Natural Gas

In Re: I/M/O the Merger of Exelon Corporation, Pepco Holdings, Inc., Potomac Electric Power Company, Exelon Energy Delivery Company, LLC and New Special Purpose Entity, LLC. Docket No. FC 1119. Ongoing. ACG is assisting the Office of the People’s Counsel for the District of Columbia in analyzing the policy aspects of the proposed merger including its potential impacts.

In Re: I/M/O The Peoples Gas Light and Coke Company and North Shore Gas Company Proposed General Increase in Gas Rates. Case No. 14-0224/14-0225. Ongoing.  ACG is assisting the Illinois Attorney General in a benchmarking and investment performance analysis regarding the Companies’ petitions. This includes comparing the Companies to a peer group with respect to usage, pricing, pipeline materials, replacement, and safety data.

In Re: I/M/O Iberville Parish v. Acadian Gas Pipeline System. Ongoing. ACG is assisting Phillip J. Caballero, C.P.A. in the determination of the market value of pipeline construction materials purchased before the construction period for tax purposes.

In Re: I/M/O The Petition of NSTAR Gas Company for approval by the Department of Public Utilities, pursuant to G.L. C. 164, § 94A and § 94B, of a Gas Service Agreement between NSTAR Gas Company and Hopkinton LNG Corp.; D.P.U. No. 14-64. Ongoing. ACG is assisting the Massachusetts Attorney General with an examination of the Company’s filing. This includes reviewing rate changes and the prudency of the agreement as well as analyzing ratepayer cost impacts.  

In Re: I/M/O Anthony Williams, et al. vs. Duke Energy Corporation, et al. Case No.: 1:08-cv-0046. Ongoing. ACG is assisting Demarco Law Firm with an analysis of Ohio retail electricity markets and the transfer of Duke settlement terms from regulated to unregulated operations. Additionally, ACG is conducting an analysis/estimation of potential excess profits arising from Duke’s retail market actions.

In Re:  I/M/O the Petition of South Jersey Gas Company for Approval of Increased Base Tariff Rates and Charges for Gas Service and Other Tariff Revisions; BPU Docket No. GR13111137. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in analyzing the economic, policy, and engineering aspects of the Company’s filing.  This includes evaluating its compliance with the energy master plan and other regulations as well as analyzing capital expenditures.

In Re:  I/M/O the Petition of Public Service Electric & Gas Company for Approval of Electric and Gas Base Rate Adjustments Pursuant to the Capital Infrastructure Investment Program Extension; BPU Docket No. ER13111108/GR13111109. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the reasonableness and prudence of the Company’s request to recover gas infrastructure project costs from their CIP II program by rolling $7.1 million into base rates.

In Re:  I/M/O the Board's Establishing of a Generic Proceeding to Review the Prudency of Costs Incurred by NJ Utility Companies in Response to Major Storm Events in 2011 and 2012 (South Jersey Gas Company); B.P.U. Docket Nos. AX13030196/GO13060600. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas.  In connection with major storm events, ACG is examining the Company’s restoration efforts and is assessing the prudency of costs incurred.

In Re:  I/M/O the Petition of South Jersey Gas Company for Approval of the SHARP and Associated Recovery Mechanism; BPU Docket No. GO13090814. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas concerning their storm hardening and reliability infrastructure program.  ACG is reviewing the economic, policy, and engineering aspects of the Company’s filing.

In Re:  I/M/O the Board's Establishing of a Generic Proceeding to Review the Prudency of Costs Incurred by NJ Utility Companies in Response to Major Storm Events in 2011 and 2012 (PSE&G); B.P.U. Docket Nos. AX13030196/EO13070607. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by Public Service Electric & Gas.  Concerning PSE&G’s gas operations, ACG is examining the Company’s restoration efforts and is assessing the prudency of costs incurred in connection with major storm events.

In Re:  I/M/O the Petition of South Jersey Gas Company to Change the Levels of its Societal Benefits Clause (“SBC”) and its Transportation Initiation Clause (“TIC”); B.P.U. Docket No. GR13070685. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas.  ACG is analyzing the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  I/M/O the Petition of Public Service Electric & Gas Company for Approval of Changes in Its Electric Green Programs Recovery Charges and Its Gas Green Programs Cost Recovery Filing; BPU Docket Nos. ER13070603/GR13070604. Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the proposed rate changes involving six of the Company’s energy efficiency programs.

In Re:  I/M/O the Petition of Public Service Electric & Gas Company to Modify its Manufactured Gas Plant (MGP) Remediation Component Within its Electric Societal Benefits Charge (SBC) and its Gas SBC; for a Board Order Finding that its MGP Remediation Work Performed During the Remediation Adjustment Charge (RAC) 20 Period, August 1, 2011 to July 31, 2012.  Completed 2014.    ACG assisted the New Jersey Division of Rate Counsel in examining the petition by PSE&G.  ACG analyzed the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  I/M/O the Petition of Public Service Electric & Gas Company - Sale of MGP Property in City of Camden, in Middlesex County.  Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the sales contract proposed by the Company with respect to its subsidiary, New Jersey Properties, Inc.

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas to Amend its Tariff to Include a Natural Gas Vehicle Service Classification; BPU Docket No. GT1308785. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by Elizabethtown Gas.  ACG is investigating whether the Company’s proposal will adversely impact the rates charged or services provided to its customers under other service classifications.

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas for Approval of the ENDURE Program and Deferred Accounting Treatment; BPU Docket No. GO13090826. Completed 2014. ACG assisted the New Jersey Division of Rate Counsel in examining the petition by Elizabethtown Gas concerning their Distribution Utility Reinforcement Effort infrastructure rate program.  ACG reviewed the economic, policy, and engineering aspects of the Company’s storm hardening program filing for reasonableness and prudency.

