1 Application No:
Exhibit No.:
2 Witness:
A.08-02-001
S. Nasim Ahmed
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In the Matter of the Application of San Diego Gas & )
Electric Company (U 902 G) and Southern California )
Gas Company (U 904 G) for Authority to Revise
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Their Rates Effective January 1, 2009, in Their
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Biennial Cost Allocation Proceeding.
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A.08-02-001
(Filed February 4, 2008)
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PREPARED DIRECT TESTIMONY
OF S. NASIM AHMED
SOUTHERN CALIFORNIA GAS COMPANY
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BEFORE THE PUBLIC UTILITIES COMMISSION
OF THE STATE OF CALIFORNIA
December 5, 2008
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TABLE OF CONTENTS
Page
2
3 I.
Qualifications ............................................................................................................. 1
4 II.
Purpose ....................................................................................................................... 1
5 III.
Summary .................................................................................................................... 1
6 IV.
Forecast Of Regulatory Account Balances As Of December 31, 2008 ..................... 3
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B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
M.
N.
O.
P.
Q.
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V.
Affiliate Transfer Fee Account (ATFA) ........................................................... 3
Blythe Operational Flow Requirement Memorandum Account (BOFRMA) .. 3
Core Fixed Cost Account (CFCA) ................................................................... 4
Economic Practicality Shortfall Memorandum Account (EPSMA) ................ 5
Enhanced Oil Recovery Account (EORA) ....................................................... 5
FERC Settlement Proceeds Memorandum Account (FSPMA)........................ 6
Firm Access and Storage Rights Memorandum Account (FASRMA) ............ 6
Gain / Loss on Sale Memorandum Account (GLOSMA) ................................ 6
Hazardous Substance Cost Recovery Account (HSCRA)................................ 7
Integrated Transmission Balancing Account (ITBA)....................................... 7
Intervenor Awards Memorandum Account (IAMA) ....................................... 9
Montebello True-Up Tracking Account (MTTA) ............................................ 9
Noncore Fixed Cost Account (NFCA) ............................................................. 9
Noncore Storage Balancing Account (NSBA) ............................................... 10
Noncore Storage Memorandum Account (NSMA) ........................................ 11
Research Royalty Memorandum Account (RRMA) ...................................... 12
Self-Generation Program Memorandum Account (SGPMA) ........................ 12
Proposed Elimination Of Regulatory Accounts ....................................................... 13
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Baseline Memorandum Account (BMA) ....................................................... 13
Brokerage Fee Account (BFA) ....................................................................... 13
Core Interstate Transition Cost Surcharge Account (CITCSA) ..................... 13
Cost of Service Revenue Requirement Memorandum Account (COSRRMA)14
El Paso Turned-Back Capacity Memorandum Account (EPTCBA) ............. 14
Gas Industry Restructuring Memorandum Account (GIRMA) ...................... 15
Late Payment Charge Memorandum Account (LPCMA) .............................. 15
Natural Gas Vehicle Account (NGVA) .......................................................... 15
NGV-RDD Memorandum Account (NGV-RDD) ......................................... 16
Noncore Fixed Cost Tracking Account (NFCTA) ......................................... 17
Noncore Interstate Transition Cost Surcharge Account (NITCSA) ............... 17
Research Development & Demonstration Expense Account (RDDEA) ....... 17
Wheeler Ridge Firm Access Charge Memorandum Account (WRFACMA) 18
G-PAL Memorandum Account (GPMA) ....................................................... 18
San Diego Gas & Electric Storage Memorandum Account (SDGESMA) .... 19
Long Beach Storage Memorandum Account (LBSMA) ................................ 19
Southwest Gas Storage Memorandum Account (SGSMA) ........................... 19
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1 VI.
Supplier Refunds ...................................................................................................... 20
2 VII. Other Regulatory Account Items ............................................................................. 21
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B.
Otay Mesa System Reliability Memorandum Account (OMSRMA) ............ 21
Company-Use Fuel for Load Balancing Account (CUFLBA) ....................... 21
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1
PREPARED DIRECT TESTIMONY
OF S. NASIM AHMED
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3 I.
Qualifications
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My name is S. Nasim Ahmed. I am employed by San Diego Gas & Electric Company
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5 (SDG&E). My business address is 555 West 5 Street, Los Angeles, California. I am the
6 Principal Business Analyst in the Regulatory Accounts group within the Regulatory Affairs
7 Department which supports the regulatory activities for Southern California Gas Company
8 (SoCalGas). I have held my current position since October 2002. My responsibilities for
9 SoCalGas’ regulatory balancing, tracking, and memorandum accounts include implementation of
10 regulatory accounting procedures for compliance with Commission decisions, quantifying and
11 recording the monthly entries and adjustments to the regulatory accounts, and preparing
12 forecasted balances for regulatory accounts for inclusion in SoCalGas’ annual compliance
13 filings.
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I received my Bachelor of Science degree in Accounting from California State
15 University, Long Beach in 1987. I began my employment at Pacific Lighting Corporation, then
16 the parent company of SoCalGas, in 1987 in the Internal Audit Department. I have held various
17 positions of increasing responsibility in Internal Audit, General Accounting, and Utility
18 Regulatory Accounting before assuming my current position.
19 II.
Purpose
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The purpose of my testimony is to (1) present the forecasts of the SoCalGas December
21 31, 2008 regulatory account balances to be incorporated into the Biennial Cost Allocation
22 Proceeding (BCAP) adopted rates, (2) describe the SoCalGas regulatory accounts that are
23 proposed to be eliminated as they are no longer required with any remaining or residual balance
24 to be transferred to other regulatory accounts, (3) propose a refund plan for supplier refunds
25 received by SoCalGas, and (4) address other items related to SoCalGas regulatory accounts.
26 III.
Summary
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The rates authorized in Decision (D.) 00-04-060, SoCalGas’ 1999 BCAP, became
28 effective June 1, 2000. As authorized by the Commission, SoCalGas subsequently filed annual
1 regulatory account updates by advice letter in October of each year, requesting authority to
2 incorporate estimated December 31 regulatory account balances into rates effective January 1 of
3 the following year. SoCalGas filed its latest annual regulatory account update by advice letter in
4 October 2007, requesting authority to incorporate estimated December 31, 2007 regulatory
5 account balances into rates effective January 1, 2008. The Commission granted such authority
6 on December 21, 2007.
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Section IV describes the forecasts and proposed changes to regulatory accounts. Section
8 V describes proposals for the elimination of regulatory accounts and the transfer or disposition of
9 any remaining balance in those accounts. Section VI describes the proposed refund plan for
10 supplier refunds received by SoCalGas. The last section of my testimony, Section VII, describes
11 other regulatory account-related items.
