direct testimony mr. joseph j. vortherms before the public ... ra… · craig brown normal weather...

Direct Testimony Mr. Joseph J. Vortherms

Before the Public Utilities Commission of The State of Minnesota

In the Matter of the Application of CenterPoint Energy Resources Corp., d/b/a

CenterPoint Energy Minnesota Gas For Authority to Increase Rates for Natural Gas Utility

Service in Minnesota

Docket No. G-008/GR-15-424 Exhibit______(JJV-D)

Revenue Requirements Policy

Interim Revenue Deficiency and Rates Compliance Requirements

August 3, 2015

MR. JOSEPH J. VORTHERMS Docket No. G-008/GR-15-424

TABLE OF CONTENTS

Page I. Introduction ......................................................................................................... 1 II. Revenue Requirements ....................................................................................... 4 III. Policy ................................................................................................................... 6 IV. Interim Revenue Deficiency and Rates ............................................................. 16 V. Compliance Information .................................................................................... 16

Mr. Joseph J. Vortherms Direct Testimony Revenue Requirements, Policy, Interim Revenue Docket No. G-008/GR-15-424 Deficiency and Rates, Compliance Requirements

1

I. INTRODUCTION 1

Q. Please state your name, business address, and position with CenterPoint Energy 2

Minnesota Gas, an operating unit of CenterPoint Energy Resources Corp. 3

(“CenterPoint Energy”). 4

A. My name is Joseph J. Vortherms. I am Division Vice President of Regional 5

Operations for CenterPoint Energy at505 Nicollet Mall, Minneapolis, Minnesota 6

55402. 7

8

Q. What are your present responsibilities? 9

A. I am responsible for all business and operational results pertaining to CenterPoint 10

Energy in Minnesota. 11

12

Q. Describe your educational background, as well as your business and professional 13

experience. 14

A. Exhibit___(JJV-D), Schedule 1, is a resume of my educational and professional 15

background. 16

17

Q. What is the purpose of your testimony? 18

A. My testimony has four main objectives. First, I will discuss the basic approach 19

utilized by CenterPoint Energy in developing this rate change request. Second, I 20

will discuss significant components of the filing, along with a summary of the 21

overall revenue requirement. Third, I will identify and discuss the major factors that 22


2

are impacting our business and will policy matters related to those factors. Fourth, 1

I will address the compliance items included in our filing. 2

3

Q. Mr. Vortherms, please provide a brief overview of CenterPoint Energy. 4

A. CenterPoint Energy is primarily a natural gas distribution company serving more 5

than 260 communities in Minnesota. CenterPoint Energy has been in business for 6

over 140 years in Minnesota and we are committed to providing natural gas 7

services in a safe, reliable and customer driven manner. This commitment has 8

been recognized by others with CenterPoint Energy: 9

• Consistently achieving first quartile ranking in the Midwest Region of the 10

J.D. Power and Associates’ Residential Gas Utility Customer Satisfaction 11

Survey. 12

• Ranking among the top three of all U.S. investor-owned utilities in the 13

American Customer Satisfaction Index for the past five years. 14

• Ranking first place in the Midwest in the 2014 Cogent Residential Utility 15

Trust Brand and Engagement Study. 16

We employ approximately 1,300 Minnesotans, with 75% of those employed being 17

union jobs. 18

19

Q. Mr. Vortherms, who are the other witnesses testifying for CenterPoint Energy? 20

A. The following other witnesses will offer testimony on the subjects listed below: 21

Witness Subject 22

Talmadge Centers Integrity Management Program 23


3

Kirk Nesvig Operating Revenue, Expenses, Net Rate Base 1

Robert Hevert Cost of Capital, Capital Structure 2

Dr. Robert Livezey Climate Change/ Weather Normals 3

Craig Brown Normal Weather Quantification 4

George Fitzpatrick Sales Forecast 5

Matthew Troxle Class Cost of Service 6

Russell Feingold Zero-Intercept Study to Derive a Customer Component 7

of Distribution Mains 8

Burl Drews Rate Design and Tariff Changes 9

Peggy Sorum Interim Rates 10

11

Q. Mr. Vortherms, please describe the basic approach utilized by CenterPoint Energy 12

in preparing this rate change request for the Commission’s review and approval? 13

A. Similar to our past several rate cases, CenterPoint Energy has utilized a projected 14

test year representing the twelve months ending September 30, 2016, which 15

matches the initial twelve-month period the new rates will be in effect. Again 16

consistent with the approach the Commission has approved in our past several 17

rate cases, test year revenues, expenses and rate base have been projected 18

using forecasted number of customers and gas usage for this time frame, as well 19

as changes in costs from the “base year” that are known and measurable. 20

21

As discussed in more detail by Mr. Nesvig, CenterPoint Energy’s test year 22

calculations began with actual financial information for the calendar-year base 23


4

period ending December 31, 2014. Adjustments to the 2014 actual data were 1

made to eliminate out of period expenses, and to reflect normal operations for the 2

regulated utility portion of the business. Then, this data was adjusted to reflect 3

known changes in operating conditions and inflation, through September 30, 2016. 4

Witness Kirk Nesvig describes this process in detail as it relates to operating 5

revenues, operating expenses, taxes and rate base. 6

7

Q. How was the cost of capital determined? 8

A. As discussed by Mr. Robert Hevert, the costs of capital and capital structure have 9

been developed as if the Minnesota operations of CenterPoint Energy were a 10

single A-rated, natural gas distribution company. This hypothetical capital structure 11

is consistent with that of typical gas distribution companies and is consistent with 12

the capital structure agreement approved by the Minnesota Public Utilities 13

Commission in Docket No. G-008/CI-02-1368 and utilized in the Company’s 14

general rate cases since that time. 15

16

II. REVENUE REQUIREMENTS 17

Q. What is CenterPoint Energy’s revenue deficiency for the test year? 18

A. CenterPoint Energy’s filed revenue deficiency for the test year is approximately 19

$54.1 million. Exhibit ___(JJV-D), Schedule 2, provides a summary of the 20

calculation of this revenue deficiency. Under CenterPoint Energy’s current rates, 21

the overall rate of return for the test year, the twelve months ended September 30, 22

2016, is projected to be approximately 4.46 percent. In order to provide an overall 23


5

rate of return of 7.94 percent, as recommended by Mr. Hevert, CenterPoint 1

Energy’s current revenues for natural gas service must be increased by about 2

$54.1 million or 6.4% percent. 3

4

Q. How are revenue requirements determined? 5

A. On advice of counsel, under Minnesota Statutes Section 216B.16, in setting a 6

utility’s revenue requirements, the Commission must consider the need of the 7

utility to receive: 8

“revenue sufficient to enable it to meet the cost of furnishing the service, 9

including adequate provision for depreciation of its utility property used and 10

useful in rendering service to the public, and to earn a fair and reasonable 11

return upon the investment in such property.” 12

This is the essence of what is known as the “regulatory compact” between 13

regulators and the companies they regulate. In return for the ability to do business 14

in the state and the requirement of complying with state regulations, utilities are 15

allowed the opportunity to recover the full reasonable and necessary cost of doing 16

business in the state. Mr. Hevert discusses this concept further in his testimony. 17

