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PREVIOUS ENGAGEMENTS 2017-11-06T23:06:56+00:00

Electric

In Re:  I/M/O Electronic Application of Kentucky Power Company for (1) A General Adjustment of its Rates for Electric Service; (2) An Order Approving its 2017 Environmental Compliance Plan; (3) An Order Approving its Tariffs and Riders; (4) An Order Approving Accounting Practices to Establish Regulatory Assets and Liabilities; and (5) An Order Granting All Other Required Approvals and Relief; Case No. 2017-00179; Ongoing.  ACG is assisting the Office of Rate Intervention for the Kentucky Attorney General in its analysis of the AEP-Kentucky Power Company rate case.  ACG will assist the Attorney general and evaluating the Company’s rate design proposals as well as the Company’s economic development surcharge proposal.  ACG will also provide an analysis on the impact of the Company’s rate design proposal on low-income customers.

 

In Re:  I/M/O the Joint Application of Great Plains Energy Incorporated, Kansas City Power & Light Company and Westar Energy, Inc. for approval of the Acquisition of Westar Energy, Inc. by Great Plains Energy Incorporated; Docket No. 18-KCPE-095-MER; Ongoing.  ACG is assisting the Kansas Electric Power Cooperative, Inc. (“KEPCo”) in the examination of proposed merger of Great Plains Energy and Westar Energy.  ACG will examine the Joint Applicants’ Application for financial analysis regarding the level of financial risk that may result for the transaction. ACG will prepare analyses that will examine a number of different contractual, regulatory and policy actions that can be taken to mitigate the risk of this transaction to KEPCo and its ratepayers. This analysis will include the development of regulatory mechanisms often referred to as “ring fencing” measures to mitigate future financial and regulatory risk.  Additionally, ACG will evaluate the necessity of competitive bidding conditions and the Combined Company’s integrated resource plan.

 

In Re: I/M/O The Formula Rate Plan Filings of Entergy Arkansas, Inc. Pursuant to APSC Docket No. 15-015-U; Docket No. 16-036-FR; Ongoing.  ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s formula rate plan and evaluation report.  ACG will work with counsel to ensure that the FRP filing is consistent with the FRP rules and statute.  ACG developed a historic and regional peer-group benchmarking analyses on the Company’s operation and maintenance (“O&M”) costs, administrative and general (“A&G”) costs, and proposed changes to plant in service focusing on larger production, transmission and distribution plant investment changes.

 

In Re:  I/M/O Petition of NSTAR Electric Company and Western Massachusetts Electric Company each d/b/a Eversource Energy for Approval of an Increase in Base Distribution Rates for Electric Service Pursuant to G.L. c. 164, § 94 and 220 C.M.R. § 5.00; D.P.U. 17-05; Ongoing.  ACG is assisting the Massachusetts Attorney General’s Office to provide expert testimony in the matter of NSTAR Electric Company/Western Massachusetts Electric Company d/b/a Eversource Energy rate case before the Massachusetts Department of Public Utilities.  ACG will evaluate the Company’s proposed Grid Wise Performance Plan and the associated Performance Based Ratemaking Mechanism (“PBRM”).

 

Before the Section 70, Article 13 Arbitration Panel; Northeast Nebraska Public Power District; City of South Sioux City, Nebraska; City of Wayne, Nebraska; City of Wakefield, Nebraska; City of Valentine, Nebraska; City of Beatrice, Nebraska; City of Scribner, Nebraska; Village of Walthill, Nebraska, (Plaintiff) v. Nebraska Public Power District (Defendant); Completed 2017.  ACG assisted the Plaintiff’s in this matter in evaluating if a discount provided was unfair, unreasonable, and discriminatory.

 

In Re:  I/M/O the Joint Application of Great Plains Energy Incorporated, Kansas City Power & Light Company and Westar Energy, Inc. for approval of the Acquisition of Westar Energy, Inc. by Great Plains Energy Incorporated; Docket No. 16-KCPE-593-ACQ; Completed 2017.  ACG assisted the Kansas Electric Power Cooperative, Inc. (“KEPCo”) in the examination of proposed merger of Great Plains Energy and Westar Energy.  ACG examined the Joint Applicants’ Application for financial analysis regarding the level of financial risk that may result for the transaction ACG will prepare analyses that will examine a number of different contractual, regulatory and policy actions that can be taken to mitigate the risk of this transaction to KEPCo and its ratepayers. This analysis will include the development of regulatory mechanisms often referred to as “ring fencing” measures to mitigate future financial and regulatory risk.

 

In Re: I/M/O The Application of Oklahoma Gas and Electric Company for Approval of a General Change in Rates, Charges, and Tariffs; Docket No.16-052; Ongoing.  ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating Oklahoma Gas and Electric Company’s rate case filing.  ACG will work with counsel in evaluating the Company’s proposed class cost of service study, rate design, and formula rate plan as well as other rider revisions.  ACG will developed an alternative class cost of service study and rate design.  ACG will also evaluate the Company’s proposed formula rate plan for consistency with legislation and other formula rate plans that have been approved by the Commission.  Additionally, ACG will evaluate the appropriateness of the proposed riders and revisions to existing riders.

 

In Re: I/M/O The Formula Rate Plan Filings of Entergy Arkansas, Inc. Pursuant to APSC Docket No. 15-015-U; Docket No. 16-036-FR; Completed 2016.  ACG assisted the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s formula rate plan.  ACG will work with counsel to ensure that the FRP filing is consistent with the Company’s other tracker mechanisms and that there are no double recoveries of costs or lost revenues, nor any other unanticipated conflicts with these other trackers. ACG developed a historic and regional peer-group benchmarking analyses on the Company’s operation and maintenance (“O&M”) costs, administrative and general (“A&G”) costs, and proposed changes to plant in service focusing on larger production, transmission and distribution plant investment changes.  ACG also developed general forecasts of the O&M, A&G, and investments under future FRPs and developed rate impact outlook.  ACG prepared a retail rate benchmark analysis that compared the Company’s existing rates, and projected FRP rates, against historic trends and a regional peer group average over a five year period. Additionally, ACG analyzed and evaluated all possible material issues impacting ratepayers with a particular emphasis on fixed income and lower income households.

In Re:  In the Matter of the Application of Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Formal Case No. 1139; Completed 2017.  ACG assisted the D.C. Office of the People’s Counsel in the examination of Pepco’s request for a rate increase.  ACG provided a general policy analysis as well as an examination of the Company’s jurisdictional and class cost of service studies, rate design, and the bill stabilization adjustment mechanism.

In Re:  Examination of Kemper IGCC; Docket No. 2017-AD-112; Ongoing.  ACG is assisting the Mississippi Public Utilities Staff (“MPUS”) in the analysis of the economic and rate impacts of the Kemper IGCC Project.  ACG will examine the overall net benefits of the Kemper project from the perspective of Mississippi Power’s ratepayers as well as the State of Mississippi.  This net benefits analysis will require the development and execution of two differing modeling activities: (1) a rate impact model and (2) an economic impact model.  ACG will also evaluate cost allocation and rate design issues as well as assist the estimation of a revenue requirement.  ACG will also conduct a financial analysis to examine how various cost recovery scenarios would impact Mississippi Power and its parents cash flow position and how those cash flow changes may impact various key financial statistics commonly examined for debt rating purposes such as free cash flow from operations as share of debt, cash flow from operations as share of debt, capital structure, and other metrics commonly replied upon by Moody’s, S&P and Fitch.

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of a Second Extension of the Solar Generation Investment Program and Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO16050412; Ongoing.  On behalf of the New Jersey Division of Rate Counsel, ACG is reviewing the Public Service Electric & Gas Company’s proposed Solar 4 All Extension Program.  The extension of PSE&G’s existing “Solar 4 All” would expand the development of solar installations to develop an additional 100 MW of solar photovoltaic systems within the Company’s electric service territory.  Under this program, PSE&G proposed to finance, own, and operate solar systems that will be installed in target landfills and brownfields which have been identified in the 2011 Energy Master Plan (“EMP”) and the Solar Act legislation.  PSE&G would recover all program costs through the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).  ACG will examine the policy and economic implications of the program.

 

In Re:  Petition for Rate Increase by Florida Power & Light Company; Docket No. 160021-EI; Completed 2016.  ACG is assisting the Florida Office of Public Counsel in examining the Company’s petition for a rate increase.  ACG is evaluating the forecasting methodologies used the Company proposed multi-year rate plan.  ACG’s analysis will examine the Company’s customer and load growth forecasts as well as the energy sales and revenue forecasts.

 

In Re: Review of Policies Related to Customer-owned Solar Generation and Possible Modification of the Commission’s Current Net Metering Rules; Docket No. R-33929; Ongoing.  ACG is assisting the Louisiana Public Service Commission in examining the solar energy polices and rulemaking to make a number of housekeeping changes to the rules relating to reimbursement rates and utility installation caps. Additionally, ACG will provide a policy analysis regarding the solar energy policies.  ACG will provide an expert report on the findings of the solar energy policies analysis.

 

In Re: Federal Energy Regulatory Commission Confederated Salish and Kootenai Tribes, Energy Keeper, Incoporated, Project No. 5-103, Completed 2016.

ACG assisted the Duncan Weinberg law firm in developing a wholesale cost of service analysis, from a hydroelectric generation facility, for a group of irrigation customers, before the Federal Energy Regulatory Commission (“FERC”).  ACG conducted a net benefits evaluation in the determination of the cost of producing power at the project.  ACG also examined the reasonableness of the rental payments of the project.

In Re:  I/M/O the Merger of the Southern Company and AGL Resources, Inc.; Docket No. GM15101196; Completed 2016. ACG assisted the New Jersey Division of Rate Counsel in examining the Joint Petition for approval of the merger of the Southern Company and AGL Resources. This included the evaluation of the Joint Petitioners’ proposed commitments in relationship to the Board merger standards and policies, synergy savings, merger benefits, and future reporting and monitoring if the merger is approved.  ACG also analyzed the impact that the proposed merger will have on reliability and service quality, the local community, rates and charges, Corporate Governance, and regulatory oversight.

