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HomeMy WebLinkAbout1999-03-01 City CouncilCity City of Palo Alto Manager’s Report TO: ATTENTION: FROM: HONORABLE CITY COUNCIL FINANCE COMMITTEE 2 CITY MANAGER DEPARTMENT: UTILITIES DATE: SUBJECT: MARCH 1, 1999 CMR:148:99 PROPOSED IMPLEMENTATION PLAN FOR DIRECT ACCESS FOR GAS UTILITY CUSTOMERS REPORT IN BRIEF This report recommends Council approval of a Natural Gas Direct Access Implementation Plan. The plan will allow the City to offer gas supply choices similar to what PG&E is offering to its customers. The plan revises the City’s current gas direct access program for large customers and proposes to phase in direct access to additional customers over a three year period. Phase 1, proposed to begin middle to late 1999, applies to approximately ten large commercial customers~ The phase-in of gas direct access is intended to be flexible and responsive to changes in the marketplace, as well as’ reflecting activity in neighboring California Public Utilities Commission (CPUC) regulated service territory. The Palo Alto Utilities may adjust the administration and pace of the phase-in based on customer interest, practices in neighboring service territory, and technical and operational issues, including: implementation of the customer information system, billing and metering issues, and the availability of gas pool management services. On November 4, 1998, the Utilities Advisory Commission recommended that Council approve the proposed Natural Gas Direct Access Implementation Plan. CMR:148:99 Page 1 of 5 RECOMMENDATION Staff recommends that the City Council: Approve the initiation and implementation of the City of Palo Alto Natural Gas Direct Access Implementation Plan which updates a program Under existing Resolution No. 7522 (CMR:229:95) to allow direct access for natural gas customers. Adopt a Resolution of the Council of the City of Palo Alto approving amendments to Rules and Regulations 2, 6, 7, 11, 13, and adoption of a new Rule and Regulation 12 of the Utility Rules and Regulations pertaining to implementation of direct access for natural gas customers. 3.Authorize the City Manager or her designee to amend the Plan and associated documents with non-substantive changes and to execute gas service provider agreements. BACKGROUND The City of Palo Alto Utilities (CPAU) is committed to offering competitive prices and services to its customers. On June 19, 1995 the City Council approved Resolution No. 7522 (CMR:229:95) offering large natural gas customers (non-core customers) the opportunity to purchase gas on the open market, thus initiating direct access for natural gas customers. The Transportation-Only Natural Gas Rate (G-4), established at that time, allowed non-core natural gas customers the option of purchasing gas from competing suppliers and having it delivered to CPAU at the California border. The City. would then be responsible for transporting gas within California. To date, no customers have elected the G-4 tariff, primarily due to CPAU’s competitive prices. Industry changes have put further pressure on utilities to provide greater choice to customers. On March 1, 1998, PG&E’s intrastate transportation system became open access, creating new opportunities to provide service choices to CPAU’s natural gas customers. On June 22, 1998, the City Council approved (CMR:195:98) removing the intrastate transmission charges from the transportation-only rate. The City’s continuing commitment to customer satisfaction is driving the need to develop the Natural Gas Direct Access Implementation Plan and to make necessary revisions to Utility Rules and Regulations. CMR:148:99 Page 2 of 5 DISCUSSION Natural Gas Direct Access Implementation Plan The Natural Gas Direct Access Implementation Plan (Attachment I) is intended to revise CPAU’s current direct access program for large customers and offer customer choice to additional CPAU customers over a three year period beginning in 1999 and completing in 2001. The plan includes service structure, phase-in schedule and eligibility criteria. It is a general guide for the processes to be used to allow greater participation in gas direct access. The plan allows customers two options: 1) CPAU as the full service provider; or 2) gas direct access with CPAU providing transportation-only service. The plan will begin with the City’s non-core gas Customers. Other customer segments are to become eligible in subsequent phase-in periods. Revisions to Rules and Regulations Adoption of the Natural Gas Direct Access Implementation Plan will require a number of changes (shown in bold) to the Utilities Rules and Regulations (Attachment II). The following is a summary of the significant changes. Rule and Regulation 2- Definitions and Abbreviations: This provides a list of definitions of utilities terms and acronyms often used in the rules. Significant Changes: The number of terms defined has been expanded twofold. Rule and Regulation 12- Natural Gas Direct Access: This establishes terms and conditions under which the Gas Utility shall render distribution services under gas direct access, including terms and conditions under which the City will provide gas balancing services to gas commodity service providers. It sets forth requirements and responsibilities for customers and their gas commodity service providers, and, establishes the gas balancing responsibilities of the gas ’commodity service providers. Significant Change: This is a new rule that establishes the necessary procedures for providing gas direct access to customers and for reconciling the difference between a customer’s actual gas usage and the quantity of gas that was delivered on the customer’s behalf. Rule and Regulation 13 - Shortage of Supply and Interruption of Delivery: This establishes terms and conditions under which utility service may be interrupted. CMR:148:99 Page 3 of 5 Significant Change: The title has been changed to "Shortage of Supply and Interruption of Delivery of Energy and Gas". Language was added to establish the necessary procedures for curtailing customers’ gas supply services. The rule establishes penalties for noncompliance by gas commodity service providers to gas direct access customers and CPAU’s full-service customers. Gas Service Provider Agreement The Gas Service Provider Agreement (Attachment III) is a required contractual agreement between the gas commodity provider and the City. The Gas Service Provider Agreement was modeled after the Electric Direct Access Service Provider Agreement (DASPA) and PG&E’s Core Transport Agent agreement. The proposed Gas Service Provider Agreement was designed for phase I of the plan, direct access for large CPAU gas customers, and a separate agreement may be needed for the subsequent phase-in of smaller customers. In general, the Gas Service Provider Agreement covers: (1)term and termination, (2) contract quantity, (3) formal communications, (4) default and remedies for default, and (5) metering protocols. RESOURCE IMPACT The rule revisions, new rules, and Gas Service Provider Agreement are not expected to have any significant impact of Utilities revenues. POLICY IMPLICATIONS The proposed Gas Service Provider Agreement and changes to the rules and regulations do not represent a policy change for CPAU’s large customers. The Natural Gas Direct Access Implementation Plan proposes a schedule and structure for providing direct access to all CPAU gas utility customers if feasible. ENVIRONMENTAL REVIEW Approval of revisions to these Utility Rules and Regulations does not constitute a project under the California Environmental Quality Act. Therefore, an environmental assessment is not required. CMR:148:99 Page 4 of 5 ATTACHMENTS Attachment I - Gas Direct Access Implementation Plan Attachment II - Resolution pertaining to and the Rules and Regulations Numbers 2,6,7,11,12, and 13 Attachment III - Gas Service Provider Agreement Attachment IV - Utilities Advisory Commission Minutes of November 4, 1998 PREPARED BY:Karla Dailey,Resource Planner, SupplyResources Blake Heitzman, Manager, Competitive Assessment Randy Baldsehun, Assistant Director of Utilities Administrative Services DEPARTMENT HEAD APPROVAL: J. Director of Utilities CITY MANAGER APPROVAL: EMILY HARRISON ~~--- Assistant City Manager CMR:148:99 Page 5 of 5 ATTACHMENT I City of Palo Alto Utilities NATURAL GAS DIRECT ACCESS PLAN Acronyms CPAU CGSP CGSPA GDA GSPA GSP MMBTU PG&E UUT Used City of Palo Alto Utilities Core Gas Service Provider Core Gas Service Provider Agreement Gas Direct Access Gas Service Provider Agreement Gas Service Provider; an entity providing supply of firm gas commodity, scheduling and transmission services for delivery to CPA’s points of receipt One million British thermal units ,Pacific Gas and Electric Company Utility User Tax; City ofPalo Alto’s local tax assessed on all utility services INTRODUCTION This attachment provides an overview of the City of Palo Alto Utilities (CPAU) Natural Gas Direct Access Plan. This plan is intended to revise CPAU’s current direct access program for large customers and offer customer choice to all CPAU customers over a 3 year period. This is a general guide to the processes used to effect participation in Gas Direct Access (GDA), including service structure under GDA, phase-in schedule and eligibility criteria. Detailed terms and requirements for large customer GDA will be provided in CPAU’s rules and regulations and in the Gas Service Provider Agreement (GSPA). A Core Gas Service Provider Agreement (CGSPA) may need to be developed for small commercial and residential customers due to metering differences and the need for extremely high reliability. BACKGROUND In 1993, CPAU responded to the deregulation of interstate pipelines by developing a new rate for transportation-only service (G4). The G4 tariff allows noncore customers to purchase gas commodity from an alternate supplier and deliver that gas to CPAU at the California border. Noncore customers are defined as customers who use over 250,000 therms per year and accept lower reliability than the core. Core customers include both residential and small commercial customers who use less than 250,000 therms per year and large customers who require the highest reliability, To date, no customers have elected the G4 tariff primarily due to CPAU’s competitive prices. On March 1, 1998, a portion of PG&E’s intrastate pipeline became open access allowing marketers to move gas within the state and offer bundled services closer to the customers’ meter. CPAU is responding to this by revising the existing tariffs and rules to give noncore customers maximum choice and flexibility to take advantage of this in their natural gas supply portfolios. PG&E COMPARISON Noncore customers on PG&E’s system (including wholesale customers such as CPAU) have been able to directly procure gas commodity since November 1987. In fact, PG&E is planning to phase out the gas commodity tariff‘for noncore customers in three years. In addition, PG&E has offered aggregation as a means to allow small customers access to the gas market since 1991. Core aggregation has had little market participation, however, PG&E has recently lowered some of the barriers to entry and is currently aggressively marketing the program. NATURAL GAS DIRECT ACCESS OPTIONS Deregulation of the natural gas utility industry has opened up a competitive market, allowing customers access to the gas commodity market. Staffproposes that all CPAU customers will eventually have the following two options under Gas Direct Access: 1)Polo Alto Provider: The customer may elect the City as its full service provider. In this case, the customer is not required to take any action. CPAU will continue to be responsible for furnishing the customer with all of its natural gas service needs Outside Provider - Gas Direct Access: Noncore customers may elect to purchase natural gas commodity from a Gas Service Provider (GSP), and core customers may elect to purchase natural gas commodity from a Core Gas Service Provider (CGSP). CPAU will then transport the gas from PG&E’s backbone system to the customer site using CPAU’s existing contractual local transmission rights and distribution system. CPAU will contract with a pool manager to handle gas operational and administrative tasks. All GSPs/CGSPs will work directly with CPAU’s pool manager. GSP/CGSP Responsibilities, The GSP/CGSP shall be responsible for supplying natural gas and associated services to meet the load of their customers. Their duties will include, but may not be limited to, load forecasting, allowance for shrinkage, .monthly balancing, daily balancing during operational emergencies, nominations on interstate and intrastate pipelines, settlement payment obligations, and associated reporting. GSPs/CGSPs will be responsible for billing and collecting from their customers the charges, surcharges and taxes associated with gas services rendered, including the City’s utility users tax (UUT). The billing details for the core aggregation program will be established at a later date. CPAU Responsibilities Because CPAU serves core customers, CPAU has been allocated capacity on PG&E’s low cost backbone transmission pipeline. CPAU will assign a pro rata share of this capacity to GCSPs serving core customers within Palo Alto. CPAU, through its designated pool manager, will be responsibl~ for providing local transmission services (through CPAU’s contract with PG&E), distribution services, metering services, balancing services, and scheduli.ng confirmation and imbalance notification. CPAU will deliver the gas from CPAU’s pool point at the terminus of PG&E’s backbone system to the customer’s site utilizing CPAU’s contractual rights and its distribution sysiem. CPAU, through a contracted meter data manager, will provide customer meter data to the GSP/CGSP and the pool manager. CPAU is also responsible for billing customers for charges, surcharges the UUT and other taxes associated with local transmission and distribution services rendered. Thus, a GDA customer will receive a bill for commodity services from the GSP/CGSP and a bill for local transmission and distribution services from CPAU. As a pass-through ofPG&E’s ruies, CPAU will impose monthly balancing on the GDA customers according to CPAU’s Rules and Regulations. Also in compliance with PG&E, CPAU will impose daily balancing during an operational emergencies declared by PG&E. This means that (C)GSPs will have to match gas nominations with actual gas usage each day within a given tolerance band. Any resulting imbalance charges will be levied on the GSP/CGSP. The penalties associated with imbalance services will be consistent with those of PG&E and will be provided in the Rules and Regulations. The following table is a summary of GSP/CGSP and CPAU’S responsibility under Gas Direct - Access: TABLE 1: Responsibilities of Parties Under GDA * Deliver natural gas to CPAU pool point * Provide for losses from point of receipt to customer location * Provide day ahead load forecasting * Financial responsibility for their customers imbalances * Bill customer for natural gas commodity and all (C)GSP services *Bill customer for UUT *Submit all required nominations * Contract with a Pool Manager to provide some of the services below * Provide local transmission to city gate * Meter customer usage * Provide distribution services from city gate to customer *Bill customer for distribution and all CPAU services * Bill customer for UUT * Provide balancing services through tolerance band * Schedule CPAU pool with PG&E * Bill GSP/CGSP for imbalances and noncompliance during an operational emergency DIRECT ACCESSREQUIREMENTS Requirements for Noncore Natural Gas Direct Access Services In order to take advantage of GDA~ noncore customers must apply for direct access service in writing. GSPs will be required to sign a Gas Service provider Agreement (GSPA) and present a security deposit. Customers will be required to sign an authorization for Direct Access service designating the GSP as their commodity supplier. Requirements for Core Natural Gas Direct Access Services GDA for core customers is currently an undeveloped program. CGSP may be required to aggregate a minimum volume of load, which will be defined in the Pules and Regulations. CGSPs shall be required to sign a P~equest for Gas Aggregation Services with CPAU, present a security deposit, and sign a CGSPA. Customers will indicate, by a simple form, that they wish to receive gas commodity services from a specific CGSP. PHASE-IN PROCESS CPAU recognizes current technical and operational constraints that must be considered in order to facilitate an orderly transition to full GDA for all customers. These constraints include metering and billing, and availability of the new customer information system. CPAU intends to ensure that all the logistics of GDA implementation will occur in a timely, cost- effective, efficient and satisfactory manner. Therefore, GDA implementation shall be phased-in as mitigation of constraints allows it. CPAU believes that a phase-in approach over several years will result in a more successful implementation of GDA than a full opening before all constraints are removed and systems are fully tested. GDA phase-in is planned to occur in three one-year periods contingent on the items cited above. The first open season is scheduled to commence in May, 1999 for the noncore class (customers. who are already eligible for G4). The second and third phases will be for core customers but are also contingent on the items cited above. Assuming CPAU moves forward with a core aggregation program, all customers will be eligible for GDA by July 2001. Allocation and Eligibility , Customers have been divided into these major eligibility segments: 1. Noncore customers: Commercial/industrial accounts with demand greater than 250,000 terms per year. 2. Commercial Core:Commercial/industrial accounts with demand less than 250,000 terms per year. 3. Residential Core:All residential accounts. Table 2 shows when customer segments may participate in GDA. Once an account is designated eligible, it continues to be eligible through subsequent phase-in periods. The noncore class is currently eligible for the G4 rate, and will have an opportunity to participate in the revised program in the first phase. As part of the cost of service study currently underway, sta,ffis 4 investigating the possibility of allowing customers to combine’ accounts. This would increase number of customers eligible for GDA in the first phase. TABLE 2: Natural Gas Direct Access Phase-In Schedule Phase Customer Open Direct Annual Number Eligibility Season Access Volume of Begins (MMBTU)Accounts Phase 1 Noncore May 1999 July 1999 59,000 10 Phase 2 Commercial Core May 2000 July 2000 200,000 2,529 Phase 3 Residential May 2001 July 2001 120,000 20,588 Notifications and Open Seasons As shown in Table 2, open seasons for eligible customers will initiate each phase-in period. The open season will provide a reasonable window of opportunity for customers to evaluate their options and give CPAU time to pi-epare to serve those customers who chose GDA. However, staff is currently evaluating whether GDA applications will be valid year round. Application Process During an open season, interested customers shall submit an application for eligible accounts to be entered into the GDA. Splitting of an account load between a GSP/CGSP and CPAU will not be allowed. Within the application, the customer shall specify CPAU’s account number, service address and total load of each account for which the customer wishes to obtain an alternate GSP. CPAU will verify eligibility and notify the customers as such within 5 days &the end of the open season period. Once all requirements have been met, including execution of all necessary agreements and any necessary metering changes, and the initial service date of GDA has been established, then the customer may purchase its gas requirements from a GSP/CGSP. The account shall continue to participate in GDA for as long as the customer chooses to do so, subject to the terms of GDA agreements and CPAU’s Rules and Regulations. CHANGES TO GAS DIRECT ACCESS SERVICE The customer shall provide CPAU advance written notice to: (1) voluntarily terminate GDA service; (2) apply to materially change the gas usage requirements for GDA; (3) change GSP/CGSPs. Acceptance of any voluntary service change may be subject to CPAU’s gas supply availability or other operational requirements. Other terms and conditions related to suspension or termination due to customer or GSP/CGSP default will be delineated in the GDA rule and the GSPA. If, after a termination, a customer wishes to participate in GDA, the customer would need to reapply for participation in the next open season period. ATTACHMENT II RESOLUTION NO. RESOLUTION OF THE COUNCIL OF THE CITY OF PALO ALTO APPROVING AND ADOPTING RULES AND REGULATIONS GOVERNING UTILITY SERVICES AND FEES AND CHARGES EFFECTIVE JULY I,1999 WHEREAS, pursuant to Chapter 12.20 of the Palo Alto Municipal. Code the City Council may by resolution adopt rules and regulations governing utility services and the fees and charges therefor; and WHEREAS, the City Council has determined to revise the existing rules and regulations and to adopt new rules and regula- tions, tobe effective July i, 1999; NOW, THEREFORE, the Council of the City of Palo Alto does hereby RESOLVE as follows: SECTION I. Pursuant to Section 12.20.010 of the Palo Alto Municipal Code,¯ the amended and the new rules and regulations governing utility services, and the fees and charges therefor, attached hereto and incorporated herein, are hereby approved and adopted. Except as specifically amended by this resolution, all existing utility rules and regulations shall remain in full force and effect as of the date of their original adoption. SECTION. 