3/24/2020 S T A T E OF M I C H I G A N BEFORE THE ...

3/24/2020

S T A T E OF M I C H I G A N

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

* * * * In the matter of the application of ) DTE Gas Company for authority ) to increase its rates, amend its rate ) Case No. U-20642 schedules and rules governing the ) distribution and supply of natural gas, ) and for miscellaneous accounting authority. ) __________________________________________)

QUALIFICATIONS AND DIRECT TESTIMONY OF

PAUL R. AUSUM

MICHIGAN PUBLIC SERVICE COMMISSION

QUALIFICATIONS OF PAUL R AUSUM CASE NUMBER U-20642

PART I

1

Q. Please state your name and business address. 1

A. My name is Paul R. Ausum, and my business address is 7109 West Saginaw 2

Highway, Lansing, Michigan 48917. 3

Q. By whom are you employed, and in what position? 4

A. I am employed by the Michigan Public Service Commission (MPSC or the 5

Commission) as an Economic Analyst in the Act 304 and Sales Forecasting 6

Section within the Energy Operations Division. 7

Q. What are your responsibilities in your current position? 8

A. I am responsible for performing technical analysis in Gas Cost Recovery (GCR) 9

and Power Supply Cost Recovery (PSCR) plans and reconciliations and for 10

providing input and sales forecasting support for both gas and electric general rate 11

cases. This analysis leads to the development of MPSC Staff (Staff’s) positions 12

and recommendations. I also monitor the natural gas market and closely track any 13

price movement. 14

Q. Please outline your educational background. 15

A. I earned a Bachelor of Science degree in Economics, with honors, from Oakland 16

University in December 2018. 17

Q. Have you previously provided testimony before the Commission? 18

A. No. 19

DIRECT TESTIMONY OF PAUL R AUSUM CASE NUMBER U-20642

PART II

2

Q. What is the purpose of your testimony in this proceeding? 1

A. The purpose of my testimony is to support the projected sales levels that Staff 2

considers reasonable for DTE Energy Gas Company (DTE or the Company). 3

Q. Are you sponsoring any exhibits? 4

A. Yes. I am sponsoring the following exhibit: 5

Exhibit S-18 Staff’s October 2020-September 2021 Sales Forecast. 6

Q. Was this exhibit prepared by you? 7

A. Yes. 8

Q. Did Staff analyze the forecasted sales presented by Company witness George H. 9

Chapel? 10

A. Yes, Staff analyzed the October 2020-September 2021 sales forecast Mr. Chapel 11

supported. The results of his forecast were presented in Exhibit A-15, Schedule 12

E1.1, page 1 of 2. 13

Q. Does Staff support the Company’s sales forecast as filed? 14

A. No. It is Staff’s position that the Company’s October 2020-September 2021 sales 15

forecast, which projects a decrease in delivered volume of 5,933 million cubic 16

feet (MMcf) of natural gas while concurrently forecasting an addition of 29,129 17

customers (Exhibit A-15, E1.1, pages 1 and 2), is not entirely consistent with 18

historic trends and is not easily explained by the Company’s assumptions about 19

the projected test year and/or adjustments to the weather normalized historic test 20

year, and is thus unreasonable. 21

Q. How did Staff analyze the Company’s projected test year sales forecast? 22


PART II

3

A. Staff analyzed historical weather normalized monthly sales figures for the period 1

of September 2014 through August 2019 provided by the Company. For each rate 2

schedule, Staff developed a 12-month (annual) rolling total of weather normalized 3

sales to identify any historical trends that could be extrapolated. The Company 4

provided weather normalized 2018 sales figures as a starting point for its 5

projected sales volumes (Exhibit A-15, Sch. E1.1, col. (b), lines 8-14). Staff 6

assessed the forecasting methods the Company used to get from its 2018 7

normalized sales levels to its October 2020-September 2021 projected test year 8

sales. 9

Q. Did Staff analyze the customer count forecasts? 10

A. Yes, Staff analyzed the customer counts in the forecasted test period using 11

historical customer levels provided by the Company dating back to September 12

2014. Staff determined the Company’s projected test year customer counts were 13

consistent with historic to present trends. 14

Q. Does Staff support the Company’s customer count forecast as filed? 15

A. Yes. 16

Q. Does the Company’s sales forecast for the October 2020-September 2021 test 17

year appear consistent with historical weather normalized sales trends? 18

A. No. The Company forecasts a decrease in total sales volumes from the historic 19

2018 test year to the October 2020-September 2021 projected test year for all rate 20

schedules, despite forecasting increased customer counts for three of said 21

schedules (A, GS-1, and S) from the historic to projected test year. The forecasted 22


PART II

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increases in customer count for these three customer groups can be found on 1

Exhibit A-15, E.1.1, page 2 of 2. 2

Q. What is your understanding of the adjustments the Company applies to its 2018 3

historic test year sales and the Company’s assumptions of the projected test year? 4

A. The Company adjusts its 2018 historic test year actual sales for the impact of 5

weather through a weather normalization process. It then adjusts sales due to 6

expected changes in customer count, as well as expected volume changes due to 7

changes in the rate-schedule consumption per customer as described by Mr. 8

Chapel on page GHC-10 of his testimony, lines 9-12: 9

“[s]econd, DTE Gas expects changes in overall rate schedule 10

consumption per customer due to variances in the Company’s gas 11

heating value, demographic changes in the Company’s customer base, 12

and energy waste reduction on an ongoing basis through 2019 and 13

into the projected test year.” 14

Q. What is your understanding of how DTE accounts for the effects of weather on 15

sales volumes in the projected test year? 16

A. To “capture weather-related effects impacting customers’ usage” (GHC-10, line 17

13) DTE uses a 15-year normal weather forecast based on weather occurring from 18

2004-2018. 19

Q. What is your understanding of how energy waste reduction (EWR or 20

conservation) affects DTE’s October 2020-September 2021 projected sales? 21

A. Mr. Chapel cites DTE’s most recent EWR Plan filing (Case U-20429), in which 22

“the Company projected annual demand reductions due to EWR to be 1% 23


PART II

5

annually” (GHC-18, line 24 through GHC-19, lines 1-2). EWR conservation 1

measures will reduce demand for natural gas, all else equal, and forecasted sales 2

will be lower as a result. 3

Q. How do you understand “variances in the Company’s gas heating value” to affect 4

the October 2020-September 2021 projected sales? 5

A. Due to increasing system-average heating values for the gas that DTE delivers to 6

customers, DTE expects less gas consumption per customer, all else equal, and 7

less sales as a result. System-average heating values have increased, from 1,050 8

British Thermal Units (Btu)/cubic foot (cf) in the August 2017-July 2019 period 9

to 1,060 as of July 2019 (GHC-14). DTE is assuming the July 2019 figure of 10

1,060 Btu/cf as the system-average heating value in the projected test year and 11

have subsequently adjusted the projected test year sales forecast by a factor of 12

0.9907 (1,050/1,060) to quantify the effect that the new system-average value 13

would have on consumption, and thus sales. Mr. Chapel describes this adjustment 14

on page GHC-15, lines 5-6 of his testimony. 15

Q. How does DTE justify the change in weather-normalized sales from the historical 16

to the projected test year? 17

A. On page GHC-11, line 25, through GHC-12, lines 1-3, Mr. Chapel states: 18

“The reduction from the weather-normalized total sales of 160.9 Bcf in the 19

historical period to 155.0 Bcf in the projected year is due to both conservation and 20

increased heating values, offset by gains in the number of customers.” 21

Q. Does Staff agree with the October 2020-September 2021 test year sales forecast 22

as prepared by the Company? 23


PART II

6

A. No. DTE forecasts a reduction in delivered sales volumes of 5,933 MMcf, while 1

simultaneously projecting an addition of 29,129 customers. Both of these 2

expected changes are shown in Exhibit A-15, E1.1, pages 1 and 2. For each rate 3

schedule there seems to be reductions in sales that are not easily explained by 4

weather normalization, changing customer counts, or decreased usage due to 5

increased system-average heating values and EWR measures. 6

Q. Has Staff done its own analysis resulting in a projected test year sales forecast it 7

supports? 8

A. Yes, Staff took actual monthly weather normalized sales from September 2014-9

August 2019 as provided by the Company and created rolling 12-month 10

(annualized) sales figures for each rate schedule. These rolling totals were plotted 11

with the projected test year forecasted amounts included to establish a relationship 12

between historical sales trends and the Company’s projected test year sales 13

volumes. 14

Q. Did Staff consider the adjustments to the historic test year done by DTE and 15

DTE’s assumptions of the projected test year in its analysis of the October 2020-16

September 2021 forecast? 17

A. Yes. Staff considered and incorporated all the same adjustments and assumptions 18

described in Mr. Chapel’s testimony. 19

Q. How did Staff account for EWR conservation measures in the October 2020-20

September 2021 sales forecast? 21

A. Staff began with the Company’s 2018 weather normalized sales and applied an 22

assumption of compounded 1% energy waste reduction measures for each year 23


PART II

7

and fraction of a year (9 out of 12 months) between the historic and projected test 1

years. To quantify this assumption, Staff multiplied 2018 weather normalized 2

sales volumes taken from Exhibit A-15, E1.1, page 1, column (b), lines 8-14 by 3

0.99 to represent EWR conservation in 2019, and then multiplied sales again by 4

0.99 to represent EWR conservation expected in 2020. After this, Staff multiplied 5

sales volumes by 0.9925, or 1-(0.01*(9/12)), to quantify the EWR measures 6

expected for the 9 months of 2021 that are part of the projected test year. The 7

adjustment to the Company’s 2018 weather normalized sales that resulted from 8

this assumption is shown in Exhibit S-18, page 1, column (c). 9

Q. Did Staff account for increased system-average heating values in adjusting the 10

Company’s sales forecast? 11

A. Yes. After adjusting 2018 weather normalized sales volumes for EWR 12

conservation measures, Staff multiplied projected volumes for all rate schedules 13

by a factor of 0.9907 to account for increased system average heating values. 14

Because the system average heating values assumed for the projected test year did 15

not start occurring until July 2019, the adjustment due to increased heating values 16

was done after adjusting for EWR measures. The reductions expected from 17

increased heating values are shown in column (d) on page 1 of Exhibit S-18. 18

Q. Did Staff consider customer count changes in developing its recommended test 19

year sales? 20

A. Yes, after adjusting 2018 weather normalized sales volumes for EWR measures 21

and increased system-average heating values, Staff then added or subtracted from 22

sales volumes depending on whether the Company forecasted an increase or 23


PART II

8

decrease in customers for each rate schedule being considered. Staff multiplied 1

the forecasted customer change by usage rates that were determined using the 2

Company’s historical test year if customer declines were forecasted and the 3

Company’s projected test year forecast if customer additions were forecasted. The 4

change in usage due to forecasted customer changes are shown in column (e) on 5

page 1 of Exhibit S-18, and the calculation of forecasted customer usages is 6

shown on page 2 of the same Exhibit. 7

Q. What is Staff’s recommended adjustment to DTE’s October 2020-September 8

2021 test period sales? 9

A. Staff recommends that DTE’s test year sales be increased by 2,472 MMcf or 10

approximately 2%. The increased sales level is the sum of individual adjustments 11

made to each rate schedule (A, 2A I, 2A II, GS-1, GS-2, and S) by Staff, and is 12

depicted in column (f) on page 1 of Exhibit S-18—Staff’s October 2020-13

September 2021 Sales Forecast, with the difference between Staff’s 14

recommendation and DTE’s forecast presented in column (h) of page 1. 15

Q. Does this conclude your direct testimony? 16

A. Yes, it does. 17

March 24, 2020



* * * * In the matter of the application of ) DTE GAS COMPANY for authority ) to increase its rates, amend its rate ) Case No. U-20642 schedules and rules governing the ) distribution and supply of natural gas, ) and for miscellaneous accounting authority. ) __________________________________________)


CYNTHIA L. CREISHER


QUALIFICATIONS OF CYNTHIA L. CREISHER CASE NUMBER U-20642

PART I

1

Q. Please state your name, address, and occupation. 1

A. My name is Cynthia L. Creisher and my business address is 7109 West Saginaw 2

Highway, Lansing, Michigan. I am employed by the Michigan Public Service 3

Commission (MPSC or Commission) as a Public Utilities Engineer in the Gas 4

Operations Section of the Energy Operations Division. 5

Q. Please briefly describe your educational background and work experience. 6

A. I earned a Bachelor of Science degree in Mechanical Engineering from Kettering 7

University, formerly GMI Engineering & Management Institute, in 2002. Prior to 8

my employment at the MPSC, I was employed in the automotive manufacturing 9

industry by Fasco DC Motors as a Product Design Engineer where I was 10

responsible for the development, testing, and production launch of electric motors 11

and actuators. I began my employment with the MPSC in February 2009 as a 12

Public Utilities Engineer. During my tenure, I have attended the Annual 13

Regulatory Studies Program sponsored by the National Association of Regulatory 14

Utility Commissioners and numerous seminars, facility tours, and site visits 15

related to the gas industry. My responsibilities include engineering duties related 16

to the Commission’s regulation of natural gas well production and proration; 17

transmission of natural gas, crude oil, and petroleum products by pipeline; 18

underground natural gas storage; gas pipeline safety; compliance with gas 19

technical standards, including review of gas utilities’ meter testing programs; and 20

various other gas utility functions, including review of gas utilities’ customer 21

attachment programs and complaints or inquiries related to those programs. 22


PART I

2

Q. Have you participated in any other cases before the Commission prior to this 1

proceeding? 2

A. Yes, I have participated in the development of Staff’s position or filed testimony 3

before the Commission in the following cases: 4

Case No. Case Description 5

U-15766 MichCon Gathering CO2 treatment complaint 6

U-15985 MichCon gas rate case 7

U-16230 Commission’s Own Motion regarding operating wells under vacuum 8

U-16280 Toro Energy waiver of compliance 9

U-16388 Commission Own Motion for Continental Resources to show cause 10

U-16407 MichCon long-term main-renewal plan 11

U-16451 MichCon long-term meter move out plan 12

U-16855 Consumers Energy Company gas rate case 13


U-17169 SEMCO Energy Gas Company main replacement program 15



U-17668 Consumers Energy Company meter testing waiver request 18

U-17701 DTE Gas Company main replacement program 19

U-17824 SEMCO Energy Gas Company main replacement program 20

U-17880 Michigan Gas Utilities Corporation gas rate case 21


U-17999 DTE Gas Company gas rate case 23


PART I

3



U-18999 DTE Gas Company gas rate case 3


U-20522 Consumers Energy Company infrastructure recovery mechanism 5

reconciliation 6

U-20479 SEMCO Energy Gas Company gas rate case 7


DIRECT TESTIMONY OF CYNTHIA L. CREISHER CASE NUMBER U-20642

PART II

4


A. The purpose of my testimony is to present Staff’s position and recommendations 2

regarding DTE Gas Company’s (DTE or the Company) case. First, I will address 3

the Company’s proposed operating and maintenance (O&M) expenses for 4

distribution operations. Second, I will address the Company’s proposed capital 5

expenditures in the following categories: Routine Distribution, Main Renewal 6

Program (MRP), Meter Move Out (MMO), Meter Move Out / Meter Assembly 7

Check (MMO MAC) programs, and the Infrastructure Recovery Mechanism 8

(IRM). Finally, I will address the Company’s proposed modification to its tariffs 9

regarding the Customer Attachment Program. 10

Q. Are you sponsoring any exhibits in this proceeding? 11

A. Yes. I am sponsoring the following seventeen exhibits: 12

(1) Exhibit S-16.0, Staff Adjustments to Projected O&M Expenses – Distribution 13

– Other Projected Adjustments, is a one-page exhibit summarizing Staff’s 14

adjustments to the Company’s O&M expense adjustments for distribution 15

operations related to Distribution Record Remediation, Transmission Fitting 16

Conversion, and Damage Prevention as identified in Company Exhibit A-13, 17

Schedule C5.3. 18

(2) Exhibit S-16.1, Staff Adjustments to Capital Expenditures – Routine 19

Distribution and Infrastructure Recovery Mechanism, is a one-page exhibit 20

summarizing Staff’s adjustments to the Company’s capital expenditures related to 21

Routine Distribution, MRP, and MMO as identified in Company Exhibit A-12, 22

Schedule B5.1. 23


PART II

5

(3) Exhibit S-16.2, DTE Gas Company’s Response to Staff Audit Request CLC-1

8.1, is a two-page exhibit in which the Company responds to Staff’s question 2

related to known and measurable adjustments for MAOP Distribution Record 3

Remediation O&M expenses. 4



related to known and measurable adjustments for Transmission Fitting 7

Conversion O&M expenses. 8



related to known and measurable adjustments for Damage Prevention O&M 11

expenses. 12


19.1, is a one-page exhibit in which the Company responds to Staff’s question 14

related to known and measurable adjustments for Damage Prevention O&M 15

expenses. 16

(7) Exhibit S-16.6, DTE Gas Company’s Response to Discovery Request STDG-17

1.3C, is a 22-page exhibit in which the Company responds to Staff’s questions 18

related to Lost and Unaccounted for Gas (LAUF) related to mechanical damages. 19


2.2a, is a one-page exhibit in which the Company responds to Staff’s questions 21

related to contractor turn-key services for the MRP. 22


PART II

6


2.2b, is a one-page exhibit in which the Company responds to Staff’s questions 2

related to contractor turn-key services for the MRP. 3

(10) Exhibit S-16.9, DTE Gas Company’s Meter Assembly Check Progress 4

Reports, is a 15-page exhibit that includes three monthly progress reports for 5

meter assembly check inspections submitted to Staff: January 2019 report 6

containing 2018 cumulative data through December, January 2020 report 7

containing 2019 cumulative data through December, and February 2020 data 8

containing 2020 data through February. 9

(11) Exhibit S-16.10, DTE Gas Company’s Response to Staff Audit Request 10

CLC-17.1, is a one-page exhibit in which the Company responds to Staff’s 11

questions related to monthly surcharge amounts related to the Customer 12

Attachment Program. 13

(12) Exhibit S-16.11, Staff Comparison of Monthly Finance Charge Periods to 14

Annual Propane Savings, is a one-page exhibit summarizing Staff’s calculation of 15

customer payments and cost savings related to switching fuel service from 16

propane to natural gas. 17

(13) Exhibit S-16.12, DTE Gas Company’s Annual Report for Calendar Year 18

2018, Gas Distribution System (PHMSA Form 7100.1-1), is a four-page exhibit. 19

(14) Exhibit S-16.13, DTE Gas Company’s Annual Report for Calendar Year 20

2019, Gas Distribution System (PHMSA Form 7100.1-1), is a four-page exhibit. 21

(15) Exhibit S-16.14, Output from DTE Gas Company’s “Calculate Your 22

Potential Savings” website tool, is a 15-page exhibit that contains the output of 23


PART II

7

propane usage and price information inputted into the Company’s website tool 1

used for calculating savings when converting to natural gas from other fuel 2

sources. 3

(16) Exhibit S-16.15, MPSC’s State Heating Oil and Propane Price (SHOPP) 4

Report for 2019/2020, is a two-page exhibit that contains the raw data and chart 5

output as can be found on the MPSC website as of March 19, 2020. 6

(17) Exhibit S-16.16, Staking & Damage Prevention, is a seven-page exhibit, 7

which is a presentation provided to Staff at a meeting between MPSC and DTE 8

Staff on February 24, 2020. 9

DISTRIBUTION O&M EXPENSES 10

Q. Please briefly describe what the Company is proposing related to Distribution 11

O&M expenses. 12

A. As described in the direct testimony of Company witness Mark Johnson and as 13

shown in Company Exhibit A-13, Schedules C5 and C5.3, the Company is 14

proposing O&M expenditures of $125,099,000 related to Distribution in the test 15

year ending September 30, 2021. The Company arrived at the proposed test year 16

O&M expenses using the 2018 actual O&M expenses for each operational area 17

and then applying the Company’s inflation factors to derive adjustments for the 18

2019, 2020, and 9-months ending September 30, 2021 periods. The Company 19

also identified other known adjustments that would impact the test year O&M 20

expense levels. 21

Q. Does Staff propose any adjustments to the Company’s projected test year O&M 22

expense levels? 23


PART II

8

A. Yes. As presented in the testimony of Staff witness Brian Welke, Staff proposes 1

adjustments to the Company’s proposed O&M expense level based on inflation. 2

Staff further recommends that the projected test year O&M expense level related 3

to certain known factors outside of inflation should also be adjusted. 4

Q. Please describe the Company’s known and measurable adjustments included in 5

Distribution O&M expenses. 6

A. As described in the testimony of Company witness Mark Johnson, the Company 7

includes three categories of expenses: Maximum Allowable Operating Pressure 8

(MAOP) Distribution Record Remediation expenses of $3,000,000, Transmission 9

Fitting Conversion expenses of $300,000, and Damage Prevention expenses of 10

$1,500,000. 11

Q. Please describe Staff’s proposed adjustments related to MAOP Distribution 12

Record Remediation expenses. 13

A. In response to Staff Audit Request CLC-8.1, which is included as Exhibit S-16.2, 14

the Company identified $650,855 in test year expenses related to contingency. 15

Consistent with Staff’s position related to the recovery of contingency as 16

supported by Staff witness Joy Wang, the contingency amount of $650,855 17

should not be allowed for recovery in MAOP Record Remediation O&M 18

expenses. 19

Q. Please describe Staff’s proposed adjustments related to Transmission Fitting 20

Conversion expenses. 21

A. In response to Staff Audit Request CLC-8.2, which is included as Exhibit S-16.3, 22

the Company identified $73,167 in test year expenses related to contingency. 23


PART II

9

Consistent with Staff’s position related to the recovery of contingency as 1

supported by Staff witness Joy Wang, the contingency amount of $73,167 should 2

not be allowed for recovery in Transmission Fitting Conversion O&M expenses. 3

Q. Does Staff propose any adjustments to the $1,500,000 measurable adjustment to 4

Damage Prevention as presented in the testimony of Company witness Mark 5

Johnson? 6

A. No, Staff is generally supportive of DTE’s efforts to expand its damage 7

prevention team to effectively reduce the number of damages related to 8

excavation activities near the Company’s pipelines as outlined in the testimony of 9

Company witness Mark Johnson and as supported by Staff Audit Requests CLC-10

8.3 and CLC-19.1, which are included as Exhibits S-16.4 and S-16.5, 11

respectively. 12

Q. Does Staff propose any other adjustments to Damage Prevention expenses or 13

expenditures 14

Yes. Staff does propose adjustments related to costs incurred by the Company as 15

the result of excavation damages to its pipeline systems. Excavation damages to 16

pipelines are typically characterized into three categories: first-party damages 17

caused by the pipeline operator, second-party damages caused by a pipeline 18

operator’s contractor or other party working for the pipeline operator, and third-19

party damages caused by contractors, utility operators, or other persons engaged 20

in excavation activities near the pipeline but not working for or on behalf of the 21

pipeline operator. It is Staff’s position that the expansion of the Company’s 22

damage prevention activities should result in a decrease in the number of 23


PART II

10

excavation damages experienced on its pipeline system. Furthermore, Staff 1

opines that ratepayers should have limited responsibility for the subsidization of 2

damages that occur on the Company’s pipelines as a result of poor excavation 3

activities, particularly those caused by the Company itself or by excavators 4

performing work on behalf of the Company. Additionally, the Company has the 5

ability to directly bill for excavation damages where the damaging party is at 6

fault. 7

Q. Please describe efforts that the Company is undertaking to reduce the number of 8

excavation damages. 9

A. As shown in Staff Exhibit S-16.16, which is a presentation provided to MPSC 10

Staff during a routine communication meeting between MPSC pipeline safety and 11

Company Staff on February 24, 2020, the Company outlines activities that were 12

implemented in 2019, planned short-term and long-term activities, findings, and 13

performance. The Company outlines performance improvement achieved in 2019 14

as a result the measures taken to improve damage prevention performance, 15

including changes related to employee staffing, process changes, and education 16

and training in efforts to improve pipeline facility locating timeliness and quality 17

as well as increased communication with excavators and other stakeholders. As 18

shown on page 6 of Staff Exhibit S-16.16, the Company has realized a significant 19

improvement in the rate of excavation damages per number of pipeline facility 20

locate requests, or tickets, submitted to the Company. The Company’s Annual 21

Reports for Calendar Year 2018 and 2019, Gas Distribution System, are included 22

as Staff Exhibits S-16.12 and S-16.13. The reports show that the Company 23


PART II

11

1

2

3

4

5

6

7

8

9

10

experienced 1,608 excavation damages to pipeline facility and a total of 296,631

excavation tickets submitted in 2018, and comparatively the Company

experienced 1,344 excavation damages and a total of 336,297 excavation tickets

submitted in 2019. The increased number of excavation tickets submitted to the

Company is indicative of increased excavation activity near the Company’s

pipeline facilities. Despite the increased excavation activity, the Company was

able to achieve a reduction in the number damages to its pipeline facilities. Staff

anticipates that the performance enhancements realized in 2019 in addition to

activities planned in 2020 will result in further improvements to the number of

excavation damages experienced on the Company’s distribution system.

11

Q. Please describe Staff’s proposed adjustments related to Damage Prevention12

expenses and expenditures.13

A. As shown in the Company’s response to Staff Discovery Request STDG-1.3C,14

which is included as Exhibit S-16.6, Staff was seeking to determine if the15

Company had been appropriately billing excavators that were at fault for damage16

to its pipeline facilities. Staff requested information related to the number of17

mechanical damages on the system, specifically by first (Company), second18

(Company’s contractor), and third (Other contractor) party damages. The19

Company failed to provide the requested information in the manner requested but20

did however provide the total number of damages and average cost related to21

those damages for each year from 2016 through 2018 as well as 2019 through22

August. Based on the excavation damage costs provided for 2016 through 201823


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12

year average cost incurred related 1 (Staff Exhibit S-16.6), the Company has a three-

to excavation damages of $2,150,728. 2

Year Cost 3 2016 $2,182,203 4 2017 $2,102,840 5 2018 $2,167,141 6 3-Year Average $2,150,728 7

The Company should target a decrease in excavation damage costs that are 8

effectively passed on to the ratepayer. The excavation damage cost decreases 9

should be achieved through reduction in the number of excavation damages on the 10

pipeline system, reduction in the amount of unbilled or uncollected costs related 11

to at-fault third-party damages, and no recovery of first- and second-party 12

damages. Because the Company failed to respond with the specific information 13

requested by Staff, Staff was not able to quantify each of these reductions and 14

therefore proposes that the Company target a $500,000 reduction in excavation 15

damage costs in calendar year 2020 and a $1,000,000 reduction in 2021. 16

Additionally, since the Company’s response to Staff Discovery Request STDG-17

1.3C (Exhibit S-16.6) did not allocate the costs as capital expenditures or O&M 18

expenses, Staff further proposes that the adjustments of $500,000 in 2020 and 19

$1,000,000 in 2021 be allocated at 50% to O&M expenses and 50% to capital 20

expenditures. As shown in Staff Exhibit S-16.0, Staff recommends that the test 21

year O&M expenses related to excavation damages be reduced by $437,500, and 22

as shown in Staff Exhibit S-16.1, Staff also recommends that the Routine 23

Distribution capital expenditures related to excavation damages be reduced by 24


PART II

13

$187,500 in the nine months ending September 30, 2020, and by $437,500 in the 1

test year ending September 30, 2021. 2

INFRASTRUCTURE RECOVERY MECHANISM PROGRAMS 3

Q. Please describe the Company’s IRM. 4

A. DTE Gas received Commission approval in the April 16, 2013 Order in the 5

Company’s general rate case, MPSC Case No. U-16999, to implement the IRM to 6

recover capital investments related to its accelerated infrastructure replacement 7

and improvement programs. The programs included in the IRM are the Pipeline 8

Integrity program, the Main Renewal Program (MRP), and the Meter Move Out 9

(MMO) program with a combined annual capital expenditure of $77.4 million. 10

DTE received subsequent Commission approval in MPSC Case Nos. U-17701 11

and U-17999 to further expand its IRM, particularly related to the MRP. The 12

Company most recently received Commission approval in the September 13, 13

2018 order in the Company’s general rate case, MPSC Case No. U-18999, to 14

expand the IRM to include the MMO meter assembly check (MAC) program and 15

to further accelerate the MRP, with a total combined IRM expenditure level of 16

$223,820,000 for 2019, $247,120,000 for 2020 and $245,120,000 for 2021 17

through 2023. 18

Q. What is the Company proposing in this proceeding for 2021 through 2025 capital 19

expenditures in the programs included in the IRM? 20

A. As discussed in the direct testimony of Company witness Andrew Dewey and as 21

shown in Company Exhibit A-12, Schedule B5.2, the Company proposes IRM 22

capital expenditures of $282,720,000 annually in 2021 through 2025. The 23


PART II

14

Company is specifically proposing increases in capital expenditures in the MRP 1

with no increases proposed related to the MMO or Pipeline Integrity programs 2

and a reduction related to the MMO MAC for the periods included in the IRM. 3

Q. Does Staff support the Company’s proposal to include only test year period 4

capital expenditures through December 31, 2020, and to defer the test year period 5

expenditures through the remainder of the test year ending September 30, 2021 to 6

be recovered through the IRM? 7

A. Yes. Staff supports the Company’s proposal to include the test year expenditures 8

occurring in 2021 as part of the IRM so that the Company can operate the IRM on 9

a calendar year basis. 10

Q. Does Staff recommend any adjustments to the IRM capital expenditures for 2021 11

through 2025? 12

A. No. Staff does not propose adjustments to capital expenditures in the IRM 13

program years, as is also supported by the testimony of Staff witness Nathan 14

Miller for expenditures related to the Pipeline Integrity program. 15

Q. Does Staff recommend any adjustments to capital expenditures related to the 16

programs included in the IRM during the bridge or test year? 17

A. Yes, proposed adjustments to capital expenditures for the MRP and MMO in the 18

bridge and test years are discussed in the subsequent sections in my testimony. 19