Again on advice of counsel, the utility bears the burden of demonstrating that its 18

proposed revenue requirements, and any associated rate increase to achieve that 19

level of revenues, is “just and reasonable.” 20

21

Q. What is driving the need for CenterPoint Energy to request a rate change at this 22

time? 23


6

A. CenterPoint Energy is making, and will continue to make, significant capital 1

expenditures in the State of Minnesota. These capital expenditures are the primary 2

“driver” of this rate increase request. In accordance with natural gas pipeline safety 3

and integrity regulations discussed by CenterPoint Energy witness Centers, these 4

capital expenditures are necessary to maintain a safe and reliable system and to 5

respond to significant public improvement requirements on our system. Later in my 6

testimony I will elaborate on the level of capital expenditures CenterPoint Energy 7

will be engaged in over the next several years. While these expenditures obviously 8

add costs that must be recovered from our customers, the good news from the 9

customer’s perspective is that the current low natural gas price environment in 10

which we and other natural gas distribution companies operate, together with the 11

Company’s efforts to effectively manage expenses, helps reduce the amount of 12

this rate change request. 13

14

III. POLICY MATTERS AND CURRENT CRITICAL ISSUES 15

Q. What are the biggest external factors influencing CenterPoint Energy and the 16

natural gas business at this time? 17

A. Currently, two phenomena are having the greatest impact on our Company and on 18

the industry as a whole – the abundant domestic supply of natural gas and the 19

increased emphasis on system safety and integrity. I will discuss each of these 20

phenomena before turning to other issues which we address in this rate case. 21

22

23


7

Natural Gas Supply and Pricing 1

Q. What benefits does natural gas offer the country and Minnesota? 2

A. Natural gas has been a clean burning, efficient primary heating source for many 3

years. Natural gas is by far the cleanest burning fossil fuel, producing 50% less 4

CO2 than coal and 30% less CO2 than oil. Since 1987, the numbers of residential 5

natural gas customers in the United States have increased over 40%, yet gas use 6

per residential customer has decreased by nearly 16%. Additionally, I would note 7

here that thanks to new technologies and techniques for developing shale gas, our 8

domestic supplies are bountiful which should mean more affordable and more 9

stable prices for our customers than we have seen in the past. 10

11

The recent December 2014 report from the Potential Gas Agency, developed with 12

the support of the Colorado School of Mines, estimates the total potential gas 13

resources in the United States at 2,515 TCF. This represents more than a 14

doubling of the total potential domestic gas resources understood to exist in 2004. 15

16

Q. How does this abundance of natural gas supply benefit consumers? 17

A. While many factors can impact natural gas prices, such as level of economic 18

activity, price of competitive energy, storage levels and customer demand, this 19

stronger supply position is the primary reason current prices have dropped nearly 20

60% relative to their 2008 levels. 21

22


8

Q. Despite these price drops, do natural gas costs continue to represent the single 1

largest cost component included in the bills of Minnesota natural gas customers? 2

A. Yes. Currently, approximately 63% of every dollar paid to CenterPoint Energy by 3

its customers simply reimburses the Company for its direct costs of natural gas. In 4

2008, this same percentage was approximately 81%. 5

6

Q. What is the regulatory framework for recovery of natural gas costs? 7

A. Minnesota Statutes provide for separate treatment for the utilities’ gas costs as 8

compared to the treatment of general operating costs and profits, through the 9

Purchased Gas Adjustment Statute. As a result of this statute, the cost of natural 10

gas the Company purchases on behalf of our customers is a direct pass through. 11

12

Q. And how has this framework led to benefits for CenterPoint Energy’s Minnesota 13

customers? 14

A. Since the cost of natural gas the Company purchases on behalf of our customers 15

is a direct pass through, our customers have benefited greatly from the lower gas 16

cost environment of recent years. Conservatively, I estimate that through 2014, 17

our customers have saved over $3 billion dollars in their natural gas bills off the 18

high prices experienced in the years leading up to and into 2008. From 2005 19

through 2008, the wholesale costs of commodity for our customers averaged 20

approximately $7.86 per DT. As long as the current abundant domestic supply 21

picture remains, we expect gas costs to stay below these past levels, leading to 22

more affordable and stable bills for our customers for years to come. 23


9

Q. With this understanding, how does a residential customer’s bill in 2008 compare to 1

what is being projected in this rate request? 2

A. Based on normal weather, our average residential customer’s annual bill in 2008 3

was $1,015. In contrast, after factoring in the Company’s current rate increase 4

request, the projected average annual residential customer’s bill annual bill will be 5

$730 – a reduction of over 28% from the 2008 total bill. 6

7

Q. Can the lower gas cost environment help balance other business challenges? 8

A. Yes. Our biggest challenge going forward is that we have an aging infrastructure 9

that, when considered along with additional regulatory requirements related to 10

pipeline safety and integrity, significant public improvements requirements and the 11

need to modernize our system, will require significant capital expenditures in 12

Minnesota over the course of the next decade. I’ll describe this later in my 13

testimony. However, it is important to realize that most of these capital projects will 14

not have a new customer attached to them. Therefore, our utility costs (excluding 15

the cost of gas) will be increasing through the years. Certainly, the low natural gas 16

cost environment can help mitigate the impact of these increased costs on 17

customers. 18

19

CenterPoint Energy’s Safety and Reliability Efforts 20

Q. What is the basic priority of CenterPoint Energy’s Natural Gas Business? 21

A. Our priority is to provide safe and reliable service to our Minnesota Customers. 22

This priority is critical and supersedes everything else we do. When customers 23


10

need natural gas for heating or any other end use, we need to be able to provide 1

that service on demand. Moreover, we are dedicated to designing and operating 2

our system to ensure the safety of our customers, general public, and employees. 3

4

Q. Do you believe that CenterPoint energy has been successful in meeting this goal? 5

A. Yes I do. CenterPoint Energy has engaged for many years in pro-active safety 6

and integrity management in order to maintain and replace the infrastructure 7

serving our existing customers. Common practices have included safety related 8

activities such as leak surveys, leak repairs, infrastructure replacements and 9

upgrades. Because of these activities, our customers have not faced a significant 10

number of distribution related outages for many years. For example, from April 11