In Re:  I/M/O New Jersey Gas Company for Approval of the NJ RISE Program and Associated Rate Recovery Mechanism; BPU Docket No. GO13090828. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by New Jersey Natural Gas requesting approval of their proposed infrastructure program, the NJ Reinvestment in System Enhancement, and the associated accounting treatment and cost recovery mechanism.  ACG is reviewing the economic, policy, and engineering aspects of the Company’s filing.

In Re:  I/M/O the Board's Establishing of a Generic Proceeding to Review the Prudency of Costs Incurred by NJ Utility Companies in Response to Major Storm Events in 2011 and 2012 (New Jersey Natural Gas Company); B.P.U. Docket Nos. AX13030196/GO13070610. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by New Jersey Natural Gas.  In connection with major storm events, ACG is examining the Company’s restoration efforts and is assessing the prudency of costs incurred. 

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas to Revise the Remediation Adjustment Clause Component of its Societal Benefits Charge Rate; BPU Docket No. GR13090839. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by Elizabethtown Gas.  ACG is investigating the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  I/M/O New Jersey Natural Gas Company’s Annual Review and Revision of its Societal Benefits Charge Factors for Remediation Years 2012 and 2013; B.P.U. Docket No. GR13070674. Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition by New Jersey Natural Gas.  ACG is investigating the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  In the Matter of Advice Letter No. 791 Filed by Public Service Company of Colorado to Increase the Rates for All Natural Gas Sales and Transportation Services by Implementing a General Rate Schedule Adjustment (GRSA) in the Company’s Colorado P.U.C. No. 6 Gas Tariff to Become Effective January 17, 2011; Docket No. 10AL-963G. Completed 2014.  ACG assisted Colorado’s Office of Consumer Counsel with an examination of the Pipeline System Integrity Adjustment (“PSIA”) Reports filed by the Company.  ACG assessed the reasonableness and prudence of the Company’s PSIA operations and maintenance expenditures and internal auditing policies associated with the first annual PSIA review.

In Re:  I/M/O the Petition of Public Service Electric & Gas Company for Approval of the Energy Strong Program; BPU Docket No. EO13020155/GO13020156. Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by Public Service Electric and Gas Company.  ACG addressed the overall economic impact of both the electric and natural gas components of the Energy Strong proposal including cost, rate, and employment impacts.  ACG also addressed public policy issues and engineering issues associated with the Company’s natural gas system hardening modification proposals.

In Re:  Strategic Energy/Economic Development Report. Completed 2013.  ACG was retained by the Mississippi Energy Institute (“MEI”) to develop a research tool that could be used to assist state, regional, and local economic development professionals as well as other policy stakeholders in successfully competing for a number of rapidly-emerging energy-based manufacturing opportunities arising from the unconventional energy production revolution now occurring in the U.S.  ACG produced a study designed to educate stakeholders about how this revolution had arisen, how it was being successfully leveraged to create a new “manufacturing renaissance” in the U.S., and how Mississippi could actively and successfully participate in this new renaissance.

In Re:  Bay State Gas Company d/b/a Columbia Gas of Massachusetts’s Petition for Approval of an Increase in Base Distribution Rates for Gas Service; D.P.U. 13-75; Completed 2013.  ACG assisted the Attorney General’s Office with an analysis of the Company’s Targeted Infrastructure Replacement Factor (TIRF) and issues relating to infrastructure replacement, regulatory lag, and environmental benefits of the TIRF.  ACG also conducted a benchmarking analysis comparing the Company’s O&M and A&G costs on a per customer and per volume basis.

In Re:  In the Matter of the Petition of South Jersey Gas Company for Authorization to Construct a 24” Pipeline through Maurice River Township in Cumberland County, City of Estell Manor in Atlantic County and Upper Township in Cape May County, New Jersey; Docket No. GO13030202. Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in reviewing the Company’s request and evaluated the necessity of the new pipeline.

In Re:  I/M/O the Petition of Public Service Electric and Gas Company to Modify its Manufactured Gas Plant (MGP) Remediation Component within its Electric Societal Benefits Charge (SBC) and its Gas SBC; for a Board Order Finding that its MGP Remediation work Performed During the Remediation Adjustment Charge (RAC) 20 Period, August 1, 2011 to July 31, 2012.; Docket No. GR13040302; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition of Public Service Electric and Gas Company to revise the Remediation Adjustment Clause component of its Societal Benefits Charge.  ACG investigated the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  Investigation of the 2013 Avoided Energy Supply Component (AESC) Study; DPU Dockets 12-100 through 12-111; Ongoing.  ACG is assisting the Massachusetts Office of the Attorney General with a review and analysis of the 2013 Avoided Energy Supply Component Study.  ACG is addressing the issues of avoided generation, transmission, and distribution costs.  ACG is also examining fuel price forecasts and critical input assumptions, Demand Reduction Induced Price Effect, and load forecasts and reserves. 

In the Matter of Advice Letter No. 830-Gas of Public Service Company of Colorado, with Accompanying Tariff Sheets Concerning Implementing a General Rate Schedule Adjustment (GRSA), to become Effective January 12, 2013; Docket No. 12AL-1268G.  Completed 2013.  ACG was been retained by Colorado’s Office of Consumer Counsel to provide an expert opinion on the economic and policy issues associated with the extension and expansion of the Pipeline System Integrity Adjustment (“PSIA”) proposed by Public Service Company of Colorado.  ACG testified against expanding the PSIA because it would lead to a considerable increase in rates, it did not include any performance benchmarks, it was not proved to be cost-effective, it did not address regulatory challenges, and the Company did not provide any specific regulatory or economic justifications.