2. This Council finds that the adoption of this resolution will not have a significant impact on the environment. SECTION 3. July I, 1999. The foregoing changes shall become effective INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST:APPROVED: City Clerk APPROVED AS TO FORM: Mayor APPROVED: Senior Asst. City Attogney City Manager bif~ctor of Administrative- Services Director of Utilities 981110 syn 0071555 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 ABBRE .VIATIONS: ADQ - AMK - Btu - ccf - CPAU - CPUC DA’ - DASPA - EFO - ERU ESP FERC GDA GSP GSPA kVar kVarh kW kWh MDQ - MMBTU - OFO - PAMC - PG&E - PT - RWQCP - UUT - Average Daily Quantity Automated Meter Reading British Thermal Unit hundred cubic feet City of Palo Alto Utilities California Public Utilities Commission. Direct Access Direct Access Service Provider Agreement Emergency Flow Order Equivalent Residential Unit Energy Service Provider Federal Energy Regulatory Commission Gas Direct Access Gas Service Provider Gas Service Provider Agreement Kilovar Kilovar-hours Kilowatt Kilowatt-hour Maximum Daily Quantity Megawatt One million Btus. Operational Flow Order Palo Alto Municipal Code Pacific Gas and Electric Company Pacific Standard Time Regional Water Quality Control Plant Utilities Users Tax CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 1 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 B. GENERAL DEFINITIONS: Account The identification number in CPAU’s billing system for utility services. Administrative Services Director The individual designated as the director of administrative services under Section 2.08.150 of Chapter 2.08 of Title 2 of the Palo Alto Municipal Code, and any Person who is designated the representative of the director of administrative services. Agency --- Any local, county, state or federal governmental body or quasi-governmental body, including, without limitation, the CPUC, the FERC and any joint powers agency, but excluding the City and any board, commission or council of the City. Aggregated Load The combined Load of all Eligible Customers, measured in MMBtu per Day, served by a Gas Service Provider within the City. Average Daily Quantity Also "ADQ". The monthly contracted for quantity of natural gas with the City divided by the number of Customer’s operating days in that month. Applicant An individual, corporation, partnership, agency, or other legal entity or authorized agent of same, requesting CPAU to supply any or all of the following: 2. 3. 4. 5, 6, 7. Electric Service Water Service Gas Service Sewage Collection Refuse and Recycling Collection Storm Drain Service Fiber Optic Service Backbone Transmission System That portion of PG&E’s system used to transport gas from PG&E’s interconnection with interstate pipelines, other local distribution companies, and the California gas fields to CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 2 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 PG&E’s local transmission and distribution system as defined by Rule I of PG&E’s gas tariff or applicable sections. Balancing Agent CPAU’s Gas Balancing Agent as designated by PG&E form 79-869, "Customer Authorization for Agent to Act for Customer with Respect to Gas Balancing and Rule 14 Services and Obligations" or replacement form. Balancing Service CPAU’s service to accommodate imbalances between actual Customer Gas usage and Customer-owned gas delivered to CPAU. Billing Period Also "service period" or "billing cycle". The normal billing cycle for CPAU Customers is monthly. The number of days in the billing cycle or billing period is determined by the number of days between meter reads. A Customer’s meters are read approximately every 27-33 days. On an average basis, a billing period is 30 days. The Billing Period for Gas Direct Access Customers will coincide with PG&E’s billing cycle for gas transportation. Billing Therms The number of billing units for natural gas that is based on the metered consumption (in ccf) multiplied by the product of an altitude pressure adjustment and a Btu factor (heating content of natural gas which varies monthly). One (1) therm equals 100,000 Btu. British Thermal Unit Also :’Btu". The standard unit for measuring a quantity of thermal energy. Business Day Any Day, except a Saturday, Sunday, or any Day observed as a legal holiday by the City. Capacity The total quantity of natural gas that can be transported over the applicable portions of PG&E’s pipeline system or the Distribution System for a specified period of time or at point(s) of interconnection. Charge Any assessment, cost, fee or levy for natural gas, gas transportation or related services, energy, or energy-related services other than a Tax, including any Transition Cost CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-3 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Recovery Charge, Public Benefits Charge, and other such mandated or required public surcharges. Charter The Charter of the City of Palo Alto. City Attorney The individual designated as the city attorney of the City under Section 2.08.120 of Chapter 2.08 of Title 2 of the Palo Alto Municipal Code, and any Person who is designated the representative of the City Attorney. City Clerk The individual designated as the city clerk of the City under Section 2.08.110 of Chapter 2.08 of Title 2 of the Palo Alto Municipal Code, and any Person who is designated the representative of the City Clerk. City Manager The individual designated as the city manager of the City under Section 2.08.140 of Chapter 2.08 of Title 2 of the Palo Alto Municipal Code, and any Person who is designated the representative of the City Manager. City of Palo Alto Also "City". The government of the City of Palo Alto, a chartered city and a municipal corporation duly organized and validly existing under the Laws of the State of California, with a principal place of business located at 250 Hamilton Avenue, Palo Alto, County of Santa Clara. City of Palo Alto Utilities The term CPAU shall mean all utilities operated by the City of Palo Alto. Such utilities shall include, but not be limited to, water, gas, electric, sewage collection, refuse collection, storm drain, and fiber optics. The City of Palo Alto is the legal entity which owns and is responsible for the City of Palo Alto Utilities. City’s Pool(s) The identification number(s) assigned to CPAU by PG&E in CPAU’s Natural Gas Service Agreement which may be used to nominate gas for delivery to CPAU. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PAL(] ALTO UTI,LITIES Sheet No. - 4 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Code The words "the Code" or this Code" shall mean the Palo Alto Municipal Code. Core Customer All residential Customers, commercial and industrial Customers physically connected to the Distribution System whose natural gas use is less than 250,000 Therms per year, and all commercial and industrial Customers physically connected to the Distribution System whose gas use is 250,000 Therms per year or greater and who are not served under a Noncore Rate Schedule. Core Market Customer ~ A customer who purchases full gas service from CPAU under one rate schedule that includes gas supply, distribution services from CPAU, and pipeline transportation services. Commercial Service Commercial utility service is provided to businesses, non-profit organizations, and industrial customers. In addition, applies to utilities services through a master meter serving multi-family residential dwellings. Cubic Foot of Gas Also "cf". The quantity of gas that, at a temperature of sixty (60) degrees Fahrenheit and a pressure of 14.73 pounds per square inch absolute, occupies one cubic foot. Curtailment The act of reducing or interrupting the delivery of natural gas. Customer The person, corporation, agency, or entity in whose name service is rendered for a particular account as evidenced by the signature on the application, contract, or agreement for service. In the absence of a signed instrument, a customer shall be identified by the receipt of any payment of bills regularly issued in the name of the person, corporation, or agency regardless of the identity of the actual user of the service. Customer Fiber Customer single mode and/or multi-mode fiber optic cables that can be installed to interconnect to locations within City of Palo Alto limits, but outside of CPAU established single mode network path. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 5 DEFINITIONS AND ABBREVIATIONS RI J-LE AND REGULATION 2 Customer-Owned Generation An electric generator owned by the Customer, interconnected with and operating in parallel with CPAU facilities. Dark Fiber A strand of optic transmission material within a fiber optic cable that is provided by CPAU without any of the light transmitters, receivers, or electronics required for telecommunications over the fiber. Day Any calendar day, unless a Business Day is specified, commencing at 12:00:00 a.m. PST on a calendar day and ending at 12:00:00 a.m. PST on the following calendar day. Decatherm A unit of energy equal to ten Therms or one million Btu (MMBtu). Default Rate Schedule The rate schedule to which a Customer is assigned automatically by CPAU for a period of twelve months, in the event a Customer does not elect a specific rate schedule determined by CPAU to be available at that time. Demand The highest rate of delivery of electric energy, measured in kilowatts (kW) or kilovolt amperes (kVA) occurring instantaneously or registered over a fixed time period (normally fifteen minutes unless otherwise specified within a monthly billing cycle). Demand Charge An electrical charge or rate that is applied to a metered demand reading expressed in kilowatts to compute a demand charge component of a Customer’s electric bill. Direct Access Also "DA". The election by a Customer to procure its electricity, and related energy services, from an Energy Service Provider, other than CPAU. In this situation, a Customer deals directly with an ESP for commodity supply, while distribution and applicable transmission services would continue to be provided by CPAU. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 6 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Direct Access Metering Also "DA Metering". An electromechanical device capable of recording or transmitting energy use to effect Direct Access, including any communication system or services needed to allow the access to meter read information. Such metering shall conform to the standards and specifications currently adopted by CPAU. Direct Access Plan Also "DA Plan." The document detailing the processes and procedures adopted by CPAU to effect and allocate participation in Direct Access within CPAU’s Service Territory, including phase-in schedule, eligibility criteria and selection processes. Direct Access Service Request Also "DASR". The form required to initiate Direct Access Service. Direct Access Service Provider Agreement Also "DASPA". Also referred to as Direct Access Service Provider Contract (DASPC). The contract between CPAU and the DA Customer’s Energy Service Provider that delineates the terms and conditions under which Energy Services may be scheduled or nominated to the City’s Schedule Coordinator and transmitted to the DA Customer. Distribution Services Includes, but is not limited to, utility service provided by the Distribution System and other services such as billing, meter reading, administration, marketing, and customer services. Distribution System The infrastructure owned and operated by CPAU which is capable of transmitting electrical power or transporting water, wastewater, or gas within the City of Palo Alto. The electric distribution system transmits power from the City’s interconnection with Pacific Gas and Electric Company to CPAU’S meter located on the Customer’s premises. The gas distribution system transports gas from Pacific Gas and Electric Company receiving stations to CPAU’s meter located on the Customer premises. The water distribution system transports water from the San Francisco Water Department receiving stations and CPAU wells to the meter located on the Customer premises. The Wastewater Collection System transports sewage from the Customer’s premises to the Water Quality Control Plant. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-7 DEFINITIONS AND ABBREVIATIONS RI ILE AND REGULATION 2 Distribution and Transmission Services Services provided by CPAU to effect the physical delivery of Energy Services provided by the Energy Services Provider from the Point of Receipt to the Direct Access Customer’s Service Address. Diversion See PG&E Rule 14 or replacement Rule. Effluent Partially or completely treated sewage flowing out of any sewage treatment facility. Eligible Customer Any Person who is authorized by the City to receive gas from a GSP or energy from an ESP, or both. Emergency Flow Order Also, "EFO". See PG&E’s Rule 14 or replacement Rule. Emergency Service Electric Service supplied to, or made available to, load devices which are operated only in emergency situations or in testing for same. Energy Services Energy commodity and any applicable ancillary services used to generate and transport such commodity from its origin to the City’s Point of Receipt. May also mean the sale of value added services associated or related to the provision and/or usage of energy commodity. Energy Service Provider Also "ESP." The agent employed by the DA Customer obligated to procure, schedule, nominate, and transport Energy Services. ESP shall also include any and all agents or contractors employed or utilized by ESP in performance of its obligations, including scheduling coordinator(s). Equivalent Residential Unit Also "ERU". This is the basic unit for computing storm drainage fees. All single-family and duplex units are billed 1 ERU and are considered to have an impervious area of 2,500 square feet. All other non-residential properties have ERU’s computed to the nearest 1/110 ERU using this CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 8 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 formula: No Of ERU=Impervious Area (sq.ft.) /2,500 sq.ft. , Full Service Provision by CPAU of both Distribution and Transmission Sei’vices, and Energy or Gas Commodity Services to its Customer, Also known as "Fully Bundled Service", Gas Any combustible gas or vapor, or combustible mixture of gaseous constituents used to produce heat by burning. It shall include, but not be limited to, natural gas, gas manufactured from coal or oil, gas obtained from biomass or from land fill, or a mixture of~ any or all of the above. Gas Day Any calendar day, commencing at 7:00:00 a.m. Pacific Standard Time on a calendar day and ending at 7:00:00 a.m. Pacific Standard Time on the following calendar day. Gas Direct Access Also "GDA." The election by a Customer to procure its natural gas, and related natural gas services, from a Gas Service Provider, other than CPAU. In this situation, a Customer obtains natural gas commodity directly from a GSP, but local transmission of the natural gas commodity is effectuated by CPAU in accordance with the terms of CPAU’s Natural Gas Service Agreement with PG&E..Also, distribution services would continue to be provided by CPAU. Gas Direct Access Service Request Also "GDASR". The form required to initiate Gas Direct Access Service. Gas Service Provider Also "GSP". The Person who procures, schedules, nominates and arranges transport of natural gas to Gas Direct Access Customers, including its successors and assigns. Gas Service Provider Agreement Also "GSPA". The contract between CPAU and the Gas Direct Access Customer’s Gas Service Provider that establishes the terms and conditions under which Gas services may be provided to the Gas Direct Access Customer. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-9 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Imbalance Charge A fee that is imposed by CPAU as a result of actions taken by the GSP when the confirmed gas nominations which are accepted and scheduled by PG&E do not match the Gas Direct Access Customer’s Load. Inspector The authorized inspector, agent, or representative of CPAU. Interstate Transportation (or Transmission) Transportation of natural gas on a pipeline system under the regulation of the FERC. Intrastate Transportation (or Transmission) Transportation of natural gas on the PG&E system under the regulation of the CPUC. Kilovar (kVar) A unit of reactive power equal to 1,000 reactive volt-amperes. Kilovar-hours (kVarh) The amount of reactive flow in one hour, at a constant rate ofkilovar. Kilowatt (kW) A unit of power equal to 1,000 watts. Kilowatt-hour (kWh) The amount of energy delivered in one hour, when delivery is at a constant rate of one kilowatt; a standard unit of billing for electrical energy. Law Any administrative or judicial act, decision, bill, certificate, charter, code, constitution, opinion, order, ordinance, policy, procedure, rate, regulation, resolution, rule, schedule, specification, statute, tariff, or other requirement of any district, local, municipal, county, joint powers, state, or federal agency, or any other Agency having joint or several jurisdiction over the Parties to this Contract, in effect either at the Commencement Date or during the Term hereof, including, without limitation, any regulation or order of an official or quasi-official entity or body governing the applicable service provided by the City to which a Customer may be subject or bound. CITY OF PALO ALTO UTILITIES - Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 10 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Load(s) The electric power demand (KW) of the Customer at its Service Address within a measured period of time, normally 15 minutes or the quantity of gas required by a Customer at its Service Address, measured in MMBtu per Day, Load Profiling A methodology which may be employed by CPAU, in lieu of DA Meeting, to compute the bill for all DA Customers who have accounts that do not require, or are exempt from, Direct Access Metering. The methodology may include application of a class-average hour-by-hour load profile to determine a monthly average usage profile appropriate for that class of customer. Local Transmission System PG&E’s pipelines used to accept gas from the Backbone Transmission System, and transport it to the Distribution System. Main Sewer Line Any sewer line not including a building connection (service) sewer. Master-metering Where CPAU installs one service and meter to supply more than one residence, apartment dwelling unit, mobile home space, store, or office. Maximum Daily Quantity Also "MDQ". The maximum quantity of Gas that can be nominated daily, as specified in Exhibit A of the Gas Service Provider Agreement. Meter The instrument owned and maintained by CPAU that is used for measuring either the electricity, gas or water delivered to the Customer. Meter Read The recording of usage data from metering equipment Minimum Charge The least amount for which service will be rendered in accordance with the rate schedule. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 11 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Noncore Customer A commercial or industrial customer whose gas use is 250,000 Therms per year or greater and who is served under a non-core Rate Schedule. Occupied,Domestic Dwelling Any house, cottage, flat, or apartment unit having a kitchen, bath, and sleeping facilities, which is occupied by a person or persons. Open Season CPAU’s process used to advertise and take applications from Eligible Customers for obtaining Direct Access or Gas Direct Access services. Operational Flow Order Also "OFO". See PG&E’s Rule 14 or replacement Rule. Person Any individual, for profit corporation, nonprofit corporation, limited liability company, partnership, limited liability partnership, joint venture, business trust, sole proprietorship, or other form of business association. PG&E City Gate " The point at which PG&E’s Backbone Transmission System connects to PG&E’s local transmission and distribution system. Point of Delivery (POD) Unless otherwise specified, .that location on the Customer’s’Premises where the CPAU circuit and Customei’s electrical wiring are interconnected or the point(s) on the Distribution System where the City delivers natural gas that it has transported to the Customer. Point of Receipt The designated location at which CPAU receives energy supplied by an ESP and/or Scheduling Coordinator on behalf of a DA Customer or the designated location at which CPAU receives gas supplied by a GSP on behalf of a GDA Customer. The Points of Receipt for energy will be designated in the DASPA as one of the NCPA Points of Receipt, the Palo Alto City Gate meter or other specified point(s). The Point of Receipt for gas will be the City’s Pool or other specified point(s). CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 12 DEFINITIONS AND ABBREVIATIONS RI ILE AND REGULATION 2 Pole Line Overhead wires and overhead structures, including poles, towers, support wires, conductors, guys, studs, platforms, cross arms braces, transformers, insulators, cutouts, switches, communication circuits, appliances attachments, and appurtenances, located above ground and used or useful in supplying electric, communication, or similar or associated service. Pool A nomination tool provided by PG&E that allows the aggregation of natural gas supply from several sources. Pool Manager The Person designated by the City to perform a variety of tasks related to management of the City’s Pool, which may include nominations through the City’s Pool, imbalance tracking, accounting, and billing. Power Factor The percent of total power delivery (kVA) which does useful work. For billing purposes, average power factor is calculated from a trigonometric function of the ratio of reactive kilovolt-ampere- hours to the kilowatt-hours consumed during the billing month. Premises All structures, apparatus, or portion thereof occupied or operated by an individual(s), a family, or a business enterprise, and situated on an integral parcel of land undivided by a public street, highway, or railway. Primary Service CPAU electric distribution Service provided to a Customer’ s premises at a voltage level equal to or greater than 1000 volts. Provision Any agreement, circumstance, clause, condition, covenant, fact, objective, qualification, restriction, recital, reservation, representation, term, warranty, or other stipulation in a contract or in Law that defines or otherwise controls, establishes, or limits the performance required or permitted by any party. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY QF PALQ ALTO UTILITIES Sheet No. - 13 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Prudent Utility Practices The methods, protocols, and procedures that are currently used or employed by utilities to design, engineer, select, construct, operate and maintain facilities in a dependable, reliable, safe, efficient and economic manner. Public Benefits Charge Mandated charge on electric bills to fund qualifying energy and low-income customer programs and services that benefit the public good in accordance with AB 1890. Public Works Department City of Palo Alto department responsible for providing storm drain, wastewater treatment, and refuse and recycling services. Rate Schedule One or more tariff sheets setting forth the charges and conditions for a particular class or type of utility service. A rate schedule includes wording such as Schedule number, title, class of service, applicability, territory, rates, conditions, and references to rules. Recyclable The material is recyclable if it is easily collected and processed and there is a demand for it. The most common recyclable materials are paper, glass, metal, and some plastics. Recyclable materials are processed, manufactured, and reused in order to regain material for human use. Residential Service Utility service provided to separately metered single family or multi-family, domestic dwelling. Scheduling Coordinator An entity providing the coordination of power schedules and nominations to effect transportation and distribution of electric power and energy. Secondary Service CPAU electric distribution service provided to a Customer’s premises at a voltage level less than 1000 volts. Service Address The official physical address of the building or facility assigned by CPAU’s Planning Department, at which Customer receives utility services. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 14 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Service Charge A fixed monthly charge applicable on certain rate schedules that does not vary with consumption. The charge is intended to recover a portion of certain fixed costs. ’ Services or Service Lines Facilities of CPAU, excluding transformers and meters, between CPAU’s transmission or distribution system and the Point of Delivery to the Customer. Service Territory The geographic boundaries within the City of Palo Alto limits served by the physical distribution system of the CPAU. Shrinkage The volume of natural gas expressed as a percentage that is not delivered to a Customer due to the physical operation of the Interstate Transmission System or the Distribution System, or both. Sole Discretion An individul will base a decisionupon factors as is deemed appropriate by that individual, and that individual will not be required to state any reason for the decision. Standby Service Back-up energy services provided by CPAU to a DA customer who returns to CPAU for commodity supply service on short notice either due to ESP not providing commodity supply service or by choice of the Customer. Tax Any assessment, charge, imposition, license, or levy (including any utility users tax) and imposed by any Agency, including the City. Temporary Service Service requested for limited period of time or of indeterminate duration such as, but not limited to, service to provide power for construction, seasonal sales lot~ (xmas trees), carnivals, rock crushers or paving plants. Temporary service does not include emergency, breakdown or standby service. Therm A unit used to measure a quantity of heat for natural gas that is equal to 100,000 British Thermal CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 15 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Units (Btu). Tolerance Band The percentage of gas usage, on a Monthly basis, as set by PG&E in its Schedule G-BAL or replacement tariff at which PG&E and CPAU will’provide Balancing Service at no additional Charge. Transition Cost Recovery Also "TCR." Mandated charge on all electric bills to fund the CPAU repayment of costs of fixed and variable costs of above-market generation which may be characterized as "stranded costs". Trap Any approved equipment or appliance for sealing an outlet from a house-connection sewer to prevent the escape of sewer gas from a main line through a building connection (service) sewer. Uncontrollable Force Any cause beyond the control of the party affected, including but not restrcted to, failure of or threat of failure of facilities, .flood, earthquake, storm, drought, fire, lightening, epidemic, war, riot, civil disturbance, or disobedience, labor dispute, labor or material shortage, sabotage, restraint by court order or action by public authority, which by exercise of due diligence such party could not reasonable have been expected to avoid and which by exercise of due diligence it shall be unable to overcome. Underground Utility District An area in the City within which poles, overhead wires, and associated overhead structures are prohibited or as otherwise defined in Section 12.04.050 of the PAMC. Utilities Department City of Palo Alto department responsible for providing water, gas, electric, wastewater collection, and fiber optic services. Utilities Director The individual designated as the director of utilities under Section 2.08.200 of Chapter 2.08 of Title 2 of the Palo Alto Municipal Code, and any Person who is designated the representative of the director of utilities. Utility Rules and Regulations The compendium of utility rules and regulations prepared by the Department of Utilities and adopted by ordinance or resolution of the Council pursuant to Chapter 12.20 of the Palo Alto Municipal Code, as amended from time to time. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALtO UTILITIES Sheet No.-16 DEFINITIONS AND ABBREVIATIONS RULE AND REGULATION 2 Utilities User Tax Also "UUT". City of Palo Alto tax imposed on utility charges to a water, gas, and/or electric service user. Charges include charges made for metered energy and water and charges for service including customer charges, service charges, standby charges, charges for temporary services, demand charges, and annual and monthly charges. In 1987, Palo Alto voters approved a 5 percent tax on utility charges for water, gas, and electricity to raise revenue for general governmental purposes of the City of Palo Alto. A reduced tax of 3 percent was approved for qualifying high volume users. The tax does not apply to Refuse, Storm Drain, or Wastewater Collection charges. (END) CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-17 ESTABLISHMENT AND REESTABLISHMENT OF CREDIT RULE AND REGULATION 6 A.ESTABLISHMENT OF CREDIT FOR RESIDENTIAL SERVICE: The Applicant’s credit will be established: If the Applicant is the owner of the residence to which CPAU is requested to supply service; or If the Appli£ant makes a sufficient cash deposit with CPAU to secure payment of any bills for service to be supplied by CPAU; or If the Applicant has previously been a Customer of CPAU within the past two years and during the last twelve consecutive months of that prior service has not received more than (2) five-day past due notices, and provided that the credit of the Applicant is unimpaired in the opinion of CPAU; or If the Applicant’s credit is otherwise established to the satisfaction of the Utilities Supervisor, Customer Service Center. B.ESTABLISHMENT OF CREDIT FOR COMMERCIAL SERVICE: The Applicant’s credit will be established: If the Applicant makes a sufficient cash deposit with CPAU to secure payment of any bills for service to be supplied by CPAU; or If the Applicant provides, in lieu of a cash deposit, a certificate of deposit drawn on a local bank or savings and loan association, or a surety bond sufficient to secure the payment of any bill for service to be supplied by CPAU; or 3.If the Applicant’s credit is otherwise established to the satisfaction of CPAU.. C.REESTABLISHMENT OF CREDIT: An Applicant who has been a utility Customer of CPAU and whose service has been discontinued for any reason, including failure to pay utility bills, may be required to reestablish credit before service is resumed, by making a cash deposit and by paying all past due bills outstanding. However, an Applicant for residential CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 ~...::.. ’:: :- ~, CITY OF PALO ALTO UTILITIES Sheet No.-1 ESTABLISHMENT AND REESTABLISHMENT OF CREDIT RULE AND REGULATION 6 service will not be denied service for failure to pay past due bills outstanding for other classes of service. The requirement to pay past due bills under this section is not applicable to Customers who have filed for bankruptcy. A Customer who fails to pay utility bills before they become past due, and who further fails to pay such bills within the time required by a second notice of nonpayment, may be required to reestablish credit by making a cash deposit with CPAU and by paying all past due bills outstanding regardless of whether or not service has been discontinued for nonpayment. A Customer may be required to reestablish credit in accordance with this section if the conditions of service or basis on which credit was originally established have, in the opinion of CPAU, materially changed. 4.RE-ESTABLISHMENT OF CREDIT FOR GAS SERVICE PROVIDERS An applicant who is a Gas Service Provider and.who fails to pay billing statements on or before the due dates as prescribed in the Gas Service Provider Agreement and the Utility Rules and Regulations or has been referred to a collection agency for collection shall be required to re-establish its credit with CPAU as a condition precident to the resumption of service. The Gas Service Provider may re-establish credit by: (A)Paying all past Charges, plus interest, due and payable to CPAU, and (B)Posting of a security deposit in the amount and form satisfactory to the City Attorney. D.CUSTOMER CREDIT RATING SYSTEM: A credit rating system has been established by CPAU for all accounts and is shown on a Customer’s utilities bill statement. The following ratings are based on a Customer’s rolling 12-month payment history in terms of the Customer’s record in paying bills before they became due. "A" is the highest rating and means the Customer paid before the due date in at least 11 of the 12 previous months. "B" means the Customer usually paid before CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-2 ESTABLISHMENT AND REESTABLISHMENT OF CREDIT RULE AND REGULATION 6 the due date but in two or three months paid after the due date. "C" means the Customer customarily pays after the due date and did so between 4 to 7 times over the previous 12 months. "D" means the Customer is habitually delinquent and paid after the due date at least 7 times over the previous 12 months. In addition, Customers who have had their service terminated for non-payment automatically receive a "C" or "D" rating based on the number of notices, regardless of how frequent or infrequent they paid previous bills before they were due. (END) CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 3 DEPOSITS RULE AND REGULATION 7 AMOUNT OF DEPOSIT: 1.The amount of a deposit shall be set forth in Customer Deposits Rate Schedule C- 2, If a Customer has been delinquent on more than once in the past twelve months the deposit may be set higher than is set forth under the applicable rates in Rate Schedule C-2. This amount shall not exceed a sum equal to twice the estimated monthly utilities bill. Where a deposit is made for commercial service, CPAU may from time to time require an additional deposit to offset increases in utility rates or increased utility usage. If a Customer files for bankruptcy protection under Chapter 7, Chapter 11, or Chapter 13, the Customer shall be required to establish credit under Rule 6.b. 1 and/or 6.B.2. The requirement for a deposit may be waived by the Supervisor, Utilities Customer Service Center if: (A) (13)- He/she is satisfied of the creditworthiness of the Customer based upon a prior history with CPAU and/or; An audited financial report is provided of recent operations which indicates to the satisfaction of the Supervisor, Utilities Customer Service Center that the business is financially healthy and/or; Deposits can be in the form of a certificate of deposit at a local bank or savings and loan, indemnity or surety bond, or cash. A security deposit may be required from an Energy Service Provider (ESP) providing Direct Access Service to Palo Alto Customers. The terms relating to the amount, collection, return or use of the security deposit will be included in the Direct Access Service Provider Agreement (DASPA) signed CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 1 DEPOSITS RULE AND REGULATION 7 between the ESP and CPAU. RETURN OF DEPOSIT: Upon discontinuance of service, CPAU will refund the Customer’s deposit or the balance thereof which is in excess of unpaid bills for service furnished by CPAU. If the deposit is unclaimed for a period of one year after discontinuance of service, the deposit will become the property of CPAU. CPAU may refund a Customer’s deposit by draft or by applying the deposit to the Customer account and the Customer will be advised. If the Customer establishes service at a new location, CPAU may retain the deposit for such new account in partial or total fulfillment of the deposit obligation for the new account. Residential deposits will be refunded at the end of one year of service provided all bills for service have been paid before they become past due. Deposits held for commercial service shall be refunded when service is discontinued by the Customer, or after three years if all bills for service during the recent 12 month period have been paid before they become past due. 6.CPAU will not pay interest on customer deposits. SECURITY DEPOSITS FOR GAS SERVICE PROVIDERS The Gas Service Provider shall be responsible for paying to CPAU any pool administration Charges, Imbalance Charges, Taxes,. and any other City Charges that may arise from the provision of Gas services to Eligible Customers. The Gas Service Provider shall place a security deposit with CPAU to secure the payment of the Charges referred to herein before the Gas Service Provider may provide Gas commodity services to any Eligible Customer. A security deposit in the amount of $90 per MMBtu of MDQ (rounded up to the nearest MMBtu) shall be due and payable on the date that the CPAU CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 UTILITIES Sheet No. - 2. DEPOSITS RULE AND REGULATION 7 t autho?izes the Gas Service Provider to commence the delivery of Gas. The deposit shall secure the payment of all Charges payable by the Gas Service Provider to CPAU, including, without limitation, the pool administration Charges, Imbalance Charges, Taxes, gas commodity replacement Charges, and any other applicable City Charges. The form of the security deposit shall be: (A)Cash, which shall earn no interest during the term of the deposit with CPAU; or (B)Irrevocable and renewable Standby Letter of Credit issued by a major U.S. financial institution reasonably acceptable to the City, acting by and through the Administrative Services Director; or (c)Renewable surety bond issued by a major insurance company or admitted surety acceptable to the City and in a form acceptable to the City Attorney, or A certificate of deposit, the term of which is renewable for successive terms of not less than one (1) year each, that is assigned to the City; or (E) Other form of security deposit acceptable to the City. Security deposits shall be held as long asthe Gas Service Provider provides Gas services in CPAU’S service territory. (END) CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 % ,:.".:. ~ CITY OF PALO ALTO UTILITIES Sheet No. - 3 BILLING, ADJUSTMENTS,AND PAYMENT OF BILLS RULE AND REGULATION 11 At PREPARATION AND PRORATION OF BILLS: Bills for utility services will be prepared on a monthly basis in accordance with the rate schedule or CPAU contract applicable to the premises served, as determined by CPAU. The monthly minimum or service charge for metered water (and related wastewater), gas, or electric service, as well as the consumption "blocks" if applicable for opening, closing, or regular bills, will be prorated on the basis of the number of days in the service period to the number of days in an average month. The number of days in an average month will be taken as 30.4. The effect of such proration will be to produce a uniform average unit cost for the commodity regardless of the number of days in the service period. In the event that water, gas, electric, refuse, wastewater and/or storm drain rates change during the service period, charges will be prorated on the basis of the number of days covered by the previous rate schedule to the number of days covered by the new rate schedule. The monthly (or bimonthly) flat-rate charge for refuse, storm drain and wastewater or other nonmetered services will be billed 12 times per year, or equivalent thereof on regular bills. Such charges will only be prorated on opening or closing bills and when rates change. BILLING UNITS: 1.All metered’ billing units used for billing purposes shall be determined to the nearest whole unit. Such units may include, kW, kWh, kVa, kVar, hp, therms, and or ccf. C.PAYMENT OF BILLS: CPAU issues’ bills to its customers on a monthly basis. Bills shall be deemed received upon personal delivery to Customer or three days following the deposit of the bill in the United States Mail to the Customer’s last known address. Bills for CPAU services are due and payable 20 days following issuance of the bill statement. Bills unpaid after the 20 CITY OF PALO ALTO UTILITIES Issued by the City Council .... ,~’~2111 Effective 9-1-99 ~..- CITY OF PALO ALTO UTILITIES Sheet No. - 1 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 day period are considered delinquent. If a Customer’s payment is not received by CPAU before the next bill statement is issued, the outstanding balance in excess of $100 will be assessed a late payment charge in accordance with this rule. For the convenience of CPAU Customers there are a number of ways to pay CPAU bills: By enclosing the bill stub and check and mailing to: CPAU, P.O. Box 10097, Palo Alto, CA 94303-0897. By paying in person at the Civic Center, Revenue Collections, 1st Floor, 250 Hamilton Avenue, Palo Alto between the hours of 8:00 a.m and 4:30 p.m.. Visa and Master card payments can be processed at Revenue Collections. By dropping the payment in the Night Depository Box either in the from of the Civic Center Plaza or at the drive-up Night Depository Box in the Civic Center Garage, A level. By banking at a financial institution or subscribing to a service company that provides automatic payments by telephone transfer between the Customer and the bank. This involves the Customer notifying (by touch tone telephone) the bank or service company each month of the utilities bill amount, the amount is deducted from their bank account, and the bank issues a check to CPAU. LATE PAYMENT CHARGES: Any unpaid balance above $100 from a prior billing period is delinquent and assessed a late payment charge. Utilities charges incurred in the current billing period are due and payable by the "Due Date" indicated on the front of the bill statement. Bills’unpaid by the due date are considered delinquent and a late payment charge is added to the outstanding balance if payment is not received before the next bill is rendered. Based on the particular merits of a given situation, late payment charges may be waived by CPAU. Examples of situations where a waiver is granted are generally those under which the Customer is faced with circumstances beyond his or her control. Two examples are: (A) The posting of payments received by CPAU is delayed or in error. CITY OF PALOALTO UTILITIES Issued by the City Council ..... ,,~,’~;i Effective 9-1-99 ~.... ~:: ’::: " CITY OF PALO ALTO UTILITIES Sheet No. - 2 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 (B)The Customer is withholding payment or partial payment pending resolution of an inquiry, In the event the Customer makes a payment of less than the total amount of bill rendered, which amount includes any previous balance owing, CPAU shall apply said payment first to the previous billing charges and the remainder, if any, to the current billing charges unless otherwise agreed to by CPAU. In the event that a Customer participating in the ProjectPLEDGE Program has a delinquent bill, late charges will not be applied. However, the Customer’s participation in ProjectPLEDGE will be discontinued after three consecutive months in which the Customer has not included their pledge amount in the bill. The late payment charge will be computed on the balance forward using the following schedule: If Balance is: $ 00.00 to 99.99 100.00 to 199.99 200.00 to 299.99 300.00 to 399.99 400.00 to 499.99 500. 