2010 through 2014, CenterPoint Energy has had fewer than 160 hours of system 12

integrity unplanned outages on isolated areas of our system out of a total of 13

41,600 hours of operation. 14

15

Q. While the work to modernize CenterPoint Energy’s distribution system has been 16

done routinely for many years, what changes have taken place that have caused 17

an acceleration of these replacements and upgrades? 18

A. As discussed by Company witness Centers, recent continuing state and federal 19

pipeline safety and integrity efforts have placed increasing requirements on 20

operators like CenterPoint Energy to more formally identify threats, rank them and 21

then execute risk mitigation plans. These efforts are leading to accelerated 22

replacements and upgrades on our system, compared to our history. 23


11

Q. What type of capital expenditures does CenterPoint Energy make in Minnesota? 1

A. We routinely make capital expenditures in distribution facilities to serve new 2

customers, replace or reinforce the system and relocate distribution facilities due 3

to public improvements. Additionally, we invest in communications and computer 4

assets, vehicles and other general equipment and in our supplemental plant 5

(storage and peaking facilities). 6

7

Q. Historically how much have these expenditures in Minnesota been on an annual 8

basis? 9

A. For the ten years of 2002 through 2011, CenterPoint Energy’s capital 10

expenditures averaged $65 million annually in Minnesota. 11

12

Q. Between now and 2021, do you expect the capital expenditures made by the 13

Company to look different than in the past? 14

A. Yes, based on the information currently available to us, we expect that the 15

Company’s level of capital expenditures in Minnesota will approximate $200 16

million per year through 2021. 17

18

Q. What are the main reasons for this level of capital expenditures? 19

A. As Mr. Centers discusses in detail, the Company will invest significant capital in its 20

safety and integrity management efforts. 21


12

• In addition, we are experiencing significant activity regarding public 1

improvements by local governments that require us to protect and, at times 2

relocate, our distribution facilitates. 3

4

Q. In addition to its safety and reliability efforts, is CenterPoint Energy making 5

changes to its facilities? 6

A. Yes. Recently, the Company moved its headquarters in downtown Minneapolis to 7

505 Nicollet Mall. We are also in the process of building a new warehouse to 8

support our Minnesota Operations. 9

10

Q. Why did CenterPoint Energy relocate its headquarters? 11

A. The lease on the Company’s LaSalle headquarters is set to expire in 2016. This 12

lease rate is well below current market rates, meaning the Company faced the 13

possibility of markedly higher lease rates going forward. To address this issue the 14

Company explored alternatives to the LaSalle headquarters. During this 15

exploration, in addition to focusing on costs, the Company sought facilities that 16

could: accommodate our need for approximately 100,000 square feet of space; 17

recognize and demonstrate our long term commitment to the City of Minneapolis in 18

supporting its downtown; offer access to public transportation for our employees. 19

Opportunities to purchase a facility that meets our needs in downtown Minneapolis 20

are not frequent. However, one became available on Nicollet Mall. Ultimately, we 21

determined that the purchase of the Nicollet Mall site best fit our long-term needs 22

based on costs, size and location. 23


13

Q. Please explain the need for the new warehouse. 1

A. The need for the new warehouse is driven by capacity constraints and the aging of 2

our existing facilities. The new warehouse facility will increase our warehouse 3

capacity by over 25% and will consolidate all warehouse operations into one. 4

5

Q. Does CenterPoint Energy sponsor witnesses on these matters? 6

A. Yes, Mr. Centers will address the needs for capital investments and safety 7

requirements and Mr. Nesvig supports CenterPoint Energy’s overall capital 8

expenditures in Minnesota, including those for public improvements and facilities. 9

10

Q. Are there positive ramifications flowing from the increased level of the Company’s 11

safety and integrity management expenditures in Minnesota? 12

A. Yes. First and foremost, our customers will continue to realize the benefits of a 13

safe and reliable distribution system. Additionally, the projects lead to jobs and the 14

increased economic activity associated with those jobs. Our best estimate is that, 15

between CenterPoint Energy employees and contractors, there will be 16

approximately 600 people working on the Company’s safety and integrity 17

management projects. Most of these jobs are union jobs. Additionally, the 18

communities we serve will realize additional property tax revenues. 19

20

Q. What is the challenging aspect of the increased level of the Company’s Capital 21

Expenditures in Minnesota? 22


14

A. Since the majority of our capital expenditures in Minnesota will not have new 1

customers directly associated with them, the Company will need to seek regular 2

rate relief. We currently estimate that our revenue requirement in the State will 3

increase, on average, approximately $25 million per year through 2021. 4

5

Q. Is the Company aware of the availability of Gas Utility Infrastructure and Multi-Year 6

rate plan recovery mechanisms as alternative to filing standard rate cases? 7

A. Yes. 8

9

Q. What is the Company’s policy regarding such mechanisms? 10

A. Conceptually speaking, CenterPoint Energy supports the use of alternative 11

ratemaking mechanisms if those mechanisms can streamline the regulatory 12

process while fairly treating both ratepayers and the utility. While not everyone 13

may agree, we do think there is a degree of “rate case fatigue” in the rate 14

regulatory community and such mechanisms have the potential to work well for a 15

company like CenterPoint Energy that is in the midst of reasonably predictable and 16

high greater capital expenditures. 17

18

Q. You state that such mechanisms could work. What is the Company’s perspective 19

of the current application of such mechanisms in Minnesota? 20

A. To date, our perspective is that the regulatory community has taken a cautious 21

approach in implementing such mechanisms and has not shown interest in 22

tailoring different mechanisms to fit utilities in different situations. As a result, each 23


15

mechanism has limitations. Additionally, these mechanisms appear to have a 1

higher degree of unpredictability, when compared to a traditional rate case – 2

particularly a case such as the current rate case where the principal “driver” is the 3

Company’s investments in safety and reliability measures. As a result, until 4

broader consensus develops on alternative ratemaking mechanisms, we have 5

determined that filing rate cases best positions us to meet our fiduciary 6

responsibilities. 7

8

CenterPoint Energy’s Rate Design Plan 9

Q. Does the Company propose new monthly basic charges as part of its rate design 10

plan in this proceeding? 11

A. Yes. Mr. Drews addresses this issue in his testimony and supportive information 12

is provided by witnesses Feingold and Troxle. 13

14

Q. Why is the Company proposing to increase the monthly basic charges even 15

though the Company’s RD Rider full decoupling mechanism became effective July 16

1 of this year? 17

A. First, it is important to remember that the RD Rider will be in place as a three-year 18

pilot. CenterPoint Energy is very optimistic that the RD Rider can become 19

permanent after pilot expires. However, in the event that the Rider does not 20

become permanent, the Company proposes a modest increase in the monthly 21

basic charges for sales customers. This slightly higher monthly charge will 22

maintain the ratio of basic charge revenues to non-gas revenue, excluding CIP 23


16

and GAP revenues, resulting from the final rates authorized in CenterPoint 1

Energy’s 2013 rate case. Mr. Drews addresses these matters more thoroughly in 2

his testimony. 3

4

IV. INTERIM REVENUE DEFICIENCY AND RATES 5

Q. Has CenterPoint Energy petitioned the Commission for interim rates pending a 6

final decision in this filing? 7

A. Yes. A Petition for Interim Rates is included with this filing. The Petition seeks an 8

interim revenue increase of approximately $47.8 million or 5.65 percent, to be 9

effective with service rendered on and after October 2, 2015. The proposed interim 10