 

In Re: I/M/O The Empire District Electric Company Request for Authority to Implement a General Rate Increase for Electric Service; Case No. ER-2016-0023; Completed 2016. ACG is assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. Empire District Electric Company is requesting an increase of approximately $33.4 million, or an increase of 7.28%. The Company is requesting the additional revenue to recover investment costs, property taxes, and long termoperation and maintenance costs.  The Company is proposing a 15.5 percent increase to the residential customer charge. ACG examined the Company’s cost of service issues and proposed revenue distribution and rate design.  (no work actually performed)

 

In Re: I/M/O The Application of Entergy Arkansas, Inc. for Approval of Changes in Rates for Retail Electric Service; Docket No. 15-015-U; Completed 2016.  ACG assisted the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s request for a rate increase in matters pertaining to the economic development rider and the Company’s cost of service study.  ACG provided expert testimony and research.

 

In Re: I/M/O Union Electric Company d/b/a Ameren Missouri’s tariff to Increase Its Revenues for Electric Service; Case No. ER-2014-0258; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. The Company’s filing requested an increase of approximately $264 million, and listed several factors including continued investment in delivery systems, escalating net energy costs, and revenue requirement increases.  ACG provided research, cost of service, revenue distribution and rate design expertise and support to the Office of Public Counsel to assist with the analysis of the Company’s rate increase request.

 

In Re: I/M/O The Empire District Electric Company for Authority to File Tariffs Increasing Rates for Electric Service Provided to Customers In the Company’s Missouri Service Area; Case No. ER-2014-0351; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. Empire District Electric Company requested an increase of approximately $24.3 million, or an increase of 5.54%. The Company requested the additional revenue to recover investment costs, RTO transmission fees, property taxes, and long term maintenance costs.  The Company was proposing a 50 percent increase to the residential customer charge. ACG provided expert testimony and analysis which included an alternative cost of service model, a two-step revenue allocation, and proposed a rate design, which did not increase the customer charges.  ACG’s customer charge recommendation was consistent with the results of the alternative CCOSS and limited the impact of the rate increase to the residential and small commercial customers.  ACG also assisted OPC with settlement negotiations with the Company and other intervenors in the case.

 

In Re: I/M/O Kansas City Power & Light Company’s Request for Authority to Implement a General Rate Increase for Electric Service; Case No. ER-2014-0370; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. The Company is requested an increase of 15.75% or $120.9 million.  The Company requested the additional revenue to recover costs associated with operation, maintenance, fuel and purchase power, transmission fees, property taxes and additional investments in plant and expenses.  The Company was proposing a 178% increase to residential customer charges.  ACG provided expert testimony and analysis which included an alternative cost of service model, a two-step revenue allocation, and proposed a rate design, which did not increase the customer charges.  ACG’s customer charge recommendations limited the impact of the rate increase to the residential and small commercial customers and balanced the relationship between customer charges and customer related costs.  ACG also provided testimony on the behalf of OPC regarding the Company’s proposed electrical vehicle charging station pilot program which would install 1,000 charging stations.  ACG recommended the Commission reject the charge station program due to the lack of information regarding capital investments and expenses relating to the program and the Company’s failure to provide detail illustrating that the program was in the public’s interest.

 

In Re: PSE&G Economic Analysis of Capital Expenditure Program (Rutgers Study); RC File No.: 15-G-93; Completed 2015. ACG assisted the New Jersey Division of Rate Counsel in examining the Rutgers’ Economic Impact Analysis based on capital expenditures made by the Public Service Electric and Gas Company (“PSE&G”). The examination of the impact analysis will focus on the reasonableness of the assumptions, along with the positive and negative economic impacts discussed within the study.

 

In Re: The United States Environmental Protection Agency’s Proposed Rule on Carbon Dioxide Emissions from Existing Fossil-Fuel Fired Electric Generating Units under Section 111(d) of the Clean Air Act. Docket No. R-33253; Ongoing. ACG is assisting the Louisiana Public Service Commission in researching and preparing comments regarding the reasonableness and impacts of the Environmental Protection Agency’s potential policy. ACG is also creating analytical models to determine company specific impacts, costs, and economic development changes as well as assisting the LPSC in developing a State Implementation Plan.

In Re: Methodology for Calculating Avoided Costs of Complying with the Global Warming Solutions Act. DPU 14-86; Completed 2015. ACG assisted the Massachusetts Attorney General’s Office in reviewing the Marginal Abatement Cost Curve, which is used to assess the cost-effectiveness of energy efficiency programs. ACG has been tasked with analyzing this model, with particular attention paid to the avoided costs of complying with the Global Warming Solutions Act.

 

In Re: I/M/O Examination of the Comprehensive Costs and Benefits of Net Metering in Louisiana; Docket No. X-33192; Completed 2015. ACG assisted the Louisiana Public Service Commission with a comprehensive cost-benefit analysis of net metering in Louisiana in order to develop appropriate policies for the state.  ACG also investigated the ratepayer impacts at varying levels of participation in the net metering program. ACG provided an expert report to the Commission which included three empirical models to estimate the impact of the Commission’s net metering policies on ratepayers of Louisiana regulated utilities.  ACG conducted a cost-benefit analysis that examined a wide range of current and projected costs and benefits associated with solar NEM installations.  Additionally, a cost-of-service analysis was performed that estimated the ratemaking implications of the Commission’s solar NEM policies.  ACG also conducted an income distribution analysis that examined the distribution of solar NEM benefits across various income distribution categories.

In Re:  In the Matter of Docket No. 8191, Petition of Green Mountain Power Corp. for Approval of an Alternative Regulation Plan; Docket No. 8190, Investigation into Green Mountain Power Corp. Tariff Filing Requesting a Rate Decrease; Completed 2014.  ACG assisted AARP of Vermont in analyzing the Company’s alternative regulation plan.  ACG is assessed the benefits and detriments of the plan and whether it is in compliance with state regulations. After analysis, ACG determined the initially proposed plan was unnecessarily complex and shifted risk from Green Mountain Power to the ratepayer. ACG presented the AARP’s recommended modifications to the plan, creating a more transparent and risk equitable alternative regulation plan.

 

In Re:  In the Matter of Delmarva Power & Light Company’s Application For Approval of a Forward Looking Rate Plan; Docket No. 13-384; Completed 2014.  ACG assisted Delaware’s Division of the Public Advocate with an analysis of the Company’s request to increase electric revenue by $56.3 million over four years.  ACG evaluated the benefits and/or detriments of this type of rate plan for residential and small commercial consumers, and whether the plan is consistent with rate design principles.  ACG also examined the Company’s Regulatory Planning Model, which is used to forecast the Company’s distribution rate base and earnings. (Case Settled – No work actually completed)

In Re:  New Jersey Renewable Energy; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in its ongoing oversight of the state’s continued efforts to promote renewable energy within the state.  ACG has provided assistance in the analysis of the 2012 “Solar Act”, which provided for aggregate net metering and increased incentives for solar energy on landfills, among others provisions.  ACG has also provided an analysis of the New Jersey Solar Renewable Energy Credit (“SREC”) market and solar development trends to determine the size and scope of volatility in the market.

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; Completed 2015. ACG assisted the Office of the People’s Counsel for the District of Columbia in analyzing the policy aspects of the proposed merger of Exelon and Pepco, including the potential impacts on service quality, cost of service, and rates.  ACG provided expert testimony on various economic, public policy, and regulatory policy issues associated with the merger.  ACG provided an economic impact analysis, as well as review and analysis of the impact of the merger on employment, utility management and operation, system reliability, regulatory oversight, and potential impacts on the competitive market.

 

In Re:  Central Maine Power Company’s Rate Design Case (Phase II) in Connection with Their ARP 2014 Proceeding; Docket No. 2013-00168; Completed 2014.  ACG assisted Maine’s Office of Public Advocate in examining Central Maine Power’s Rate Design filing.  In addition to analyzing the Company’s rate design and revenue distribution, ACG also provided a critique of the Company’s Class Cost of Service and Marginal Cost of Service Studies. ACG evaluated the impact of the Company’s proposed standby service rates on residential and net metered customers.  ACG’s analysis found several weaknesses in the proposed Marginal Cost of Service Study including failure to utilize an appropriate methodology, and the use of flawed historic and forecast data to develop cost estimates. In response to these weaknesses, ACG recommended a two-step methodology for developing rates, along with the rejection of the Company’s standby rates, as the rates were inconsistent with Maine’s energy efficiency and renewable generation policies.

In Re:  The Petition of Fitchburg Gas and Electric Company (Electric Division) d/b/a Unitil for Approval of an Increase in Base Distribution Rates for Electric Service; D.P.U. 13-90; Completed 2014.  ACG assisted the Massachusetts Attorney General with an examination of the capital cost adjustment mechanism (“CCAM”) and the performance-based regulation (“PBR”) proposals filed by the Company.  ACG also critiqued the Company’s productivity-cost inflation analysis. ACG recommended rejection of the PBR based on several factors including lack of future ratepayer benefits, a flawed productivity-cost inflation analysis, and an alternative analysis suggesting the electric distribution productivity was higher than the Company’s analysis suggested.

In Re:  In the Matter of Delmarva Power & Light Company’s Application For an Increase in Electric Base Rates; Docket No. 13-115; Completed 2014.  ACG assisted Delaware’s Division of the Public Advocate with an analysis of the Company’s class cost of service study (CCOSS) and rate design. ACG also assessed the Company’s reliability and evaluated its compliance with Commission standards.  ACG recommended rejection of pro forma Adjustment 26 finding that it lacked a defined review for appropriateness and reasonableness.  For the CCOSS, ACG recommended the modifications of using a Total Distribution Plant allocator to allocate general and common plant accounts.  ACG’s rate design recommendations included a two-step methodology, whereby, the first step would limit the rate increase to any under-earning class, and the second step would distribute any remaining revenue deficiency across all other classes in proportion to their test year revenue.

In Re:  In the Matter of the Application of Baltimore Gas & Electric Company for Adjustments to Its Electric and Gas Base Rates; Case No. 9326; Completed 2013. ACG assisted the Maryland Office of People’s Counsel with an examination of the Company’s filing and provided expert opinions on the Electric Reliability Investment initiative (ERI), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s ERI finding it to be inconsistent with the Governor’s Reliability and Resiliency Task Force report.  For the Electric CCOSS, ACG recommended the modification of using an A&E allocation method using a 4CP measure of demand which recognizes the dual-use nature of sub-transmission assets, and the modification of using a total distribution plant allocation of general plant costs.  For the Gas CCOSS, ACG recommended the modification of allocating main-related distribution plant on the basis of demand and commodity, and the use of a total distribution plant allocator for general and common plant accounts.  ACG’s rate design recommendations included a two-step methodology, whereby, the under-earning classes would receive 1.25 times the system average increase and then the remaining increase would be allocated to the remaining classes in relation to their current revenues.  The distribution rates would be increased with allocations to the volumetric and demand components on an equal percentage basis.                  

