COMMONWEALTH OF PENNSYLVAN

Transcription

1 I COMMONWEALTH OF PENNSYLVAN IRWINA. POPOWSKY Consuer Advocate OFFICE OF CONSUMER ADVOCATE 555 Walnut Street, 5th Floor, Foru Place Hasburg, Pennsylvania (717) (in PA only) FAX (717) March 14, 2006 Jaes J. McNulty Secretary Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street Han-isburg, PA DOCUMEN RE: Pennsylvania Public Utility Coission v. Peoples Natural Gas Copany, d/b/a Doinion Peoples 1307(f) Proceeding Docket No. R CCOO \ Dear Secretary McNulty: Enclosed for filing, are an original and three (3) copies of the Foral Coplaint and Public Stateent ofthe Office of Consuer Advocate, in the above-referenced proceeding. Copies have been served on the parties of record as indicated on the enclosed Certificate of Service. Sincerely, Enclosures cc: Parties of Record Office of Special Assistants DOC Shaun A. Sparks Assistant Consuer Advocate DOCUMENT CO p-l o ^-f ci: JJ r < 1.cr- CD TO 73 o o

2 0) Pennsylvania Public Utility Coission n Foral Coplaint For Please Print. (/y CCCLo \ 30 \ C OOO \ 1. Your nae, ailing address, telephone nuber and utility account nuber: Nae Irwin A. Popowsky, Consuer Advocate Street/P.O.Box 555 Walnut Street 5th Floor Foru Place Apt # City Harrisburg State Pennsvlvania Zip County Dauphin Area Code/Hoe Phone Area Code/Work Phone ( Utility Account Nuber If the above ailing address differsfrothe address where the utility service is this inforation below. Nae Street/P.O. Box City County_ DOCUMENT FOLDER State Zip MAR Nae of utility copany your coplaint concerns: The Peoples Natural Gas Copany d/b/a Doinion Peoples. provided, list 3. Type of Utility (circle one): GAS STEAM HEAT WATER ELECTRIC MOTOR CARRIER SEWER o "j i JO o TELEPHONE - (LOCAL OR LONG DISTANCE) CD ro rn o

3 0) 4. What is your coplaint? A. On January 30, 2006, pursuant to 52 Pa. Code section 53.65, The Peoples Natural Gas Copany b/d/a Doinion Peoples ("Peoples") subitted a portion of its Pre-filing inforation in support of its annual reconciliation of purchased gas cost ("PGC") rates. Peoples subitted its pre-filing inforation on March 1, 2006, and the OCA expects Peoples to subit its Definitive Filing on or about April 1, B. Peoples' Pre-filing inforation does not indicate the anticipated effect of the annual PGC reconciliation on existing rates. C. The Public Utility Code provides that the rates of a natural gas distribution utility cannot be deeed just and reasonable unless the Coission finds that the utility is pursuing a least cost fuel procureent policy, consistent with the utility's obligation to provide safe, adequate and reliable service to custoers. 66 Pa. C.S The Coission ust find, aong other things, that the utility has (1) fully and vigorously represented ratepayer interests before the Federal Energy Regulatory Coission, (2) taken all prudent steps to negotiate favorable gas supply contracts and to relieve its obligations under contracts that ay be adverse to ratepayer interests, (3) taken all reasonable steps to obtain lower cost gas supplies, and (4) not withheld or caused to be withheld gas supplies that should have been utilized as part of a least cost fuel procureent policy. D. The Public Utility Code also requires the Pennsylvania Public Utility Coission to ake specificfindingswith regard to the justness and reasonableness of all purchases fro any affiliated supplier.

4 E. The Consuer Advocate is epowered to represent the interests of Pennsylvania utility consuers before the Pennsylvania Public Utility Coission, pursuant to Act 161 of the General Assebly, as aended, 71 P.S , et seq. F. After initial review of Peoples' filing, the Consuer Advocate files this Foral Coplaint in order to ensure that the Copany's proposed purchased gas cost rates are consistent with a least- cost fuel procureent policy and do not result in rates and charges that are excessive, unjust or unreasonable, discriinatory or otherwise contrary to Coission regulation or policy, and to ensure that all quarterly updates to Peoples' PGC rate were done in accordance with the Public Utility Code and the Coission's regulations. 5. What do you want the Public Utility Coission to do about your coplaint? The Consuer Advocate respectfully requests that the Public Utility Coission: A. Hold evidentiary hearings as andated by Section 1307 (f) ofthe Public Utility Code; B. Hold public input hearings in Peoples' service territory if consuer interest arises; C. Deny any rate or tariff changes which are not the result of a least cost fuel procureent policy as defined by the standards set forth in section 1318 of the Public Utility Code, and as defined by other applicable rateaking standards; D. Ensure that Peoples custoers are not allocated any costs which should not be boe by the. E. Deny any rate or tariff change that is unjust, unreasonable, unduly discriinatory or contrary to sound rateaking principles; F. Grant any other relief the Coission ay dee appropriate.

5 YOU MUST SIGN AND DATE YOUR COMPLAINT. The inforation I have placed on this for is true and correct to the best of y knowledge. I understand that I could be punished under Pennsylvania State Law if I purposely give false inforation. March 14, If you are represented by a lawyer in this atter you ust provide your lawyer's nae, address and telephone nuber. Lawyer's Nae: Address: Jaes A. Mullins, Assistant Consuer Advocate Shaun A. Sparks, Assistant Consuer Advocate 555 Walnut Street, Foru Place, s" 1 Floor Harrisburg, PA Telephone Nuber: S7940

6 PUBLIC STATEMENT OFTHE OFFICE OF CONSUMER ADVOCATE PURSUANT TO 71 P.S. SECTION 309-4(e) Act 161 ofthe Pennsylvania General Assebly, 71 P.S , as enacted July 9, 1976, authorizes the Consuer Advocate to represent the interests of consuers before the Pennsylvania Public Utility Coission ("PUC" or "Coission"). In accordance with Act 161, and for the following reasons, the Consuer Advocate deterined to file a Foral Coplaint before the Coission involving The Peoples Natural Gas Copany d/b/a Doinion Peoples ("Doinion Peoples.") That Coplaint concerns the rates that Doinion Peoples charges its custoers for natural gas service. The objective ofthe Consuer Advocate in filing a Foral Coplaint in this atter is to protect the interests of custoers of Doinion Peoples. The Consuer Advocate will fully exaine and investigate the proposed rate changes to deterine if those changes are both adequate and lawful. The Consuer Advocate respectfully requests that the Pennsylvania Public Utility Coission provide for full hearings to deterine if those rate changes coply with Pennsylvania law, and if they do not, to grant the appropriate relief. MAR DOCUMENT FOLDER

7 0) CERTIFICATE OF SERVICE Pennsylvania Public Utility Coission v. Docket No. R Peoples Natural Gas Copany d/b/a Doinion Peoples 1307(f) Proceeding I hereby certify that I have this day served a true copy of the foregoing docuent, the Foral Coplaint and Public Stateent ofthe Office of Consuer Advocate, upon parties of record in this proceeding in accordance with the requireents of 52 Pa. Code 1.54 (relating to service by a participant), in the anner and upon the persons listed below: Dated this 14 lh day of March Richard A. Kanaskie, Esquire Office of Trial Staff Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street Harrisburg, PA SERVICE BY and INTEROFFICE MAIL SERVICE BY and FIRST CLASS MAIL Lillian S. Harris, Esquire Hawke, McKeon, Sniscak & Kennard, LLP 100 North Tenth Street P.O. Box 1778 Harrisburg, PA Susan G. George, Esquire Peoples Natural Gas Copany 625 Liberty Avenue Pittsburgh, PA 15222

8 (I Willia R. Lloyd, Jr. Sall Business Advocate Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA Stephen J. ICeene Senior Assistant Consuer Advocate Jaes A. Mullins Shaun A. Sparks Assistant Consuer Advocates Counsel for Office of Consuer Advocate 555 Walnut Street 5th Floor, Foru Place Harrisburg, PA (717) S7891.DOC CO CR s* rn o -<-a < c: XT' * ) i t--» * i' i CD _> ro c:

9 COMMONWEALTH OF PENNSVLVANIA PENNSYLVANIA PUBLIC UTILITY COMMISSION P O BOX 3265, HARRISBURG PA March 15, 2006 LILLIAN S HARRIS, ESQUIRE HAWKE MCKEON SNISCAK & KENNARD LLP 100 NORTH 10 TH STREET HARRISBURG PA MAR RE: PA PUC vs THE PEOPLES NATURAL GAS COMPANY D/B/A DOMINION PEOPLES Docket Nuber R C0001 Dear Sir/Mada: A Coplaint has been filed against you in the above-captioned atter before the Pennsylvania Public Utility Coission by OFFICE OF CONSUMER ADVOCATE. This coplaint, of which the attached is a true and correct copy, has been presented and filed of record with the Pennsylvania Public Utility Coission. The Pennsylvania Public Utility Code, 66 Pa. C.S., requires the Coission to serve on each party naed in a coplaint a copy of the coplaint. Within twenty (20) days fro the date on which this coplaint is served, you ay either satisfy this coplaint or coply with the provisions of 52 Pa. Code, Section 5.61 et seq., as aended. Very truly yours, Jaes J. McNulty Secretary (SEAL) Certified Mail Retu Receipt Requested DOCUMENT ane

10 LVANIA PUBLIC UTIUTY COMMISSION Foral Coplaint For Please Print or type. FEB 2k P 8-33 H8: 1. CUSTOMER NAME (COMPLAINANT) BUREAU Your nae, ailing address, county, telephone nuber, utility account nuber and service address: Nae /Srttfr V /T^fV a Street/P.O. Box /?n V KaX ^ / i Apt# City tflj?>bnf\ State /^S County S^yLAiR AreaCode/HOMEPhone(^/_yy (o^>9 7 Area Code/WORK Phone Utility Account Nuber (fro your bill) 7- y&av-<333?-o<ks- DOCUMENT FOLDER If your coplaint Involves utility service provided to a different address than your ailing address, please list this infonnation below. Nae Street/P.O. Box APR City Zip 2. UTILITY NAME (RESPONDENT) Nae of utility copany your coplaint concerns: - 3 oz-n ttf/o V F^FkZS, 3. TYPE OF UTILITY (check one) ELECTRIC STEAM HEAT [3 / GAS WASTEWATER WATER MOTOR CARRIER (taxi, oving copany, liousine) TELEPHONE (local, long distance) Rev. Jan. 200$

11 4. ' COMPLAINT (check one) A. In genera!, what is your coplaint? I want to oppose the copany's ^fep^j^edrate increase. There are incorrect charges on y bill. There is a reliability, safety or quality proble with y utility service. I received a notice that y utility service is being terinated. I would like a payent agreeent. Other (explain) B. State the facts pf your coplaint Include any specific dates, ties or places that are iportant. If the coplaint is about a bill, tell us about any charges that you believe are not correct. Use additional paper if you need ore space. Provide copies of all relevant docuents you believe will support your coplaint ^ IO WftrTT To 0 E TtfE. A/ Y5 5. RELIEF What do you want the Public Utility Coission to do about your coplaint? additional paper if you need ore space. Use Rev. Jan. 2005

12 6. ' PROTECTION FROM ABUSE * Answer the following question if your coplaint is against a natural gas distribution copany, an electric distribution copany or a water copany AND your coplaint is about a billing proble, an application for service proble, a terination of service proble or a request for a payent agreeent Has a court granted a "Protection fro Abuse" order for your personal safety? YES NO 7. PRIOR UTILITY CONTACT Answer the following question only if you are a residential custoer and your coplaint is against an electric distribution utility, natural gas distribution utility or a water distribution utility. Have you spoken to a utility copany representative about this coplaint? YES (indudes appeals of BCS deterinations) ca^ NO tf you tried to, but could not speak to a utility copany representative about your coplaint please explain why. 8. VERIFICATION AND SIGNATURE You ust print or type your nae below on the line provided for the verification paragraph, and you ust sign and date (in ink) this for on the lines provided. Verification: i / /<<)* t V Hf/cJO), hereby state that the facts above set forth are true and correct (or are true and correct to the best of y knowledge, inforation and belief) and that I expect to be abie to prove the sae at a hearing held in this atter. I understand that the stateents herein are ade subject to the penalties of 18 Pa. CS (relating to unsworn falsification to authorities). (Signahife) O?-»X*>-6<D (Date) Rov. Jan. 2005

13 I 9. ; LEGAL REPRESENTATION (IF ANY) If you'are represented by a lawyer in this atter you ust provide your lawyer's nae, address and telephone nuber. State Zip 10. FILING Please retu the copleted for to one ofthe addresses listed below: If usina U.S. Postal Service: Secretary Pennsylvania Public Utility Coission P.O. Box 3265 Hasburg, PA If usina oveiaht deiiverv service: Secretary Pennsylvania Public Utility Coission 400 North Street Coonwealth Keystone Building, 2 nd Boor Harrisburg. Pennsylvania Facsiiles and/or electronic filings ofthe coplaint for will not be accepted. If you have any questions about filling out this for, please contact the Secretary's Bureau at Keep a copy of your coplaint for your records Rav. Jan. 2005

14 Lb COMMONWEALTH OF PENNSYLVANIA PENNSYLVANIA PUBLIC UTILITY COMMISSION P O BOX 3265, HARRISBURG PA April 6, 2006 LILLIAN S HARRIS, ESQUIRE HAWKE MCKEON SNISCAK & KENNARD LLP 100 NORTH TENTH STREET HARRISBURG PA DOCUMENT FOLDER RE: PA PUC vs THE PEOPLES NATURAL GAS COMPANY Docket Nuber R C0002 Dear Sir/Mada: A Coplaint has been filed against you in the above-captioned atter before the Pennsylvania Public Utility Coission by HARRY HRICKO. This coplaint, of which the attached is a true and correct copy, has been presented and filed of record with the Pennsylvania Public Utility Coission. The Pennsylvania Public Utility Code, 66 Pa. C.S., requires the Coission to serve on each party naed in a coplaint a copy of the coplaint. Within twenty (20) days fro the date on which this coplaint is served, you ay either satisfy this coplaint or coply with the provisions of 52 Pa. Code, Section 5.61 et seq., as aended. Very truly yours, (SEAL) Jaes J. McNulty Secretary Certified Mail Retu Receipt Requested ane A PR

15 PENNSYLVANIA PUBLIC UTILITY COMMISSION Foral Coplaint For Please print or type. J). f<l-ooa Ulhoi C CUSTOMER NAME (COMPLAINAN I) Your nae, ailing address, county, telephone nuber, utility account nuber and service address: AHg. Nae ( ^ / ^ / / d f ^ C~ t^l ZGJO OB/) CC^PO n Cl J9M^gS Street/P.O. Box 232 /Sj/ii/l $ 7~ Apt # City 4-4^^^ County / n ^ ^ c K state _ Zip 7 Area Code/HOME Phone Area Code/WORK Phone ^fb-zc'tz r Utility Account Nuber (fro your bill) J J /- >/S~ ^ f / U i_i L_l i_j ^ V_ If your coplaint involves utility service provided to a different address than your ailing address, please list this inforation below. Nae Street/P.O. Box City State DOCUMENT FOLDER APR ^ Zip 2. UTILITY NAME (RESPONDENT) Rev. Jan Nae of utility copany your coplaint concerns TYPE OF UTILITY (check one) ELECTRIC GAS WATER TELEPHONE (local, long distance) _J vj* \j L. FOLDER STEAM HEAT WASTE WATER <_ > -] ' 1-0 IT! ^ { -t-, '. Xj ' IVIOTOR CARRIER > (taxi, oving copany, liousine) co MAR nn ~n CD ro AH O CO cr: ^ J. (j ^. -!