Q. Please briefly describe the Company’s proposal in this proceeding related to IRM 20

flexibility. 21

A. As discussed in the testimony of Company witness Andrew Dewey, the Company 22

proposes that it be allowed to increase or decrease the expenditures for each 23


PART II

15

program by up to 3.2% of the total IRM capital expenditure of $282,700,000, 1

which results in a flexibility of $9,000,000. Further, the Commissioned ordered 2

in MPSC Case No. U-18999 that the MMO and MMO MAC programs should be 3

minimum spending levels; however, the Company in this proceeding requests that 4

the flexibility be applied across all programs if the MMO and MMO MAC targets 5

of inside meters impacted are achieved. 6

Q. Does Staff agree with the Company’s request related to the IRM flexibility?7

A. No. First, Staff disagrees that an underspend on MMO or MMO MAC is8

9

10

11

12

13

14

15

appropriate. Staff recommends that the approved capital expenditures amounts

for each program remain as minimum spend levels until the MAC inspection

backlog is eliminated and the Company has demonstrated adequate control of

MAC compliance going forward. Second, Staff recommends that the flexibility

limit for the IRM should not be calculated including the MMO and MMO MAC

programs. Therefore, Staff recommends that the IRM flexibility be set to 3.2% of

the combined MRP and Pipeline Integrity program capital expenditure level of

$243,520,000, which results in a flexibility limit of $7,792,640.16

1. Main Renewal Program17

Q. Please briefly describe the Company’s proposal related to the MRP.18

A. As discussed in the testimony of Company witness Andrew Dewey, the MRP is19

the Company’s long-term main renewal program that was initiated to reduce the20

amount of poor performing mains in the Company’s distribution system.21

Identified poor performing mains on the Company’s distribution system include22

cast and wrought iron mains, bare steel mains, and coated steel mains that are not23


PART II

16

cathodically-protected. As shown in Company Exhibit A-12, Schedule B5.1, the 1

Company is proposing capital expenditures for recovery in rate base related to the 2

MRP of $196,235,000 in 2019, $183,405,000 in the nine months ending 3

September 30, 2020, and $61,135,000 in the 12 months ending September 30, 4

2021. As shown in Company Exhibit A-12, Schedule B5.2, the Company is 5

proposing capital expenditures for recovery through the IRM surcharge related to 6

the MRP of $232,400,000 annually for 2021 through 2025. As shown in 7

Company Exhibit A-12, Schedule B6.2, and in Tables 2, 3, and 4 in the testimony 8

of Company witness Andrew Dewey, the Company projects to retire 207 miles 9

and install 220 miles in 2019 with a capital expenditure of $196,200,000, retire 10

230 miles and install 269 miles in 2020 with a capital expenditure of 11

$244,500,000, and retire 236 miles and install 279 miles annually in 2021 through 12

2025 with a capital expenditure of $232,400,000. In program year 2020, the 13

Company is implementing an expansion of the MRP from 178 miles of high-risk 14

main remediated to 206 miles annually as approved by the Commission in MPSC 15

Case No. U-18999, which included $2,000,000 related to one-time expansion 16

costs. The testimony of Company witness Andrew Dewey details increasing 17

contractors’ costs and other cost factors that impact the Company’s expenditure 18

levels as projected and approved in MPSC Case No. U-18999. 19

Q. Does Staff support the Company’s proposed level of capital expenditures related 20

to the MRP? 21

A. Staff recognizes the increasing contractor costs and other factors and is generally 22

supportive of an increase in capital expenditure level related to the MRP. Staff, 23


PART II

17

however, does not support the Company’s proposed recovery level for the 2020 1

calendar year. As is highlighted in the Company’s response to Staff Audit 2

Requests CLC-2.2a and CLC-2.2b, which are included as Staff Exhibits S-16.7 3

and S-16.8, the Company projected $9,000,000 related to MRP contracts to 4

complete the work related to 3,000 turn key services, but the actual contracted 5

costs were $3,900,000 for 1,692 turn key services. Additionally, the Company 6

indicates in response to Staff Audit Request CLC-15.1 that actual 2019 costs 7

related to the MRP were $200,200,000, or $4,000,000 more than projected in the 8

Company’s filed case. Staff recognizes that the Company has attempted to take 9

into consideration a myriad of factors to project the cost impact to the MRP in 10

2020 through 2025, but given the variability of the actual costs, Staff recommends 11

a more conservative approach related to the 2020 MRP capital expenditure 12

allowed for recovery in 2020. 13

Q. What adjustments does Staff recommend to the Company’s capital expenditures 14

for the MRP? 15

A. Staff recommends that the capital expenditure allowed for recovery be adjusted 16

based on the 2021 through 2025 projected MRP capital expenditures, to include 17

the $2,000,000 in one-time expansion costs for 2020. As shown in Staff Exhibit 18

S-16.1, Staff recommends a 2020 program year capital expenditure of 19

$234,400,000, with $175,799,250 in the nine months ending September 30, 2020, 20

and $58,599,750 in the 12 months ending September 30, 2021. 21

2. Meter Move Out and Meter Move Out - Meter Assembly Check Programs 22


PART II

18

Q. Please briefly describe the Company’s proposal related to the MMO and MMO 1

MAC programs. 2

A. As discussed in the testimony of Company witness Andrew Dewey, the MMO 3

and MMO MAC programs are accelerated meter move-out programs that remove 4

meters located inside residences or other structures through either relocation to an 5

outside location or abandonment of the service line and meter, where the MMO 6

MAC specifically targets inside meters that are overdue for required MAC 7

inspections. As shown in Company Exhibit A-12, Schedule B5.1, the Company is 8

proposing capital expenditures for recovery in rate base related to the MMO and 9

MMO MAC programs respectively of $24,441,000 and $15,115,000 in 2019, 10

$20,751,000 and $12,427,000 in the nine months ending September 30, 2020, and 11

$6,917,000 and $4,142,000 in the 12 months ending September 30, 2021. As 12

shown in Company Exhibit A-12, Schedules B5.2 and B6, the Company is 13

proposing capital expenditures for recovery through the IRM surcharge related to 14

the MMO and MMO MAC programs respectively of $22,700,000 and 15

$16,500,000 annually for 2021 through 2025. The Company projects to impact 16

12,790 inside meters through the MMO and 8,000 inside meters annually through 17

the MMO MAC in 2019 through 2025. Additionally, the Company has set targets 18

to impact meters through the MMO, MMO MAC, Routine Distribution, and MRP 19

programs to effectively eliminate inside meters from DTE’s distribution system 20

by 2028. 21

Q. Is Staff satisfied with the Company’s performance and goals related to the MMO 22

programs and the backlog of MAC inspections? 23


PART II

19

A. Yes. Staff has taken issue in the Company’s previous general rate cases related to 1

the Company’s ability to meet the target number of inside meters impacted 2

through the MMO as originally approved by the Commission in Case U-16999, as 3

well as the Company’s efforts to reduce the backlog of inside meters with overdue 4

MAC inspections1. The Company has complied with monthly MAC and MMO 5

reporting to Staff that demonstrates that the Company is committed and making 6

progress toward meeting targets of the MMO programs and reduction of the MAC 7

backlog. Staff is agreeable to the Company’s projection for completing meter 8

move out activities through the MMO and MMO MAC programs, the MRP, and 9

other routine distribution activities as discussed in the testimony of Company 10

witness Andrew Dewey and presented in Company Exhibit A-12, Schedule B6.3. 11

Staff recommends that the Company be required to continue providing monthly 12

MAC reporting to Staff until the MAC backlog is complete, and the Commission 13

finds it appropriate to remove the reporting requirement. 14

Q. Does Staff support the Company’s proposed level of capital expenditures related 15

to the MMO and MMO MAC programs? 16

A. No. Staff is supportive of the Company’s proposed capital expenditures related to 17

the MMO MAC program and recognizes that the Company has been able to 18

implement this program more cost efficiently than was originally projected in 19

Case No. U-18999. Staff, however, is not supportive of the Company’s proposed 20

capital expenditures related to the MMO program. The Company’s projected 21

1 See, for example, MPSC Case No. U-18999, 4 TR 1357-1364.


PART II

20

expenditures for 2020 are not consistent with the Company’s historical 1

performance for the program in 2018 or with its projected expenditures for 2019 2

and 2021 through 2025. As shown in the table below, which is based on 3

information provided in Company Exhibits A-12, Schedules B5.1, B5.2, and 4

B6.3, the cost per inside meter impacted through the MMO program was $2,020 5

in 2018 and is projected to be $1,911 in 2019, $2,163 in 2020, and $1,775 in 2021 6

through 2025. 7

Inside Unit Cost/ 8 Year Meters Capital Inside Meter 9 2018 12,126 $24,495,000 $2,020 10 2019 12,790 $24,441,000 $2,163 11 2020 12,790 $27,668,000 $1,911 12 2021-2025 12,790 $22,700,000 $1,775 13

Q. What adjustments does Staff recommend to the Company’s capital expenditures 14

for the MMO program? 15

A. Staff recommends that the capital expenditure allowed for recovery be adjusted 16

based on the 2018 actual unit cost per inside meter impacted in the MMO 17

program. As shown in Staff Exhibit S-16.1, Staff recommends a total 2020 18

calendar year capital expenditure of $25,835,800 based $2,020 per inside meter 19

impacted for 12,790 inside meters, with $19,376,850 in the nine months ending 20

September 30, 2020, and $6,458,950 in the 12 months ending September 30, 21

2021. 22

CUSTOMER ATTACHMENT PROGRAM 23

Q. Please briefly describe the Company’s proposed changes to Section C8.6 of its 24

Rate Book. 25


PART II

21

A. The Company proposes to modify its tariff related to the Fixed Monthly Charge 1

for the Customer Attachment Program. The Fixed Monthly Charge allows the 2

Company to offer the Fixed Monthly Surcharge as an alternative payment method 3

for the customer contribution of the revenue deficiency related to main and/or 4

service extensions. The Company proposes to modify the allowable period for 5

the Fixed Monthly Surcharge from 10 years to 20 years. 6

Q. Is Staff supportive of the Company’s proposal to increase the allowable period for 7

the Fixed Monthly Surcharge? 8

A. No, Staff disagrees with the Company’s proposal. In response to Staff Audit 9

Request CLC-17.1, which is included as Staff Exhibit S-16.10, the Company 10

provided monthly surcharge amounts for varying customer contribution amounts 11

from $1,000 to $10,000 over varying surcharge periods from 1 year to 20 years. 12

Staff then compared the total of the monthly surcharge payments over the 13

respective periods to the projected savings for a customer converting from 14

propane to natural gas using the Company’s online potential savings calculator2, 15

with varying propane usage from 750 gallons to 1,250 gallons to determine the 16

customer’s net cost savings over a 20-year period. Staff used a propane cost of 17

$1.81 per gallon, which is based on the peak price per the MPSC’s 2019/2020 18

SHOPP Report, Residential Heating Oil and Propane Price Comparison3. As 19

2 “Calculate Your Potential Savings” accessed from the Company’s website at https://newlook.dteenergy.com/wps/wcm/connect/dte-web/home/service-request/common/natural-gas/switching-to-natural-gas on March 11, 2020. Staff Exhibit S-16.14 contains data generated using the Company’s website tool on March 19, 2020. 3 The 2019/2020 SHOPP Report can be accessed from the MPSC website at https://www.michigan.gov/mpsc/0,9535,7-395-93308_93325_93424-510410--,00.html. Staff Exhibit S-16.15 contains data exported from the 2019/2020 SHOPP Report as of March 19, 2020.

https://newlook.dteenergy.com/wps/wcm/connect/dte-web/home/service-request/common/natural-gas/switching-to-natural-gas

https://newlook.dteenergy.com/wps/wcm/connect/dte-web/home/service-request/common/natural-gas/switching-to-natural-gas

https://www.michigan.gov/mpsc/0,9535,7-395-93308_93325_93424-510410--,00.html


PART II

22

shown in Staff Exhibit S-16.11, Staff found that in the scenario with a $10,000 1

customer contribution amount, where the monthly surcharge would likely be 2

considered cost prohibitive, the change in the monthly surcharge period from 10 3

years to 20 years significantly impacted the customer’s energy savings over the 4

20-year period. In scenarios where the customer’s fuel usage is based on 750 5

gallons of propane, the extended surcharge period would actually result in the 6

customer incurring an increase in costs over the 20-year period. Furthermore, 7

taking the propane season minimum price and seasonal average price into account 8

would result in greater negative impact on customers’ cost savings. Staff’s 9

comparison of customer costs and savings over the 20-year period does not take 10

into account any of the customer’s costs of switching to natural gas that are not 11

included in the customer contribution to the Company, such as appliance 12

conversion or purchases. Therefore, Staff recommends that the Company’s 13

request for modification of the allowable surcharge period be denied. 14


A. Yes, it does. 16

March 24, 2020



* * * * In the matter of the application of ) DTE Gas Company for authority to ) increase its rates, amend its rate schedule ) Case No. U-20642 and rules governing the distribution and ) supply of natural gas, and for ) miscellaneous accounting authority ) __________________________________________)


JAMES E. LA PAN


QUALIFICATIONS OF JAMES E. LA PAN CASE NUMBER U-20642

PART I

2

Q. Please state your name and business address. 1

A. My name is James E. LaPan and my business address is 7109 West Saginaw 2

Highway, Lansing, MI. 3

Q. Who are you currently employed by and in what position? 4

A. My employer is the Michigan Public Service Commission (MPSC or 5

Commission) and my job title is Public Utility Engineer. 6

Q. What are your responsibilities in your current position? 7

A. My current responsibilities consist of assisting with Staff’s analysis of natural gas 8

and electric utility depreciation rate case filings. This includes determining the 9

remaining book value of current assets, performing life and net salvage analysis, 10

and reviewing the terminal costs estimates associated with decommissioning 11

retired plants. Also, I assist with performing compliance and prudency reviews of 12

utility environmental response and remediation costs associated with historic 13

Manufactured Gas Plant (MGP) Facility remediation, as presented in utility 14

natural gas rate case filings. Furthermore, as requested, I am involved in studies 15

of all facilities in former and current natural gas and electric utility plants. Such 16

studies are conducted through on-site review and examination via walk-throughs, 17

along with interviews with Company subject matter expert personnel of each 18

facility as needed. Additional reviews of facility operations, environmental 19

compliance, asset retirement obligation, system and site integrity, and plant 20

demolition and decommissioning costs are also part of my duties. As requested, I 21

have provided technical presentations regarding specialized topics of interest; 22

most recently, this involved an internal Commission Staff training session where I 23


PART I

3

presented an explanation of the review criteria for MGP remediation activities and 1

costs and how compliance and prudence are determined. 2

Q. Would you please describe your educational background and work experience? 3

A. I earned a Bachelor of Science in Biosystems Engineering from Michigan State 4

University (MSU) in August 2006. Prior to attending MSU, I was in the honors 5

program at Delta College. 6

While attending Delta College, I was employed at the Delphi 7

Corporation as an engineering apprentice from May 2000 through August 2002. 8

During this apprenticeship, I worked with engineering professionals to address 9

technical issues, including state and federal regulatory compliance issues related 10

to onsite electric generation, hazardous material handling, and wastewater 11

treatment. I was directly involved in the activities surrounding the 12

decommissioning and demolition of Delphi’s Chassis Plant 2. I was also involved 13

in the development of several programs and operational procedures that dealt with 14

the capture and reuse of spent materials, in particular, waste sludge from Delphi’s 15

wastewater treatment facility. 16

After transferring to MSU, I was employed by the Statewide Planning 17

Section of the Michigan Department of Transportation (MDOT) in a student 18

assistant position from June 2005 through June 2006. My duties included 19

providing technical support for the implementation and assignment of federal 20

grant money under the Congestion Mitigation and Air Quality Control (CMAQ) 21

program for project proposals submitted. My assistance with the development of 22


PART I

4

modeling and forecasting programs was used to aid in the qualification, 1

quantification, and prioritization of those proposals. 2

Q. Have you attended any additional courses of study or any professional seminars? 3

A. Yes. I have regularly attended the annual meetings and attended the following 4

classes offered by the Society of Depreciation Professionals (SDP): “Depreciation 5

Basic,” “Life and Net Salvage Analysis,” “Analyzing the Life of Real-World 6

Property,” and “Preparing and Defending a Depreciation Study” in September 7

2012, September 2013, September 2014, and September 2015, respectively. I last 8

participated in annual training at the Society of Depreciation Professionals in 9

2017. While employed at the MPSC, I attended the Electric Utility Consultants, 10

Inc. (EUCI) annual conference on “Plant Retirement and Remediation: Mitigating 11

Risk, Cost and Liability of Deactivated Assets" and the Institute of Public Utilities 12

(IPU) advanced regulatory studies program. I last participated in annual training 13

seminars in depreciation of regulated utilities provided by the National 14

Association of Regulatory Utility Commissioners (NARUC) in 2018. In August 15

2006, I attended NARUC’s two-week training program for regulatory 16

professionals held each year on the campus of Michigan State University. 17

Q. Have you prepared testimony for any other proceedings? 18

A. Yes. I have prepared testimony for the following proceedings: 19

Case Number Company Subject/Type 20

U-15506 Consumers Energy Company Rate Case 21

U-15702 SEMCO Energy Gas Company GCR Plan Case 22

23


PART I

5

Case Number Company Subject/Type 1

U-15985 Michigan Consolidated Gas Company Rate Case 2

U-15896 Consumers Energy Gas Company Rate Case 3

U-16125 SEMCO Energy Gas Company Capacity Improvement 4

U-16117 Detroit Edison Depreciation Case 5


U-16054 Consumers Energy Company Depreciation Case 7

U-16055 Consumers Energy & Detroit Edison Depreciation Case 8

U-16801 Indiana Michigan Power Company Rate Case 9


U-16938 Consumers Energy Company Depreciation Case 11

U-16999 Michigan Consolidated Gas Company Rate Case 12

U-16991 DTE Electric Company Depreciation Case 13


U-17882 Consumers Energy Company Gas Rate Case 15



U-18452 SEMCO Energy Gas Company Depreciation Case 18

U-18467 UPPCo Depreciation Case 19

U-20118 DTE Gas Company Depreciation Case 20

U-20359 Indiana Michigan Power Company Depreciation Case 21

U-20479 SEMCO Energy Gas Company Gas Rate Case 22

DIRECT TESTIMONY OF JAMES E. LA PAN CASE NUMBER U-20642

PART II

6

Q. What is the purpose of your testimony? 1

A. The purpose of my testimony is to provide Staff’s recommendations regarding the 2

reasonableness and prudence of the environmental assessment and remediation 3

activities, and those associated incremental costs, at DTE Gas’s (DTE or 4

Company) former manufactured gas plant (MGP) facilities1 (site or property). I 5

will also offer recommendations regarding the declaration of a closure status of 6

the Company’s MGP sites. In addition, I will be supporting Staff’s 7

recommendation regarding change in future cost recovery for certain non-8

incremental, recurring costs. 9

Reasonableness and Prudence of MGP Costs. 10

Q. Has Staff found the Company’s remedial activities at its former MGP Facilities, 11

from August 2017 through July 2019, to be reasonable and prudent? 12

1 "Facility" means any area, place, parcel or parcels of property, or portion of a parcel of property where a hazardous substance in excess of the concentrations that satisfy the cleanup criteria for unrestricted residential use has been released, deposited, disposed of, or otherwise comes to be located. Facility does not include any area, place, parcel or parcels of property, or portion of a parcel of property where any of the following conditions are satisfied: (i) Response activities have been completed under this part or the comprehensive environmental response, compensation, and liability act, 42 USC 9601 to 9675, that satisfy the cleanup criteria for unrestricted residential use. (ii) Corrective action has been completed under the resource conservation and recovery act, 42 USC 6901 to 6992k, part 111, or part 213 that satisfies the cleanup criteria for unrestricted residential use. (iii) Site-specific criteria that have been approved by the department for application at the area, place, parcel of property, or portion of a parcel of property are met or satisfied and hazardous substances at the area, place, or property that are not addressed by site-specific criteria satisfy the cleanup criteria for unrestricted residential use. (iv) Hazardous substances in concentrations above unrestricted residential cleanup criteria are present due only to the placement, storage, or use of beneficial use by-products or inert materials at the area, place, or property in compliance with part 115. (v) The property has been lawfully split, subdivided, or divided from a facility and does not contain hazardous substances in excess of concentrations that satisfy the cleanup criteria for unrestricted residential use. (vi) Natural attenuation or other natural processes have reduced concentrations of hazardous substances to levels at or below the cleanup criteria for unrestricted residential use. Natural Resources and Environmental Protection Act, Act 451 of 1994, MCL 324.20101


PART II

7

A. Yes. Staff found that during this timeframe, from August 2017 through July 1

2019, the Company continued to successfully advance their site closure plans 2

which consist of reaching the required level of cleanup at each historic MGP site, 3

in the most cost-effective way. The Company’s environmental assessment and 4

remediation activities were reasonable and prudent. 5

Q. What are the costs associated with the environmental assessment and remediation 6

activities performed by DTE Gas at their former MGP sites between August 2017 7

and July 2019? 8

A. Referring to page four of the Company’s Exhibit A-13, Schedule C13, the 9

Company is requesting recovery of $23,014,727 for the assessment and 10

remediation performed at its MGP sites from August 2017 through July 2019. 11

Q. What is Staff’s recommendation regarding the Company’s request for recovery of 12

these environmental and remediation expenses? 13

A. Staff recommends the Commission find that these costs were reasonably and 14

prudently incurred by the Company for site assessment, mitigation of risk, and for 15

the remediation of their historic MGP sites. 16

Q. Did Staff determine the cleanup criteria at each site? 17

A. No. Regulatory oversite on the cleanup criteria falls within the responsibilities of 18

Michigan’s Department of Energy, Great Lakes, and Environment (EGLE) and 19

the level of cleanup obtained at each site is determined by the Company. 20

Commission Staff responsibility lies solely with a determination whether the 21

remedial activities were performed in the most prudent and cost-effective manner. 22

Declaration of Closure Status 23


PART II

8

Q. The Company’s Exhibit A-13, Schedule C13, page 3, indicates that it has been 1

performing remedial activities at its historic MGP sites for more than 35 years. 2

Will the Company be able to reach closure at each facility? 3

A. The Company has worked closely with EGLE and Staff to produce a level of 4

transparency and understanding of its closure strategies at its former MGP sites. 5

DTE Gas has a strategy that will ultimately address all hazards and/or potential 6

exposure pathways and thus qualify for a No Further Action (NFA) designation 7

from the Michigan Department of EGLE for each MGP property listed on page 2 8

of the Company’s Exhibit A-13, Schedule C13. 9

Recommendation for Future Change in Recovery of Non-incremental Recurring 10

Costs. 11

Q. What are non-incremental and recurring costs at MGP sites? 12

A. Non-incremental and recurring costs are related to the ongoing monitoring and 13

reporting at a MGP site which occur either after a determination is made to close 14

the site, or when the site receives an NFA designation by EGLE. 15

Q. Please explain what Staff considers to be non-incremental and recurring? 16

A. Examples would be costs associated with the long-term remediation activities that 17

are conducted on-site, which are intended to mitigate particular site hazards at a 18

steady pace over a long period of time. These types of activities also have more 19

predictable and measurable costs associated with them; they are recurring costs 20

that are non-incremental. Similarly, any post-closure care, maintenance, sampling 21

and/or reporting requirements at a site are typically recurring costs that are also, 22

not “extraordinary”. 23


PART II

9

1

Q. Do these costs represent a significant portion of expenses incurred at MGP sites? 2

A. No. These types of costs are comparatively smaller and more likely associated 3

with the ongoing monitoring and reporting (e.g. groundwater and surface water) 4

as well as other routine maintenance possibly required as a condition of NFA 5

approval. 6

Q. Do ongoing monitoring and reporting costs originate from the Company’s 7

obligation as a responsible party of a Part 201 Facility? 8

A. Costs of monitoring and reporting may have originated from the obligation of 9

mitigating risks associated with MGP impacts. 10

Q. What are incremental costs? 11

A. Incremental costs are non-recurring and considered unusual and extraordinary 12

costs associated with initial investigation and remediation activities. These types 13

of costs represent the largest and most significant cost at former MGP sites. 14

Q. What specific regulatory recovery policy did the Commission create relative to 15

recovery of MGP remediation costs? 16

A. The Commission’s order in MPSC Case No. U-10630 distinguished between 17

unique and extraordinary, or incremental costs, providing, 18

19 costs associated with the assessment and remediation of environmental 20

contamination arising from the operation of a manufactured gas plant are 21 unique, extraordinary costs, which may not be exclusively categorized as 22 either utility operating costs or non-utility operating costs. April 13, 1995 23 Order, p 10. 24

25


PART II

10

Additionally, the Commission pointed out in its order in MPSC Case Nos. U-1

10149 and U-10150 that deferral and amortization of the related environmental 2

assessment and remediation expenses would ultimately incentivize the Company 3

to contain its costs for those activities. The Commission explained that “the 4

potential harm to the utility’s shareholders’, as well as the incentive arising from 5

it, is effectively eliminated by authorizing the utility to use deferred accounting 6

for these costs.” October 28, 1993 Order, pp 143-144. Prior to this, the 7

Commission explained that 8

9

Absent the accounting authority sought in this proceeding, the utility would be 10 required to expense all assessment and remediation costs on an annual basis as 11 incurred. This requirement would have provided Mich Con with a strong 12 incentive to minimize its costs in an attempt to protect its shareholders. 13 However, the potential harm to the utility’s shareholders, as well as the 14 incentive arising from it, is effectively eliminated by authorizing the utility to 15 use deferred accounting for these costs. Id. at 143. 16

17

The quote above speaks to the Company’s incentive to minimize spending on 18

environmental assessment and remediation, because without the authority to use 19

deferred accounting, those costs would have to be expensed resulting in a cost 20

against shareholders. The authority to utilize deferred accounting “effectively 21

eliminated” that incentive to underspend on these categories. However, in that 22

same order, the Commission approved Staff’s proposed accounting treatment of 23

the carrying costs, which only allowed for recovery after a prudency review in a 24

subsequent rate case, stating that 25

26


PART II

11

Staff’s proposal is an attempt to reestablish that incentive, at least in part, by 1 precluding carrying charges from accruing on each vintage year’s accounts 2 between rate cases. The Commission finds that the Staff’s proposal is 3 reasonable… Id. at 144. 4

5

Therefore, the accounting authority approved by the Commission in Case Nos. U-6

10149 and U-10150 mitigated the potential harm to the Company’s shareholders 7

from annual expensing of environmental assessment and remediation costs, and 8

therefore eliminated the incentive to underspend. At the same time, the 9

Commission placed a check on the potential for overspending by only allowing 10

for accrual of carrying charges once the Company’s environmental assessment 11

and remediation costs underwent a thorough prudency and reasonableness review 12

in subsequent rate cases. 13

14

Additionally, the Commission distinguished that incremental costs are eligible for 15

deferral and amortization recovery of MGP expenses in its April 28, 2005 Order 16

in Case No. U-13898, U-13899, page 23 through page 31. Specifically, the 17

Commission agreed with Staff “that the deferral and amortization of MGP 18

expenses relates only to incremental costs.” The Commission further states: 19

20 As with Mich Con’s use of in-house legal counsel in relation to the insurance 21 recoveries, the Commission finds that use of in-house employees is not an 22 “incremental” MGP cost that is eligible for the unusual and extraordinary 23 treatment that the Commission has permitted for MGP costs. Id., p. 28 24

25

Q. Is the Staff recommendation distinguishing between incremental and non-26

incremental costs? And what change is staff proposing? 27


PART II

12

A. Yes. In future cases, Staff is proposing the company recover the non-incremental 1

recurring costs for routine monitoring and reporting and other operations and 2

maintenance activities, in operations and maintenance (O&M) expenses, rather 3

than by deferral and amortization method more appropriate for extraordinary 4

incremental expenses. 5

Q. Please explain what staff considers to be incremental costs? 6

A. Examples of this would be the remedial activities conducted to rectify the hazards 7

at an MGP Facility which consist of the investigation and assessment2 and the 8

removal or remediation3 activities. Incremental costs related to environmental 9

assessments could include, in some instances, interim remedial action as well as 10

site-specific delineation and the engineering or development of a feasibility study. 11

Incremental costs would be the remediation activities to remove or abate the 12

threat to human health and the environment. 13

Q. Please explain Staff’s recommendation regarding the future recovery of non-14

incremental costs incurred at a Company’s Part 201 MGP Facility. 15

A. Based on longstanding Commission directives and policy, Staff recommends that 16

costs that arise from environmental remediation activities at a Part 201 Facility 17

that are recurring and long lasting (i.e. non incremental) are more appropriately 18

recovered elsewhere in the Company’s rates. More specifically, Staff 19

recommends that the known, measurable, and recurring costs associated with the 20

maintenance and continued operation of a long-term treatment system at a Part 21

2 Commission Order Case No. U-10149, U-10150, dated 10-28-93, page144 3 Commission Order Case No. U-8635, dated 12-22-88, page 32; Act 451 of 1994


PART II

13

201 Facility be determined to be non-incremental and thus recovered as a typical 1

operation and maintenance (O&M) expense beginning August 2019. 2

Q. Please explain Staff’s recommendation regarding the treatment of costs incurred 3

for environmental investigation and remediation at any of the Company’s 4

properties which are not designated as a Part 201 Facility, that have received an 5

approved Remedial Action Plan (RAP) or No Further Action (NFA), in part or 6

site wide, designation by EGLE or that is considered closed by the Company. 7

A. Staff recommends that costs incurred at an environmentally contaminated site that 8

is not designated as a Facility, under Environmental Remediation, MCL 9

324.20101 et seq., Part 201 of the Natural Resources and Environmental 10

Protection Act (NREPA), Act 451 of 1994, that has already received and 11

approved RAP or NFA, or that is not considered closed, not be recovered through 12

the Commission’s stated policy regarding recovery of MGP expenses. 13

Q. Does this include any MGP Holder site the Company and Staff have agreed the 14

Company has no further due care obligations at? 15

A. Yes, this includes any site that is considered a Part 201 Facility as well as any site 16

that the Company has considered either closed or not an MGP Facility. Sites 17

considered closed by the Company can been seen on Company Exhibit A-13, 18

Schedule C13, page 2, column (c). 19

Q. Does this complete your testimony? 20

A. Yes, it does. 21

March 24, 2020



* * * * In the matter of the application of ) DTE GAS COMPANY for authority ) to increase its rates, amend its rate ) Case No. U-20642 schedules and rules governing the ) distribution and supply of natural gas, ) and for miscellaneous accounting authority ) __________________________________________)