increase of 5.65 percent applies to all rate classes on a uniform basis consistent 11

with the existing rate design. Supporting schedules, workpapers, notices and other 12

required information is included with the Petition for Interim Rates. 13

14

V. COMPLIANCE INFORMATION 15

Q. Mr. Vortherms, please discuss how CenterPoint Energy has ensured this filing is in 16

compliance with all applicable regulatory requirements? 17

A. As in our 2015 general rate change filing, CenterPoint Energy has systematically 18

identified each requirement, assigned responsibility for completing the 19

requirement, and verified through proofing and cross-checking that the information 20

provided meets the requirements. 21

22

Q. Please list where each of those required items can be found in this filing. 23


17

A. Exhibit_____(JJV-D), Schedule 3, provides a listing of all applicable regulatory 1

requirements for this filing and the location in the filing where each compliance 2

item may be found. 3

4

Q. Does this conclude your direct testimony? 5

A. Yes, it does. 6

Docket No. G-008/GR-15-424 Exhibit____(JJV-D)

Schedule 1

JOSEPH J. VORTHERMS

Division Vice President, Minnesota Regional Operations 505 Nicollet Mall, Minneapolis, Minnesota

CURRENT RESPONSIBILITIES (April 2012 – Present) Responsibilities include both gas utility operations in Minnesota and the Home Service Plus business, which together serve nearly 800,000 customers. PREVIOUS PROFESSIONAL EMPLOYMENT CenterPoint Energy

Director, HSP Sales & Marketing, Minneapolis, Minnesota 2006-2012

Director, HSP Workload Planning & Dispatch, Minneapolis, Minnesota 2004-2006

Director, Home Comfort Sales, Minneapolis, Minnesota 2002-2004

NorAm Consumer Services Director, Finance,

Minneapolis, Minnesota 1998-2002 Minnegasco Inc.

Director, Accounting & Tax, Minneapolis, Minnesota 1994-1998

Manager, Budget Reporting Credit & Tax, Minneapolis, Minnesota 1991-1994

Supervisor, Budget & Reporting, Minneapolis, Minnesota

Dayton Hudson Corp. 1988-1991 Sr. Analyst, Planning, Reporting & Analysis,

Minneapolis, Minnesota 1984-1988 Deloitte, Haskins & Sells

Auditor Minneapolis, Minnesota 1982-1984

EDUCATION Minnesota State University, Mankato,

Mankato, Minnesota Bachelor of Science Degree, Accounting & Finance 1982

CenterPoint Energy Docket No. G-008/GR-15-424Minnesota Exhibit________(JJV-D)

Schedule 2

CenterPoint EnergySummary of Revenue Requirements - Total Company

Test Year - Twelve Months Ending September 30, 2016($000s)

Test YearUsing

Line Description Existing RatesNo. (a) (b)

1 Average Net Rate Base $912,820

2 Operating Revenue $851,183

3 Operating Expense $810,427

4 Operating Income $40,756

5 Overall Rate of Return 4.46%(Line 4/Line 1)

6 Rate of Return Required 7.94%

7 Required Operating Income $72,478(Line 1 x Line 6)

8 Operating Income Deficiency $31,722(Line 7-Line 4)

9 Gross Revenue Conversion Factor 1.7056

10 Revenue Deficiency $54,106(Line 8 x Line 9)

Docket No. G-008/GR-15-424 Exhibit ___(JJV-D) Schedule 3, Page 1 of 17

CENTERPOINT ENERGY RESOURCES CORP., d/b/a

CENTERPOINT ENERGY MINNESOTA GAS COMPLIANCE REQUIREMENTS

Requirement Rule/Docket Reference

Compliance Location

Notice of Change in Rates. A utility filing for a general rate change shall include:

1) proposal for change in rates as prescribed in Minn. R. pt. 7825.3500;

2) modified rates as prescribed in Minn. R. pt. 7825.3600;

3) expert opinions and supporting exhibits as prescribed in Minn. R. pt 7825.3700;

4) informational requirements as prescribed in Minn. R. pts. 7825.3800 to 7825.4400; and

5) 5) statement indicating the method of insuring the payment of refunds as prescribed in part 7825.3300.

Minn. R. 7825.3200. Volumes 1 and 2 (see below for specific requirements and locations).

Methods and Procedures for Refunding. Refund Agreement signed by authorized official of the utility to refund any portion of the increase in rates determined to be unreasonable together with interest thereon.

Minn. R. 7825.3300. Volume 1 after Notice of Change in Rates under Notice of Change in Rates tab.

Proposal for Change in Rates. The utility’s proposal for a change in rates shall summarize the notice of change in rates and shall include the following:

A. name, address, and telephone number of the utility without abbreviation and then name and address and telephone number of the attorney for the utility;

B. date of filing and date modified rates are effective;

C. description and purpose of the change in rates requested;

D. effect of the change in rates expressed in gross revenue dollars and as a percentage of test year gross revenue; and

E. signature and title of utility officer authorizing the proposal.

Minn. R. 7825.3500. Volume 1 after Summary of Filing under Notice of Change in Rates tab.

Modified Rates. All proposed changes in rates shall be shown by filing revised or new pages to the rate book previously filed with the Commission and by identifying those pages which were not changed. Each revised or new page of the rate book shall contain the information required for each page of the rate book and shall be in a format consistent with the currently filed rate book. In addition, each revised page shall contain the revision number and the page number of revised page.

Minn. R. 7825.3600. Revised tariffs included in Volume 1 under Proposed Tariff tab.



Compliance Location

Expert Opinions and Supporting Exhibits. Expert opinions and supporting exhibits shall include written statements, in question and answer format, together with supporting exhibits of utility personnel and other expert witnesses as deemed appropriate by the utility in support of the proposal. At a minimum, expert opinions shall include a statement by the chief executive officer or other designated official in support of the proposal.

Minn. R. 7825.3700. Direct testimony in question and answer format, together with supporting exhibits are included in Volume 2. Additional support also included in corresponding workpaper volumes. Direct testimony of Mr. Joseph J. Vortherms, Division Vice President of Regional Operations included in Volume 2.

Scope. As a part of the utility's notice of a change in rates, iInformation requirements parts 7825.3900, 7825.4000, item A; 7825.4100, item A; 7825.4200, item A; and 7825.4300, items A and B shall be supplied and all other information requirements prescribed by parts 7825.3800 to 7825.4400 shall be supplied where applicable to the utility.

Minn. R. 7825.3800 Volumes 1 and 2 (see the details in this matrix for specific requirements and locations).

Jurisdictional Financial Summary Schedule(s). A. The proposed rate base, operating income,

overall rate of return, and the calculation of income requirements, income deficiency, and revenue requirements for the test year.

