In Re: I/M/O the Petition of South Jersey Gas to Modify and Extend its Existing Capital Investment Recovery Tracker ("CIRT II"); Ongoing. ACG is assisting the New Jersey Division of Rate Counsel with an examination of the filing and is empirically examining the Company’s past pipeline replacement actions and past corrosion-related leak performance. ACG is also analyzing the claimed job growth and economic development benefits created under the previous mechanism.
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; Ongoing. On behalf of the Nebraska Public Advocate, ACG is examining the application submitted by SourceGas Distribution and is addressing the issues of decoupling, customer adjustments, weather normalization (test year adjustment and new normalization period), class cost of service, and rate design.
In Re: In the Matter of the Application of UNS Gas, Inc. for Approval of a Rate Increase; Docket No. G-04204A-11-0158; Ongoing. ACG is assisting the Arizona Corporation Commission with an examination of the application submitted by UNS Gas, Inc. ACG is providing expert testimony and analysis on the issues of rate design, class cost of service, and revenue decoupling.
In Re: Avista Utilities 2011 General Rate Case; Docket No. UG-110877; Ongoing. ACG is assisting the Washington Attorney General with an examination of Avista Utilities’ current revenue decoupling mechanism and compliance with the UTC conservation policy statement. ACG is also examining the Energy Efficiency Load Reduction Adjustment as well revenue requirement issues that include executive compensation, affiliate transactions, incentive compensation, and the internal accounting audit.
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 is assisting the Maryland People’s Counsel with an analysis of Washington Gas Light Company’s rate design, cost of service study, and pipeline replacement rate tracker mechanism.
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 is preparing an analysis as well as direct and rebuttal testimony responding to rate design and revenue decoupling issues.
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 is assisting the Arizona Corporation Commission with an examination of the application submitted by Southwest Gas Corporation. ACG is providing expert testimony on rate design, cost of service, billing determinants, and revenue decoupling.
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 requirements.
In Re: New England Gas Company’s Petition for a Base Rate Increase and Decoupling Mechanism; D.P.U. 10-114; Completed 2010. ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by New England Gas Company. ACG provided expert testimony recommending the rejection of the company’s proposed Targeted Infrastructure Replacement Factor.
In Re: Texas Gas Service’s El Paso Service Area Rate Case; Docket 9988; Completed 2010. ACG assisted the City of El Paso, Texas, with an examination of the application submitted by Texas Gas Service Company to increase its rates for natural gas service provided to its El Paso Service Area. ACG prepared expert witness testimony and analysis on issues related to the Company’s class cost of service study (minimum system and zero intercept analysis); rate design proposals; and weather normalization adjustment.
In Re: Rate Case for Boston Gas Company, Essex Gas Company, and Colonial Gas Company d.b.a. National Grid; D.P.U. 10-55; Completed 2010. ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by National Grid to increase the natural gas distribution rates for customers of Boston Gas Company, Essex Gas Company, and Colonial Gas Company. ACG provided expert testimony on issues related to the Companies’ proposed Net Inflation Factor, Revenue Decoupling, Allocated Class Cost of Service, Rate Design, Technology & Innovation Fund, Targeted Infrastructure Rider, and other related matters.
In Re: In the Matter of Chattanooga Gas Company’s Petition for a General Rate Increase; Docket No. 09-00183; Completed 2010. ACG assisted the Tennessee Attorney General Consumer Advocate & Protection Division with an examination of the application submitted by Chattanooga Gas Company to increase its rates and charges for natural gas service rendered in Tennessee. ACG prepared discovery and analyzed issues regarding the Company’s revenue decoupling proposal and energy efficiency programs. ACG provided testimony on issues surrounding the utility’s energy efficiency program called “energySMART,” the proposed decoupling mechanism, and the bare steel replacement program and its relationship to the proposed decoupling mechanism.
In Re: Texas Gas Service’s El Paso Service Area Rate Case; Completed 2010. ACG assisted the City of El Paso, Texas, with an examination of the application submitted by Texas Gas Service Company to increase its rates for natural gas service provided to its El Paso Service Area. ACG prepared expert witness testimony and analysis on issues related to the Company’s class cost of service study (minimum system and zero intercept analysis); rate design proposals; weather normalization adjustment; and its cost of service adjustment clause, conservation adjustment clause proposals, and other cost tracker policy issues.