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Formal Case No. 1103; Completed 2013.  ACG served as the main policy witness for the D.C. Office of the People’s Counsel.  ACG provided an overview of the OPC’s position as well as an expert opinion on the regulatory policy issues associated with the Company’s proposed Rate Making Adjustment 34. ACG recommended rejection of Rate Making Adjustment 34 due to the proposed investments not being known and measureable and the omission of any prudence review.

 

In Re:  In the Matter of the Application of Delmarva Power & Light Company for Adjustments to Its Retail Rates for the Distribution of Electric Energy; Case No. 9317; Completed 2013.  ACG assisted the Maryland Office of People’s Counsel with an examination of the Company’s filing and provided expert opinions on the Grid Resiliency Charge (GRC), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s GRC in its entirety and identified numerous deficiencies.  For the CCOSS, ACG recommended allocator modifications to the accounts of General and Common Plant, Customer Service and Information Expense, and Sales Expense. ACG’s rate design recommendations included a two-step methodology, whereby, the under-earning classes would receive 1.05 times the system average increase and then the remaining increase would be allocated to the remaining classes in relation to their current revenues.  The distribution rates would be increased with allocations to the volumetric and demand components on an equal percentage basis.

 

In Re: I/M/O the Verified Petition of Rockland Electric Company for Approval to Implement an Extended SREC-Based Financing Program Pursuant to N.J.S.A. 48:3-98.1 (SREC II Program); BPU Docket EO12090799; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining the Company’s request to extend its current Solar Renewable Energy Certificate (SREC) financing program into the “SREC II Program.”   SREC II Purchase and Sale Agreements of approximately 4.5 MW of installed solar capacity were estimated over a three-year period in their service territory.

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for an Increase in Its Retail Rates for the Distribution of Electric Energy; Case No. 9311; Completed 2013.  The Company requested a $60.8 million increase in base distribution revenue.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on the issues of the Grid Resiliency Charge (GRC), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s GRC proposal since it was premature, was inconsistent with the recommendations included in the Governor’s Resiliency Task Force Report, included a number of inherent mechanism design flaws, and was inconsistent with prior Commission precedent on infrastructure trackers.  ACG recommended alternative CCOSS allocation factors that included the use of an Average and Excess demand allocator based on a 4 Coincident Peak measure for allocating sub-transmission Plant and Associated Expenses; the use of the Sum of Customer Max and Non-Coincident Annual Class Peak Demands, with 50 percent weight given to each factor, to allocate secondary voltage distribution plant accounts and related O&M expenses; and the allocation of PSC Assessments based on gross Maryland retail sales revenue.  ACG also recommended that the Company update its supporting cost studies for meters and customer accounts and sales expense, as well as the installation on customer premise cost study and its outdoor lighting cost allocation study.  For rate design, ACG recommended that revenue responsibilities for developing rates should be allocated using a two-step methodology. In the first step, the under-earning classes receive 1.05 times the system average increase. In the second step, the remaining increase is allocated to all classes in relation to their current revenues.

 

In Re:  I/M/O the Petition of Atlantic City Electric Company Concerning a Proposal for an Extended Solar Renewable Energy Certificate (SREC) Based Financing Program; BPU Docket No. EO12090799; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining the Atlantic City Electric Company’s request for approval of its proposed 23 MW long term Solar Renewable Energy Certificate (SREC) financing program.

 

In Re:  I/M/O the Petition of Fishermen’s Atlantic City Wind Farm, LLC for the Approval of the State Waters Project and Authorizing Offshore Wind Renewable Energy Certificates; BPU Docket No. EO11050314V; Completed 2013.  ACG was retained by the New Jersey Division of Rate Counsel to provide an expert opinion to the Board of Public Utilities on the revised offshore wind development application submitted by Fishermen’s Atlantic City Wind Farm (FACW).  ACG recommended rejection of the FACW project because it did not meet statutory requirements and it was not in the public interest since it would not produce a net economic benefit to New Jersey ratepayers.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of Extension of a Solar Generation Investment Program and Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO12080721; Completed 2013.  On behalf of the New Jersey Division of Rate Counsel, ACG reviewed Public Service Electric & Gas Company’s proposed Solar 4 All Extension Program.  The extension of PSE&G’s existing “Solar 4 All” would expand the development of solar installations to develop an additional 136 MW of solar photovoltaic systems within the Company’s electric service territory.  Under this program, PSE&G proposed to finance, own, and operate solar systems that would be installed on landfills, brownfields, warehouse roofs and parking lots.  PSE&G would recover all program costs through a new component of the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of a Solar Loan III Program and an Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO12080726; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining Public Service Electric & Gas Company’s proposal for a third solar loan program as a continuation of its Solar Loan I and Solar Loan II programs.  PSE&G would continue its solar photovoltaic development program across all customer classes within its electric service territory.  PSE&G would provide financing for the installation of these systems on the customers’ premises, which is repaid using solar renewable energy certificates (“SRECs”) or cash. PSE&G would recover all program costs through a new component of the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).

 

I/M/O the Petition of Jersey Central Power & Light Company Concerning a Proposal for an SREC-Based Financing Program; BPU Docket No. EO12080750; Completed 2013. ACG assisted the New Jersey Division of Rate Counsel in examining the filing by Jersey Central Power & Light requesting approval of its proposed 52 MW long term Solar Renewable Energy Certificate (SREC) financing program.  The “SREC II Program” is a continuation of the Company’s “SREC I Program,” whereby, JCP&L would support SREC-based financing of solar generation projects by entering into Board-approved long-term agreements for the purchase of SRECs from solar project owners or developers at prices set through bi-annual solicitations.

 

In Re:  I/M/O the Petition of Public Service Electric & Gas Company for Approval of Changes in its Electric RGGI Recovery Charges and its Gas RGGI Recovery Charges and for Changes in the Tariff for Electric Service; BPU Docket No.: GR12070605 & ER12070606; Completed 2013. On behalf of the New Jersey Division of Rate Counsel, ACG reviewed the Company’s proposed changes to its cost recovery of six energy efficiency, demand response, and solar energy programs.

 

In Re:  Rule Making to Consider the Impact of Alternative Fuel Vehicles on Electric and Gas Utility Operations; LPSC File No. 334; Completed 2013.  ACG assisted the Louisiana Public Service Commission in the development of potential rules for alternative fuel vehicles for Louisiana’s electric and natural gas utilities.  Tasks included reviewing best practices rules and regulations, developing stakeholder questions, coordinating a technical hearing, and synthesizing the information from the technical hearing.

 

In Re:  Avista Utilities 2011 & 2012 General Rate Cases; Consolidated Docket Nos. UE-110876 & 120436; 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:  Application of El Paso Electric Company to Change Rates and to Reconcile Fuel Costs; Docket No. 40094; Completed 2012.  El Paso Electric Company requested a base rate increase of $26.255 million.  ACG was retained by the City of El Paso to analyze the Company’s Jurisdictional Allocation Study, Class Cost of Service Study, and rate design proposal.  The case was settled before testimony was submitted.

 

In Re:  In the Matter of the Application of Delmarva Power & Light Company for Authority to Increase Its Rates For Electric Distribution Service; Case No. 9285; Completed 2012.  Delmarva Power & Light Company requested a $25.2 million increase in its Maryland distribution rates.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on Delmarva’s proposed Reliability Investment Recovery Mechanism (“RIM”), class cost of service study (“CCOSS”), and rate design.  ACG recommended rejection of the Company’s RIM due to numerous deficiencies.  ACG found the RIM to be poorly-constructed, ambiguous, and unproven as a regulatory mechanism. It also placed an undue amount of risk on ratepayers without proving commensurate benefits.  Concerning the CCOSS, ACG presented alternative allocation factors for several accounts including General Plant, Common Plant, Customer Service and Information Expenses, and Sales Expenses.  ACG’s rate design recommendations included increasing customer charges for those classes where their current revenues were less than their customer-related costs to a level that moved towards their full cost of service.  Distribution rates would also be moved towards their full cost of service.  ACG’s revenue distribution recommendations included constraints that 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 Potomac Electric Power Company For Authority to Increase Its Rates and Charges For Electric Distribution Service; Case No. 9286; Completed 2012.  Potomac Electric Power Company requested a $68.4 million increase in its Maryland distribution rates.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on Delmarva’s proposed Reliability Investment Recovery Mechanism (RIM), class cost of service study (CCOSS), and rate design. ACG recommended rejection of the Company’s RIM due to numerous deficiencies.  ACG found the RIM to be poorly-constructed, ambiguous, and unproven as a regulatory mechanism. It also placed an undue amount of risk on ratepayers without proving commensurate benefits.   ACG presented an alternative CCOSS which altered several allocation factors including the use of the Sum of Customer Max Demands and Non-Coincident Annual Class Peak Demands for secondary voltage distribution plant accounts and related operations and maintenance expenses, and allocating PSC Assessments based on gross Maryland retail sales.  ACG’s rate design recommendations included increasing customer charges for those classes where their current revenues were less than their customer-related costs to a level that moved towards their full cost of service.  Distribution rates would also be moved towards their full cost of service.  ACG’s revenue distribution recommendations included constraints that 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 Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Case No. FC1087; Completed 2012.  ACG assisted the District of Columbia’s Office of the People’s Counsel with an analysis of Potomac’s proposed infrastructure mechanism and claims of regulatory lag.  ACG recommended that the Commission reject the Company’s Reliability Investment Recovery Mechanism, finding it to be unnecessary, suffering from technical deficiencies, and inviting inefficiencies and higher rates.

 

In Re: Petition for an Increase in Rates by Gulf Power Company; Docket No. 110138-EI; Completed 2011.  ACG assisted the Florida Office of the Public Counsel with the analysis of the rate application filed by Gulf Power Company with a specific focus on the company’s affiliate transactions.  ACG examined the operations of GPC and its affiliates to ensure that any unregulated operations and affiliates were appropriately treated and that costs were correctly allocated or charged to them so that the Company’s regulated operations were not being subsidized by the nonregulated operations.