B. The actual unadjusted average rate base consisting of the same components as the proposed rate base, unadjusted operating income, overall rate of return, and the calculation of income requirements, income deficiency, and revenue requirements for the most recent fiscal year.

C. The projected unadjusted average rate base consisting of the same components as the proposed rate base, unadjusted operating income under present rates, overall rate of return, and the calculation of income requirements, income deficiency, and revenue requirements for the projected fiscal year.

Minn. R. 7825.3900. Volume 1 – Schedule A-1.

https://www.revisor.mn.gov/rules/?id=7825.3900









Compliance Location

Rate Base Schedules. A. Rate base summary schedule by major rate

base component showing the proposed rate base, the unadjusted average rate base for the most recent fiscal year and unadjusted average rate base for the projected fiscal year. The totals for this schedule shall agree with the rate base amounts included in the financial summary.

B. A comparison of total utility and Minnesota jurisdictional rate base amounts by detailed rate base component showing:

1) total utility and the proposed jurisdictional rate base amounts for the test year including the adjustments, if any, used in determining the proposed rate base,

2) the unadjusted average total utility and jurisdictional rate base amounts for the most recent fiscal year and the projected fiscal year.

C. Adjustment schedules showing the title, purpose, description and the summary calculations of each adjustment used in determining the proposed jurisdictional rate base.

D. A summary by rate base component of the assumptions made and the approaches used in determining average unadjusted rate base for the projected fiscal year. Such assumptions shall be identified and quantified into two categories – know and measurable changes from the most recent fiscal year and projected changes.

Minn. R. 7825.4000. Volume 1 – Schedule B-1. Volume 1 – Schedules B-2(a), B-2(b) and B-2(c). Total utility and Minnesota jurisdictional amounts are the same amount for all three 12-month periods required. Proposed adjustments are included in Mr. Nesvig’s testimony, exhibits and workpapers. Test Year adjustments are discussed and documented in his testimony. A table of contents for the location of specific summary schedules of rate base items can be found in his workpaper, Exhibit ___ (KRN-WP), Vol. 2, Schedule 38, pages 1-2), workpaper 1. A summary by rate base component of the assumptions made and approaches used can be found in Mr. Nesvig’s workpaper, Exhibit ___ (KRN-WP), Vol. 2, Schedule 27, Workpaper 1. Additional detail of the projected fiscal year rate base assumptions and approaches are included in Vol. 1 – Schedule B-3 and B-4, discussed and documented in Mr. Nesvig’s testimony, schedules and workpapers.



Compliance Location

Operating Income Schedules. A. Summary schedule of jurisdictional operating

income statements which reflect proposed test year operating income, and unadjusted jurisdictional operating income for the most recent fiscal year and the projected fiscal year calculated using present rates.

C. For investor-owned utilities only, a summary schedule showing the computation of total utility and allocated Minnesota jurisdictional federal and state income tax expense and deferred income taxes for the test year, and the most recent fiscal year, and the projected fiscal year. This summary schedule shall be supported by a detailed schedule, showing the development of the combined federal and state income tax rates.

D. A summary schedule of adjustments to jurisdictional test year operating income and detailed schedules for each adjustment providing an adjustment title, purpose and description of the adjustment, and summary calculations.

E. A schedule summarizing the assumptions made and the approaches used in projecting each major element of operating income. Such assumptions and approaches shall be identified and quantified into two categories: known changes from the most recent fiscal year and projected changes.

Minn. R. 7825.4100. Volume 1 – Schedules C-1 and C-2. Volume 1- Schedule C-3. Total utility and Minnesota jurisdictional amounts are now the same amount for all three 12-month periods required. Summary schedule of adjustments to operating income can be found in Mr. Nesvig’s Exhibit ___ (KRN-WP), Vol. 1, Schedules 2, 3 & 4. Detailed Test Year adjustments are discussed and documented in Mr. Nesvig’s testimony and workpapers. A schedule summarizing assumptions made and the approaches used in projecting operating income can be found in Mr. Nesvig’s workpaper, Exhibit ___ (KRN-WP), Vol. 2, Schedule 26, pages 1 - 5, workpaper 1. Additional detail on the approaches used to develop operating income included in Volume 1 – Schedules C-4 and C-5. Identification and quantification of each of the changes from the most recent fiscal year is found in Mr. Nesvig’s testimony.



Compliance Location

Rates of Return Cost of Capital Schedules. A. A rate of return cost of capital summary

schedule showing the calculation of the weighted cost of capital using the proposed capital structure and the average capital structures for the most recent fiscal year and projected fiscal year. This information shall be provided for the unconsolidated parent and subsidiary.

B. Supporting schedules showing the calculation of the embedded cost of long-term debt, and the embedded cost of preferred stock, at the end of the most recent fiscal year and projected fiscal year.

C. Schedule showing average short-term securities for the proposed test year, most recent fiscal year, and the projected fiscal year.

Minn. R. 7825.4200. Volume 1 – Schedule D-1. Weighted cost of capital is shown separately for CenterPoint Energy Resources Corp., d/b/a CenterPoint Energy Minnesota Gas, CenterPoint Energy Resources Corp. and CenterPoint Energy, Inc. for the three 12-month periods required. Volume 1 – Schedule D-2.

Rate Structure and Design Information A. A summary comparison of test year operating

revenue under present and proposed rates by customer class of service showing the difference in revenue and the percentage change.

B. A detailed comparison of test year operating revenue under present and proposed rates by type of charge including minimum, demand, energy by block, gross receipts, automatic adjustments, and other charge categories within each rate schedule and within each customer class of service.

C. A cost of service study by customer class of service showing revenues, costs, and profitability for each class of service, identifying the procedures and underlying rationale for cost and revenue allocations. Such study is appropriate whenever the utility proposes a change in rates which results in a material change in its rate structure.

Minn. R. 7825.4300. Volume 1-Schedule E-1 (a) and (b). Volume 1-Schedule E-2. Class cost of service studies are provided in Mr. Troxle’s testimony, Schedule 2 and workpapers 1, 6, 7 & 8.

Other Supplemental Information. A schedule showing the development of the gross revenue conversion factor.

A. Annual report to stockholders including financial statements and statistical supplements for the most recent fiscal year.

B. A schedule showing the development of the gross revenue conversion factor.

Minn. R. 7825.4400. Volume 1, Schedule G. Volume 1, Schedule F.



Compliance Location

Filing. Documents must be directed to the attention of the executive secretary.

Minn. R. 7829.0400, subp. 1.

Volume 1 in Cover Letter under Notice of Change of Rates tab.

Number of copies to be filed. Minn. R. 7829.0400, subp. 2 and January 31, 2001 letter from MPUC. Minn. Stat. §216.17, subd. 3.

Original E-filed to MPUC and DOC, plus additional paper copies as requested.