In Re: I/M/O the Joint Petition of South Jersey Gas Company and RC Cape May Holdings, LLC for Approval of a Standard Gas Service Agreement (FES) and Standard Gas Service Agreement (FES) Addendum; Docket No. GO13010052. Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in reviewing the petition, with a particular focus on the cost allocation issues for the high pressure transmission line and the impacts on ratepayers.

In Re: I/M/O the Consolidated Dockets Involving South Jersey Gas Company's CIRT I, CIRT II, and CIRT III; Docket Nos. GR12100890, GO11100632, GR09110907, G009010051, GR11060334. Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's request to roll into base rates costs associated with its CIRT I, CIRT II, and CIRT III investments. ACG provided an expert opinion on the reasonableness and prudency of the Company’s CIRT investments and conducted analyses on the cost and schedule performance of construction activities, leak reductions, and types of infrastructure replacements. ACG also benchmarked SJG’s pipeline replacement actions and past corrosion-related leak performance against similarly situated utilities.

In Re: I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas for Approval to Revise its Base Rates to Recover the Costs of its Utility Infrastructure Enhancement Program and Related Tariff Revisions; Docket No. GR12100951. Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's request to roll into and recover through base rates $2.1 million in costs associated with its Utility Infrastructure Enhancement (“UIE”) I and II programs. ACG provided an expert opinion on the reasonableness and prudency of the Company’s UIE investments and is conducting analyses on the cost and schedule performance of construction activities, leak reductions, and types of infrastructure replacements. ACG also benchmarked Elizabethtown’s pipeline replacement actions and past corrosion-related leak performance against similarly situated utilities.

In Re: I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas to Revise the 2012 Remediation Adjustment Clause Component of its Societal Benefits Charge Rate; Docket No. GR12100936; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in investigating the budgeting, cost recovery, prudence, and ratemaking treatment of costs in the remediation of the Company’s former manufactured gas plant sites.

In Re: I/M/O the Petition of New Jersey Natural Gas Company to Establish the Rates Necessary to Recover Capital Investment Costs Associated with the Accelerated Energy Infrastructure Investment Programs and for Approval of Necessary Related Changes to Gas Rates in the Company's Tariff; Docket No. GR1211035.  Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's request for recovery of $6.9 million in capital investment costs associated with its AlP I and AlP II projects. ACG provided an expert opinion on the reasonableness and prudency of the AIP I and II projects proposed for addition to rate base. ACG evaluated the Company’s cost and schedule performance, AIP monitoring reports, leak reduction performance, claimed job growth and economic performance, types of infrastructure replacements, and engineering practices related to managing corrosion-related leaks.  ACG also benchmarked NJNG’s pipeline replacement actions and past corrosion-related leak performance against similarly situated utilities.

In Re: I/M/O Cogen Technologies Linden Venture, L.P. Public Service Electric and Gas Company and Elizabethtown Gas Company (1) Motion for Protective Order and Exemption from Public Disclosure of Confidential Information (2) Approval of Gas Service Agreement Between Cogen Technologies Linden, Venture L.P. ("Buyer") and Public Service Gas Company and Elizabethtown Gas Company ("Seller");  Docket No. GM12100970; Completed 2012.  ACG assisted the New Jersey Division of Rate Counsel in preparing comments concerning the petitioners’ proposed modifications to their gas service agreement, whereby, approval of an Interim Operating Agreement for Butane Service ("IOA") was requested.  ACG recommended approval of the modifications contingent upon the Board requiring the petitioners to submit a detailed report documenting the expected and actual impacts of the IOA on the petitioners and ratepayers.

In Re: I/M/O the Petition of Jersey Central Power & Light Company for the Review and Approval of Costs Incurred for Environmental Remediation of Manufactured Gas Plant Sites Pursuant to the Remediation Adjustment Clause of its Filed Tariff (“2011 Annual RAC Filing”); Docket No. ER12080751; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in reviewing the manufactured gas plant environmental remediation costs and expenditures incurred in 2011 by Jersey Central Power & Light.  ACG is also examining the proposal by the Company to defer costs related to Natural Resource Damage issues and incentive compensation costs.

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas for Approval of an Accelerated Infrastructure Replacement Program and an Associated Cost Recovery Mechanism; BPU Docket No. GO12070693.  Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's proposed Accelerated Infrastructure Replacement program, whereby the planned to invest up to $135 million over a five-year period to enhance the safety, reliability, and integrity of its natural gas distribution infrastructure. ACG also analyzed the associated cost recovery mechanism.

In Re:  I/M/O the Petition of South Jersey Gas Company to Implement an Accelerated Infrastructure Replacement Program and Associated Recovery Mechanism; BPU Docket No. GO12070670.  Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's proposed Accelerated Infrastructure Replacement program, whereby they proposed to invest $250 million over five years for the accelerated replacement of its cast iron and bare steel main and service infrastructure.  ACG also analyzed the associated cost recovery mechanism as well as the Company’s Capital Investment Recovery Tracker program.