In Re: In the Matter of Piedmont Natural Gas; Docket No. 09-00104; Completed 2010. ACG assisted the Tennessee Attorney General Consumer Advocate & Protection Division with an examination of the application submitted by Piedmont Natural Gas to implement its proposed energy efficiency programs and corresponding rate mechanisms including revenue decoupling. ACG prepared expert witness testimony examining Piedmont’s proposed revenue decoupling mechanism and included such issues as alignment of utility’s financial incentives with Tennessee’s energy efficiency policy, ratepayer protection mechanisms, effect of decoupling on business risk, and decoupling effects on earnings. ACG’s testimony also addressed the utility’s energy efficiency programs as well as its weather normalized billing determinants.
In Re: In the Matter of SourceGas Distribution LLC, Lakewood, Colorado, Seeking Approval of a General Rate Increase; Docket No. NG-0060; Completed 2010. ACG is assisting the Nebraska Public Advocate with an examination of the application submitted by SourceGas to increase its distribution non-gas rates and charges for natural gas service rendered in Nebraska. ACG prepared testimony on such issues as revenue decoupling proposal, customer adjustment rider, inflation adjustment rider, pipeline infrastructure cost recovery rider, and several issues related to weather normalization.
In Re: Petition of Bay State Gas Company for Approval of a General Increase in Gas Distribution Rates Proposed in Tariffs M.D.P.U. Nos. 70 through 105, and for Approval of a Revenue Decoupling Mechanism; Completed 2009. ACG assisted the Massachusetts Attorney General with an examination of the application submitted by Bay State Gas Company to increase its distribution non-gas rates and charges for natural gas service rendered in Massachusetts. ACG provided testimony on the Company’s revenue decoupling proposal, the Company’s Targeted Infrastructure Reinvestment Factor (“TIRF”) proposal, and several issues related to the Company’s inclining block rate design proposals.
In Re: Allegations Concerning Activities at the Grand Bayou (Louisiana) Natural Gas Storage Cavern Against Dow Chemical; Completed 2009. ACG assisted Lemle & Kelleher with analysis, studies, and other support as necessary during the course of litigation. ACG has provided expert analysis and report on gas storage valuation issues.
In Re: The Complaint of Weldon Johnson, Individually and as Representative of Other Arkansas Customers Similarly Situated vs. CenterPoint Energy, Inc., FKA Reliant Energy, Inc., CenterPoint Energy Resources Corp., CenterPoint Gas Marketing Company, CenterPoint Energy Pipeline Services, Inc., CenterPoint Energy Field Services; Kinder Morgan Texas Pipeline, L.P., Kinder Morgan Energy Partners, L.P., Kinder Morgan, G.P., Inc., Kinder Morgan Texas Pipeline, L.P., Kinder Morgan Texas Pipeline, GP, Inc., Kinder Morgan Texas Pipeline, GP, Inc., Texas Gas, LLC, Gulf Energy Marketing, LLC, KM Texas Pipeline, LP, Midcon Corp., Houston Pipeline Company, LP, And Shell U.S. Gas & Power, LLC; Docket No. 07-105-C; Completed 2009. ACG assisted Arkansas Office of the Attorney General with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Arkla. Analysis included evaluating the costs passed through the purchased gas adjustment clause from affiliated companies.
In Re: Determination of Salt Cavern Lease Agreements, State of Louisiana, Office of Mineral Resources, Completed 2009. ACG acted in a mediator role evaluating a fair lease structure and payment schedule for two new salt cavern natural gas storage facilities between Jefferson Island Storage and Hub (Sequent/AGL Resources) and the State of Louisiana (Department of Natural Resources, Office of Mineral Resources). Analysis included the development of natural gas storage profitability models under various income earning scenarios and recommendations on lease payment structures.
In Re: Transcontinental Gas Pipeline Corporation Before the United States District Court of Louisiana, Lake Charles Division; Civil Action No. 2:07-CV-2165; Completed 2009. ACG assisted Transcontinental Gas Pipeline action before the United States District Court of Louisiana. ACG provided expert rebuttal testimony on behalf of Transcontinental Gas Pipeline regarding whether certain properties could be used for an industrial purpose in the near future, absent Transco’s proposed action, and the function for which the subject pipelines are currently, and anticipated, to be utilized.