In Re:  Request of Fitchburg Gas and Electric Light Company d/b/a/ Unitil (Electric Division) for an Increase in Base Distribution Rates and a Revenue Decoupling Mechanism; D.P.U. 11-01; 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: Petition of Western Massachusetts Electric Company for Approval of a General Increase in Electric Distribution Rates and a Revenue Decoupling Mechanism; Docket No. D.P.U. 10-70; Completed 2011.  ACG assisted the Massachusetts Attorney General with an examination of the application submitted by Western Massachusetts Electric Company to increase its electricity distribution rates. ACG provided analyses and testimony related to the Company’s proposed Inflation Adjustment Clause, Revenue Decoupling Mechanism, Rate Design Policy, Capital Reliability Reconciliation Clause, and other related matters.

In Re: Southern Indiana Gas and Electric Company d/b/a Vectren Energy Delivery of Indiana, Inc., Electric Rate Case; Completed 2010.  ACG assisted the Indiana Office of Utility Consumer Counselor (“OUCC”) with the examination of the application submitted by Vectren South Electric to increase its electric distribution rates. ACG provided testimony on the Company’s revenue decoupling proposal; its proposed Reliability Cost and Revenue Adjustment tracker, including its Variable Production Cost recovery component; and components of its proposed Midwestern Independent System Operator (“MISO”) Cost and Revenue Adjustment (“MCRA”) tracker.

In Re: Application of El Paso Electric Company to Change Rates, to Reconcile Fuel Costs, to Establish of Texas Formula-Based Fuel Factors, and to Establish an Energy Efficiency Cost Recovery Factor; Docket No. 37690; Completed 2010.  ACG assisted the City of El Paso with the examination of the application submitted by El Paso Electric Company to increase its rates for electric service.  ACG conducted analyses related to the Company’s proposed energy efficiency programs, including examination of energy and demand savings, cost-benefit analyses, spending budgets, and ability to meet energy and demand saving goals and objectives.  ACG also examined the Company’s jurisdictional allocations which included an analysis of the appropriate production and transmission allocation factors, treatment of off-system sales, and direct assignments.  ACG prepared an alternative class cost of service study which included examining the appropriate demand, energy, and customer factors; treatment of interruptible customers; examination of MCD and NCP methodologies; and the allocation of expenses and rate base accounts.  Finally, ACG developed alternative revenue distributions and rate design recommendations for residential, small commercial, general service, industrial, and governmental customers.  Our rate design analyses included examinations of load factors, seasonal differentials, time-of-use rates, customer charges, and inverted block rates.

In Re: Review of Replacement Fuel Costs Associated with the February 26, 2008 Outage on Florida Power & Light’s Electrical System; Completed 2010.  ACG assisted the Florida Office of the Public Counsel in evaluating the net replacement power cost (“net RPC”) estimate proposed by Florida Power & Light Company (“FPL”).  The Company offered this estimate in order to credit rate payers for the loss of load event in Florida on February 26, 2008.  ACG provided testimony on the merits of FPL’s proposal and provided a series of alternative net RPC credit calculations including an alternative RPC recommendation.

In Re: Research Support on Louisiana Renewable Energy Development Project, Miscellaneous Energy Efficiency and Conservation Issues; Completed 2009. ACG assisted the City of Ruston, Louisiana, in evaluating the opportunities of a co-firing application at the municipal generation facility owned by the City.

In Re: Petition of Massachusetts Electric Company and Nantucket Electric Company for a General Increase in Electric Rates and Approval of a Revenue Decoupling Mechanism; Completed 2009.  ACG assisted the Massachusetts Attorney General with the examination of the application submitted by Massachusetts Electric Company and Nantucket Electric Company to increase its electric rates for electric service rendered in Massachusetts. ACG prepared discovery and provided testimony on the Company’s revenue decoupling proposal, net inflation factor proposal, capital recovery mechanism, and several issues related to the Company’s proposed inclining block rate design.

In Re: Petition for increase in rates by Florida Power & Light Company; Docket Nos. 080677-EI and 090190-EI; Completed 2009.  ACG assisted the Florida Office of the Public Counsel in analyzing Florida Power & Light Company’s application for a rate increase. ACG prepared discovery, analyzed Company Minimum Filing Requirements, and filed direct testimony on accounting issues and affiliate transactions issues. Issues examined included the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

In Re: Petition for increase in rates by Progress Energy Florida, Inc.; Docket No. 090079-EI; Completed 2009.  ACG assisted the Florida Office of the Public Counsel with analyzing Progress Energy Florida’s application for a rate increase.  ACG prepared discovery, analyzed Company Minimum Filing Requirements, and prepared direct testimony on accounting issues and affiliate transactions issues. Issues examined included the ratemaking treatment of affiliate transactions, cost allocations between regulated and unregulated affiliates, and the treatment of revenue recorded below-the-line for ratemaking purposes.

In Re: New Jersey, Provision of Basic Generation Service (“BGS”); Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, by providing an expert opinion to the New Jersey Board of Public Utilities on cost recovery proposals by electric distribution companies (“EDCs”) for increased solar energy costs.

In Re: In the Matter of the Renewable Portfolio Standard – Amendments to the Minimum filing Requirements for Energy Efficiency, Renewable Energy, and Conservation Programs and For Electric Distribution Company Submittals of Filings in connection with Solar Financing; BPU Docket No. EO06100744 and EO08100875; Completed 2009. ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the Board of Public Utilities on the policy and program design issues associated with the SREC-based financing proposal offered by Atlantic City Electric Company. This proposal was filed by the Company pursuant to a BPU Board Order supported by the Regional Greenhouse Gas Initiative legislation, N.J.S.A. 48:3-98.1, which authorizes electric and gas public utility companies in New Jersey to provide energy efficiency, conservation, and Class I renewable energy programs on a regulated basis.

In Re: In the Matter of the Verified Petition of Jersey Central Power & Light Concerning a Proposal for an SREC-Based Financing Program under N.J.S.A. 48:3-98.1; BPU Docket No. EO08090840; Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the Board of Public Utilities on the policy and program design issues associated with the SREC-based financing proposal offered by Jersey Central Power & Light Company. This proposal was filed by the Company pursuant to a BPU Board Order supported by the Regional Greenhouse Gas Initiative legislation, N.J.S.A. 48:3-98.1, which authorizes electric and gas public utility companies in New Jersey to provide energy efficiency, conservation, and Class I renewable energy programs on a regulated basis.

In Re: New Jersey Energy Master Plan; Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the New Jersey Board of Public Utilities on the pending New Jersey Energy Master Plan (“EMP”). ACG has provided assistance in the analysis of clean energy programs (energy efficiency and renewable energy) and its implications for rate payers and an examination of market and rate impacts of various clean energy program implementation scenarios. ACG has also examined issues related to lost distribution revenues and revenue decoupling.

In Re: In the Matter of Atlantic City Electric Company’s “Blueprint for the Future,” Establishing an Advanced Metering Infrastructure Program, Demand-Side Management Initiatives, Utility-Provided Demand Response Programs and Other Programs, and Requesting BPU Approval of Cost Recovery Mechanisms Related Thereto; BPU Docket No. EO07110881; Completed 2008.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with the examination of the solar energy and revenue decoupling proposal by Atlantic City Electric Company. The Company sought authorization to establish a separate Advanced Metering Infrastructure rate adjustment mechanism, recover program costs for the proposed Direct Load Control through the existing System Control Charge, and implement utility-provided energy efficiency and conservation programs. The Company sought to recover costs related to the proposed low-income conservation programs, solar programs, large customer Internet-based platform, and other demand-side management initiatives through the existing Societal Benefits Charge. Also included in the proposal was a Bill Stabilization Adjustment mechanism or revenue decoupling mechanism.

In Re: Investigation and Potential Rulemaking into the Development of a Potential Incentive-Based Mechanism for Fuel Cost Recovery by Louisiana Jurisdictional Electric Utilities; Docket No. R-30426; Completed 2008.  ACG assisted the Louisiana Public Service Commission in an investigation on the potential for an incentive-based mechanism for fuel cost recovery by Louisiana jurisdictional electric utilities.

In Re: Investigation into the Ratemaking and Generation Planning Implications of Nuclear Construction in Louisiana; Docket No. R-29172; Completed 2008.  ACG assisted the Staff of the Louisiana Public Service Commission with preparation of the rule to provide an incentive approach to promote nuclear power plant development in Louisiana.

In Re: Recommendations for Alternative Compliance Payments and Solar Alternative Compliance Payments for Energy Year 2008, A Stakeholder Process Regarding Alternative Compliance Payment and Solar Alternative Compliance Payment Levels for Energy Year 2009 and 2010 or Longer, and a Solar REC-Only Pilot; BPU Docket Number EO06100744; Completed 2008.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, in its participation in a stakeholder proceeding to consider a wide range of proposed solar energy market designs and policies. The formal purpose of the proceeding was to examine the appropriate levels for solar alternative compliance payment prices in upcoming years. In addition the stakeholder process includes an examination of solar energy market structure and design, including whether or not a rebate-based approach should be maintained relative to other financial support options that might rely more heavily on tradable SRECs.

In Re: Investigation into the Fuel Adjustment Clause Practices of Entergy Gulf States and Its Affiliates; Docket No. U-27103; Completed 2012.  ACG assisted the Louisiana Public Service Commission with an investigation into the fuel procurement and cost recovery practices of Entergy Gulf States, Inc., for fuel adjustment clause (“FAC”) purposes. The analysis includes the appropriateness of costs included in the FAC including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations. ACG’s analyses examine issues associated with affiliate pipeline companies, excessive nuclear fuel costs, compliance with Commission orders, pricing of electricity among affiliated companies, off-system sales and purchased power, plant outages, transportation storage costs, and risk management practices.