Proof of Service. Filings must be accompanied by proof of service on the persons on the appropriate service list.

Minn. R. 7829.0400, subp. 3.

Volume 1 after Notice of Change in Rates under Notice of Change in Rates tab.

Format. Filings must identify the nature of the filing as briefly as possible and indicate that the matter is before the Minnesota Public Utilities Commission. Filings must be on 8-1/2 x 11-inch paper, unless the executive secretary authorizes a non-conforming filing for good cause shown.

Minn. R. 7829.0400, subp. 4.

Volume 1 and 2 cover inserts and Cover Letter under Notice of Change in Rates tab. All pages are on 8-1/2 x 11-inch paper.

Summary. A utility filing a general rate case or other filing that requires determination of its gross revenue requirement shall include, on a separate page, a brief summary of the filing, sufficient to apprise potentially interested parties of its nature and general content.

Minn. R. 7829.2400, subp. 1.

Volume 1 after Cover Letter under Notice of Change in Rates tab.



Compliance Location

Service. A document filed with the Commission must be served the same day on the persons listed on the appropriate service list, except when this chapter permits service of a summary of the filing. Service may be accomplished by first class mail or by delivery in person, unless otherwise provided by law or Commission order. Service on the DOC is complete upon receipt by the DOC. For all other persons, service by mail or FAX transmission plus mail is complete upon mailing, unless the executive secretary directs otherwise for specific documents. When a party or participant is represented by an attorney, service upon the attorney is considered service upon the party or participant. As of January 1, 2008, any telephone company or telecommunications carrier subject to chapter 237; any public utility, cooperative association, or municipal utility subject to chapter 216B; and state agencies, shall file documents with the commission via the commission's electronic filing system. The executive secretary may approve an exemption from this requirement if an affected company or agency is unable to submit filings via the commission's electronic filing system. All parties, participants, or other interested persons shall submit filings to the commission via the commission's electronic filing system whenever practicable, but may also file by personal delivery or by mail. A utility filing a general rate change request shall serve copies of the filing on the Department and Residential Utilities Division of the Office of the Attorney General. The utility shall serve the filing or the summary of the filing on the persons on the applicable general service list and persons who were parties to its last general rate case or incentive plan proceeding.

Minn. R. 7829.0400, subp. 5. Minn. Stat. §216.17, subd. 3. Minn. R. 7829.2400, subp. 2.

Service made by E-Filing to the MPUC and DOC; delivery in person to the OAG-RUD. Summary of the filing is served on all other persons via U.S. mail.

Establishing List. The utility shall maintain general service lists of persons who have filed these requests (a written list of the types of filing they wish to receive). The utility shall add to each list the persons who intervened in its last general rate case and persons on the official service list for its last filing of the same type.

Minn. R. 7829.0600, subp. 1.

The general service list is included in Volume 1 after the Notice of Change in Rates under the Notice of Change in Rates tab.



Compliance Location

Trade Secret and Proprietary Information. Persons filing documents containing proprietary information, trade secrets, or other privileged information shall excise this information in the public copies.

Minn. R. 7829.0500, subp. 2 and January 31, 2001 letter from MPUC.

Non-Public and Public versions E-filed to MPUC and DOC. Three copies of Non-Public hand-delivered to OAG. All other persons receive a Summary of the filing via U.S. Mail.

Document containing protected information. The first page or cover page of a document containing protected information must be clearly marked in bold print “TRADE SECRET INFORMATION – NOT FOR PUBLIC DISCLOSURE” or words of similar import. Every page on which protected information appears must be similarly marked and the protected information must be underlined, placed in brackets, or other clearly identified as the information which is to be protect from disclosure.

Minn. R. 7829.0500, subp. 4 and January 31, 2001 letter from MPUC.

Non-Public and Public versions identified on cover insert and on each page. All protected information is clearly marked.

Notice to Public and Governing Bodies. A utility seeking a general rate change shall give notice of the proposed change to the governing body of each municipality and county in its service area and to its ratepayers. The utility shall also publish notice of the proposed change in newspapers of general circulation in all county seats in its service areas.

Minn. R. 7829.2400, subp. 3.

All required notices are included in Volume 1 under Proposed Notices tab.

Notice of Hearing. The utility shall notify its ratepayers of hearings held in connection with its rate change request in the manner directed by the Commission. The utility shall publish notice of hearings on its rate change request in newspapers of general circulation in all county seats in its service area, as directed by the Commission.

Minn. R. 7829.2400, subp. 7.

Public Hearing Notices to customers are typically included in the customer bill. The official notice to be published will be subsequently provided to the MPUC under separate cover.



Compliance Location

(a) … a public utility filing a general rate case petition shall include a schedule separately itemizing all travel, entertainment, and related employee expenses as specified by the commission, including but not limited to the following categories:

1) travel and lodging expenses; 2) food and beverage expenses; 3) recreational and entertainment expenses; 4) board of director-related expenses, including

and separately itemizing all compensation and expense reimbursements;

5) expenses for the ten highest paid officers and employees, including and separately itemizing all compensation and expense reimbursements;

6) dues and expenses for memberships in organizations or clubs;

7) gift expenses; 8) expenses related to owned, leased, or

chartered aircraft; and 9) lobbying expenses.

(b) To comply with the requirements of paragraph (a), each applicable expense incurred in the most recently completed fiscal year must be itemized separately, and each itemization must include the date of the expense, the amount of the expense, the vendor name, and the business purpose of the expense. For expenses identified in response to paragraph (a), clauses (1) and (2), the utility shall disclose the total amounts for each expense category and provide separate itemization for those expenses incurred by or on behalf of any employee at the level of vice president or higher and for board members. The petitioning utility shall also provide a one-page summary of the total amounts for each expense category included in the petitioning utility’s test year.

Minn. Stat. § 216B.16, subd. 17; Travel, Entertainment and Related Employee Expenses.

Testimony of Mr. Nesvig, starting at page 35 line 11 and Exhibit ___ (KRN-D), Schedule 28, and Exhibit ___ (KRN-WP), Vol. 3, Schedule 55 workpapers 1-18.

Be prepared to demonstrate in future rate cases that we follow the cost allocation principles recommended by the Commission, or that our non-regulated activities are insignificant, or that our cost allocation principles produce similar results as would allocations following the recommended cost allocation principles, or that the public interest is better served by another method.

March 1, 1995 Order Finding Compliance, exempting northwestern Wisconsin, requiring preparation and closing docket. Docket G,E-999/CI-90-1008

Testimony of Mr. Nesvig, starting at page 114 line 1 and Exhibit ___ (KRN-WP), Vol. 2, Schedule 54, Workpapers 1-28.



Compliance Location

Service Extension Information Respond to six questions raised by the PUC regarding service extension policy and practice. Respond to three concerns raised about the impact of service extension-related additions on a company’s rate base.