NATHAN J. MILLER


QUALIFICATIONS OF NATHAN J. MILLER CASE NUMBER U-20642

PART I

1

Q. Please state your name, address, and occupation. 1

A. My name is Nathan J. Miller, and my business address is 7109 West Saginaw 2

Highway, Lansing, Michigan 48917. I am employed by the Michigan Public 3

Service Commission (MPSC or Commission) as a Supervisor in the Gas 4

Operations Section of the Energy Operations Division. 5

Q. Please briefly describe your educational background and work experience. 6

A. I earned a Bachelor of Science degree in Civil Engineering from Michigan 7

Technological University in 2008 and my professional engineering license in 8

2015. Prior to the MPSC, I was employed in the transportation industry by 9

Wilbur Smith Associates as a Transportation Engineer, responsible for the design 10

of highway facilities and for generating the cost-estimates. I began employment 11

with the MPSC in July 2011 as a Gas Safety Engineer, and completed the 12

following courses with the Pipeline and Hazardous Materials Safety 13

Administration (PHMSA) Inspector Training & Qualifications Division during 14

that time: 1) Safety Evaluation of Gas Pipeline Systems Course; 2) Pipeline 15

Safety Regulation Application and Compliance Procedures Course; 3) Pipeline 16

Failure Investigation Techniques Course; 4) Corrosion Control of Pipeline 17

Systems Course; 5) Welding and Welding Inspection of Pipeline Materials 18

Course; 6) Gas Pressure Regulation and Overpressure Protection Course; 7) 19

Plastic and Composite Materials Course; 8) Root Cause/Incident Investigation 20

Course; 9) Fundamentals of (SCADA) System Technology and Operation Course; 21

10) Safety Evaluation of Distribution Integrity Management Programs (DIMP) 22

Course; 11) External Corrosion Direct Assessment (ECDA) Field Course; 12) 23


PART I

2

Safety Evaluation of Inline Inspection (ILI)/Pigging Programs Course; 13) 1

Fundamentals of Integrity Management Course; 14) Gas Integrity Management 2

(IM) Protocol Course; and 15) Operator Qualifications Course. Additionally, I 3

received Level 1 accreditation for inspecting the coating and cathodic protection 4

of buried pipelines using DC Voltage Gradient Technology (DCVG) and Close 5

Interval Potential Survey (CIS). My responsibilities as a Gas Safety Engineer 6

were reviewing pipeline operator’s systems for compliance with the Michigan 7

Gas Safety Standards (MGSS). This included: 1) Design; 2) Welding; 3) 8

Construction; 4) Pressure Control; 5) Corrosion Control; 6) Pressure Testing; 7) 9

Operations; 8) Maintenance; 9) Operation Qualification; and 10) Incident 10

Investigation. Eventually, my responsibilities increased and included statewide 11

responsibility for inspecting the Transmission and Distribution Integrity 12

Management Programs established by pipeline operators. These regulations 13

represented the first major performance and risk-based gas safety regulations 14

adopted by PHMSA and, by association, the Commission’s Gas Safety Standards. 15

Audits included inspection for compliance with the regulations and referenced 16

industry standards. An integral component of both Transmission and Distribution 17

Integrity Management Programs is the development of a comprehensive risk 18

assessment program for pipe segments that assesses the likelihood of failure for 19

individual threats and associated potential consequences. 20

I departed the Michigan Public Service Commission in August 2015 and 21

assumed a position of Staff Engineer at DTE Energy as a member of the 22

Transmission Integrity Management group. Responsibilities included: 1) 23


PART I

3

enhancing the risk assessment program; 2) correlating risk results to preventive 1

and mitigative measures; 3) conducting inline inspections; and 4) developing 2

standards for process improvement. Additionally, I assisted the Distribution 3

Integrity Management group by identifying program gaps and implementing 4

corrective actions to ensure compliance with the regulations. Lastly, I have 5

attended various workshops on risk assessment methodologies and inline 6

inspection defect analysis. 7

I returned to the Michigan Public Service Commission in December 2016 8

as Supervisor of the Gas Safety and Infrastructure Unit of the Gas Operations 9

Section, my current position. My responsibilities include directing, coordinating, 10

and supervising programs, activities, and staff. Programs are related to Michigan 11

Gas Safety Standards, gas infrastructure improvements, gas utility capital 12

spending, gas utility operations and maintenance spending, gas infrastructure 13

replacement plans and reconciliations, customer attachment programs, natural gas 14

utility certificates of public convenience and necessity (Act 69 of 1929), well 15

connection permits, gas production records, and siting for natural gas facilities 16

(Act 9 of 1929), liquid facilities (Act 16 of 1929), and natural gas storage (Act 17

238 of 1923). 18

Q. Have you participated in any other cases before the Commission prior to this 19

proceeding? 20

A. Yes, I have assisted in the development of Staff’s position or exhibits in the 21

following cases: 22


PART I

4


U-16280 Toro Energy waiver of compliance 2


U-17643 Consumers Energy gas rate case 4

U-17701 DTE Gas Company main replacement program 5

U-18166 Consumers Energy Saginaw Trail Pipeline 6

U-18200 Savoy Columbia 36 Pipeline 7

U-18202 SEMCO Energy Marquette Connector Pipeline 8

U-20198 Zeeland Farm Services Ithaca, LLC Act 9 case 9

U-20322 Consumers Energy Rate Case 10

U-20479 SEMCO Energy Rate Case 11

Q. Have you filed testimony before the Commission in any of the aforementioned 12

cases? 13

A. Yes, I have filed testimony before the Commission in the following cases: 14


U-18166 Consumers Energy Saginaw Trail Pipeline 16

U-18200 Savoy Columbia 36 Pipeline 17

U-18202 SEMCO Energy Marquette Connector Pipeline 18



U-20479 SEMCO Energy Rate Case 21

DIRECT TESTIMONY OF NATHAN J. MILLER CASE NUMBER U-20642

PART II

5


A. The purpose of my testimony is to present a portion of the Michigan Public 2

Service Commission Staff’s (Staff) positions and recommendations regarding 3

DTE Gas Company’s (DTE or the Company) request for rate relief in the 4

following areas: 5

(1) Routine Transmission Plant Capital Expenditures 6

(2) Routine Storage Plant Capital Expenditures 7

(3) Other Capital Project Expenditures 8

(4) Infrastructure Recovery Mechanism Capital Expenditures (Pipeline 9

Integrity) 10

(5) Natural Gas Storage Operation and Maintenance Expenses 11

(6) Transmission Operation and Maintenance Expenses 12

(7) Staff General Recommendations 13

(8) Staff General Concerns 14

Q. Are you sponsoring any exhibits in this proceeding? 15

A. Yes. I am sponsoring the following exhibits: 16

(1) Exhibit S-7.01, Staff’s Capital Adjustments, is a one-page exhibit that 17

provides for this testimony’s adjustments to the Company Exhibit A-12, 18

Schedule B5.1. 19

(2) Exhibit S-7.02, Company’s Response to Discovery Request STDG-1.12, is 20

a two-page exhibit that provides for the capital expenditures associated 21

with the Quality Assurance Program. 22


PART II

6


a one-page exhibit providing the Company’s response to a request for the 2

USofA account numbers associated with the “BRM Unit #4 Engine 3

Rebuild.” 4

(4) Exhibit S-7.04, Michigan Public Service Commission Gas Safety Staff 5

Non-Compliance 407141, is a four-page exhibit that identifies a probable 6

violation of the Michigan Gas Safety Standards associated with the 7

Company’s Milford Junction Loop project and the Company’s associated 8

response. 9


a one-page exhibit that provides for the capital expenditures associated 11

with Non-Compliance 407141. 12


a four-page exhibit associated with the DTE Gas Site Security Program. 14

(7) Exhibit S-7.07, Excerpt from MPSC Case No. U-20640, is a one-page 15

exhibit that presents the Company’s cost estimate associated with the 16

Lincoln-Traverse City Pipeline Loop Act 9 filing. 17

(8) Exhibit S-7.08, Excerpt from MPSC Case No. U-20641, is a one-page 18

exhibit that presents the Company’s cost estimate associated with the 19

Frankfort Pipeline Loop Act 9 filing. 20


a three-page exhibit that provides the Company’s explanation regarding 22


PART II

7

differences between the cost estimates for the TCARP between this instant 1

case and the associated Act 9 filings. 2

(10) Exhibit S-7.10, Company’s Response to Discovery Request STDG-1.19, 3

is a one-page exhibit that identifies the cost estimate for the Van Born 4

Project commensurate with what would be filed in an Act 9 proceeding. 5


a seven-page exhibit providing the Company’s response to a request for 7

how five known and measurable adjustments in the Transmission Expense 8

category were determined. 9


a two-page exhibit providing the Company’s response to a request for how 11

gas released at compressor stations during an emergency shutdown is 12

accounted for. 13


a one-page exhibit providing the Company’s response to a request for the 15

USofA account numbers associated with sub-programs of the Company’s 16

Pipeline Integrity Management Program. 17

(14) Exhibit S-7.14, Uniform System of Accounts, is a 142-page exhibit 18

providing the Uniform System of Accounts Prescribed for Natural Gas 19

Companies Subject to the Provision of the Natural Gas Act. 20


a two-page exhibit providing the Company’s response to a request for how 22


PART II

8

the O&M associated with the expansion of integrity assessments in 1

Medium Consequence Areas was determined. 2

(16) Exhibit S-7.16, Company’s Responses to Discovery Request STDG-6.5 3

through STDG-6.8, is a six-page exhibit providing the Company’s 4

response to a request for how specific line items were calculated for 5

several In-Line Inspection Expansion Projects and for the Southfield 24” 6

Pipe Replacement. 7


a two-page exhibit providing the Company’s response to the increase in 9

the number of actionable anomalies detected due to advances in 10

technology used to perform assessments. 11

Q. Will this testimony be proposing any adjustments to contingency expenditures? 12

A. No. Staff’s recommended contingency adjustments will be detailed in the direct 13

testimony of Staff Witness Joy H. Wang. Any adjustments in this testimony will 14

not be inclusive of contingency amounts. 15

Q. Will this testimony be proposing any capital expenditure inflation adjustments? 16

A. Yes. Where applicable, adjustments will use the inflation factors sponsored in the 17

direct testimony of Staff Witness Joe E. Ufolla. 18

Q. Will this testimony be proposing any operation and maintenance expense inflation 19

adjustments? 20

A. No. All operation and maintenance expense inflation adjustments will be 21

included in the direct testimony of Staff Witness Brian Welke. 22


PART II

9

(1) Routine Transmission Plant Capital Expenditures 1

Q. Does Staff propose any adjustments to the historical Routine Transmission Plant 2

capital expenditures that the Company incurred from January 1, 2018, through 3

December 31, 2018? 4

A. Based on the information currently available, this testimony is not proposing any 5

adjustments to the historical capital expenditures for this program at this time. 6

Q. Does Staff propose any adjustments to the projected Routine Transmission Plant 7

capital expenditures that the Company is incurring from January 1, 2019, through 8

September 30, 2021? 9

A. Yes. As described in Lines 3-9 on Page 19 of the direct testimony of Company 10

Witness Alida D. Sandberg: 11

The Sales and Use tax and River Rouge Insurance Recovery credits in the 12 historical five-year calculation result in the appearance of increased 13 projected capital expenditures in this proceeding. The Sales and Use tax 14 and River Rouge insurance recovery credits were one-time credits applied 15 in case U-18999. Otherwise, Transmission Plant capital expenditures 16 excluding the Sales and Use tax and River Rouge Insurance Recovery 17 credit is expected to remain consistent with the five-year historical capital 18 spend level, respectively. 19

However, the amounts reflected in Company Exhibit A-12, Schedule B5.1, Page 20

1, Line 2 for the projected bridge year and projected test year are not “consistent 21

with the five-year historical capital spend level” once the Sales and Use tax and 22

River Rouge Insurance Recovery is excluded. Rather, there is a 49.21% increase 23

from the five-year average from 2014-2018 (column (b)) to the projected test year 24

(column (g)). It is Staff’s understanding that a portion of this increase is due to 25

the Quality Assurance Program that is proposed in Lines 22-25 on Page 7 and 26


PART II

10

Lines 1-2 on Page 8 of the direct testimony of Company Witness Alida D. 1

Sandberg, which states that: 2

From August 2019 through September 30, 2021, the end of the projected 3 test year, DTE Gas will have incurred $3.1 million of quality assurance 4 capital expenditures. Expenditures are projected to be $0.6 million in 5 2019, $1.7 million in 2020, and $1.0 million in 2021. These expenditures 6 are allocated 30% for distribution plant and 70% for transmission plant 7 and are included on Exhibit A-12, Schedule B5.1, line 1, columns (f) and 8 (g), and line 2, columns (f) and (g). 9

Staff’s Discovery Request STDG 1.12 (Refer to Staff Exhibit S-7.02) illustrates 10

the Quality Assurance Program expenditures in the projected bridge and test 11

years. A summary of these expenses, along with the allocation for distribution 12

and transmission plant, is illustrated in Table 1. 13

Table 1: Quality Assurance Capital Expenditures 14

15

Staff is supportive of the Company’s efforts to implement a more rigorous Quality 16

Assurance Program, but seeks to align the projected bridge year and projected test 17

year capital expenditures with the five-year historical capital spend level (as 18

specified in the direct testimony of Company Witness Alida D. Sandberg). Staff 19

therefore proposes that Routine Transmission Plant be adjusted for inflation based 20

on the amount spent for the five-year average from 2014-2018 (after excluding 21

the Sales & Use Tax Settlement). According to Line 2, Column (b) on Page 1 of 22

Company Exhibit A-12, Schedule B5.1, this amount is $5,972,000. Therefore, 23

Projected Test Year

2019 Projected9 Mos Ending 09/30/2020

12 Mos Ending 09/30/2021

Distribution Plant $180,000 $390,000 $360,000 $930,000Transmission Plant $420,000 $910,000 $840,000 $2,170,000Total Capital Expenditures $600,000 $1,300,000 $1,200,000 $3,100,000

Projected Bridge YearQuality Assurance Capital Expenditures

Total QA Program Cost


PART II

11

without factoring in the Quality Assurance Program (which will be added later), 1

Staff calculates capital expenditures for Routine Transmission Plant in the amount 2

of $6,080,000 for the 12 months ending December 31, 2019, $6,171,000 for the 9 3

months ending September 30, 2020, and $6,299,000 for the test year ending 4

September 30, 2021. Once the capital expenditures for the Quality Assurance 5

Program are included, this results in capital expenditures for Routine 6

Transmission Plant in the amount of $6,500,000 for the 12 months ending 7

December 31, 2019, $7,081,000 for the 9 months ending September 30, 2020, and 8

$7,139,000 for the test year ending September 30, 2021. This results in a 9

downward adjustment of $1,947,000, an upward adjustment of $657,000, and a 10

downward adjustment of $1,773,000, respectively. Refer to Line 2 in Staff 11

Exhibit S-7.01. 12

(2) Routine Storage Plant Capital Expenditures 13

Q. Does Staff propose any adjustments to the historical Routine Storage Plant capital 14

expenditures that the Company incurred from January 1, 2018, through December 15

31, 2018? 16



Q. Does Staff propose any adjustments to the projected Routine Storage Plant capital 19

expenditures that the Company is incurring from January 1, 2019, through 20


A. No. However, Staff does have recommendations to the Commission regarding 22

the Company’s practice of capitalizing what are identified as maintenance 23


PART II

12

expenses. Particularly, Staff’s recommendation is based on the Company 1

capitalizing the “BRM Unit #4 Engine Rebuild” project, as referenced in Lines 6-2

10 on Page 21 of the direct testimony of Company Witness Alida D. Sandberg: 3

Two of the storage plant projects have expenditures large enough to fall 4 into DTE Gas’s highest cost projects and are supported in detail in Exhibit 5 A-12, Schedule B5.3 DTE Gas Highest Cost Top 25 Capital Projects. 6 Specifically, the projects are Belle River and Columbus Valve Upgrade 7 project and BRM Unit 4 Engine Rebuild. 8

However, Company Exhibit A-12, Schedule B5.3 identifies the “BRM Unit #4 9

Engine Rebuild” as a maintenance expense: 10

To complete major maintenance per the manufacturers' recommended 11 schedule (prior to 25,000 hours of runtime since last rebuild). This will 12 help ensure engine operational reliability. 13

* * * 14 Evaluation and rebuild, as necessary, of all major components on the 15

engine and major auxiliary units. 16 * * * 17 Following manufacturer recommendations will ensure unit reliability for 18

Midstream sales and Gas Control winter and summer needs. 19

The Federal Energy Regulatory Commission (FERC) provides a Uniform System 20

of Accounts (USofA) to ensure accurate and consistent accounting for 21

jurisdictional companies. As part of the USofA, accounting codes are provided 22

with instructions on what expenditures are appropriate to be assigned to such 23

accounts. Staff, in Discovery Request STDG-6.3 (Refer to Staff Exhibit S-7.03), 24

requested the “account number that this [BRM Unit #4 Engine Rebuild] project is 25

associated with in the Uniform System of Accounts Prescribed for Natural Gas 26

Companies.” The Company response stated, “Underground Storage Plant - 27

Compressor Station Equipment (Account 354).” 28


PART II

13

Account 354’s instructions state: 1

This account shall include the cost installed of compressor station 2 equipment used wholly or predominantly for the purpose of raising the 3 pressure of gas for delivery to underground storage or to raise the pressure 4 of gas withdrawn from underground storage for delivery to the 5 transmission or distribution system. 6

The engine that was rebuilt as part of this project would have already been 7

included as gas plant when it was originally installed and the inclusion of 8

maintenance tasks in Account 354 are inappropriate. The USofA provides a 9

maintenance account for the type of activity that the Company performed; 10

Account 834 entitled “Maintenance of compressor station equipment.” The 11

instructions for Account 834 states: 12

This account shall include the cost of labor, materials used and expenses 13 incurred in the maintenance of equipment, the book cost of which is 14 includible in account 354, Compressor Station Equipment. (See operating 15 expense instruction 2.) 16

The referenced “operating expense instruction 2” states in part: 17

The cost of maintenance chargeable to the various operating expense and 18 clearing accounts, includes labor, materials, overheads and other expenses 19 incurred in maintenance work. A list of work operations applicable 20 generally to utility plant is included hereunder. 21

* * * 22 2. Inspecting, testing, and reporting on condition of plant specifically to 23

determine the need for repairs, replacements, rearrangements and changes 24 and inspecting and testing the adequacy of repairs which have been made. 25

3. Work performed specifically for the purpose of preventing failure, 26 restoring serviceability or maintaining life of plant. 27


PART II

14

The following parallels exist between the work that the Company performed for 1

the “BRM Unit #4 Engine Rebuild” and the instructions for Account 834. 2

• Company: “[e]valuation and rebuild, as necessary….” 3

Account 834: “[i]nspecting, testing, and reporting on condition of 4 plant specifically to determine the need for repairs” 5

• Company: “… ensure unit reliability for Midstream sales and Gas 6 Control winter and summer needs.” 7

Account 834: “[w]ork performed specifically for the purpose of 8 preventing failure, restoring serviceability or maintaining life of plant” 9

The similarities between the work that the Company performed and the 10

instructions for Account 834 are obvious and lead Staff to the recommendation 11

that the Commission direct the Company to review the projects that it identifies as 12

capital projects to ensure that they are aligned with the accounting practices 13

specified by the USofA, commensurate with the Commission Order in MPSC 14

Case No. U-14811. Due to the timing of this instant case and the availability of 15

information that Staff had available as of the filing of this testimony, Staff does 16

not recommend a disallowance of the “BRM Unit #4 Engine Rebuild” capital 17

expenditures at this time. However, misclassifications of maintenance work will 18

be investigated in future rate cases and adjustments made accordingly. 19

(3) Other Capital Project Expenditures 20

Nexus 21

Q. Does Staff propose any adjustments to the historical Nexus capital expenditures 22

that the Company incurred from January 1, 2018, through December 31, 2018? 23


PART II

15



Q. Does Staff propose any adjustments to the projected Nexus capital expenditures 3

that the Company is incurring from January 1, 2019, through September 30, 4

2021? 5


adjustments to the projected capital expenditures for this program at this time. 7

Milford Junction Loop 8

Q. Does Staff propose any adjustments to the historical Milford Junction Loop 9


December 31, 2018? 11



Q. Does Staff propose any adjustments to the projected Milford Junction Loop 14



A. Yes. On October 10, 2017, MPSC Gas Safety Staff issued Non-Compliance 17

407141 to the Company for a failure on its part to perform adequate pressure 18

testing on the facilities that were being constructed at the Milford Compressor 19

Station (Refer to Staff Exhibit S-7.04). The Company pressure-tested many of the 20

components that were to be installed at the compressor station at a remote 21

location and then cut up those components to facilitate easier transportation to the 22

final installation location. The final assembly and several welds were never 23


PART II

16

subjected to a pressure test. One of the welds that was never pressure-tested 1

resulted in a leak when introducing gas pressure to the system. This leak resulted 2

in a multitude of remedial actions, one of which included a new pressure-test of 3

the entire assembly, this time in accordance with the Michigan Gas Safety 4

Standards. As identified in Discovery Request STDG-1.17 (Refer to Staff Exhibit 5

S-7.05), a residual cost of retesting these facilities was $1,418,000 in 2019. Since 6

this cost was a direct result of the Company’s failure to adhere to the Michigan 7

Gas Safety Standards, Staff proposes that the amount of $1,418,000 be disallowed 8

for recovery during the 12 months ending December 31, 2019. Refer to Line 11 9

in Staff Exhibit S-7.01. The Company’s ratepayers should not be responsible to 10

reimburse the Company for shortcuts taken during construction that resulted in 11

rework. 12

DTE Gas Site Security 13

Q. Does Staff propose any adjustments to the historical DTE Gas Site Security 14


December 31, 2018? 16

A. The Company is not proposing any capital expenditures for this time period. 17

Q. Does Staff propose any adjustments to the projected DTE Gas Site Security 18



A. Yes. In Discovery Request STDG-6.4 (Refer to Staff Exhibit S-7.06), Staff 21

requested that the Company provide “[a] list of all of the specific projects 22

included in this Program” and “[t]he specific risk that is associated with the 23


PART II

17

individual projects that warrants its inclusion into the Program.” The Company 1

response failed to identify the specific risk associated with each identified project, 2

instead stating only that: 3

The need for security measures at DTE Gas sites is taken from a DTE 4 Energy risk-based approach to protect critical infrastructure. Gas 5 pipelines have been targeted internationally and within the US, requiring 6 improved security measures. These improvements, as stated above, are 7 needed to reduce the risk of a malicious or unintentional cyber and/or 8 physical security breach at DTE Gas operational facilities that are critical 9 to ensuring reliable service to its customers. 10

While Staff agrees with the response that the Company provided, it failed to 11

identify what specifically was required at each project location. Without this 12

information, Staff is unable to analyze the expenditures, determine their suitability 13

for recovery, and review their applicability for capitalization. As Staff explicitly 14

requested the “specific risk that is associated with the individual projects” and the 15

Company failed to fulfill that request, Staff proposes disallowing recovery of 16

these expenditures at this time. Staff therefore proposes a disallowance of capital 17

expenditures for DTE Gas Site Security in the amount of $4,238,000 for the 12 18

months ending December 31, 2019, $2,011,000 for the 9 months ending 19

September 30, 2020, and $3,239,000 for the test year ending September 30, 2021. 20

Refer to Line 12 in Staff Exhibit S-7.01. 21

Traverse City Alpena Reinforcement Project 22

Q. Please explain the Traverse City Alpena Reinforcement Project (TCARP). 23

A. As described in Lines 20-25 on Page 22 and Lines 9-15 on Page 23 of the direct 24

testimony of Company Witness Rajan M. Telang: 25


PART II

18

The Traverse City/Alpena Reinforcement Project (TCARP) consists of 1 looping existing pipelines with approximately 8.8 miles of 10” diameter 2 pipe and 14.2 miles of 8” diameter pipe, installation of six (6) 3 interconnects with DTE Michigan Gathering Holding Company pipelines, 4 installation of one (1) new gate station, and modifications to 11 existing 5 gate stations to provide a redundant supply of gas, mitigating potential 6 integrity and outage risks to approximately 90,000 customers. 7

* * * 8 The Lincoln-Traverse City and Alpena systems rank as two of the top 9

single source pipelines requiring risk mitigation. A major incident on 10 either of these pipelines could result in an unprecedented outage with 11 unacceptable impacts to DTE Gas customers. As the Commission 12 indicated in the SEA recommendations G-4 and G-6, it is important for 13 utilities to plan for contingencies and worst-case scenarios and where 14 possible incorporate redundancies to avoid these types of outages and 15 customer impacts. 16

Q. Does Staff propose any adjustments to the historical TCARP capital expenditures 17

that the Company incurred from January 1, 2018, through December 31, 2018? 18



Q. Does Staff propose any adjustments to the projected Traverse City Alpena 21

Reinforcement Project capital expenditures that the Company is incurring from 22

January 1, 2019, through September 30, 2021? 23

A. Yes. The Act 9 application for the Lincoln-Traverse City Pipeline Loop in MPSC 24

Case No. U-20640 indicates that the total expenditures are $26,785,000 (Refer to 25

Staff Exhibit S-7.07). The Act 9 application for the Frankfort Pipeline Loop in 26

MPSC Case No. U-20641 indicates that the total expenditures are $37,675,000 27

(Refer to Staff Exhibit S-7.08). Therefore, the total TCARP expenditures as 28

identified in the Company’s Act 9 filings is $64,460,000 ($56,422,000 without 29

contingencies). 30


PART II

19

However, Company Exhibit A-12, Schedule B5.1, Line 13 indicates a total 1

of $83,319,000 for these projects. Additionally, Discovery Request STDG-1.1 2

(Refer to Staff Exhibit S-7.09) indicated that there will be an additional 3

$10,200,000 that is estimated to be incurred after the test year ends, for a total of 4

$93,500,000 ($90,257,000 without contingencies)1. This represents a 45% 5

increase in the total project cost over what was provided in the respective Act 9 6

cases for these projects. Staff requested a narrative in Discovery Request STDG-7

1.1 (Refer to Staff Exhibit S-7.09) on “why the requested $83.3 million is greater 8

than the sum of the two cost estimates of the 10” Lincoln-Traverse City Pipeline 9

Loop and 8” Frankfort Pipeline Loop…” The Company responded: 10

In addition to the footnote in response STDG-1.1A, the 10” Lincoln-11 Traverse City Pipeline Loop ($26.8M) and the 8” Frankfort Pipeline Loop 12 ($27.5M) are a portion of the overall TCARP project cost in this 13 proceeding. Additional capital expenditures of $29.0M included in the 14 $83.3M are for the proposed interconnections with DTE Michigan 15 Gathering Holding Company, new DTE Gas facilities and modifications to 16 existing facilities to support the improved reliability of our system and 17 reduce the number of potential outages (see table in STDG-1.1A for a 18 detailed breakout of costs as well as Exhibit A-12). Construction 19 completion of the 8” Frankfort Pipeline Loop and the interconnections is 20 after the end of the projected test year. 21

The Company provided that one of the reasons for the discrepancy in 22

expenditures between this instant case and the Act 9 applications is that 23

“additional capital expenditures … included in the $83.3M are for the proposed 24

interconnections with DTE Michigan Gathering Holding Company….” However, 25

the Act 9 applications already included such interconnections. 26

1 Staff used the contingency amount of $3,243,180 present in Company Exhibit A-12, Schedule B5.3. This does not match the contingency amount of $3,300,000 present in Discovery Request STDG-1.1A (Staff Exhibit S-TCARP)


PART II

20

Lines 7-10 on Page 4 of the direct testimony of Christopher M. Paquette in 1

MPSC Case No. U-20640 states: 2

The first phase is the 10” Lincoln – Traverse City Pipeline Loop, which 3 consists of approximately 9.0 miles of 10-inch diameter steel pipeline and 4 the expansion of existing facilities to provide an interconnection with 5 existing DTE Gas pipelines [emphasis added]. 6

Additionally, Lines 7-9 on Page 4 of the direct testimony of Christopher M. 7

Paquette in MPSC Case No. U-20641 states: 8

The second phase, the 8” Frankfort Loop Pipeline, consists of 9 approximately 13.0 miles of 8-inch diameter steel pipeline and the 10 expansion of existing facilities to provide an interconnection with existing 11 DTE Gas pipelines [emphasis added]. 12

These two applications clearly state that the Act 9 filings include “the expansion 13

of existing facilities to provide an interconnection with existing DTE Gas 14

pipelines.” Therefore, these interconnections should not be included as an 15

additional expense in this rate case beyond what was estimated in the Act 9 16

filings. 17

Even were that not the case, the Company stated “[c]onstruction 18

completion of the interconnections is after the end of the projected test year.” 19

Any construction work that exists beyond the projected test year is not suitable for 20

inclusion in this instant case. 21

Staff therefore finds that the Company failed to provide adequate 22

information to determine the legitimacy of the expenditures requested in this 23

instant case. Less all contingencies (which are addressed in the testimony of Staff 24

Witness Joy H. Wang), the Act 9 filings indicated that this project will be 25

approximately 63% of what the Company projected in this instant case 26


PART II

21

($56,422,000/$90,257,000). Therefore, Staff proposes limiting the Company’s 1

expenditures to 63% in this instant case to align with the expenditures present in 2

the Act 9 filings. 3

In Company Exhibit A-12, Schedule B5.3, the Company identified 4

$170,000 of contingency in the 12 months ending December 31, 2019, $0 of 5

contingency in the 9 months ending September 30, 2020, and $3,073,180 of 6

contingency in the test year ending September 30, 2021. These costs will be 7

detailed in the direct testimony of Staff Witness Joy H. Wang. Excluding 8

contingency, the Company is proposing $6,080,000 in the 12 months ending 9

December 31, 2019, $19,833,000 in the 9 months ending September 30, 2020, and 10

$54,163,000 in the test year ending September 30, 2021. Using the 11

aforementioned methodology of allowing recovery of only 63% of what the 12

Company is including in this instant case (for all non-contingency expenses), 13

Staff proposes downward adjustments of $2,250,000 for the 12 months ending 14

December 31, 2019, $7,338,000 for the 9 months ending September 30, 2020, and 15

$20,040,000 for the test year ending September 30, 2021. Refer to Line 13 in 16

Staff Exhibit S-7.01. 17

Van Born Project 18

Q. Please describe what the Company is proposing with the Van Born Project. 19

A. As described in Lines 14-25 on Page 40 and Lines 15-21 on Page 41 of the direct 20

testimony of Company Witness Alida D. Sandberg: 21

The Van Born Project is the installation of a new pipeline and regulating 22 equipment and the looping of two existing pipelines, which will provide a 23 redundant source of gas supply into DTE Gas’s southeast market area. 24


PART II

22

* * * 1 DTE Gas continuously evaluates its natural gas system to identify 2

potential projects that would enhance the reliability of gas supply to its 3 customers. This evaluation identified the Van Born System as a higher risk 4 area needing risk mitigation. 5

* * * 6 A new 7 mile 24”, 858 psig pipeline commencing at Willow Gate Station 7

will be constructed with regulation at the end reducing the pressure from 8 858 psig to 540 psig. This will be the new source of supply for the 30” 9 Van Born pipeline. The operating pressure of the first seven (7) miles of 10 the existing 30” Van Born pipeline will be lowered to 300 psig and 11 connected in parallel to the 36” Van Born pipeline, thus providing the 12 required supply redundancy to mitigate the outage potential to 13 approximately 120,000 customers during the winter heating season. 14

