Current through Register Vol. 54, No. 38, September 21, 2024
(a) A
license will not be issued or remain in force until the licensee furnishes
proof of a bond or other security. See section 2208(c)(1)(i) of the act
(relating to requirements for natural gas suppliers).
(b) The purpose of the security requirement
is to ensure the licensee's financial responsibility. See section 2208(c)(1)(i)
of the act.
(c) The amount and the
form of the security, if not mutually agreed upon by the NGDC and the licensee,
shall be based on the criteria established in this section. The criteria shall
be applied in a nondiscriminatory manner. The Commission will periodically
review the established criteria upon petition by any party. The NGDC shall
include the rules, formulas and standards it uses to calculate and adjust
security amounts in a tariff.
(1) The amount
of the security should be reasonably related to the financial exposure imposed
on the NGDC or supplier of last resort resulting from the default or bankruptcy
of the licensee. The amount of security should reflect the difference between
the cost of gas incurred by the NGDC or supplier of last resort and the amount
payable by the licensee's retail gas customers during one billing cycle.
(i) The amount of security established under
this paragraph may be modified based on one or more of the following:
(A) The licensee's past operating history on
the NGDC's system and on other NGDC systems, including the length of time that
the licensee operated on the NGDC system, the number of customers served and
past supply reliability problems.
(B) The licensee's credit reports.
(C) The number and class of customers being
served.
(D) Information that
materially affects a licensee's creditworthiness as set forth in subparagraph
(ii)(A)-(E).
(E) The licensee's
demonstrated capability to provide the volume of natural gas necessary for its
customers' needs.
(ii)
The amount of the security may be adjusted as circumstances warrant. The
adjustments must be reasonable and based on one or more of the following
criteria:
(A) A change in a licensee's recent
operating history on the NGDC system or on other NGDC systems that has
materially affected NGDC system operation or reliability. A change that could
materially affect NGDC system operation or reliability may occur when a
supplier fails to deliver natural gas supply sufficient to meet its customers'
needs, or fails to comply with NGDC operational flow orders as defined in
§
69.11 (relating to
definitions).
(B) A change in a
licensee's credit reports that materially affects a licensee's
creditworthiness. A licensee's creditworthiness could be materially affected
when two of the following credit rating companies change the licensee's credit
rating:
(I) Dun & Bradstreet.
(II) Standard & Poor's Rating Services,
Inc.
(III) TransUnion
LLC.
(IV) Equifax, Inc.
(V) Experian Information Solutions,
Inc.
(C) A significant
change in the number of customers served, in the volume of gas delivered, or in
the unit price of natural gas or a change in the class of customers being
served by the licensee. A change over a consecutive 30- day period of 25% in
the number of customers served, in the volume of gas delivered or in the
average unit price of natural gas would represent a significant
change.
(D) A change in operational
or financial circumstances that materially affects a licensee's
creditworthiness. A licensee's creditworthiness could be materially affected
when two of the following investment rating companies change the licensee's
rating of its issued securities from an investment grade or good rating to a
speculative or moderate credit risk rating, and vice versa:
(I) Standard & Poor's Rating Services,
Inc.
(II) Moody's Investment
Service, Inc.
(III) Fitch,
Inc.
(IV) A. M. Best Company,
Inc.
(V) DBRS,
Inc.
(E) A change in the
licensee's demonstrated capability to provide the volume of natural gas
necessary for its customers' needs that materially affects NGDC system
operation or reliability. A change that could materially affect NGDC system
operation or reliability may occur when a supplier fails to deliver natural gas
supply sufficient to meet its customers' needs on five separate occasions
within a 30-day period, or fails to comply with NGDC operational flow orders as
defined in § 69.11.
(2) The following legal and financial
instruments and property shall be acceptable as security:
(i) Bond.
(ii) Irrevocable letter of credit.
(iii) Corporate, parental or other
third-party guaranty.
(iv) Escrow
account.
(v) Accounts receivable
pledged or assigned to an NGDC by a licensee participating in the NGDC's
purchase of receivables program that has been approved by the Commission as
being consistent with Commission orders, guidelines and regulations governing
the programs.
(vi) Calls on
capacity, netting NGDC gas supply purchases from the NGS against NGS security
requirements, or other operational offsets as may be mutually agreed upon by
the NGDC and the NGS.
(vii)
Cash.
(3) In addition to
the requirements in this section, small suppliers with annual operating
revenues of less than $1 million may utilize real or personal property as
security with the following supporting documentation:
(i) A verified statement from the licensee
that it has clear title to the property and that the property has not been
pledged as collateral, or otherwise encumbered in regard to any other legal or
financial transaction.
(ii) A
current appraisal report of the market value of the property.
