Interconnect point with the TCPL/TQM system and if not,
please explain why not?
49.2
As the use of Gaz Métro's transmission facilities in respect of gas
delivered outside the territory would also appear to vary from situation to
situation, please explain why Gaz Métro is proposing a single rate zone
for the calculation of this unit price rather than individual rates based on
the specific location of each Receipt point as was done with the Category
A costs.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 56 of 80
QOGA - Gaz Métro-50
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 36-39
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro has used various terms in this section including "transmission
system", "transmission lines", "mainlines", "transportation pipelines",
"transmission pipelines", "distribution function" and "transportation
function".
Information Requests:
50.1
Please confirm that Gaz Métro's proposed allocation procedure for these
costs was an attempt to determine the costs which are attributable to that
portion of Gaz Métro's system which are "transmission facilities" (e.g.
high pressure pipelines).
50.2
Please confirm that Gaz Métro's proposed allocation procedure for these
costs does not allocate any costs which are attributable to that portion of
Gaz Métro's system which are "distribution facilities" (e.g. low pressure
pipelines) and if not, please explain why not.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 57 of 80
QOGA - Gaz Métro-51
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 37- lines 3-4
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro has proposed to allocate 32% of the total cost of the gas
unaccounted for in the system to the transmission function. The 32% was
based on the percentage of Gaz Métro's pipelines that are transmission
pipelines.
Information Request:
51.1
Please explain why Gaz Métro is proposing to allocate the cost of
unaccounted for gas based on a categorization of pipeline function rather
than based on the quantities of all volumes utilizing its system.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 58 of 80
QOGA - Gaz Métro-52
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 38
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Table 5 Costs Related to Transportation Portion
Preamble:
Information Request:
52.1
Please confirm that the heading for the second column of Table 5 on page
38 "2008/2010 BUDGET Producer" is incorrect and the amounts set out
in this column are the portion of Gaz Métro's 2008/2009 BUDGET costs
set out in column 1 of Table 5 on page 38 which are considered by Gaz
Métro to be appropriately allocated to the transmission function.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 59 of 80
QOGA - Gaz Métro-53
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 39- lines 1-9
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro has determined that $48.3 million of its system costs are
attributable to the transmission function but has further indicated that it
was not in a position to make an appropriate allocation of this amount
between its Consumer customers and the Producers.
Information Request:
53.1
Rather than fixing the unit price at .70¢/m3 for a period of time, why is
Gaz Métro not proposing to establish the unit price from time to time
based on dividing the $48.3 million by the volumes of gas utilizing the
transmission facilities for all of the Consumer customers and for all of the
Producers?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 60 of 80
QOGA - Gaz Métro-54
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 39- lines 10-15
Section 3.4.2.2 Unit Price by Volumes Delivered Outside the Territory
Preamble:
Gaz Métro has proposed that the unit rate for deliveries outside the
territory to be equal to the average unit cost for Rate D4, excluding the
4.10 level, based on their similar consumption characteristics to those of
the Producers.
Information Request:
54.1
Please provide a list of each of Gaz Métro's Rate D4 customers and
describe the consumption characteristics of each (e.g. maximum daily
volume, minimum daily volume, average daily volume, level of volumes,
stability of the volumes, term of commitment).
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 61 of 80
QOGA - Gaz Métro-55
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 39, lines 24-26
Section 3.5.1 Revision of Maximum Contractual Capacity (MCC)
Preamble:
Gaz Métro has indicated that an increase in the MCC as specified in the
receipt rate service contract will be permitted if it is physically possible
for Gaz Métro to increase the capacity at a receipt point.
Information Requests:
55.1
If it was physically possible for Gaz Métro to increase the capacity at a
receipt point, does this mean that the Connection line would have had
surplus capacity and if so, please explain who bears the cost of this
surplus capacity prior to the increase in the MCC?
55.2
Please provide an example showing how that Producer's receipt rate
would be recalculated if the MCC was increased with no additional
Category A costs being incurred by Gaz Métro.