Q. Is Staff supportive of the Van Born Project? 15

A. Yes. The Company’s Van Born Project will provide redundancy to a critical 16

number of customers in the Company’s southeast territory. An outage in this 17

location presents an unacceptable level of risk for the Company to accept. 18

Q. Does the Van Born Project require an Act 9 proceeding before the Commission? 19

A. Yes. 20

Q. What is Staff’s position regarding capital expenditures for projects that have not 21

yet received approval from the Commission pursuant to Act 9? 22

A. Staff opines that Companies be allowed to recoup the expenditures that would be 23

necessary to facilitate an accurate and detailed Act 9 application. These 24

expenditures have typically been limited to those identified with project 25

engineering, as the application itself requires a specific level of detail to be 26

included. 27

Q. What level of expenditures has the Company projected for the engineering 28

associated with the Van Born Project? 29


PART II

23

A. As identified in Discovery Request STDG-1.19 (Refer to Staff Exhibit S-7.10), 1

the Company has identified $1,850,000 in engineering expenses associated with 2

the Van Born Project. 3

Q. Does Staff propose any adjustments to the historical Van Born Project capital 4

expenditures that the Company incurred from January 1, 2018, through December 5

31, 2018? 6

A. The Company is not proposing any capital expenditures for this time period. 7

Q. Does Staff propose any adjustments to the projected Van Born Project capital 8

expenditures that the Company is incurring from January 1, 2019, through 9


A. Yes. Staff is only supporting recovery of the engineering expenses incurred for 11

the Van Born Project in the amount of $1,850,000. Contingency values of 12

$150,000 for the 9 months ending September 30, 2020, and $1,625,000 for the 13

test year ending September 30, 2021, are not included in adjustments in this 14

testimony and will be detailed in the direct testimony of Staff Witness Joy H. 15

Wang. Therefore, this testimony will be proposing a downward adjustment of $0 16

for the 9 months ending September 30, 2020, and a downward adjustment of 17

$8,775,000 for the test year ending September 30, 2021. Remaining contingency 18

values, once adjusted by Staff Witness Joy H. Wang, will result in a net recovery 19

of $1,850,000. Refer to Line 14 in Staff Exhibit S-7.01. 20

(4) Infrastructure Recovery Mechanism Capital Expenditures (Pipeline Integrity) 21

Q. What sub-programs are included in the Company’s Pipeline Integrity Program? 22


PART II

24

A. As described on Lines 20-24 on Page 48 of the direct testimony of Company 1

Witness Alida D. Sandberg, such sub-programs include the following: 2

(A) Pipeline Integrity Assessments 3

(B) In-Line-Inspection (ILI) Expansion 4

(C) Remote Control Valves (RCV) 5

(D) Maximum Allowable Operating Pressure (MAOP) Record Review 6

(E) Records Management System Development. 7

Q. Does Staff propose any adjustments to the historical Infrastructure Recovery 8

Mechanism capital expenditures that the Company incurred from January 1, 2018, 9

through December 31, 2018? 10



Q. Does Staff propose any adjustments to the projected Infrastructure Recovery 13

Mechanism capital expenditures that the Company is incurring from January 1, 14

2019, through September 30, 2021? 15


adjustments to the projected capital expenditures for this program at this time. 17

(5) Natural Gas Storage Operation and Maintenance Expenses 18

Q. Does Staff propose any adjustments to the projected Natural Gas Storage 19

operation and maintenance expenses during the test year? 20


adjustments to the projected operation and maintenance expenditures for this 22


PART II

25

program outside of inflation at this time. Inflation adjustments will be addressed 1

in the direct testimony of Staff Witness Brian Welke. 2

(6) Transmission Operation and Maintenance Expenses 3

Q. Please explain what the Company is proposing for Transmission Operation and 4

Maintenance expenses in this instant case. 5

A. As described in Lines 3-12 on Page 14 of the direct testimony of Company 6

Witness Mark C. Johnson: 7

Five known and measurable adjustments, other than inflation, are assumed 8 within Transmission expense (See Exhibit A-13, Schedule C5.2). These 9 adjustments are related to: 10

1. Pipeline Integrity: $8.4 million (line 3, column(j)) 11 2. MAOP Transmission Records Remediation: $4.6 million (line 10, 12

column (j)) 13 3. Blue Lake transmission: $0.9 million (line 10, column (j)) 14 4. Pipeline Safety Management Systems: $1.1 million (line 10, column (j)) 15 5. QA Third Party Support: $0.1 million (line 10, column (j)) 16 6. Cyber security and additional nominations support: $1.5 million (line 17

10, column (j)) 18

The subsequent sections of this testimony will focus on each of the “[f]ive known 19

and measurable adjustments, other than inflation.” Inflation adjustments will be 20

addressed in the direct testimony of Staff Witness Brian Welke. 21

Pipeline Integrity 22

Q. What level of operation and maintenance expenses is the Company requesting in 23

Pipeline Integrity? 24

A. As illustrated in Company Exhibit A-13, Schedule C5.2, the Company is 25

requesting $8,390,000. 26

Q. Why is the Company projecting additional expenditures related to Pipeline 27

Integrity? 28


PART II

26

A. As described in Lines 15-23 on Page 14 of the direct testimony of Company 1

Witness Mark C. Johnson: 2

The increase in Pipeline Integrity expenses reflects: 3 1. Increasing the number of pipelines to be reassessed, dictated by the last 4

time an assessment was conducted, typically a 7-year cycle, 5 2. Increase in the number of actionable anomalies detected due to 6

advances in technology used to perform the assessments, 7 3. Increase in the miles of pipe assessable by In Line Inspection (ILI) 8

method. ILI is more expensive than other methods of inspection. Witness 9 Sandberg’s testimony supports the benefits of ILI as well as the regulatory 10 drivers for the ILI expansion program. 11

Q. Does Staff agree with these increases? 12

A. No. Discovery Request STDG-1.5 (Refer to Staff Exhibit S-7.11) requested “a 13

spreadsheet (with calculations intact) of how each expense … was determined 14

with specific line items detailing the individual appropriations that resulted in the 15

provided summation.” 16

Q. Did the Company provide such a spreadsheet? 17

A. No. The Company’s response, also included in Staff Exhibit S-7.11 indicated 18

how the $8,390,000 was divided between Labor, Material, Contract Services, and 19

Other categories, but there was no detail about how these amounts were 20

“determined with specific line items detailing the individual appropriations that 21

resulted in the provided summation.” Dividing the requested amount into the 22

provided four categories with no support for how those numbers were calculated 23

does little to suggest that the requested amount is anything but arbitrary. 24

Q. Does Staff propose any adjustments to the projected Pipeline Integrity operation 25

and maintenance expenditures during the test year? 26


PART II

27

A. Yes. The Company failed to support the expenditures that it projected in Staff 1

Exhibit S-7.11. Staff remains supportive of the Company’s efforts to improve 2

pipeline safety through its transmission integrity management program but is 3

unable to support the Company’s request for increased projected expenses that are 4

not supported by data. While the Company has not supported its projected 5

expenses in this case, Staff does recognize that the Company is increasing “the 6

miles of pipe assessable by In Line Inspection (ILI) method” as stated by 7

Company Witness Mark C. Johnson. Staff proposes an operation and 8

maintenance expense for Pipeline Integrity in the amount of $4,195,000. This 9

results in a downward adjustment in Pipeline Integrity operation and maintenance 10

expenses of $4,195,000. 11

MAOP Transmission Records Remediation 12


MAOP Transmission Records Remediation? 14



Q. Does Staff propose any adjustments to the projected MAOP Transmission 17

Records Remediation operation and maintenance expenditures for the test year? 18



program at this time. 21


PART II

28

Blue Lake Transmission 1


Blue Lake Transmission? 3


requesting $885,000. 5

Q. Does Staff propose any adjustments to these projected operation and maintenance 6

expenditures for the test year? 7




Pipeline Safety Management Systems 11


Pipeline Safety Management Systems? 13








QA Third Party Support 21


QA Third Party Support? 23


PART II

29


requesting $125,000. 2






Cyber Security and Additional Nominations Support 8


Cyber Security and Additional Nominations Support? 10








(7) Staff General Recommendations 18

Q. Does Staff have any recommendations with how the Company is allocating lost 19

and unaccounted for gas? 20

A. Yes. Discovery Request STDG-1.3 (refer to Staff Exhibit S-7.12) requested how 21

gas vented at compressor stations during emergency shutdowns was accounted 22

for. The Company’s response included the following table: 23


PART II

30

Table 2: Compressor Station Vented Gas 1

2

As can be seen from this excerpt, there are inconsistencies in how these costs are 3

being recovered. Staff proposes that all gas that is vented to the atmosphere, 4

whether it be through emergency shutdowns that occur at compressor stations or 5

out of relief valves located in the Company’s system, be accounted for as 6

“Company Use” gas. When gas is vented to the atmosphere out of equipment that 7

was designed and installed specifically for that purpose, the amounts of gas 8

released can be calculated and should not be considered as unaccounted for. This 9

is consistent with the recommendation that Staff made in Case U-20322 for 10

Consumers Energy Company. 11

Q. Does Staff have any recommendations with the Company’s application of the 12

USofA? 13

A. Yes. In Discovery Request STDG-5.1 (Refer to Staff Exhibit S-7.13), Staff 14

requested the USofA accounting codes that the Company was using for work 15

associated with reviewing maximum allowable operating pressures and 16

developing a records management system. The Company responded stating that 17

Event Date EventQuantity

(MCF) LostValue of Gas

Lost Cost Recovered As

1/1/2018 Planned Station ESD Total For Year 2,229 7,740.61$ Company Use 1/1/2018 Planned Station ESD Total For Year 815 2,831.59$ Company Use 1/1/2018 Unplanned Station ESD 12 40.41$ Company Use 4/1/2018 Station ESD 241 804.36$ Company Use

4/23/2018 Planned Station ESD 12,050 40,251.11$ Lost Gas 7/9/2018 Planned Station ESD 16,944 56,600.41$ Lost Gas

9/20/2018 Unplanned Station ESD 38 127.72$ Lost Gas 9/26/2018 Station ESD 332 1,110.20$ Lost Gas 9/26/2018 Unplanned Station ESD 11,098 37,071.05$ Lost Gas 1/1/2019 Planned Station ESD Total For Year 3,248 10,849.62$ Company Use 1/1/2019 Planned Station ESD Total For Year 698 2,331.60$ Company Use 5/6/2019 Planned Station ESD 12,050 35,546.88$ Lost Gas 7/8/2019 Planned Station ESD 20,613 60,808.12$ Lost Gas

9/27/2019 Unplanned Station ESD 316 932.57$ Company Use


PART II

31

the accounting code for these work activities was associated with Account 303 1

entitled “Miscellaneous intangible plant.” The Uniform System of Accounts 2

describes this account as follows: 3

This account shall include the cost of patent rights, licenses, privileges, 4 and other intangible property necessary or valuable in the conduct of the 5 utility's gas operations and not specifically chargeable to any other 6 account. 7

Staff opines that a more appropriate accounting code for the maximum allowable 8

operating pressure record review would be Account 182.2 entitled “Unrecovered 9

plant and regulatory study costs” which states: 10

182.2 Unrecovered plant and regulatory study costs. 11 A. This account shall include: (1) Nonrecurring costs of studies and 12

analyses mandated by regulatory bodies related to plants in service, 13 transferred from account 183.2, Other Preliminary Survey and 14 Investigation Charges, and not resulting in construction; and (2) when 15 authorized by the Commission, significant unrecovered costs of plant 16 facilities where construction has been cancelled or which have been 17 prematurely retired. 18

B. This account shall be credited and account 407.1, Amortization of 19 Property Losses, Unrecovered Plant and Regulatory Study Costs, shall be 20 debited, over the period specified by the Commission. 21

C. Any additional costs incurred, relative to the cancellation or premature 22 retirement, may be included in this account and amortized over the 23 remaining period of the original amortization period. Should any gains of 24 recoveries be realized relative to the cancelled or prematurely retired 25 plant, such amounts shall be used to reduce the unamortized amount of the 26 costs recorded herein. 27

D. In the event that the recovery of costs included herein is disallowed in 28 rate proceedings, the disallowed costs shall be charged to account 426.5, 29 Other Deductions, or account 435, Extraordinary deductions, in the year of 30 such disallowance. 31

* * * 32 407.1 Amortization of property losses, unrecovered plant and regulatory 33

study costs. This account shall be charged with amounts credited to 34 Account 182.1, Extraordinary Property Losses, and Account 182.2 35 Unrecovered Plant and Regulatory Study Costs, when the Commission has 36 authorized the amount in the latter account to be amortized by charges to 37 gas operating expenses. 38


PART II

32

Refer to Staff Exhibit S-7.14 for the USofA. The Company’s review of 1

maximum allowable operating pressures was required per a Pipelines and 2

Hazardous Materials Safety Administration (PHMSA) Advisory Bulletin issued 3

on January 10, 2011, and a final rule entitled “Safety of Gas Transmission 4

Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements and 5

Other Related Amendments” that was finalized on October 1, 2019. Therefore, 6

because this work is being conducted commensurate to those regulatory 7

requirements, Staff recommends that the Company utilize Account 182.2 for these 8

expenditures, which is intended to house “regulatory study costs.” 9

(8) Staff General Concerns 10

Q. Does Staff have any other concerns with the Company’s request for relief in this 11

instant case? 12

A. Yes. Through several different discovery responses, Staff requested a level of 13

detail to substantiate capital expenditures or operation and maintenance expenses. 14

Specifically, Staff requested spreadsheets with specific line items detailing how 15

the requested amounts were calculated. The Company, when it even provided a 16

spreadsheet, only separated the total requested amounts into “Labor (Internal),” 17

“Material,” “Contract Services,” or “Other,” without any calculations to support 18

the values entered into those categories. As the Company presumably performed 19

some level of analysis to develop those levels of expenditures prior to the rate 20

case, the request for this information would seem to be relatively easy for the 21

Company to produce. However, the lack of supporting calculations indicates to 22

Staff that either the amounts requested were not developed based on any analysis 23


PART II

33

or that the Company is intentionally withholding information that Staff requires to 1

determine a prudency review and reasonableness for reimbursement. Refer to 2

Staff Exhibit S-7.15 for an example of the Company’s ambiguity in providing 3

discovery responses. 4

Additionally, Discovery Requests STDG-6.5 through STDG-6.8 (refer to 5

Staff Exhibit S-7.16) sought information on the Company’s cost estimates for the 6

categories of Labor, Material, Contract Services, Overheads, Contingency, and 7

AFUDC for several In-line Inspection Expansion Projects and for the Southfield 8

24” Pipe Replacement. Specifically, Staff requested that the Company: 9

… provide a spreadsheet (with calculations intact) of how each expense 10 (Labor, Material, Contract Services, Overheads, Contingency, and 11 AFUDC) was determined with specific line items that result in the 12 provided summations for each time period provided above. 13

Bafflingly enough, instead of providing these calculations, the Company simply 14

responded with the same information that Staff included in its Discovery Request, 15

except in a spreadsheet format. The spreadsheets provided contained no 16

information or calculations to indicate how the Labor, Material, Contract 17

Services, Overheads, Contingency, and AFUDC amounts were calculated. The 18

simple values placed into these categories, along with the Company’s reluctance 19

to provide how they were developed, does little to provide Staff reassurance that a 20

valid cost estimate was developed for these projects and does little to further the 21

Company’s case that these amounts are suitable for cost recovery. 22


A. Yes, it does. 24

March 24, 2020



* * * * In the matter of the application of ) DTE Gas Company for authority to increase ) its rates, amend its rate schedules and rules ) Case No. U-20642 governing the distribution and supply of ) natural gas, and for miscellaneous accounting ) authority. __________________________________)

EXHIBITS OF

PAUL R. AUSUM

CYNTHIA L. CREISHER

JAMES E. LAPAN

NATHAN J. MILLER


Michigan Public Service Commission Case No.: U-20642DTE Energy Gas Company Exhibit No.: S-18Forecasted Deliveries by Rate Schedule Page: 1 of 2Volumes in MMcf (2004-2018 15-Year Weather Normalization) Witness: P.R. Ausum

Date: 3/24/2020

Column: (a) (b) (c) (d) (e) (f) (g) (h)

Source: Exhibit A-15, E1.1, p.1 (b)-[(b)*0.99*0.99*0.9925] (b)+(c)-[(b+c)*0.9907] see col. (j) on page 2 (b)+(c)+(d)+(e) Exhibit A-15, E1.1, p.1 (f)-(g)col. (b), lines 8-14 col. (k), lines 8-14

Line ScheduleWeather Normalized

2018 Historic Test YearAdjustment due to

1% Annual EWR Assumption Adjustment due to

Increased Heating ValueAdjustment due to

Forecasted Customer UsageOct. 2020-Sep. 2021

Staff ForecastOct. 2020-Sep. 2021

DTE Forecast Difference1 RATE A 112,216 (3,058) (1,015) 2,675 110,818 109,416 1,402 2 RATE 2A I 332 (9) (3) (14) 305 295 11 3 RATE 2A II 4,629 (126) (42) (247) 4,214 4,033 181 4 RATE GS-1 41,161 (1,122) (372) 80 39,747 39,054 693 5 RATE GS-2 1,009 (28) (9) (159) 814 693 120 6 RATE S 1,541 (42) (14) 44 1,530 1,465 65

7 Total 160,888 (4,384) (1,455) 2,379 157,427 154,955 2,472

totals may not add exactly due to rounding

Michigan Public Service Commission Case No.: U-20642DTE Energy Gas Company Exhibit No.: S-18Calculation of projected test year additional customer usage Page: 2 of 2Volumes in MMcf (2004-2018 15-Year Weather Normalization) Witness: P.R. Ausum

Date: 3/24/2020

Column: (a) (b) (c) (d) (e) (f) (g) (h) (i) (j)

Source: Ex. A-15, E1.1, p. 2 Ex. A-15, E1.1, p.2 (b)-(c) Ex. A-15, E1.1, col. (k), Ex. A-15, E1.1, p.1 (e)-(f) (e)÷(b) (f)÷(c) if (d)>0, (j) = (d)*(h)col. (o), lines 1-7 col. (f), lines 1-7 p.1, lines 8-14 col. (b), lines 8-14 if (d)<0, (j) = (d)*(i)

Line ScheduleOct. 20-Sep. 21

Customer Count2018

Customer Count Δ in cust.DTE Oct. 20-Sep. 21

Forecasted DeliveriesDTE 2018

WN Deliveries Δ in deliveriesOct. 20-Sep. 21 yearly use/cust. 2018 yearly use/cust.

Forecasted Customer Usage

1 RATE A 1,197,847 1,168,562 29,285 109,416 112,216 (2,800) 0.09 0.10 26752 RATE 2A I 1,228 1,284 (56) 295 332 (37) 0.24 0.26 -143 RATE 2A II 4,982 5,263 (281) 4,033 4,629 (596) 0.81 0.88 -2474 RATE GS-1 89,265 89,082 183 39,054 41,161 (2,107) 0.44 0.46 805 RATE GS-2 45 53 (8) 693 1,009 (316) 15.41 18.90 -1596 RATE S 220 213 7 1,465 1,541 (77) 6.66 7.22 44

7 Total 1,293,587 1,264,458 29,129 154,955 160,888 (5,933) 2,379

totals may not add exactly due to rounding

Michigan Public Service Commission Case No.: U-20642DTE Gas Company Exhibit: S-16.0 Staff Adjustments to Projected O&M Expenses - Distribution - Other Projected Adjustments Witness: C. Creisher

Projected 12 Month Period Ending September 30, 2021 Page: 1 of 1($000)

(a) (b) (c) (d) (e) (f) (g)

Company 1/1/20 - 1/1/21 - 10/1/20 - Staff Line Projected Contingency 12/31/20 12/31/21 9/30/21 ProjectedNo. Description Adjustments Adjustment Damages 1/ Damages 1/ Damages Test Period

(b) + (c) + (f)1 Other Projected Expenses2 Other Expenses3 Distribution Record Remediation 2,950 (651) - - - 2,299 4 Transmission Fitting conversion 300 (73) - - - 227 5 Damage Prevention 1,500 - (250) (500) (438) 1,063 6 Total Other Expense 4,750$ (724)$ (250)$ (500)$ (438)$ 3,588$

1/ Targeted reduction in excavation damage costs in 2020 of $500,000 and 2021 of $1,000,000 with 50% allocated as O&M expense and 50% allocated as capital expenditure.

Staff Projected Adjustments

Michigan Public Service Commission Case No.: U-20642DTE Gas Company Exhibit: S-16.1Staff Adjustments to Capital Expenditures - Routine Distribution Witness: C. Creisher

and Infrastructure Recovery Mechanism Page: 1 of 1($000)

(a) (b) (c) (d) (e) (f) (g) (h) (i) (j)

Company Projected Staff Adjustment Staff Projected Company Projected Staff Adjustment Staff Projected Company Projected Staff Adjustment Staff ProjectedLine 12 mos. ending 12 mos. ending 12 mos. ending 9 Mo. ending 9 Mo. ending 9 Mo. ending 12 mos. ending 12 mos. ending 12 mos. endingNo. 12/31/2019 12/31/2019 12/31/2019 09/30/2020 09/30/2020 09/30/2020 09/30/2021 09/30/2021 09/30/2021

Routine1 Distribution Plant 1/ 107,600$ -$ 107,600$ 76,878$ (188)$ 76,690$ 94,111$ (438)$ 93,673$

Infrastructure Recovery Mechanism 3/2 Main Renewal Program 196,235$ -$ 196,235$ 183,405$ (7,605)$ 175,800$ 61,135$ (2,535)$ 58,600$ 3 MMO MAC Initiative 15,115$ -$ 15,115$ 12,427$ -$ 12,427$ 4,142$ -$ 4,142$ 4 Meter Move-Out Program 24,441$ -$ 24,441$ 20,751$ (1,374)$ 19,377$ 6,917$ (458)$ 6,459$

1/ Targeted reduction in excavation damage costs in 2020 of $500,000 and 2021 of $1,000,000 with 50% allocated as O&M expense and 50% allocated as capital expenditure.

Description

Bridge Year Projected Test YearCapital Expenditures

MPSC Case No.:Requestor:

Question No.:Respondent:

Page:

U-20642StaffCLC-8.1M. C. Johnson1 of 1

Question: Regarding Lines 11-18 on Page 24 of Company witness Mark Johnson,which states in part that:

Three known and measurable adjustments are assumed within distributionoperations expense. These adjustments are related to (Exhibit A-13,Schedule C5.3):

1. MAOP Distribution Record Remediation: $3.0 million (column (j), line 10)

Please provide a spreadsheet (with calculations intact) of how eachexpense (1-3 above) was determined with specific line items detailing theindividual appropriation that results in the provided summation.

Answer: Please see attachment U-20642 CLC-8.1 MAOP Distribution RecordRemediation.

Attachments: U-20642 CLC-8.1 MAOP Distribution Record Remediation

Case No.: U-20642 Witness: C. Creisher

Exhibit: S-16.2 Page: 1 of 2

Case No.: U‐20642Audit Request: CLC‐8.1Respondent: M. JohnsonFile Attachment: U20642 CLC‐8.1 MAOP Distribution Record Remediation ($ millions)

MAOP Distribution Record Remediation O&M ExpendituresProjected Test Year 12 mos. ending 09/30/2021

Projected 9 mos. ending 09/30/2021

Middlebelt MAOP Record Defects:Labor (Internal) 82,400$ 82,400$ Material 392,840$ 392,840$ Contract Services 1,590,000$ 1,590,000$ Overheads 104,277$ 104,277$ Contingency 650,855$ 650,855$ AFUDC 179,000$ 179,000$

Middlebelt MAOP Record Defects Total $ 2,999,372 $ 2,999,372 MAOP Distribution Record Remediation ‐ Total 2,999,372$ 2,999,372$

U‐20642 MAOP Distribution Record Remediation



+MPSC Case No.:

Requestor:Question No.:Respondent:

Page:




2. Transmission fitting conversion: $0.3 million (column (j), line 10)


Answer: Please see attachment U-20642 CLC-8.2 Transmission fitting conversion.

Attachments: U-20642 CLC-8.2 Transmission fitting conversion



Case No.: U‐20642Audit Request: CLC‐8.2Respondent: M. JohnsonFile Attachment: U20642 CLC‐8.2 Transmission fitting conversion ($ millions)

Transmission fitting conversion O&M ExpendituresProjected Test Year 12 mos. ending 09/30/2021

Projected 9 mos. ending 09/30/2021

Beech Main Transmission fitting conversion:Labor (Internal) 4,371$ ‐$ Material ‐$ ‐$ Contract Services 198,969$ ‐$ Overheads 5,658$ ‐$ Contingency 73,167$ ‐$ AFUDC 17,835$ ‐$

Beech Main Transmission fitting conversion Total $ 300,000 $ ‐ Transmission fitting conversion ‐ Total 300,000$ ‐$

U‐20642 Transmission fitting conversion





Page:




3. Damage Prevention: $1.5 million (column (j), line 10).


Answer: Please refer to file attachment “U-20642 CLC-8.3 Damage Prevention”,tab labeled CLC-8.3

Attachments: U-20642 CLC-8.3 Damage Prevention



Case No.: U‐20642Audit Request: Respondent: M. JohnsonFile Attachment: ($ millions)

Damage Prevention O&M Expenditures 1/2018

Projected2020Annual

2021Annual

3 Mos. Ending10/01/2020 ‐ 12/31/2020

9 Mos. Ending 01/01/21‐09/30/21

Damage PreventionLabor (Internal) $ 648 $ 1,606 $ 1,641 401$ 1,231$ Material $ 25 $ 57 $ 58 14$ 44$ Contract Services $ 375 $ 597 $ 610 149$ 458$ Other (Non ‐ Labor) $ 86.5 $ 442 $ 451 110$ 339$

Damage Prevention ‐ Total $ 1,134 2,701$ 2,761$ 675$ 2,071$

1/ This excludes Miss Dig and standby service and represents costs for the Damage Prevention team only

U‐20642 Damage Prevention





Page:


Question: With reference to the Company response to Staff Audit Request CLC-8.3,please provide a description of the Contract Services expenditures in theamount of $200,000 and the Other (Non-labor) expenditures in the amountof $350,000 that are included in the 2020 Damage Prevention O&Mexpense projection.

Answer: The Contract Service expenditures in the amount of $200,000 is for 2contractors supporting the Damage Prevention and Billing process.

The Contract Service expenditures in the amount of $350,000 is forOptimain ticket risk-ranking software.

Attachments: None





Page:

U-20642StaffSTDG-1.3CM. C. Johnson1 of 1

Question: Regarding Lines 2-9 on Page 4 of Company witness Larisa Abayev, whichstates:

“There are a number of contributors to LAUF gas including:1. Metering inaccuracy…2. Leaks and theft…3. Other metering and billing issues….”

Please provide, from 2018-2019, a breakdown of all of the gas that was lostdue to the following events:

C. Mechanical damages on the system, separated by first (Company),second (Company’s contractor) and third (Other contractor) party damages.

As part of this breakdown, please list each event, the date of each event,the quantity of gas lost, the value of the gas that was lost, and from wherethe cost of these events was recovered (for example, LAUF, billed tocontractor, etc.).

Answer: If by “recovered”, you mean “recorded” then please see attached file.