16 (H 4. COMPLAINT (check one) A. In general, what is your coplaint? 2 I want to oppose the copany's proposed rate increase. 51 There are incorrect charges on y bill. There is a reliability, safety or quality proble with y utility service. I received a notice that y utility service is being terinated. I would iike a payent agreeent. B Other. X /Ot>r SitL Tfrr Th ut/a/ty foaf/y?, S/O'JO (explain) USC/? l/f/y 6*> >0 JvPfti/ffg/tfT^Ujke*V rflo^/vt 7~& ur/t/ry 7& ^rsf ht&a B. State the facts of your coplaint. r\rt/cv v IOTK Include any specific dates, ties or places that are iportant. If the coplaint is about a bill, tell us about any charges that you believe are not correct. Use additional paper if you need ore space. Provide copies of all relevant docuents you believe will support your coplaint. r h 645 &iu f**- ntv AK T" t*"*** tvctv "TMeA """TA. 5. RELIEF What do you want the Public Utility Coission to do about your coplaint? additional paper if you need ore space. Use nte fax rae n+r J-W/? / h^ a < A " " awry C'P*"**- J Rev. Jan. 2005

17 to 6. PROTECTION FROM ABUSE Answer the following question if your coplaint is against a natural gas distribution copany, an electric distribution copany or a water copany AND your coplaint is about a billing proble, an application for service proble, a terination of service proble or a request for a payent agreeent. Has a court granted a "Protection fro Abuse" order for your personal safety? YES NO PRIOR UTILITY CONTACT Answer the following question only if you are a residential custoer and your coplaint is against an electric distribution utility, natural" gas distribution utility or a water distribution utility. Have you spoken to a utility copany representative about this coplaint? YES (includes appeals of BCS deterinations) NO J3 If you tried to, but.could not speak to a utility copany representative about your coplaint, please explain why. 8. VERIFICATION AND SIGNATURE You ust print or type your nae below on the line provided for the verification paragraph, and you ust sign and date (in ink) this for on the lines provided. Verification.-^? / ^, hereby state that the facts above set forth are true and correct (or are true and correct to the best of y knowledge, inforation and belief) and that I expect to be able to prove the sae at a hearing held in this atter. I understand that the stateents herein are ade subject to the penalties of 18 Pa. C.S (relating to unsworn falsification to authorities). (Signature) (D^) / Rev. Jan. 2005

18 to 9. LEGAL REPRESENTATION (IF ANY) If you are represented by a lawyer in this atter you ust provide your lawyer's nae, address and telephone nuber. Lawyer's Nae Street City State Zip Area Code/Phone Nuber 10. FILING Please return the copleted for to one ofthe addresses listed below: If using U.S. Postal Service: Secretary Pennsylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA If using overnight deiiverv service: Secretary Pennsylvania Public Utility Coission 400 North Street Coonwealth Keystone Building, 2 nd Floor Harrisburg, Pennsylvania Facsiiles and/or electronic filings of the coplaint for will not be accepted. If you have any questions about filling out this for, please contact the Bureau at Secretary's Keep a copy of your coplaint for your records Rev. Jan. 2005

19 to COMMONWEALTH OF PENNSYLVANIA PENNSYLVANIA PUBLIC UTILITY COMMISSION P O BOX 3265, HARRISBURG PA LILLIAN S HARRIS, ESQUIRE HAWKE MCKEON SNISCAK & KENNARD LLP 100 NORTH TENTH STREET HARRISBURG PA RE: APRIL 6, 2006 D0CUMEN FOLDER PA PUC vs THE PEOPLES NATURAL GAS COMPANY Docket Nuber R C0003 Dear Sir/Mada: A Coplaint has been filed against you in the above-captioned atter before the Pennsylvania Public Utility Coission by CHARLES COULSON. This coplaint, of which the attached is a true and correct copy, has been presented and filed of record with the Pennsylvania Public Utility Coission. The Pennsylvania Public Utility Code, 66 Pa. C.S., requires the Coission to serve on each party naed in a coplaint a copy of the coplaint. Within twenty (20) days fro the date on which this coplaint is served, you ay either satisfy this coplaint or coply with the provisions of 52 Pa. Code, Section 5.61 et seq., as aended. Very truly yours, (SEAL) Jaes J. McNulty Secretary Certified Mail Retu Receipt Requested APR SS

20 MONWEALTH OF PENNSYLV, J^A OFFICE OF SMALL BUSINESS ADVOlfA Suite 1102, Coerce Building 300 North Second Street Harrisburg, Pennsylvania T)EI D Willia R. Lloyd, Jr. Sall Business Advocate April 10,2006 (717) (717) (FAX) HAND DELIVERED Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street Harrisburg, PA Re: DOCUMENT Pennsylvania Public Utility Coission v. The Peoples Natural Gas Copany, t/a Doinion Peoples Docket No. R COOCM to rn rn CO cr CD CO 03 rn O rn Dear Secretary McNulty: I a delivering for filing today the original plus three copies of the Foral Coplaint, Public Stateent, and Verification, as well as a Notice of Appearance for Sharon E. Webb, on behalf of the Sall Business Advocate, in the above captioned atter. Two copies have been served today on all known parties in this proceeding. A Certificate of Service to that effect is enclosed. If you have any questions, please do not hesitate to contact e. Sincerely, Enclosures Sharon E. Webb Assistant Sall Business Advocate cc: Certificate of Service Brian Kalcic 13

21 PENNSYLVANIA PUBLIC UTILITY COMMISSION BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMI v. DOCKET NO. R C O C O THE PEOPLES NATURAL GAS COMPANY, d/b/a Doinion Peoples 1307(0 CERTIFICATE OF SERVICE I certify that I a serving two copies of the Foral Coplaint, Verification, Public Stateent, and Notice of Appearance for Sharon E. Webb, on behalf of the Office of Sall Business Advocate, by e-ail and first class ail upon the persons addressed below: Lillian S. Harris, Esquire Hawke McKeon Sniscak & Kennard 100 North Tenth Street P.O. Box 1778 Harrisburg, PA (717) (717) (fax) lsharris@.hsk-law.co Susan G. George, Esquire Peoples Natural Gas Copany 625 Liberty Avenue Pittsburgh, PA (412) Irwin A. Popowsky, Esquire Office of Consuer Advocate 555 Walnut Street 5th FL Foru Place Han-isburg, PA (717) (717) (fax) spopowskvfsipaoca.org Richard A. Kanaskie, Esquire Office of Trial Staff Pa. Public Utility Coission P.O. Box 3265 Harrisburg, PA (717) (717) (fax) o 5 rkanaskiefajstate.pa.us =6 rn 5 CD 33 rn o Date: April 10, 2006 Sharon E. Webb Assistant Sall Business Advocate rn C: CO CO < rn Z3

22 at BEFORE THE ff\ PENNSYLVANIA PUBLIC UTILITY CdMWIISSIOlSSJ PENNSYLVANIA PUBLIC UTILITY COMMISSION v. ' DOCKET NO. R G.CC04 THE PEOPLES NATURAL GAS COMPANY, T/A DOMINION PEOPLES COMPLAINT OF SMALL BUSINESS ADVOCATE DOCUMENT The Coplainant is: Willia R. Lloyd, Jr. Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA (717) The nae and address of the Coplainant's attorney is: CO rn o rn -<-, cr rn O cn CO o fry O Sharon E. Webb Assistant Sall Business Advocate Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA (717) The respondent utility is: APR The Peoples Natural Gas Copany 625 Liberty Avenue Pittsburgh, PA 15222

23 0) 4- The Coplainant is authorized and directed by the Sall Business Advocate Act, Act 181 of 1988, 73 P.S , to represent the interests of sall business consuers of utility services in atters before the Pennsylvania Public Utility Coission ("Coission"). 5. On March 1, 2006, pursuant to Section 1307(0 of the Public Utility Code, 66 Pa. C.S. 1307(0, The Peoples Natural Gas Copany t/a Doinion Peoples ("PNG" or "Copany") subitted pre-filed supporting inforation concerning its annual Purchased Gas Cost ("PGC") Rate filing. On March 31, 2006, the Copany ade its definitive Section 1307(0 filing and subitted testiony. 6. Section 1318 ofthe Public Utility Code, 66 Pa. C.S. 1318, provides that no rates of a natural gas distribution utility shall be deeed just and reasonable unless the Coission finds that the utility is pursuing a least cost fuel procureent policy, consistent with the obligation to provide safe, adequate and reliable service. The Coission ust find, aong other things, that the utility has (1) fully and vigorously represented ratepayer interests before the Federal Energy Regulatory Coission; (2) taken all prudent steps to negotiate favorable gas supply contracts and to relieve its obligations under contracts that ay be adverse to ratepayer interests; (3) taken all reasonable steps to obtain lower cost gas supplies; and (4) not withheld or caused to be withheld gas supplies that should have been utilized as part of a least cost fuel procureent policy. 66 Pa. C.S. 1318(a). 7. The OSBA files this Foral Coplaint to ensure that the Copany's proposed purchased gas cost rates are consistent with a least cost fuel procureent policy and do not result in rates and charges that are excessive, unjust, unreasonable, discriinatory or otherwise contrary to Coission regulation or policy.