Click the links below to view further examples of ACG's experience in the gas industry.
2005 - 2008
In Re: In the Matter of the Assessment of Value Issued to the Jefferson Island Storage and Hub; Appeal Number 2007-125 and 2007-299. Completed 2008. ACG assisted AGL Resources with its appeal before the Louisiana Tax Commission regarding the valuation of its Jefferson Island natural gas storage facility and hub. ACG provided expert witness testimony on behalf of AGL Resources that included an evaluation and critique of the valuation methods used by the local parish tax assessor and its outside consultants.
In Re: In the Matter of the Application of Questar Gas Company to Increase the Distribution Non-Gas Rates and Charges and Make Tariff Modifications; Docket No. 07-057-13; Completed 2008. ACG assisted the Utah Committee of Consumer Services with the examination of the application submitted by Questar Gas Company to increase its distribution non-gas rates and charges for natural gas service rendered in Utah. ACG provided expert testimony, exhibits and assistance on class cost of service issues, rate design issues, decoupling, customer charges, and Contributions in Aid of Construction policy matters.
In Re: AGL Resources, Inc., Tax Analysis; Completed 2008. ACG assisted AGL Resources by reviewing and analyzing the Georgia Department of Revenue Valuation Methodology.
In Re: Washington Utilities and Transportation Commission v. Northwest Natural Gas Company; WUTC Docket No. UG-080546; Completed 2008. ACG assisted the Washington Attorney General in its examination of several issues in Northwest Natural Gas Company’s rate case and decoupling proposal. These issues included revenue decoupling and rate design with an emphasis on customer charges and the Company’s Smart Energy Program.
In Re: Commission Audit of the Purchased Gas Adjustment Filings of CenterPoint Energy-Arkla; Docket No. U-27196-Subdocket A; Completed 2008. ACG assisted the Louisiana Public Service Commission with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Arkla. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations.
In Re: Application of SEMCO Energy Gas Company for Authority to Redesign and Increase its Rates for Sale and Transportation of Natural Gas in its MPSC Division and Other Relief; Docket No. U-14893; Completed 2007. ACG assisted the Michigan Attorney General’s Office in its review of SEMCO’s application for a rate increase and rate redesign. SEMCO had proposed to decouple the Company’s revenues and sales through the elimination of variable charges for all distribution non-gas costs. ACG examined the pros and cons of revenue decoupling, incentive mechanisms to foster conservation and DSM, the current state of decoupling and DSM in the gas industry, the financial impacts of decoupling, the financial impacts of declining sales, the relationship between sales and revenue, deferred accounting mechanisms, and alternatives to decoupling.
In Re: Joint Application of Questar Gas Company, the Division of Public Utilities, and Utah Clean Energy for the Approval of the Conservation Enabling Tariff Adjustment Option and Accounting Orders; Docket No. 05-057-T01; Completed 2007. ACG assisted the Utah Committee of Consumer Services to examine the joint application submitted by Questar Gas Company, the Division of Public Utilities, and Utah Clean Energy, requesting approval for the adoption of a Conservation Enabling Tariff and other enabling accounting mechanisms and proposals. ACG extensively examined the pros and cons of revenue decoupling, incentive mechanisms to foster conservation and DSM, the current state of decoupling and DSM in the gas industry, the financial impacts of decoupling, the financial impacts of declining sales, the relationship between sales and revenue, deferred accounting mechanisms, and alternatives to decoupling.
In Re: Commission Audit of Purchased Gas Adjustment Filings of Reliant Energy-Entex Pursuant to Commission General Order Dated March 24, 1999; Docket No. U-26721; Completed 2007. ACG assisted the Louisiana Public Service Commission with an evaluation of the costs recovered through the purchased gas adjustment clause of CenterPoint Energy-Entex. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations. Once the first phase of the audit had been completed and research indicated that the audit period should be extended to investigate certain irregular cost recovery practices, ACG was hired to continue the investigation.