55.3
Please provide examples showing how that Producer's receipt rate would
be recalculated if the MCC was increased with additional Category A
costs being incurred by Gaz Métro and without additional Category A
costs being incurred by Gaz Métro.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 62 of 80
QOGA - Gaz Métro-56
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 39 – line 27 to Page 40 – line 5
Section 3.5.1 Revision of Maximum Contractual Capacity (MCC)
(ii)
Page 42 – line 18
Section 3.5.3 Contract Term, Renewal Term and Indemnity
Preamble:
In Reference (i) Gaz Métro is proposing to allow a Producer to reduce its
MCC if another Producer is prepared to take the capacity and pay the
related costs. In Reference (ii) Gaz Métro has indicated that a Producer
may have to pay an "indemnity" to Gaz Métro.
Information Requests:
56.1
Would the "receiving" Producer have to take the capacity for the entire
remaining term of the original receipt rate service contract?
56.2
Would the responsibility for the "indemnity" referred to in Reference (ii)
be allocated between the "receiving" Producer and the "transferring"
Producer and if so how?
56.3
Will Gaz Métro develop a procedure, utilized by most other Canadian
pipelines, whereby a Producer may make temporary assignments of its
capacity under a receipt rate service contract to another Producer without
Gaz Métro's consent; provided that the Producer which is making the
temporary assignment continues to remain liable to Gaz Métro for all
charges and if not, please explain why not?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 63 of 80
QOGA - Gaz Métro-57
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 40 – line 19
Section 3.5.2.1 Daily Overruns of Maximum Contractual Capacity (MCC)
Preamble:
Gaz Métro has indicated that if it is operationally possible to accept
deliveries of gas from a Producer in excess of that Producer's MCC, it will
be carried out through the daily nomination process and if excess capacity
is limited, excess capacity will be allocated by Gaz Métro among those
Producers requesting it on a prorata basis based on the level of excess
volumes nominated by each Producer.
Information Requests:
57.1
Why is Gaz Métro proposing to allocate available excess capacity on the
basis of nominations for excess volumes rather than based on each
requesting Producer's respective MCC?
57.2
Does Gaz Métro propose to place an upper limit on the volume of excess
capacity which any Producer can nominate and if not, please explain why
not?
57.3
Has Gaz Métro considered how the concept of Authorized Overrun
Service ("AOS") is utilized by other Canadian pipelines and if so, please
explain why Gaz Métro did not consider the AOS concept to be a suitable
model for addressing Producer's requests to deliver excess volumes?
57.4
Has Gaz Métro considered the concept of "Account Availability" utilized
on the Westcoast system which allocates excess capacity based on recent
production levels, and if so, please explain why Gaz Métro did not
consider the "Account Availability" concept to be a suitable model for
addressing Producer's requests to deliver excess volumes?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 64 of 80
QOGA - Gaz Métro-58
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 41
Section 3.5.2.2 Deliveries between Nominated and Injection Volumes
Preamble:
Gaz Métro has proposed to incorporate tolerances and penalty levels and
amounts as used by TCPL in order to account for differences between a
Producer's nominated volumes and the volumes actually injected at a
receipt point by that Producer.
Information Requests:
58.1
Has Gaz Métro considered basing tolerances on an aggregated basis i.e.
linking various Receipt points and manage imbalances on a cumulative
basis rather than on an individual Receipt point basis and if not, please
explain why not?
58.2
Has Gaz Métro considered basing tolerances on a net pipeline position
procedure where imbalance penalties are not imposed on an individual
Producer where that particular Producer's imbalance is in the opposite
direction of Gaz Métro's overall position and if not, please explain why
not?
58.3
Please describe all additional tools which Gaz Métro could offer to
Producers in order that Producers will be able to minimize imbalance
costs e.g. daily inventory transfers, intra day nomination adjustments,
temporary assignments of capacity?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 65 of 80
QOGA - Gaz Métro-59
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 42 – line 18 to Page 43 – line 6
Section 3.5.3 Contract Term, Renewal Term and Indemnity
Preamble:
Gaz Métro is proposing an initial minimum term for a receipt rate service
contract of ten years, a renewal possibility but with an obligation to pay an
indemnity in certain circumstances.
Information Requests:
59.1
Please provide a complete description of the procedure which will apply
for renewals of a receipt rate service contract both at the end of the initial
term and at the end of any renewed term thereafter including the notice
period, the duration of minimum renewal term and the duration of the
maximum renewal term.