24 8. In view of the foregoing, the Sall Business Advocate respectfully requests that the Pennsylvania Public Utility Coission: a. Hold evidentiary hearings in accordance with Section 1307(0 of the Public Utility Code; b. Deny any proposed rate changes which are not the result of a least cost fuel procureent policy as defined by the standards set forth in Section 1318 of the Public Utility Code, and as defined by other applicable rateaking standards; c. Ensure that PNG's sall business custoers are not allocated any costs that should not be boe by the; d. Deny any rate change that is unjust, unreasonable, unduly discriinatory or contrary to sound rateaking principles; and e. Grant such other relief as ay be necessary or appropriate. Respectfully subitted, Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA (717) (717) (fax) Willia R. Lloyd, Jr. Sall Business Advocate Attorney ID # Dated: April 7, 2006

25 VERIFICATION I. Willia R. Lloyd, Jr., hereby state that the facts set forth herein above are true and correct to the best of y knowledge, inforation and belief and that I expect to be able to prove the sae at a hearing held in this atter. I understand that the stateents herein are ade subject to the penalties of 18 Pa. C.S (relating to unsworn falsification to authorities). Date: April 7, 2006 (Signature) CO r-o o -n. -* ~n "zry ~^ -.. O J-. < c ~ ^ } rn cr CO ' * i * * > cn o cr; CO

26 DOCUMENT FOLDER PUBLIC STATEMENT OF SMALL BUSINESS ADVOCATE. ^ CONCERNING THE INTEREST '^/-o ^ c OF SMALL BUSINESS CONSUMERS ' J^' <J>. TO BE PROTECTED BY THE FILING OF A COMPLAINT ^ < > AGAINST THE 2006 GAS COST RATE FILING OF '<. THE PEOPLES NATURAL GAS COMPANY / ^ t/a DOMINION PEOPLES DOCKET NO. R' The Sall Business Advocate is authorized and directed to represent the interest of sall business consuers of utility services in Pennsylvania under the provisions of the Sall Business Advocate Act, Act 181 of 1988, 73 P.S ("Act"). The Act further provides that the Sall Business Advocate is to issue publicly a written stateent stating concisely the specific interest of sall business consuers to be protected by his initiation of or intervention in any proceeding involving those interests before the Public Utility Coission or any other agency or court. This public stateent relates to the filing today by the Sall Business Advocate of a. coplaint against the proposed 2006 Gas Cost Rate Filing of The Peoples Natural Gas Copany, t/a Doinion Peoples ("PNG" or "Copany"). The Sall Business Advocate files this foral coplaint against PNG's proposed Gas Cost Rate in order to protect the interests of the Copany's sall business custoers. A thorough inquiry by the Public Utility Coission into all of the eleents of PNG's proposed gas cost rate is necessary to ensure that the utility is pursuing a least cost fuel procureent policy, consistent with the obligation to provide safe, adequate and reliable service. In view ofthe foregoing, the Sall Business Advocate will participate in proceedings before the Public Utility Coission to investigate the reasonableness of the proposed rates in PNG's 2006 Gas Cost Rate Filing. The Sall Business Advocate will ask the Coission to deny any proposed rate increase or other changes in PNG's present tariffs that apply to sall business custoers that are APR ^

27 not proven by PNG to be lawful, just, reasonable, and non-discriinatory to all of its custoer classes. Dated: April 7 t 2006

28 PENNSYLVANIA PUBLIC UTILITY COMMISSION BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION v. DOCKET NO. R ; THE PEOPLES NATURAL GAS COMPANY, T/A DOMINION PEOPLES NOTICE OF APPEARANCE DOCUMEN The Office of Sall Business Advocate, pursuant to 52 Pa. Code 1.24, hereby enters the appearance of Sharon E. Webb in the above captioned proceeding. Docuents in this proceeding should continue to be served on the following. Sharon E. Webb Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, Pennsylvania (717) (717) CO rn o rn '-J ZD rn O era ~o CO cn co o rn < o APR Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA (717) (717) (fax) Sharon E. Webb Assistant Sall Business Advocate Attorney ID No For: Willia R. Lloyd, Jr. Sall Business Advocate Attorney ID No Dated: April 7, 2006

29 (0 COMMONWEALTH OF PENNSYLVANIA PENNSYLVANIA PUBLIC UTILITY COMMISSION P O BOX 3265, HARRISBURG PA APRIL 12,2006 LILLIAN S. HARRIS, ESQUIRE HAWKE MCKEON SNISCAK & KENNARD LLP 100 NORTH TENTH STREET HARRISBURG PA DOCUMENT RE: PA PUC vs PEOPLES NATURAL GAS COMPANY T/A DOMINION PEOPLES Docket Nuber R C0004 Dear Sir/Mada: A Coplaint has been filed against you in the above-captioned atter before the Pennsylvania Public Utility Coission by OFFICE OF SMALL BUSINESS ADVOCATE. This coplaint, of which the attached is a true and correct copy, has been presented and filed of record with the Pennsylvania Public Utility Coission. The Pennsylvania Public Utility Code, 66 Pa. C.S., requires the Coission to serve on each party naed in a coplaint a copy of the coplaint. Within twenty (20) days fro the date on which this coplaint is served, you ay either satisfy this coplaint or coply with the provisions of 52 Pa. Code, Section 5.61 et seq., as aended. Very truly yours, (SEAL) Jaes J. McNulty Secretary Certified Mail Retu Receipt Requested jih APR

30 Horace P. Payne, Jr. Senior Counsel 0) Doinion Resources Services, Inc. 625 Liberty Avenue, Pittsburgh, PA Phone: , Fax: E-ail: Web Address: II ^Doinion CERTIFIED MAIL Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA March 27, 2006 RECEIVED MAR PA PUBLIC UTILITY COMMISSION Dear Secretary McNulty: Re: Harry Hricko v. The Peoples Natural Gas Copany at Docket No.~e On behalf of The Peoples Natural Gas Copany, enclosed please find an original and three (3) copies of its Answer filed in the above-referenced atter. If you have any questions or concerns regarding this atter, please do not hesitate to contact e. DOCUMENT FOLDER Very truly yours, Enclosures cc: Harry Hricko, R.D. 4, Box 211, Altoona, PA Joseph Gregorini - Doinion Tower

31 0) Harry Hricko v. The Peoples Natural Gas Copany COMMONWEALTH OF PENNSYLVAN BEFORE [ ty THE PUBLIC UTILITY COMMISSION ) Coplaint Docket ) No. ^ ) 2006 fc-6066,13t> >C0a,lT DOCUMEN C RECEIVED ANSWER OF THE PEOPLES NATURAL GAS COMPANY d/b/a DOMINION PEOPLES MAR 2 8 ^og Aditted. PA PUBLIC UTILITY C0MMI8SION The Peoples Natural Gas Copany d/b/a Doinion Peoples Ek&HuTAriV'i PUR^y 625 Liberty Avenue Pittsburgh, PA Horace P. Payne, Jr., Counsel for The Peoples Natural Gas Copany n 4. Aditted. Under Section 1307(f) of the Public Utility Code, Doinion.Peoples subits its "annual" gas cost recovery filing to be effective October 1 of each year. The Pennsylvania Public Utility Coission subjects this filing to a full investigation and final rates are not ipleented until the Coission renders a final decision on the level of the gas cost rate. Under Section 1307(f), Doinion Peoplesfilesquarterly changes to its purchased gas cost rates to be effective January 1, April 1, July 1 and October 1. These quarterly filings serve two purposes: to adjust the gas cost rate to true-up any prior period over or under collections, and to update the projected costs with the ost current inforation available. The three coponents of gas cost (Capacity, Gas Cost Adjustent Charge, and Natural Gas Supply Charge) reflect a pass-through of the costs that Doinion Peoples incurs for buying gas on behalf of our custoers. There is no ark-up or profit added. By law, Doinion Peoples ust purchase the lowest cost gas that is available. Over the^past few years natural gas prices have reained at higher than historical levels for soe of the following reasons: The decrease in gas production as a result of recent hurricanes. Continued aging of ost ajor U.S. and Canadian gas fields. Relatively cheap, easy to produce gasfieldsare being depleted.