12
SoCalGas will file its annual regulatory account update by advice letter in October 2008
13 providing an update on the forecasted regulatory account balances as of December 31, 2008.
14 That regulatory account balance update will reflect the latest available information on the
15 regulatory account balances, including forecasts of other regulatory accounts established in other
16 proceedings (e.g., 2008 General Rate Case Application (A.) 06-12-010). That update of
17 regulatory account balances will supersede the forecast being provided herein in Section IV in
18 order to ensure that rates are based on forecasted regulatory account balances that reflect the
19 latest available information for incorporating into rates effective January 1, 2009.
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Consistent with existing authorized practices, SoCalGas will file its next annual
21 regulatory account balance update by advice letter in October 2009, requesting authority to
22 incorporate those balances into rates effective January 1, 2010. This will keep the updates of
23 SoCalGas’ regulatory account balances on an annual basis.
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The rate impact of the regulatory account balances is addressed in the testimony of Mr.
25 Lenart.
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As discussed in detail in the following section, the forecasted December 31, 2008
27 regulatory account balances are summarized in Table 1 and are based on recorded activity
28 through November 2007.
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1 IV.
Forecast Of Regulatory Account Balances As Of December 31, 2008
2
A.
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The ATFA was established by D.97-12-088 to record the transfer payment to SoCalGas
Affiliate Transfer Fee Account (ATFA)
4 from Sempra Energy when an employee moves from SoCalGas to a Sempra Energy affiliate.
5 The ATFA is forecast to be overcollected by $69,000 as of December 31, 2008 due to transfer
6 payments received in late 2007 not incorporated into rates effective January 1, 2008. Should
7 payments be made in December 2007 and in 2008, a revised forecast will be incorporated in the
8 October 2008 regulatory account balance update. SoCalGas proposes to include the ATFA
9 balance in rates to be amortized over a 12-month period beginning January 1, 2009.
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B.
Blythe Operational Flow Requirement Memorandum Account (BOFRMA)
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The Commission approved Advice Letter (AL) 3286 authorizing SoCalGas to establish
12 the BOFRMA to track certain costs associated with SoCalGas’ Gas Acquisition Department’s
13 purchase and delivery of gas to sustain operational flows at Blythe, thereby ensuring that gas is
14 delivered to customers connected to the southern portion of SoCalGas’ system. SoCalGas was
15 authorized to track costs in the BOFRMA until the earlier of August 31, 2006, the expiration date
16 of SoCalGas’ transportation agreement with the El Paso Natural Gas Company (El Paso), or until
17 a new procedure for supporting the Blythe minimum flow requirement is implemented by the
18 Commission. With SoCalGas entering into new transportation agreements with El Paso to take
19 effect after August 31, 2006, and with no new procedure by the Commission on the Blythe
20 minimum flow requirement, the Commission approved AL 3648 authorizing SoCalGas’ request
21 for a 12-month extension on the BOFRMA. The Commission approved AL 3733 further
22 extending the BOFRMA another 12 months through August 31, 2008.
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The BOFRMA is forecast to be $4.9 million undercollected as of December 31, 2008.
24 The undercollected balance is primarily due to minimum flows occurring at the Blythe receipt
25 point through November 2007. For costs incurred in December 2007 and in 2008, SoCalGas
26 will update the BOFRMA forecast. Although these costs are tracked in the BOFRMA as memo
27 entries (i.e., not recorded on SoCalGas’ financial statements), the costs were recorded in the
28 Purchased Gas Account (PGA) for recovery in procurement rates. SoCalGas proposes to include
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1 the forecasted BOFRMA balance in rates to be amortized over a 12-month period beginning
2 January 1, 2009. The undercollected BOFRMA balance will be amortized in transportation
3 rates; therefore, a corresponding credit will be made to the PGA.
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The proposal for the allocation of the BOFRMA undercollected balance in rates is
5 discussed in the testimony of Mr. Lenart.
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Pursuant to D.07-12-019, SoCalGas is authorized to establish a System Reliability
7 Memorandum Account (SRMA) to record costs related to minimum flow requirements for
8 SoCalGas’ entire system. As such, upon implementation of the SRMA, SoCalGas will cease
9 recording costs related to minimum flow requirements in the BOFRMA.
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C.
Core Fixed Cost Account (CFCA)
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The CFCA balances authorized margin, transition, and other non-gas fixed costs
12 allocated to the core market with revenues collected in rates intended to recover these costs. The
13 CFCA also includes administrative costs and uncollectible deferred billings associated with the
14 payment deferral plan pursuant to Resolution E-4065.
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The CFCA is forecast to be undercollected by $3.4 million as of December 31, 2008.
16 The forecasted undercollected balance is primarily due to higher gas prices for company-use fuel
17 and unaccounted-for (UAF) gas compared to the adopted cost of gas in the previous BCAP with
18 some offsets from throughput-related revenues. The forecasted undercollected balance includes
19 one supplier refund, the disposition of which is described in Section VI of my testimony.
20 SoCalGas proposes to include the CFCA balance in rates to be amortized over a 12-month period
21 beginning January 1, 2009.
22
Beginning in January 1, 2009, instead of recording 1/12 of the authorized margin on a
23 monthly basis in the CFCA, SoCalGas proposes to seasonalize the authorized margin based on
24 the proposed core demand forecast as described in the testimony of Mr. Emmrich. This change
25 will provide a more consistent comparison between revenues and costs recorded in the CFCA
26 similar to the authorized seasonality of revenues and costs recorded in the Noncore Fixed Cost
27 Account (NFCA). If the BCAP is delayed and not implemented in January 2009, then the CFCA
28 would record 1/12 of the authorized margin for the months prior to the implementation date and
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1 a seasonalized monthly margin for the months subsequent to the implementation date. This
2 would result in the CFCA recording an annual margin different from what is authorized.
3 Therefore, if the BCAP authorizes an implementation in a month subsequent to January,
4 SoCalGas proposes to implement seasonalizing the authorized margin at the beginning of the
5 subsequent year.
6
As described in Section V.H in my testimony, SoCalGas proposes to identify Natural Gas
7 Vehicle (NGV) customers as a sub-class of the core customer class. As a result, the NGV
8 customers will be accorded revenue accounting treatment similar to the other core customers and
9 the NGV transportation costs and related net revenues will be recorded in the CFCA.
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D.