In Re: The Feasibility, Costs, and Benefits of Co-Firing Agricultural Residue and Energy Crops at Louisiana Generation Facilities; Completed 2008.  ACG assisted Cleco Power, LLC, and Entergy Services, Inc., with an examination of the availability and relative economics of utilizing agricultural residues and energy crops in a co-firing application at the Rodemacher Power Station under development by Cleco Power, L.L.C., and the Little Gypsy Power Station re-powering proposal offered by Entergy Louisiana, L.L.C. ACG performed an extensive literature review on the costs and heating values of agricultural residues and energy crops as well as current co-firing applications. Availability and economic analyses were done for corn stover, cotton gin trash, rice straw, grain sorghum, soybean residue, wheat straw, switchgrass, sugar cane bagasse, and wood mill residue.

In Re: Application for Approval of Advanced Metering Pilot Program; LPSC Docket No. S-30336; Completed 2008.  ACG assisted the Staff of the Louisiana Public Service Commission in its examination of the potential public benefits of implementing an advanced metering system (“AMS”) and demand response (“DR”) program for the South Baton Rouge area as proposed by Entergy Gulf States, Inc.

In Re: In the Matter of the Petition of Public Service Electric & Gas Company for Approval of a Solar Energy Program and an Associated Cost Recovery Mechanism;BPU Docket No. EO07040278; Completed 2007. ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with the preparation of an expert opinion to the Board of Public Utilities on the policy issues associated with Public Service Electric & Gas Company’s solar energy proposal. PSE&G proposed to implement a solar photovoltaic development program across all customer classes within its electric service territory. PSE&G would provide financing for the installation of these systems on the customers’ premises and recover the costs of the program, including an incentive, through its electric Societal Benefits Charge.

In Re: An Investigation Into the Ratemaking and Generation Planning Implications of the U.S. EPA Clean Air Interstate Rule; Docket No. R-29380; Completed 2012.ACG assisted the Louisiana Public Service Commission with the development of a methodology and recommendation for allocating NOx allowances to qualifying electricity generating units in the State of Louisiana.  The Clean Air Interstate Rule (CAIR) provides a Federal framework requiring states to reduce emissions of sulfur dioxide (SO2) and nitrogen oxide (NOx).

In Re: Investigation to Determine if it is Appropriate for LPSC Jurisdictional Electric Utilities to Provide and Install Time-Based Meters and Communication Devices for Each of Their Customers Which Enable Such Customers to Participate in Time-Based Pricing Rate Schedules and Other Demand Response Programs; Docket No. R-29213; Completed 2007.  ACG assisted the Louisiana Public Service Commission with its examination of the opportunities for Demand Response Mechanisms for Louisiana as required under 1252(a) of the Energy Policy Act of 2005.  ACG prepared a request for comments as well as held a technical conference to survey interested parties’ opinions on demand response and advanced metering.

 

In Re: Petition for Rate Increase by Florida Power & Light Company; Docket No. 050045-EI; Completed 2005.  ACG assisted the Florida Office of the Public Counsel with examining the issues associated with the proposed load forecast by Florida Power & Light Company’s in its request for a rate increase.  ACG also presented information associated with the Company test year O&M expenditures to be considered in evaluating its request for a 50-basis point incentive to its allowed return on equity.  Other issues that ACG examined included affiliate transactions, cost allocation techniques, advertising expenditures, charitable contributions, and FPL’s purchase of turbines from affiliates at prices significantly higher than available in the market.

In Re: Impact of Renewable Portfolio Standard Increase; Completed 2005. ACG assisted the New Jersey Division of Ratepayer Advocate with an evaluation of a proposed increase in the state’s renewable portfolio standard to 20 percent of all resources.  The analysis included a review of the current status of renewable energy development in the US, characterization of renewable power generation technologies, as well as recent trends in renewable technologies and market penetration.  ACG focused on the cost effectiveness of various renewable technologies compared to conventional fossil fuel technologies, including an estimation of economic and rate impacts, a discounted cash flow analysis, and analysis of renewable energy credits trading.

In Re:  Generic Proceeding to Explore a Formal Request for Proposal for Utilities that are Considering Alternatives for Adding Generating Capacity; Docket No. 2005-191-E; Completed 2005. ACG assisted NewSouth Energy, LLC, a Calpine Corporation subsidiary with preparation of direct and rebuttal testimony on the advantages of competitive bidding and the development of rules requiring utilities to submit Requests for Proposals to the market prior to obtaining or self-developing generation resources.

In Re: Petition of Entergy Mississippi, Inc. for a Certificate of Public Convenience; Docket No. 05-UA-323; Completed 2005.  On behalf of Calpine Corporation, ACG provided direct testimony addressing the proposal by Entergy Mississippi, Inc., to seek approval from the Mississippi Public Service Commission for a Certificate of Public Convenience and Necessity to acquire and operate the Attala Energy Facility.

In Re: In the Matter of the Application of PacifiCorp for Approval of its Proposed Electric Service Schedules and Electric Service Regulations; Docket No. 04-035-42; Completed 2005.  ACG assisted the Utah Committee of Consumer Services with the preparation of discovery and prefiled direct and rebuttal testimony concerning affiliate transactions issues including: relationships with coal affiliates, relationships between regulated and nonregulated affiliates, cost allocation methods for allocating costs between affiliated companies. The analysis included examinations of common officers and directors of affiliated companies, employee time records and exception time reports, direct assignment versus cost allocation methodologies, the Massachusetts Formula for cost allocations, and cost allocation manuals, policies and documentation.

In Re: Lafayette City-Parish Consolidated Government et al v. Entergy Gulf States, Inc. and Entergy Corporation; Docket No. 00994490J; Completed 2005.  ACG assisted Lafayette Utility Service, the City of Lafayette, and the Lafayette City Parish Consolidated Government with preparation of an expert rebuttal report.  The report, filed with the 15th Judicial District Court of Lafayette Parish, Louisiana, critiqued a valuation study conducted on behalf of Entergy Gulf States, Inc., that examined the fair market value of property proposed for expropriation by the City of Lafayette and the Lafayette Utilities System.

In Re: South Carolina Electric & Gas, Application for Adjustments in the Company’s Electric Rate Schedules and Tariffs; Docket No. 2004-178-E; Completed 2004.ACG assisted Columbia Energy, LLC (subsidiary of Calpine Corporation) with preparation of testimony before the South Carolina Public Service Commission. Issues included evaluating the reasonableness of SCE&G’s proposal to enter the entirety of its Jasper Generating Facility into rates. ACG reviewed previous rate filings, company benefit analyses, off-system sales, reserve margins, and demand forecasts.

In Re: Florida Power & Light Company, Levelized Fuel Cost Recovery and Capacity Cost Recovery Proceeding; Docket No. 040001-EI; Completed 2004.  ACG assisted Power Systems Manufacturing, Thomas K. Churbuck, and the Florida Industrial Power Users Group with evaluating the reasonableness of FPL’s proposal to recover costs associated with three purchased power agreements with Southern Company Services, including the preparation of testimony.

In Re: Review of Florida Power Corporation’s Earnings, Including Effects of Proposed Acquisition of Florida Power Corporation By Carolina Power & Light; Docket Number 000824-EI; Completed 2002.  ACG assisted the Florida Office of the Public Counsel with preparation of discovery and analysis of Company Minimum Filing Requirements.  This included the preparation of direct testimony on accounting issues; merger and acquisition issues, including synergy savings and merger costs; and affiliate transactions issues. Other examined issues included the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

 

In Re: Review of the Retail Rates of Florida Power & Light Company; Docket No. 001148-EI; Completed 2002.  ACG assisted the Florida Office of the Public Counsel with Florida Power & Light Company’s application for a rate increase. ACG contributed to the preparation of discovery, analysis of Company Minimum Filing Requirements, and preparation of direct testimony on accounting issues and affiliate transactions issues.  Examined issues included those associated with the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

In Re: Gulf Power Company Request for a Rate Increase; Docket No. 010949-EI; Completed 2001. ACG assisted the Florida Office of the Public Counsel with the Gulf Power Company’s application for a rate increase.  ACG prepared discovery, analyzed Company Minimum Filing Requirements, prepared direct testimony on accounting issues, forecasting issues, and affiliate transaction issues.

In Re: Request Letter of Non-Opposition for Official Action of Approval to Transfer of Controlling Interest in their Common Stock as a Result of the Merger of Applicants’ Corporate Parent Company, Entergy Corporation with FPL Group; Docket No. U-25354; Completed 2001.  ACG assisted the Staff of the Louisiana Public Service Commission with an investigation into the proposed merger between Florida Power & Light Group and Entergy Corporation.  ACG examined regulatory issues associated with largest proposed merger in the US power industry including rate impacts, impacts on transmission system reliability and governance, customer service, economic impacts, employment impacts, market power and competitive market conditions, merchant power interconnection issues, affiliate relationships, and synergy savings.

In Re: Economic Impacts of Merchant Power Plant Development Mississippi; Completed 2001.  ACG assisted the Office of the Governor, State of Mississippi with preparation of an economic impact study to model the potential economic benefits associated with merchant power plant development in Mississippi. The analysis included development of power market impact model that estimated changes in regional wholesale price associated with merchant development. Transmission and rate issues were also examined.

In Re: Gulf Power Company; Smith Wetlands Mitigation Plan; Docket No. 000808-EI; Completed 2001.  ACG assisted the Office of the Public Counsel with preparation of discovery, analysis of Company testimony, and preparation of prefiled direct testimony on the Wetlands Mitigation Plan.

In Re: Generic Issues Associated with Applications for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344l; Docket No. 22344; Completed 2001. Members of ACG assisted the City of Amarillo, Texas, with an analysis of Southwestern Public Service Company’s proposed unbundling plan. This included an analysis of proposed generation capacity auction, impacts of capacity actions on purchased power factor, the relationship of fuel adjustment clauses on unbundled rates, market power, transmission pricing and governance issues, federal-state jurisdictional issues, and price forecasting.

In Re: Application of Southwestern Public Service for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344; Docket No. 22351; Completed 2001.  Members of ACG assisted the City of Amarillo, Texas, with an analysis of the unbundled cost of service plan proposed by Southwestern Public Service Company before the Public Utilities Commission of Texas.  The proposed unbundled cost of service study was required under Senate Bill 7 in Texas to facilitate retail choice.  Analysis included the review of revenue requirement reasonableness; affiliate relationships, class cost of service, jurisdictional allocations, revenue distribution, and forecast billing determinants.