32 il Growth of gas for use in power generation Decline in gas iportsfrocanada Deand for gas in short ter is very inelastic, so there are very large jups in price when supply is constrained 5. Doinion Peoples states that Coplainant's concerns about gas costs are not appropriately addressed in this foru and should instead be reviewed in future rate proceedings of Respondent. Furtherore, portions of the coplaint are directed to the Coission itself and cannot be answered by Doinion Peoples. For the reasons listed above, Doinion Peoples respectfully requests that this coplaint be disissed. 6. Unknown to Respondent. 7. Aditted. Respectfully subitted, torace P. Payne, Jr. Counsel for The Peoples Natural Gas Copany

33 ti VERIFICATION COMMONWEALTH OF PENNSYLVANIA ) ) SS: ALLEGHENY COUNTY ) Susan G. George, being duly sworn or affired according to law, deposes and says that she is Assistant Secretary of The Peoples Natural Gas Copany d/b/a Doinion Peoples; that she is authorized to and does ake this verification for it; that the facts set forth above are true and correct to the best of her knowledge, inforation and belief; and that she expects the said The Peoples Natural Gas Copany d/b/a Doinion Peoples to be able to prove the sae at the hearing hereof. Sworn and subscribed before e this 2&ttLzy of ^H^t^cA., Notary Public Notarial Seal r!? A- Mason, Notafy Public MyCo^onExa^ Feb. 18,2010 Meber, P e n n s y ] ^ ^ ^ ^ ^

34 CERTIFICATION OF SERVICE proceeding. I hereby certify that 1 have served a copy of the foregoing upon each party to this Done at Pittsburgh, Pennsylvania, this day of^f^jj/la Acs- Horace P. Payng^Jr. Counsel ft The Peoples Natural Gas Coinpany 2 B 2008

35 Horace P. Payne, Jr. Senior Counsel Doinion Resources Services, Inc. 625 Liberty Avenue, Pittsburgh, PA Phone: , Fax: E-ail: Web Address: 3^ ^ Doinion" March 27, 2006 CERTIFIED MAIL Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA Dear Secretary McNulty: Re: Charles Coulson v. The Peoples Natural Gas Copany at Docket Nofe^ On behalf of The Peoples Natural Gas Copany, enclosed please find an original and three (3) copies of its Answer filed in the above-referenced atter. If you have any questions or concerns regarding this atter, please do not hesitate to contact e. DOCUMENT FOLDER Very truly yours. Enclosures cc: Charles Coulson, 232 Blair St., Grove City, PA Joseph Gregorini - Doinion Tower Heather Doyle - Doinion Tower c D MAR FA PUBLIC UTiLITY COMMISSIQN

36 0) COMMONWEALTH OF PENNS BEFORE THE PUBLIC UTILITY COMMISSION Charles Coulson d/b/a Econ-o-CIeaners ) Coplaint Docket v. ) No. e3f)065929~ The Peoples Natural Gas Copany ) 2006 THE RSCE.VED ^ -000,6/201(2.0001, MAR ANSWER OF pugi ITII ITV PEOPLES NATURAL GAS COMPANY fircn ^ ' i JX PPW'-«SS!0N d/b/a DOMINION PEOPLES ' 3 ^ ^ 1. Aditted. The Peoples Natural Gas Copany d/b/a Doinion Peoples 625 Liberty Avenue Pittsburgh, PA Horace P. Payne, Jr., Counsel for The Peoples Natural Gas Copany 4. DOCUMENT FOLDER Aditted. Under Section 1307(f) of the Public Utility Code, Doinion Peoples subits its "annual" gas cost recovery filing to be effective October 1 of each year. The Pennsylvania Public Utility Coission subjects this filing to a full investigation and final rates are not ipleented until the Coission renders a final decision on the level of the gas cost rate. Under Section 1307(f), Doinion Peoplesfilesquarterly changes to its purchased gas cost rates to be effective January 1, April 1, July 1 and October 1. These quarterly filings serve two purposes: CO C3 CD ct: <C to adjust the gas cost rate to true-up any prior period over or under collections, and to update the projected costs with the ost current inforation available. The three coponents of gas cost (Capacity, Gas Cost Adjustent Charge, and Natural Gas Supply Charge) reflect a pass-through of the costs that Doinion Peoples incurs for buying gas on behalf of our custoers. There is no ark-up or profit added. By law, Doinion Peoples ust purchase the lowest cost gas that is available. Over the past few years natural gas prices have reained at higher than historical levels for soe of the following reasons: The decrease in gas production as a result of recent hurricanes.

37 It Continued aging of ost ajor U.S. and Canadian gas fields. Relatively cheap, easy to produce gas fields are being depleted. Growth of gas for use in power generation Decline in gas iports fro Canada Deand for gas in short ter is very inelastic, so there are very large jups in price when supply is constrained Finally, Doinion Peoples adits that Coplainant was rendered an estiated bill on Deceber 27, 2005 due to an inability to access the property to obtain a eter reading. In accordance with 52 Pa. Code , when a public utility encounters difficulty in obtaining access to a property to obtain a eter read, estiated bills can be rendered. As indicated on the attached Doinion Peoples Stateent of Account ("Exhibit A"), other than the Deceber 27, 2005 billing, Coplainant's natural gas bill has been based on an actual reading obtained every other onth going back to February, Doinion Peoples states that Coplainant's concerns about gas costs are not appropriately addressed in this foru and should instead be reviewed in future rate proceedings of Respondent. Furtherore, portions of the coplaint are directed to the Coission itself and cannot be answered by Doinion Peoples. For the reasons listed above. Doinion Peoples respectfully requests that this coplaint be disissed. Unknown to Respondent. Aditted. Respectfully subitted, ' c */<k torace P. Payne, Jj/^ Counsel for ^ The Peoples Natural Gas Copany

