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Diverging views on weather normalization and CET guardrails at Enbridge rate hearing
Summary
Enbridge asked to shorten the HDD normal baseline to 10 years; DPU and OCS recommended more study or a 15‑year compromise and stronger CET filing/trigger rules. Company stands by a reset to better align normalization with recent observed weather.
SALT LAKE CITY — The hearing featured a technical dispute about the baseline used to calculate normal heating‑degree days (NHDD) for Enbridge Gas Utah’s weather normalization adjustment (WNA) and related effects on the Conservation Enabling Tariff (CET).
Enbridge witness David Landward proposed lowering the baseline used to compute normal heating‑degree days from the current 20‑year window to a 10‑year window ending Dec. 31, 2024. Landward said the older baseline sits ‘‘above’’ recent average heating demand and causes repeated upward adjustments, producing a systematic bias that favors increased normalized usage. He argued a reset is prudent maintenance of the normalization mechanism; he also offered to arrange technical briefings for the Division.
Division witnesses urged greater empirical rigor. David Fields recommended further statistical analysis before moving to a 10‑year baseline and noted NOAA’s practice of 30‑year normals and the AGA survey showing a range of approaches among utilities; the Division proposed a 15‑year compromise and additional study. Ryan Daigle and other intervenors advocated CET guardrails: more frequent CET filings if balances exceed a $10 million threshold, a higher amortization cap, and expedited return of large over‑collections.
Mendenhall (Enbridge) told the commission the company supports some DPU suggestions (adjusting CET cap to 5%) but opposes moving CET balances into the commodity 191 account because that would reduce transparency. He said the company plans to include a third‑party evaluation of energy‑efficiency programs in the upcoming budget filings.
The commission heard technical questions from commissioners about the statistical significance of observed differences in average HDDs between 10‑, 15‑ and 20‑year windows, and about how Enbridge’s customer‑level WNA operates in the billing system. The Division asked for more detailed methodology documentation from the company. No final action was taken; commissioners asked parties to keep working and to provide the Commission with agreed elements where possible.