Economic Practicality Shortfall Memorandum Account (EPSMA)
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The EPSMA, which is not recorded on SoCalGas’ financial statements, tracks the
12 shortfall in revenue that is recorded in the CFCA principally as a result of large core customers
13 electing to transfer from core to noncore service. In both D.97-04-082 and D.00-04-060,
14 SoCalGas was authorized to update the demand forecast to account for core to noncore migration
15 and assign 20% of the revenue shortfall occurring in the CFCA directly to noncore customers
16 (remaining 80% is recovered from core customers). The EPSMA is forecast to be undercollected
17 by $178,000 as of December 31, 2008. SoCalGas proposes to amortize and record the
18 corresponding entries into the CFCA over a 12-month period beginning January 1, 2009.
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E.
Enhanced Oil Recovery Account (EORA)
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The EORA balances EOR recorded revenues against a forecasted EOR revenue and
21 actual company-use fuel and UAF gas costs. The EORA is forecast to be undercollected by $3.1
22 million as of December 31, 2008. The forecasted undercollected balance is primarily due to
23 higher gas prices for company-use fuel and UAF gas compared to the cost of gas adopted in the
24 previous BCAP. EOR revenues are also down from the previously adopted forecast. SoCalGas
25 proposes to include the EORA balance in rates to be amortized over a 12-month period
26 beginning January 1, 2009.
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1
F.
FERC Settlement Proceeds Memorandum Account (FSPMA)
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The original purpose of the FSPMA (formerly known as El Paso Settlement Proceeds
3 Memorandum Account) was to record solely the El Paso Settlement Proceeds allocable to Core
4 Aggregation Transportation (CAT) customers pursuant to D.03-10-087. As authorized in AL
5 3614, the FSPMA was expanded to record the CAT customers’ share of all FERC settlement
6 proceeds received from other companies settling with the State of California for their
7 involvement in the 2000-2001 energy crisis.
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The FSPMA is forecast to be undercollected by $26,000 as of December 31, 2008 due to
9 an over-amortization of refunds accumulated in prior years. SoCalGas proposes to include the
10 FSPMA balance in rates to be amortized over a 12-month period beginning January 1, 2009.
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G.
Firm Access and Storage Rights Memorandum Account (FASRMA)
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Pursuant to D.06-12-031, SoCalGas established the FARMA to record costs incurred to
13 implement a firm tradable access rights structure which would provide customers with an
14 opportunity to obtain firm access into the utility system at a specific receipt point throughout the
15 year. In D.07-12-019, SoCalGas was authorized to expand the FARMA (i.e., rename as
16 FASRMA) to record reasonable costs associated with establishing and maintaining new postings
17 on the Electronic Bulletin Board (EBB), a secondary market for storage rights, a new fifth
18 nomination cycle, new optional enhanced balancing services, and system expansion projects
19 (plus related third party review).
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The FASRMA is forecast to be $3.6 million undercollected as of December 31, 2008 as a
21 result of projected implementation costs. SoCalGas proposes to include the FASRMA balance in
22 rates to be amortized over a 12-month period beginning January 1, 2009. The proposal for the
23 allocation of the FASRMA undercollected balance in rates is discussed in the testimony of Mr.
24 Lenart.
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H.
Gain / Loss on Sale Memorandum Account (GLOSMA)
26
Pursuant to D.06-04-032, SoCalGas established the Gain on Sale Memorandum Account
27 (GOSMA) to record the gain on sale associated with the sale of 36 lots at the Playa del Rey
28 (PdR) storage facility pending the outcome of the Gain on Sale proceeding. Pursuant to D.06-
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1 05-041 as modified by D.06-12-043 and Resolution G-3399, on August 6, 2007 SoCalGas filed
2 supplemental AL 3642-A modifying the GOSMA (i.e., renamed to GLOSMA) to record the
3 ratepayer’s allocation of any after tax gains or losses associated with the sale of the PdR lots as
4 well as any future sales of utility assets.
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The GLOSMA is forecast to have a remaining overcollected balance of $143,000 as of
6 December 31, 2008 primarily due to accumulated interest. SoCalGas proposes to include the
7 GLOSMA balance in rates to be amortized over a 12-month period beginning January 1, 2009.
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I.
Hazardous Substance Cost Recovery Account (HSCRA)
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The HSCRA was established to record hazardous substance clean-up and insurance
10 litigation costs related to manufactured gas plants, presently identified federal Superfund sites,
11 and other sites identified by the utility offset by recorded insurance recoveries from third parties,
12 insurance carriers, and customers. Consistent with Commission authorization in D.94-05-020,
13 90% of hazardous substance costs, 70% of insurance litigation costs and a portion of any
14 insurance recoveries (determined by adopted formula) are allocable to customers.
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The HSCRA is forecast to be undercollected by $22.3 million as of December 31, 2008.
16 The forecasted undercollected balance is due to the ratepayer’s 90% share of clean-up costs
17 (approximately $22 million) offset partially by approximately $0.3 million of allocated insurance
18 recoveries. SoCalGas proposes to include the HSCRA balance in rates to be amortized over a
19 12-month period beginning January 1, 2009.
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J.
Integrated Transmission Balancing Account (ITBA)
21
Pursuant to D.06-04-033 and D.06-12-031, SoCalGas was authorized to establish the
22 ITBA which consists of two sub-accounts: System Integration (SI) sub-account and the Firm
23 Access Rights (FAR) sub-account. The purpose of the SI sub-account is to record the difference
24 between the authorized transmission system revenue requirement and the corresponding
25 transmission revenues and revenues from interruptible off-system delivery service to the Pacific
26 Gas & Electric system. The purpose of the FAR sub-account is to record the difference between
27 authorized and recorded firm and interruptible access charges.
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1
With the implementation of system integration of the combined transmission system of
2 SoCalGas and SDG&E effective January 1, 2008, the SI sub-account of SoCalGas’ ITBA is
3 forecast to be $4.0 million undercollected as of December 31, 2008. The forecasted
4 undercollected balance is due to authorized transmission system costs exceeding the projected
5 transmission revenues. In combining the forecasted balances for SoCalGas’ ITBA SI sub6 account and SDG&E's ITBA and re-allocating the combined balance based on the adopted cold7 year throughput, SoCalGas’ ITBA SI sub-account is forecast to be undercollected $7.5 million.