38 DOMINION PEOPLES Stateent of Account Nao AbtJfess CHARLES COULSON DBA Ep 232 BLAIR ST Account Nuber g1 For Questions Call (800^ DETAILS READ DATE AVG BILL, READ METER DAILY DAYS SOURCE READING USAGE USAGE DEGREE DAYS BILL AMT SALES/ STATE TAX CITY/ COUNTY TAX DUE DATE LATE,- PMT, PMT. ;. : ' CHRGE * AMOUNT,PMT DATE ADJ AbJuisT DESC'. v TOTAL ' PLAN PLAN^.PLAN ACCT DESC AMTDUE AMT DUE BALANCE 1...; 'JJ, -^^ 03/15/ $.00 $.00 $.00 $.00 $2, ^15/2006 $.00 $.00 "$.ooi8u.3f> 02/27/ ACTUAL $ $17.82 $.00 03/21/2006 $.00. $00,.".foo 100 $ /22/ GUST READ 2, $.00 $.00 $.00. $.00,.$00.': $ $ $.00. $.00 $.00 $.00 :$.oo './ v.. $-38.& ; $.00 $.00 02/08/2006 * _ $.00. S.00 $.00 $.00.$.00 ( $-36:64. LPC, $.00 J s:oo 01/27/ SYSTEM EST ^ : $2, $ $.00 02/22/2006._$3e.'64..j $.00.,.. /IOO W 100,..s.oo $4, ^7/ SYSTEM EST 2, $2, $ S.00 01/20/2006 $.00 $1,498,87 12/28/2005, $.00 $.00 s.00 $2, /22/2005 2a SYSTEM EST $1, $84.73 $.00 12/20/2005 $.00 $ llflijWMM r. t ;$.>o ':. ; $.00 $.00 $1, ^5^ ACTUAL $ $54.39 $.00 11/16/2005 $.00- $ /10/2005 $.00-1 $ 0 0. "..s.oo $ ^V 'SYSTEM EST 2, $ $49.42 $.00 10/19/2005 $.00, $ ;O9/14/2O08 ' $.00,100. $.00 $872,96 06/25/ ACTUAL io 2 $ $45.46 $.00 09/16/2005 $.00 $ /17/2005 ^OO. 07/20/ SYSTEM EST Z3 0 $ $54.15 $.00 08/19/2005 $.00 $ /11/2005 S $.00 ^. M oo $ /24/ ACTUAL 1, $ $55.92 $.00 07/18/2005 $.00 $ '06/20/ $.00. ; $.00. $-00 $ '05^24/ OUST READ $1, $59.03 $.00 06/21/2005 $.00 $ /17/2005 $:oo..... $.00.' s.00 $1, /25/ ACTUAL $481.6* $27.27 $.00 05/18/2005 S.00 $1, /21/2005 '. $.00 -, ^$.00. $ /28/ SYSTEM EST 1, Si, $ $.00 04/21/2005 $.00 $2, /17/2005. " too "* «>.-s.oo $ jd2/24k005 t. 29 ACTUAL _. 1 '- a30 r2!_ $1, $88.88 $.00 03/16/2005 $23.13 '. $.00,,". $.00. $.00 " S.00 $2, ':, s.oo s.oo $1, " '- '. ff1/2^605, 35 SYSTEM EST 1.5M ,1173 SI, $87.27 $.00 02/22/2005 $.00 $1, /14/ $.00 $.00 $1, /20/ CUST READ 1, $.00 $.00 -,$ 00,.. $.00. $.00, $.00 $ /22/20M 34 ACTUAL :i $1,139.90, $84.63 $.00 01/13/2005 $.00 "$918.06"12/13/2004 $.00 $.00 ' $.00 $1, /18/ 'CUST READ $ $51.86 $.00 12/15/2004 $.00 $1, /05^004 $.00 $ $ /21/ ACTUAL 1, $ $33.34 $.00 11/12/2004 $13.92 S :$.oo.... S.OO'- $.00 $1, /22/ SYSTEM EST-1;155.8~ '3.r 22* S $52.52 $.00 10/18/2004' $.00 $ (^/09/ fpo $.00 $.00 $ /23/ ACTUAL S 25 $500:13 $26.31 $.00 09/14/2004 $.00 $ /23/2004 $.00.: $.00 $.00 $ /23/ SYSTEM EST 1, $ $ 56:3$ $.00.,-. $.00. JCOOJ' $.00 $.00 ^,..$.00 07/23/ 'MANUAL'EST 1,014.4, $ $55:61 $.00 08/24/ $.00 $.00, - ^... $.00 ' ' $.00 $.06 $ /23/ SYSTEM EST 1,014, $ $ /18/2004 $.00 $1, /12/2004 $.00 CANCEL.-'..* :. $-00 $.00.$995.'47. 06/23/ ACTUAL $ $32.45 $.00 07/15/2004 $.00, $.00. =.*oo.,* /24/ SYSTEM EST _M; $ $.00 $.00 $.00 -'. '":- ;;.V i ;-\...S.OQ _,./ $ i $.00- $1, /24/ CUST READ S 149" $ $27.47 $.00 07/ ". $.00,$.00.,.^100,., ^ _ $.00 $.00 $ /24/ SYSTEM EST $1, $59.32 $.00 06/17/2004 $.00 $ /10/2004 ' ',$.00 CANCEL. $ $1, /22/ ACTUAL $ $8.76 $.00 05/17/2004 $.00 $1, /14/2004 $,00, $.00 $.00 $ /24/ SYSTEM EST Jl, $67.08 $.00 04/ $.00 $1,845:48 03/18/2004, - $.00 $.06 ICQ $1, "EXHIBU A 1 'PAGE 1 OF 2"

39 DOMINION PEOPLES Stateent of Account Nae CHARLES COULSON DBA EC Account Nuber 3461S For Questions Cal! (600^764^)111 Aiidress.232 BLAIR ST Meter Nuber Hearing Ipaired Custoers Cali,tDD (90p)- 3?;:1333 DETAILS ;-. AVG - :' READ' BILL ' READ ' METER '' DAILY- DATE DAYS ' SOURCE' READING USAGE USAGE DEGREE ' "-" "BILt DAYS" " AMT' ' * SALES/ STATE COY/. COUNTY " L TAX. TAX'.... J;.... DUE - DATE..lATEl. PMT- CHRGE p-- '. AMOUNT RNfTDATE ' ADj;-. ' ADJUST DESC.. >.'., - TOTAL" '* PLAN.^ PLAN^. PLAN-; facct! DESC" AMT DUE AMT DUE BALANCE.02/24/ ACTUAL $ $47.01 $.00 03/17/2004 ^5.00. $ /23/2004 $.06 $.00 S'.QO $1, /26/2004 3S SYSTEM EST , $1, $91.28 $.00 02/19/2004 $.00 $1, /12/2004 $.00,, '. $.00 $.00 $1, '12^ ACTUAL $1, $5970 $.00 01/13/2004 $.00 $ /10/2003 $.00. $.00 $.00 SI /19/ SYSTEM EST $ $54.41 $ /2003 $.00 $ /10/2003 $.00 $.00 S.00 $9' /22/2003 ;,30 ACTUAL $ $1.06 $.00 11/13/2003 $.00 $ /16/2003 $.00 - : $.00. S.OO $ /22/ SYSTEM EST 97; $ $1.04 $.00 10/18/2003 $.00 $222.88,09/10/2003. $.00 $.00 $.00. $ ^1/ ACTUAL : $ $.88 $.00 09/12/2003 $.00 $ /13/2003 $.00,. $.00 $.00 $ /23/2003,. 30 SYSTEM EST.9, $ $.95 $.00 08/18/2003 $.00 $ /14/2003 $.00 ";. $.00,$:oo $238:36 06/23/ ACTUAL. ^ : $ $1.10 "S.OO 07/15/2003 $.00 $ /18/2003. _. -' " $.00 ' $.00 $i269;is.'65/ SYSTEM EST $ $1.07 $.00 06/18/2003 $.00 $ /12/2003 $.00 S.Q0., _ S.00 $ '' " ';'/. '04/23ffiCfQ3. 30 ACTUAL $ $.86 $.00 05/15/ VM; $344:97,^0^y/20p3_ $ /; >.-. f-oo. _,;$:oo $216.78».=.-- 03/24/ SYSTEM,EST $ $1.46 $;oo 04/17/2003 $.00 $723-22^03/11/2003. $.00_ S-OO S:'00 Ji3M.97.' 02/ ''. /, ACTUAL 9i362.6 r.'*" L - ' '- V $.00 03/18/2003, ' - - x * : 0 ^.sxo_ $ '. '.',.' t ' i 1 ^-iv-:.. r" i' ) i BUD-BUDGET PLAN DEF - DOLLAR ENERGY FUND DEP- DEPOSITS CtA. CONtiNAlQ.OeCONST / NSC - INSUFFICIENT FUNDS CHARGE DFA - DEFERRED AGREEMENT' LPN - LATE PWT CHRGE (NONUTIUTY) LPC - LATE PMT CHRGE RCC - RECONNECTION CHANGE N^t'wsuwfcterrtiibfe AMOUNT INT'- INTEREST'. NSH - INSUFFlCiENT FUNDS (NONUTIUTY) UTG-UTILITY "-. - DSCNT- DISCOUNTv-^^" *

40 0 VERIFICATION COMMONWEALTH OF PENNSYLVANIA ) ) SS: ALLEGHENY COUNTY ) Susan G. George, being duly sworn or affired according to law, deposes and says that she is Assistant Secretary of The Peoples Natural Gas Copany d/b/a Doinion Peoples; that she is authorized to and does ake this verification for it; that the facts set forth above are true and correct to the best of her knowledge, infonnation and belief; and that she expects the said The Peoples Natural Gas Copany d/b/a Doinion Peoples to be able to prove the sae at the hearing hereof. Susan G. George Sworn and subscribed before e this ^^faay of'v^ci^l, Notary Public COMMONWEALTH OF PENNSYLVAMIA Notarial Seal Barbara A Mason, Notaiy Public City Of Pittsburgh, Allegheny County My Coission Expires Feb. 18,2010 Meber, Pennsylvania Association of Notaries

41 CERTIFICATION OF SERVICE proceeding. I hereby certify that I have served a copy of the foregoing upon each party to this Done at Pittsburgh, Pennsylvania, this, zr- Horace P. Payng&fr. Counsel f<5r The Peoples Natural Gas Copany SL7 $ >TyCn

