Project Background
In August 2018, the OEB approved the amalgamation of Enbridge Gas Distribution Inc. (EGD) and Union Gas Limited (UGL) to form Enbridge Gas Inc. (Enbridge Gas), effective January 1, 2019. Prior to the amalgamation, EGD and UGL independently owned and operated natural gas storage facilities. Then, as now, the storage facilities serve both utility and non-utility customers.
Enbridge Gas has filed a cost-based application (EB-2022-0200) for the establishment of transmission, storage and distribution rates effective January 1, 2024 (the Application). The Application includes a proposal for a harmonized unregulated storage cost allocation methodology. The methodology is based on a Storage Cost Allocation Study by Ernst & Young LLP that was filed with the Application.
The Issues List for the Application includes the following interrelated issues:
Issue No. 47: Should the cap on cost-based storage service for in-franchise customers established in the Natural Gas and Electric Interface Review (NGEIR) Decision remain at 199.4 PJ?
Issue No. 48: Is the purchase of storage service at market-based rates by Enbridge Gas from Enbridge Gas for in-franchise customers appropriate?
Issue No. 50: Is the allocation of capital assets and costs between utility and non-utility storage operations appropriate?
Further context for this project can be found in the following documents:
- EB-2005-0551 Natural Gas and Electric Interface Review (NGEIR) Decision with Reasons (November 7, 2006)
- EB-2022-0200 Enbridge Gas 2024 Rebasing Application Exhibit 1-13-2 Storage Cost Allocation Study
In Procedural Order No.1 in the Application, the OEB determined that it is appropriate to hear the Application in 2 phases (Phase 1 and Phase 2). The OEB also determined that the above-noted Issues 47, 48 and 50 will be addressed in Phase 2 of the Application. Currently, Phase 2 is expected to begin in late 2023, with the exact timing to be determined. Given that the specific timeline for Phase 2 is not yet established and Vendor availability and flexibility is a matter of critical importance to the OEB, Vendor(s) responding to this RFP will be asked to demonstrate in their Bid(s) that they can be available to provide the required services and deliverables in this context.
Purpose and Objectives
To retain a natural gas storage expert who will review the relevant material in the Application and identified in this RFP (e.g., the NGEIR Decision) and assist OEB staff in testing the technical aspects of the natural gas storage evidence related to Issues 47, 48 and 50.
The natural gas storage expert may also be asked to opine on whether the integration of the EGD and UGL storage systems may have created synergies that are not being accounted for in the Application.
The natural gas storage expert will be required to assist OEB staff with the preparation of interrogatories and submissions on the Application and may be asked to help prepare OEB staff for a technical conference or with cross examination if there is a hearing. The ability to file and defend an expert report is considered an asset but is not a requirement for Vendor(s) responding to this RFP and is therefore not part of the evaluation criteria of this procurement.
Full details of the RFP document is available only through MERX at www.merx.com or 1-800-964-6379, MERX reference number 0000248207.