Attachment: U-20642 STDG-1.3C-01 Lost Gas



Station Address Damage Occurred City Damage Occurred Damage Date CCFH/MCF

Volume of Lost Gas cfh=100 cubic feet mcf=1,000 cubic

feet

Amt of Lost Gas for Services

Amt of Lost Gas for Mains

Grand Rapids 0‐11705 TORREY TRL NW TALLMADGE TWP 8/3/2019 MCF 34 0 43.62Lynch 1 RIVERBANK RD DETROIT 6/28/2019 CCFH 34 23.8 0Lynch 1 WASHINGTON DETROIT 10/5/2019 MCF 34 0 867.21Lynch 1 WOOWARD DETROIT 3/1/2019 MCF 34 0 37.39Lynch 100 WORCHESTER PL HIGHLAND PARK 10/14/2019 CCFH 4 3.36 0Lynch 10047 CHALMERS ST DETROIT 4/17/2019 CCFH 4 1.12 0Michigan 1005 S 7 TH ST ANN ARBOR 1/15/2019 MCF 4 0 11.84Mount Pleasant 1006 HAROLD AVE MOUNT PLEASANT 1/7/2019 CCFH 34 4.76 0Lynch 10109 NOTTINGHAM RD DETROIT 5/31/2019 CCFH 4 2.32 0Lynch 1012 YORKSHIRE GROSSE POINTE PARK 10/2/2019 CCFH 16 4.48 0Mount Pleasant 1015 E MAPLE ST MOUNT PLEASANT 7/24/2019 CCFH 16 4.48 0Allen 1017 SPRINGWELLS ST DETROIT 9/26/2019 MCF 16 0 21.5Traverse City 10299 CEDAR RUN RD LONG LAKE 4/11/2019 CCFH 34 4.76 0Muskegon 1031 W LAKETON AVE MUSKEGON 5/28/2019 CCFH 16 2.24 0Lynch 10329 BRITAIN ST DETROIT 6/18/2019 MCF 4 0 3.5Grand Rapids 1034 ALDERMAN ST BELDING 8/16/2019 CCFH 16 4.48 0Michigan 10382 MARTZ RD YPSILANTI 10/19/2019 CCFH 34 9.52 0Alpena 1040 HIGHLAND CT ALPENA 11/21/2019 CCFH 34 1.59 0Michigan 10401 HARRISON ROMULUS 7/16/2019 MCF 34 0 156.71Grand Rapids 1049 DEN HERTOG ST SW WYOMING 1/16/2019 CCFH 16 2.32 0Traverse City 1050 GRAY RD PENNINSULA 8/9/2019 CCFH 34 9.52 0Allen 1063 DRAGOON ST DETROIT 3/7/2019 MCF 4 0 5.55Traverse City 1064 LOCHMOOR LN TRAVERSE CITY 11/13/2019 CCFH 34 18.02 0

10685 SCARLET OAK 2/28/2019 CCFH 25 14 0Lynch 10710 LANARK ST DETROIT 7/30/2019 MCF 4 0 1.33Muskegon 1080 ADA AVE MUSKEGON 7/3/2019 CCFH 16 4.48 0Lynch 10845 NOTTINGHAM RD DETROIT 9/12/2019 MCF 4 0 2.56Grand Rapids 10858 WILDWOOD DR GREENVILLE 6/10/2019 CCFH 34 14.28 0Lynch 10889 E OUTER DR DETROIT 4/18/2019 MCF 16 0 13.6Alpena 109 RIVER ALPEANA 9/26/2019 MCF 16 0 214.62Muskegon 1090 HORTON RD MUSKEGON 9/19/2019 CCFH 16 4.48 0Allen 10909 KOLB AVE ALLEN PARK 3/4/2019 CCFH 16 9.15 0Big Rapids 111 N OAK ST BIG RAPIDS 10/23/2019 CCFH 34 0.79 0Michigan 1114 WELLINGTON CT ANN ARBOR 4/16/2019 CCFH 4 0.84 0Grand Rapids 1115 PINE NW GRAND RAPIDS 6/28/2019 CCFH 4 1.12 0Muskegon 1116 3rd ST MUSKEGON 10/8/2019 MCF 16 0 97.02Michigan 1121 FREDON ST ANN ARBOR 7/31/2019 MCF 4 0 14.23Allen 11234 FORD AVE RIVERVIEW 3/7/2019 CCFH 16 9.15 0Muskegon 1124 LANGERLAND AVE MUSKEGON 5/22/2019 CCFH 16 1.49 0Grand Rapids 1128 KALAMAZOO SE GRAND RAPIDS 10/1/2019 CCFH 4 0.56 0Muskegon 113 N ORCHARD ST HART 8/16/2019 CCFH 16 4.48 0Michigan 11300 WHITTAKER RD AUGUSTA 8/7/2019 CCFH 34 19.04 0Allen 11326 ARCHDALE ST DETROIT 6/27/2019 CCFH 4 0.56 0

1134 CEDAR ST 3/6/2019 CCFH 4 1.12 0Mount Pleasant 11340 ALPINE DR LAKE 11/2/2019 CCFH 34 18.02 0Mount Pleasant 11340 ALPINE DR LAKE 11/12/2019 CCFH 34 18.02 0Grand Rapids 11407 24 TH AVE MARNE 3/18/2019 CCFH 34 4.93 0Allen 1141 LEWERENZ ST DETROIT 5/4/2019 CCFH 4 1.12 0Allen 11414 LAUDER ST DETROIT 7/29/2019 CCFH 4 1.12 0

11414 LAUDER ST 7/29/2019 CCFH 4 1.12 0Lynch 11426 MORAN ST HAMTRAMCK 5/29/2019 CCFH 4 1.12 0Allen 11427 CAPE COD ST TAYLOR 9/27/2019 CCFH 16 4.98 0Michigan 1145 OAK VALLEY DR ANN ARBOR 5/17/2019 MCF 34 0 539.07Grand Rapids 1149 KALAMAZOO AVE SE GRAND RAPIDS 10/4/2019 CCFH 4 0.56 0Grand Rapids 11491 78 TH ALLENDALE 3/29/2019 CCFH 34 9.86 0Traverse City 1150 HAMMOND RD E TRAVERSE CITY 6/27/2019 CCFH 34 28.56 0Alpena 1152 PINE RD ALPEANA 7/25/2019 CCFH 34 1.9 0Michigan 1152 SHARE AVE YPSILANTI 3/1/2019 CCFH 16 0.23 0Grand Rapids 1157 MEDIVAL PARK SE GRAND RAPIDS 7/25/2019 CCFH 34 14.28 0Lynch 11570 E WARREN AVE DETROIT 9/23/2019 MCF 4 0 6.05Allen 11583 CAPE COD TAYLOR 9/19/2019 CCFH 34 4.76 0Traverse City 116 N OAK ST TRAVERSE CITY 6/16/2019 CCFH 34 7.14 0Allen 11629 CAPE COD ST TAYLOR 9/18/2019 CCFH 34 14.28 0Allen 1164 WHITE AVE LINCOLN PARK 10/8/2019 CCFH 16 4.98 0Allen 11660 KLINGER HAMTRAMCK 5/16/2019 CCFH 34 9.52 0Allen 11677 ARCHDALE ST DETROIT 10/29/2019 CCFH 4 1.12 0Lynch 11707 WHITTIER DETROIT 10/18/2019 CCFH 4 1.68 0Allen 1172 WHITE AVE LINCOLN PARK 10/24/2019 CCFH 16 4.48 0Allen 1172 WHITE AVE LINCOLN PARK 11/20/2019 CCFH 16 4.24 0Lynch 11767 WHITEHALL DETROIT 7/26/2019 MCF 4 0 2.04Michigan 1180 KAY PARKWAY ANN ARBOR 10/1/2019 CCFH 4 1.12 0Lynch 11822 WHITEHILL DETROIT 7/19/2019 CCFH 4 0.25 0Alpena 1185 US HIGHWAY 23N ALPEANA 11/18/2019 CCFH 34 4.51 0Lynch 12017 MACK SERVICE DRIVE DETROIT 9/7/2019 CCFH 16 22.4 0Allen 12038 KLINGER HAMTRAMCK 5/8/2019 CCFH 16 1.12 0Mount Pleasant 1204 BUCKINGHAM PL MOUNT PLEASANT 11/11/2019 CCFH 34 9.01 0Allen 1205 10 TH ST WYANDOTTE 8/20/2019 CCFH 4 0.28 0Lynch 1205 CANTON ST DETROIT 7/9/2019 CCFH 4 0.02 0Lynch 12110 CHARLEST ST HAMTRAMCK 6/5/2019 CCFH 16 0.08 0Michigan 1214 HORSE SHOE CIR(BLDG 13) ANN ARBOR 8/21/2019 MCF 4 0 292.68



Muskegon 1217 HOLTON RD MUSKEGON TOWNSHIP 4/26/2019 MCF 34 0 1444.81225 VESTA ST 12/27/2019 CCFH 16 4.24 0

Lynch 12250 JANE ST DETROIT 7/29/2019 CCFH 4 0.37 0Grand Rapids 1230 52ND SW WYOMING 9/19/2019 CCFH 34 9.52 0Lynch 1241 GLYNN CT DETROIT 6/12/2019 CCFH 4 1.68 0Muskegon 1242 CLAYTON AVE NORTON SHORES 7/22/2019 CCFH 16 8.96 0Grand Rapids 12471 MCMURTY SAND LAKE 10/11/2019 CCFH 34 9.52 0Michigan 12475 JORDAN RD SALINE 2/5/2019 MCF 34 0 6.65Michigan 1251 CLARITA ST YPSILANTI 2/18/2019 CCFH 34 9.86 0Lynch 12603 DEXTER DETROIT 8/7/2019 MCF 4 0 1532.3Lynch 12603 RIAD ST DETROIT 8/20/2019 CCFH 4 0.09 0Lynch 12668 GRATIOT AVE DETROIT 11/14/2019 MCF 4 0 5.32Muskegon 1268 W HILE RD NORTON SHORES 6/4/2019 CCFH 16 7.47 0Grand Rapids 1270 BECK WITH AVE NE GRAND RAPIDS 8/9/2019 CCFH 16 4.48 0Allen 1275 CHANDLER AVE LINCOLN PARK 6/26/2019 CCFH 16 4.48 0Lynch 128 BRINGTON ST HIGHLAND PARK 1/14/2019 CCFH 4 1.12 0Allen 1280 LINCOLN ST WYANDOTTE 5/14/2019 CCFH 16 4.48 0Mount Pleasant 1280 S CAMPUS DR MOUNT PLEASANT 10/9/2019 MCF 16 0 114.8Lynch 12815 E JEFFERSON AVE DETROIT 5/3/2019 CCFH 4 0.56 0Lynch 12831 CALDWELL HAMTRAMCK 6/20/2019 MCF 4 0 2.35Allen 12871 CONWAY ST DETROIT 10/28/2019 CCFH 4 1.12 0Allen 1288 FERRIS AVE LINCOLN PARK 8/30/2019 CCFH 16 2.24 0Michigan 13003 OSTRANDER RD LONDON 7/7/2019 CCFH 34 9.52 0

1302 1ST AVE 6/4/2019 CCFH 34 3.17 0Grand Rapids 1305 BUTH DR NE PLAINFIELD 1/8/2019 CCFH 34 2.47 0Kingsford 1305 DEVEREAUX ST IRON MOUNTAIN 10/24/2019 CCFH 34 28.56 0Grand Rapids 1312 KIMBERLY SE GRAND RAPIDS 7/22/2019 CCFH 16 2.24 0Allen 13212 WALNUT ST SOUTHGATE 11/14/2019 CCFH 16 4.24 0Grayling 1329 E.HOUGHTON LK DR DENTON TWP 4/12/2019 CCFH 34 23.8 0Traverse City 1330 W LONG LAKE RD LONG LAKE 8/26/2019 CCFH 34 1.59 0Allen 1339 WILSON AVE LINCOLN PARK 7/30/2019 CCFH 16 1.49 0Allen 1339 WILSON AVE LINCOLN PARK 7/31/2019 CCFH 16 3.36 0Grand Rapids 1340 W FULTON ST GRAND RAPIDS 8/21/2019 CCFH 34 19.04 0Lynch 13403 TACOMA ST DETROIT 7/25/2019 CCFH 4 4.48 0Grand Rapids 13437 LIME LAKE DR SOLON 11/7/2019 CCFH 34 4.51 0Lynch 13531 MANOR ST DETROIT 8/2/2019 CCFH 4 2.24 0Muskegon 1357 E ISABELLA AVE MUSKEGON MN 200 2/5/2019 CCFH 16 3.48 0Big Rapids 137 N OAK ST EVART 10/1/2019 CCFH 34 0.32 0Michigan 13706 STAMFORD ST VAN BUREN 9/5/2019 MCF 34 0 50.01

1373 PLETT RD 2/7/2019 CCFH 34 9.52 0Lynch 13811 ROSSINI DR DETROIT 6/4/2019 CCFH 4 1.74 0Allen 13946 BLACKSTONE ST DETROIT 3/27/2019 CCFH 4 13.92 0Allen 14005 MELLON ST DETROIT 11/1/2019 CCFH 4 1.12 0Allen 14005 MELLON ST DETROIT 11/5/2019 CCFH 4 1.12 0Lynch 14021 MAYFIELD ST DETROIT 3/12/2019 MCF 4 0 3.51Lynch 14027 BRINGARD ST DETROIT 7/31/2019 CCFH 4 0.56 0Allen 14127 MORTENVIEW DR TAYLOR 7/25/2019 CCFH 16 4.48 0Kingsford 1415 S STEPHENSON AVE IRON MOUNTAIN 11/12/2019 CCFH 34 9.01 0Michigan 14177 PLANK RD MILAN 10/7/2019 MCF 34 0 29.62Lynch 1421 VINEWOOD DETROIT 10/23/2019 CCFH 16 4.48 0Allen 14220 MARLOWE DETROIT 4/1/2019 CCFH 4 1.72 0

14241 COYLE ST 8/6/2019 CCFH 4 0.56 0Michigan 14360 ARDMORE DETROIT 3/27/2019 CCFH 4 2.32 0Allen 14377 COYLE ST DETROIT 8/23/2019 CCFH 4 1.12 0Lynch 1439 W ELIZABETH ST DETROIT 9/10/2019 MCF 4 0 5.44Lynch 14413 KENT DETROIT 7/8/2019 MCF 4 0 3.36Allen 14440 TIREMAN ST DETROIT 6/25/2019 MCF 4 0 5.37Allen 145 BERKLEY ST DEARBORN 5/23/2019 CCFH 16 4.48 0Allen 14500 FREELAND ST DETROIT 8/9/2019 CCFH 4 0.56 0Allen 14503 COYLE ST DETROIT 9/3/2019 CCFH 4 6.16 0Allen 14503 COYLE ST DETROIT 11/20/2019 MCF 4 6.16 5.83Allen 14516 TERRY ST DETROIT 7/9/2019 CCFH 4 1.12 0Lynch 14518 LIBERAL ST DETROIT 2/14/2019 CCFH 4 2.32 0Michigan 14551 MARLOWE ST DETROIT 3/26/2019 CCFH 4 0.19 0Allen 14570 SOUTHFIELD RD ALLEN PARK 3/22/2019 CCFH 16 4.58 0

14578 CHALFONTE 5/15/2019 CCFH 4 0.56 0Allen 14578 MARLOWE AND CHALFONT DETROIT 5/15/2019 CCFH 4 0.56 0Lynch 14607 WISCONSIN DETROIT 8/26/2019 CCFH 4 1.12 0Allen 14705 TIREMAN AVE DEARBORN 8/2/2019 MCF 4 0 6.5

14743 LANETTE ST 5/15/2019 CCFH 4 4.48 014744 W CHICAGO 5/22/2019 CCFH 4 1.2 0

Allen 14748 MICHIGAN DEARBORN 8/14/2019 MCF 34 0 263.89Allen 1487 PHILOMENE BLVD LINCOLN PARK 6/12/2019 MCF 16 0 5.04Allen 14890 SOUTHVIEW DR SOUTHGATE 11/1/2019 CCFH 16 2.12 0Grand Rapids 1490 BRIARCLIFF DR SE CASCADE 3/6/2019 CCFH 34 14.79 0Grand Rapids 14917 SHANER AVE NE NELSON 12/17/2019 CCFH 34 9.1 0Allen 14975 ARDMORE DETROIT 8/6/2019 MCF 4 0 10.19Traverse City 150 E ELEVENTH ST TRAVERSE CITY 6/14/2019 CCFH 34 2.38 0Muskegon 150 SEMINOLE RD NORTAN SHORES NSR 3/11/2019 MCF 16 0 181.61Allen 1500 MAYWOOD AVE ANN ARBOR 6/7/2019 CCFH 4 2.24 0Muskegon 1501 E APPLE AVE STE D MUSKEGON 10/8/2019 CCFH 16 7.47 0Lynch 1502 E EUCLID DETROIT 8/24/2019 MCF 16 0 258.65Allen 15047 MARK TWAIN ST DETROIT 4/10/2019 CCFH 4 0.56 0Grand Rapids 1505 WOODLAWN AVE SE EAST GRAND RAPIDS 3/29/2019 CCFH 16 2.29 0



1507 PINECREST AVE SW 6/4/2019 CCFH 16 1.12 0Lynch 1516 IROQUOIS ST DETROIT 12/13/2019 MCF 4 0 18.23Allen 15239 DEMEAN AVE ALLEN PARK 8/7/2019 CCFH 16 3.36 0Allen 15244 MCLAIN AVE DETROIT 6/28/2019 CCFH 16 2.24 0

15346 DIXIE 12/16/2019 CCFH 16 4.24 0Allen 15349 GULLEY RD TAYLOR 6/8/2019 CCFH 24 6.72 0Allen 15450 HUBBELL DETROIT 8/20/2019 CCFH 4 1.12 0Allen 15452 SOUTHFIELD FWY DETROIT 7/12/2019 CCFH 4 1.12 0Allen 15484 SOUTHFIELD FWY DETROIT 1/28/2019 CCFH 4 2.32 0Lynch 1550 TUXEDO ST DETROIT 10/23/2019 MCF 4 0 79.91

1556 FERN NE 7/23/2019 CCFH 4 1.68 0Lynch 15579 EASTWOOD ST DETROIT 10/23/2019 CCFH 4 2.24 0Lynch 15701 WYOMING ST DETROIT 10/16/2019 MCF 4 0 45.51Lynch 15829 PRAIRIE DETROIT 7/16/2019 MCF 4 0 10.18Allen 15838 SOUTHFIELD HWY DETROIT 7/24/2019 CCFH 4 1.12 0Allen 15841 CURTIS DETROIT 12/27/2019 CCFH 4 1.12 0Lynch 15862 NORMANDY ST DETROIT 2/25/2019 MCF 4 0 5.46Lynch 15919 PETSOKEY AVE DETROIT 4/12/2019 CCFH 4 30.24 0Michigan 15920 ALLEN RD TAYLOR 2/4/2019 CCFH 16 4.58 0Lynch 15985 WINDMILL POINTE GROSSE POINTE 9/17/2019 MCF 4 0 8.7

16000 W 7 MILE RD 7/12/2019 CCFH 4 1.12 0Allen 16159 LENORE DETROIT 12/13/2019 CCFH 16 4.24 0Allen 16222 PLYMOUTH RD DETROIT 3/25/2019 MCF 4 0 9.87Allen 16254 PREST ST DETROIT 10/15/2019 MCF 2 0 10.15Allen 1627 W DAVIDSON DETROIT 5/27/2019 CCFH 4 2.24 0Michigan 16500 ELWELL RD VAN BUREN 7/9/2019 CCFH 16 4.48 0Lynch 16504 PINEHURST DETROIT 8/27/2019 MCF 4 0 8.5Lynch 16527 WILDEMERE ST DETROIT 1/11/2019 MCF 4 0 5.79Lynch 16581 BAYLIS ST DETROIT 5/3/2019 CCFH 34 9.52 0Allen 16582 PRAIRIE ST DETROIT 7/23/2019 CCFH 34 4.76 0Allen 1668 MYRON AVE LINCOLN PARK 9/27/2019 CCFH 16 4.48 0

1669 NE BALL AVE 5/8/2019 CCFH 16 2.99 0Lynch 1686 W. EUCLID ST DETROIT 6/21/2019 CCFH 4 2.24 0Allen 16920 PEMBROKE AVE DETROIT 5/23/2019 CCFH 4 1.12 0Lynch 17 WELLINGTON PL GROSSE POINTE 4/26/2019 MCF 4 0 12.14Allen 17141 SHAFTSBURY AV DETROIT 5/1/2019 MCF 4 0 0.56Mount Pleasant 1715 CHIPPEWA WAY MOUNT PLEASANT 9/9/2019 MCF 34 0 786.16Michigan 17200 N MI STATE RD 52 LYNDON 7/25/2019 MCF 34 0 57.5Allen 17250 WESTBROOK DETROIT 10/29/2019 MCF 4 0 841.88Grand Rapids 1729 MARGARET AVE SE GRAND RAPIDS 10/11/2019 CCFH 4 0.56 0Allen 17410 ECORSE RD ALLEN PARK 9/25/2019 CCFH 16 4.48 0Big Rapids 17435 APACHE TRL HOWARD CITY 7/19/2019 CCFH 34 4.76 0Allen 17531 STANSBURY ST DETROIT 4/18/2019 CCFH 4 1.68 0Allen 17555 PARKE LN GROSSE ILE 6/27/2019 CCFH 34 9.52 0Lynch 17601 MOUND RD DETROIT 9/25/2019 CCFH 4 0.56 0Grand Rapids 1761 RONDO SE KENTWOOD 8/6/2019 CCFH 16 1.12 0Grand Rapids 1761 RONDO ST SE KENTWOOD 7/29/2019 CCFH 16 1.12 0Allen 17720 LENNANE ST REDFORD 2/21/2019 MCF 16 0 34.05Lynch 1774 PARKER DETROIT 8/15/2019 CCFH 16 4.48 0Allen 17750 LENNANE REDFORD 2/21/2019 MCF 16 0 84.64

17754 WORMER ST 4/1/2019 MCF 16 0 20.09Allen 18009 STANSBURY DETROIT 4/16/2019 CCFH 4 0.56 0Lynch 18014 CHALMERS ST DETROIT 5/2/2019 CCFH 4 0.56 0Lynch 18032 CHALMERS ST DETROIT 4/29/2019 CCFH 4 0.84 0Allen 1817 FORT ST WYANDOTTE 8/29/2019 MCF 16 0 13.93Allen 18200 APPOLINE DETROIT 2/6/2019 MCF 4 0 2.26Allen 18203 ROBSON ST DETROIT 3/26/2019 CCFH 4 0.57 0Allen 18203 ROBSON ST DETROIT 4/24/2019 CCFH 4 0.57 0Lynch 18210 SANTA ROSA DR DETROIT 11/27/2019 CCFH 4 1.06 0Grand Rapids 1825 CHICAGO DR SW WYOMING 3/26/2019 CCFH 16 24.02 0Allen 18257 ROBSON DETROIT 3/28/2019 CCFH 4 1.14 0Allen 18257 ROBSON ST DETROIT 6/6/2019 CCFH 4 0.09 0Muskegon 1826 PAPPAS RD MUSKEGON 5/26/2019 CCFH 16 0.37 0Allen 18266 HUNTLEY AVE BROWNSTOWN 9/11/2019 CCFH 16 1.12 0Allen 18409 PARKE LN GROSSE ILE 6/26/2019 CCFH 34 14.28 0Allen 18409 PARKE LN GROSSE ILE 9/10/2019 CCFH 34 14.28 0Allen 1842 DEERING ST GARDEN CITY 5/1/2019 CCFH 4 8.96 0Allen 18443 ROBSON DETROIT 4/3/2019 MCF 4 0 8.37Allen 1845 CAPITOL AVE LINCOLN PARK 9/26/2019 CCFH 16 3.36 0Lynch 18455 REVERE DETROIT 7/12/2019 CCFH 4 1.12 0

18500 ILENE ST 7/1/2019 CCFH 4 1.68 0Allen 1853 CAPITOL AVE LINCOLN PARK 9/5/2019 MCF 16 0 8.96Allen 1853 CAPITOL AVE LINCOLN PARK 10/19/2019 CCFH 16 8.96 8.96Lynch 18617 GREELEY ST DETROIT 4/26/2019 CCFH 4 3.36 0Allen 1869 CAPITOL AVE LINCOLN PARK` 9/25/2019 CCFH 16 8.96 0Muskegon 1879 SUPERIOR MUSKEGON 4/23/2019 MCF 34 0 59.78Allen 18818 FORT RIVERVIEW 2/20/2019 MCF 16 0 10.9Muskegon 1883 LAKESHORE DR MUSKEGON 10/25/2019 CCFH 16 2.24 0Allen 18903 ROBSON ST DETROIT 4/11/2019 MCF 4 0 7.64Lynch 18925 LIVERNOIS AVE DETROIT 6/10/2019 MCF 34 0 17.32

18935 SCHONHERR ST 2/11/2019 CCFH 4 1.16 0Allen 18981 ROBSON ST DETROIT 4/15/2019 MCF 4 0 1.28Allen 1909 W LONGMEADOW RD TRENTON 5/28/2019 CCFH 16 4.26 0Allen 19169 LAHSER RD DETROIT 8/1/2019 CCFH 4 1.49 0



Allen 1923 RAYMOND AVE DEARBORN 8/14/2019 CCFH 16 1.49 0Allen 19233 LAHSER RD DETROIT 8/9/2019 CCFH 4 1.12 0Allen 19334 MAIN SOUTHGATE 2/19/2019 MCF 34 0 105.68Allen 19345 WINTHDROP ST DETROIT 8/10/2019 CCFH 4 0.56 0Lynch 19389 CANTERBURY RD DETROIT 10/16/2019 CCFH 4 0.06 0Grand Rapids 1940 44TH ST SE GRAND RAPIDS 8/19/2019 CCFH 34 4.76 0Allen 19413 PREVOST ST DETROIT 7/1/2019 CCFH 4 0.56 0Grand Rapids 1944 PRAIRIE PKWY SW WYOMING 5/9/2019 CCFH 16 4.48 0Grand Rapids 1944 PRAIRIE PKY SW WYOMING 5/14/2019 CCFH 16 5.6 0Allen 19444 PREVOST ST HWY DETROIT 7/29/2019 CCFH 4 0.56 0Michigan 1946 WHITE AVE MILFORD 7/25/2019 CCFH 4 1.12 0Allen 19491 APPOLINE DETROIT 2/9/2019 MCF 4 0 42.66Allen 19552 SAWYER ST DETROIT 1/2/2019 CCFH 4 1.24 0Lynch 19586 HIKORY DETROIT 6/17/2019 CCFH 4 0.65 0

1960 CHESTNUT ST 6/5/2019 CCFH 34 1.59 0Allen 19610 ALGONAC ST DETROIT 8/11/2019 CCFH 4 0.56 0Allen 19745 WHITCOMB ST DETROIT 9/18/2019 CCFH 4 1.12 0Lynch 19784 ROWE DETROIT 7/27/2019 CCFH 4 0.28 0Allen 19797 RUTHERFORD ST DETROIT 7/23/2019 CCFH 4 2.24 0Lynch 19800 CHARLESTON HIGHLAND PARK 5/7/2019 CCFH 4 2.24 0Allen 19807 LAHSER RD DETROIT 7/18/2019 CCFH 4 0.56 0Grand Rapids 1990 CASCADE FARMS DR. SE GRAND RAPIDS 6/10/2019 CCFH 34 7.14 0

19904 BILMORE 7/10/2019 MCF 4 0 80.17Muskegon 1991 LAKESHORE DR MUSKEGON 9/9/2019 CCFH 16 8.96 0

1993 E WILLIS ST 2/3/2019 MCF 16 0 48.58Allen 19939 WINTHROP ST DETROIT 4/10/2019 CCFH 4 1.12 0Allen 19939 WINTHROP ST DETROIT 9/23/2019 CCFH 4 1.12 0Lynch 19966 WASHBURN ST DETROIT 1/25/2019 MCF 4 0 3.91Alpena 1st Ave ALPENA 6/26/2019 CCFH 34 1.59 0Grand Rapids 20 CORINNIE ST SW GRAND RAPIDS 7/17/2019 CCFH 16 4.48 0Muskegon 200 HAMILTON MUKSEGON 5/23/2019 CCFH 16 2.24 0Allen 20018 FERGUSON ST DETROIT 8/14/2019 CCFH 4 0.56 0Allen 20040 SCHOOLCRAFT DETROIT 1/5/2019 CCFH 16 7.46 0

201 GRAND RIVER AVE 2/13/2019 CCFH 16 4.64 0Grand Rapids 2015 LAKE MICHIGAN DR NW GRAND RAPIDS 10/15/2019 CCFH 16 2.24 0Lynch 20164 CHARLESTON ST DETROIT 1/23/2019 CCFH 4 0.87 0Allen 2018 DETROIT ST DEARBORN 11/4/2019 CCFH 16 4.24 0Allen 2018 DETROIT ST DEARBORN 11/26/2019 CCFH 16 4.24 0Grayling 202 CHERRY HILL ST HOUGHTAN LAKE 5/6/2019 CCFH 34 9.52 0

202 N. PARK DE NW 4/11/2019 CCFH 34 4.76 0Michigan 2020 HANNAN RD CANTON 1/4/2019 CCFH 34 1.76 0Allen 20240 ANNAPOLIS ST DEARBORN HEIGHTS 7/19/2019 CCFH 16 2.24 0Lynch 2025 BEAUFAIT DR GROSSE POINTE WOODS 10/17/2019 CCFH 34 38.08 0Allen 20274 FOXBORO ST RIVERVIEW 7/23/2019 CCFH 16 4.48 0Allen 20285 LAHSER RD DETROIT 7/15/2019 CCFH 4 1.12 0Michigan 2034 LAKESHORE DR MUSKEGON 6/17/2019 MCF 16 0 6.62Mount Pleasant 204 E DAVIS ST MIDDLETON 10/7/2019 CCFH 34 4.76 0Lynch 20403 CHARLESTON ST DETROIT 9/5/2019 CCFH 4 1.12 0Allen 20423 MARK TWAIN ST DETROIT 12/28/2019 CCFH 4 0.53 0Allen 2059 NEW YORK AVE LINCOLN PARK 9/18/2019 MCF 16 0.92 0Allen 20625 W RIVER RD GROSSE ILE 10/10/2019 CCFH 34 24.67 0Grand Rapids 2070 10 MILE NE COMSTOCK PARK 2/2/2019 CCFH 34 4.93 0Allen 2073 Philomene Blvd LINCOLN PARK 6/12/2019 CCFH 16 4.48 0Lynch 20888 NORWOOD DR HARPER WOODS 6/6/2019 CCFH 34 9.52 0Mount Pleasant 209 W BROADWAY ST MOUNT PLEASANT 5/16/2019 CCFH 34 1.59 0

210 US 31 SOUTH 4/8/2019 CCFH 34 9.52 0Escanaba 2107 5th Ave S Escanaba 7/22/2019 CCFH 34 1.59 0Michigan 211 BUCHOLZ CT ANN ARBOR 8/28/2019 MCF 4 2.24 0Allen 213 BEAKES ANN ARBOR 7/30/2019 CCFH 16 4.48 0Michigan 213 BEAKES ST ANN ARBOR 6/29/2019 CCFH 16 4.48 0Traverse City 213 E RD ST LEELANAU 5/31/2019 CCFH 34 4.76 0Allen 2155 NEW YORK AVE LINCOLN PARK 7/30/2019 CCFH 16 4.48 0Grayling 216 E 10th ST MENTOR 8/14/2019 CCFH 34 9.52 0Allen 21749 CANTERBURY AVE GROSSE ILE 10/28/2019 CCFH 34 9.52 0Michigan 2175 VALLEY GATE MILFORD 5/28/2019 CCFH 34 14.28 0Michigan 218 MONROE ST SALINE 9/26/2019 CCFH 34 9.52 0Grand Rapids 219 ELMWOOD NE GRAND RAPIDS 8/6/2019 CCFH 4 1.12 0Grand Rapids 2190 64th ST SW BYRON CENTER 9/6/2019 CCFH 34 9.52 0Grand Rapids 21955 PINE ST SAND LAKE 9/10/2019 CCFH 34 4.76 0

21965 THOROFARE RD 3/6/2019 CCFH 34 9.52 0Michigan 220 CANFIELD ST MILAN 7/2/2019 CCFH 16 6.72 0Grand Rapids 2211 VALLEYWOOD SE GRAND RAPIDS 8/29/2019 CCFH 34 4.76 0Michigan 223 MADISON CHELSEA 5/21/2019 CCFH 16 0 267.94Allen 22359 CHERRY HILL ST DEARBORN 5/14/2019 CCFH 16 4.48 0Lynch 2239 FENKELL DETROIT 10/1/2019 MCF 4 0 400.11Allan 224 BERKLEY ST DEARBORN 9/7/2019 CCFH 16 4.48 0Mount Pleasant 226 N JANE FULTON 8/14/2019 MCF 34 0 19.04Allen 22624 WEST RD TRENTON 5/29/2019 CCFH 16 6.96 0Allen 22624 WEST RD TRENTON 5/29/2019 CCFH 16 6.96 0Allen 22686 GARRISON DEARBORN 7/1/2019 CCFH 16 4.48 0Big Rapids 227 N OAK ST EVART 10/10/2019 CCFH 34 0.16 0Lynch 2274 LAMOTHE ST DETROIT 9/22/2019 CCFH 4 0.56 0Allen 22908 GODDARD RD TAYLOR 11/6/2019 CCFH 16 0.35 0Michigan 2302 WESTBROOKE CT ANN ARBOR 4/23/2019 CCFH 34 9.52 0



2305 C6 SANDALWOOD 6/22/2019 CCFH 25 14 0Allen 23101 EUREKA RD TAYLOR 10/28/2019 CCFH 16 6.72 0Allen 23307 BEECHCREST ST DEARBORN HEIGHTS 10/28/2019 CCFH 16 13.44 0Allen 23312 EDWARD ST DEARBORN 12/11/2019 CCFH 16 2.12 0Muskegon 2358 W. GILES RD LAKETON 6/26/2019 CCFH 16 3.36 0