In Re: New Energy Ventures, Distributed Generation Proceedings; CPUC Rulemaking 98-12-015; Completed 2000.  ACG examined unbundled distribution rate design proposals by California’s investor-owned distribution utilities and their implications for rate design issues associated with distributed energy on behalf of New Energy Ventures and Honeywell Power Systems. ACG also assisted with the preparation of expert witness testimony in Phase II Distributed Generation Proceedings.

In Re: In the Matter of the Application of the Kansas Power and Light Company and KCA Corporation for Approval of the Acquisition of All Classes of the Capital Stock of Kansas Gas and Electric Company, to Merge with Kansas Gas and Electric Company, to Issue Stock and Incur Debt Obligations; Case Number EM-91-213; Completed 1995.  Members of ACG assisted the Staff of the Missouri Public Service Commission with preparation of discovery; preparation of direct testimony on accounting issues, financial issues, financial cost modeling, and merger issues; and preparation of cross-examination questions.

 

In Re: Preliminary Analysis of Proposed Merger Between Washington Water Power Company and Sierra Pacific Power Company; Completed 1995.  Members of ACG assisted the Nevada Public Service Commission with preparation of an expert report on accounting issues, financial issues, and merger issues.

In Re: Investigation into Currently Authorized Return on Equity of Tampa Electric Company; Docket Number 930987-EI; Completed 1993.  Members of ACG assisted the Florida Office of the Public Counsel with its investigation into the authorized return on equity of Tampa Electric Company.  This included assistance with preparation of discovery, direct testimony on accounting and financial issues, issues and positions for Prehearing Statement, and cross-examination questions.

In Re: Application of El Paso Electric Company for Authority to Change Rates, Docket Numbers 5640, 6350, 7460, 8363, 9945; Completed 1992.  Members of ACG assisted the City of El Paso in response to El Paso Electric Company’s application for a rate increase in certain municipalities in the State of Texas. This included assistance with the preparation of discovery, analysis of Company Minimum Filing Requirements, and preparation of cross-examination questions. Also, members prepared direct testimony on accounting issues, prudence issues, class cost of service studies, and cost allocations.

In Re: Application for a Rate Increase Filed by El Paso Electric Company; Docket No. 9945; Completed 1991. Members of ACG assisted the City of El Paso with the preparation of class cost of service studies concerning El Paso Electric Company.  Analyses included an examination of allocation methodologies including demand versus energy factors, customer factors, administrative and general allocations; coincident peak methodology, non-coincident peak methodology; and asset and expense functionalization and categorization.

In Re: Application for a Rate Increase Filed by El Paso Electric Company; Docket No. 9165; Completed 1990.  Members of ACG assisted the City of El Paso with the preparation of discovery, cross-examination, and testimony on class cost of service studies, affiliate transactions, excess capacity, off-system sales, financial integrity and rate moderation.  Class cost of service testimony examined allocation methodologies including demand versus energy factors, customer factors, administrative and general allocations, and the allocation of taxes; coincident peak and non-coincident peak methodologies; and asset and expense functionalization and categorization.

In Re: Washington Utilities and Transportation Commission vs. Puget Sound Power and Light Company; Case No. U-89-2688-T; Completed 1990.  Members of ACG assisted the Washington Utilities and Transportation Commission with an examination of prudence issues associated with the WNP-3 nuclear power plant.

In Re: Inquiry of the Public Utility Commission of Texas into the Prudence and Efficiency of the Planning and Management of the Construction of the South Texas Nuclear Project; Docket No. 6668; Completed 1989.  Members of ACG prepared discovery, testimony, and cross-examination questions in connection with the Commission’s review of the prudence of the South Texas Nuclear Project.

In Re: The Application of the El Paso Electric Company for a Rate Increase in Certain Municipalities in the State of Texas; Docket Number 635; Completed 1987.  Members of ACG assisted the City of El Paso with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, cost allocations, revenue requirement, and class cost of service issues; and preparation of cross-examination questions.

In Re: Application of Texas Utilities Electric Company for a Rate Increase; Docket No. 5640; Completed 1984.  On behalf of Texas Cities, members of ACG examined the request by Texas Utilities Electric Company for a rate increase. ACG prepared discovery, testimony, and cross-examination questions in connection with financial and accounting matters.

 

In Re: Application of the Connecticut Light and Power Company for an Increase in Rates and Revenues; Docket No. 83-07-15; Completed 1983.  On behalf of Connecticut Office of Consumer Counsel, members of ACG examined the request by Connecticut Light and Power Company for a rate increase. Members of ACG prepared discovery, testimony, and cross-examination questions in connection with financial and accounting matters.

Gas

In Re:  I/M/O The Petition of Public Service Electric and Gas Company for Approval of the Next Phase of the Gas System Modernization Program and Associated Cost Recovery Mechanism (“GSMP II”); BPU Docket No. GR17070776; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the economic impacts, market policy, and engineering aspects of the gas system replacement plan.  ACG will conduct an analysis of the Company’s past replacement programs as well as an analysis of the costs and benefits of the proposed phase II of the program.

 

In Re:  I/M/O The Merger of AltaGas Ltd. and WGL Holdings, Inc.; Formal Case 1142; 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 of AltaGas and WGL, including the potential impacts on service quality, cost of service, and rates.  ACG will provide expert testimony on various economic, public policy, and regulatory policy issues associated with the merger.  ACG provided an economic impact analysis, as well as review and analysis of the impact of the merger on employment, utility management and operation, system reliability, regulatory oversight, and financial risks associated with the merger.

 

In Re:  I/M/O Laclede Gas Company’s Request to Increase Its Revenues for Gas Service; Docket No. GR-2017-0215; Completed 2017.  ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and the replacements made under its pipeline replacement program.

 

In Re:  I/M/O Laclede Gas Company d/b/a Missouri Gas Energy’s Request to Increase Its Revenues for Gas Service; Docket No. GR-2017-0216; Completed 2017.  ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and the replacements made under its pipeline replacement program.

 

In Re:  I/M/O The Application of Oklahoma Gas and Electric Company for Approval of a General Change in Rates, Charges and Tariffs; Docket No. 16-052-U; Ongoing. ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating OGE’s request for a rate increase in matters pertaining to the Company’s cost of service study, rate design, and proposed formula rate plan.  ACG will evaluate the Company’s cost of service model for appropriate cost causation principles and conduct an alternative cost of service analysis.  ACG will also develop an alternative rate design proposal.  ACG will provide expert testimony and research.

 

In Re:  I/M/O The Formula Rate Plan Filings Of Centerpoint Energy Resources Corp. D/B/A CenterPoint Energy Arkansas Gas Pursuant To APSC; Docket No. 15-098-U; Ongoing.

ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating CenterPoint Energy’s formula rate plan.  ACG will work with counsel to ensure that the FRP filing is consistent with the Company’s other tracker mechanisms and that there are no double recoveries of costs or lost revenues, nor any other unanticipated conflicts with these other trackers. ACG will develop a historic and regional peer-group benchmarking analyses on the Company’s operation and maintenance (“O&M”) costs, administrative and general (“A&G”) costs, and proposed changes to plant in service focusing on larger production, transmission and distribution plant investment changes.  ACG will also develop general forecasts of the O&M, A&G, and investments under future FRPs and developed rate impact outlook.  ACG will prepare a retail rate benchmark analysis that compares the Company’s existing rates, and projected FRP rates, against historic trends and a regional peer group average over a five year period. Additionally, ACG will analyze and evaluate all possible material issues impacting ratepayers with a particular emphasis on fixed income and lower income households

 

In Re:  I/M/O the Board of Public Utilities Infrastructure Programs Stakeholder Process; Docket. No. Pending; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the Board Staff’s straw proposal regarding the implementation of regulations for a Multi-Year Infrastructure Program for New Jersey utilities.  ACG will evaluate the engineering and policy implications of a multi-year infrastructure program as well as the necessity of the infrastructure program.  ACG will provide an expert analysis of the Board Staff straw proposal and provide assistance in developing any necessary program terms.

 

In Re:  I/M/O the Petition of the South Jersey Gas Company for Approval of Increased Base Tariff Rates and Charges for Gas Service and Other Tariff Revisions;Docket. No. GR17010071; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition filed by South Jersey Gas Company (“SJG” or “Company”) requesting approval of an increase in the Company’s rates and charges for gas service.  The Company is requesting to increase base rates by $74.8 million or 15.3 percent.  ACG will conduct an evaluation of the Company’s increases in capital expenditures as a result of investments for base replacements, customer growth, and accelerated replacement programs.  Additionally, ACG will examine issues associated with the construction of Compressed Natural Gas (“CNG”) stations including the economic and environmental benefits as well as the gas market policy associated with a utility’s construction and operation of public CNG stations.  ACG will also analyze the engineering implications of the replacement of 5 miles of pipeline and the modification of two distribution stations.

In Re: I/M/O the Petition of New Jersey Natural Gas Company for a Determination Concerning the Holmdel Regulator Station Pursuant to N.J.S.A. 40:55D-19; Docket No. GO17010023, Ongoing. ACG is assisting the New Jersey Division of Rate Counsel in examining the petition filed by New Jersey Natural Gas (“NJNG” or “Company”) in its appeal of the Holmdel Township Zoning Board (“Zoning Board”) and request that the New Jersey Board of Public Utilities (“B.P.U. or “Board”) authorize the construction of the proposed regulator station.  ACG will provide engineering analysis on the evaluation of the appropriate pressure of the transmission main as well as the necessity of the installation of a heater to control temperature drops.  ACG will also evaluate the location of the proposed regulator station on the Company’s selected site location.

In Re:  I/M/O the Petition of Pivotal Holdings, Inc. d/b/a Elizabethtown Gas for Approval of Increased Base Tariff Rates and Charges for Gas Service and Other Tariff Revisions; Docket. No. GR16090826; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the petition filed by Elizabethtown Gas (“Elizabethtown” or “Company”) requesting approval of an increase in the Company’s rates and charges for gas service.  The Company is requesting to increase base rates by $19 million or 6.6 percent.  ACG will conduct an evaluation of the Company’s increases in capital expenditures as a result of investments for base replacements, customer growth, and accelerated replacement programs.  Additionally, ACG will examine issues associated with the construction of a gas liquefaction facility including the economic and environmental benefits associated with the facility, a sizing analysis, and project costs.