59.2
Would any renewal right be at the sole option of the Producer and if not,
please explain why not?
59.3
Please confirm that Gaz Métro's proposed "indemnity" is also known in
the gas transportation industry as an "exit fee".
59.4
As the breakeven point has been established by Gaz Métro as 20 years,
please confirm that at the end of the term of a receipt rate service contract
an exit fee will be required to be paid by the Producer to Gaz Métro in all
situations where the length of the initial term, plus any renewal term of
that receipt rate service contract, is less than 20 years and if not, please
explain why not.
59.5
Please describe the benefit, if any, which a Producer would receive if it
elected to terminate its receipt rate service contract before the end of a 20
year period and pay the exit fee as opposed to simply renewing the receipt
rate service contract throughout such 20 year period.
59.6
Please provide a detailed example showing how the exit fee would be
calculated.
59.7
Please confirm that the "book value of the assets" on page 43 line 3 refers
to the book value of that Producer's Category A facilities at the time the
exit fee is to be paid to Gaz Métro.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 66 of 80
QOGA - Gaz Métro-59
59.8
Please provide a further explanation of that portion of the exit fee which is
"the revenue shortfall that the Producer would have paid if it had been
under contract until the breakout point was achieved" referred to at page
43 lines 4-5.
59.9
To the extent that amortization costs of the Producer's Category A
facilities would appear to be included in the portion of the exit fee referred
to in QOGA- Gaz Métro IR 59.8, why does the exit fee also include a
component equal to the book value of these assets?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 67 of 80
QOGA - Gaz Métro-60
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 43 – lines 7-10
Section 3.5.3 Contract Term, Renewal Term and Indemnity
Preamble:
Gaz Métro has proposed that a portion of any exit fee paid by a Producer
would be refunded in accordance with the agreement between the parties.
Information Requests:
60.1
Please explain why a standardized procedure for the refund of an exit fee
should not be developed rather than leaving it to be agreed to in the future
by Gaz Métro and the individual Producers which may be involved.
60.2
Does Gaz Métro also propose to refund a portion of the exit fee to the
original Producer if the facilities are subsequently used by Gaz Métro to
service its Consumer customers and if not, please explain why not?
60.3
Why would a portion of the exit fee not also be refunded to the original
Producer if the facilities are subsequently used by either another Producer
or by Gaz Métro to service its Consumer customers subsequent to the end
of the 20 year period?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 68 of 80
QOGA - Gaz Métro-61
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 43 – line 11 to Page 44 line 7
Section 3.5.4 Composition of Natural Gas and Calorific Content
Preamble:
Gaz Métro has proposed that the gas to be delivered at each receipt point
must satisfy the quality specifications approved by the NEB but Gaz
Métro also reserves the right to add additional specifications.
Information Requests:
61.1
Please confirm that the quality specifications approved by the NEB refer
to those particular gas quality specifications set out in Section V "Quality"
of TransCanada PipeLines General Terms and Conditions.
61.2
If Gaz Métro cannot provide the confirmation set out in QOGA-Gaz
Métro IR 61.1, please provide a listing of each quality specification which
would apply to deliveries of gas by a Producer at a Receipt point.
61.3
Does Gaz Métro agree that all gas to be delivered by Gaz Métro at a
Delivery point within the territory or at a Delivery point outside the
territory will meet the same quality specifications and if not, please
explain why not?
61.4
Please explain why Gaz Métro should be allowed to impose any new
additional quality specification which is more stringent than that which
would apply to gas being delivered to Gaz Métro from the TCPL/TQM
system.
61.5
Please explain what "costs" a Producer has to reimburse Gaz Métro for as
referred to at page 44 line 7.
61.6
Please explain why a Producer should be required to reimburse Gaz Métro
for any cost attributable to the injection of non-compliant gas in the
situation where Gaz Métro has knowingly continued to receive the noncompliant gas.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 69 of 80
QOGA - Gaz Métro-62
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 44
Section 3.5.5 Pressure
Preamble:
Gaz Métro has indicated that a Producer's gas has to be delivered at a
Receipt point at the pressure stipulated by Gaz Métro in the receipt rate
service contract, up to a maximum of 110% of that pressure.