42 Hawke McKeon ATTORNEYS AT LAW Sniscak & K ennard LLP a T. Hawke n J. McKeon ofn3s J. Sniscak Noran Jaes Kennard Lillian Sith Harris Scott T Wyland Todd S. Stewart Craig R. Burgraff Steven D. Snyder Janet L. Miller Steven K. Haas Willia E. Lehan Rikardo J. Hull Katherine E. Lovette 100 North Tenth Street, Harrisburg, PA Phone: Fax: VIA HAND DELIVERY Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street - Filing Roo P.O. Box 3265 Harrisburg, PA April 26, 2006 Re: R C Pennsylvania Public Utility Coission v. The Peoples Natural Gas Copany d/b/a Doinion Peoples; ANSWER TO COMPLAINT OF HARRY HRICKO Dear Secretary McNulty: This correspondence is in response to the April 6, 2006 Secretarial Letter regarding the re-docketed coplaint of Mr. Harry Hricko. Mr. Hricko's coplaint was originally docketed at Docket No. C On March 27, 2006, Doinion Peoples filed an answer to the coplaint. The Coission has now re-docketed the coplaint in Doinion Peoples' 1307(f) proceeding at Docket No. R C0002. Doinion Peoples stands on its previously-filed answer and copies of that answer are attached hereto for inclusion in the Coission's files in this proceeding. A copy of this correspondence is being served on Mr. Hricko, the Honorable Mark A. Hoyer, and the other active parties of record. Thank you for your attention to this atter. Yery^truly yours. co o a-* LSH/kl cc: Per Certificate of Service illian S. Harris cr rn co cr ro CD rn o C7 imailing ADDRESS: P.O. BOX 1778 HARRISBURG, PA 17105

43 Horace P. Payne, Jr. Senior Counsel Doinion Resources Services, Inc 625 Liberty Avenue. Pinsburgh, PA Phone: 412^ , Fax: E-ail: Web Address: o CERTIFIED MAIL Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA March 27,2006 r Ceo. CP 5 CP. Dear Secretary McNulty: Re: Harry Hricko y. The Peoples Natural :Gas Copany at Docket Kb. C On behalf of The Peoples Natural: Gas Copany, enclosed please find an original and three (3):copies of its Answer filed in the above-referenced atter. If you have any questions or concerns regarding this atter, please do not hesitate to contact e. Very truly yours. Enclosures cc: Harry Hricko, R.D. 4, Box 211,'Altoona, PA Joseph Gregorini - Doinion Tower

44 <lf> COMMONWEALTH OF PENNSYLVANIA BEFORE THE PUBLIC UTILITY COMMISSION Harry Hricko v. The Peoples Natural Gas Copany ) Coplaint Docket )No.C ) Aditted. ANSWER OF THE PEOPLES NATURAL GAS COMPANY d/b/a DOMINION PEOPLES - 2. The Peoples Natural Gas Copany d/b/a Doinion Peoples 625 Liberty Avenue Pittsburgh, PA Horace P. Payne, Jr., Counsel for The Peoples Natural Gas Copany 3. Aditted 4. Under Section 1307(f) of the Public Utility Code, Doinion Peoples subits its "annual" gas cost recovery filing to. be. effective October 1 of each year.. The Pennsylvania Public Utility Coission subjects this filing to a full investigation and final rates are not ipleented until the Coission renders a final decision on the level of the gas cost rate. Under Section 1307(f), Doinion Peoples files quarterly changes to its purchased gas cost rates to be effective January 1, April 1, July I and October These quarterly filings serve two purposes: MAY to adjust the gas cost rate to true-up any prior period over or under collections, and to update the projected costs with the ost current inforation -available. The three coponents of gas cost (Capacity, Gas Cost Adjustent Charge,.and Natural Gas Supply Charge) reflect a pass-through of the costs that Doinion Peoples incurs for buying gas on behalf of our custoers. There is no ark-up or profit added. By law, 'Doinion Peoples ust purchase the lowest cost gas that is available..over the past few years natural gas prices have reained at higher than historical levels for soe ofthe following reasons: The decrease in gas productionas a result of recent hurricanes.. Continued aging of ost ajor U;S. and Canadian gas fields.. ^Relatively cheap, easy to produce gas fields are being depleted.

45 Growth of gas for use in power generation Decline in gas iports fro Canada Deand for gas in short ter is very inelastic, so there are very large jups in price when supply is constrained Doinion Peoples states that Coplainant's concerns about gas costs are not appropriately addressed in this foru and should instead be reviewed in future rate proceedings of Respondent. Furtherore, portions of the coplaint are directed to the Coission itself and cannot be answered by Doinion Peoples. For the reasons listed above. Doinion Peoples respectfully requests that this coplaint be disissed Unknown to Respondent Aditted. Respectfully subitted. torace P. Payne, Jr. Counsel for The Peoples Natural Gas Copany

46 VERIFICATION COMMONWEALTH OF PENNSYLVANIA ) ) SS: ALLEGHENY COUNTY ) Susan G. George, being duly sworn or affired according to law, deposes and says that she is Assistant Secretary of The Peoples Natural Gas Copany d/b/a Doinion Peoples; that she is authorized to and does ake this verificationfor it; that the facts set forth above are true and correct to the best of her knowledge, inforation and belief; and that she expects the said The Peoples Natural Gas Copany d/b/a Doinion Peoples to be able to prove the sae at the hearing hereof. Sworn and subscribed before e this ^g^day of ^h^mu^t, Notary Public CQMMONWFAt TH QF PEMMSV, X,*^ NotariafSeal Barbara A Mason, Notary Publfc Cty Of RHsburgn. Allegheny County jyiycotssion Expires Feb Meber. Pennsylvania Assodalioh of Notarifs

47 CERTIFICATION OF SERVICE proceeding. I hereby certify that I have served a copy of the foregoing upon each party to this Done at Pittsburgh, Pennsylvania, this _^ Horace P. Payn^LJr. Counsel fe The Peoples Natural Gas Cotnpany

48 # CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the foregoing docuent upon the persons and in the anner indicated below. Service by First Class Mail Harry Hricko R.D. 4 Box 211 Altoona, PA Service by First Class Mail and Electronic Mail Honorable Mark A. Hoyer 1103 Pittsburgh State Office Bldg. 300 Liberty Avenue Pittsburgh PA Richard A. Kanaskie, Esquire Office of Trial Staff Pennsylvania Public Utility Coission P. O. Box 3265 Hasburg, PA Shaun A. Sparks, Esquire Assistant Consuer Advocate Office of Consuer Advocate 555 Walnut Street, Foru Place, 5 th Floor Harrisburg, PA Sharon Webb, Esquire Assistant Sall Business Advocate Office of Sall Business Advocate Suite 1102 Coerce Building 300 North Second Street Harrisburg, PA o I*> ~X) CO' CO cr > c: C=3 cr> 3*. fv) CD JO o < rn Dated: April 26, 2006 Lillian S. Harris

49 Hawke McKeon Sniscak & ATTORNEYS AT LAW ] jcennard LLP Willia T. Hawke Kevin J. McKeon Thoas J. Sniscak Noran Jaes Kennard Lillian Sith Harris Scott T. Wyland Todd S. Stewart Craig R. BurgrafF Steven D. Snyder Janet L. Miller Steven K. Haas Willia E. Lehan Rikardo J. Hull Katherine E. Lovette 100 North Tenth Street, Harrisburg, PA Phone: Fax: April 26, 2006 VIA HAND DELIVERY Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street - Filing Roo P.O. Box 3265 Harrisburg, PA DOCUMENT FOLDER Re: R C Pennsylvania Public Utility Coission v. The Peoples Natural Gas Copany d/b/a Doinion Peoples; ANSWER TO COMPLAINT OF CHARLES COULSON Dear Secretary McNulty: This correspondence is in response to the April 6, 2006 Secretarial Letter regarding the re-docketed coplaint of Mr. Charles Coulson. Mr. Coulson's coplaint was originally docketed at Docket No. C On March 27, 2006, Doinion Peoples filed an answer to the coplaint. The Coission has now re-docketed the coplaint in Doinion Peoples' 1307(f) proceeding at Docket No. R C0003. Doinion Peoples stands on its previously-filed answer and copies of that answer are attached hereto for inclusion in the Coission's files in this proceeding. A copy of this correspondence is being served on Mr. Coulson, the Honorable Mark A. Hoyer, and the other active parties of record. Thank you for your attention to this atter. ly yours, LSH/kl cc: Per Certificate of Service illian S. Harris MAILING ADDRESS: P.O. BOX 1778 HARRISBURG, PA t" ^1