In Re: Lake Charles Cogeneration Project; Economic Benefit Study; Report filed January 2005; Update in progress. ACG assisted Lake Charles Cogeneration, LLC, by performing an economic impact study regarding the construction and operation of the Lake Charles Cogeneration and Regasification project. In particular the analysis looked at: (1) economic impacts – including regional investment, direct and indirect benefits, and employment opportunities; (2) fuel diversity – an understanding of gasification, petroleum coke, and the role of hydrogen; (3) economic development – how output from the facility would support a large number of Louisiana industries; (4) environmental benefits; and (5) technological benefits. Impact was estimated for Calcasieu Parish and the State of Louisiana.
In Re: In the Matter of the Assessment of Public Utility Taxable Value Issued to Columbia Gas Transmission; Tax Commissioner’s Case 01-01849 and 01-05338; Completed 2005. ACG assisted Columbia Gas Transmission with its filings before the Board of Tax Appeals in the State of Ohio, regarding its property valuation. ACG performed analyses of the competitive nature of the natural gas transportation market in Ohio. The analysis concentrated on services offered by LDCs and intrastate and interstate pipelines as well as the role of alternative products.
In Re: Evangeline Gas Company; Completed 2005. ACG assisted Evangeline Gas Company with an examination of the purchased gas adjustment clause and accounting for gas costs to Evangeline Gas Company. The analysis conducted compared the utility’s calculations to those proposed by the Staff of the PSC to determine if there were over- or under-collections of gas costs that were not properly accounted for. ACG provided the client with an outline of areas for further examination and provided them with an analysis of their gas recovery mechanisms compared to other gas companies in Louisiana.
In Re: ANR Pipeline Company v. Louisiana Tax Commission; Number 468,417 Section 22, 19th Judicial District Court, Parish of East Baton Rouge, State of Louisiana Consolidated with Docket Numbers: 480,159; 489,776; 480,160; 480,161; 480,162; 480,163; 480,373; 489,776; 489,777; 489,778; 489,779; 489,780; 489,803; 491,530; 491,744; 491,745; 491,746; 491,912; 503,466; 503,468; 503,469; 503,470; 515,414; 515,415; and 515,416; Completed 2005. ACG assisted ANR Pipeline Company with its case before the 19th Judicial District Court, Parish of East Baton Rouge, State of Louisiana by examining the levels of competition between intra- and interstate natural gas pipelines in Louisiana and the Gulf Coast. The analysis concentrated on volumes transported by intra- and interstate pipelines and connections to industrial users.
2000 - 2004
In Re: OCS-Related Infrastructure in the Gulf of Mexico Fact Book; Completed 2004. ACG assisted the Minerals Management Service with a thorough analysis of the onshore infrastructure that supports offshore Outer Continental Shelf activities. This included discussions of many facets within the oil and gas industry including platform fabrication facilities, shipbuilding and repair facilities, ports, heliports, natural gas processing plants, refineries, petrochemical plants, pipe coating services, storage facilities, and transmission networks.
In Re: Research on Hovercraft Applications in the Oil and Gas Industry; Completed 2003. ACG assisted marine services company in market research associated with oil and gas activities in the Louisiana coastal zone. ACG conducted market research to determine the scope of the potential market for hovercraft activities in exploration and production (“E&P”) and plug and abandon (“P&A”) activities in the Louisiana coast zone. ACG constructed a prototype GIS-enabled market research tool for this investigation.
In Re: CIG Field Services (El Paso Corporation) v. Kansas Board of Tax Appeals; CLMS # L98-900196; Completed 2003. ACG prepared an expert report and testimony filed before the Kansas Board of Tax Appeals regarding CIG’s property valuation. ACG performed an analysis of the competitive nature of the natural gas gathering in Kansas. The analysis concentrated on natural gas producing wells capable of sustaining economic production under reasonable economic conditions. ACG also analyzed data for gathering systems contained within single counties as well as those that cross county lines and developed a number of structural statistics to measure market concentration and market access.
In Re: Commission Audit of Purchased Gas Adjustment Filings of Louisiana Gas Service Company Pursuant to Commission General Order Dated March 24, 1999 (Paragraph VI(A)); Docket No. U-25117; Completed 2002. ACG assisted the Staff of the Louisiana Public Service Commission with an evaluation of the costs recovered through the fuel adjustment clause of Louisiana Gas Service Company. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliate suppliers of gas, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations.