Information Requests:
62.1
Is Gaz Métro only required to accept delivery of gas from a Producer if
that Producer's gas is delivered at a pressure which is between 100% and
110% of the pressure specified in the receipt rate service contract and if
not, please explain why not.
62.2
Should Gaz Métro also be required to accept delivery of gas from a
Producer if that Producer's gas is delivered at a pressure which is
sufficient to allow gas to enter the Gaz Métro system at a Receipt point at
the time, irrespective of the pressure specified in the receipt rate service
contract and if not, please explain why not?
62.3
Is a Producer only required to deliver gas at a Receipt point at a pressure
which is equal to that of the pressure specified in the receipt rate service
contract?
62.4
If the response to QOGA-Gaz Métro IR 62.1 is that Gaz Métro is only
required to accept a Producer's gas when the pressure is between 100%
and 110% of the pressure specified in the receipt rate service contract,
please describe, in general terms, how Gaz Métro will operate its gas
system to ensure that Gaz Métro will be able to accept the gas from a
Producer?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 70 of 80
QOGA - Gaz Métro-63
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 44
Section 3.5.6 Interruptions and Curtailments of Receipt of Natural Gas
Preamble:
Gaz Métro appears to be seeking the approval of the Régie to interrupt or
curtail the receipt of gas at any Receipt point.
Information Requests:
63.1
If Gaz Métro cannot provide receipt rate service to a Producer either as a
result of an event of force majeure or otherwise, will there be any
reduction of the fixed components of the receipt rate and if so, please
provide an example of how the reduction in the receipt rate would be
determined?
63.2
If Gaz Métro is not proposing to provide any reduction of the fixed
components of the receipt rate in the situation where Gaz Métro cannot
provide receipt rate service, please explain why not.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 71 of 80
QOGA - Gaz Métro-64
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 45
Section 3.5.7 Custody and Control of Natural Gas
Preamble:
Gaz Métro has indicated that it will assume custody and control of the
Producer's gas at the Receipt point. In order for a Connection line to
operate linepack gas will be required.
Information Requests:
64.1
Will linepack gas for a Connection line be supplied by the Producer or by
Gaz Métro?
64.2
If linepack gas for a Connection line is to be supplied by the Producer,
please describe how such linepack will be managed, tracked and adjusted
from time to time.
64.3
If linepack gas for a Connection line is to be supplied by Gaz Métro:
(a)
will Gaz Métro purchase such gas from the Producer and if so, at
what price; and
(b)
will the cost of Connection line linepack be included in the
determination of that Producer's receipt rate and if so, how?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 72 of 80
QOGA - Gaz Métro-65
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
(i)
Page 45
Section 3.5.7 Custody and Control of Natural Gas
(ii)
Page 22
Section 3.2.1 Unit Price by volume delivered within the territory
Preamble:
Gaz Métro has recently revised Section 3.5.7 and the QOGA is seeking
clarification as to how sales of natural gas in Quebec will occur.
Information Requests:
65.1
Please confirm that ownership of and title to all natural gas shipped by a
Producer under a receipt rate service contract will remain with that
Producer even though the natural gas will be in the custody and control of
Gaz Métro.
65.2
If a Producer wishes to sell the natural gas which was being shipped by
that Producer under a receipt rate service contract, to Gaz Métro, for Gaz
Métro's system supply:
(a)
where would the transfer of tile between the Producer and Gaz
Métro take place; and
(b)
would the Producer or Gaz Métro be responsible for the Unit Price
by volume delivered within the territory (see Reference (ii))?
65.3
If a Producer wishes to sell the natural gas which was being shipped by
that Producer under a receipt rate service contract, to a Consumer
customer would the transfer of title between the Producer and that
Consumer customer take place at the point of interconnection between the
facilities of Gaz Métro and those of the Consumer customer and if not,
please explain where the point of title transfer would occur?