March 31, 1995 Order-Inquiry into Competition Between Gas Utilities in Minnesota. Docket G-999/C1-90-563

Testimony of Mr. Nesvig,, starting at page 125, line 11. Testimony of Mr. Nesvig, starting at page 129, line 16.

Minnegasco will not seek recovery of any transaction costs related to the merger. Minnegasco will not seek recovery of any severance costs related to the merger, which are defined as severance costs incurred within twelve months of the closing of the merger and those severance costs incurred for the top 87 NorAm employees.

January 23, 1997 Stipulation [CenterPoint Energy Minnesota Gas]. Docket G-008/PA-96-950

As discussed in KRN testimony in docket G008/GR-08-1075 (Direct testimony page 127-128), this issue is no longer relevant. As indicated in that case, we do not intend to continue providing this information unless parties or the Commission believed it was still necessary. Neither parties nor the Commission indicated a desire to continue receiving this information in our Initial Filing. Therefore, we are not including testimony on this issue in this rate case.

Advertising: Statement that recovery is requested only for permitted advertisements. Description of advertisements for which recovery is requested. Sample advertisements for which recovery is requested.

Policy Statement Dated June 14, 1982

Testimony of Mr. Nesvig, starting at page 54 line 23 and Exhibit ___ (KRN-WP), Vol. 2, Schedule 32, workpapers 1-4 and Exhibit ___ (KRN-WP), Vol. 2, Schedule 33, workpaper 1.

Cash Working Capital: Lead/lag study with: 1) lead time divided into service to meter reading; meter reading to billing; and billing to collection; and 2) lag expenses divided in categories such as fuel, purchased power, labor.


Testimony of Mr. Nesvig, starting at page 117 line 23 and Exhibit ___ (KRN-WP), Vol. 2, Schedule 38, workpaper 2, starting at page 32 line 5.



Compliance Location

Charitable Contributions: Evidence as to whether the recipients of the contributions: serve the utility’s Minnesota service area; are nondiscriminatory in selecting recipients; and do not promote political or special interest groups. Evidence as to what organizations are gifted, their activities, and that no part of the contribution goes to benefit any private stockholder or individual. Itemized schedule showing amount, recipient and time of donations. Only 50% of qualified contributions shall be allowed as operating expenses.


Testimony of Mr. Nesvig, starting at page 27 line 19 and Exhibit ___ (KRN-WP), Vol. 1, Schedule 13, workpaper 4.

Organizational Dues: Schedule showing each organization being paid, the number of employees belonging to each organization and the dollar amount of dues being paid to each organization. Testimony explaining the primary purpose of each organization.


Testimony of Mr. Nesvig, starting at page 14 line 16 and Exhibit ___ (KRN-WP), Vol. 1, Schedule 12, workpapers 5-8.

Research Expenses: Description of each research activity for which an expense is claimed, with all expenses for each activity itemized and supported.





Compliance Location

Interim Rates: Name, address and telephone number of utility and attorneys. Date of filing and date proposed interim rates are requested to become effective. Description and need for interim rates. Description and corresponding dollar amount change included in interim rates as compared with most current approved general rate case and with the most recent year for which audited data is available. Effect of the interim rates expressed in gross revenue dollars as a percentage of test year gross revenues. Certification by officer of the utility. Signature and title of the utility officer authorizing the proposed interim rates. Methods and procedures for refunding. Supporting schedules and workpapers. Modified tariffs. Notices.


Volume 1 Interim Rate Petition.

Minnegasco shall provide documentation that Minnegasco customers are indemnified from potential Reliant Resources, Inc. (RRI) liabilities such as refunds and penalties associated with, for example, a) electric and/or natural gas trading irregularities, b) investigations of California and Western market price investigations, and c) shareholders and class-action lawsuits pending against RRI. Minnegasco shall ensure that such legal or financing costs associated with RRI’s numerous pending legal issues will not be borne by Minnesota ratepayers either now or in a future rate case.

April 8, 2003 Order – Inquiry into Possible Effects of the Financial Difficulties at Reliant Energy, Inc. on Reliant Energy Minnegasco and its Customers. Docket G-008/CI-02-1368

As discussed in testimony in docket G008/GR-13-316 (JJV-D pages 25-26), this issue is no longer relevant. As indicated in that case, we do not intend to continue providing this information unless parties or the Commission believed it was still necessary. Neither parties nor the Commission indicated a desire to continue receiving this information in our Initial Filing. Therefore, we are not including testimony on this issue in this rate case.



Compliance Location

16. In future rate case filings, the Company shall take the actions set forth below:

A. Meet with the DOC, and any other interested parties, prior to the preparation of its next rate case to discuss its billing cycle data and determine which data stream is appropriate to use in its test-year forecast for that rate case and in future rate case proceedings, and to file in a compliance tiling a report as to how these issues are resolved on a going-forward basis.

B. Prepare, and provide in/future initial rate case filings, a spreadsheet which calculates present and proposed revenue based on the sales forecast, numbers of customers, present, and proposed rates:

C. File any, and all, data for its sales forecast in advance of its next general rate case. The data should be filed 30 days in advance of the Company’s next general rate case filing.

D. Meet with the DOC and any other interested parties to resolve the following issues:

1) verification of CenterPoint’s process that the Company uses to calculate the input data it uses in its test-year sales analysis;

2) if, in the future, CenterPoint updates, modifies, or changes its billing system, verification of the link between the old and new billing systems and validation that there is no difference between the two billing systems; and

3) retention of all information related to CenterPoint’s billing cycle sales, cancellations/ rebills, customer bills, and weather data (adjusted for billing errors) to allow for independent verification of any and all, data used by CenterPoint and to independently analyze the reasonableness of CenterPoint’s test-year sales.

January 11, 2010 Findings of Fact, Conclusions of Law, and Order. Docket G-008/GR-08-1075

Testimony of Mr. Fitzpatrick, starting at page 4 line 7. Testimony of Mr. Fitzpatrick, starting at page 4 line 18. Testimony of Mr. Fitzpatrick, starting at page 5 line 16. Testimony of Mr. Fitzpatrick, starting at page 4 line 7 and Exhibit___ GLF-D Sch 14.

11. The Company shall track rate recovery of the rate case expenses authorized for recovery in this case for refund of any over-recovery in the next rate case. That refund shall include interest at the overall rate of return approved in this case.

June 9, 2014 Findings of Fact, Conclusions, and Order Docket G-008/GR-13-316




Compliance Location

13. The Company shall refund to customers all incentive compensation amounts approved by the Commission and included in base rates, but not paid to employees. The Company shall file an annual report within 30 days from the date incentive compensation is normally scheduled for payout.



16. In its next rate case, the Company shall discuss its approach to inter-jurisdictional cost allocation and the underlying jurisdictional cost allocation factors, as applied to the base year amount and as applied to test year adjustments, in the development of its test year revenue requirement.


Testimony of Mr. Nesvig, starting at page 114 line 14.