00 and up Late Payment Charge Per,Month is: None 1.1 percent 1.2 percent 1.3 percent 1.4 percent 1.5 percent Subparagraphs D(1) and D(2) to the contrary notwithstanding, Customers whose CPAU bills include payments of principal and/or interest on loans from CPAU which are secured by deeds of trust on real property shall be charged a late payment charge when any current CPAU bill includes an unpaid installment on such loan from a prior bill, provided that twenty (20) days have elapsed since the day of the last billing. For closing bills, the elapsed time will be thirty (30) days. The late charge on such loan payment shall be six percent (6%) of the installment due or fine dollars ($5), whichever is greater. No charge will be imposed more than one for a late payment for the same installment; provided, however, that the imposition of the late charge on any late payment will not eliminate or supersede late charges imposed on prior late payments. No late charge will be imposed on any installment which is paid or tendered in full CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 3 BII,LING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 on or before its due date, or within the ten (10} days after notice is given that the late charge will be imposed even though an earlier installment or installments, or any late charges thereon, may have been paid in full when due. For purposes of determining whether late charges may be imposed, any payment tendered by the Customer shall be applied by CPAU to the most recent installment due. Nothing in this Rule and Regulation shall be construed to alter in any way the duty of the Customer to pay any installment on a loan from CPAU when due or to alter the fights of CPAU to enforce the payment of such installments. Nothing in this subparagraph shall alter the payment or collection of late Charges assessed in accordance with subparagraphs (1) and (2) of this Rule and Regulation for CPAU bills or portions thereof which do not include payments on loans secured by real property. In the event a Customer’s payment of principal and interest is past due on an unsecured loan from CPAU, the applicable late payment charge may be established in the contract with the customer, RETURNED CHECK CHARGE: A service charge will be made and collected by the City of Palo Alto for each . check returned by a bank to CPAU for the reason of insufficient funds in accordance with Rate Schedule C- 1. DISPUTED BILLS: 1.CORRECTNESS OF BILL If the correctness of a bill is questioned or disputed by the Customer, an explanation should be requested from a Utilities Customer Service Representative within five (5) days of receiving the utility bill.. If the bill is determined to be incorrect, a corrected bill will be issued to the Customer. 2.BILL REVIEW PROCEDURE (A)A Customer who has initiated a complaint or requested an investigation within five (5) days of receiving the utility bill shall be given an opportunity to review the complaint with the Supervisor, Customer Service Center. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-4 BILLING, ADffUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 (c) The review shall include consideration of whether the Customer should be permitted to amortize the unpaid balance of their account over a reasonable period of time. After reviewing the disputed bill, the Supervisor, Customer Service Center will: (1) Authorize any necessary adjustments; or (2) Advise the Customer that the bill is correct as presented; and (3) Determine if an amortization period is warranted. If an amortization period is warranted and agreed to by the Customer, service will not be discontinued for nonpayment provided the Customer complies with the amortization agreement, and provided the current bill is paid within 20 days of the date issued. If the Customer fails to comply with the amortization agreement, service shall be subject to discontinuance for nonpayment of bills as provided in Rule 14. (E)Failure of the Customer to notify CPAU of a billing error or to request an explanation of charges within 20 days of the date of the bill will constitute acceptance by the Customer of the bill as rendered. PAYMENT OF BILLS IN DISPUTE If a Customer disputes a specific utility charge on a utilities bill covering multiple utilities, the bill amount for utility services which are not in dispute shall be due and payable by the date due on the bill statement. The Customer is not obligated to pay the utility charge in dispute while CPAU is investigating the disputed charges. Upon completion of the investigation, CPAU will notify the Customer if and when a payment is required. BILLING ADJUSTMENTS: Under certain circumstances, CPAU will adjust a Customer’s bill to correct for billing error or for reasons of equity and fairness. Such adjustments are generally of a one-time nature. Billing error is the incorrect billing of an account due to an error by CPAU or the CITY OF PALO ALTO UTILITIES Issued by the City Council "~:,%2Effective 9-1-99 ~ .,... CITY OF PALO ALTO UTILITIES Sheet No. - 5 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION ,11 Customer which results in incorrect charges to the Customer. Some billing errors also arise if the Customer provides incorrect information to CPAU. Billing adjustments applied to Customer charges for reasons of equity and fairness include water or gas leak credits, smoothing, and in cases where excessive consumption of water, gas, and/or electricity occurred and where Customers rented debris boxes as a result of the Customer’s reasonable efforts to mitigate or remedy property damage or loss caused by an event of force majeure. Billing errors include, butare not limited to, incorrect meter reads or meter read estimates, clerical errors, wrong therm factors, wrong meter multiplier, incorrect voltage discount, meter installation, crossed meters, undercharges due to meter tampering, an inapplicable rate, an oversight in the process of entering the appropriate meter information into the computer system for billing, or field errors such as installing the meter or regulator incorrectly. 1.SMOOTHING ADJUSTMENT A smoothing adjustment averages the usage of a customer over two billing periods. The Supervisor, Customer Service Center or a designated representative shall determine if a smoothing adjustment is indicated, A smoothing adjustment may be appropriate if consumption between two billing cycles changes to an extraordinary high level and is caused by the following. (1) An estimated meter reading by CPAU; or (2) A longer or irregular billing cycle. 2.METER ERRORS AND OTHER BILLING ADJUSTMENTS (A)When, as a result of a test, a meter is found to be more than two percent (2%) fast, CPAU will refund the Customer the overcharge based upon the corrected meter readings for the period the meter was in use. When, as a result of a test, a meter in residential use is found not to register, or to register more than ten percent (10%) slow, CPAU may bill CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 6 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND P~GULATION 11 (c) the Customer for the undercharge base on an average bill. The bill will be computed upon an estimate of consumption based upon the Customer’s prior use. When, as a result of a test, a meter in other than residential use is found not to register, or to register more than two percent (2%) slow, CPAU may bill the Customer for the undercharge base on an average bill. The bill will be computed upon an estimate of consumption based upon the Customer’s prior use during the same season of the year. APPLICABLE ADJUSTMENT PERIOD FOR METER ERRORS, RETROACTIVE BILLING, AND REFUNDS When it is found that a meter is recording in error or an error in billing has occurred, the date and cause of which can be reliably established, the retroactive billing adjustment will apply as follows: (A)Where the Customer has been undercharged, the period to be backbilled shall not exceed 6 months; Where the Customer has been overcharged the period to be refunded shall not exceed 12 months; Where there is evidence that theft of energy or water has occurred, CPAU shall retroactively bill and collect any underpayment or nonpayment of charges. The applicable period to assess charges shall be from the date it can be reasonably established the theft began to the date in which the underpayment was discovered and initially established. The applicable period shall not exceed 4 years. 4.WATER OR GAS LEAK CREDITS: Billing adjustments may be made for water or gas lost as a result of leakage in a line on the Customer premises beyond the CPAU meter. Leaking faucets, toilets, hoses, or sprinklers do not qualify for a billing credit unless a determination has been made by CPAU that the Customer had no control of such device(s) leaking. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 7 BILLING,ADffUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 Under no circumstances will a billing credit be provided a Customer when the facts indicate that a Customer had knowledge of a water or gas leak, but failed to take corrective measures in a timely manner. It is the Customer’s responsibility to maintain their lines and equipment in a reasonable condition such that leaks do not occur. Generally, a leakage credit will be granted for a one month billing cycle. However, depending on the circumstances, a two month billing cycle may be granted by the Supervisor, Customer Service Center. Such circumstances include, but are not limited to, a leak occurring while a Customer is out of town for an extended period of time. Leak credits will not be provided beyond a two month billing cycle. (B)All Customer classes are eligible for the leak credit. To qualify for the water leak credit, evidence of having repaired the leak is required. Such evidence may consist of a plumber’s repair bill material receipt or field verification by CPAU. Customers who are negligent or slow to react in repairing a leak do not qualify for a leak credit. (0 To arrive at the corrected bill amount which reflects the leak credit, CPAU will estimate what would have been the normal consumption and calculate a normal bil! based on that consumption. Then, actual consumption in excess of the normal figure will be billed at CPAU’s current wholesale commodity cost plus ten percent. The sum of these two calculations represents a revised billing amount. The leak credit is the difference between the revised billing amount and the original bill. BILLING ADJUSTMENTS IN CONNECTION WITH FORCE MAJEURE EVENTS For purposes of this Rule and Regulation, the term "force majeure" means the occurrence of an event that is beyond the reasonable control of the utility Customer and, which by reasonable efforts, the Customer could not prevent. Such events include, but are not limited to, an Act of God, an irresistible, superhuman cause, fire, flood, earthquake, or any other similar cause. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-8 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS KULE AND REGULATION 11 03)Water, Gas, and/or Electric A water, gas, and/or electric billing adjustment in connection with a force majeure event shall be limited to charges for water, gas, and/or electricity consumption in excess of the historical average for the customer The billing adjustment will be applied as a credit on the customer’s bill. The credit is for the amount of excess usage and represents the difference between the amount charged for the applicable period and an amount calculated based on the customer’s average consumption for a similar period. This credit shall include a refund of any applicable utilities users tax that was based on the amount of excess usage. (2)The Director of Utilities shall determine the historical average consumption. Depending on the availability of data and other reasonable considerations, the basis for calculating such averages may be the same month(s) in a previous year, a recent 12 month average, a 6 month seasonal average for winter or summer, or other appropriate period(s) as determined by the Director of Utilities. (c)Debris Boxes (1)A billing adjustment or refund in connection with debris boxes shall be limited to Palo Alto Sanitation Company charges incurred or to be incurred out-of-pocket by the resident, owner, or business for removal of flood-damaged materials only. Refunds will not be applied to charges paid through insurance policies. The Palo Alto Sanitation Company will keep a record of those residences and businesses that request debris boxes during the applicable refund. period. (D)To qualify for an adjustment under this section, the customer may be required to provide documentation to verify damage to the residence or building, or contents thereof. In circumstances in which the City has previously verified such damage such as by a field visit or has made a determination from other information resources, documentation from the customer may not be required. However, to qualify for a refund for debris . CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 9 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND. REGULATION 11 box rentals, a signed statement by the customer is required that attests that the debris box was used for flood-damaged materials only and that the Customer has not and will not be reimbursed by homeowners insurance or any other agency. H.BUDGET BILLING PAYMENT PLAN: A Budget Billing Payment Plan establishes equalized monthly payments and is available to all residential Customers who qualify as set forth below. Customers may join the Budget Billing Payment Plan at any time prior to July 1, the beginning of the annual budget payment cycle, providing however, the Customer account balance is zero, and the Customer has not been removed from the budget plan for non-payment within the previous six months. A Customer electing to Utilize the plan shall agree to make monthly payments based on CPAU’s estimate of the Customer charges for the twelve-month period July 1 through the next June 30, reflecting anticipated rate changes. CPAU does not guarantee that the total actual charges will not exceed or be less than its estimate. CPAU will review the account on a periodic basis and may revise its estimate in response to changing rates or variations in the amount of service used. CPAU may require that Customers pay a revised monthly amount as a condition to continuing participation in the plan. 4.DISCONTINUANCE OF BUDGET BILLING: The budget payment plan shall remain in effect from year to year, subject to review of the monthly payment amount, and shall terminate when: (A) (B) (C) (O) (E) The customer notifies CPAU to terminate participation in the plan; CPAU notifies the customer of the termination of its budget payment plan: The Customer no longer takes service at the premises; or The Customer owes an amount of two or more monthly payments. However, if the customer eliminates the delinquency, removal from the plan will not occur. The Customer participates in Direct Access and buys from another Energy CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-10 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 Service Provider. Upon termination of either CPAU service or participation in the budget payment ¯ plan, any amount owned by the Customer for actual charges shall immediately become due and any amount due the Customer shall be refunded as soon as possible. RESALE PROHIBITED: Services shall be used by Customer only for the purposes specified in the service agreement and applicable rate schedule(s). CPAU service shall not be resold except as provided in this rule. Premises which are receiving service in conflict with this Rule as of the effective date of this Rule may continue to receive service under such conditions if so authorized in writing by CPAU. Sub-metering shall be considered .sufficient evidence that utilities are being resold, with the exception of provision I-4 below. Property owners may bill the cost of providing utilities’ to individual tenants separately from rent only with consent of the Assistant Director of Utilities, Administrative Services. Charges for utilities may be allocated based upon metering, square footage, or another methodology determined to be reasonable by CPAU. Under no circumstances can the total costs of CPAU services allocated to tenants exceed the costs of CPAU services billed to the property owner by CPAU. A property owner using a billing procedure coming within the scope of this Rule must disclose all information used to determine a tenant’s utilities bill to the tenant or CPAU, or both, upon request. Property owners are responsible for resolving utility bill disputes with their tenants. Tenants may request and receive from CPAU a copy of previous bills for a period not to exceed 12 months, charged to the property owner who sub-meters. J.ACCOUNTING, BILLING, AND PAYMENT FOR GAS SERVICE PROVIDERS CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 11 BILLING, ADJUSTMENTS, AND PAYMENT OF BILLS P~ULE AND REGULATION 11 1.INFORMATION CHARGES CPAU shall charge, and the Gas Service Provider shall pay, for any non- confidential or non-proprietary information requested by the Gas Service Provider pertaining to the Eligible Customer which is in addition to information normally provided in accordance with CPAU’s procedures. BILLING All billings between the Gas Service Provider and CPAU for services under a Gas Service Provider Agreement shall be performed by CPAU or the Pool Manager on a calendar month basis. (A)All billing statements shall reflect the period from 7:00:00 a.m. PST on the first Day of each calendar month until 7:00:00 a.m. PST hours on the first Day of the following calendar month; provided, however, the billing statements for any partial first month and partial last month of service shall be prorated by the number of Gas Days of service during such month. Bills sent to the Gas Service Provider shall be sent to the appropriate billing address specified in the Gas Service Provider Agreement. (c)Payments for amounts billed to the Gas Service Provider shall be due on the last Day of the month in which the billing statement is issued or the fifteenth (15th) Day after receipt of the billing statement, whichever is later. Payments for amounts owed by CPAU to ~the Gas Service Provider shall be applied as a credit to the Gas Service Provider’s bill within the time in which the Gas Service Provider is required to pay CPAU’s bills. If, as a result of the credit, the Gas Service Provider is owed money, CPAU shall make payment in accordance with this Rule. Payment shall be made at the offices designated in The Gas Service Provider Agreement, or by electronic funds transfer to accounts specified in The Gas Service Provider Agreement. (D) Amounts not paid on or before the due date shall be payable with CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 \ .~:~.:,.-. CITY OF PALO ALTO UTILITIES Sheet No. - 12 BILLING,ADJUSTMENTS, AND PAYMENT OF BILLS RULE AND REGULATION 11 o (E) interest accrued at the rate of one percent (1%) per month, or the maximum interest rate permitted by Law, whichever is less, prorated by Days from the due date to the date of payment. When payments are mailed to CPAU, the billing statements shall be deemed paid on the dates of receipt by CPAU. If the Gas Service Provider disputes the accuracy of. any portion of the billing statement, then the Gas Service Provider shall pay the undisputed portion within the time required herein. Upon a determination that any disputed amount should be paid bythe Gas Service Provider, the Gas Service Provider shall pay such amount, plus accrued interest, at the rate established in this Rule. (F)CPAU shall adjust a billing statement as deemed reasonably necessary by the Utilities Director for any billing statement error that is established. All adjustments or billing statement errors shall be resolved promptly as practicable, and, upon resolution, shall be included in the billing statement for the next regular Billing Period. RECORDS CPAU and the Gas Service Provider Shall keep accounting records and books for two (2) years in accordance with generally accepted accounting principles and practices in the industry. CPAU and the Gas Service Provider shall have the right to examine those books and the accounting records of the other during that two-year (2-year) period. Any examination will be at the examining Party’s expense, must be conducted at a reasonable time, and must be confined to the extent necessary to verify the accuracy of any statement, charge, or computation or any demand made under or as a result of transporting Customer-owned Gas. " (END) CITY OF PALO ALTO UTILITIES Issued by the City Council "~ ....--," .... Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. - 13 NATURAL GAS DIRECT ACCESS RULE AND REGULATION 12 A.APPLICAB~ITY This Rule applies to Gas Direct Access Customers and Gas Service Providers providing Gas service to Gas Direct Access Customers in accordance with the provisions of Schedule G,4 and the Gas Service Provider Agreement. GENERAL 1. NATURE OF SERVICE The Gas Service Provider will deliver or have delivered to PG&E quantities of Gas in accordance with PG&E Gas Rule 21, and PG&E will deliver equivalent quantities of Gas adjusted for in-kind Shrinkage allowance, on a Btu-for-Btu basis, into the City’s Pool. From the City’s Pool, CPAU will use the Local Transmission System and Distribution System to deliver or have delivered the equivalent quantities of Gas to the Customer’s Point of Delivery. The Gas delivered to the Customer will not necessarily be the Gas that the Gas Service Provider delivered to PG&E or CPAU. 2.GAS SPECIFICATIONS Do Unless otherwise agreed to by both parties, the gas delivered to CPAU must meet the quality specifications detailed in PG&E’s Rule 21 or replacement rule. The minimum and maximum heating value and the pressure of the gas must be such that the gas can be integrated into CPAU’s system of the Point(s) of Receipt. DELIVERY INTO PG&E SYSTEM The Gas Service Provider must deliver the quality of Gas, allowance for in-kind shrinkage, and minimum volumes to PG&E under the nominations procedures spelled out by PG&E in its Gas Rule 21. All nominations must be communicated to the Pool Manager thirty (30) minutes prior to PG&E’s deadlines. DELIVERY INTO THE CITY’S POOL CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO AL~O UTILITIES Sheet No. - 1 NATURAL GAS DIRECT ACCESS RULE AND REGULATION 12 o IN-KIND SHRINKAGE ALLOWANCE - LOCAL DISTRIBUTION The in-kind shrinkage quantity represents the unaccounted-for gas attributable to the volume of gas received by CPAU for Gas Direct Access service. Gas Service Providers shall deliver each Gas Day at the Point of Receipt an additional in-kind quantity of Gas equal to two and one half percent (2.5%) of the total volume of Gas to be delivered. NOMINATIONS AND NOMINATION CHANGES e The GSP will conform to both CPAU nomination standards and PG&E nomination standards when coordinating gas nominations with the Pool Manager. (A)All nominations shall be communicated to the Pool Manager in accordance with PG&E Rules except for a thirty (30) minute nomination deadline adjustment by facsimile transmission to the number set forth in the Gas Service Provider Agreement. Nominations that are accepted and scheduled by PG&E will be confirmed by the Pool Manager to the Gas Service Provider. (c)If the Gas Service Provider fails to provide the proper nomination information, then the Gas Services Provider will be required to pay any Imbalance Charges imposed by PG&E on CPAU due to that failure. EMERGENCIES The Gas Service Provider shall respond to Curtailments, Operational Flow Orders, and Emergency Flow Orders in accordance with Rule 13. DAILY USAGE MEASUREMENT For purposes of determining daily usage, Noncore Customers are required to have CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CiTY OF PALO ALTO UTILITIES Sheet No. - 2 TRANSPORTATION OF NATURAL GAS RULE... AND REGULATION 12 Fo Meters that can record daily usage. Telemetering will be installed on Noncore Customers’ meters, where CPAU determines that it is cost effective. SECURITY DEPOSITS AND REESTABLISHMENT OF CREDIT Security deposits will be made by the Gas Service Provider in accordance with Rule 6. Credit may be reestablished in accordance with Rule 7. ADDITIONAL FACILITIES Transportation of Gas does not obligate CPAU to construct any additional facilities or to modify any existing facilities to provide receipt of Gas into CPAU’s system. POSSESSION OF GAS The Gas Service Provider shall be deemed to be in control and possession of the Gas until the Gas is delivered to CPAU at the Point of Receipt. The Gas Service Provider shall be deemed to regain control and possession of the Gas upon delivery from CPAU to or on behalf of the Customer. I~NDEMNIFICATION The Gas Service Provider shall indemnify, protect, defend and hold harmless the City, its council members, directors, officers, employees, partners, principals, contractors, agents and representatives, from and against any and all administrative and judicial proceedings and orders, charges, claims, costs, damages, demands, expenses, fines, judgments, liabilities, losses, penalties, including reasonable attorney’s fees and the costs of defense arising, directly or indirectly, in whole or in part, out of the City’s activities or the City’s property and not arising out of the sole negligence or willful misconduct of the City. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-3 TRANSPORTATION OF NATURAL GAS RULE AND REGULATION 12 K.GAS BALANCING FOR GAS DIRECT ACCESS CUSTOMERS Imbalances will be maintained at the City’s Pool. For deliveries made to Direct Access Customers, the Customer’s Gas Service Provider will be responsible for imbalances. All Gas Service Providers must endeavor to ensure that daily Gas deliveries match daily Gas usage. The Customer’s Gas Service Provider will assume responsibility for managing and clearing imbalances for the Aggregated Load served by that Gas Service Provider. The Gas Service Provider shall be responsible, including financially responsible, from the date the Gas Service Provider Agreement goes into effect, for all applicable balancing, capacity allocation and constraint obligations, charges, penalties, and credits related to Gas service. Any existing imbalances and/or adjustments to past imbalances will also become the responsibility of the Gas Service Provider upon the effective date of the Gas Service Provider Agreement. The Gas Service Provider will nominate transportation deliveries to the City’s Pool on behalf of the customer in accordance with this Rule. 1.USAGE MEASUREMENT For purposes of determining daily usage, Noncore Customers are required to have Meters that can record daily usage. Telemetering will be installed on Noncore Customers’ meters, where the City determines that it is cost effective. . o TOLERANCE BAND The Tolerance Band is equal to the percentage of usage in the month the imbalance occurred set by PG&E in PG&E’s Schedule G-BAL or other replacement tariff. ’ CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-4 TRANSPORTATION OF NATURAL GAs RULE AND .REGULATION 12 CUMULATIVE IMBALANCE A Gas Service Provider’s cumulative imbalance shall be the difference, for each calendar month, between the metered usage of its Customers and actual monthly Gas deliveries plus any adjustments carried forward from prior months. A cumulative imbalance quantity will be stated each month on the cumulative imbalance statement. o Any remaining cumulative imbalance, within the Tolerance Band, will be considered the first transaction during the calendar month following the just- completed imbalance period. Any remaining cumulative imbalance in excess of the Tolerance Band will be automatically cashed out. Cashouts will includea commodity cashout only. Commodity cashout prices will be in accordance with PG&E’s Schedule G-BAL or replacement tariff. ACCOUNTING ADJUSTMENTS If accounting adjustments result in a change to a previous cumulative imbalance, then: 1. If any portion of the adjusted quantity was previously subject to an imbalance cashout, the adjusted portion of the cashout will be reversed. 2. Any remaining adjustment quantity will be considered the first transaction ’during the calendar month following the date of notification of the adjustment, unless otherwise agreed to by CPAU. CURTAILMENT OF SERVICE Imbalance Services by CPAU may be curtailed. Details are provided in Rule 13. 6.TERMINATION CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No. TRANSPORTATION OF NATURAL GAS RULE AND REGULATION 12 Upon termination of the Gas Service Provider agreement, any remaining imbalance will be cashed out at the applicable commodity cashout prices. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 9-1-99 CITY OF PALO ALTO UTILITIES Sheet No.-6 SHORTAGE OF SUPPLY AND INTERRUPTION OF DELIVERY OF ENERGY AND GAS RULE AND REGULATION 13 A. GENERAL: CPAU will make reasonable efforts to deliver continuous and sufficient utility service to its Customers, but CPAU does not guarantee the continuity or sufficiency of supply. CPAU will not be liable for service interruption, shortage or insufficiency of utility supply, or any loss or damage occasioned thereby. INTERRUPTION OF DELIVERY: Co When interruptions occur, CPAU will endeavor to reestablish service with the shortest possible delay consistent with the safety of its Customers and the general public. CPAU will have the right to suspend service temporarily for the purpose of maldng repairs of improvements to the system. When CPAU finds it necessary to schedule an interruption to its service, it will, where feasible, notify all Customers to be affected of the approximate time and the anticipated duration of the interruption. CPAU will endeavor to schedule interruptions at hours that will be least inconvenient to the Customers and consistent with economical utility operations. SHORTAGE OF SUPPLY: During times of threatened or actual shortage of supply, CPAU will apportion the available supply among its Customers in accordance with the Emergency Load Shedding Plans, incorporated herein by reference, on file with CPAU. With due regard for public health and safety, these plans will provide for shortages caused by insufficient supply or natural or manmade events which reduce the capacity of CPAU’s suppliers and CPAU is requested to limit the level of delivery to its Customers for some specified period of time of"until further notice." The Director of Utilities is authorized to adjust the Emergency Load Shedding plans to reflect changes in personnel, distribution systems, utility services, or other factors, when, in the opinion of the Director of Utilities such adjustments will lead to better protection of the public health and general welfare. CITY OF PALO ALTO UTUtJTIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. -1 SHORTAGE OF SUPPLY AND INTERRUPTION OF DELIVERY OF ENERGY AND GAS RULE AND REGULATION 13 Do OVERSUPPLY OR POWER SURGES ON THE DISTRIBUTION SYSTEM Power surges may occur due to conditions beyond the control of CPAU or its Customers. CPAU will make reasonable efforts to minimize power surges occurring on the CPAU distribution system, but CPAU does not guarantee that power surges will not occur. CPAU recommends that Customers protect their connected loads and equipment from power surges. CPAU shall not be liable for any loss or damage occasioned by power surges. CAPACITY ALLOCATION; CONSTRAINT OR CURTAILMENT OF NATURAL GAS SERVICE CPAU may reduce, interrupt, or allocate natural Gas supply services for operational reasons in the event of projected or actual supply or capacity shortages. A Point of Receipt service restriction is a reduction of the nominations at the Point of Receipt to match the capacity available in the Distribution system. Gas Direct Access Customers and their Gas Service Providers are solely responsible for providing the necessary services upstream of the Point of Receipt. A Point of Delivery service restriction is a reduction of the daily quantity delivered to the Customer or temporary interruption of the Customer’s service. CPAU will exercise good faith efforts to furnish and deliver continuous service and a sufficient quantity of Gas to Customers, but CPAU does not guarantee continuity of service or SUfficiency of quantity. CPAU shall not be liable for any interruption, shortage, or insufficient supply, or any loss or damage of any kind or character caused by such, if caused by an Uncontrollable Force or any other cause that is beyond CPAU’s reasonable control except that arising from its failure to exercise reasonable diligence. CPAU shall be the sole judge of whether it is operationally able to receive and/or deliver Gas on its Distribution System. CPAU shall not be liable to the Customer for damages, or otherwise, as the result of any interruption, reduction, or allocation of Gas transportation capacity or delivery service. CPAU may, in the exercise of reasonable judgment, reduce receipts or deliveries of natural Gas in order to test, alter, modify, enlarge, or repair any part of the CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO U T I L I T I E S Sheet No. -2 SHORTAGE OF SUPPLY AND INTERRUPTION OF DELIVERY OF ENERGY AND GAS RULE AND REGULATION 13 Distribution System or any facility or property related to the operation of the Distribution System. In all such cases, CPAU shall give the Customers reasonable notice as circumstances will permit, and CPAU shall complete such repairs or improvements as soon as practicable and with minimal inconvenience to Customers. CPAU shall not be responsible for any Curtailment, confiscation, or inability to deliver natural Gas into the PG&E, or any other upstream pipeline, system. CPAU shall not be responsible for any Curtailment or confiscation by PG&E causing an inability to deliver natural Gas into CPAU’s Pool. Any shortfall in deliveries into the City’s Pool must be made up by obtaining third-party Gas supplies, reducing customer usage, or receiving supplies subject to the balancing provisions described in Utility Rule and Regulation 12, if available. 1. RECEIPT POINT CAPACITY ALLOCATION (A) (B) (C) CITY OF PALO Issued by the City Effective 7-1-99 Allocation Because of Non-conformance of Gas to CPAU’s Specifications CPAU has the right and responsibility to maintain the quality standards of the gas in its system. CPAU may refuse to accept gas or to accept limited amounts of gas if the gas is not of the quality required for service to CPAU Customers. CPAU shall be the sole judge of the ability of its system to accept any such gas not conforming to its specifications. (See Utility Rule and Regulation 12.) Allocation Due to Local Constraints CPAU may reduce the amount of gas CPAU receives on the Customer’s behalf due to operating conditions or regulatory requirements affecting all or a portion of CPAU’s system. CPAU will take whatever steps it determines are operationally appropriate in the event a constraint on CPAU’s Distribution System threatens service to Customers. In the event CPAU reduces the receipt of Customer-owned gas for any reason cited above, the Customer must obtain third party gas, stop receiving service, or receive supplies subject to the imbalance provisions ALTO UT]I~ITIES Council CITY OF PALO ALTO UTILITIES Sheet No. -3 SHORTAGE OF SUPPLY AND INTERRUPTION OF DELIVERY OF ENERGY AND GAS RULE AND REGULATION 13 in Utility Rule and Regulation 12 if this service is available. 2. POINT OF DELIVERY SERVICE RESTRICTIONS (A)Reasons for service restrictions O) (2) Operating Constraints CPAU may interrupt or reduce delivery of natural Gas in the event of projected or actual capacity constraints or projected or actual supply shortages on the Distribution System, subject to the priorities set forth in Section 3. Local Constraints In the event of lo~:alized constraints, Customers in unconstrained areas may continue to receive service; provided, however that CPAU may take whatever steps it determines are operationally necessary in the event a constraint on the Distribution System threatens service to Customers. This may include Curtailment of Noncore Customers. 3.CURTAILMENT PRIORITIES In the event of a projected or actual supply Curtailment, Customers will be curtailed in the following order of precedence: 1.Noncore Accounts 2.Core Commercial Accounts 3.Residential Accounts Should the amounts to be curtailed be less than an entire category, CPAU will curtail accounts on a pro rata or rotating block basis. CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO U T I L I T I E S Sheet No. -4 SHORTAGE OF SUPPLY AND INTERRUPTION OF DELIVERY OF ENERGY AND GAS RULE AND REGULATION 13 4.OPERATIONAL FLOW ORDERS, EMERGENCY FLOW ORDERS, AND DIVERSIONS If at any time PG&E imposes an OFO, EFO, or diversion requirements upon CPAU, the Pool Manager, or the Balancing Agent, the Gas Service Provider and all Customers will comply with those restrictions in accordance with PG&E’s Rule 14. If the Gas Service Provider does not comply with the requirements established by PG&E during an OFO, EFO or Diversion, the Gas Service Provider or Customer will pay a noncompliance Charge. The noncompliance charge will be calculated in accordance with PG&E’s Rule 14 or replacement Rule.- This applies to Gas Direct Access Customers and Noncore Full-Service Customers. (END) CITY OF PALO ALTO UTILITIES Issued by the City Council Effective 7-1-99 CITY OF PALO ALTO UTILITIES Sheet No. -5 ATTACHMENT III GAS SERVICE PROVIDER CONTRACT THIS GAS SERVICE PROVIDER CONTRACT ("Contract"), dated as of , 19__, is entered into, by and between the CITY OF PALO ALTO, a municipal corporation of the State of California (~CITY") and ("GSP") (collectively, "Parties", and, individually, ~Party"), in reference to the following facts: A. In the exercise of the powers granted under Article XI, Section 9 of the California Constitution, the Charter, the Palo Alto Municipal Code and other Laws, the Palo Alto City Council has authorized the CITY’s gas utility customers to negotiate with other suppliers of natural gas and other related natural gas services. B. The CITY’s designated Pool Manager will serve as the CITY’s exclusive .agent in connection with the CITY’s exercise of rights and the performance of obligations under this Contract. C. In reliance on the GSP’s due authorization and qualification to provide natural gas commodity services to retail customers in the State of California, the CITY wishes to authorize the GSP to negotiate, directly, with the CITY’s natural gas utility customers in accordance with applicable Laws and the Provisions. The GSP wishes to provide natural gas commodity and related natural gas services to the CITY’s Eligible natural gas utility customers in accordance with applicable Laws and the Provisions. follows: IN CONSIDERATION OF the Provisions, the Parties agree, as ARTICLE 1 .SPECIAL TERMS : INTERPRETATION i.i General. The special terms that are denoted by initial or full capitalized letters in this Contract and its exhibits shall have the meanings set forth in the Palo Alto Municipal Code, the Utilities Rates and Regulations and this Contract, unless the context clearly indicates otherwise. 1.2 Applicable Utilities Rates and Requlation~. The GSP agrees to fully comply with the Utilities Rates and Regulations, including, without limitation, Rule and Regulation numbers 2, 6, 7, iI~ 12 and 13, as may be amended from time to time, and Rate Schedule G-4, as may be amended from time to time, all of which pertain to the provision of natural gas service, and the Provisions of this Contract and its exhibits. 1.3 Consequences of Changes. If the CITY adopts, modifies or repeals any portion of the Utilities Rules and 981218 syn 0071556 1 Regulations that would result in the material and adverse alteration of the rights or obligations of the GSP under this- Contract, then, upon the written request of the GSP, the Parties shall, in good faith, confer and attempt to renegotiate any Provision of this Contract that is directly affected by such adoption, modification or repeal. If the Parties are unable to renegotiate the applicable Provisions of this Contract to their mutual satisfaction within a reasonable time, then any Party may exercise its rights under this Contract or by Law to terminate this Contract. ARTICLE 2.TERM AND TERMINATION 2.1 ~.This Contract will become effective as of (~Service Initiation Date") and will remain in effect, unless and until it is terminated by the GSP or the CITY in accordance with the Palo Alto Municipal Code, the Utilities Rules and Regulations and this Contract. 2.2 Termination by. CITY. The CITY, acting by and through the City Manager in the exercise of his or her Sole Discretion, may terminate for convenience this Contract, and termination hereof shall become effective forty five (45) Days after the date on which written notice of termination is received by the GSP. The GSP may not compel a contrary or different decision on any such matter, and notwithstanding any other Provision of this Contract, the individual exercising such Sole Discretion on behalf of the CITY shall not be liable to the other Party. 2.3 Termination... by GSP. The GSP may terminate for convenience this Contract, and termination hereof shall become effective ninety (90) Days after the date on which written notice of termination is received by the CITY; provided, however, if the CITY adopts, modifies or repeals a special term or condition that has the effect of. materially and adversely altering the GSP’s rights or obligations under this Contract, the GSP may terminate for convenience this Contract forty-five (45) Days after the date on which written notice of termination is received by the Utilities Director, acting on behalf of the CITY. The GSP shall bear the burden of proving to the CITY that the CITY’s adoption, modification or repeal of .a special term or condition will materially and adversely alter the GSP’s rights or obligations under this Contract. 2.4 Termination . for ....Cause. This Contract may be terminated for cause by a Party in accordance with the Provisions of this Contract or by Law. 981218 syn 0071556 2 2.5 Conflicting T~rmination Notices. Nothing in this Contract shall be deemed or construed to prohibit the exercise of a Party’s right to terminate for cause at any time after a right to terminate for convenience has been exercised, but such termination for convenience has not yet become effective. In the event that both a notice of termination for cause and a notice of termination for convenience-have been delivered, this Contract shall terminate on the earlier of the effective termination date of such notice. ARTICLE 3.GAS DIRECT ACCESS SERVICES 3.1 Commliance...with Laws. The Parties, and each of them, shall comply with the applicable Laws in the exercise of their rights and obligations under this Contract. 3.2 Grant of. Authority. In consideration of the mutual covenants, the CITY hereby authorizes the GSP to provide natural gas commodity services and other related natural gas services to one or more Eligible Customers, and the GSP hereby agrees to provide natural gas commodity services and other related natural gas services to the Eligible Customers in accordance with the applicable Laws and the Provisions of this Contract. 3.2.1 Subject to the GSP’s compliance with the conditions precedent governing the initiation of natural gas commodity services to an Eligible Customer, natural gas may be delivered on or after the first Day of the Billing Period immediately following the Service Initiation Date. Natural gas commodity services shall not be provided to an Eligible Customer before the Service Initiation Date that is established for that Eligible Customer. The CITY will not accept any natural gas nomination from the GSP prior to an Eligible Customer’s Service Initiation Date. ~ 3.3 Exercise of Authority. The GSP shall comply with the following preliminary and procedural requirements as a condition precedent to the provision of natural gas commodity services to an Eligible Customer. 