50 Horace P. Payne, Jr. Senior Counsel Doinion Resources Services, Inc. 625 Liberty Avenue, Pinsburgh, PA Phone: , Fax: ' E-ail: Web Address: vw.do.co March 27, 2006 o i TO >- cn ^3 o CERTIFIED MAIL Jaes J. McNulty, Secretary ipersylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA ro CD crv Dear-Secretary McNulty: Re: Charles Conlsoh v. The Peoples Natural Gas Copany at Docket No. C On behalf of The Peoples Natural Gas Copany/enelosed.pleasefind an original and three (3) copies of its Answerfiledin the above-referenced atter. If you have any questions or concerns regarding this atter, ;please do npt hesitate to contact e. Encloisures cc:' rcharies Coulson, 232 Blair : St., Grove City, PA Joseph Gregorini - Doinion Tower v/ ' Heather Doyle - Doinion Tower '

51 o COMMONWEALTH OF PENNSYLVANIA * ^ ^ ^ BEFORE ^ THE PUBLIC UTILITY COMMISSION ^.V 0 ^ Charles Coulson d/b/a Econ-o-CIeaners ) Coplaint Docket ^ cg^ v. ) No. C The Peoples Natural Gas Copany ) 2006 & ANSWER OF THE PEOPLES NATURAL GAS COMPANY d/b/a DOMINION PEOPLES DOCUMENT 1. Adited. FOLDER 2. The Peoples Natural Gas Copany d/b/a Doinion Peoples 625 Liberty Avenue. Pittsburgh, PA Horace P. Payne, Jr., Counsel for The Peoples Natural Gas Copany 3. Aditted. 4.. Under Section 1307(f) ofthe Public Utility Code, Doinion Peoples subits its "annual" gas cost recovery filing to be effective October 1 of each year. The Pennsylvania Public Utility Coission subjects this filing to a full investigation and final rates are not ipleented until the Coission renders a final decision on the level of the gas cost rate. Under Section 1307(f), Doinion Peoplesfilesquarterly changes to its purchased gas cost rates to be effective January 1, April 1, July 1 and October 1. These quarterly filings serve two purposes:. to adjust the gas cost rate to true-up any prior period over or under collections, and to update the projected costs with the ost current infonnation available.. The three coponents of gas cost (Capacity, Gas Cost Adjustent Charge, and Natural Gas Supply Charge) reflect a pass-through ofthe costs that Doinion Peoples incurs for buying gas on behalf of our custoers. There is no ark-up or profit added. By law. Doinion Peoples ust purchase the lowest cost gas that is available. -Over the past few years natural gas prices have reained at higher than historical levels for soe of the following reasons:. The decrease in gas production as a result of recent hurricanes.

52 Continued aging of ost ajor U.S. and Canadian gas fields. Relatively cheap, easy to produce gas fields are being depleted. Growth of gas for use in power generation Decline in gas iportsfrocanada Deand for gas in short ter is very inelastic, so there are very large jups in price when supply is constrained Finally, Doinion Peoples adits that Coplainant was rendered an estiated bill on Deceber 27,2005 due to an inability to access the property to obtain a eter reading. In accordance with 52 Pa. Code , when a public utility encounters difficulty in obtaining access to a property to obtain a eter read, estiated bills can be rendered. As indicated on the attached Doinion Peoples Stateent of Account {"Exhibit A"), other than the Deceber 27,2005 billing. Coplainant's natural gas bill has been based on an actual reading obtained every other onth going back to February, Doinion Peoples states that Coplainant's concerns about gas costs are not appropriately addressed in this foru and should instead be reviewed in future rate proceedings of Respondent Furtherore, portions of the coplaint are directed to the Coxnission itself and cannot be answered by Doion Peoples. For the reasons listed above, Doion Peoples respectfully requests that this coplaint be disissed. 6. Unknown to Respondent. 7. Aditted. Respectfully subitted. torace P. Payne, Counsel for The Peoples Natural Gas Copany

53 i#^9htdfac»iuht SALES/. CitW STATE TAX ftfflfflffi Vi ^Ag^,,j/.zjao.7 ^r-a-.-.w^st-...^/^^ -g^^-' ^r>-^---» - ^'1 'i-i. irfntitilfir - I II ' ii i i f --r if- -H * - ^ i y, r : _ r-l-\...^, -'-'-*~-**-'rt'-i'ii'i f, '[. r ' ^ i - Tirr ri 'V^ir^T7irr*" J -r'-- / -,: -^i'iiiivr'iifiifti- i (, -i-r-^rifr^fifi-; 'ffwsal56ii4'.:.31 ACTUAL i-, ^r, I-* -T i «1.B& $.00 12rt5/i»64 ^^ «.jj'^^la!!^'. f ', ' l '-<^ir'^'if-- f.- l- J ---.-r-v '"IY'I -MP. : "$:M >t,i3s.9b ^^ ^^ (^ MP 11/12tt lb4 $13.02 r ---^^^\'-. T 2-.^^...v^L -Y^;-.-, ^-Q 0..;-: vw -5aia.C5 "EXHIBIT A" "PAGE 1 OF 2"

54 bmlnttn PEOPLES StateiMt of Accburiit A'ddr%8,.^32:61 jgt. 'I ' Meier Nuber 222S2S 2 ^^Oeifteiril'Call fadav^s^aii : - - >.''...'':V/',,-J:,.' : -AVG'''- SALES/,>..dtixi.~ P i&b- eia'"- '.METERS DA^ besrtev- fittc... SfXTe cotw ^;cc^';'&a ^:.'6'oia^>fti^))»G. u^ ";DAVS"- " y. ^ wx-..tw.-. DAT? CttRQE,"iWfiWiW-PSirrtWVTE " : "'WjljV DESfc"'.; OESC" O^E AMt tjitfealandfe to ' 1070 StOOM M7.01 IOO 03/17/2004 ' $1S.C0. JS12.M Ky23fl 0t>4 ' S.OO J.66'" $':q'd, $1,845.^6 MOTftW ' ^ 'sf&f&xti&r ttoa ^7 taw tidies 53', /1^004 $.00 $1, OI/lSSW* '. ' $, VPO 5i,8'ia.69 IfB-l ttMLftftft J5970. $.00 Qinw too $«i^a IZAIVZWI SJDO $,00 $1.0M,57 jift'ibdm;.. 28 SvatfiM EST o.'.i&a 3.a. 473 tnua t-m 12/15/ J.OO $267,78 ilflj^zhios $:*."too "sjoa $9Si.a 10^'(^3-.h:.atfAtttUAl.. 4=18.7 'l'lfl.8.., 4.0'. Ml $i.i». iti. 9,00.iwtttt',.. Veif 42W.78 J.0O. WIO - *2fi7.78 $.00 id/iefioos J.OO -*.oo *x»o -szss.te ^7^^-.-2^'Ai3TliAi:.. 9,WS.7 (f7;e, $.88...$.00 09/12/2003 S.Ot) j36.0s/1s2to3 $.06.. $,00 $,00.$222:80 ffitisfitfsz -30 5*51651 EST &R&8- flsj... T 35, 0.it»8.4B..%» too oerftaooa. it» UltoJb-tfttti \: *M ', $.oo. iwo.$2^38 i,..... i.52 ACTUAI-'. -.o fti&:7 -w.110 $2S&:i5.$1.10 *.00,.Q7rt$ftEW3 208 i.99 $1.07 too eefftebfe..wo" «i*^»:fl5rt2fi(wi ' ^.-!0*ft^SAl&:';.. Sb.ACJTUAL.' *. ^.. ^ fel8;78 $.88 $.dd osnstibos ssftitf.ovff.. fcft.- C^te5^\.. C'^ACTUAL.&;36Ze - - ^ i r -ni--,,!^- - I " '... $1^8 $;oa 04M7/25Ss-.- ^.06 ' ipasaa esiiisxa:,. t.t»..: ' ' ' ',..v... 1 ^ _ i - j. -. li ; $.00 03/)8S( if Tnif nntfi'i'i i^^intlliyrr''i'"i''ft w r,; rrf-""-* /.^^S'uffib^^. UTG iuriuty.- - DSCNT * O^tif^: rr,-: ' ' -^