65.4
For the sales transaction described in QOGA-Gaz Métro IR 65.3, please
fully describe all arrangements which Gaz Métro would require to be in
place between the Producer, Gaz Métro and the Consumer customer in
order to effect such a sale of gas.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 73 of 80
QOGA - Gaz Métro-66
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 42
Section 3.5.3 through Section 3.5.7
Preamble:
In Section 3.5.3 through Section 3.5.7 Gaz Métro has discussed certain
additional requirements that will apply to receipt rate service.
Information Requests:
66.1
Is Gaz Métro requesting that the Régie specifically approve, in this
proceeding, each of the matters discussed in Section 3.5.3 through
Section 3.5.7?
66.2
If Gas Métro's response to QOGA-Gaz Métro's IR 66.1 is yes, please
explain why Gaz Métro believes that the concepts discussed in
Section 3.5.3 through Section 3.5.7 are sufficiently advanced for approval
at this time.
66.3
Would Gaz Métro agree that the matters addressed in Section 3.5.3
through Section 3.5.7 are typically addressed in other Canadian pipelines
tariff documents in much greater detail and if so, please explain why Gaz
Métro has not provided a similar level of detail.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 74 of 80
QOGA - Gaz Métro-67
References:
(i)
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 45-55
Section 4 Conditions of Natural Gas Service and Tariff
(ii)
B-7 Gaz Métro-2, Document 2 (English Translation)
Revised Conditions of Natural Gas Service and Tariff
Preamble:
Gaz Métro appears to be requesting that the Régie approve, in this
proceeding, the indicated changes to its Conditions of Natural Gas Service
and Tariff (Reference (ii)).
Information Requests:
67.1
Will Gaz Métro undertake to provide a further revision of conditions of
Natural Gas Service and Tariff prior to the commencement of the hearing
in order to reflect any corrections or further clarifications which may arise
from the information requests of the QOGA and other intervenors and if
not, please explain why not?
67.2
If Gaz Métro is not prepared to provide the undertaking requested in
QOGA-Gaz Métro IR 67.1, please explain what process Gaz Métro would
propose to ensure that the Conditions of Natural Gas Service and Tariff
accurately and fully reflect the full business understanding between Gaz
Métro and the Producers upon which receipt rate service is to be provided
by Gaz Métro to the Producers.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 75 of 80
QOGA - Gaz Métro-68
References:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 48 – line 5
Section 4.1.2 Chapter 2: Distribution System
Preamble:
Gaz Métro has proposed an amendment to Section 2.1 in its Tariff,
Distribution System respecting
"The distributor shall determine the location of its
distribution system, which includes the receipt
point".
Information Request:
68.1
Please explain why is the location of any receipt point not being
established as a result of discussions between a Producer and Gaz Métro
rather than simply as determined by Gaz Métro?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 76 of 80
QOGA - Gaz Métro-69
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 52 – line 2
Section 4.1.7 Chapter 7: Payment
Preamble:
Gaz Métro's proposed Section 7.3.1 Written Contract utilizes the term
"solidarily liable".
Information Requests:
69.1
Please confirm that this term should be "severably liable" and please
explain what Gaz Métro interprets the term "severably liable" to mean.
69.2
If Gaz Métro cannot provide the confirmation requested in QOGA- Gaz
Métro IR 69.1, then please explain what Gaz Métro means by the term
"solidarily liable".
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 77 of 80
QOGA - Gaz Métro-70
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Pages 52-53
Section 4.1.8 Chapter 8: Deposit
Preamble:
Gaz Métro is requesting the right to require a deposit from any Producer,
up to a maximum amount equal to 12 months of service charges under a
receipt rate service contract for an initial retention period of 60 months.
Information Requests:
70.1
Please confirm that Gaz Métro will only request a deposit from a Producer
if Gaz Métro has reasonable concerns about that Producer's financial
ability to pay the service charges under a receipt rate service contract and
if not, please explain why not.
70.2
If Gaz Métro cannot provide the confirmation requested in QOGA-Gaz
Métro IR 70.1, please describe all other situations where Gaz Métro will
require a deposit to be paid by a Producer.
70.3
Could any concerns which Gaz Métro may have about the financial ability
of a Producer to pay the service charges under a receipt rate service
contract also be addressed by other mechanisms (e.g. parental company
guarantee, letter of payment guarantee, pledge of assets as collateral) and
if not, please explain why not?