3.3.1 The GSP shall obtain an Eligible Customer’s written authorization in the form set forth in EXHIBIT "A" to provide natural gas commodity services. Such authorization shall constitute the Customer’s request to receive Gas Direct Access service from the CITY under Rate Schedule G-4, and shall constitutes the Eligible Customer’s authorization to the GSP to act on the Eligible Customer’s behalf in providing natural gas commodity services to the Customer. 981218 ~yn 0071~56 3 3.3.2 An Eligible Customer who wishes to terminate authorization and commence receiving natural gas commodity services from .the CITY must provide written notice to the CITY to terminate the authorization. The termination may apply to all or some of the Customer’s accounts, as specified in EXHIBIT ~A". A termination of such authorization, in the form as set forth in EXHIBIT ~B", must be submitted to the CITY, and a copy of EXHIBIT "B" must be given to the GSP. 3.3.3 A summary (Exhibit "D") must be completed by the GSP and must be submitted to the CITY, if the GSP provides natural gas commodity service to more than one’ Customer under the Contract. 3.3.4 The GSP shall execute on or before the Commencement Date the CITY’s Standard of Conduct for Affiliates, in the form as set forth in EXHIBIT "F". 3.3.5 The GSP shall post a security deposit in an amount, as set forth in Utilities Rule and Regulation number 7, before it may commence providing natural gas commodity services to an Eligible Customer under this Contract. ARTICLE,,,4.CONTRACT QUANTITIES 4.1 ~____Q. The Maximum Daily Quantity of natural gas, as specified in EXHIBIT ~A", will be the maximum amount of natural gas that the GSP may deliver into the City’s Pool for delivery to an Eligible Customer on any Gas’Day. The MDQ for the GSP shall be equal to the sum of the MDQs of all Eligible Customers served by the GSP. ARTICLE 5.BILLING 5.1 Charoes. The GSP agrees to pay the CITY for all charges associated .with services that the CITY provides to the GSP. These charges shall include, without limitation, imbalance charges, as set forth in Utilities Rule and Regulation number 12, as may be amended from time to time, Operational Flow Order, Emergency Flow Order, and Involuntary Diversion penalties, as set forth in Utilities Rule and Regulation number 13, as may be amended from time to time, and the Pool Administration Charge and the Metering Charge, as set forth in EXHIBIT ~G". 5.2 Payment DUe. The CITY will bill the GSP for any and all services rendered to the GSP under this Contract. The charges shall be due and payable in accordance with Utilities Rule and Regulation number ii as may be amended from time to time. 981218 syn 0071556 ARTICLE 6.METERING AND DEVIATIONS 6.1 Meter standards. The metering standards set forth in the Utilities Rules and Regulations shall govern GSP-Eligible Customer transactions authorized under this Contract. The CITY shall be responsible for collecting, maintaining and storing the Eligible Customer’s historical natural gas meter data, which shall be made available to the GSP, provided that the Eligible Customer authorizes, in writing, such disclosure by the CITY. 6.2 Determination of Load. The CITY or its designated Meter Data Management Agent shall interrogate by means of remote facilities the Eligible Customer’s interval meter data, including, without limitation, the performance of data validations and associated data corrections as may be deemed necessary by the CITY in order for the CITY to prepare settlement-quality data. The detailed information shall be provided to the GSP on a daily basis. ARTICLE 7.GENERAL OBLIGATIONS 7.1 General Obligations. In addition to the other obligations of the GSP specified in this Contract, the GSP shall: 7.1.1 Pay for all Charges due and payable to the CITY; 7.1.2 Comply with all associated reporting requirements; 7.1.3 Endeavor to ensure that daily natural gas commodity deliveries match the daily Eligible Customer’s natural gas usage; 7.1.4 Accept responsibility for imbalances in accordance with Utilities Rule and Regulation number 12; 7.1~.5 Communicate with the CITY’s agent, as necessary, or as deemed appropriate by the CITY, on matters directly affecting the rights and obligations of the Parties under this Contract; 7.1.6 Bill and collect the Charges for natural gas commodity services and related Charges, including, without limitation, Taxes, and file all tax forms, including the Utility Users Tax Remittance Form, as set forth in EXHIBIT ~E"; 7.1.7 Notify the CITY of the names, addresses, telephone numbers and other relevant information of any Person representing the GSP in.connection with this Contract; 7.1.8 Adhere to Prudent Utility Practices in providing natural gas commodity services to Eligible Customers under this Contract; 981218 syn 0071556 5 7.1.9 Assure that its Affiliates meet the standards of conduct in dealing with Eligible Customers, as are set forth in EXHIBIT "F"; 7.2 Eligible C~stQmer Service DisconneGtion. If the CITY r~quires th% discontinuance of natural gas commodity services to an Eligible Customer, the CITY shall notify the GSP only if the CITY’s service to the Eligible Customer’s Accounts is closed permanently in accordance with applicable CITY procedures. In such event, the CITY will give not less than five (5) Days’ prior written notice¯ The CITY shall not be liable for damages for its failure to provide such notice¯ 7~3 Planned,,,,,Curtailment. During a period of planned curtailment, which will affect, substantially, service provided by the GSP to an Eligible Customer, the CITY will attempt to notify the GSP of the curtailment, so that the GSP may make any desired modifications to its Gas nominations that ar4 supplied to the Pool Manager. The CITY will not be liable for damages for its failure to provide such notice. 7.4 Emergency_ Curtailment. Natural gas commodity services provided by the GSP shall be subject to emergency curtailments in accordance with Utilities Rule and Regulation number 13, as may be amended from time to time. ARTICLE 8.REPRESENTATIONS AND WARRANTIES 8.1 warrants : GSP REPRESENTATION.The GSP represents and 8.1.1 It is a corporation duly organized and validly existing and in good standing under the Laws of the State of ¯It has all requisite corporate power and authority to own its property, real and personal, and operate its business as and where it is now being conducted. 8.1.2 It has the power and authority to enter into this Contract and perform its obligations hereunder. The execution, delivery and performance hereof have been duly authorized by all necessary corporate actions and proceedings. This Contract is (and any other instrument, document or writing to be executed and delivered by the GSP pursuant hereto will be) legal, valid and binding obligations of the GSP, and enforceable against the GSP in accordance with the Provisions of this Contract except as may be limited by applicable Laws. 9~121~ syn 0071556 6 8.1.3 The execution and delivery hereof and any other instrument, document or writing contemplated hereby by the GSP will not conflict with or violate or constitute a breach or default under the Articles of Incorporation or Bylaws of the GSP or the provision of any mortgage, trust, indenture, bond, lien, pledge, release,contract, guaranty or instrument to which the GSP is subject. 8.1.4 All information, financial statements, records, reports, resolutions, certifications and other documents or writings which will be submitted by the GSP pursuant to the Provisions of this Contract will be true and correct at the time such information, financial statements, records, reports, resolutions, certifications and other documents or writings are submitted or made available to the CITY. 8.1.5 There are no unresolved claims or disputes between the GSP and the CITY. There are no actions, suits or proceedings pending or, to the knowledge of the GSP, threatened against the GSP that, if adversely determined to the GSP, would materially and adversely affect the ability of the GSP to perform its obligations under this Contract. 8.2 CITy RE~RESENTATIQN. The CITY represents and warrants: 8.2.1 It is a municipal corporation duly organized and validly existing and in good standing under the Laws of the State of California. It has all requisite corporate power and authority to own its property, real and personal, and operate its business as and where it is now being conducted. 8.2.2 It has the power and authority to enter into this Contract and perform its obligations hereunder. The execution, delivery and-performance hereof have been duly authorized by all necessary actions and proceedings. This Contract is (and any other instrument, document or writing to be executed and delivered by the GSP pursuant hereto will be) legal, valid and binding obligations of the CITY, and enforceable against the CITY in accordance with the Provisions hereof except as may be limited by applicable Laws. 8.2.3 The execution and delivery hereof and any other~ instruments, documents or writings contemplated hereby by the~CITY will not conflict with or violate any provision of the Charter or the Municipal Code. 981218 ~yn 0071556 7 ARTICLE 9.ASSIGNMENT 9.1 General. Except as provided by Law, this Contract shall not be assigned, in whole or in part, by a Party without the written consent of the other Party, and any assignment, transfer, license, conveyance, sale, hypothecation or encumbrance hereof by shall be void. ARTICLE i0.WAIVER AND ,, RELEASE I0.I waiver. The consent by a Party to any act by the other Party shall not be deemed to imply consent or to constitute the waiver of a breach of any Provision hereof or continuing~waiver of any subsequent breach of the same or any other Provision, nor shall any custom or practice which may arise between the Parties in the administration of any part of the Provisions hereof be construed to waive or lessen the right of a Party to insist upon the performance by the other Party in strict accordance with the Provisions hereof. 10.2 Release. The CITY will not be liable for interruption, shortage or insufficiency of supply or delivery of Gas, or any loss or damage of any kind or character arising from or related thereto, excepting only such damage arising directly from the CITY’s gross negligence or willful misconduct. ARTICLE Ii.DEFAULT AND REMEDIES FOR DEFAULT I0.i GSP Default. This Contract may be terminated by the CITY upon the occurrence of a default by the GSP under this Contract, and the GSP fails to cure the same within thirty (30) Days or within such longer period of time, as is provided below, after the receipt of notice from the CITY, or, when the cure reasonably requires more than thirty (30) Days, the failure of the GSP to commence to cure within such thirty (30) Days and thereafter diligently and continuously prosecute such cure to completion, including, without limitation, any of the following: i0.I.i Failure to pay any C~arge, when due, unless the GSP in good faith disputes all or any portion of such Charge, in which case the GSP shall pay only the undisputed portion, if any, until such dispute is resolved; 10.1.2 Failure to pay any Tax, when due, or the failure to perform any other obligation requiring the payment of money under the Provisions hereof, and the failure continues for a period of forty-five (45) Days, unless the GSP in good faith disputes all or any portion of such Tax, in which case the GSP shall pay only the undisputed portion, if any, until such dispute is resolved; 981218 syn 0071556 10.1.3 Failure to observe, perform or comply with any material Provision of this Contract required to be observed, performed or complied with by the GSP; 10.1.5 Assignment or transfer of its interest in this Contract, whether voluntarily or by operation of Law, in violation of the Provisions of this Contract; 10.1.6 General assignment of its assets for the benefit of its creditors; 10.1.7 Filing by or against the GSP a petition to have the GSP adjudicated a bankrupt, or a petition for a reorganization or arrangement under any Law relating to bankruptcy or insolvency, unless the same is dismissed within one hundred eighty (180) Days after the same is instituted; 10.1.8 A Person other than the CITY obtains an order or decree in any court of competent jurisdiction enjoining or prohibiting the GSP from performing under this Contract, and such order or decree is not vacated within one hundred eighty (180) Days after the granting thereof, unless the GSP upon the written demand of the CITY indemnifies the CITY against loss or damage suffered by the CITY as a result of the GSP’s nonperformance pursuant to such order or decree; and 10.1.9 Any representation, warranty, or statement made by the GSP in this Contract that shall prove to have been incorrect in any material respect when made. In the event of a default by the GSP, the CITY shall give notice of default to the GSP at least thirty (30) Days before any notice of termination shall become effective. lOf2 CITY Default. This Contract may be terminated by the GSP upon the occurrence of any of the following defaults by the CITY: 10.2.1 Failure to observe,’ perform or comply with any material Provision hereof required to be observed, performed or complied with by the CITY, and the CITY fails to cure the same within thirty (30) Days, or, when the cure reasonably requires more than thirty (50) Days, the failure of the CITY to commence to cure within such thirty (30) Days and thereafter diligently and continuously prosecute such cure to completion; 10.2.2 General assignment of its assets for the benefit of its creditors, or the filing by or against the CITY a petition to have the CITY adjudicated a bankrupt, or a petition for a reorganization or arrangement under any Law relating to bankruptcy 981218 syn 0071556 9 or insolvency, unless the same is dismissed within one hundred eighty (180) Days after the same is instituted, unless the CITY upon the written demand of the GSP indemnifies the GSP against loss or damage suffered by the GSP as a result of the CITY’s non- performance pursuant to such order or. decree; and 10.2.3 A Person other than the GSP obtains an order or decree in any court of competent jurisdiction enjoining or prohibiting the CITY from performing under this Contract, and such order or decree is not vacated within one hundred eighty (180) Days after the granting thereof, unless the CITY upon the written demand of the GSP indemnifies the GSP against loss or damage suffered by the GSP as a result of the CITY’s non-performance~pursuant to such order or decree. In the event of a default by the CITY, the GSP shall give notice of default to the CITY at least thirty (30) Days before any notice of termination shall become effective.. _ 10.3 Remedies. for D~f~ult. In .addition to all other rights and remedies provided by Law or otherwise provided in this Contract, to which the non-breaching Party may resort cumulatively, or in the alternative, the non-breaching Party may: 10.3.1 Except as otherwise provided herein, keep this Contract in effect and enforce all of its rights and remedies hereunder, including the right to payment of Charges as they may become due, by appropriate legal action; 10.3.2 Seek the specific performance hereof by the breaching Party or other rights or remedies at law or in equity; and 10.3.3 Terminate for cause this Contract by giving notice of termination. 10.4 Suspension., If the GSP fails to procure and schedule gas for more than five (5) consecutive Days, or defaults in making payments to the CITY, or otherwise fails to perform its obligations pursuant to this Contract or the Utilities Rules and Regulations, this Contract may be immediately suspended. The CITY shall immediately notify the Eligible Customer of the suspension, which shall remain in effect for thirty (30) Days, after which time the GSP may resume performance of its obligations if the CITY is satisfied with the performance of the GSP. 10.4.1 During the term of the suspension, the Eligible Customer shall be provided service under Rate Schedule number G-3. 981218 8yn 0071556 10 During the term of suspension, the CITY will assume imbalance, EF0, and 0FO responsibilities for the Customer’s Load. 10.4.2 If the failure of performance by the GSP occurs twice in the period of any one year, this Contract may be immediately terminated by the CITY, and the Eligible Customer shall be returned to the CITY’s gas procurement service. 10.5 Uncontrollable....Force. A Party to this Contract shall not be deemed in default under this Contract when such Party’s failure of performance is attributable to an Uncontrollable Force. 10.6 Limitations. NOTWITHSTANDING ANY OTHER PROVISION OF THIS CONTRACT, NEITHER PARTY SHALL BE LIABLE TO THE OTHER FOR ANY CONSEQUENTIAL, EXEMPLARY, INCIDENTAL, INDIRECT, LIQUIDATED, PUNITIVE OR SPECIAL DAMAGES OR LOST REVENUE OR LOST PROFITS TO ANY PERSON ARISING OUT OF THIS’ CONTRACT OR THE PERFORMANCE OR NONPERFORMANCE OF ANY PROVISION OF THIS CONTRACT, EVEN IF SUCH PARTY HAS BEEN INFORMED OF THE POSSIBILITY OF SUCH DAMAGES. THE CITY’S TOTAL LIABILITY FOR ANY CLAIM OR DEMAND OF THE GAS SERVICE PROVIDER ARISING OUT OF THIS CONTRACT SHALL NOT EXCEED THE AMOUNT OF THE CHARGES PAID BY THE GAS SERVICE PROVIDER TO THE CITY PRIOR TO THE DATE OF CLAIM OR DEMAND. [DOES THIS APPLY?] ARTICLE II.NOTICE All notices which shall or may be given pursuant to this Contract shall be, in writing, and delivered by the United States Postal Service, by means of private express delivery systems, or by facsimile transmission, provided a copy of the same is followed by delivery by the United States Postal Service or by private express delivery systems, to the addresses of the parties identified in Exhibit ~C", as stated below. Notices hereunder shall be effective upon receipt to the addressee. ARTICLE 12.MISCELLANEOUS PRO~ISIONS 12.1 Integration. This Contract contains the entire understanding between the Parties with respect to the subject~ matter herein. There are no representations, warranties, agreements or understandings (whether oral or written) between the Parties relating to the subject matter hereof which are not fully expressed herein. 12.2 .Amendments. This Contract may not be amended except pursuant to a written instrument signed by the Parties. All exhibits, which may be amended from time to time, and any addenda and schedules which, from time to time, may be referred to in any 981218 syn 0071556 Ii duly executed amendment to this Contract are by such reference incorporated in this Contract and shall be deemed a part hereof. 12.3 Bin~lina Effect. This Contract shall be binding upon and inure to the benefit of the successors and permitted assignees of the Parties~ 12.4 Headings. The Article headings hereof are inserted for convenience of reference only, are not a part hereof and shall have no effect on the construction or interpretation hereof. 12.5 CounterpartS. This Contract may be executed in any number of counterparts, each of which shall be an original, but all of which together shall constitute one and the same instrument. 12.6 Applicable Law. This Contract shall be governed by and construed in accordance with the Laws of the State of California without regard to its conflicts of laws, rules, or principles. 12.7 _~_~W~. In the event that suit is brought by a Party, the Parties agree that trial of such action shall be vested exclusively in the state courts of California, County of Santa Clara, or in the United States District Court, Northern District of California, in the County of Santa Clara. 12.8 Severability. If any Provision is held by court of competent jurisdiction in a final judicial action to be void, voidable, or unenforceable, such Provision shall be deemed severable from the remaining Provisions and shall in no way affect the validity of the remaining portions hereof. 12.9 Conflicting Provisions. To the extent any Provision of this Contract is in conflict with the Palo Alto Municipal Code or the Utilities Rules and Regulations, the applicable provision that imposes the higher duty on the Parties, and each of them, shall govern. 12.10 Rules of Inter~_retation. Each Party and its counsel have. reviewed this Contract. Accordingly, the normal rule of construction to the effect that any ambiguities are to be resolved against the drafting party shall not be employed in the construction and interpretation hereof. 12.11 Time is o.f Essence. For the purposes hereof, the time in which an act is to be performed ’shall be computed by excluding the first Day and including the last. If the time in which an act is to be performed falls on a Saturday, Sunday, or any 981218 syn 0071556 12 Day observed as a official holiday by the CITY, the time for performance shall be extended to the following Business Day. IN WITNESS WHEREOF, this Contract is duly executed by the Parties on the date first above stated in Palo Alto, County of Santa Clara, California. ~ ATTEST:CITY OF PALO ALTO City Clerk APPROVED AS TO FORM: Senior Asst. City Attorney APPROVED: Assistant City Manager Director of Administrative Services Director of Utilities Risk Manager Mayor GSP By: Name: Title: By: Name: Title: Taxpayer Identification No. (Compliance with Corp. Code § 313 is required if the entity on whose behalf this contract is signed is a corporation. In the alternative, a certified corporate resolution attesting to the signatory authority of the individuals signing in their respective capacities is acceptable) 981218 sya 0071556 13 CERTIFICATE OF ACKNOWLEDGMENT (Civil Code § 1189) STATE OF COUNTY OF ) ) ) On , before me, the undersigned, a notary public in and for said County, personally appeared (check one) [ ] personally known to me ([ ] or proved to me on the basis of satisfactory evidence) to be the person(s) whose name(s) is/are subscribed to the within instrument, and acknowledged to me that he/she/they executed the same in his/ her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the ~entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. CERTIFICATE OF ACKNOWLEDGMENT (Civil Code § 1189) STATE OF COUNTY OF ) ) ) On notary public in and for , before me, the undersigned, a said County, personally appeared ! (check one) [ ] personally known to me ([ ] or proved to me on the basis of satisfactory evidence) to be the person(s) whose name(s) is/are subscribed to the within instrument, and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. 