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Pursuant to D.06-04-033, SoCalGas filed AL 3706-B indicating that the ITBA SI sub-
9 account will record the authorized transmission system revenue requirement which includes the
10 cost for transmission company-use fuel. Since SoCalGas did not intend nor did D.06-04-033
11 change the regulatory treatment of transmission company-use fuel costs, SoCalGas proposes to
12 clarify that the ITBA SI sub-account will record actual, not authorized, transmission company13 use fuel costs. This is consistent with the balancing account treatment of these costs in the
14 CFCA, NFCA, and EORA prior to the establishment of the ITBA.
15
Similar to what is described in Section IV.C in my testimony, beginning January 1, 2009,
16 instead of recording 1/12 of the authorized margin on a monthly basis in the ITBA SI Sub17 account, SoCalGas proposes to seasonalize the authorized margin based on the proposed demand
18 forecast as described in the testimony of Mr. Emmrich.
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SoCalGas proposes no forecast for the FAR sub-account as of December 31, 2008, as
20 SoCalGas does not anticipate implementation of the FAR system until the latter months of 2008
21 at the earliest.
22
Currently the ITBA is authorized to have two sub-accounts; however, given the distinct
23 and different functions recorded in each sub-account and the different allocation methodologies
24 of the balances, SoCalGas proposes to have two separate regulatory accounts instead of one
25 account with two sub-accounts. The activity related to the SI sub-account would be recorded in
26 one regulatory account (i.e., in the existing ITBA) and the activity related to the FAR sub27 account would be recorded in a new regulatory account, the FAR Balancing Account (FARBA).
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K.
Intervenor Awards Memorandum Account (IAMA)
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The IAMA was established to record authorized payments to intervenors for recovery in
3 rates. The IAMA is forecast to be undercollected by $48,000 as of December 31, 2008 due to
4 authorized payments made in late 2007 not incorporated into rates effective January 1, 2008.
5 Should intervenor payments be made in December 2007 and in 2008, an updated forecast will be
6 included in the October 2008 regulatory account balance update. SoCalGas proposes to include
7 the IAMA balance in rates to be amortized over a 12-month period beginning January 1, 2009.
8
L.
Montebello True-Up Tracking Account (MTTA)
9
Pursuant to the Amended Settlement Agreement approved by D.01-06-081, SoCalGas
10 was authorized to track the ratepayer’s share (50%) of the actual net after tax gains associated
11 with the abandonment of the Montebello storage facility to the $30 million upfront refund
12 provided to ratepayers over the 12-month period beginning in September 2001. As SoCalGas
13 continues to recover cushion gas from the storage facility, SoCalGas anticipates a difference
14 between the amount recorded in the tracking account and the upfront refund. A zero balance is
15 forecast for the MTTA as of December 31, 2008; however, should SoCalGas record an
16 adjustment in the MTTA in December 2007 and in 2008, a revised forecast will be incorporated
17 in the October 2008 regulatory account balance update for amortization in rates over a 12-month
18 period beginning January 1, 2009.
19
M.
Noncore Fixed Cost Account (NFCA)
20
The purpose of the NFCA is to balance an authorized margin, transition, and other actual
21 non-gas costs allocated to noncore customers (excluding EOR) with corresponding revenues to
22 recover such costs. The NFCA also includes administrative costs and uncollectible deferred
23 billings associated with the payment deferral plan pursuant to Resolution E-4065.
24
Pursuant to D.02-12-017, the Commission approved SoCalGas’ proposal for 100%
25 balancing account protection beginning January 1, 2003. Continuation of the balancing account
26 protection is discussed in the testimony of Mr. Morrow. Should SoCalGas not receive continued
27 100% balancing account treatment, SoCalGas proposes to exclude from sharing the difference
28 between authorized and actual costs for other company-use fuel and UAF gas. Both company-
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1 use fuel and UAF gas costs are highly sensitive to changes in gas prices for which SoCalGas has
2 no control over. The Commission approved in D.00-04-060 an authorized Weighted Average
3 Cost of Gas (WACOG) of $2.31 / Dth in calculating authorized company-use fuel and UAF gas
4 costs. In comparison, the average annual actual WACOG for 2006 was $6.25 / Dth, almost 3
5 times higher than the authorized WACOG. Even during the first full year after implementation
6 of the 1999 BCAP, the average annual actual WACOG for 2001 was $5.02 / Dth. The
7 unpredictability of gas prices in the market was further evidenced during two months in 2005
8 where the actual monthly WACOG peaked at over $10 / Dth. As such, SoCalGas believes it
9 should not be placed at risk for differences between actual and authorized costs for other
10 company-use fuel and UAF gas.
11
The NFCA is forecast to be $10.4 million undercollected as of December 31, 2008. The
12 forecasted undercollected balance is primarily due to higher expected costs for company-use fuel
13 and UAF gas and lower throughput-related revenues. SoCalGas proposes to include the NFCA
14 balance in rates to be amortized over a 12-month period beginning January 1, 2009.
15
Pursuant to D.00-04-060, the NFCA does not balance costs and related revenues for
16 SoCalGas’ international wholesale customer Ecogas Mexicali (formerly known as Distribuidora
17 de Gas Natural de Mexicali (DGN)). With the contract between Ecogas and SoCalGas ending in
18 August 2009, SoCalGas plans to file tariffs implementing rates effective upon the contract’s
19 expiration date. As such, upon implementation of the new tariffs and rates, SoCalGas proposes
20 to treat Ecogas similar to its other wholesale customers and balance the authorized and actual
21 costs and the related revenues in the NFCA.
22
N.
Noncore Storage Balancing Account (NSBA)
23
The NSBA was established to balance non-gas costs for the unbundled storage service
24 program and the reservation revenues collected from customers who contract for unbundled
25 storage services. The NSBA provides for 50 / 50 sharing between ratepayers and shareholders
26 for unbundled storage service and 100% balancing of unallocated storage costs.
27
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As described in Section IV.O of my testimony, SoCalGas established the Noncore
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2 Storage Memorandum Account (NSMA) to record storage costs including the unallocated scalar
3 and the related revenues of the unbundled storage service in accordance with D.07-12-019.
The NSBA is forecast to be $2.0 million overcollected as of December 31, 2008. The
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5 forecasted overcollected balance is primarily due to revenues in excess of costs for remaining
6 months of 2007 not incorporated into rates effective January 1, 2008. SoCalGas proposes to
7 include the NSBA balance in rates to be amortized over a 12-month period beginning January 1,
8 2009.
In accordance with the Settlement Agreement (SA) adopted in D.08-12-020 in Phase I of
9
10 the BCAP, SoCalGas will eliminate the NSMA effective December 31, 2008. Effective January
11 1, 2009 the NSBA will record the authorized costs and related revenues associated with the
12 unbundled storage program. In addition, the NSBA will record the net revenues from hub
13 services collected under SoCalGas’ G-PAL tariff and reflect the new sharing mechanism related
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14 to this account.