In Re:  I/M/O the PennEast Pipeline Company, LLC FERC Certification; Docket. No. CP15-558-000; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in examining the PennEast Pipeline Company, LLC’s request to develop a large transportation line from the Marcellus basin in Pennsylvania and into New Jersey and New York.  ACG will examine the need for the pipeline give current transportation capacity opportunities in the region, and New Jersey utilities’ current and anticipated contractual transportation obligations, competitive alternatives, and the economic impacts of the proposed project. Additionally ACG will analyze trends in transportation capacity release markets and provide an examination and comparison of recent New Jersey utility capacity investments, as well as other regional capacity investments, particularly storage and liquefied natural gas (“LNG”) capacity investments.  ACG will assist in the examination of affiliate issues between the regulated and unregulated operations of the New Jersey utilities that are participants/co-owners of the PennEast project.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of Electric and Gas Base Rate Adjustment Pursuant to Energy Strong Program; Docket. No. ER16030272/GR16030273; Completed 2017.  ACG is assisting the New Jersey Division of Rate Counsel in examining PSE&G’s request to move investments associated with its Energy Strong Program into rate base. ACG will conduct an evaluation of the Company’s projects and expenditures and the overall progress of the Company’s program.

In Re: I/M/O The Application of CenterPoint Energy Arkansas for Approval of Changes in Rates for Retail Electric Service; Docket No. 15-098-U; Completed 2016.  ACG assisted Division of Consumer Utility Rate Advocacy in evaluating CenterPoint’s request for a rate increase in matters pertaining to the Company’s cost of service study and rate design.  ACG evaluated the Company’s cost of service model for appropriate cost causation principles and conducted an alternative cost of service analysis.  ACG also developed an alternative rate design proposal.  ACG provided expert testimony and research.

 

In Re:  I/M/O the Petition of South Jersey Gas Company to Continue its Accelerated Infrastructure Replacement Program (“AIRP”) Pursuant to N.J.S.A. 48:2-21 and N.J.S.A. 48:2-21.1 and for Approval of a Base Rate Adjustment to Reflect AIRP Investments in Base Rates. Docket No. GR16020175; Completed 2016.  ACG is assisting the New Jersey Division of Rate Counsel in examining South Jersey Gas Company’s petition to extend its AIRP for an additional seven years for the accelerated replacement of its at-risk infrastructure to modernize its grid.  ACG will analyze and evaluate the cost-benefit and cost-effectiveness of the proposed program, perform a benchmarking analysis, and evaluate the programs construction cost estimates. Additionally, ACG will analyze from an engineering perspective the Company’s proposed changes to its infrastructure as well as other engineering matters.

In Re:  I/M/O the Petition of New Jersey Natural Gas Company for Approval of an Increase in Gas Base Rates and for Changes in its Tariff for Gas Service; Approval of SAFE Program Extension; and Approval of SAFE Extension and NJ RISE Rate Recovery Mechanisms Pursuant to N.J.S.A. 48:2-21, 48:2-21.1 and for Changes to Depreciation Rates for Gas Property Pursuant to N.J.S.A. 48:2-18. Docket No. GR15111304; Completed 2016.  ACG is assisting the New Jersey Division of Rate Counsel in examining New Jersey Natural Gas Company in the evaluation and analysis related to the Company’s SAFE program and cost recovery mechanism, costs associated with the SRL Pipeline, economic and environmental benefits, customer and load growth, associated with the liquefaction program.  This will include the analysis of the project cost estimates, benchmarking analysis, and facilities sizing analysis.

 

In Re:  I/M/O a General Investigation Regarding the Acceleration of Replacement of Natural Gas Pipelines Constructed of Obsolete Materials Considered to be a Safety Risk; Docket No. 15-GIMG-343-GIG; Completed 2016.  ACG is assisting the Kansas Citizens’ Utility Ratepayer Board in the examination of the accelerated pipeline programs proposed by Atmos Energy, Black Hills, and Kansas Gas Service.  ACG will examine the engineering aspects of the Company’s application and testimony relating to pipeline replacement programs and activities.  ACG will prepare expert testimony which includes an analysis of the Company’s replacement programs and a comparative analysis of the Company’s program and programs operated by other regional utilities.

 

In Re:  I/M/O the Merger of the Southern Company and AGL Resources, Inc.; Docket No. GM15101196; Completed 2016. ACG assisted the New Jersey Division of Rate Counsel in examining the Joint Petition for approval of the merger of the Southern Company and AGL Resources. This included the evaluation of the Joint Petitioners’ proposed commitments in relationship to the Board merger standards and policies, synergy savings, merger benefits, and future reporting and monitoring if the merger is approved.  ACG also analyzed the impact that the proposed merger will have on reliability and service quality, the local community, rates and charges, Corporate Governance, and regulatory oversight.

 

In Re:  I/M/O the Application of Atmos Energy Corporation for Adjustment of its Natural Gas Rates in the State of Kansas; Docket No. 16-ATMG-079-RTS; Completed 2016.  ACG assisted the Kansas Citizens’ Utility Ratepayer Board in the examination of an infrastructure tracking mechanism requested by Atmos Energy in its rate case application.  ACG examined the engineering aspects of the Company’s application and testimony relating to pipeline replacement programs and activities.  ACG prepared expert testimony which included an analysis of the Company’s replacement programs and a comparative analysis of the Company’s program and programs operated by other regional utilities.

In Re:  I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas for Approval of a Safety, Modernization and Reliability Program and Associated Cost Recovery Mechanism; Docket No. GR15091090; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel with the evaluation of Elizabethtown’s petition of the approval of the Company propose replacement program of vintage mains and service as well as the analysis of the costs associated with the proposed pipeline replacement program.  ACG will analyze and evaluate the cost-benefit and cost-effectiveness of the proposed program, perform a benchmarking analysis, and evaluate the programs construction cost estimates. Additionally, ACG will analyze from an engineering perspective the Company’s proposed changes to its infrastructure as well as other engineering matters.

 

In Re:  I/M/O the Joint Application of SourceGas Arkansas Inc., SourceGas Inc., SourceGas LLC, SourceGas Holdings LLC, and Black Hills Utility Holdings, Inc. for all Necessary Authorizations and Approvals for Black Hills Utility Holdings, Inc. to Acquire SourceGas Holdings LLC; Docket No. 15-078-U; Completed 2015.  ACG assisted the Office of the Arkansas Attorney General in the examination of proposed acquisition of SourceGas Holdings LLC by Black Hills Utility Holdings.  ACG examined the Joint Applicants’ Application for consistently with Commission merger standards, as well as the impact on ratepayers, the community and employment levels.  Additionally, ACG will conduct an analysis of any potential cost savings and merger synergies that will arise as a result of the acquisition.

 

In Re: I/M/O of the Application of SourceGas Arkansas Inc. for an Order Approving the Acquisition of Certain Storage Facilities and the Recovery of Investments and Expenses Associated Therewith; Docket No. 15-031-U; Completed 2015.  ACG assisted the Office of the Arkansas Attorney General in examining the SourceGas Arkansas Inc.’s application for the purchase, acquisition and further development of the Stockton Storage Facilities and the associated cost recovery mechanism.  ACG prepared expert testimony which included a cost-benefit analysis, an analysis of the Company’s transmission costs, as well as conducted a due diligence review.  ACG also assisted with settlement discussions and provided settlement testimony on the behalf of the Office of the Arkansas Attorney General.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company 2015/2016 Annual BGSS Commodity Charge Filing for its Residential Gas Customers Under Its Residential Gas Customers Under its Residential Gas Customers Under its Periodic Pricing Mechanism and for Changes in its Balancing Charge; Docket No. GR15060647; Completed 2016. ACG assisted the New Jersey Division of Rate Counsel in examining PSE&G’s Basic Gas Supply Service annual filing. This included the evaluation of the Company’s gas charges and balancing charges for the 2015/2016 period. ACG conducted an analysis of the Company gas procurement and gas hedging practices.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of Electric and Gas Base Rate Adjustment Pursuant to Energy Strong Program; Docket. No. ER15030389/GR15030390; Completed 2015.  ACG assisted the New Jersey Division of Rate Counsel in examining PSE&G’s request to move investments associated with it Energy Strong Program into rate base. ACG conducted an evaluation of the Company’s projects and expenditures as well as visits to project sites to evaluate the Company’s program progress.

 

In Re:  I/M/O the Petition of New Jersey Natural Gas Company for Approval and Authorization to Construct and Operate the Southern Reliability Link Pursuant to N.J.A.C. 14:7-1.4; Docket No. GO15040402; Completed 2016.  ACG assisted the New Jersey Division of Rate Counsel in examining New Jersey Natural Gas Company in the evaluation and analysis related to the engineering aspects of the Company’s proposal to construct a natural gas transmission pipeline in the southern portion of the Company’s service territory.  ACG conducted an analysis of the project cost estimates, proposed pipeline size, and gas flow modeling.

 

In Re:  I/M/O the Office of the People’s Counsel’s Complaint Against Washington Gas Light Company Regarding the Unlawful Compensation of Competitive Service Providers in Violation of its Rate Schedule Number 5; FC 1126; Completed 2016.  ACG assisted the District of Columbia’s Office of People’s Counsel in the investigation of whether a violation has occurred.  This will include a comparative analysis of natural gas prices across various hubs and natural gas spot prices with WGL’s weighted cost of gas and the prices paid to the CSPs, as well as an examination of gas market distortions and WGL’s affiliate relationships.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for the Approval of a Gas System Modernization Program and Associated Cost Recovery Mechanism; Docket No. GR15030272; Completed 2015.  ACG assisted the New Jersey Division of Rate Counsel in examining the economic impacts, market policy, and engineering aspects of the gas system replacement plan.  ACG conducted an analysis of the Company’s past replacement programs and a cost benefit analysis of the proposed program.

 

In Re: I/M/O the Petition of Vermont Gas systems, Inc. for a certificate of public good, pursuant to 30 V.S.A. §248, authorizing the construction of the “Addison Natural Gas Project”; Docket No. 7970; Completed 2015. ACG assisted Vermont’s AARP in examining ratemaking and policy issues associated with the Addison Natural Gas Project. ACG provided an economic impact study, along with an examination into ratepayer costs and the system wide effects of the infrastructure project.