(4) When practicable, the NGDC
shall use applicable North American Energy Standards Board forms or language
for financial and legal instruments that are used as security.
(5) The NGDC shall file an annual report with
the Secretary no later than April 30 of each year. The report must contain the
following information for the prior calendar year:
(i) The criteria that is used to establish
the amount of security that an applicant must provide to the NGDC in order to
be granted a license by the Commission.
(ii) The criteria that is used to determine
the amount of security that a licensee must provide to ensure its financial
responsibility in order to maintain a license.
(iii) The criteria that is used to determine
that a change in the amount of security is needed for the licensee to maintain
a license.
(iv) The number of
instances in the last year that the NGDC determined that a change in the amount
of security was needed for a licensee to maintain its license. For each
instance, the following information shall be reported:
(A) The name of the licensee
involved.
(B) The date of the
NGDC's determination.
(C) The
reason for the determination.
(D)
The licensee's response to the NGDC determination.
(v) The types of legal instruments, financial
instruments and property, real and personal, that the NGDC accepted as security
for licensing purposes. For each security type reported, the following
information shall be reported:
(A) The name of
the applicant or licensee involved.
(B) The name and address of the bank, company
or other entity that is acting as the surety or guarantor.
(C) The amount of security.
(D) The date that the security was
posted.
(6)
When an NGDC determines that an adjustment in the amount or type of security
that a licensee must provide to maintain its license is warranted, the NGDC
shall provide notice of its determination to the licensee in writing. The
NGDC's determination must be based on the criteria in paragraphs (1), (2) and
(3). The licensee shall comply with the NGDC's determination no later than 5
business days after the date that the licensee was served with notice of the
NGDC's determination. When the licensee disagrees with the NGDC's
determination, the licensee may file a dispute with the NGDC in accordance with
paragraph (8).
(7) A licensee may
request that the NGDC adjust the amount or type of security the licensee must
provide to maintain its license. The licensee shall provide its request in
writing to the NGDC. The request must be based on criteria in paragraphs (1),
(2) and (3). The NGDC shall make its determination on the request and provide a
written response to the licensee within 5 business days after the date that the
request was made. When the NGDC agrees to the requested adjustment in security,
the licensee shall post the security within 5 business days after the date that
the licensee was served with notice of the NGDC's determination. When the
licensee disagrees with the NGDC's determination, the licensee may file a
dispute with the NGDC in accordance with paragraph (8).
(8) When there is a dispute relating to the
form or amount of security, the applicant or licensee shall notify the NGDC of
the dispute and attempt to resolve the dispute. If a resolution is not reached
within 30 days after the date that the NGDC is notified of the dispute, the
applicant or the licensee may:
(i) Submit the
dispute to the Secretary for assignment to the appropriate bureau, office, or
other designated unit for informal mediation and resolution. A party
dissatisfied with the staff determination may file a petition for appeal from a
decision made by the Bureau under §
5.44 (relating to petitions for
appeal from staff) or may file a formal complaint with the Commission under
§
§
5.21 and
5.22 (relating to formal
complaints generally; and content of formal complaint).
(ii) File a formal complaint with the
Commission and request alternative dispute resolution by the Office of
Administrative Law Judge.
(iii)
File a formal complaint with the Commission and proceed with the litigation of
the complaint.
(iv) File a petition
with the Commission and request review of the criteria used by the
NGDC.
(9) When a licensee
submits a dispute or files a formal complaint relating to an adjustment in
security by an NGDC, the following obligations apply:
(i) The licensee shall provide to the NGDC
the adjusted security amount as directed by the NGDC. The licensee shall
maintain the adjusted amount of security until the dispute or complaint is
resolved or until directed otherwise by the Commission.
(ii) The licensee shall continue to operate
on the NGDC system in accordance with system operation and business rules and
practices until the dispute or complaint is resolved or until directed
otherwise by the Commission.
(iii)
The licensee shall cause to be delivered to the NGDC system natural gas supply
in the volume necessary to fulfill its customers' requirements and provide
customer support services until the dispute or complaint is resolved or until
directed otherwise by the Commission.
(iv) The NGDC shall permit the licensee to
continue to operate on the NGDC system until the dispute or complaint is
resolved or until directed otherwise by the
Commission.
(d)
The licensee shall submit to the Commission documentation demonstrating that it
has complied with the bonding or security requirement. One copy of each bond,
letter of credit, or other financial or legal instrument or document evidencing
an agreement between the licensee and the NGDC shall be submitted to the
Commission.
(e) Licensee liability
for violations of 66 Pa.C.S. (relating to the Public Utility Code) and
Commission orders and regulations is not limited by these security
requirements.