2359 W GILES RD 6/26/2019 CCFH 4 0.84 0Allen 23609 PARKE LN GROSSE ILE 8/29/2019 CCFH 34 1.59 0Michigan 23645 HURON RIVER DR HURON TWP 6/27/2019 MCF 34 0 111.99Allen 23668 SIBLEY RD BROWNSTOWN 6/25/2019 CCFH 34 7.14 0Allen 23713 WILSON AVE DEARBORN 6/7/2019 CCFH 16 0.07 0Allen 23761 WILSON AVE DEARBORN 6/4/2019 CCFH 16 4.64 0Petoskey 2385 PENNSYLVANIA AVE HARBOR SPRINGS 5/28/2019 CCFH 34 1.9 0Lynch 2411 W GRAND BLVD DETROIT 1/23/2019 CCFH 4 0.04 0Grand Rapids 2412 WINDVIEW SW WYOMING 1/22/2019 MCF 34 0 268.02Allen 24301 ROCKFORD ST DEARBORN 10/11/2019 CCFH 16 0.09 0Grand Rapids 2434 ARUNDEL DR SE GRAND RAPIDS 8/22/2019 CCFH 16 4.48 0Allen 24424 COLONIAL DR WOODHAVEN 10/9/2019 CCFH 34 10.57 0Lynch 2468 MARKET ST DETROIT 11/5/2019 CCFH 16 8.48 0Lynch 2478 RIOPELLE DETROIT 9/25/2019 MCF 16 15.07 0Allen 24897 PURITAN REDFORD 10/8/2019 MCF 16 0 7.09

25039 ROUGE RIVER DR 12/16/2019 CCFH 16 4.24 0Grayling 2525 INDUSTRIAL DR GRAYLING 10/18/2019 CCFH 34 9.52 0Traverse City 2533 CARROLL RD TRAVERSE CITY 9/12/2019 CCFH 34 4.76 0Allen 255 BERKLEY ST DEARBORN 5/21/2019 CCFH 16 6.72 0Michigan 255 FERMAN ST MILAN 10/2/2019 CCFH 16 2.24 0Michigan 2550 MEADOWOOD LN MILFORD 3/14/2019 MCF 34 0 41.41Muskegon 2555 W RIVERWOOD DR TWIN LAKE 10/26/2019 CCFH 34 9.52 0Muskegon 256 BIRCH DR LAKETON 11/4/2019 CCFH 16 4.24 0Big Rapids 2569 W Bay Dr Sand Lake 1/1/2019 CCFH 34 9.52 0Allen 25718 SCHOOLCRAFT REDFORD 4/26/2019 MCF 16 0 13.05Allen 25966 SENECA ST FLAT ROCK 10/15/2019 CCFH 16 4.48 0Traverse City 2639 BLUE RIDGE LN GARFIELD 8/22/2019 CCFH 34 28.56 0Grand Rapids 2640 CLYDE PARK SW WYOMING 10/18/2019 CCFH 16 2.24 0Lynch 2644 W GRAND BLVD DETROIT 6/5/2019 MCF 4 0 11.57Michigan 26581 RINNE RD NEW BOSTON 9/26/2019 MCF 34 0 161.43Lynch 2663 E PALMER ST DETROIT 9/10/2019 MCF 16 0 7.38Mount Pleasant 2668 S IVY LN UNION 11/21/2019 CCFH 34 4.51 0Allen 26714 ROYAL DR WOODHAVEN 10/18/2019 CCFH 34 4.76 0Allen 26767 BELLE LN REDFORD 6/7/2019 MCF 16 284.18 0Allen 26805 VAN BORN RD TAYLOR 5/15/2019 CCFH 16 4.48 0Allen 26905 DOXTATOR ST DEARBORN HEIGHTS 12/18/2019 CCFH 16 4.24 0Allen 26998 BLUE HERON DR FLAT ROCK 11/2/2019 CCFH 34 9.01 0Michigan 2700 STONE MEADOW DR MILFORD 10/3/2019 MCF 34 0 70.78Lynch 2705 BELMONT ST HAMTRACK 2/19/2019 MCF 4 0 0.96

27100 VAN BORN RD 1/18/2019 MCF 16 0 70.41Michigan 2716 LOWELL RD ANN ARBOR 8/16/2019 CCFH 34 9.52 0Allen 27165 GRAND RIVER AVE REDFORD 4/22/2019 CCFH 16 4.48 0Grand Rapids 2719 PLAINFIELD AVE NE GRAND RAPIDS 1/17/2019 CCFH 4 0.58 0Michigan 2721 INTERNATIONAL DR YPSILANTI 9/10/2019 MCF 34 0 61.59Tawas 2723 S M76 WEST BRANCH 7/5/2019 CCFH 34 3.17 0Grand Rapids 2728 3 MILE NE GRAND RAPIDS 8/27/2019 CCFH 34 14.28 0Michigan 2731 NEWPORT ANN ARBOR 11/19/2019 MCF 0 0 1689.83Grand Rapids 2747 ELMWOOD DR SE EAST GRAND RAPIDS 10/10/2019 CCFH 16 1.49 0

27485 SIBLEY RD 7/3/2019 CCFH 34 9.52 0Michigan 27845 FORD RD GARDEN CITY 10/3/2019 CCFH 16 8.96 0Lynch 280 ALFRED ST DETROIT 8/12/2019 CCFH 16 4.48 0

282 LINCOLN 6/12/2019 CCFH 4 0.56 0Michigan 28204 FORD 5/26/2019 CCFH 16 4.48 0Lynch 2822 JOHN R DETROIT 10/23/2019 CCFH 16 2.24 0Grand Rapids 2833 EASTERN AVE SE GRAND RAPIDS 6/26/2019 CCFH 16 4.48 0Lynch 284 GROVE ST HIGHLAND PARK 4/16/2019 CCFH 4 0.56 0Allen 28403 OLD N GIBRALTAR RD GIBRALTOR 7/10/2019 CCFH 16 4.48 0Muskegon 2843 WORDEN ST NORTON SHORES 9/11/2019 CCFH 16 4.48 0Tawas 2847 N US HIGHWAY 23 OSCODA 7/22/2019 CCFH 34 3.17 0Allen 2872 W JEFFERSON AVE TRENTON 10/16/2019 CCFH 16 4.48 0Michigan 2874 CANTERBURY CT MILFORD 9/3/2019 MCF 34 0 1903.9

28778 COLEMAN 1/29/2019 CCFH 34 9.52 0Lynch 288 GROVE ST HIGHLAND PARK 1/8/2019 CCFH 4 0.02 0Michigan 28937 WARREN RD GARDEN CITY 3/19/2019 CCFH 16 2.29 0Michigan 28937 WARREN RD GARDEN CITY 3/19/2019 MCF 16 2.29 52.79Muskegon 2894 SYLVAN MUSKEGON TOWNSHIP 9/20/2019 CCFH 16 3.73 0Michigan 2900 GOLFSIDE PITTSFIELD 6/3/2019 MCF 4 0 31.37

2900 HOLIDAY PINES 5/15/2019 CCFH 34 3.17 0Grand Rapids 2901 WOODGLEN NW GRAND RAPIDS 6/4/2019 CCFH 16 4.48 0

2925 EAGLE ISLAND 5/14/2019 CCFH 34 9.52 0Muskegon 2986 QUARTERLINE RD FRUITPORT TOWNSHIP 10/24/2019 MCF 16 0 8.86Muskegon 300 N APRICOT LANE SHELBY 10/11/2019 CCFH 34 9.52 0Michigan 3000 FULLER RD ANN ARBOR 11/6/2019 CCFH 100 39.49 0Lynch 3007 NORTHWESTERN DETROIT 11/14/2019 MCF 16 4.32 0Grand Rapids 3020 WOODRIFF CIR.SE EAST GRAND RAPIDS 4/19/2019 CCFH 16 2.24 0Kingsford 3031 STATE HIGHWAY M69 MANSFIELD 12/9/2019 CCFH 34 1.5 0Grand Rapids 304 41 ST SW WYOMING 3/18/2019 MCF 16 0 180.18Grand Rapids 3049 THONCREST DR SE CASCADE 10/15/2019 CCFH 34 3.97 0Grayling 305 GOLFREW ROSSOMNON/LYON 7/9/2019 CCFH 34 19.04 0



Allen 3063 BIDDLE AVE WYANDOTTE 11/7/2019 CCFH 16 1.41 0Petoskey 3063 GRATIOT ST TUSCRORA 11/11/2019 CCFH 34 1.5 0Allen 3082 CHANDLER LP 6/18/2019 CCFH 16 4.48 0Grand Rapids 309 LAKESIDE DR SE GRAND RAPIDS 9/17/2019 CCFH 4 1.12 0Grand Rapids 3099 28 TH SE GRAND RAPIDS 8/6/2019 CCFH 34 9.52 0Michigan 310 BAYPOINTE DR BELLEVILLE 4/5/2019 CCFH 34 9.52 0Escanaba 310 N 12th ST ESCANABA 10/18/2019 CCFH 34 3.17 0Traverse City 310 S CEDAR ST TRAVERSE CITY 6/26/2019 CCFH 34 2.38 0Alpena 312 W MIRE ST APT B ALPEANA 8/21/2019 CCFH 34 228.48 0Michigan 3120 ANDORA DR SUPERIOR 5/30/2019 CCFH 34 9.52 0Grand Rapids 3130 Alpine NW Grand Rapids/Alpine TWP 5/21/2019 MCF 34 0 195.3Allen 31462 BALMORAL ST GARDEN CITY 6/17/2019 CCFH 16 4.48 0Michigan 31468 BLOCK ST GARDEN CITY 2/5/2019 CCFH 16 2.32 0Allen 31489 LEONA ST GARDEN CITY 5/28/2019 CCFH 16 4.48 0Lynch 3170 GILBERT DETROIT 9/27/2019 MCF 4 0 2.71Lynch 3185 GILBERT ST DETROIT 7/31/2019 MCF 4 0 7.84Grand Rapids 3188 BONNELL SE EAST GRAND RAPIDS 7/9/2019 CCFH 16 4.48 0Grand Rapids 3196 CORPORATE GROVE DR HUDSONVILLE 10/21/2019 CCFH 34 0.79 0Grand Rapids 32 QUIMBY ST NE GRAND RAPIDS 9/23/2019 CCFH 4 0.56 0Traverse City 320 FRANKLIN ST APT 2 TRAVERSE CITY 9/7/2019 CCFH 16 3.36 0Muskegon 320 WELLESLEY DR NORTON SHORES 10/2/2019 CCFH 16 2.24 0Grand Rapids 3215 BURTON ST SE GRAND RAPIDS 8/27/2019 MCF 16 0 8.96Grand Rapids 322 VALLEY NW GRAND RAPIDS 9/25/2019 CCFH 4 1.12 0Traverse City 323 GREEN ACRES LN ELK RAPIDS 7/18/2019 MCF 34 0 5.6Traverse City 323 MAIN ST FRANKFORT 5/17/2019 CCFH 34 4.76 0

3235 EDGEWOOD DR 2/19/2019 CCFH 4 1.12 0Mount Pleasant 3255 LAPHAM DR HAYES 6/10/2019 CCFH 34 19.04 0Grand Rapids 3264 HAGER GEORETOWN WP 9/11/2019 CCFH 34 7.14 0

3288 ALLEN ST 12/21/2019 CCFH 16 2.24 0Muskegon 329 E DAYTON FREMONT 4/25/2019 CCFH 16 3.36 0Michigan 32985 JOHN HAUK ST GARDEN CITY 5/3/2019 CCFH 16 4.48 0Michigan 3300 ANN ARBOR SALINE RD ANN ARBOR 11/6/2019 MCF 34 0 463.37Grand Rapids 3300 EAGLE RUN NE GRAND RAPIDS 8/5/2019 CCFH 34 2.38 0Lynch 3301 23 RD DETROIT 7/26/2019 MCF 16 0 3736.43Traverse City 3301 VETERANS DR GARFIELD TOWNSHIP 1/8/2019 CCFH 34 2.48 0Muskegon 3310 ALBERTA NORTON SHORES NSR 7/9/2019 CCFH 34 6.35 0Lynch 3314 HOLOBROOK ST HAMTRAMCK 7/8/2019 MCF 4 0 21.68Lynch 3321 CLIPPERT ST DETROIT 8/26/2019 CCFH 4 2.24 0Grand Rapids 3360 GOLDEN EAGLE WAY HUDSONVILLE 9/11/2019 MCF 34 0 757.47Muskegon 3370 E LAKETON AVE MUSKEGON 8/21/2019 CCFH 16 2.24 0Grand Rapids 3410 CHICAGO DR HUDSONVILLE 3/29/2019 CCFH 16 4.64 0Grand Rapids 3418 NOBB HILL DR JENISON 2/19/2019 CCFH 34 49.3 0Grand Rapids 3435 VAN BUREN ST HUDSONVILLE 8/29/2019 CCFH 16 1.49 0Lynch 3437 3 RD DETROIT 3/8/2019 MCF 16 0 446.1Lynch 3454 BAGLEY ST DETROIT 9/17/2019 CCFH 16 4.18 0Grand Rapids 350 NORTHLAND DR ROCKFORD 9/5/2019 CCFH 16 6.72 0Grand Rapids 3500 BUTTRICK AVE SE CASCADE 3/12/2019 CCFH 34 4.93 0Mount Pleasant 3520 W BEAL CITY RD BEAL CITY 9/20/2019 CCFH 34 5.55 0Michigan 3550 OLD PLANK RD MILFORD 12/6/2019 CCFH 34 0.3 0Muskegon 3558 HENRY ST NORTON SHORES 8/17/2019 CCFH 16 6.72 0Grand Rapids 3572 BLUE JAY ST MONTCALM 5/28/2019 CCFH 34 0.16 0Lynch 3579 E WARREN AVE DETROIT 9/30/2019 CCFH 16 4.48 0

36 GLENDALE 3/13/2019 CCFH 4 1.12 0Michigan 361 RAWSONVILLE DR VAN BUREN 6/20/2019 CCFH 34 38.08 0Allen 364 CHERRY ST WYANDOTTE 6/3/2019 CCFH 16 2.32 0Lynch 3654 HUNT DETROIT 2/28/2019 MCF 16 0 11.46Muskegon 367 E SHERMAN BLVD MUSKEGON HEIGHTS 10/11/2019 CCFH 16 3.36 0Michigan 368 PLEASANT RIDGE CT SALINE 4/21/2019 CCFH 16 4.48 0Michigan 36898 MARIO ANN CT ROMULUS 6/5/2019 MCF 16 0 7.43Grand Rapids 3690 MALLORY AVE SW WYOMING 9/22/2019 CCFH 16 2.24 0Allen 3700 PRACTICE DR MELVINDALE 4/18/2019 CCFH 34 12.69 0Lynch 3765 FULLERTON DETROIT 6/7/2019 CCFH 16 0.15 0Grand Rapids 3768 BRADFORD ST NE GRAND RAPIDS 9/30/2019 CCFH 34 4.76 0Allen 3770 BROOKSHIRE TRENTON 4/24/2019 CCFH 16 4.48 0Muskegon 3770 HESS NORTON SHORES 6/24/2019 CCFH 16 1.87 0Grand Rapids 3810 LAKE BIRCH ST NE GRAND RAPIDS 10/23/2019 CCFH 34 4.76 0Lynch 3830 FULLERTON DETROIT 7/12/2019 CCFH 16 4.48 0Lynch 3886 BELMONT ST HAMTRAMCK 7/11/2019 CCFH 34 9.52 0Allen 3900 HAGGERTY CANTON 9/6/2019 MCF 34 0 58.46Michigan 391 RUSIC LN N BELLEVILLE 9/3/2019 MCF 34 0 51.57Grand Rapids 3926 KIRKSHIRE DR SE GRAND RAPIDS 7/8/2019 CCFH 16 1.12 0Lynch 3940 CANIFF ST HAMTRAMCK 4/5/2019 MCF 16 0 12.11Lynch 3970 CADIEUX RD DETROIT 8/30/2019 CCFH 4 0.37 0Lynch 3973 MIRACLES BLVD DETROIT 9/16/2019 MCF 16 0 8.05Michigan 3975 JACKSON RD SCIO 8/1/2019 CCFH 34 9.52 0Allen 3979 13TH ST ECORSE 12/4/2019 CCFH 4 1.06 0Petoskey 398 W 4th ST HARBOR SPRINGS 8/5/2019 CCFH 34 1.59 0Michigan 3980 RANCHERO DR PITTSFIELD 9/24/2019 CCFH 34 4.76 0Allen 40 W ALEXIS ST ECOSE 9/27/2019 CCFH 4 1.12 0Lynch 40 W ROBINWOOD HIGHLAND PARK 10/11/2019 MCF 4 0 72.59Traverse City 400 E EIGHT ST TRAVERSE CITY 6/5/2019 CCFH 16 2.24 0Lynch 4004 E OUTER DR DETROIT 11/7/2019 MCF 16 0 20.17Sault Sainte Marie 4007 I 75 BUSINESS SPUR SAULT STE MARIE 5/7/2019 CCFH 34 2.38 0Grand Rapids 404 LAMOREAUX DR NW ALPINE 2/28/2019 CCFH 16 2.29 0



Grand Rapids 4050 PLAINFIELD AVE NE PALINFIELD 8/13/2019 CCFH 16 3.36 0Grand Rapids 4057 56th SW St WYOMING 1/17/2019 CCFH 34 9.86 0Lynch 4087 FULLERTON ST DETROIT 5/20/2019 CCFH 16 6.72 0Lynch 4100 W OUTER DR DETROIT 5/3/2019 CCFH 4 1.12 0Michigan 41460 S HAGGERTY CIRCLE CANTON 7/31/2019 MCF 34 0 103.54

41460 S HAGGERTY CIRCLE 7/31/2019 MCF 34 0 103.54Lynch 4161 NOTTINGHAM RD DETROIT 11/13/2019 CCFH 4 0.53 0Michigan 417 GLAZIER RD SYLVAN 11/19/2019 CCFH 34 0.75 0Allen 418 MERIDAN ST DEARBORN 7/26/2019 CCFH 16 4.48 0Grand Rapids 4180 BLUE HERON DR SE KENTWOOD 2/6/2019 CCFH 34 4.93 0Lynch 42 SAND BAR LN DETROIT 7/25/2019 MCF 16 0 28.94Grand Rapids 421 PLYMOUTH SE GRAND RAPIDS 5/20/2019 MCF 4 0 78.96Lynch 4215 BALFOUR DETROIT 7/19/2019 CCFH 4 1.12 0Michigan 42278 SARATOGA CIR CANTON 9/5/2019 MCF 34 0 7.13Traverse City 423 US HIGHWAY 31 S BLAIR 9/9/2019 CCFH 34 9.52 0Grand Rapids 4237 GREENBEIR CT SE GRAND RAPIDS 8/12/2019 CCFH 34 4.47 0Michigan 42660 SALTZ RD CANTON 7/12/2019 CCFH 34 19.04 0Traverse City 428 S SHORE DR NORTHPORT 4/11/2019 CCFH 34 9.52 0Allen 435 BERKLEY ST DEARBORN 5/16/2019 MCF 16 0 2.04Lynch 4385 NOTTINGHAM RD DETROIT 6/26/2019 MCF 4 0 0.26Allen 4394 CHALMERS DETROIT 9/6/2019 CCFH 4 2.24 0Lynch 44 HARBOR HILL RD GROSSE POINTE FARMS 11/30/2019 MCF 34 0 281.59Michigan 44005 SOUTHAMPTON DR CANTON 10/16/2019 CCFH 34 4.76 0Grand Rapids 4405 44 TH ST SE KENTWOOD 8/7/2019 CCFH 34 9.52 0Michigan 4429 GRANDEUR OAKS LN ANN ARBOR 7/29/2019 CCFH 34 7.14 0Grand Rapids 4430 SUGARBUSH CT SW WYOMING 4/13/2019 CCFH 34 9.52 0Allen 4465 SYRACUSE ST DEARBORN HEIGHTS 11/7/2019 CCFH 16 4.24 0Allen 4473 SYRACUSE ST DEARBORN HEIGHTS 11/7/2019 CCFH 16 4.24 0Grand Rapids 448 BRIDGE ST SW GRAND RAPIDS 3/28/2019 CCFH 4 1.16 0

448 WEBSTER NW 7/24/2019 CCFH 4 1.4 0451 COLLINS 11/20/2019 CCFH 16 2.12 0

Muskegon 4555 HARDING CT NORTAN SHORES NSR 2/28/2019 CCFH 16 9.15 0Grand Rapids 4575 44th ST SE KENTWOOD 9/17/2019 CCFH 34 4.76 0Big Rapids 4587 N PARK REED CITY 8/8/2019 CCFH 16 4.48 0Lynch 4590 MILITARY ST DETROIT 9/11/2019 MCF 4 0 3.61Allen 460 PAGEL AVE LINCOLN PARK 10/2/2019 CCFH 16 3.36 0Grand Rapids 4617 S DIVISION AVE WYOMING 4/2/2019 CCFH 16 109.82 0

4620 STEIN RD 8/13/2019 CCFH 34 19.04 0Michigan 46315 WEAR RD SUMPTER 2/12/2019 MCF 34 9.52 44.61Grand Rapids 4636 TETON CTSE GRANDVILLE 7/1/2019 CCFH 16 2.24 0Michigan 46485 KILLARNEY CIR CANTON 10/9/2019 CCFH 34 14.28 0Allen 4700 W OUTER DR DETROIT 4/2/2019 CCFH 4 1.72 0Grand Rapids 4764 LEONARD ST NW TALLMADGE TWP 8/21/2019 CCFH 34 4.76 0Lynch 4801 W WARREN AVE DETROIT 8/5/2019 MCF 4 0 882.29Traverse City 4812 VANCE RD BLAIR 8/19/2019 CCFH 34 28.56 0Tawas 4830 LAKE TOLAKE RD GREENBUSH 9/5/2019 CCFH 34 6.35 0Allen 486 W MAIN ST MILAN 6/18/2019 CCFH 16 6.96 0Lynch 490 CHARLOTTE DETROIT 8/6/2019 MCF 16 0 97.69Traverse City 4973 NORTHWOOD DR GLEN ARBOR 8/14/2019 CCFH 34 1713.6 0Lynch 5000 FREDRO HAMTRAMCK 6/14/2019 CCFH 16 6.72 0Lynch 5045 EASTLAWN ST DETROIT 2/13/2019 CCFH 4 1.16 0Michigan 507 GLAZIER RD CHELSEA 7/23/2019 MCF 34 0 6.73Traverse City 508 WEBSTER ST TRAVERSE CITY 12/6/2019 CCFH 16 2.12 0

5080 KRAFT SE 7/1/2019 CCFH 34 23.8 0Allen 5095 S HURON RIVER DR BERLIN 12/18/2019 CCFH 16 4.24 0

512 E CASS ST 6/19/2019 CCFH 34 2.38 0Petoskey 5124 LOWER SHORE DR HARBOR SPRINGS 10/28/2019 CCFH 34 1.59 0Michigan 5127 PARK RD ANN ARBOR 11/8/2019 CCFH 34 0.45 0Grand Rapids 514 W GRANT GREENVILLE 8/8/2019 CCFH 16 4.48 0Traverse City 5156 MACKENZIE DR MILTON 5/24/2019 CCFH 34 7.14 0Muskegon 5160 ORSHAL FRUITLAND TOWNSHIP 10/9/2019 CCFH 34 7.14 0

5185 N CLARE AVE 6/5/2019 CCFH 34 19.04 0Grand Rapids 52 COLFAX ST NE GRAND RAPIDS 7/29/2019 CCFH 4 1.87 0

5215 KALAMAZOO 8/27/2019 CCFH 16 215.04 0Grayling 522 GARFIELD BLVD ROSCOMMON 7/22/2019 CCFH 34 14.28 0Grand Rapids 5225 SE 33rd ST GRAND RAPIDS 10/5/2019 CCFH 34 12.69 0Grand Rapids 5237 MADISON AVE SE KENTWOOD 10/1/2019 CCFH 16 215.04 0Escanaba 524 S 12th ST ESCANABA 9/5/2019 MCF 34 0 5.6Traverse City 524 SIXTH ST TRAVERSE CITY 8/7/2019 CCFH 34 4.76 0Michigan 5240 JACKSON RD ANN ARBOR 8/2/2019 CCFH 34 14.28 0Allen 525 MOHAWK DEARBORN 9/10/2019 CCFH 16 4.48 0Tawas 5260 WASHINGTON RD OSCODA 9/21/2019 CCFH 34 0.16 0Grand Rapids 529 LIVINGSTON AVE NE GRAND RAPIDS 9/26/2019 CCFH 16 1.49 0Lynch 53 OXFORD RD GROSSE POINTE SHORES 2/13/2019 CCFH 4 1.16 0Lynch 5300 GRAYTON DETROIT 9/20/2019 CCFH 4 0.56 0Lynch 5309 BERKSHIRE ST DETROIT 5/30/2019 CCFH 4 2.32 0Grand Rapids 5355 PINE ISLAND DR NE PLAINFIELD 10/30/2019 CCFH 34 4.76 0Grand Rapids 536 CORDELIA ST SW GRAND RAPIDS 10/1/2019 CCFH 16 1.49 0Lynch 536 SHELBY DETROIT 9/9/2019 MCF 16 0 119.36Traverse City 5368 US HIGHWAY 31 N ACME 5/16/2019 CCFH 34 7.14 0Michigan 540 THOMPSON ST ANN ARBOR 11/25/2019 MCF 16 0 185.42Traverse City 5404 MOBILE TRL W BLAIR 6/14/2019 CCFH 34 4.76 0Allen 5413 MEAD DEARBORN 5/13/2019 CCFH 34 2.38 0Allen 5432 W VERNOR DETROIT 8/30/2019 CCFH 16 2.24 0



Michigan 5445 GREGORY RD WEBSTER 7/25/2019 CCFH 34 7.14 0546 E LARNED ST 5/13/2019 MCF 16 0 36.07

Lynch 546 LARNED ST DETROIT 9/27/2019 CCFH 16 0.15 0Allen 5476 ORCHARD DEARBORN 4/30/2019 CCFH 34 1.59 0Grand Rapids 5480 38A ALPINE AVE NW ALPINE TWP 9/23/2019 CCFH 34 4.76 0Lynch 5510 HAVERHILL ST DETROIT 10/19/2019 CCFH 4 2.8 0Grand Rapids 5537 BENTBROK SE KENTWOOD 4/23/2019 CCFH 34 4.76 0Grayling 5563 W HIGGINS ROSCOMMON 7/1/2019 CCFH 34 7.14 0Grayling 5563 W HIGGINS LAKE RD LYON 7/2/2019 CCFH 34 6.12 0Alpena 559 W WOODWARD AVE ROGERS CITY 8/6/2019 CCFH 34 9.52 0Grand Rapids 5603 STONEBRIDGE SW GRANDVILLE 9/6/2019 CCFH 34 4.76 0Lynch 5628 KOPERNICK ST DETROIT 7/3/2019 MCF 4 0 87.38Lynch 5632 PARKDALE ST DETROIT 7/26/2019 CCFH 16 0.15 0Grand Rapids 5665 28 TH SW GRAND RAPIDS 8/6/2019 CCFH 34 2.38 0Grand Rapids 5670 EAGLE SE KENT 2/5/2019 MCF 34 0 1.52Lynch 5689 FRENCH RD DETROIT 9/11/2019 CCFH 4 1.26 0Lynch 5794 FRENCH APT 2 DETROIT 7/12/2019 MCF 4 0 79.86

5800 SAGE 12/20/2019 CCFH 34 6.76 0Allen 5811 GRANBY UNIT A CANTON 8/1/2019 MCF 34 0 15.42Grand Rapids 5811 LARKSPUR LN ALLENDALE 10/31/2019 CCFH 16 0.75 0Allen 5811 W VERNOR HWY DETROIT 2/28/2019 MCF 4 0 5.05Grand Rapids 5830 CLYDE PARK AVE SW WYOMING 5/13/2019 CCFH 34 9.52 0Michigan 5835 GRANBY CANTON 8/1/2019 MCF 34 0 28.9Tawas 5862 M 55 GRANT 10/16/2019 CCFH 34 0.16 0Allen 5892 HAZEL ST TAYLOR 5/10/2019 CCFH 16 2.24 0Allen 5893 GRANBY CANTON 4/23/2019 CCFH 34 9.52 0

590 TAWAS BEACH RD 3/31/2019 CCFH 4 53.76 0Michigan 5900 S WATER RD NEW ERA 6/11/2019 CCFH 34 9.52 0Lynch 5918 BRUSH ST DETROIT 9/26/2019 MCF 16 0 30.74Allen 5919 HIGHVIEW ST DEARBORN HEIGHTS 6/12/2019 CCFH 16 4.48 0Allen 5919 SIGLER RD BERLIN 8/11/2019 CCFH 34 4.76 0

5920 2ND AVE APT2 5/13/2019 CCFH 16 8.96 0Allen 5920 HIGHVIEW ST DEARBORN HEIGHTS 5/4/2019 CCFH 16 4.48 0Grand Rapids 5964 PARVIEW DR SE CASCADE 4/11/2019 CCFH 34 9.52 0Allen 5969 ROBINDALE AVE DEARBORN HEIGHTS 9/27/2019 MCF 16 0 0.48Grand Rapids 5970 METRO WAYSW WYOMING 6/18/2019 CCFH 34 9.52 0Allen 5990 HAMPDEN ST TAYLOR 9/25/2019 CCFH 16 4.48 0Allen 60 HALTINER RIVER ROUGE 4/30/2019 CCFH 4 0.65 0Petoskey 600 HIGHLAND DR PETOSKEY 4/26/2019 CCFH 34 4.76 0Allen 6007 HAROLD ST TAYLOR 8/9/2019 CCFH 16 3.76 0

6008 KIRKHOF 7/17/2019 CCFH 34 38.08 06008 KIRKHOF 7/17/2019 CCFH 34 38.08 0

Lynch 6026 MAXWELL DETROIT 12/9/2019 MCF 4 0 2.82605 HONEYCREEK NE 5/18/2019 CCFH 34 4.76 0

Big Rapids 610 E CHURCH ST REED CITY 8/2/2019 CCFH 34 4.76 0Michigan 6135 BECK D BELLEVILLE 9/7/2019 CCFH 34 0.32 0Allen 614 CHIPPEWA ST ELK RAPIDS 4/17/2019 CCFH 34 7.14 0Muskegon 6140 MACARTHUR RD EGELSTON 8/22/2019 CCFH 16 2.24 0