15
O.
Noncore Storage Memorandum Account (NSMA)
16
Pursuant to D.07-12-019, SoCalGas filed AL 3812 on December 31, 2008, subsequently
17 supplemented by AL 3812-A on January 29, 2008, to establish the NSMA to record storage costs
18 including the unallocated scalar and the related revenues associated with SoCalGas’ Unbundled
19 Storage Program. As discussed in Section IV.N of my testimony, the NSMA will be eliminated
20 effective December 31, 2008. In conjunction with this, SoCalGas will transfer the ratepayer
21 allocation of the 2008 net revenues recorded in the NSMA to the NSBA.
SoCalGas will include a forecast of the ratepayer’s allocation of the NSMA based on the
22
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23 adopted sharing mechanism in the advice letter to be filed in early December. The forecasted
24 ratepayer allocation will be amortized over a 12-month period beginning in January 1, 2009.
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In compliance with the BCAP Phase I decision, SoCalGas will file an advice letter in early December detailing
revisions to its regulatory accounts.
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1
P.
Research Royalty Memorandum Account (RRMA)
2
The RRMA records all royalties, licensing fees, and other revenue attributable to
3 SoCalGas’ Research, Development, and Demonstration projects. The RRMA is forecast to be
4 $10,000 overcollected as of December 31, 2008 due to accumulated interest. Should SoCalGas
5 receive royalty payments in December 2007 and in 2008, a revised forecast will be incorporated
6 in the October 2008 regulatory account balance update. SoCalGas proposes to include the
7 RMMA in rates to be amortized over a 12-month period beginning January 1, 2009.
8
Q.
Self-Generation Program Memorandum Account (SGPMA)
9
Pursuant to D.02-02-026, D.01-09-012, D.01-07-028, D.01-03-073, and the California
10 Solar Initiative (CSI) adopted in D.05-12-044 and D.06-01-024, the Commission authorized the
11 regulatory accounting treatment of the incremental costs associated with SoCalGas’ Self12 Generation Incentive Program (SGIP) prescribed under Assembly Bill (AB) 970. Self13 generation, as defined in D.01-03-073, refers to distributed generation technologies, such as
14 microturbines, small gas turbines, wind turbines, photovoltaics, fuel cells, internal combustion
15 engines, and combined heat and power (or co-generation).
16
Pursuant to the CSI which was later modified by D.06-12-033, the SGIP was revised to
17 exclude funding and incentive payments for technologies related to the solar energy program.
18 Such activity is to be recorded in the California Solar Initiative Balancing Account.
19
The SGPMA is forecast to be undercollected by $8.0 million as of December 31, 2008
20 due to the revenue requirement for SoCalGas’ SGIP for 2009. In D.06-12-033, SoCalGas’
21 prospective authorized revenue requirement for the SGIP was lowered to $8 million to fund only
22 non-solar distributed generation projects. However, the funding level for the SGIP is only
23 authorized through December 31, 2007. On December 19, 2007, the Commission issued a
24 proposed decision recommending the SGIP funding level for 2008 and onwards be equal to the
25 funding in 2007. A final decision is anticipated in the first quarter of 2008, so SoCalGas will
26 include an updated forecast in the October 2008 regulatory account balance update for any
27 difference between the proposed and final SGIP funding level. SoCalGas proposes to include
28 the SGPMA balance in rates to be amortized over a 12-month period beginning January 1, 2009.
- 12 -
1 V.
Proposed Elimination Of Regulatory Accounts
2
A.
3
Pursuant to D.02-04-026, the BMA, which is not recorded on SoCalGas’ financial
Baseline Memorandum Account (BMA)
4 statements, tracks the under- or overcollection of revenues recorded in the CFCA as a result of
5 changing the baseline allowances, and not rates. The BMA also tracks the administrative
6 expenses, which are recorded in the CFCA, associated with the medical baseline program
7 changes.
8
Pursuant to D.04-02-057, SoCalGas was authorized to revise its rates to reflect the
9 baseline-related shortfalls on an on-going basis and amortize the undercollected balance in the
10 BMA. A zero balance is forecast for the BMA as of December 31, 2008 as the account’s balance
11 is projected to be fully amortized. As this account is no longer required, SoCalGas proposes to
12 eliminate the BMA.
13
B.
Brokerage Fee Account (BFA)
14
The BFA balances authorized noncore brokerage fee costs against noncore brokerage fee
15 revenues. With the elimination of core subscription service at the end of 2003, SoCalGas no
16 longer incurs brokerage costs for noncore gas purchases. As a result, SoCalGas proposes to
17 eliminate the authorized brokerage fees for noncore customers, transfer the forecasted
18 undercollected balance of $90,000 as of December 31, 2008 to the NFCA, and eliminate the
19 BFA.
20
C.
Core Interstate Transition Cost Surcharge Account (CITCSA)
21
The purpose of the CITCSA is to record the difference between SoCalGas’ obligation for
22 pipeline demand charges allocated to the core for interstate capacity net of the cost of demand
23 charges for SoCalGas’ capacity reserved to provide core service and any related revenues
24 received from brokering such capacity. SoCalGas’ proposal for the Gas Industry Restructuring
25 (GIR) established the CITCSA. Although the GIR was authorized in D.01-12-018, changes to
26 the tariffs based on the GIR were not authorized until D.04-04-015. However, the Commission
27 ordered a stay on D.04-04-015 to ensure consistency with the direction being taken in
28 Rulemaking 04-01-025. In D.04-09-022, the stay on D.04-04-015 was continued and SoCalGas
- 13 -
1 was ordered to file an application on its system integration and FAR proposals. As a result, the
2 GIR was never implemented and SoCalGas continued to record activity in the CFCA and did not
3 use the CITCSA.
4
With the expiration of the Transportation Service Agreements (TSA) with the
5 Transwestern Pipeline Company (Transwestern) and El Paso Natural Gas Company (El Paso) on
6 October 31, 2005 and August 31, 2006, respectively, SoCalGas removed the interstate
7 reservation capacity charges from transportation rates (see AL 3531 and AL 3644). Under
8 SoCalGas’ new TSAs with Transwestern and El Paso, the reservation charges will be recovered
9 from customers through procurement rates. As a result, the CFCA was modified accordingly.
10
SoCalGas proposes to eliminate the CITCSA as it is no longer required.
11
D.