In Re:  Bay State Gas Company d/b/a Columbia Gas of Massachusetts’s Petition for a Distribution Rate Increase; D.P.U. 12-25; Completed 2012.  ACG was retained by the Massachusetts Attorney General to provide an expert opinion on the infrastructure cost recovery proposals offered by the Bay State Gas Company in their rate case filing.   ACG recommended to the Commission that it reject the Company’s “rate year rate base” proposal finding it to be asymmetrically constructed such that ratepayers would bear an undue amount of risk for investments that may or may not reduce leaks or improve reliability.  ACG also recommended rejection of the Company’s proposals to modify the annual review process for the capital investments eligible under its current Targeted Infrastructure Reinvestment Factor (or “TIRF”).  ACG also recommended that if the TIRF was adopted, a specific leak rate or leak reduction goal should be established to benchmark the Company’s performance.  This goal would require the Company to replace 38 miles of leak-prone mains and 1,839 leak-prone services per year.  Additionally, the Company would also be required to reduce its annual corrosion-related leaks by five percent per year for its mains and seven percent per year for its services. 

In Re:  I/M/O the Petition of New Jersey Natural Gas Company for Approval of the Safety Acceleration and Facility Enhancement Program and Associated Recovery Mechanism; BPU Docket No. GO12030255; Completed 2012.  ACG assisted the New Jersey Division of Rate Counsel with an analysis of the Company's proposal for an accelerated five-year capital investment program for the replacement of the Company's existing cast iron and unprotected steel distribution infrastructure.  ACG participated in settlement negotiations and made recommendations as to the reporting requirements of the program.

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas to Revise the Remediation Adjustment Clause Component of its Societal Benefits Charge Rate; BPU Docket No. GR11080485. Completed 2012.   ACG assisted the New Jersey Division of Rate Counsel in examining the petition of Elizabethtown Gas to revise the Remediation Adjustment Clause component of its Societal Benefits Charge.  ACG investigated the budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites. ACG also evaluated the Company’s competitive bid practices and invoice review process.

In Re:  In the Matter of New Jersey Natural Gas Company Annual Review and Revision of Societal Benefits Charge Factors for Remediation Years 2010 and 2011; BPU Docket No. GR12020123; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining the filing of New Jersey Natural Gas’ Annual Review and Revision of Societal Benefits Charge Factors for Remediation Years 2010 and 2011.  ACG investigated the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  I/M/O Public Service Electric and Gas Company to Modify its Manufactured Gas Plant (MGP) Remediation Component with Its Electric Societal Benefits Charge (SBC); Docket No. GR11100779. Completed 2012.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition of Public Service Electric and Gas Company to revise the Remediation Adjustment Clause component of its Societal Benefits Charge.  ACG investigated the costs, budgeting, cost recovery, prudence, and ratemaking treatment of costs in remediating its former manufactured gas plant sites.

In Re:  Investigation of the Development of the 2011 Avoided Energy Supply Component Study; DPU Docket 11-120; Completed 2012.  ACG assisted the Massachusetts Office of the Attorney General with a review and analysis of the 2011 Avoided Energy Supply Component Study.  ACG addressed the issues of avoided costs, Demand Reduction Induced Price Effect, avoided transmission and distribution costs, and natural gas price forecasts.  ACG also prepared comments on carbon and energy efficiency rules.

In Re:  Avista Utilities 2011 & 2012 General Rate Cases; Consolidated Docket Nos. UG-110877 & 120437; Completed 2012.  ACG assisted the Washington Attorney General with an examination of the revenue decoupling mechanism proposed by the Northwest Energy Coalition as well as revenue requirement issues.  ACG submitted testimony detailing the proposal’s lack of compliance with the UTC’s conservation policy statement and its unfair shift of revenue recovery risk onto ratepayers.

In Re: I/M/O the Petition of South Jersey Gas to Modify and Extend its Existing Capital Investment Recovery Tracker ("CIRT II"); Completed 2012.  ACG assisted the New Jersey Division of Rate Counsel with an examination of the South Jersey Gas filing to extend its accelerated pipeline replacement and cost recovery program.  The CIRT mechanism allowed the Company to recover a return on and of incremental investments associated with certain qualifying projects including its Accelerated Main Replacement Program.  ACG examined the Company’s past pipeline replacement actions and past corrosion-related leak performance as well as the claimed job growth and economic development benefits created under the previous mechanism.  ACG recommended and quantified a leak reduction target based on the Company's long run historic leaks per mile of replaced pipe.

In Re: In the Matter of the Application of SourceGas Distribution LLC, Lakewood, Colorado, seeking approval of a general rate increase; Docket No. NG-0067.  Completed 2012.  SourceGas Distribution requested an annual revenue increase of approximately $8.279 million.  ACG was retained by the Nebraska Public Advocate to review the Company’s petition and provide expert opinions.  ACG recommended the discontinuation of the Company’s High Efficiency Assistance Tool appliance rebate program since it did not conform to accepted standard practices in energy efficiency and would not provide noticeable energy savings.  ACG also recommended the denial of the Company’s proposed Energy Audit and Natural Gas appliance rebate programs since evidence was not provided that they were a cost effective use of ratepayer resources and no performance accountability measures were included.  ACG recommended rejection of the Company’s proposed revenue decoupling mechanism because it would shift revenue recovery risk away from the Company and onto ratepayers.  Also, the decoupling mechanism did not include a review or analysis period, any ratepayer protection provisions, or a significant commitment to energy efficiency.  ACG recommended the rejection of the Company’s proposed CA rider because the Company failed to explain or provide any explicit customer benefits that would arise from the CA Rider.  ACG also recommended rejecting the Company’s proposal to shorten its weather normalization period to twelve years since its methodology was inconsistent with traditional ratemaking practices.  In examining the Company’s CCOSS that they used to estimate the cost of providing service to each customer class, ACG recommended alternative cost allocation factors to Intangible Plant, General Plant, Land & Land Rights, Structures & Improvements, Industrial Measuring and Regulating Station Equipment, Customer Accounts Expense, Sales Expense, and Regulatory Commission Expense.  ACG’s rate design recommendations included changes to customer charges that would move classes closer to the system average rate of return.  ACG recommended the continuation of the existing two-tiered declining block volumetric rate structure.  ACG’s recommendations would prevent any one class from receiving a rate increase greater than 1.25 times the system average.