 

In Re: I/M/O the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas To Establish A Neighborhood Expansion Program; Docket No. GR15010038; Completed 2016. ACG assisted the New Jersey Division of Rate Counsel in examining the economic impacts of Elizabethtown’s expansion program. ACG conducted an analysis of the Company’s infrastructure planning, economic impact modeling, cost/benefit analysis, and rate impact study.

 

In Re: I/M/O the Petition of Fitchburg Gas and Electric Light Company d/b/a Unitil for approval by the Department of Public Utilities of the Company’s 2015 Gas System Enhancement Program Plan, pursuant to G.L. c. 164, § 145, and for rates effective May 1, 2015; Docket No. 14-130; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing Fitchburg’s proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated Fitchburg’s proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of The Berkshire Gas company for approval by the Department of Public Utilities of the Company’s Gas system Enhancement Program Plan for 2015, pursuant to G.L. c. 164, § 145, and for rates effective May 1, 2015; Docket No. 14-131; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing Berkshire’s proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated Berkshire’s proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of Boston Gas Company and Colonial Gas Company d/b/a National Grid for approval by the Department of Public Utilities of the Companies’ Gas System Enhancement Program Plan for 2015, pursuant to G.L. c. 164, § 145, and for rates effective May 1, 2015; Docket No. 14-132; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing National Grid’s proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated Boston Gas and Colonial Gas Companies’ proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of Liberty Utilities for approval by the Department of Public Utilities of the Company’s Gas System Enhancement Program Plan for 2015, pursuant to G.L. c. 164, § 145, and for rates effective May 1, 2015; Docket No. 14-133; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing Liberty Utilities’ proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated Liberty’s proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of Bay State Gas Company d/b/a Columbia Gas of Massachusetts for approval by the Department of Public Utilities of the Company’s Gas System Enhancement Program Plan for 2015, pursuant to G.L. c. 164, § 145, and for rates to be effective May 1, 2015; Docket No. 14-134; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing Bay State’s proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated Bay State’s proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of NSTAR Gas Company for approval by the Department of Public Utilities of the Company’s Gas System Enhancement Program Plan for 2015, pursuant to G.L. c. 164, § 145, and for rates to be effective May 1, 2015; Docket No. 14-135; Completed 2015. ACG assisted the Massachusetts Attorney General in analyzing NSTAR’s proposal to accelerate the replacement of leak prone main and service piping. ACG evaluated NSTAR’s proposal compared to previous accelerated replacement plans in the state on several aspects including: program costs and benefits, rate design, ratepayer protections, and performance benchmarking.

 

In Re: I/M/O the Petition of Green Mountain Power Corporation for approval of an Alternative Regulation Plan, pursuant to 30 V.S.A. § 218d; Docket No. 8191; Completed 2014. ACG assisted AARP in examining the filing by Green Mountain Power Corporation requesting a new Alternative Regulation Plan. ACG focused on evaluating the independent peer group and provided thorough evaluation of the claims made by Green Mountain Power. Additionally, ACG provided recommendations to maintain a fair balance between stockholder and ratepayer benefits.

 

In Re: I/M/O an Audit of the Affiliated Transactions between New Jersey Natural Gas Company and Its Affiliates and a Comprehensive Management Audit of New Jersey Natural Gas Company Pursuant to N.J.S.A. 48:2-16.4, N.J.S.A 48:3-49, N.J.S.A 48:3-58 and N.J.A.C 14:3-12.1 through 14:3-12.4; Docket No. GA13010008; Completed 2015. ACG assisted the New Jersey Division of Rate Counsel in reviewing the gas utility affiliate relations and management processes audit conducted by NorthStarConsulting and the associated comments filed by New Jersey Natural Gas.  ACG analyzed and evaluated a number of issues identified in the audit and provided recommendations for the resolution of the issues.

 

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; Completed 2015. ACG assisted the Office of the People’s Counsel for the District of Columbia in analyzing the policy aspects of the proposed merger of Exelon and Pepco, including the potential impacts on service quality, cost of service, and rates.  ACG provided expert testimony on various economic, public policy, and regulatory policy issues associated with the merger.  ACG provided an economic impact analysis, as well as review and analysis of the impact of the merger on employment, utility management and operation, system reliability, regulatory oversight, and potential impacts on the competitive market.

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; Completed 2014.  ACG assisted the Illinois Attorney General in a benchmarking and investment performance analysis regarding the Companies’ petitions. This included comparing the Companies to a peer group with respect to usage, pricing, pipeline materials, replacement, and safety data.  ACG provided testimony and analysis that demonstrated the Companies’ proposed test-year expenses were considerably higher than reasonable levels and should be reduced.  In addition to identifying considerable accumulated inefficiencies embedded in the Companies’ test-year projections that needed to be eliminated.  ACG recommended that the Commission consider using Peoples’ leak reduction performance as an additional metric for evaluating the success of its pipeline replacement efforts.

 

In Re: I/M/O Iberville Parish v. Acadian Gas Pipeline System; Completed 2015. ACG assisted 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.  ACG conducted an analysis and prepared a report that determined the cost of the pipe was low and not in reasonable range of market value estimates.

 

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; Completed 2015. ACG assisted the Massachusetts Attorney General with an examination of the Company’s filing. This included reviewing the contract and pricing structure of the agreement as well as analyzing ratepayer impacts.  

 

In Re: I/M/O Anthony Williams, et al. vs. Duke Energy Corporation, et al.; Case No.: 1:08-cv-0046; Completed 2015. ACG assisted Demarco Law Firm with an analysis of Ohio retail electricity markets and the transfer of Duke’s settlement terms from regulated to unregulated operations. Additionally, ACG conducted an analysis/estimation of potential excess profits arising from Duke’s retail market actions.  The Company reached an $81 million settlement to end the class-action lawsuit.

 

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; Completed 2014.  South Jersey Gas Company filed a petition with the New Jersey Board of Public Utilities to increase rates. The petition also included a proposal for investment in a new LNG Liquefaction System planned to be built in McKee City, and a tariff revision specifically on CNG.  ACG assisted the New Jersey Division of Rate Counsel in analyzing the economic, policy, and engineering aspects of the Company’s filing.  This included an evaluation on its compliance with the energy master plan, other regulations, and analyzing capital expenditures. ACG’s analysis included reviewing the proposed construction of a liquefaction system, the Compressed Natural Gas station building program, and an in-depth evaluation of the Company’s Cost of Service Study and Rate Design proposals.

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; Completed 2014.  ACG assisted 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. ACG prepared a report for the New Jersey Division of Rate Counsel providing an overview and analysis of current CIP II projects being undertaken by PSE&G.

 

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); BPU Docket Nos. AX13030196/GO13060600; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas.  In connection with major storm events, ACG examined 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas concerning their storm hardening and reliability infrastructure program.  ACG reviewed 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by Public Service Electric & Gas.  Concerning PSE&G’s gas operations, ACG examined 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by South Jersey Gas.  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 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; Completed 2014.   ACG assisted the New Jersey Division of Rate Counsel in examining the petition by Elizabethtown Gas.  ACG investigated 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 New Jersey Gas Company for Approval of the NJ RISE Program and Associated Rate Recovery Mechanism; BPU Docket No. GO13090828; Completed 2014.  ACG assisted 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 reviewed 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by New Jersey Natural Gas.  In connection with major storm events, ACG examined the Company’s restoration efforts and assessed 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by Elizabethtown Gas.  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 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; Completed 2014.  ACG assisted the New Jersey Division of Rate Counsel in examining the petition by New Jersey Natural Gas.  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; Completed 2015.  ACG assisted theMassachusetts Office of the Attorney General with a review and analysis of the 2013 Avoided Energy Supply Component Study.  ACG addressed the issues of avoided generation, transmission, and distribution costs.  ACG also examined fuel price forecasts and critical input assumptions, Demand Reduction Induced Price Effect, and load forecasts and reserves.

 

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; Completed 2014.  ACG assisted 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 also examined 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 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 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 its 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:  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:  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:  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:  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 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 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 they 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:  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 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:  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:  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 assisted 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 provided an 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.

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 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: 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.

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.  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.

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.

Economic Impact

In Re: I/M/O the Petition of Fishermen’s Atlantic City Wind Farm, LLC for the Approval of the State Waters Project and Authorizing Offshore Wind Renewable Energy Certificates; BPU Docket No. EO11050314V; Completed 2013. ACG was retained by the New Jersey Division of Rate Counsel to provide an expert opinion to the Board of Public Utilities on the revised offshore wind development application submitted by Fishermen’s Atlantic City Wind Farm (FACW). ACG recommended rejection of the FACW project because it did not meet statutory requirements and it was not in the public interest since it would not produce a net economic benefit to New Jersey ratepayers.

In Re: I/M/O the Petition of Vermont Gas systems, Inc. for a certificate of public good, pursuant to 30 V.S.A. §248, authorizing the construction of the “Addison Natural Gas Project”; Docket No. 7970; Completed 2015. ACG assisted Vermont’s AARP in examining ratemaking and policy issues associated with the Addison Natural Gas Project. ACG provided an economic impact study, along with an examination into ratepayer costs and the system wide effects of the infrastructure project.

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; Completed 2015. ACG assisted the Office of the People’s Counsel for the District of Columbia in analyzing the policy aspects of the proposed merger of Exelon and Pepco, including the potential impacts on service quality, cost of service, and rates. ACG provided expert testimony on various economic, public policy, and regulatory policy issues associated with the merger. ACG provided an economic impact analysis, as well as review and analysis of the impact of the merger on employment, utility management and operation, system reliability, regulatory oversight, and potential impacts on the competitive market.

In Re: PSE&G Economic Analysis of Capital Expenditure Program (Rutgers Study); RC File No.: 15-G-93; Completed 2015. ACG assisted the New Jersey Division of Rate Counsel in examining the Rutgers’ Economic Impact Analysis based on capital expenditures made by the Public Service Electric and Gas Company (“PSE&G”). The examination of the impact analysis focused on the reasonableness of the assumptions, along with the positive and negative economic impacts discussed within the study.

Research

After researching the performance of Vermont Gas systems, David Dismukes released a report refuting the effectiveness of the Alternative Regulation Plan after seeing multiple shortcomings and failures arise since its integration in 2006.