12
Pursuant to D.03-12-057, the purpose of the COSRRMA is to record the shortfall or
Cost of Service Revenue Requirement Memorandum Account (COSRRMA)
13 overcollection resulting from the difference between authorized base margin revenues recovered
14 under currently authorized rates and the final 2004 revenue requirement adopted by the
15 Commission in the Phase I decision of SoCalGas’ 2004 Cost of Service (COS) proceeding.
16 Pursuant to D.04-12-009, the COSRRMA was expanded to record the difference for 2005 until
17 the Phase II decision of SoCalGas COS proceeding.
18
The COSRRMA is forecast to have a residual overcollected balance of $14,000 as of
19 December 31, 2008. SoCalGas proposes to transfer the balance to the CFCA and NFCA based
20 on the allocation methodology consistent with this account and eliminate the COSRRMA.
21
E.
El Paso Turned-Back Capacity Memorandum Account (EPTCBA)
22
Pursuant to D.02-07-037, the purpose of the EPTCBA is to balance costs associated with
23 the subscription, retention, and disposition of turned-back capacity on the El Paso interstate
24 pipeline and any proceeds realized from brokering such capacity. The last of the contracts
25 related to this turned-back capacity ended in March 2007.
26
The EPTCBA is forecast to have a residual overcollected balance of $36,000 as of
27 December 31, 2008. SoCalGas proposes to transfer this balance to the CFCA and NFCA based
28 on the allocation methodology consistent with this account and eliminate the EPTCBA.
- 14 -
1
F.
Gas Industry Restructuring Memorandum Account (GIRMA)
2
The purpose of the GIRMA was to record the difference between the incremental costs
3 associated with the implementation of the regulatory market structure adopted in D.01-12-018
4 and revenues from rates to recover such costs as authorized by the Commission. As described in
5 Section V.C of my testimony, the GIR structure was never realized, so the account was never
6 used. As the account is no longer required, SoCalGas proposes to eliminate the GIRMA.
7
G.
Late Payment Charge Memorandum Account (LPCMA)
8
The purpose of the LPCMA is to record late payment charges assessed to non-residential
9 customers. In A.06-12-010, SoCalGas’ 2008 General Rate Case, SoCalGas proposed an adopted
10 level of late payment charges be included with other miscellaneous revenues to reduce
11 SoCalGas’ base margin revenue requirement; therefore, late payment charges will no longer be
12 subject to regulatory account treatment.
13
The LPCMA is forecast to have a residual overcollected balance of $21,000 as of
14 December 31, 2008. Subject to the Commission’s ruling on the GRC application, SoCalGas
15 proposes to transfer the LPCMA balance to the CFCA and NFCA based on the allocation
16 methodology consistent with this account and eliminate the LPCMA.
17
H.
Natural Gas Vehicle Account (NGVA)
18
D.95-11-035 and Resolution G-3191 established the level of NGV program spending
19 over a six-year period beginning December 21, 1995. The Commission issued Resolution G20 3322, D.02-12-056, and D.03-10-086 extending the funding level through 2005. D.03-10-086
21 also authorized the funding level of “discretionary” program costs such as customer service,
22 training, and other “non-mandatory” program costs. Pursuant to D.02-12-056, the utility’s next
23 GRC or COS proceeding should include a review of “mandatory” program costs such as
24 acquisition costs of alternative fuel use fleet vehicles. As a result, D.04-12-015, SoCalGas’ 2004
25 COS, authorized the recovery of mandatory costs in the base margin revenue requirement. D.0526 05-010 extended the discretionary program spending level until the utility’s next GRC.
27
In A.06-12-010, SoCalGas’ 2008 GRC, similar to treatment of mandatory program costs,
28 SoCalGas proposes to recover “discretionary” program costs in the base margin revenue
- 15 -
1 requirement. Subject to the Commission’s ruling on the GRC proceeding, SoCalGas proposes to
2 remove the recording of “discretionary” program costs from the NGVA and include the proposed
3 base margin revenue requirement for these program costs in the CFCA. In addition, beginning
4 January 1, 2009, SoCalGas proposes to identify the NGV customer class as a core customer class
5 similar to other core customer classes (e.g., non-residential core customer class). As a result,
6 SoCalGas proposes that the NGV customer class be treated similar to the other core customer
7 classes and that NGV transportation costs and related net revenues be recorded in the CFCA.
8 SoCalGas proposes that the NGV procurement costs and related revenues be recorded in the
9 PGA.
10
The NGVA is forecast to be $7.0 million overcollected as of December 31, 2008 due to
11 revenues exceeding the commodity and operational program costs. Based on the proposals
12 described above, SoCalGas proposes to transfer the NGVA balance to the CFCA and NFCA
13 based on the allocation methodology consistent with this account and eliminate the NGVA.
14
I.
NGV-RDD Memorandum Account (NGV-RDD)
15
D.95-11-035 and Resolution G-3191 established the level of NGV program spending
16 including the NGV-related Research, Development, and Demonstration (RDD) program over a
17 six-year period beginning December 21, 1995. The Commission issued Resolution G-3322 and
18 D.03-10-086 extending the funding level through 2005. D.05-05-010 extended the funding level
19 until the utility’s next GRC.
20
In A.06-12-010, SoCalGas’ 2008 GRC, SoCalGas proposes to combine the spending
21 level for the NGV RDD program with the non-public interest RDD program in the base margin
22 revenue requirement. As a result, the NGV-RDD program would be fully integrated into the
23 base margin RDD program. Excluding the authorized cost from the NGV-RDD’s 2008 activity,
24 the account is forecast to have a residual undercollected balance of $18,000 as of December 31,
25 2008 as a result of accumulated interest. Subject to the Commission’s ruling on A.06-12-010,
26 SoCalGas proposes to transfer the balance to the CFCA and NFCA based on the allocation
27 methodology consistent with this account and eliminate the NGV-RDD.
28
- 16 -
1
J.
Noncore Fixed Cost Tracking Account (NFCTA)
2
The purpose of the NFCTA is to record the difference between the authorized costs in
3 rates and the noncore portion of the actual carrying cost of gas in storage. As originally
4 authorized in D.94-07-064, the NFCTA also recorded the difference between the authorized
5 costs in rates and the noncore portion of actual take-or-pay (TOP) and minimum purchase
6 obligations (MPO) costs. With the elimination of TOP and MPO costs, the NFCTA was revised
7 to eliminate the recording of these costs as authorized in AL 3653.
8
The NFCTA is forecast to be $118,000 undercollected as of December 31, 2008
9 primarily due to higher carrying cost of storage as a result of higher gas prices. As the noncore
10 portion of the carrying cost of gas in storage is no longer required, SoCalGas proposes to transfer
11 the remaining balance to the NFCA and eliminate the NFCTA.