615 N CIRCLE DR 8/12/2019 CCFH 34 9.52 0Lynch 6155 GRAND RIVER DETROIT 9/30/2019 MCF 4 24.62 0Allen 616 LIGHT TOWER DR BELLEVILLE 9/3/2019 MCF 34 0 44.04Lynch 6162 MICHIGAN AVE DETROIT 6/14/2019 CCFH 4 1.68 0Lynch 6191 MARSEILLES DETROIT 11/12/2019 CCFH 4 0.27 0Grand Rapids 621 FREMONT NW GRAND RAPIDS 9/17/2019 CCFH 4 1.12 0Allen 621 N JOHN DALY RD DEARBORN HEIGHTS 6/8/2019 CCFH 16 4.48 0

623 WORDEN SE 7/16/2019 CCFH 4 0.28 0Big Rapids 6287 TAMARACK RD CATO 6/18/2019 CCFH 34 1.59 0Escanaba 630 S 16TH ST ESCANABA` 6/20/2019 CCFH 34 2.38 0

6300 BRIARWOOD 7/20/2019 CCFH 34 9.52 06317 HEREFORD 2/28/2019 CCFH 4 0.56 0

Michigan 6332 MIDDLEBELT RD GARDEN CITY 11/7/2019 CCFH 16 10.6 0Allen 6333 MEAD ST DEARBORN 8/30/2019 CCFH 4 0.56 0Allen 6347 HAMPDEN ST TAYLOR 9/16/2019 MCF 16 0 38.43Allen 6356 GREENFIELD RD DEARBORN 10/1/2019 CCFH 4 1.24 0Traverse City 640 BIRCHWOOD AVE TRAVERSE CITY 8/30/2019 CCFH 34 4.76 0Allen 6402 STEADMAN DEARBORN 10/18/2019 MCF 4 0 0.72Muskegon 654 WESLEY AVE MUSKEON 9/11/2019 CCFH 4 0.75 0Michigan 6555 SHARON ST GARDEN CITY 7/4/2019 CCFH 16 8.96 0Allen 6565 GREENFIELD6565 GREENFIELD RD DETOIT 8/30/2019 CCFH 4 2.24 0Allen 6648 PAYNE DEARBORN 6/27/2019 MCF 4 0 25.21Michigan 6655 JACKSON RD SCIO 10/9/2019 CCFH 34 14.28 0Michigan 666 CAMPBELL AVE YPSILANTI 4/9/2019 CCFH 4 0.56 0

666 SELDON ST 6/11/2019 CCFH 16 8.96 0Allen 6719 ASBURY PARK DETROIT 9/24/2019 CCFH 4 0.04 0Muskegon 6755 OLD CHANNEL TRL WHITEHALL TOWNSHIP 10/16/2019 CCFH 34 4.76 0Grand Rapids 6766 VINTAGE DR HUDSONVILLE 10/3/2019 CCFH 34 4.76 0Allen 6795 BRACE ST DETROIT 7/9/2019 CCFH 4 1.12 0Lynch 6860 BRIMSON DETROIT 10/17/2019 CCFH 4 10.45 0Traverse City 6880 E HARBOR DR ELK RAPIDS 1/11/2019 CCFH 34 4.96 0Allen 6910 THEISEN DEARBORN 5/15/2019 CCFH 34 2.86 0Grayling 6939 NOTTINGHAM DR GRAYLING 7/28/2019 CCFH 34 4.76 0

6939 NOTTINGHAM DR 7/28/2019 CCFH 34 4.76 0Allen 7005 FREDA ST DEARBORN 7/12/2019 CCFH 34 19.04 0Traverse City 701 US HIGHWAY 31 S BLAIR 8/29/2019 CCFH 34 4.76 0



Allen 7017 FREDA DEARBORN 7/9/2019 MCF 34 0 148.07Allen 7032 THEISEN DEARBORN 3/6/2019 CCFH 34 9.86 0Petoskey 704 PROSPECT EAST JORDAN 8/14/2019 CCFH 34 1.59 0

7049 ENTERPRISE 11/11/2019 CCFH 34 18.02 0Traverse City 705 N CEDAR KALKASKA 5/22/2019 MCF 34 0 1610Escanaba 711 STEPHENSON AVE ESCANABA 10/7/2019 CCFH 34 0.32 0Ludington 714 N LAKESHORE DR LUDINGTON 8/12/2019 CCFH 34 3.97 0

7144 BRADFIELD SE 7/24/2019 CCFH 34 7.14 0Grand Rapids 7175 WILDERMERE NE ROCKFORD 7/29/2019 MCF 34 0 445.2Grand Rapids 719 KNAPP ST NE GRAND RAPIDS 1/24/2019 CCFH 4 0.29 0Petoskey 7203 LIGHTFOOT RD HARBOR SPRINGS 7/2/2019 CCFH 34 47.6 0Michigan 7217 W LIBERTY ANN ARBOR 7/2/2019 MCF 34 0 12.5Grand Rapids 725 SE ABBEY MILL CT ADA 3/6/2019 MCF 34 0 1457.74Allen 7301 ORCHARD AVE DEARBORN 6/19/2019 CCFH 4 1.14 0Allen 7301 ORCHARD AVE DEARBORN 7/26/2019 CCFH 4 1.12 0Traverse City 7303 COUNRY ROAD 612 NE COLD SPRINGS 9/9/2019 MCF 4 0 32.28Grand Rapids 7303 S DIVISION BYRON TWP 8/5/2019 MCF 16 0 1934.1Allen 7394 PATTON DETROIT 11/21/2019 CCFH 4 0.35 0Grand Rapids 749 PRESIVE CIRCLE SE KENTWOOD 6/26/2019 CCFH 16 2.24 0Allen 7535 LITTLEFIELD BLVD DEARBORN 9/3/2019 MCF 34 0 1586.51Allen 7600 CRANE YPSILANTI 6/18/2019 CCFH 34 4.76 0Mount Pleasant 7625 W DREW RD SHERMAN 6/3/2019 CCFH 34 9.52 0Lynch 7630 KIPLING ST DETROIT 5/17/2019 CCFH 4 0.34 0Michigan 7675 SCULLY RD WEBSTER 5/31/2019 CCFH 34 28.56 0Grand Rapids 76th & CLYDE PARK SW BYRON CNTER 8/21/2019 MCF 34 0 2593.5Grand Rapids 77 MONROE CTR NW GRAND RAPIDS 12/4/2019 CCFH 16 2.12 0Grand Rapids 7714 NIGHTINGALE DR SE GAINES 12/3/2019 CCFH 34 9.01 0

7755 ORCHARD 6/19/2019 CCFH 4 0.5 0Allen 7755 ORCHARD AVE DEARBORN 8/10/2019 CCFH 4 0.56 0Michigan 7765 BIRCKLAN DR CANTON 4/25/2019 CCFH 34 19.04 0Allen 785 ALLEN MUSKEGON 4/22/2019 CCFH 34 3.17 0Michigan 7968 THORNWOOD ST CANTON 10/9/2019 CCFH 34 7.14 0

7969 WHISTLE CREEK SW 5/23/2019 CCFH 34 7.14 0Michigan 7980 5TH ST DEXTER 7/23/2019 CCFH 16 4.48 0Michigan 7980 5th ST DEXTER 8/28/2019 CCFH 16 4.48 0Allen 8001 YINGER DEARBORN 5/8/2019 MCF 4 0 28.42Big Rapids 8023 21 MILE RD EVART 7/17/2019 CCFH 34 3.17 0Michigan 803 MANDERLY DR MILFORD 9/18/2019 CCFH 4 3.92 0Allen 8030 ODENNELL DR GROSSE ILE 5/15/2019 CCFH 34 14.28 0

808 MCCLELLAND 8/16/2019 CCFH 16 0.75 0Michigan 81 W WABASH AVE BELLEVILLE 7/20/2019 CCFH 16 4.48 0Traverse City 8140 BEL CHRRIE DR PENINSULA 5/28/2019 CCFH 34 4.76 0Sault Sainte Marie 817 RYAN AVE SAULT STE MARIE 5/20/2019 CCFH 34 1.59 0Lynch 818 CADIEUX DETROIT 4/11/2019 MCF 16 0 28.34Michigan 819 ANN ST YPSILANTI 1/21/2019 CCFH 34 2.32 0Allen 8209 PARK AVE ALLEN PARK 8/13/2019 CCFH 16 1.49 0Allen 8209 PARK AVE ALLEN PARK 9/10/2019 CCFH 16 1.49 0Grand Rapids 821 COLLEGE AVE SE GRAND RAPIDS 9/5/2019 CCFH 4 0.28 0Michigan 8217 HONEY LANE CANTON 7/22/2019 MCF 34 0 149.28Michigan 8262 AUSTIN RD SALINE 10/25/2019 CCFH 34 9.52 0Allen 828 MOHAWK ST DEARBORN 9/6/2019 CCFH 16 2.24 0Allen 8341 PARK AVE ALLEN PARK 9/9/2019 CCFH 16 4.48 0Grand Rapids 835 SE EASTERN AVE GRAND RAPIDS 5/10/2019 MCF 4 0 11.32Lynch 8359 LINWOOD ST DETROIT 9/23/2019 CCFH 4 0.56 0Michigan 836 RAIL ROAD YPSILANTI 6/18/2019 CCFH 34 14.28 0Allen 8360 HURON ST DEXTER 5/31/2019 CCFH 16 6.96 0Allen 8409 W JEFFERSON AVE DETROIT 2/18/2019 MCF 16 0 13.25Michigan 841 GREEN YPSILANTI 9/25/2019 MCF 34 0 103.47Grand Rapids 8484 WOODHAVEN DR SW BYRON CENTER 1/14/2019 CCFH 34 9.52 0Grand Rapids 850 FREEMAN SW GRAND RAPIDS 10/9/2019 CCFH 16 3.36 0Grand Rapids 8500 SKYLINE ST SW BYRON 5/22/2019 CCFH 34 4.76 0Lynch 8531 COLFAX ST DETROIT 3/25/2019 CCFH 4 2.29 0Allen 8559 STAWELL ST DETROIT 5/6/2019 CCFH 4 1.12 0Grand Rapids 8569 BROWER LAKE RD NE COURTLAND 5/10/2019 CCFH 34 0.79 0Grand Rapids 864 PATTERSON SE ADA 9/11/2019 CCFH 34 7.14 0Lynch 8699 ARNOLD DETROIT 3/25/2019 MCF 16 0 116.21Ludington 87 E HANOVER PENTWATER 4/24/2019 CCFH 34 1.59 0Michigan 8700 ROE RD CHELSEA 8/7/2019 MCF 34 0 199.27Grand Rapids 872 INDIAN LAKES NW SPARTA 8/27/2019 MCF 34 0 9.52Grand Rapids 8830 BELDING RD NE CANNON 12/4/2019 CCFH 34 9.01 0Allen 8850 PARDEE TAYLOR 9/2/2019 MCF 16 0 42.05Grand Rapids 888 COACH LIGHT DR BYRON CENTER 1/14/2019 MCF 34 0 177.24Grand Rapids 8884 STERLING HILLS NE ROCKFORD 7/15/2019 CCFH 34 19.04 0Traverse City 890 E HARBOR HWY CLEVELAND 5/7/2019 CCFH 34 4.76 0Michigan 8912 MERITT YPSILANTI 5/25/2019 CCFH 34 9.52 0Lynch 90 HILL ST HIGHLAND PARK 4/8/2019 MCF 4 0 13.3

907 BATES SE 12/16/2019 CCFH 4 0.18 0Muskegon 915 LINTNER RD EGELSTON TOWNSHIP 9/19/2019 CCFH 16 1.49 0

91511 CLEVELAND 6/21/2019 CCFH 16 2.24 0916 MERIDAN 7/16/2019 CCFH 16 4.48 0

Michigan 916 RIDGE RD SYLVAN 9/13/2019 CCFH 34 28.56 0Michigan 916 RIDGE RD SYLVAN 11/5/2019 CCFH 34 27.03 0Allen 9166 MERCEDES ST REDFORD 2/22/2019 CCFH 16 2.32 0Allen 9197 FALCON ST DETROIT 6/23/2019 CCFH 4 0.28 0



Lynch 92 HILL ST HIGHLAND PARK 1/2/2019 CCFH 4 2.49 0Grand Rapids 922 COTTAGE GROVE ST GRAND RAPIDS 1/16/2019 CCFH 4 0.12 0Michigan 922 DEWEY AVE ANN ARBOR 5/15/2019 MCF 4 0 7.07

9236 MACKINAW TRL 11/7/2019 CCFH 34 4.51 0Grand Rapids 927 KENNETH SW WYOMING 3/28/2019 MCF 4 0 57.76Grand Rapids 9327 PINE ISLAND DR SPARTA 6/3/2019 CCFH 34 3.29 0Michigan 934 MARYS ANN ARBOR 5/21/2019 MCF 4 0 28.82

9363 PAULINE ST 9/5/2019 MCF 16 0 103.88Grand Rapids 95 LAMOREAUX NW COMSTOCK PARK 6/5/2019 CCFH 16 2.24 0Grayling 953 S AUSABLE TRL GRAYLING 10/28/2019 CCFH 34 7.14 0Grand Rapids 954 SYDNEY DR WALKER 6/18/2019 CCFH 16 2.24 0Allen 9545 TELEGRAPH RD TAYLOR 10/9/2019 CCFH 16 4.98 0Lynch 96 E GRAND HIGHLAND PARK 3/24/2019 CCFH 4 1.72 0Tawas 960 S M 33 WEST BRANCH 10/24/2019 CCFH 34 0.79 0Lynch 983 LINCOLN RD GROSSE POINTE 8/6/2019 CCFH 4 0.02 0Allen 9858 SIL ST TAYLOR 11/12/2019 CCFH 16 4.24 0Grand Rapids 989 84th ST SE GAINES 9/16/2019 CCFH 34 9.52 0Allen 9895 ROOSEVELT ST TAYLOR 6/7/2019 CCFH 16 2.24 0Traverse City 9929 WESTWOOD DR LONG LAKE 11/6/2019 CCFH 34 9.01 0Grand Rapids BIG SKY TRL SE 10/1/2019 MCF 34 90.4 0Cadillac BOON RD CADILLAC 11/15/2019 MCF 34 0 420Grand Rapids CENTER DR NW GRAND RAPIDS 5/22/2019 MCF 34 0 117.18Lynch CENTRAL & INSELRUHE AVE DETROIT 10/8/2019 CCFH 34 3.97 0Petoskey E THIRD IFO ADDRESS 229 HARBOR SPRINGS 4/24/2019 MCF 34 0 4.31Grand Rapids EAGLE DR SE GRAND RAPIDS 2/11/2019 MCF 34 0 1.52Lynch ELM AND BROOKLYN DETROIT 6/11/2019 CCFH 16 13.44 0Allen GERMAN ROCKWOOD 6/6/2019 CCFH 16 4.48 0

GRANDVIEW AVE 1/16/2019 MCF 18 0 52.56Muskegon HARRISON AND LINCOLN MUSKEGON HEIGHTS 9/30/2019 MCF 16 0 31.08Grand Rapids HIGHLANDER NE ROCKFORD 4/19/2019 CCFH 34 19.04 0Mount Pleasant INDUSTRIAL DR CLARE 8/12/2019 MCF 34 0 342.51Muskegon LAKESHORE DR/FRISBIE MUSKEGON 8/28/2019 MCF 16 0 53.2Allen MOHAWK & DENWOOD DEARBORN 9/9/2019 CCFH 16 4.48 0Petoskey NIPICON CHEBOYGAN 9/19/2019 CCFH 34 9.52 0Traverse City RENNIE SCHOOL RD TRAVERSE CITY 4/8/2019 MCF 34 0 12.44

S 26TH ST 6/11/2019 CCFH 34 14.28 0Grand Rapids TENNYSON DR SW WYOMING 10/10/2019 MCF 16 0 425.5Muskegon TURTLE RIDGE FRUITPORT TOWNSHIP 9/13/2019 MCF 34 0 94.5

US23 MACKINAW 5/21/2019 CCFH 34 9.52 0Sault Sainte Marie W WATER TOWER DR KINROSS/KINCHELOE 7/8/2019 MCF 34 0 340.62Sault Sainte Marie WEST AVE SAULT STE MARIE 6/28/2019 MCF 34 0 228.48



Station Address Damage OccurredCity Damage Occurred

Damage Date CCFH/MCFVolume of Lost Gas cfh=100 cubic feet

mcf=1,000 cubic feetAmt of Lost Gas for Services Amt of Lost Gas for Mains

ALLEN RD 14564 SOUTHFIELD RD ALLEN PARK 1/8/2018 CCFH 8 2.49 0ALLEN RD 6166 W OUTER DR DETROIT 1/10/2018 CCFH 4 1.24 0ALLEN RD 6056 N BEECH DALY RD

DEARBORN HEIGHTS

1/11/2018 CCFH 16 4.98 0ALLEN RD 25812 WARRINGTON

DEARBORN HEIGHTS

1/18/2018 MCF 1 0 3LYNCH RD 18967 SAN JUAN DETROIT 1/11/2018 CCFH 14 4.35 0LYNCH RD 275 E HANCOCK DETROIT 1/16/2018 CCFH 68 21.15 0LYNCH RD 12040 BROADSTREET AVE DETROIT 1/19/2018 MCF 1 0 2.92MICHIGAN AVE 6369 MUNGER RD YPSILANTI 1/11/2018 CCFH 34 10.57 0GRAND RAPIDS 10046 CAMPUS VIEW DR ALLENDALE 1/8/2018 CCFH 9 2.64 0GRAND RAPIDS 249 LANE AVE SW GRAND RAPIDS 1/8/2018 CCFH 4 1.24 0GRAND RAPIDS 167 ROSEMARY ST SE GRAND RAPIDS 1/15/2018 CCFH 3 0.93 0ALLEN RD 2655 22ND ST WYANDOTTE 1/7/2018 CCFH 16 4.98 0ALLEN RD 8600 ROSEMONT DETROIT 1/24/2018 CCFH 4 1.24 0LYNCH RD 5760 WILLIAMS DETROIT 1/24/2018 MCF 115 0 361.88GRAND RAPIDS 11155 56TH AVE ALLENDALE 1/23/2018 CCFH 34 10.54 0GRAND RAPIDS 2725 BIRCHCREST DE SE GRAND RAPIDS 1/24/2018 CCFH 5 17.00 0GRAND RAPIDS 4314 STRATTON BLVD SE KENTWOOD 1/24/2018 CCFH 136 42.16 0GRAND RAPIDS 1631 64TH ST SE BYRON CENTER 1/25/2018 CCFH 102 31.72 0MUSKEGON 9152 QUINN ST 1/26/2018 CCFH 34 10.57 0LYNCH RD 18801 CHAREST DETROIT 1/5/2018 CCFH 8 2.49 0ALLEN RD 4304 7TH ECORSE 1/11/2018 CCFH 7 2.18 0ALLEN RD 17771 RENO RIVERVIEW 1/25/2018 CCFH 16 4.98 0TRAVERSE CITY 1041 E FRONT ST TRAVERSE CITY 1/16/2018 CCFH 40 12.44 0MICHIGAN AVE BLACKWOOD & STEEPLECHASE CANTON 1/29/2018 MCF 309 0 977.71ALLEN RD 24105 SIBLEY RD BROWNSTOWN 1/29/2018 CCFH 29 9.02 0LYNCH RD 6470 E JEFFERSON AVE DETROIT 1/30/2018 MCF 154 0 485.67LYNCH RD 7771 RADCLIFFE DETROIT 2/1/2018 CCFH 8 2.49 0MICHIGAN AVE 31939 ALVIN ST GARDEN CITY 2/1/2018 CCFH 13 4.21 0GRAND RAPIDS 150 WALLINWOOD AVE NE GRAND RAPIDS 1/29/2018 CCFH 1 0.31 0GRAND RAPIDS

3685 ROGER B CHAFFEE MEMORIAL DR

KENTWOOD 2/1/2018 CCFH 16 4.96 0LYNCH RD 2505 W MCNICHOLS RD DETROIT 2/6/2018 CCFH 4 1.24 0LYNCH RD 18540 MACK AVE

GROSSE POINTE FARMS

2/8/2018 CCFH 17 5.29 0LYNCH RD 5845 RENVILLE DETROIT 2/8/2018 CCFH 12 3.73 0GRAND RAPIDS 11757 BRISBEN LN GRAND RAPIDS 2/7/2018 CCFH 51 15.81 0GRAND RAPIDS 2799 10 MILE RD ROCKFORD 2/7/2018 MCF 60 0 722.76GRAND RAPIDS 14556 16TH ST MARNE 2/8/2018 CCFH 34 10.54 0MUSKEGON 1080 W BROADWAY MUSKEGON 2/8/2018 CCFH 16 4.98 0ALLEN RD 9450 PELHAM RD TAYLOR 2/12/2018 CCFH 58 18.04 0ALLEN RD 8384 W OUTER DR DETROIT 2/14/2018 CCFH 6 1.87 0LYNCH RD 616 W HANCOCK ST DETROIT 2/12/2018 CCFH 48 14.93 0MICHIGAN AVE 2597 OXFORD CIRCLE SCIO TWP 2/15/2018 MCF 113 0 357.08GRAND RAPIDS 2983 SIR CHARLES DR NE ROCKFORD 2/12/2018 CCFH 68 21.08 0GRAND RAPIDS 1513 ELLIOTT ST SE GRAND RAPIDS 2/15/2018 CCFH 4 2.49 0LYNCH RD 4596 FRENCH RD DETROIT 2/23/2018 CCFH 4 1.24 0GRAND RAPIDS 126 GOLD AVE GRAND RAPIDS 2/21/2018 MCF 2 0 318.78GRAND RAPIDS 8305 COTTONWOOD DR JENISON 2/22/2018 CCFH 16 2.48 0GRAND RAPIDS 1397 TURNING CREEK DR GAINES 2/23/2018 CCFH 34 5.27 0GRAYLING 2570 LAKEVIEW AVE LEWISTON 2/15/2018 CCFH 102 31.72 0ALLEN RD 8440 W OUTER DR DETROIT 2/26/2018 CCFH 4 1.24 0ALLEN RD 8500 W OUTER DR DETROIT 2/28/2018 CCFH 4 1.24 0ALLEN RD 22131 DAVID TAYLOR 3/2/2018 CCFH 16 13.92 0LYNCH RD 16266 LEBERAL ST DETROIT 2/26/2018 CCFH 4 1.74 0MICHIGAN AVE 3122 MONTROSE AVE YPSILANTI 3/2/2018 CCFH 34 19.72 0GRAND RAPIDS 3540 ROBIN AVE SW WYOMING 2/26/2018 CCFH 16 2.48 0GRAND RAPIDS 1240 LAFAYETTE SE GRAND RAPIDS 2/28/2018 CCFH 4 0.62 0ALLEN RD 8528 W OUTER DR DETROIT 3/5/2018 CCFH 4 1.16 0ALLEN RD 22822 BUCKINGHAM DETROIT 3/8/2018 CCFH 16 4.64 0ALLEN RD 8728 W OUTER DR DETROIT 3/9/2018 MCF 2 0 295.5ALLEN RD 18361 GREYDALE AVE DETROIT 3/10/2018 CCFH 4 1.16 0GRAND RAPIDS 824 BRIDGE ST NW GRAND RAPIDS 3/7/2018 CCFH 4 0.29 0GRAND RAPIDS 300 E WASHINGTON ST GREENVILLE 3/7/2018 CCFH 16 16.24 0GRAND RAPIDS 3540 ROBIN AVE WYOMING 3/8/2018 CCFH 16 2.32 0GRAND RAPIDS 3541 ROBIN AVE SW WYOMING 3/9/2018 CCFH 4 1.16 0LYNCH RD 5615 HOMEDALE DETROIT 2/15/2018 CCFH 2 1.24 0ALLEN RD 13949 BEECH DALY REDFORD 2/26/2018 CCFH 10 4.96 0ALLEN RD 8472 OUTER DR DETROIT 2/27/2018 CCFH 4 1.24 0MICHIGAN AVE 1003 S 7TH ST. ANN ARBOR 2/27/2018 CCFH 4 1.24 0ALLEN RD 6314 BRACE ST DETROIT 3/15/2018 CCFH 4 1.16 0ALLEN RD 111 S MILITARY ST DETROIT 3/15/2018 CCFH 16 6.96 0LYNCH RD 13724 WOODWARD HIGHLAND

PARK3/13/2018 CCFH 4 1.16 0

LYNCH RD 5299 PROCTOR DETROIT 3/14/2018 CCFH 4 4.64 0MUSKEGON 739 ACCESS HWY MUSKEGON 3/17/2018 CCFH 50 4.44 0ALLEN RD 29958 BAYVIEW DR GIBRALTAR 3/19/2018 MCF 10 0 142.33ALLEN RD 16197 BILTMORE ST DETROIT 3/20/2018 CCFH 4 1.16 0ALLEN RD 15942 W 7 MILE RD DETROIT 3/21/2018 CCFH 4 2.32 0ALLEN RD 1424 MASON ST DEARBORN 3/21/2018 CCFH 4 1.16 0ALLEN RD 1642 22ND ST WYANDOTTE 3/22/2018 CCFH 16 4.64 0



ALLEN RD 16583 BILTMORE ST DETROIT 3/22/2018 CCFH 4 1.16 0LYNCH RD 7133 HOLMES DETROIT 3/22/2018 CCFH 4 1.16 0MUSKEGON 329 IONIA AVE MUSKEGON 3/19/2018 CCFH 4 522.48 0LYNCH RD 18010 JOSEPH CAMPAU DETROIT 3/28/2018 CCFH 4 1.16 0LYNCH RD 867 NAVAHOE ST DETROIT 3/29/2018 CCFH 4 2.90 0MICHIGAN AVE 10685 WARREN RD PLYMOUTH 3/27/2018 CCFH 34 15.86 0GRAND RAPIDS 15274 16TH AVE MARNE 3/26/2018 CCFH 60 4.93 0GRAND RAPIDS CEDAR RUN CT WALKER 3/27/2018 MCF 60 36.25 0GRAND RAPIDS 1475 BECKWITH VIEW NE GRAND RAPIDS 3/30/2018 CCFH 16 2.32 0MUSKEGON 3328 HOYT ST

MUSKEGON HEIGHTS

3/26/2018 CCFH 16 2.32 0ALLEN RD 7601 ASHTON ST DETROIT 4/3/2018 CCFH 4 1.16 0ALLEN RD 15526 MCLAIN AVE ALLEN PARK 4/4/2018 CCFH 16 4.64 0MICHIGAN AVE 28515 GREENVIEW ROMULUS 4/8/2018 CCFH 28 8.12 0MUSKEGON 21 W MAIN ST HART 4/2/2018 CCFH 16 5.80 0ALLEN RD 15731 ASHTON RD DETROIT 4/13/2018 CCFH 4 1.16 0LYNCH RD 4841 2ND AVE DETROIT 4/12/2018 CCFH 34 24.65 0MICHIGAN AVE 13501 S HURON RIVER DR ROMULUS 4/12/2018 CCFH 28 8.12 0ALLEN RD 1172 WHITE AVE LINCOLN PARK 4/17/2018 CCFH 16 4.64 0ALLEN RD 26228 GIBRALTAR RD FLAT ROCK 4/18/2018 CCFH 16 4.64 0ALLEN RD 23410 FENKELL DETROIT 4/19/2018 CCFH 4 0.58 0ALLEN RD 8985 PARK AVE ALLEN PARK 4/20/2018 CCFH 16 4.64 0ALLEN RD 22810 ARLINGTON ST DEARBORN 4/20/2018 CCFH 16 0.29 0ALLEN RD 24719 LANGDON FLAT ROCK 4/21/2018 CCFH 29 8.41 0ALLEN RD 9000 W VERNOR HWY DETROIT 4/21/2018 CCFH 4 2.90 0GRAND RAPIDS 4565 KENOWA AVE SW GRANDVILLE 4/20/2018 CCFH 34 2.47 0GRAND RAPIDS 9630 SUMMIT AVE ROCKFORD 4/21/2018 CCFH 34 9.86 0GRAND RAPIDS 3220 MCKEE AVE SW WYOMING 4/22/2018 CCFH 16 3.48 0ALLEN RD 23020 ARLINGTON ST DEARBORN 4/23/2018 CCFH 16 4.64 0ALLEN RD 6170 N SILVERY LANE

DEARBORN HEIGHTS

4/24/2018 CCFH 16 9.28 0ALLEN RD 7101 PINEHURST DEARBORN 4/26/2018 CCFH 34 4.93 0ALLEN RD 26408 CECILE ST

DEARBORN HEIGHTS

4/27/2018 CCFH 16 4.64 0ALLEN RD 4963 ORCHARD AVE DEARBORN 4/28/2018 CCFH 34 9.86 0ALLEN RD 24475 VIRGINIA ST TAYLOR 4/28/2018 MCF 0 0 45LYNCH RD 7191 EDWARD DETROIT 4/23/2018 CCFH 16 4.64 0ALLEN RD 19025 WILDEMERE DETROIT 4/26/2018 CCFH 4 1.16 0MICHIGAN AVE 48401 FORD RD CANTON 4/28/2018 CCFH 34 14.79 0GRAND RAPIDS 2214 ARGENTINA DR SE

EAST GRAND RAPIDS

4/23/2018 CCFH 4 0.29 0GRAND RAPIDS 2117 HALL ST SE GRAND RAPIDS 4/26/2018 CCFH 4 1.16 0GRAND RAPIDS 5823 WING AVE SE KENTWOOD 4/26/2018 CCFH 34 4.93 0GRAND RAPIDS 1520 COLLEGE AVE NE GRAND RAPIDS 4/29/2018 CCFH 4 0.87 0MUSKEGON 6195 MURRAY RD WHITEHALL 4/27/2018 CCFH 34 12.16 0MUSKEGON 1260 GRAF ST MUSKEGON 4/30/2018 CCFH 16 0.31 0MUSKEGON 1474 ALBERT AVE MUSKEGON 4/29/2018 CCFH 16 1.14 0ALLEN RD 24279 WALLOON WAY BROWNSTOWN 4/30/2018 CCFH 29 8.41 0ALLEN RD 9025 PARK AVE ALLEN PARK 5/1/2018 CCFH 16 4.64 0ALLEN RD 7025 PLAINFIELD ST