In Re: In the Matter of the Application of UNS Gas, Inc. for Approval of a Rate Increase; Docket No. G-04204A-11-0158. Completed 2012.  ACG assisted the Arizona Corporation Commission with an examination of the application submitted by UNS Gas, Inc. ACG provided expert testimony and analysis on the issues of revenue decoupling, class cost of service, and rate design. In lieu of the Company's full decoupling proposal, ACG recommended a Lost Fixed Cost Recovery mechanism, which would enable the Company to attain greater amounts of fixed cost recovery as it met its Commission-defined energy efficiency goals. ACG's class cost of service recommendation included a distribution mains allocation of 50-25-25 between customers, demand, and commodity. ACG's rate design methodology provided constraints that prevented any one class from receiving a rate increase greater than 1.25 times the system average.

In Re:  In the Matter of the Application of the Washington Gas Light Company for Authority to Increase its Existing Rates and Charges and to Revise its Terms and Conditions for Gas Service; Case No. 9276. Completed 2011.  ACG assisted the Maryland People’s Counsel with an analysis of Washington Gas Light Company’s rate case application. ACG recommended rejection of the Company’s pipeline replacement rate tracker mechanism and offered provisions and safeguards should the Commission decide a mechanism was needed.  ACG also provided recommendations on the Class Cost of Service Study and rate design, which included constraints that prevented any one class from receiving a rate increase greater than 1.25 times the system average.

In Re:  The Proposed General Increase in Natural Gas Rates by The Peoples Gas Light and Coke Company and North Shore Gas Company; Consolidated Dockets 11-0280 & 11-0281.  Completed 2011.  On behalf of the Illinois Attorney General, ACG prepared direct and rebuttal testimony responding to revenue decoupling and rate design issues.  ACG recommended rejection of the Companies’ proposal to make their Rider Volume Balancing Adjustment Mechanism permanent and also recommended the discontinuance of that revenue decoupling mechanism altogether. 

In Re:  Southwest Gas Corporation’s Application for a Rate Increase, Approval of Deferred Accounting Orders, and for Approval of an Energy Efficiency and Renewable Energy Resource Technology Portfolio Implementation Plan; Docket No. G-01551A-10-0458.  Completed 2011.  ACG assisted the Arizona Corporation Commission with an examination of the application submitted by Southwest Gas Corporation and provided expert testimony on revenue decoupling, the Class Cost of Service Study (CCOSS), and rate design.  ACG recommended rejecting the Company’s proposed efficiency enabling provision mechanism. ACG also provided recommendations on the Class Cost of Service Study and rate design, which included constraints that prevented any one class from receiving a rate increase greater than 1.25 times the system average.

In Re:  Request of Fitchburg Gas and Electric Light Company d/b/a/ Unitil (Gas Division) for an Increase in Base Distribution Rates and a Revenue Decoupling Mechanism; D.P.U. 11-02; Completed 2011.  ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by Fitchburg Gas and Electric Light Company.  ACG provided expert testimony on the Company’s Targeted Infrastructure Replacement Factor and provided recommendations concerning the revenue decoupling reporting.

In Re: New England Gas Company’s Petition for a Base Rate Increase and Decoupling Mechanism; D.P.U. 10-114; Completed 2010. ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by New England Gas Company.  ACG provided expert testimony recommending the rejection of the company’s proposed Targeted Infrastructure Replacement Factor.

In Re: Texas Gas Service’s El Paso Service Area Rate Case; Docket 9988; Completed 2010.   ACG assisted the City of El Paso, Texas, with an examination of the application submitted by Texas Gas Service Company to increase its rates for natural gas service provided to its El Paso Service Area. ACG prepared expert witness testimony and analysis on issues related to the Company’s class cost of service study (minimum system and zero intercept analysis); rate design proposals; and weather normalization adjustment.

In Re: Rate Case for Boston Gas Company, Essex Gas Company, and Colonial Gas Company d.b.a. National Grid; D.P.U. 10-55; Completed 2010.  ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by National Grid to increase the natural gas distribution rates for customers of Boston Gas Company, Essex Gas Company, and Colonial Gas Company. ACG provided expert testimony on issues related to the Companies’ proposed Net Inflation Factor, Revenue Decoupling, Allocated Class Cost of Service, Rate Design, Technology & Innovation Fund, Targeted Infrastructure Rider, and other related matters.

In Re: In the Matter of Chattanooga Gas Company’s Petition for a General Rate Increase; Docket No. 09-00183; Completed 2010.   ACG assisted the Tennessee Attorney General Consumer Advocate & Protection Division with an examination of the application submitted by Chattanooga Gas Company to increase its rates and charges for natural gas service rendered in Tennessee. ACG prepared discovery and analyzed issues regarding the Company’s revenue decoupling proposal and energy efficiency programs. ACG provided testimony on issues surrounding the utility’s energy efficiency program called “energySMART,” the proposed decoupling mechanism, and the bare steel replacement program and its relationship to the proposed decoupling mechanism.