12
K.
Noncore Interstate Transition Cost Surcharge Account (NITCSA)
13
The purpose of the NITCSA is to record the difference between SoCalGas’ obligations
14 for interstate pipeline capacity allocated to noncore customers and revenues received by
15 SoCalGas for core subscription reservations, the authorized revenue requirement for noncore
16 customers, and brokered capacity.
17
As discussed in Section V.C of my testimony, with the expiration of the SoCalGas’ TSAs
18 with Transwestern and El Paso, interstate capacity reservation charges were removed from
19 transportation rates. The NITCSA is forecast to have a residual overcollected balance of $8,000
20 as of December 31, 2008. With the removal of interstate capacity reservation charges from
21 transportation rates, the NITCSA is no longer required. SoCalGas proposes to transfer the
22 residual balance to the NFCA and eliminate the NITCSA.
23
L.
Research Development & Demonstration Expense Account (RDDEA)
24
The purpose of the RDDEA is to record the difference between authorized costs in rates
25 and actual costs associated with non-public interest research, development, and demonstration
26 programs.
27
The 1997-2003 program cycle of the RDDEA is forecast to have an overcollected
28 balance of $3,000 as of December 31, 2008. As SoCalGas no longer anticipates incurring any
- 17 -
1 expense related to this program cycle, SoCalGas proposes to transfer the residual balance to the
2 CFCA and NFCA based on the allocation methodology consistent with this account and
3 eliminate the 1997-2003 program cycle.
4
M.
Wheeler Ridge Firm Access Charge Memorandum Account (WRFACMA)
5
Pursuant to D.00-04-060, the total annual revenue requirement related to Wheeler Ridge
6 facilities was rolled into rates effective June 1, 2000. Accordingly, Schedule G-ITC was
7 modified to eliminate the firm and interruptible volumetric charges, the zone rate credit, and the
8 fuel charge components of the tariff; however, the firm access reservation charge was retained.
9 The purpose of the WRFACMA is to record the reservation charges for firm access charged
10 under the G-ITC tariff for future refund to customers.
11
As described in Section IV.J of my testimony, SoCalGas will be establishing a system of
12 firm access rights pursuant to D.06-12-031, which will eventually replace the G-ITC tariff.
13 SoCalGas no longer receives revenues from the G-ITC tariff as SoCalGas’ remaining customer
14 ended its Wheeler Ridge access agreement in early 2007. With SoCalGas establishing a separate
15 account to record firm access charges, the WRFACMA will no longer be required. The
16 WRFACMA is forecast to have a residual overcollected balance of $34,000 as of December 31,
17 2008 due to the carryover of the remaining balance from 2007. SoCalGas proposes to transfer
18 the residual balance to the CFCA and NFCA based on the allocation methodology consistent
19 with this account and eliminate the WRFACMA.
20
N.
G-PAL Memorandum Account (GPMA)
21
D.07-12-019 authorized SoCalGas to establish the GPMA to record net revenues received
22 under SoCalGas’ G-PAL (Operational HUB Services) tariff. As discussed in Section IV.N of
23 my testimony, since net revenues from hub services collected under the G-PAL tariff will be
24 recorded in the NSBA, the GPMA will no longer be required and will be eliminated. The 2008
25 net hub revenues recorded in the GPMA will be transferred to the NSMA and treated in the same
26 manner as the disposition of the net storage revenues recorded in the NSMA as discussed in
27 Section IV.O.
28
- 18 -
1
O.
San Diego Gas & Electric Storage Memorandum Account (SDGESMA)
2
The purpose of the SDGESMA is to track the cost of storage charged to SDG&E to the
3 extent that the price under the storage contract is above the rate SoCalGas charges to its own
4 core customers. The activity tracked in the SDGESMA is only memo entries (i.e., not recorded
5 on SoCalGas’ financial statements) as the actual activity is recorded in the NSBA or NSMA.
6 The SDGESMA is to track the difference related to the two one-year storage contracts with
7 SDG&E for the period of April 2006 through March 2007 and April 2007 through March 2008.
8 Pursuant to D.08-12-020 in Phase I of the BCAP, SoCalGas will eliminate the SDGESMA with
9 no adjustment to transportation rates.
10
P.
Long Beach Storage Memorandum Account (LBSMA)
11
Pursuant to D.07-12-019, SoCalGas filed AL 3818 on January 22, 2008 to establish the
12 LBSMA to track the storage charges paid by the City of Long Beach to the extent such charges
13 exceed the fully-scaled LRMC rates for each component – inventory, injection, or withdrawal 14 paid by SoCalGas’ core customers for storage service. The activity tracked in the LBSMA is
15 only memo entries (i.e., not recorded on SoCalGas’ financial statements) as the actual activity is
16 recorded in the NSMA. Pursuant to the SA in D.08-12-020 in Phase I of the BCAP, the core
17 parity issue with the City of Long Beach is resolved, so the LBSMA is no longer required.
18 SoCalGas will eliminate the LBSMA with no adjustment to transportation rates.
19
Q.
Southwest Gas Storage Memorandum Account (SGSMA)
20
Pursuant to D.07-12-019, SoCalGas filed AL 3818 on January 22, 2008 to establish the
21 SGSMA to track the storage charges paid by Southwest Gas Corporation to the extent such
22 charges exceed the fully-scaled LRMC rates for each component – inventory, injection, or
23 withdrawal - paid by SoCalGas’ core customers for storage service. The activity tracked in the
24 SGSMA is only memo entries (i.e., not recorded on SoCalGas’ financial statements) as the actual
25 activity is recorded in the NSMA. Pursuant to the SA in D.08-12-020 in Phase I of the BCAP,
26 the core parity issue with Southwest Gas Corporation is resolved, so the SGSMA is no longer
27 required. SoCalGas will eliminate the SGSMA with no adjustment to transportation rates.
28
- 19 -
1
In summary, by eliminating these regulatory accounts in Section V, SoCalGas proposes
2 to transfer a net overcollection of approximately $3.9 million and $3.0 million to the CFCA and
3 NFCA, respectively, for amortization in rates effective January 1, 2009.
4 VI.
Supplier Refunds
5
Pursuant to the Stipulation and Settlement Agreement (FERC Docket No. RP97-288-009,
6 et al), Transwestern Pipeline Company (Transwestern) was ordered to refund all revenues
7 collected above the maximum tariff rates under the negotiated rate transactions with Sempra
8 Energy Trading Corp. and Richardson Products Co., plus interest, to all firm shippers on
9 Transwestern’s system at the time of the transaction. The refund was ordered by the Federal
10 Energy Regulatory Commission on July 17, 2002. SoCalGas received $2.9 million in March
11 2003. SoCalGas proposes to transfer the Transwestern refund balance including interest accrued
12 from the date of receipt of the refund to the CFCA. The forecasted CFCA balance including the
13 Transwestern refund would be amortized over a 12-month period beginning January 1, 2009.
14
Pursuant to the Order on the Stipulation and Settlement Agreement in FERC Docket No.