17. In its next rate case, the Company shall identify and explain any changes it has made to its jurisdictional cost allocation factors and any changes in how those factors are used during the course of the next rate case proceeding.



18. In its next rate case, the Company shall present in the public summary schedules the allocation of revenue responsibility for each customer class that is listed in its tariff and not combine customer classes together when presenting its summary of the proposed revenue allocation.


Volume 1 – Schedule E-2.

19. In its next rate case, the Company shall provide additional information on curtailments and its curtailment forecasting methodology, as recommended by the Department and agreed to by the Company.


Testimony of Mr. Fitzpatrick, starting at page 20 line 19.

20. In its next rate case, the Company shall substantiate its forecasting methodology in regard to curtailments and weather-normalized sales, as recommended by the Department and agreed to by the Company.


Testimony of Mr. Fitzpatrick, starting at page 20 line 1.

21. In its next rate case, the Company shall, in consultation with the Department, provide a comprehensive examination of the predictive power, volatility, and impact on test year and future revenues of using 10-year, 15-year, and 20-year weather data in the forecast.


Testimony of Dr. Livezey, starting at page 14 line 16; Testimony of Mr. Brown starting at page 4 line 6; Testimony of Mr. Fitzpatrick starting at page 4 line 2; and Workpapers of Mr. Nesvig and Exhibit ___ (KRN-WP), Vol. 3, Schedules 58, 59 and 60.



Compliance Location

22. In its next rate case, the Company shall file a minimum system study based on a one-inch and a zero-inch pipe, in addition to a two-inch pipe.


Testimony of Mr. Troxle, starting at page 3 line 12 and Testimony of Mr. Feingold starting at page 4 line 6.

23. In its next rate case the Company’s class cost of service study shall include an explanatory filing identifying and describing each allocation method used in the study and detailing the reasons for concluding that each allocation method is appropriate and superior to other allocation methods considered by the Company, whether those methods are based on the Gas Distribution Rate Design Manual of the National Association of Regulatory Utility Commissioners or the Company’s specific system requirements, its experience, and its engineering and operating characteristics. The Company shall also explain its reasoning in cases in which it did not consider alternative methods of allocation or classification.


Testimony of Mr. Troxle, starting at page 12 line 12 and Exhibit ___ (MAT-WP), workpaper 2.

24. In the initial filing of its next rate case, the Company shall provide descriptive information relating to travel, entertainment, and related employee expenses under Minn. Stat. § 216B.16, subd. 17. To ensure that future schedules contain the required information, the Company shall develop a proposal to resolve current insufficiencies and present the proposal to the OAG and the Department in advance of its next rate case filing.


Testimony of Mr. Nesvig, starting at page 36 line 1 and Exhibit ___ (KRN-WP), Vol. 3, Schedule 52, workpaper 9 page 6.

25. In the initial filing in its next rate case, the Company shall address in detail the reasonableness of allocating capacity-related costs to ICCC customers along with a discussion of each capacity-related cost that is avoided due to the ICCC customers taking interruptible service and each capacity related-cost that would be incurred if an ICCC customer switched to firm service.


Testimony of Mr. Troxle, starting at page 45 line 7.

26. In future rate cases, if the Company proposes an interim rate refund adjustment as a result of a Reconnection Fee increase, the Company shall calculate and disclose its proposed adjustment amount at the time it proposes the adjustment.


Not applicable – no adjustment to Reconnection Fees is proposed.



Compliance Location

27. In its initial filing in future rate cases, the Company shall discuss and explain sales and margin changes for each of its liquefied natural gas contracts.


Testimony of Mr. Nesvig, starting at page 33 line 11 and Exhibit ___ (KRN-WP), Vol. 3, Schedule 52, workpaper 6 pages 6-7 and Exhibit ___ (KRN-WP), Vol. 3, Schedule 52, workpaper 6a pages 1-5.

28. In future rate case filings the Company shall separately report the amount of capitalized jurisdictional pension cost, rather than combining that cost with non-regulated pension cost.


Exhibit ___ (KRN-WP), Vol. 1, Schedule 19, workpaper 15 page 1.

2. CenterPoint Energy shall make the following filings under the time lines indicated below: … b. A depreciation certification petition 60 days prior to any general rate case filing prior to July 15, 2019 if CenterPoint projects significant depreciation rate changes; and c. An explanation in its next rate case explaining why a depreciation filing was not necessary, if such is the case;

November 20, 2014 Order Docket G-008/D-14-599

Testimony of Mr. Nesvig, starting at page 14 line 11.

Required the Company to file in its next general rate case Direct Testimony showing the monthly financial impact to ratepayers in dollar amounts to CenterPoint Energy related to the corporate allocations in the proposed MSA from the time of its implementation. The Direct Testimony should also provide any anticipated savings going forward and impact on the rate case.

June 22, 2015 Order Docket G008/AI-15-50

Testimony of Mr. Nesvig, starting at page 55 line 22 and Exhibit ___ (KRN-WP), Vol. 1, Schedule 17, workpaper 5 page 1.

Required CenterPoint to terminate CenterPoint Energy’s Insurance Recovery Account tracker. Required CenterPoint to apply all of the insurance proceeds for environmental remediation to offset a recent payment to a specific customer from the tracker account, as identified in the non-public record. Required CenterPoint to file Direct Testimony on this issue in its upcoming rate case.

July 10, 2015 Order Docket G008/GR-08-1075 and Docket G008/M-95-292



ADDITIONAL DATA SUPPLIED Concerning jurisdictional allocation and corporate cost information:

• An explanation of the allocation methodologies used to charge such costs to each business unit.

• The underlying support for developing the

allocation percentages used to charge such costs to each business unit; and

• The direct and allocated costs charged to each business unit by cost center.

September 7, 2004 Order. Docket G-008/GR-04-901

See Mr. Nesvig’s workpapers, Exhibit ___ (KRN-WP), Vol. 3, Schedule 57, workpapers 3 & 5. See Mr. Nesvig’s workpapers, Exhibit ___ (KRN-WP), Vol. 3, Schedule 57, workpapers 5 - 14. See Mr. Nesvig’s workpapers, Exhibit ___ (KRN-WP), Vol. 3, Schedule 57, workpapers 3 and 4.

For the most recent fiscal year, the projected fiscal year and the 12 months ended 12/31/09 a comparison by major categories of CenterPoint Energy Resources Corp., d/b/a Minnegasco’ rate base, operating income and income taxes to those at CenterPoint Energy, Inc. and CenterPoint Energy Resources Corp.


See Mr. Nesvig’s workpapers, Exhibit ___ (KRN-WP), Vol. 3, Schedule 56, workpapers 1 - 4.

Rate base bridge schedule and information on assumptions and approaches used in determining average rate base.


See Mr. Nesvig’s workpapers, Exhibit ___ (KRN-WP), Vol. 2, Schedule 49, workpapers 1-3.