In Re: Texas Gas Service’s El Paso Service Area Rate Case; Completed 2010.   ACG assisted the City of El Paso, Texas, with an examination of the application submitted by Texas Gas Service Company to increase its rates for natural gas service provided to its El Paso Service Area. ACG prepared expert witness testimony and analysis on issues related to the Company’s class cost of service study (minimum system and zero intercept analysis); rate design proposals; weather normalization adjustment; and its cost of service adjustment clause, conservation adjustment clause proposals, and other cost tracker policy issues.

In Re: In the Matter of Piedmont Natural Gas; Docket No. 09-00104; Completed 2010.  ACG assisted the Tennessee Attorney General Consumer Advocate & Protection Division with an examination of the application submitted by Piedmont Natural Gas to implement its proposed energy efficiency programs and corresponding rate mechanisms including revenue decoupling. ACG prepared expert witness testimony examining Piedmont’s proposed revenue decoupling mechanism and included such issues as alignment of utility’s financial incentives with Tennessee’s energy efficiency policy, ratepayer protection mechanisms, effect of decoupling on business risk, and decoupling effects on earnings. ACG’s testimony also addressed the utility’s energy efficiency programs as well as its weather normalized billing determinants.

In Re: In the Matter of SourceGas Distribution LLC, Lakewood, Colorado, Seeking Approval of a General Rate Increase; Docket No. NG-0060; Completed 2010.  ACG is assisting the Nebraska Public Advocate with an examination of the application submitted by SourceGas to increase its distribution non-gas rates and charges for natural gas service rendered in Nebraska. ACG prepared testimony on such issues as revenue decoupling proposal, customer adjustment rider, inflation adjustment rider, pipeline infrastructure cost recovery rider, and several issues related to weather normalization.

In Re: Petition of Bay State Gas Company for Approval of a General Increase in Gas Distribution Rates Proposed in Tariffs M.D.P.U. Nos. 70 through 105, and for Approval of a Revenue Decoupling Mechanism; Completed 2009. ACG assisted the Massachusetts Attorney General with an examination of the application submitted by Bay State Gas Company to increase its distribution non-gas rates and charges for natural gas service rendered in Massachusetts. ACG provided testimony on the Company’s revenue decoupling proposal, the Company’s Targeted Infrastructure Reinvestment Factor (“TIRF”) proposal, and several issues related to the Company’s inclining block rate design proposals.

In Re: Allegations Concerning Activities at the Grand Bayou (Louisiana) Natural Gas Storage Cavern Against Dow Chemical; Completed 2009.  ACG assisted Lemle & Kelleher with analysis, studies, and other support as necessary during the course of litigation. ACG has provided expert analysis and report on gas storage valuation issues.

In Re: The Complaint of Weldon Johnson, Individually and as Representative of Other Arkansas Customers Similarly Situated vs. CenterPoint Energy, Inc., FKA Reliant Energy, Inc., CenterPoint Energy Resources Corp., CenterPoint Gas Marketing Company, CenterPoint Energy Pipeline Services, Inc., CenterPoint Energy Field Services; Kinder Morgan Texas Pipeline, L.P., Kinder Morgan Energy Partners, L.P., Kinder Morgan, G.P., Inc., Kinder Morgan Texas Pipeline, L.P., Kinder Morgan Texas Pipeline, GP, Inc., Kinder Morgan Texas Pipeline, GP, Inc., Texas Gas, LLC, Gulf Energy Marketing, LLC, KM Texas Pipeline, LP, Midcon Corp., Houston Pipeline Company, LP, And Shell U.S. Gas & Power, LLC; Docket No. 07-105-C; Completed 2009.  ACG assisted Arkansas Office of the Attorney General with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Arkla. Analysis included evaluating the costs passed through the purchased gas adjustment clause from affiliated companies.

In Re: Determination of Salt Cavern Lease Agreements, State of Louisiana, Office of Mineral Resources, Completed 2009.  ACG acted in a mediator role evaluating a fair lease structure and payment schedule for two new salt cavern natural gas storage facilities between Jefferson Island Storage and Hub (Sequent/AGL Resources) and the State of Louisiana (Department of Natural Resources, Office of Mineral Resources). Analysis included the development of natural gas storage profitability models under various income earning scenarios and recommendations on lease payment structures.

In Re: Transcontinental Gas Pipeline Corporation Before the United States District Court of Louisiana, Lake Charles Division; Civil Action No. 2:07-CV-2165; Completed 2009.  ACG assisted Transcontinental Gas Pipeline action before the United States District Court of Louisiana. ACG provided expert rebuttal testimony on behalf of Transcontinental Gas Pipeline regarding whether certain properties could be used for an industrial purpose in the near future, absent Transco’s proposed action, and the function for which the subject pipelines are currently, and anticipated, to be utilized.

 

Click the links below to view further examples of ACG's experience in the gas industry.

2005 - 2008

In Re: In the Matter of the Assessment of Value Issued to the Jefferson Island Storage and Hub; Appeal Number 2007-125 and 2007-299. Completed 2008. ACG assisted AGL Resources with its appeal before the Louisiana Tax Commission regarding the valuation of its Jefferson Island natural gas storage facility and hub. ACG provided expert witness testimony on behalf of AGL Resources that included an evaluation and critique of the valuation methods used by the local parish tax assessor and its outside consultants.

In Re: In the Matter of the Application of Questar Gas Company to Increase the Distribution Non-Gas Rates and Charges and Make Tariff Modifications; Docket No. 07-057-13; Completed 2008.  ACG assisted the Utah Committee of Consumer Services with the examination of the application submitted by Questar Gas Company to increase its distribution non-gas rates and charges for natural gas service rendered in Utah. ACG provided expert testimony, exhibits and assistance on class cost of service issues, rate design issues, decoupling, customer charges, and Contributions in Aid of Construction policy matters.