70.4
Please explain why Gaz Métro is proposing the initial retention period for
a deposit from a Producer to be 60 months while the initial retention
period for a deposit from any non-domestic use customer is only 36
months?
70.5
If a Producer makes all required payments under its receipt rate service
contract for the first 60 months of the term of such service contract, does
Gaz Métro thereafter lose the right to make any further request for a
deposit from that Producer and if not, please explain why not.
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 78 of 80
QOGA - Gaz Métro-71
Reference:
B-6-Gaz Métro-1, Document 2 (English Translation)
Page 56 – lines 1-7
Section 5.2 Transportation
Preamble:
Gaz Métro has attempted to describe the arrangement where one of its
present Consumer customers wishes to obtain its gas supply from natural
gas producers in Quebec. QOGA is unclear as to which arrangements
must be entered into by the Producer, Gaz Métro and such Consumer
customer in order to effect such a sale.
Information Requests:
71.1
In the context of a Quebec natural gas supply from a Producer, please
further explain the sentence on page 56 beginning at line 6 "The customer
would then be required to deliver the natural gas, including natural gas
purchased in Quebec, to Gaz Métro's s territory in the manner he finds
suitable".
71.2
If a receipt rate service contract entitles a Producer to have its gas
delivered at a point inside Gaz Métro's territory, what additional
arrangements, if any, would a Consumer customer have to enter into with
either the Producer or Gaz Métro in order to allow for delivery of that
natural gas to the Consumer customer in Quebec?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 79 of 80
QOGA - Gaz Métro-72
References:
B-7-Gaz Métro-2, Document 2 (English Translation)
Conditions of Natural Gas Service and Tariff
Preamble:
(i)
Page 21, Section 5.2 Measurement of Volume of Natural Gas
Withdrawn or Injected
(ii)
Page 22, Section 5.5 Defective Metering Equipment
(iii)
Page 73, Section 16.6.4 Natural Gas Pressure, Composition and
Calorific Content
Reference (ii) sets out provisions to deal with a suspected meter defect.
The metering equipment referred to in Reference (i) only addresses
equipment which is required to indicate the volume of gas withdrawn or
injected but does not address the equipment required to determine the heat
content or composition of gas at a Receipt point or a Delivery point. In
Reference (iii) Gas Métro is reserving the right to suspend the receipt of
non-standard gas without notice. There appears to be no provisions
respecting the requirements for measurement utilizing a gas
chromatograph nor procedures if the gas chromatograph equipment is
suspected to be measuring in error.
Information Requests:
72.1
Please confirm if Gas Métro is proposing to utilize a gas chromatograph at
each Receipt point to measure the heat content and quality specifications
of gas being delivered by a Producer at each Receipt point.
72.2
Please describe those situations where Gas Métro would not require its
own gas chromatograph to be installed e.g. gas being analyzed at the
Producer's facilities located immediately upstream of a Receipt point.
72.3
Why does the Defective Metering Equipment procedure described in
Reference (ii) not contemplate a joint meter testing procedure with the
opportunity for a representative of each of the Producer and Gas Métro to
witness such test?
72.4
Will Gas Métro propose that the Defective Metering procedure described
in Reference (ii) also applies to the situation where there is a defective gas
chromatograph and if not, what is the procedure for dealing with a
defective gas chromatograph?
RÉGIE DE L'ÉNERGIE
GAZ MÉTRO LIMITED PARTNERSHIP
NO. R-3732-2010
INFORMATION REQUEST
August 19, 2010
Page 80 of 80
QOGA - Gaz Métro-72
72.5
Please outline, in general terms, the procedures which will be followed by
Gas Métro to correct a metering error either in respect of a volume
measurement or heat content measurement, including the threshold level
before adjustments would be made to previous invoices and billings, the
time period for which any adjustments are to be made and the
responsibility for the costs of any meter test.
72.6
If, in reliance on Reference (iii) Gas Métro suspends the receipt of a
Producer's gas based on information provided by Gaz Métro's meters
which subsequently proves to be incorrect, please describe the remedies
which Gas Métro would propose to provide to the Producer e.g. a refund
of the receipt demand charges for those volumes of gas which Gas Métro
inappropriately refused to accept from the Producer?