981218 syn 0071556 14 For City Use Contract No Date Received Service Initiation Date Termination Date Revision EXHIBIT ~A" CUSTOMER AUTHORIZATION FOR GAS DIRECT ACCESS SERVICE By this Authorization for Gas commodity service (Authorization), I request Gas Direct Access Service from the City of Palo Alto (CITY), a municipal corporation, and authorize the Gas Service Provider listed below to provide Gas commodity services on my behalf in accordance with the Utility Rules and Regulations. Gas Service Provider (legal name): My Gas Service Provider is authorized to do any and all things both proper and necessary in establishing and administering such service for and on my behalf, including (by way of illustration and not limitation) the purchase, nomination and delivery of Gas supplies, treatment, clearing and mailing payments for Gas imbalances, and all procurement-related transactions for my Palo Alto Utility Gas Accounts set forth in this Authorization. The Service Initiation Date is designated in the Gas Service Provider Agreement. The initial term of this Authorization will be nine (9) consecutive Months from the Service Initiation Date and thereafter will continue month-to-month unless the Customer closes its business, or either the Customer or the Gas Service Provider executes and submits to the CITY Exhibit B, Notice of Termination of Gas Direct Access Service (Notice of Termination). Unless otherwise specified, Notice of Termination received by the CITY prior to the first .Day of the Month will become effective foreach account on the normal meter reading date in the following month. The effected Accounts will transfer to Schedule G-3 service until an~Open Season is declared by the CITY, at which time I may take Gas service under any Optional Rate Schedule. I authorize the CITY to release~ to my Gas Service Provider by written or electronic transfer the current and historical Gas usage information for accounts set forth in this Authorization. I release, hold harmless, and indemnify the CITY from any liability, claims, demands, causes of action, damages, or expenses resulting from unauthorized use of this information. The CITY will provide its services to me in accordance with the terms and conditions of Schedule G-4, Utility Rules and Regulations 2,6,7,11,12 and 13 and any other Utility Rules and Regulations and 981218 Byn 0071557 any modifications thereto authorized from time to time by the Palo Alto City Council. I will continue to be responsible for payment of the CITY’S transportation Charges including PG&E Local Transmission System Charges and CPAU’s Distribution System Charges. I understand that the City Council does not regulate my Gas Service Provider, and that the resolution of, or any losses or damages resulting from any disputes I have with my Gas Service Provider will be my sole responsibility. Billing disputes between me and the CITY will be resolved as specified in the CITY’s Utility Rule and Regulation ii. Accounts My Gas Service Provider will serve the following City accounts be completed by the City): To Gas Service Address Account Number Meter Number Average Daily Quantity Maximum Daily. Quantity I accept the Maximum Daily Quantity of MMBTUs. The MDQ will be the maximum amount of Gas .that the Gas Service Provider will be allowed to nominate into the~City’s Pool on any Day. The MDQ is based on the historical maximum single Day use at the facilities served under the Gas Service Provider Agreement. The MDQ may be adjusted if I can document to the satisfaction of the City that changes in my operations warrant a modified MDQ. Communications The CITY will use the following Customer address to which to send formal notices.These addresses will not be used for billing on CITY accounts. 9~121~, syn 0071557 2 To Customer (Customer Name) Mailing Address Attention: To the CITY City of Palo Alto Utilities Mailing Address: 250 Hamilton Avenue~ P.O. Box 10250 Palo Alto, CA 94301 Attention: Telephone Number: ( ) Telecopier Number ( (Please Type or Print Clearly) Telephone Number (650)329- Telecopier Number (650)326-1507 Signed by: (Signature of Customer or duly- authorized representative) For (Customer Name) (Print Name) (Title (Date) Accepted by: For (Customer Name) (Print Name) (Title) (Date) 981218 ~’n 0071557 EXHIBIT For City Use Contract No Date Received Service Initiation Date Termination Date Revision NOTICE OF TERMINATION OF GAS DIRECT ACCESS SERVICE The Customer hereby directs the City to terminate Gas Direct Access Service to Customer account(s) set forth in the attached Authorization and to commence City natural gas commodity procurement service for accounts in accordance with Schedule G-3. Termination received by the first Day of the Month will become effective for each account on the first day of the following. Month. Termination is for accounts set forth below. Gas Service Address Account Number Average Daily Quantity (MMBTU) The City must receive one completed and signed Notice of Termination. Facscimiles or photocopies must be accompanied by an original. Termination should be mailed to: City of Palo Alto Utilities Manager Supply Resources P.O. Box 10250 Palo Alto, CA 94301 Telecopy Number (650) 326-1507 The Customer terminates the Authorization with the City for Gas Direct Access Service for the accounts specified. The Party executing Termination, whether a Customer or a Gas Service Provider, is responsible for sending a copy of the Notice of Termination to the other Party. The Customer and the Gas Service provider are responsible for resolving any outstanding contractual 981218 ~yn 0071557 disputes regarding Termination or which survive termination. Once Termination becomes effective, the Customer must remain on Schedule G-3 until the next Open Season or negotiate a special contract with the CITY. This Termination is executed by an authorized representative of [] Customer or [] Gas Service Provider (Company) Name: Signature: Printed Name: Title: Date: Telephone: Telecopy: 981218 syn 0071557 EXHIBIT ~C" For City Use Contract No Date Received Service Initiation Date Termination Date Revision FORMAL COMMUNICATIONS BETWEEN PARTIES This Exhibit C designates the formal contact names, mailing addresses, and telephone and telecopier numbers for the Parties to the attached Gas Service Provider Agreement. The information provided under this Exhibit C may be changed from time to time by that party submitting a revised Exhibit C to the other Party. Formal Notices and Program Administration Business Name: Mailing Address: Attention: Telephone Number; Telecopy Number: Gas Nomination Business Name: Mailing Address: Attention: Telephone Number; Telecopy Number: Imbalances Business Name: Mailing Address: Attention: Telephone Number; Telecopy Number: Invoices Mailing Address: Attention: Telephone Number; Telecopy Number: Payments Mailing Address: Accounts: Attention: Telephone Number; Telecopy Number: To the City or Pool Manager To the Gas Service Provider 981218 ayn 0071557 6 EXHIBIT D For City Use Contract No Date Received Service Initiation Date Termination Date Revision GAS SERVICE PROVIDER GROUP SUMMARY Gas Service provider Name: PrePared By: Date Prepared: An. updated Exhibit D must Accompany the Gas Service Provider’s submittal of additional Customer Authorizations. The Gas Service Provider must complete an entry for every Customer added to the Gas Service Provider’s group. The contract number will be assigned by the City. Contract Number (CITY USE ONLY) Customer Name Per Exhibit A Number of Accounts per Exhibit A 981218 syn 0071557 For City Use Contract No Date Received Service Initiation Date Termination Date Revision EXHIBIT ~E" City of Palo Alto Gas and Electric Utility Users Remittance Form Gas Service Provider Name: For the period : Tax Utility Customer Name Utility Customer .Address City Charges Plus Gas Service Provider Charges for the Period Above (This information will be kept confidential) X 5% = Utility Users Tax Owed’to the City of Palo Alto I hereby certify that the above represents the total amount owed to the City of Palo Alto for the time period above, pursuant to the Palo Alto Municipal Code (PAMC) Chapter 2.35 *. By Date Phone 9~121[~ syn 0071557 * Pursuant to Chapter 2.35 of the Municipal Code, a tax in the amount of five percent (5%) on utility usage in Palo Alto shall be collected by utility service suppliers and shall be remitted to the City of Palo Alto. The 5% rate shall be imposed on the following services: metered electricity and Gas plus any customer charges, charges for temporary services, service charges, demand charges, and any other annual and/or monthly charges. For large volume users determined by the City of Palo Alto, the rate may be reduced to 4% and 3% in accordance with Section 2.35.100 of the Municipal Code. Payment shall be due to the City of Palo Alto by the 25th of the month for the preceding billing month. Remit to: Supervisor of Revenue Collections City of Palo Alto, ist Floor 250 Hamilton Avenue, Palo Alto, CA 94301 (650) 329-2317 981218 syn 0071557 9 For City Use Contract No Date Received Service Initiation Date Termination Date Revision EXHIBIT ~F" STANDARD ,OF CONDUCT ,,, FOR AFFILIATES Neither the Gas Service Provider nor its Affiliate shall represent itself as an employee, agent or representative of the CITY or claim association-or affiliation with the CITY in any capacity other than as set forth in the Contract. The Gas Service Provider and its Affiliates, jointly and severally, expressly covenant not to intentionally deceive or mislead any Eligible Customer. "Affiliate" means (I) any Person or entity that, directly or indirectly, owns, controls or holds with the power to vote ten percent (10%) or more of the outstanding voting rights of the GAS SERVICE PROVIDER, (ii) any .Person or entity ten percent (10%) or more of the outstanding voting securities of which is, directly or indirectly, owned, controlled or held with power to vote by the GAS SERVICE PROVIDER, (iii) any Person or entity who is a director or executive officer of a Person or entity which is an affiliate thereof under (I) or (ii), (iv) any Person or entity that, directly or indirectly, through one or more intermediaries, is under common control with the GAS SERVICE PROVIDER, or (v) any general partner or limited partner of a Person or entity that, directly or indirectly, owns, controls or holds with power to vote eighty percent (80%) or more of the outstanding voting rights of the CUSTOMER. For the purposes of (iv) above, a Person or entity shall be deemed under common control with the GAS SERVICE PROVIDER only if the Person or entity that exercises such common control owns, controls or holds twenty-five (25%) or more of the outstanding voting rights of both the GAS SERVICE PROVIDER and any such other Person or entity. Effective date: 981218 syn 0071557 10 For City Use Contract No Date Received Service Initiation Date Termination Date Revision EXHIBIT ~G" GAS SERVICE PROVIDER FEE SCHEDULE B C Gas Service Provider $per month Monthly Billing Charge and Pool Administration Fee Imbalance Charges EFO, OFO, Involuntary Diversion Penalties Metering and Us~’~e Data Charge As per Rule 12 As per Rule 13 $Per month Notes: A) B) C) This charge covers the cost of monitoring daily and monthly imbalances, resolving any questions regarding imbalances and preparing the Gas Service Provider’s monthly bill for Imbalance Charges and other services. There is only one billing/pool administration Charge per Gas Service Provider per month. Imbalance Charges are described in Utility Rule and Regulation 12, and are billed on a monthly, basis. The penalties for OFO, EFO, or Involuntary Diversion noncompliance are described in Utility Rule and Regulation 13. D)This Charge covers the administrative cost of collecting and communicating metering data to the Gas Service Provider. There is only one billing/pool administration Charge per Gas ServiCe Provider per month. Effective date: 98121g syn 0071557 11 ATTACHMENT IV customers in Palo Alto. T~mo~ should be spent on these general kinds of programs, and to thei~x~? that that you want to spend some money here, I do not persoj1~lly o~ect to that. Thank you for thisreport which I had aske~r. I appreciate the work you have done. 7.New Business a. Natural Gas Direct Access Plan Mr. Balachandran: You have a description of the plan in your report. Karla Dailey will give a presentation on the mechanics of how this program works in terms of operations and contracts and the different entities involved. We will then take questions on both the presentation and the report. Ms Dailey: Just as an overview, as you have read in the report, this is Phase 1 of direct access for the gas utility. This is only for the largest customers on the system. These are the same customers who today are eligible for the G-4 Transportation Only rate. So this is not an expansion. It is more accurately a revision and improvement of what is currently approved and on the books. The plan includes our future view of how we can bring this to smaller customers -- the small commercial customers and the residential customers. I am going to focus mostly tonight on Phase I, which is for the large customers. We talked about this several months ago in several of the quarterly reports. We are on a track to bring this program to the customers sooner. We were thinki~ng that with electric DA, there were going to be some customers who were really interested in electric DA who might say that they want to buy all of their energy from someone else. We wanted to be ready for them on the gas side, if that happened. As you know, it did not happen on the electric side, so we pulled back on the reins a bit and took some time to do some more work and some more improvements on this program. It is now scheduled to be rolled out in July of 1999, which will coincide with the next phase of electric DA. I have four slides, and would like to take you through some of the concepts. Hopefully, some of these graphs will help clear up any confusion that you may have developed in reading the report or just some of the jargon that we have been using in the quarterly reports. This diagram is the physical flow of gas. Right now, the city’s gas provider, currently a company called Coral, delivers our gas in two places. They deliver part of it at the California border, and that gas moves through PG&E’s backbone system, which is the redwood line for us. They deliver the rest of it at the PG&E city gate. "City gate" is a confusing term, because it is not our city gate. It is not really anyone’s city gate, but PG&E calls it the city gate, so we have to stay with the terminology. Between PG&E’s city gate and what I am calling our city meter, there is another piece of pipeline which is PG&E’s local transmission system. These are the medium size pipes. The gas accord opened up the backbone portion of the PG&E system. It did several things, and that is one of them. So that part of the system is now open access. Anyone, a marketer, an end user, a producer, whoever, can buy capacity on the MINUTES UAC:981104:MIN Final Page 32 backbone system. The local transmission system is not unbundled, and it is not open access. The only entities that can hold capacity on that part of the system are the end-use customers. In PG&E’s eyes, Palo Alto is an end-use customer, so we hold that capacity. Our customers do not have the ability to go out and buy that on their own. The marketers do not have the ability to go out and buy that and serve them at the Palo Alto city meter. -The closest that anybody can get to our customers is the PG&E city gate. So the arrow going from the gas service providers who will be the parties who would potentially be serving our gas DA customers, the closest they can get to our customers is the PG&E city gate. We move the gas from the city gate to the city meter, and then of course, our local distribution system gets the gas to all of our customers, whether they be our full service customers or gas DA customers, the G-4 customers. This slide shows a summary of Party Responsibilities. The three parties that I have highlighted are the gas service provider, the city, and a to-be determined pool manager. The gas service provider has to get gas to the city’s pool point, which is basically the PG&E city gate for the customers. They have all been nominating, they have to be sure they deliver enough gas to Cover losses in our distribution system, and they have to bill the customer for that commodity and for any other services they might be contracted for. They also have the financial responsibility for imbalances, which means that if they have not delivered enough gas or have delivered too much gas relative to what that customer actually used, they will fall subject to our rules and regulations about imbalancing. They will have to pay those penalties as laid out in that rule. Palo Alto will provide the local transmission, the local distribution, the metering, and we will bill the customer for those services. We also provide a balancing service to the gas service provider, which means that we will set up the rules for them. We will get them tolerance band and a system to work within. It is impossible for everyone to be exactly on balance, as you cannot know exactly what the customer is going to use on a given day and deliver exactly that much gas, so through our rules and regulations, we are setting up ways for the gas service provider to meet our requirements and still be able to effectively serve our customers. The pool manager is an entity that we have not found yet. We are actually in the process of developing a Scope of Work for an RFP for this. This will be an impartial third party who will manage the Palo Alto pool with. all of these potentially different gas service providers nominating gas on behalf of Palo Alto customers. So it will be that entity’s job to keep track of what the gas service providers are nominating, to keep track of what the end users, the G-4 customers, are using, calculate those imbalances, and we will probably have them do the unbalance billing if there are any penalties or anything like that, associated with imbalances, and they will also keep track of day-to-day operational conditions, particularly on the PG&E system that the gas services providers will have to be aware of. So what we are looking for in this company is someone who is impartial, someone who is not in the MINUTES UAC:981104:MINFinalPage 33 business of buying and selling commodities, because they will have to know a lot of information about what the gas service providers are nominating for those customers. You do not really w~nt one marketer who is in charge of that and other marketers, who are having to divulge information to that company. So we are probably going to have a fairly short list of qualified bidders or proposers for that. This.is probably easier to look at than talk about, but I will try and start at the top of this slide and work around clockwise. I have the City of Palo Alto in the middle, and have tried to represent all of the agreements that will exist between ourselves and all of these other parties. The pool manager is at the top, and we will need a pool manager agreement. As I said, we are in the scoping of the RFP phase right now, so obviously that agreement does not yet exist. The second agreement is the gas service provider agreement. That~is akin to what we have been calling on the electric side the gas bus. We are calling it the gas bus on the gas side. That is one of the documents that will be going to the council in January. Our contract between ourselves and our customers will just be the tariffs and the utility rules and regulations. As part of the gas bus, there will be an exhibit that is an authorization. Basically, the customer will just say, "I, Company XYZ, authorize Marketer ABC to be my gas service provider," and all of these rules and regulations will apply. It will be a very simple, one-page form that they will have to sign authorizing that marketer to be their supplier. Between the customer and the gas service provider, they will have their own gas sales agreement, and the city will not be a party to those. We will also have a meter data manager. That company will provide a lot of services for us on the electric side. We are hoping that they can collect the individual customer data and distribute that to the pool manager and whoever else needs to see it. That will be more efficient than our staff trying to do it, since they are going to be accessing all those remote meters and setting up the software to do that. So the meter data management agreement is not just for gas. There will be a section in the agreement that applies to what they are going to do for our gas meters. Our own supplier, which is our gas service agreement currently with Coral (if it is not with Coral, it will be with someone else), but we will continue to have the same sort of commodity agreement with someone to serve our full-service customers. Last but not least, the city has an agreement with PG&E that is the natural gas service agreement. That covers the local transmission services that we get from them that are unbundled at this point, as well as the Redwood capacity that we accepted, the allocation, the 6,000 MPGs per day. We have that agreement with them, as