In Re: AGL Resources, Inc., Tax Analysis; Completed 2008.  ACG assisted AGL Resources by reviewing and analyzing the Georgia Department of Revenue Valuation Methodology.

In Re:  Washington Utilities and Transportation Commission v. Northwest Natural Gas Company; WUTC Docket No. UG-080546; Completed 2008. ACG assisted the Washington Attorney General in its examination of several issues in Northwest Natural Gas Company’s rate case and decoupling proposal. These issues included revenue decoupling and rate design with an emphasis on customer charges and the Company’s Smart Energy Program.

In Re: Commission Audit of the Purchased Gas Adjustment Filings of CenterPoint Energy-Arkla; Docket No. U-27196-Subdocket A; Completed 2008.  ACG assisted the Louisiana Public Service Commission with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Arkla. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations.

In Re: Application of SEMCO Energy Gas Company for Authority to Redesign and Increase its Rates for Sale and Transportation of Natural Gas in its MPSC Division and Other Relief; Docket No. U-14893; Completed 2007.  ACG assisted the Michigan Attorney General’s Office in its review of SEMCO’s application for a rate increase and rate redesign. SEMCO had proposed to decouple the Company’s revenues and sales through the elimination of variable charges for all distribution non-gas costs. ACG examined the pros and cons of revenue decoupling, incentive mechanisms to foster conservation and DSM, the current state of decoupling and DSM in the gas industry, the financial impacts of decoupling, the financial impacts of declining sales, the relationship between sales and revenue, deferred accounting mechanisms, and alternatives to decoupling.

In Re: Joint Application of Questar Gas Company, the Division of Public Utilities, and Utah Clean Energy for the Approval of the Conservation Enabling Tariff Adjustment Option and Accounting Orders; Docket No. 05-057-T01; Completed 2007.  ACG assisted the Utah Committee of Consumer Services to examine the joint application submitted by Questar Gas Company, the Division of Public Utilities, and Utah Clean Energy, requesting approval for the adoption of a Conservation Enabling Tariff and other enabling accounting mechanisms and proposals. ACG extensively examined the pros and cons of revenue decoupling, incentive mechanisms to foster conservation and DSM, the current state of decoupling and DSM in the gas industry, the financial impacts of decoupling, the financial impacts of declining sales, the relationship between sales and revenue, deferred accounting mechanisms, and alternatives to decoupling.

In Re: Commission Audit of Purchased Gas Adjustment Filings of Reliant Energy-Entex Pursuant to Commission General Order Dated March 24, 1999; Docket No. U-26721; Completed 2007.  ACG assisted the Louisiana Public Service Commission with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Entex. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations. Once the first phase of the audit had been completed and research indicated that the audit period should be extended to investigate certain irregular cost recovery practices, ACG was hired to continue the investigation.

In Re: Lake Charles Cogeneration Project; Economic Benefit Study; Report filed January 2005; Update in progress.  ACG assisted Lake Charles Cogeneration, LLC, by performing an economic impact study regarding the construction and operation of the Lake Charles Cogeneration and Regasification project. In particular the analysis looked at: (1) economic impacts – including regional investment, direct and indirect benefits, and employment opportunities; (2) fuel diversity – an understanding of gasification, petroleum coke, and the role of hydrogen; (3) economic development – how output from the facility would support a large number of Louisiana industries; (4) environmental benefits; and (5) technological benefits. Impact was estimated for Calcasieu Parish and the State of Louisiana.

In Re: In the Matter of the Assessment of Public Utility Taxable Value Issued to Columbia Gas Transmission; Tax Commissioner’s Case 01-01849 and 01-05338; Completed 2005.  ACG assisted Columbia Gas Transmission with its filings before the Board of Tax Appeals in the State of Ohio, regarding its property valuation. ACG performed analyses of the competitive nature of the natural gas transportation market in Ohio. The analysis concentrated on services offered by LDCs and intrastate and interstate pipelines as well as the role of alternative products.

In Re: Evangeline Gas Company; Completed 2005.  ACG assisted Evangeline Gas Company with an examination of the purchased gas adjustment clause and accounting for gas costs to Evangeline Gas Company. The analysis conducted compared the utility’s calculations to those proposed by the Staff of the PSC to determine if there were over- or under-collections of gas costs that were not properly accounted for. ACG provided the client with an outline of areas for further examination and provided them with an analysis of their gas recovery mechanisms compared to other gas companies in Louisiana.

In Re: ANR Pipeline Company v. Louisiana Tax Commission; Number 468,417 Section 22, 19th Judicial District Court, Parish of East Baton Rouge, State of Louisiana Consolidated with Docket Numbers: 480,159; 489,776; 480,160; 480,161; 480,162; 480,163; 480,373; 489,776; 489,777; 489,778; 489,779; 489,780; 489,803; 491,530;  491,744; 491,745; 491,746; 491,912; 503,466; 503,468; 503,469; 503,470; 515,414; 515,415; and 515,416; Completed 2005.  ACG assisted ANR Pipeline Company with its case before the 19th Judicial District Court, Parish of East Baton Rouge, State of Louisiana by examining the levels of competition between intra- and interstate natural gas pipelines in Louisiana and the Gulf Coast. The analysis concentrated on volumes transported by intra- and interstate pipelines and connections to industrial users.

 

2000 - 2004

In Re: OCS-Related Infrastructure in the Gulf of Mexico Fact Book; Completed 2004.  ACG assisted the Minerals Management Service with a thorough analysis of the onshore infrastructure that supports offshore Outer Continental Shelf activities. This included discussions of many facets within the oil and gas industry including platform fabrication facilities, shipbuilding and repair facilities, ports, heliports, natural gas processing plants, refineries, petrochemical plants, pipe coating services, storage facilities, and transmission networks.