In Re: Alaska Natural Gas In-State Demand Study, ASP 2001-1000-2650; Completed 2002. ACG assisted the Alaska Department of Natural Resources by conducting a supply and demand study on the behalf of the. The purpose of the study was to investigate natural gas usage opportunities in the state in order to access the possibilities of serving Alaska communities and business with new natural gas production from the Alaska North Slope. The project included a number of general economic analyses, the development of numerous statistical forecasting models, and a geographic information system (GIS) analysis that mapped existing communities to existing in-state natural gas infrastructure systems and identified those communities that currently have no access to natural gas service and their potential annual natural gas usage. This project also examined the possibilities of delivering natural gas to the interior section of Alaska including the North Slope Borough. Usage opportunities included new residential service to interior communities, commercial usage opportunities, power plant fuel substitution opportunities, and “gas-by-wire” applications. Research also examined a host of other opportunities for expanded natural gas usage including the proposed Netricity internet server farm proposal, new petrochemical opportunities, and expanded LNG opportunities in the south-central portion of the state. Estimated retail costs (tariff rates) for new service were generated and compared to existing fuel sources for space and water heating in interior communities.
In Re: ATCO Gas; Market Analysis; Completed 2001. Members of ACG assisted ATCO Gas by conducting an analysis of the Alberta, Canada, natural gas storage market in order to render an opinion as to whether the Alberta storage market is competitive. Analysis included defining product market, geographic market, and calculated market concentration (HHI). ACG also performed an evaluation of factors that might act to mitigate any exercise of market power by one or more firms. This included size and liquidity of the market, excess capacity in the pipeline system, excess storage capacity, types of customers utilizing storage services, the control of strategic assets, and the likelihood and ease of entry into the storage market.
In Re: Duke Energy Gas Transmission; Analysis of Market Power; Completed 2001. Members of ACG assisted Duke Energy Gas Transmission by performing four separate market power studies for the following storage facilities: Egan Hub, Louisiana; Moss Bluff, Texas; Copiah, Mississippi; and Tioga, Pennsylvania. The studies were performed after Duke Energy Gas Transmission acquired each of the facilities – potentially affecting the market power status of each facility. A market power study was performed for each facility, reflecting the updated corporate structure and submitted to FERC – in the form of a Prepared Statement – along with updated applications requesting to continue with the market-based rates.
In Re: An Investigation into the Allegation Filed by the Plaintiffs Against the Defendants in Case No. 532-085 in the 24th Judicial District Court; The Rhodes Company Inc. et al versus Citizens Utilities Company (Citizens), LGS Natural Gas Company (LGS Natural), LGS Intrastate Inc., (LGSI) and Louisiana Gas Service Company (LGS); Docket No.U-23812; Completed 2000. ACG assisted the Staff of the Louisiana Public Service Commission with an evaluation of the costs recovered through the fuel adjustment clause of Louisiana Gas Service Company. Analysis included evaluating the appropriateness of costs included in the PGA including transactions with affiliate suppliers of gas. The proceeding was ultimately settled, with LGS agreeing to refund $25 million to ratepayers for excess costs included in the PGA.
Prior to 2000
In Re: Washington Utilities and Transportation Commission vs. Cascade Natural Gas Corporation; Cause Number U-86-100; Completed 1987. Members of ACG assisted the Washington Utilities and Transportation Commission, Division of the Attorney General's Office, with preparation of discovery, preparation of direct testimony on class of service issues, and cost allocation issues.
In Re: Southern Union Gas Company's 1985 Rate Request; Completed 1986. On behalf of the Public Utility Regulation Board of El Paso, members of ACG assisted with an examination of revenue requirement issues including affiliate transaction and cost allocations concerning Southern Union Company's rate request. In addition, members of ACG prepared a class cost of service study.
In Re: Southern Union Gas Company's Rate Request; Completed 1985. Members of ACG assisted the Public Utility Regulation Board of El Paso with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, affiliate transactions, cost allocations, revenue issues and class cost of service issues; and preparation of cross-examination questions.