well. That is all of the agreements. This next slide is a summary of what is in the gas bus. We tried to put as much of the meat as possible into the utility rules and regulations. The contract is not nearly as thick as the gas bus, I would say. A lot more of the details are in the utility rules and regulations, but just as an overview, we did model a lot of this agreement after the electric program, as well as PG&E’s core transport agreement. That is the MINUTES UAC:981104:MIN Final Page 34 agreement under which, if you want your core customers on PG&E’s system as the marketer, you have to sign. On the PG&E system, if you are serving non-core customers, there is no agreement. The responsibility is placed on the customer, not on the gas service provider. But unlike PG&E’s non-core program, we are placing the financial responsibility on the GSP, not on the customer. That is why we need this agreement. The major components are pretty typical ofcontracts, e.g., the term and termination date, the maximum daily quantity, which is important because Palo Alto has a maximum daily quantity that we can move across the local transmission system. So we need to have some control over what a marketer can nominate for a DA customer on our system on a daily basis. So we are going to prorate our maximum daily quantity to those DA customers and put a cap on how much gas they can move through the system on any given day. Otherwise, our own core customers might be put at risk of not being able to get all of their supply if we do not limit that. Also included in the contract is communication -- who needs to call whom, how that needs to be done, default and remedies for it, metering responsibility and protocols, plus liability, default, waiver and release, assignment, warranties and representation, those types of legal items are in there. It also includes the exhibits, which include the customer authorization form I mentioned, and a sister form to that which would allow the customer to terminate their agreement with the GSP for whatever reason. That is a quick summary of it. This particular agreement and the utility ~ules and regulations are scheduled to go before the counc~l in January, and now, I will be happy to take your questions. Vice Chair Johnston: Without those charts, this would have been a lot more difficult to understand the roles of all of the parties. This has been a major help, along with the report. Commissioner Eyerly: In listening to Karla and scanning this report, if we get into this direct access, it seems to me we are going to have a lot of contracts to worry about, and I doubt if they are all going to come down in a regular format that we sign with the larger companies that might be interested. Have you thought about the legal work involved with these contracts? Mr. Balachandran: These contracts that are being developed are up-front contracts to establish the structure that will enable our customers to enter into agreements with suppliers. Let’s say that in Phase I, we have ten customers, and suppose that all of them leave. They are going to be signing agreements with someone else. We do not get involved in that. They will have had to sign the gas bus, which is a standard contract being finalized right now, which the council will approve, hopefully, in January. Ms. Dailey~ I don’t think there will be room for much, if any, negotiation on the gas bus. It is going to be a pretty standard contract that they will have to sign. We are not going to have ten different versions for ten different gas service providers. If they want to serve a customer in the City of Palo Alto, that is what they MINUTES UAC:981104:MINFinalPage 35 will have to sign. Most of the details are in th~ rules and regulations, anyway, and we will not be changing rules and regulations to fit individual gas service providers’ needs. Commissioner Eyerly: I accept what you have to say, but suppose you do get into some problems and there are some negotiations, are you going to depend upon .our city attorney’s department to handle the legal end of it if you. get into some of that? Or are you going to have a outside specialist? Have you thought about that? Ms. Dailey: I guess I do not see what there is to negotiate. We have this program, and if they want to serve our customers, here is the agreement that they have to sign. I am not anticipating any negotiations. Granted there will be problems with the program, and in the next phase, we will probably have to revise some rules and regulations as one never does things perfectly the first time. But I just do not see contract negotiations other than the contract between ourselves and our pool manager. That is certainly one that will be negotiated, and the contract between ourselves and our next gas supplier. But those are just two agreements. There will not be lots of those. Mr. Mrizek: It is ~very similar to what we are doing in the electric utility. If a customer wants to buy from another marketer, they have to agree to our terms. Commissioner Eyerly: I hope it is all that simple. Commissioner Sahagian: I agree with Paul that the graph was very helpful. I have a lot of questions for you. I appreciate that we have very competitive gas and that we have not lost any customers, but maybe I am the worrywart of the group. As I understand it today, the gas service providers cannot get into our system because basically, we are. not letting them use our distribution system. That is really the lockout. They can go to PG&E and get access all the way to our meters, and that is far as they can go. Is that correct? Ms. Dailey: No. Let me try to .answer that in a couple of different ways. They cannot get any closer to our meters than the PG&E city gate. That is true. Right now, we do have a program on the books that would allow them to buy their own gas and deliver it to the California border. Actually, in July of 1998, that rate was revised so that the backbone portion of the G-4 rate was removed. Theoretically, there is no problem except that we have not had an open season in our rate. Our rules say we have to have an open season before they can choose to go on that rate. That is really the block right now. We need to declare an open season to let the customers choose this option. In the past, we held all of the transportation from the California border all the way to the city meter. Those were PG&E’s rules. None of that pipeline was open access, so the closest anybody could get to any customer was the California border. We bought all of our gas at the California border. Now, one more piece of the puzzle has opened up as an open access pipeline, and that is the backbone. So now, anybody can get one step closer. Now we are able to buy some of our gas at the PG&E MINUTES UAC:981104:MIN Final Page 3 6 city gate. Conunissioner Sahagian: The capacity in that backbone system and the capacity in that local transmission system between the city gate and our meters, is that a fixed charge that we pay every month, or is it prorated based on voluble? Ms.. Dailey: The capacity that we own on the backbone is mostly a fixed charge, with a very small volumetric portion. The contract that we have with PG&E for the local transmission is almost all volumetric. But we have a maximum daily quantity that we can move over that system. We have a cap on how much we can bring in on a daily basis over that part of the system. Commissioner Sahagian: If a user elects to go with Brand E (not naming anyone in particular), and they purchase gas from Brand E, is any portion of our transmission cost going to become stranded costs by virtue of their buying from that new service provider, and that service provider having some independent.arrangement with PG&E to move the gas through PG&E-affiliate-owned lines? Ms. Dailey: No, because we do not really own any backbone on behalf of those large customers. Relative to our entire load, we do not have that much bac~bone, so we are not at risk of having a bunch of backbone capacity that is unused. Regarding local transmission, nobody else can hold it but us anyway. That is all volumetric. So all of the gas that gets to the city has to go through that way, one way or the other. It is really a wash, because we will get charged for it, but we will also get paid for it by the ~ustomer, because we will be charging them for that. So there is no potential stranded cost there now. Commissioner Sahagian: Hypothetically,.if three years from today, 50% of our gas users in the city were buying from another gas service provider, the remaining 50% would not be looking at any significant increase in their billing as a result of the denominator being squeezed. When you think in those terms, is it still an insignificant consideration? Ms. Dailey: Yes, I think that is so. Girish just said to me that we have 6,000 a day on the Redwood line, and say our load went all the way down to 3,000 a day in summertime, I guess that is a potential stranded capacity issue. The historical data suggests that the market value for that capacity is way higher than what we pay for it. Certainly, there are no guarantees that that will be the case in the future, but it is about half of what the tariff rate is. We get it at an all-dimension rate for a number of other reasons. So that capacity has been very, very cheap and has been very, very valuable, and the chances of the market value of it being lower than the price we pay for it is pretty slim. Commissioner Sahagian: Would it ~be reasonable, as part of our tariff structure or whatever this agreement is, to require that the gas service provider buy transmission services through us at published tariff rates so that if people do go off the system, our piece of it is being covered off and we make money on it? MINUTES UAC:981104:MINFinalPage 37 Ms. Dailey: I don’t think we want to sell it to them at published tariff rates, because the market valu~e has been double that. Commissioner Sahagiant I have another question. I have been on the short end of imbalances along the way with one of the power plants that I manage. In situations where we were using more gas than we had forecast, we got killed. We would get dragged over the coals because of the imbalances. That is a service which, if the city is going to provide and there is an interruption on the part of the gas service provider, I think the city is well within its rights to almost go right up to the edge of usury penalties, almost, for those imbalances, providing imbalanced services. I wanted to understand if that is something we are in sync with and if we are tracking the market for that sort of thing. . Ms. Dailey: Yes, we do a lot of referring to PG&E’s rules and regulations and our transportation of gas rules and regulations, like the new one that is coming out to cover this whole program. I guess our view on it has been that we want to protect ourselves from the penalties that could be imposed upon Palo Alto. PG&E sees us as Palo Alto. They do not care if we have-customers that are buying their own gas. They are blind to that. They see us as Palo Alto, and if Palo Alto is out of balance, they come to us to collect that money. So what we have tried to do is to design a rule to pass that through, basically, if the gas service provider could cause us that problem. PG&E is going to charge us, and we are going to be able to turn around and collect that money from the gas service provider. So that is how we are doing it. I don’t think their throwing our System out of balance is really that much of a concern, because PG&E is going to catch it up higher, before it gets to our distribution system. So it is just a matter of our covering ourselves against PG&E’s rules. Commissioner Sahagi.an: This is my last question. I remember that one of the questions that I jotted down in the margin was, whatmigration have we seen so far, and earlier, it was said in answering the question that there has been no migration. We are batting a thousand, so far. What migration do you anticipate when we open access? if you were to look into your crystal ball and realize that gas is probably a little easier to market commodity than electric energy at the moment, because it does not have a lot of CTC and other things encumbering it. The reliability thing does not hang quite so high in people’s heads. Realistically, what exposure are we looking at, and what happens if we do face significant migration? Mr. Balachandran: Just looking at the experience of the PG&E system for the large customers, and Phase 1 is opening up for the ten largest customers, the non-core customers, it just depends upon how heavily marketers discount to our customers and how interested they are in getting this load. After that, the remaining part of our load, which is about 85%, is small customers. PG&E has had a core aggregation program for ~about five years now, and they just have not gotten much response. Now through the gas accords, they have started to promote that program very heavily. They still have not gotten much response on that. So based on that history and just the history of customers wanting to stay with an existing provider unless there are significant savings to be MINUTES UAC:981104:MINFinalPage 38 achieved and the margins are pretty thin, I don’t see much of a risk for the core customers, commercial and residential. There really is not much in it for them. Ms. Dailey: I actually think a lot will be told by the next phase in electric DA, too. A customer is much more likely to think about doing this for gas if they have already decided to do it for electric. They will not just wake up some morning and say they want to buy their gas from somebody else. I just think it is going to be more likely that somebody like Company E who says, I can serve both your gas and electric needs, and the customer says, okay, maybe I will look at it as a package, but I do not think there is going to be a whole lot of response to the standalone thing. Commissioner Gruen: How many customers are eligible for this, and what portion of the total load in Palo Alto do they represent? I have the same question for the top two or three customers. What percentage of our total load are they? Ms. Dailey: In Table #2 in the report on Page 5, it splits that out between Phase I, which is the large customers, about ten accounts. You can refer to the annual volume, etc. Does that answer your question? (Yes) Commissioner Johnston: From what I am hearing, going forward with natural gas direct access creates no stranded costs and no equivalent CTC, and from everything you have basically said, it really does not matter very much how many customers opt into this or not, presumably because the charge is all really coming through the distribution. Is that a fair characterization? Mr. Balachandran: I would not be as categorical as you have, saying no CTC, no stranded costs I would say the risk of incurring stranded costs is really minimal. There are two things. One is that on the transportation side, the capacity that we have, we are buying under the market value at half themarket value right now. Secondly, the sequence of events that would, lead to our having some of the capacity unused is also a very unlikely scenario where small, commercial customers suddenly start leaving us in droves. In just looking at the experience of PG&E’s service territory, that is not happening. In looking at both of these scenarios, I would say the probability of stranded costs is very low. Vice Chair Johnston: Does that force us to always maintain very short- term contracts? The risks you are characterizing are based somewhat on today’s market position. If, down the road, we signed a longer-term contract, presuming we would only sign it if it was a good contract,~ and then prices went in a detrimental way to the City of Palo Alto, and the result of that was that customers wanted to leave, how do we avoid that scenario? Do we avoid that by saying we are never going to buy longer- term contracts? DO we avoid that by saying, if we are engaged in longer-term contracts, we have the right to impose a stranded cost at such time as people leave? How do we avoid it? Mr. Balachandran: Just to return to a question that Commissioner Sahagian had on risk management, which was, what are we do on the MINUTES UAC:981104:MINFinalPage 39 revenue side, we will try and match up our risk on the revenue side so that if we enter into a long-term contract on the gas side, it would probably be in response to perhaps some commitments on the sales side where, perhaps, we had 30% of our customers on three-year rate schedules. I think that is when we go in for a long-term contract. Otherwise, another way to deal with this is when we purchase a gas or supply contract, even if it is for 2, 3, 5 years, have minimum and maximum bands, and the way in which we purchase it would not necessarily be at a fixed price. It would be at an index price with an option to fix at different levels. That is pretty much the way we have it right now where the supplier serves our load. So they are taking on the volumetric risk over there. It is probably imbedded in the price someplace, so that is the way we hedge something like that. Vice Chair Johnston: The counter to that is that if we stay short term, and somebody else signs a long-term contract and ends up being a winner, they can undercut the price and effectively, overnight we could lose all of our customers. Maybe that has no risk to us if it turns out that we are collecting on the distribution side. Mr. Balachandran: That can always happen. It happened on the electric side, too, not just from someone else signing a long-term contract and the market moving favorably. It could be someone with very deep pockets who has a strategic interest in buying market shares. Then we would have to make a strategic decision on how we want to respond to that. Do we want to let go of the supply business? Or do we want to stay in the supply business for the long term and respond to that aggressively? That would be part of our business plan. Vice Chair Johnston: we open our doors? Is it true that nobody right now is mandating that Mr. Balachandran: That~is correct. Vice Chair Johnston: So this decision is just consistent with the city’s decision early’on, I believe, in the electric process, which was that we want to offer our customers a choice. Ms.. Dailey: Yes, in fact, it is consistent with an earlier decision which was the creation of the G-4 rate to begin with, in 1993 or 1994. So we made the decision to let large customers buy their own gas a long time ago. This is just a revision of that program. ~Mr. Balachandran: And that was done in response to one of our large customers requesting choice. We developed a program, but they did not exercise that choice. Vice....Chair Johnston: We need to make a recommendation on this item. MOTION: Commissioner...Sahagian: I so move. SECOND: By Chairman Eyerly. MOTION PASSES:Vice Chair Johnston:That motion passes unanimously on MINUTES UAC:981104:MINFinalPage 40 a vote of 4-0. 8.City Council~Referrals - None 9.Reports of Officials/Liaisons a. BAWUA .. Report Ms... Ratchye: The repor~ that you found at your places tonight basically states that Standard and Poor has lowered its rating on San Francisco’s sewer bonds, but not on\their water bonds yet. But for both the sewer and the water enterprises, the outlook/has changed from stable to negative. They largely p~int to Proposition H, the initiative that theSan Francisco voters approved in June/that did not allow for any rate increase for eight years.\ They are ~eclaring that "The practical loss of rate setting and the pro~ected e~sion in financial margins if action is not take is inconsistent with prudent management practices and flexibility associated with ~trongiutility credits." It looks like they will be closely watching San\Francisco and seeing what they do over the period of the 8-year rate fre@z~ and potentially increasing operational costs. They also state in\/the attachment to your report that "The commission will be forced t~\explore non-rate sources of revenue that permit them to sell water and~ewer services to nonresidential customers and exploit revenues frQ~ ~ts large real estate holdings through concession agreements, l~ases\and outright land sales." So they are suggesting that the com~ission~needs to look at some way to get enough money to run their operations.\This~is for your information. I am not sure what this means /~r us.~ ~is is fairly new information. Vice Chair Johnston:/My underst~ding was that we, meaning BAWUA, paid a fixed percentag9/ of the operational costs. Can this upset that? Isn’t this a contr~gtual agreement? Ms. Ratchye: Ye it cannot do t~at. Proposition H has nothing to do with raising rases in the suburbs~ It does not stop that at all. But you are right,~hey have to use the~same rate-making methodology that is in our contract now, which speaks almost solely to that question of rate setting and c~st allocation. It is not a fixed percentage in that it is the same percentage every year, but the method is fixed. So they can raise our rates, but they will have to find other revenues besides rate revenues to cover increasing cost. Under Proposition H, they can raise their rates 18% just to cover the cost of the bonds that the voters have already .approved, and they can also increase rates again if they have anothe~/~voter-approved bond. Those are for specific capital projects, but they are not allowed to increase rates for any operational expense for eight years (general operations, salaries, etc) which no doubt will increase in eight years. Vice Chair Johnston: Thank you very much. 9.b. NCPA Report Councilman Rosenbaum: There are a number of letters and con~nunications relative to our Western marketing plan and our efforts to secure renewal of those contracts. We put in a major effort to get a letter signed by MINUTES UAC:981104:MIN Final Page 41