In Re: Research on Hovercraft Applications in the Oil and Gas Industry; Completed 2003.  ACG assisted marine services company in market research associated with oil and gas activities in the Louisiana coastal zone. ACG conducted market research to determine the scope of the potential market for hovercraft activities in exploration and production (“E&P”) and plug and abandon (“P&A”) activities in the Louisiana coast zone. ACG constructed a prototype GIS-enabled market research tool for this investigation.

In Re: CIG Field Services (El Paso Corporation) v. Kansas Board of Tax Appeals; CLMS # L98-900196; Completed 2003.  ACG prepared an expert report and testimony filed before the Kansas Board of Tax Appeals regarding CIG’s property valuation. ACG performed an analysis of the competitive nature of the natural gas gathering in Kansas. The analysis concentrated on natural gas producing wells capable of sustaining economic production under reasonable economic conditions. ACG also analyzed data for gathering systems contained within single counties as well as those that cross county lines and developed a number of structural statistics to measure market concentration and market access.

In Re: Commission Audit of Purchased Gas Adjustment Filings of Louisiana Gas Service Company Pursuant to Commission General Order Dated March 24, 1999 (Paragraph VI(A)); Docket No. U-25117; Completed 2002.  ACG assisted the Staff of the Louisiana Public Service Commission with an evaluation of the costs recovered through the fuel adjustment clause of Louisiana Gas Service Company. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliate suppliers of gas, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations.

In Re: Alaska Natural Gas In-State Demand Study, ASP 2001-1000-2650; Completed 2002.  ACG assisted the Alaska Department of Natural Resources by conducting a supply and demand study on the behalf of the. The purpose of the study was to investigate natural gas usage opportunities in the state in order to access the possibilities of serving Alaska communities and business with new natural gas production from the Alaska North Slope. The project included a number of general economic analyses, the development of numerous statistical forecasting models, and a geographic information system (GIS) analysis that mapped existing communities to existing in-state natural gas infrastructure systems and identified those communities that currently have no access to natural gas service and their potential annual natural gas usage. This project also examined the possibilities of delivering natural gas to the interior section of Alaska including the North Slope Borough. Usage opportunities included new residential service to interior communities, commercial usage opportunities, power plant fuel substitution opportunities, and “gas-by-wire” applications. Research also examined a host of other opportunities for expanded natural gas usage including the proposed Netricity internet server farm proposal, new petrochemical opportunities, and expanded LNG opportunities in the south-central portion of the state. Estimated retail costs (tariff rates) for new service were generated and compared to existing fuel sources for space and water heating in interior communities.

In Re: ATCO Gas; Market Analysis; Completed 2001.  Members of ACG assisted ATCO Gas by conducting an analysis of the Alberta, Canada, natural gas storage market in order to render an opinion as to whether the Alberta storage market is competitive. Analysis included defining product market, geographic market, and calculated market concentration (HHI). ACG also performed an evaluation of factors that might act to mitigate any exercise of market power by one or more firms. This included size and liquidity of the market, excess capacity in the pipeline system, excess storage capacity, types of customers utilizing storage services, the control of strategic assets, and the likelihood and ease of entry into the storage market.

In Re: Duke Energy Gas Transmission; Analysis of Market Power; Completed 2001.  Members of ACG assisted Duke Energy Gas Transmission by performing four separate market power studies for the following storage facilities: Egan Hub, Louisiana; Moss Bluff, Texas; Copiah, Mississippi; and Tioga, Pennsylvania. The studies were performed after Duke Energy Gas Transmission acquired each of the facilities – potentially affecting the market power status of each facility. A market power study was performed for each facility, reflecting the updated corporate structure and submitted to FERC – in the form of a Prepared Statement – along with updated applications requesting to continue with the market-based rates.

In Re: An Investigation into the Allegation Filed by the Plaintiffs Against the Defendants in Case No. 532-085 in the 24th Judicial District Court; The Rhodes Company Inc. et al versus Citizens Utilities Company (Citizens), LGS Natural Gas Company (LGS Natural), LGS Intrastate Inc., (LGSI) and Louisiana Gas Service Company (LGS); Docket No.U-23812; Completed 2000.  ACG assisted the Staff of the Louisiana Public Service Commission with an evaluation of the costs recovered through the fuel adjustment clause of Louisiana Gas Service Company. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliate suppliers of gas. The proceeding was ultimately settled, with LGS agreeing to refund $25 million to ratepayers for excess costs included in the PGA.

 

Prior to 2000

In Re:  Washington Utilities and Transportation Commission vs. Cascade Natural Gas Corporation; Cause Number U-86-100; Completed 1987. Members of ACG assisted the Washington Utilities and Transportation Commission, Division of the Attorney General's Office, with preparation of discovery, preparation of direct testimony on class of service issues, and cost allocation issues.

In Re: Southern Union Gas Company's 1985 Rate Request; Completed 1986. On behalf of the Public Utility Regulation Board of El Paso, members of ACG assisted with an examination of revenue requirement issues including affiliate transaction and cost allocations concerning Southern Union Company's rate request. In addition, members of ACG prepared a class cost of service study.

In Re: Southern Union Gas Company's Rate Request; Completed 1985.  Members of ACG assisted the Public Utility Regulation Board of El Paso with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, affiliate transactions, cost allocations, revenue issues and class cost of service issues; and preparation of cross-examination questions.