15 RP05-422-000, the El Paso Natural Gas Company (El Paso) was ordered to refund revenues
16 collected on rates charged above the rates authorized in the settlement to all shippers on El
17 Paso’s system at the time of the transaction. The refund covers the period of January 2006
18 through September 2007. SoCalGas received $8.0 million, $2.7 million, and $2.2 million on
19 November 20, 2007, December 13, 2007, and January 16, 2008, respectively, and anticipates
20 receiving a fourth refund in March 2008. As described in Section V.C of my testimony, under
21 the new TSA with El Paso effective September 2006, reservation charges are recovered through
22 procurement rates. As a result, SoCalGas anticipates that a portion of the refund will be returned
23 to transportation customers through amortization of the CFCA and NFCA and a portion returned
24 to procurement customers through amortization of the PGA. At this time, SoCalGas is in the
25 process of identifying the refund allocation among its regulatory accounts.
26
27
28
- 20 -
1 VII.
Other Regulatory Account Items
2
A.
3
Pursuant to D.07-05-022, the purpose of the OMSRMA is to record certain costs
Otay Mesa System Reliability Memorandum Account (OMSRMA)
4 associated with the SoCalGas Pipeline System Control and Planning Department’s delivery of
5 gas to sustain operational flows at Otay Mesa.
6
There are no costs recorded in the OMSRMA as of November 2007, and SoCalGas
7 proposes no forecast of the OMSRMA as of December 31, 2008; however, if costs are recorded
8 to the OMSRMA in December 2007 or in 2008 to provide operational flow at Otay Mesa,
9 SoCalGas will update its forecast for amortization over a 12-month period beginning January 1,
10 2009. Refer to testimony of Mr. Lenart for the disposition of the balance in rates.
11
Pursuant to D.07-12-019, SoCalGas is authorized to establish a SRMA to record costs
12 related to minimum flow requirements for SoCalGas’ entire system. As such, upon
13 implementation of the SRMA, SoCalGas will cease recording entries to the OMSRMA. If there
14 is no activity recorded in the OMSRMA upon implementation of the SRMA, SoCalGas proposes
15 to eliminate the OMSRMA as it is no longer required.
16
B.
Company-Use Fuel for Load Balancing Account (CUFLBA)
17
In accordance with the proposal as described in the testimony of Mr. Watson, SoCalGas
18 proposes to establish the CUFLBA to balance the difference between actual costs for company19 use fuel for load balancing and the related revenues. Such costs and revenues will no longer be
20 recorded in the NFCA and EORA. For the disposition of the account in rates, refer to the
21 testimony of Mr. Lenart.
22
This concludes my prepared direct testimony.
23
24
25
26
27
28
- 21 -
1
Southern California Gas Company - 2009 BCAP
Present and Proposed Regulatory Account Balances
(Over) / Under Collection
Table 1
2
3
4
5
Regulatory Account Name
6
7
1
2
3
9
4
Blythe Operational Flow Requirement Memorandum Account
(BOFRMA)
Core Fixed Cost Account (CFCA) 4/
5
Economic Practicality Shortfall Memorandum Account (EPSMA)
6
El Paso Turned-Back Capacity Balancing Account (EPTCBA)
7
Enhanced Oil Recovery Account (EORA)
8
FERC Settlement Proceeds Memorandum Account (FSPMA)
9
10
Firm Access & Storage Rights Memorandum Account (FASRMA)
Gain / Loss on Sale Memorandum Account (GLOSMA)
11
Hazardous Substance Cost-Recovery Account (HSCRA)
12
Integrated Transmission Balancing Account (ITBA)
13
Interstate Transition Cost Surcharge Account (ITCSA)
15
14
15
Intervenor Award Memorandum Account (IAMA)
Late Payment Charge Memorandum Account (LPCMA)
16
16
Natural Gas Vehicle Account (NGVA)
17
NGV - Research Development & Demonstration Memo Account (NGVRDD)
18
Noncore Fixed Cost Account (NFCA) 4/
Noncore Fixed Costs Tracking Account (CCSI subaccount)
Noncore Storage Balancing Account (NSBA)
10
11
12
13
14
17
18
19
20
19
20
21
24
25
26
1/1/2009
Proposed
Amortization
(MM$)
(MM$)
2/
3/
$0.1
($0.2)
$0.0
$9.7
$0.2
($1.4)
$5.2
$0.0
$0.0
($3.8)
$16.7
$0.0
($0.3)
$0.2
($1.4)
($5.5)
$4.9
$3.4
$0.2
$0.0
$3.1
$0.0
$3.6
($0.1)
$22.3
$7.5
$0.0
$0.0
$0.0
$0.0
$4.9
($6.3)
$0.0
$1.4
($2.1)
$0.0
$3.6
$3.7
$5.6
$7.5
$0.3
($0.2)
$1.4
$5.5
$0.4
$41.5
$0.2
($17.3)
$0.0
$10.4
$0.0
($2.0)
($0.4)
($31.1)
($0.2)
$15.3
$0.0
($0.0)
$8.0
$0.1
$0.5
$0.0
$61.3
$9.5
22
Research Royalty Memorandum Account (RRMA)
23
Self-Generation Program Memorandum Account (SGPMA)
($0.1)
($0.5)
$8.0
Total
$51.8
Notes
1/ Balances exclude franchise fees and uncollectibles.
2/ Balance reflects combined SoCalGas and SDG&E ITBA balances re-allocated between utilities based on
cold year throughput.
3/
Proposed amortization based on recorded data through November 2007.
4/
CFCA and NFCA forecasted balances include transfer of balances from regulatory accounts proposed
27
28
- 22 -
(MM$)
($0.1)
$0.0
Research Development & Demonstration Expense Account (RDDEA)
- 1997 - 2003 cycle
to be eliminated in Section E. and one supplier refund in Section F. of my testimony.
Revenue
Requirement
Change Incr / (Decr)
($0.2)
$0.2
21
22
23
1/1/2008
Present
Amortization
AL 3807
Affiliate Transfer Fee Account (ATFA)
Brokerage Fee Account (BFA)
8
1/