DEARBORN HEIGHTS

5/1/2018 CCFH 16 4.64 0ALLEN RD 1144 MAPLE ST WYANDOTTE 5/2/2018 CCFH 4 1.16 0ALLEN RD 6623 N SILVERY LN

DEARBORN HEIGHTS

5/2/2018 CCFH 16 4.64 0ALLEN RD 6583 N SILVERY LN

DEARBORN HEIGHTS

5/2/2018 CCFH 16 4.64 0ALLEN RD 1034 LINCOLN LINCOLN PARK 5/4/2018 CCFH 16 4.64 0ALLEN RD 15726 MCLAIN AVE ALLEN PARK 5/4/2018 CCFH 16 4.64 0ALLEN RD 22797 MERIDIAN RD GROSSE ILE 5/5/2018 CCFH 34 9.86 0LYNCH RD 20414 SHEFFIELD DETROIT 4/30/2018 CCFH 4 2.90 0GRAND RAPIDS 269 STRAIGHT AVE SW GRAND RAPIDS 5/2/2018 CCFH 4 0.58 0GRAND RAPIDS 781 KENMOOR AVE GRAND RAPIDS 5/2/2018 CCFH 34 14.79 0GRAND RAPIDS 1033 PINE AVE NW GRAND RAPIDS 5/6/2018 CCFH 16 2.32 0MUSKEGON 1643 WOOD ST MUSKEGON 5/1/2018 CCFH 4 0.86 0MUSKEGON 1002 S COVE WHITEHALL 5/2/2018 CCFH 16 3.48 0LYNCH RD 262 MACK DETROIT 5/4/2018 CCFH 16 4.64 0ALLEN RD 13603 W CHICAGO ST DETROIT 5/7/2018 CCFH 4 1.16 0ALLEN RD 22720 SHERIDAN ST DEARBORN 5/7/2018 CCFH 16 6.96 0ALLEN RD 14028 PIERCE DR REDFORD 5/7/2018 MCF 3 0 177.32ALLEN RD 7739 MAYFAIR ST TAYLOR 5/10/2018 CCFH 16 2.32 0ALLEN RD 2556 DIX HWY LINCOLN PARK 5/10/2018 CCFH 16 4.64 0ALLEN RD 5988 N SILVERY LN

DEARBORN HEIGHTS

5/11/2018 CCFH 16 4.64 0ALLEN RD 15800 MCLAIN AVE ALLEN PARK 5/11/2018 CCFH 16 4.64 0ALLEN RD 15300 TRENTON RD SOUTHGATE 5/12/2018 CCFH 16 4.64 0ALLEN RD 22091 MICHIGAN AVE DEARBORN 5/12/2018 MCF 10 0 94.38GRAND RAPIDS 10324 42ND AVE ALLENDALE 5/9/2018 CCFH 34 17.26 0GRAND RAPIDS 7285 WILLOW WOOD DR N BELMONT 5/13/2018 CCFH 34 9.86 0MUSKEGON 512 S COURTLAND HART 5/7/2018 CCFH 16 4.64 0GRAYLING 2045 S I75 GRAYLING 2/28/2018 CCFH 34 42.26 0GRAND RAPIDS 45 BELLEVUE WYOMING 3/28/2018 CCFH 16 4.64 0ALLEN RD 22610 FENKELL DETROIT 4/12/2018 CCFH 4 1.16 0GRAYLING 41 N MOUNT TOM OSCODA 4/26/2018 CCFH 34 7.93 0GRAYLING 2989 PORTAGE GRAYLING 4/26/2018 CCFH 34 2.11 0CADILLAC 10302 M 186 FIFE LAKE 4/26/2018 MCF 60 0 503LYNCH RD 8801 OAKMAN BLVD DETROIT 4/30/2018 CCFH 4 1.16 0LUDINGTON 4442 FOX FARM RD MANISTEE 5/2/2018 CCFH 34 5.61 0ALLEN RD 13725 PENNSYLVANIA RIVERVIEW 4/10/2018 CCFH 16 4.64 0



ALLEN RD 5970 N SILVERY LNDEARBORN HEIGHTS

5/15/2018 CCFH 16 4.64 0ALLEN RD 4834 CLARK ST TRENTON 5/15/2018 CCFH 16 4.64 0ALLEN RD 6535 PINEHURST DEARBORN 5/17/2018 CCFH 34 4.93 0ALLEN RD 5648 N SILVERY LN

DEARBORN HEIGHTS

5/17/2018 CCFH 16 4.64 0ALLEN RD 23050 SHERIDAN ST DEARBORN 5/17/2018 CCFH 16 9.28 0ALLEN RD 1810 SUPERIOR BLVD WYANDOTTE 5/18/2018 CCFH 16 4.64 0LYNCH RD 334 MCMILLAN

GROSSE POINTE FARMS

5/18/2018 CCFH 5 2.61 0MICHIGAN AVE 32239 BRUCE ST ROMULUS 5/17/2018 CCFH 16 9.28 0GRAND RAPIDS 6415 DONNEGAL LN CASCADE 5/17/2018 CCFH 34 4.93 0GRAND RAPIDS 212 N CLAY ST GREENVILLE 5/17/2018 CCFH 16 4.64 0GRAND RAPIDS 3825 LAKE DR SE KENTWOOD 5/18/2018 CCFH 34 9.86 0GRAND RAPIDS 173 10 MILE RD NW SPARTA 5/18/2018 CCFH 34 14.79 0GRAND RAPIDS 364 COLLINGDALE WALKER 5/20/2018 CCFH 16 3.48 0MUSKEGON 1983 DYSON ST MUSKEGON 4/17/2018 CCFH 4 0.57 0ALLEN RD 8921 PARK AVE ALLEN PARK 5/21/2018 CCFH 16 4.64 0ALLEN RD 711 RIDGEMONT AVE DEARBORN 5/22/2018 CCFH 16 2.32 0ALLEN RD 22828 LODGE LN DEARBORN 5/23/2018 CCFH 16 2.32 0ALLEN RD 9180 MEYERS RD DETROIT 5/23/2018 CCFH 4 0.58 0ALLEN RD 22300 MCNICHOLS DETROIT 5/23/2018 CCFH 4 1.16 0ALLEN RD 641 RIDGEMONT AVE DEARBORN 5/24/2018 CCFH 16 2.32 0GRAND RAPIDS 231 STRAIGHT AVE SW GRAND RAPIDS 5/22/2018 CCFH 4 1.74 0MUSKEGON 4498 WHITEHALL RD MUSKEGON 5/22/2018 CCFH 34 4.86 0MUSKEGON 1907 HENRY ST MUSKEGON 5/23/2018 CCFH 16 4.98 0ALLEN RD 1060 WATERMAN DETROIT 5/30/2018 CCFH 16 4.64 0ALLEN RD 23601 CHERRY HILL ST DEARBORN 5/31/2018 CCFH 16 4.64 0ALLEN RD 15536 MCLAIN AVE ALLEN PARK 6/1/2018 CCFH 16 4.64 0ALLEN RD 23112 MARLBORO ST DEARBORN 6/1/2018 CCFH 34 9.86 0ALLEN RD 16525 WINTHROP ST DEARBORN 6/1/2018 CCFH 4 1.74 0LYNCH RD 574 ASHLAND ST APT 1F DETROIT 5/29/2018 CCFH 4 2.32 0LYNCH RD 346 MCKINLEY AVE

GROSSE POINTE FARMS

6/1/2018 CCFH 4 1.16 0GRAND RAPIDS 36 BLACKBURN ST SW WYOMING 5/28/2018 CCFH 4 0.58 0GRAND RAPIDS 941 THORNAPPLE RIVER DR SE ADA 5/30/2018 CCFH 34 7.40 0GRAND RAPIDS 4711 BRADFORD ST NE GRAND RAPIDS 5/31/2018 MCF 60 0 84.96GRAND RAPIDS 2890 ACQUEST AVE SE KENTWOOD 6/1/2018 CCFH 34 9.96 0GRAND RAPIDS 667 MYRTLE ST NW GRAND RAPIDS 6/1/2018 CCFH 16 6.96 0LYNCH RD 5304 FLORIDA DETROIT 5/7/2018 CCFH 4 3.48 0GRAND RAPIDS 2151 UNION AVE SE GRAND RAPIDS 4/12/2018 CCFH 4 1.16 0GRAND RAPIDS 1461 PERKINS GRAND RAPIDS 5/1/2018 CCFH 16 2.32 0GRAND RAPIDS 6772 GREENVILLE RD GREENVILLE 5/2/2018 CCFH 34 14.79 0GRAND RAPIDS 7979 KALAMAZOO SE BYRON CENTER 5/8/2018 CCFH 34 4.93 0GRAND RAPIDS 725 LAFAYETTE NE GRAND RAPIDS 5/19/2018 CCFH 4 0.87 0MUSKEGON 1675 MARQUETTE AVE MUSKEGON 5/14/2018 CCFH 16 2.29 0ALLEN RD 26200 FORD RD

DEARBORN HEIGHTS

6/4/2018 CCFH 16 4.64 0ALLEN RD 15441 OCEANA AVE ALLEN PARK 6/5/2018 CCFH 16 4.64 0ALLEN RD 6395 W OUTER DR DETROIT 6/5/2018 CCFH 4 1.74 0ESCANABA 4568 CO RD 416 20T ESCANABA 5/16/2018 CCFH 34 0.49 0ALLEN RD 15800 MCLAIN AVE ALLEN PARK 6/8/2018 CCFH 16 2.32 0LYNCH RD 4909 CECIL ST DETROIT 6/4/2018 CCFH 4 4.64 0LYNCH RD 18310 MACK

GROSSE POINTE FARMS

6/8/2018 CCFH 4 0.58 0TRAVERSE CITY 7768 N SHORE CT GREEN LAKE 5/9/2018 CCFH 34 4.86 0GRAND RAPIDS 8707 CLYDE PARK AV SW BYRON CENTER 6/4/2018 MCF 60 109.25 0GRAND RAPIDS 155 41 ST SW WYOMING 6/4/2018 CCFH 16 3.48 0TRAVERSE CITY 107 OTTAWA ST ELK RAPIDS 5/14/2018 CCFH 0 19.45 0GRAND RAPIDS 3000 E BELTLINE AV NE GRAND RAPIDS 6/4/2018 CCFH 34 7.40 0GRAND RAPIDS 2935 WALKENT DR NW WALKER 6/4/2018 CCFH 34 7.40 0TRAVERSE CITY 2408 N MEMORIAL HWY GARFIELD 5/1/2018 CCFH 34 12.16 0GRAND RAPIDS 3725 CASCADE RD SE GRAND RAPIDS 6/6/2018 CCFH 34 9.86 0TRAVERSE CITY 6050 PENINSULA TRAVERSE CITY 5/2/2018 CCFH 34 14.59 0KINGSFORD 301 MINE ST NORWAY 5/24/2018 CCFH 34 4.93 0PETOSKEY 538 W LAKE ST PETOSKEY 5/23/2018 MCF 8 23.99 0TRAVERSE CITY 1400 YELLOW DR TRAVERSE CITY 6/5/2018 CCFH 34 7.29 0KINGSFORD 1300 MICHIGAN AVE

IRON MOUNTAIN

6/4/2018 CCFH 34 19.72 0PETOSKEY 788 GROVE ST GAYLORD 5/27/2018 CCFH 34 20.76 0GRAYLING 217 ALGER GRAYLING 6/1/2018 CCFH 34 5.28 0TRAVERSE CITY 528 W 15TH TRAVERSE CITY 5/6/2018 CCFH 34 4.87 0MT PLEASANT 301 N BROWN MT PLEASANT 6/6/2018 CCFH 16 5.31 0ALLEN RD 22453 SOUTHPOINTE WOODHAVEN 6/11/2018 CCFH 29 12.62 0ALLEN RD 24279 WALLOON WAY 82 BROWNSTOWN 6/11/2018 CCFH 29 8.41 0ALLEN RD 6782 GOLDSMITH ST DETROIT 6/12/2018 CCFH 16 4.64 0ALLEN RD 18522 LENORE DETROIT 6/12/2018 CCFH 16 4.64 0ALLEN RD 13362 BEAUBIEN ST

SOUTH ROCKWOOD

6/12/2018 CCFH 16 4.64 0ALLEN RD 4785 CARLETON ROCKWOOD RD

SOUTH ROCKWOOD

6/14/2018 CCFH 34 9.86 0ALLEN RD 244 ROEHRIG TRENTON 6/16/2018 CCFH 16 4.64 0ALLEN RD 19774 BRAILE ST DETROIT 6/16/2018 CCFH 4 1.16 0TRAVERSE CITY 304 PINE ST ELK RAPIDS 5/30/2018 CCFH 34 1.62 0LYNCH RD 1609 24TH DETROIT 6/13/2018 CCFH 16 9.28 0LYNCH RD 20400 HELEN ST DETROIT 6/14/2018 CCFH 4 1.16 0LYNCH RD 20167 GREELEY ST DETROIT 6/15/2018 CCFH 4 3.48 0GRAND RAPIDS 3165 SHEAR AVE NE GRAND RAPIDS 6/11/2018 CCFH 34 4.93 0GRAND RAPIDS 3727 YELLOWSTONE DR SW GRANDVILLE 6/12/2018 CCFH 16 4.64 0



GRAND RAPIDS 8855 CLYDE PARK SW BYRON 6/12/2018 CCFH 34 7.40 0GRAND RAPIDS 15 10 MILE RD NW SPARTA 6/12/2018 CCFH 34 4.93 0GRAND RAPIDS 33 LA BELLE ST SW GRAND RAPIDS 6/13/2018 CCFH 4 0.58 0GRAND RAPIDS 860 84TH SE CALEDONIA 6/14/2018 CCFH 34 14.79 0PETOSKEY 1971 DICKERSEN RD GAYLORD 6/1/2018 MCF 54 204.20 0SSM MACKINAW TR & 3 MILE RD

SAULT STE MARIE

6/8/2018 MCF 60 312.97 0TRAVERSE CITY 4596 WILHELM RD RAPID CITY 6/12/2018 CCFH 34 7.29 0TRAVERSE CITY 839 INDIAN TRAIL BLVD EAST BAY 5/14/2018 CCFH 34 9.72 0TRAVERSE CITY 1898 WEST SILVER LAKE TRAVERSE CITY 5/14/2018 CCFH 34 3.21 0TRAVERSE CITY 823 LEELANAU FRANKFORT 4/25/2018 CCFH 34 70.45 0TRAVERSE CITY 800 COTTAGE VIEW TRAVERSE CITY 5/17/2018 MCF 60 257.00 0MT PLEASANT 1100 WATSON MT PLEASANT 6/21/2018 CCFH 34 22.55 0LYNCH RD 5545 LAKEPOINTE DETROIT 6/20/2018 CCFH 4 1.74 0PETOSKEY 6622 US 31 HAYES 6/6/2018 MCF 95 272.84 0ALLEN RD 20435 BASIL ST DETROIT 6/18/2018 CCFH 4 1.16 0ALLEN RD 1796 BUCKINGHAM AVE LINCOLN PARK 6/19/2018 CCFH 16 4.64 0ALLEN RD 18620 PLYMOUTH RD DETROIT 6/19/2018 CCFH 4 1.16 0ALLEN RD 25001 NEWTON ST DEARBORN 6/21/2018 CCFH 16 2.32 0MICHIGAN AVE 20188 LICHFIELD RD DETROIT 6/21/2018 CCFH 4 1.74 0ALLEN RD 8878 FERRY RD GROSSE ILE 6/21/2018 CCFH 16 4.64 0ALLEN RD 22912 MARLBORO ST DEARBORN 6/22/2018 CCFH 34 9.86 0LYNCH RD 5769 BEWICK ST DETROIT 6/21/2018 CCFH 4 2.32 0LYNCH RD 21335 BOURNEMOUTH ST

HARPER WOODS

6/23/2018 CCFH 34 19.72 0MICHIGAN AVE

46735 S INTERSTATE 94 SERVICE DR

BELLEVILLE 6/21/2018 CCFH 34 4.93 0GRAND RAPIDS 15 10 MILE NW SPARTA 6/18/2018 MCF 60 11.19 0GRAND RAPIDS 15 10 MILE NW SPARTA 6/19/2018 MCF 60 0 11.19GRAND RAPIDS 4460 40TH ST SE GRAND RAPIDS 6/19/2018 CCFH 34 19.72 0GRAND RAPIDS 3918 EGYPT VALLEY AV NE ADA 6/19/2018 CCFH 34 19.72 0GRAND RAPIDS 4837 CRANWOOD AVE SW WYOMING 6/21/2018 CCFH 34 4.93 0LUDINGTON 188 12TH ST MANISTEE 6/19/2018 CCFH 34 2.47 0ALLEN RD 19551 WOOD ST MELVINDALE 6/20/2018 CCFH 16 4.64 0ALLEN RD 23010 MARLBORO ST DEARBORN 6/22/2018 CCFH 16 2.32 0LYNCH RD 6134 DICKERSON ST DETROIT 6/23/2018 CCFH 4 1.16 0LYNCH RD 5545 LAKEPOINTE ST DETROIT 6/20/2018 CCFH 4 1.74 0MT PLEASANT 1629 CHIPPEWA CITY MT PLEASANT 6/20/2018 MCF 34 486.20 0ALLEN RD 19551 WOOD ST MELVINDALE 6/28/2018 CCFH 16 6.96 0ALLEN RD 20980 MILLARD ST TAYLOR 6/29/2018 CCFH 16 4.64 0ALLEN RD 22070 W RIVER RD GROSSE ILE 6/29/2018 CCFH 34 14.79 0ALLEN RD 8079 GRANDVILLE AVE DETROIT 6/29/2018 CCFH 4 1.16 0ALLEN RD 5669 HIGHVIEW ST

DEARBORN HEIGHTS

6/30/2018 CCFH 16 4.64 0LYNCH RD 20173 RUSSELL ST DETROIT 6/29/2018 CCFH 4 4.64 0LYNCH RD 3120 HENDRICKS ST DETROIT 6/30/2018 CCFH 4 3.48 0MICHIGAN AVE 2156 OVERLOOK CT ANN ARBOR 6/27/2018 CCFH 34 26.44 0GRAND RAPIDS 7255 PINE ISLAND DR NE

PLAINFIELD TWP

6/27/2018 CCFH 34 9.86 0GRAND RAPIDS 595 EASTERN AVE NE GRAND RAPIDS 6/27/2018 CCFH 4 1.16 0GRAND RAPIDS 3619 LONG GROVE DR SE KENTWOOD 6/27/2018 CCFH 34 14.79 0GRAND RAPIDS 2641 BYRON CENTER AVE SW WYOMING 6/27/2018 CCFH 16 2.32 0GRAND RAPIDS 3700 32ND ST SE KENTWOOD 6/29/2018 MCF 60 844.57 0GRAND RAPIDS 3721 HOLIDAY DR GREENVILLE 6/29/2018 CCFH 34 14.79 0MT PLEASANT 10807 LAKESIDE DR 6/26/2018 MCF 60 0 181.38ALLEN RD 16031 BEECH DALY RD TAYLOR 7/2/2018 MCF 45 0 158.26ALLEN RD 7272 W OUTER DR DETROIT 7/5/2018 CCFH 4 0.58 0ALLEN RD 32350 CHURCH ST ROCKWOOD 7/5/2018 CCFH 16 4.64 0ALLEN RD 8216 ELM ST TAYLOR 7/7/2018 CCFH 16 4.64 0LYNCH RD 3120 HENDRICKS ST DETROIT 7/3/2018 CCFH 4 4.64 0ALLEN RD 253 CREST AVE ANN ARBOR 7/5/2018 CCFH 4 0.58 0GRAND RAPIDS 8315 COTTONWOOD DR JENISON 7/2/2018 CCFH 16 3.48 0GRAND RAPIDS 4253 COSTA AVE NE GRAND RAPIDS 7/5/2018 CCFH 16 4.64 0GRAND RAPIDS 1660 SAGINAW RD SE GRAND RAPIDS 7/6/2018 CCFH 4 1.16 0MUSKEGON 6256 WALLIS ST FREMONT 7/5/2018 CCFH 16 2.49 0MT PLEASANT 1109 E CHIPPEWA MT PLEASANT 7/2/2018 CCFH 16 10.27 0ALLEN RD 2327 PEARL DETROIT 5/2/2018 MCF 2 0 317.92TRAVERSE CITY 957 AVENUE D TRAVERSE CITY 6/26/2018 CCFH 34 4.76 0MUSKEGON 6471 SCOTT TWIN LAKE 6/23/2018 CCFH 40 2.86 0LYNCH RD 19390 SAN JUAN DETROIT 7/2/2018 CCFH 4 1.16 0CADILLAC 5063 S US 131 6/21/2018 CCFH 34 4.93 0MT PLEASANT 901 E CHIPPEWA MT PLEASANT 6/25/2018 CCFH 16 5.31 0TRAVERSE CITY 942 NAKOMA TRAVERSE CITY 6/20/2018 CCFH 34 4.86 0ALLEN RD 23050 SHERIDAN DEARBORN 4/3/2018 CCFH 16 4.64 0ALLEN RD 2440 JUNCTION DETROIT 4/4/2018 MCF 2 37.81 0GRAND RAPIDS 6393 WEST RIVER DR NE BELMONT 6/7/2018 CCFH 34 14.79 0ALLEN RD 11628 FORRER DETROIT 7/8/2018 CCFH 4 2.90 0TRAVERSE CITY 8255 OUTER DR S LONG LAKE 6/21/2018 CCFH 34 4.76 0ALLEN RD 21244 VAN BORN DEARBORN

HEIGHTS6/24/2018 CCFH 16 4.64 0

ALLEN RD 2918 LAFAYETTE BL ST LINCOLN PARK 7/9/2018 CCFH 16 9.28 0ALLEN RD 6219 KINGSBURY ST ST

DEARBORN HEIGHTS

7/9/2018 CCFH 16 2.32 0ALLEN RD 8414 W OUTER DR DETROIT 7/9/2018 MCF 2 10.17 0ALLEN RD 9361 W PARKWAY ST ST DETROIT 7/9/2018 MCF 10 0.44 0ALLEN RD 4942 WALWIT ST ST DEARBORN 7/10/2018 CCFH 34 14.79 0ALLEN RD 1 PARKLANE BLVD ST DEARBORN 7/10/2018 MCF 10 0 349.87



ALLEN RD 1100 OAKWOOD BLVD ST DEARBORN 7/10/2018 CCFH 16 4.64 0ALLEN RD 15811 MANSFIELD ST ST DEARBORN 7/10/2018 CCFH 16 2.32 0ALLEN RD 22948 SIBLEY RD BROWNSTOWN 7/11/2018 CCFH 29 4.21 0ALLEN RD 1573 MICHIGAN BLVD LINCOLN PARK 7/13/2018 CCFH 16 2.32 0ALLEN RD 7124 W LAFAYETTE BLVD DETROIT 7/14/2018 CCFH 4 2.32 0LYNCH RD 18617 GREELEY ST DETROIT 7/9/2018 CCFH 4 3.48 0LYNCH RD 900 MERRILL PLASISANCE DETROIT 7/10/2018 CCFH 4 3.48 0LYNCH RD 5040 IVANHOE ST DETROIT 7/11/2018 CCFH 4 4.64 0LYNCH RD 2980 W OUTER DR DETROIT 7/12/2018 CCFH 4 4.64 0MICHIGAN AVE 10465 BEMIS RD YPSILANTI 7/14/2018 CCFH 34 10.57 0GRAND RAPIDS 4106 BLAIR ST HUDSONVILLE 7/10/2018 CCFH 34 22.44 0GRAND RAPIDS 359 DIVISION AVE S GRAND RAPIDS 7/11/2018 MCF 10 0 54.67GRAND RAPIDS 51 LABELLE ST SW GRAND RAPIDS 7/12/2018 CCFH 4 1.32 0GRAND RAPIDS 190 WEALTHY ST SW GRAND RAPIDS 7/12/2018 MCF 2 0 377.52MUSKEGON 2865 WHITEHALL RD MUSKEGON 7/11/2018 CCFH 34 9.72 0ALLEN RD 515 RIDGEMONT DEARBORN 6/27/2018 CCFH 16 4.64 0CADILLAC 117 CASS ST CADILLAC 7/13/2018 CCFH 34 3.21 0MICHIGAN AVE 211 W DAVIS ANN ARBOR 7/2/2018 CCFH 4 1.87 0ALLEN RD 14029 TALL OAKS CT RIVERVIEW 7/16/2018 CCFH 16 4.64 0ALLEN RD 10610 PARDEE RD ST TAYLOR 7/16/2018 CCFH 16 4.64 0ALLEN RD 19334 MURRAY HILL ST DETROIT 7/17/2018 CCFH 4 1.16 0ALLEN RD 14085 TALL OAKS CT RIVERVIEW 7/17/2018 CCFH 16 4.64 0ALLEN RD 13676 MULBERRY ST SOUTHGATE 7/19/2018 CCFH 16 13.92 0ALLEN RD 4661 W OUTER DR DETROIT 7/19/2018 CCFH 4 1.16 0MICHIGAN AVE 19551 WOOD ST MELVINDALE 7/20/2018 CCFH 16 2.32 0ALLEN RD 14360 GRANDVILLE AVE DETROIT 7/20/2018 CCFH 4 0.58 0ALLEN RD 1276 S ETHEL ST DETROIT 7/21/2018 CCFH 5 1.45 0LYNCH RD 19152 HELEN ST DETROIT 7/18/2018 CCFH 4 0.58 0ALLEN RD 3208 MILITARY ST DETROIT 7/19/2018 CCFH 16 2.32 0LYNCH RD 20020 ALCOY DETROIT 7/20/2018 CCFH 4 2.32 0GRAND RAPIDS 1316 MARQUETTE ST SW WYOMING 7/16/2018 CCFH 4 31.68 0GRAND RAPIDS 37 ZENO ST SW GRAND RAPIDS 7/17/2018 CCFH 4 1.32 0GRAND RAPIDS 4702 40TH AVE HUDSONVILLE 7/17/2018 CCFH 34 5.61 0GRAND RAPIDS 3435 LAKE EASTBROOK BLVD SE GRAND RAPIDS 7/18/2018 CCFH 34 22.44 0GRAND RAPIDS 6191 GEORGE ANN CT NE BELMONT 7/18/2018 CCFH 34 11.22 0GRAND RAPIDS 2165 43RD ST SE GRAND RAPIDS 7/19/2018 CCFH 34 11.22 0GRAND RAPIDS 4630 ALLYSON AVE SW WYOMING 7/19/2018 CCFH 34 8.42 0GRAND RAPIDS 6700 SE 60TH ST GRAND RAPIDS 7/20/2018 CCFH 34 16.83 0TRAVERSE CITY 510 W NINTH ST TRAVERSE CITY 6/29/2018 CCFH 34 2.46 0ALLEN RD 5624 TELEGRAPH DEARBORN

HEIGHTS7/23/2018 CCFH 16 4.64 0

MT PLEASANT 4773 LAKESIDE DR 7/12/2018 CCFH 34 21.83 0ALLEN RD 23747 ELMIRA REDFORD 7/24/2018 CCFH 16 2.32 0LYNCH RD 5915 RENVILLE ST DETROIT 7/26/2018 CCFH 34 29.58 0MICHIGAN AVE 114 WALNUT ST WYANDOTTE 7/28/2018 CCFH 16 4.64 0LYNCH RD 18965 BIRCHCREST DR DETROIT 7/23/2018 CCFH 4 3.48 0LYNCH RD 15052 SPRING GARDEN ST DETROIT 7/25/2018 CCFH 4 1.16 0LYNCH RD 320 MACK AVE DETROIT 7/26/2018 CCFH 16 4.64 0LYNCH RD 4684 NEWPORT ST DETROIT 7/26/2018 CCFH 4 2.32 0GRAND RAPIDS 4425 44TH ST SE KENTWOOD 7/23/2018 CCFH 34 5.61 0GRAND RAPIDS 5431 WING AVE SE KENTWOOD 7/24/2018 CCFH 34 44.88 0GRAND RAPIDS 158 PROSPECT ST ROCKFORD 7/25/2018 CCFH 16 1.32 0GRAND RAPIDS 1271 DEN HERTOG ST SW WYOMING 7/26/2018 CCFH 16 2.64 0GRAND RAPIDS 1749 KREFT ST NE GRAND RAPIDS 7/26/2018 CCFH 16 5.28 0GRAND RAPIDS 1607 ROBINSON RD GRAND RAPIDS 7/26/2018 CCFH 4 2.64 0GRAND RAPIDS 343 ATLAS AVE SE GRAND RAPIDS 7/27/2018 CCFH 4 1.98 0GRAND RAPIDS 643 9TH ST NW GRAND RAPIDS 7/27/2018 MCF 10 0 175.89GRAND RAPIDS 300 DICKINSON ST SW GRAND RAPIDS 7/27/2018 MCF 2 0 50.08GRAND RAPIDS 4702 40TH AVE HUDSONVILLE 7/28/2018 CCFH 34 8.42 0MUSKEGON 1892 SOUTHWOOD AVE

NORTON SHORES

7/24/2018 CCFH 16 6.86 0MUSKEGON 1683 VERNON PL MUSKEGON 7/24/2018 CCFH 16 4.58 0MUSKEGON 7338 OAK MEADOW DR TWIN LAKE 7/25/2018 CCFH 34 14.59 0MT PLEASANT 1208 E CAMPUS MT PLEASANT 7/24/2018 CCFH 16 74.76 0CADILLAC 712 SELMA CADILLAC 7/26/2018 MCF 60 0 2.86ALLEN RD 31550 GOSSETT DRIVE ROCKWOOD 7/30/2018 CCFH 16 4.64 0ALLEN RD 17110 PATTON DETROIT 7/30/2018 CCFH 4 1.16 0ALLEN RD 16643 KENNEBEC SOUTHGATE 7/30/2018 CCFH 16 2.32 0ALLEN RD 11303 STEEL DETROIT 7/30/2018 CCFH 4 2.32 0LYNCH RD 5622 MICHIGAN DETROIT 7/30/2018 CCFH 4 2.32 0LYNCH RD 2145 E CANFIELD ST DETROIT 7/31/2018 CCFH 16 13.92 0LYNCH RD 15084 SPRING GARDEN ST DETROIT 7/31/2018 CCFH 4 3.48 0LYNCH RD 3235 W OUTER DR DETROIT 7/31/2018 CCFH 4 1.16 0ALLEN RD 6040 REGULAR ST DETROIT 8/2/2018 CCFH 4 2.32 0ALLEN RD 1131 HILLCREST DR DEARBORN 8/2/2018 MCF 10 80.04 0LYNCH RD 253 MCLEAN

HIGHLAND PARK

8/2/2018 CCFH 4 2.32 0GRAND RAPIDS 828 BRIDGE ST NW GRAND RAPIDS 7/30/2018 CCFH 4 0.66 0GRAND RAPIDS 717 DICKINSON ST SE GRAND RAPIDS 7/31/2018 CCFH 4 0.33 0GRAND RAPIDS 500 GRANDVILLE AVE SW GRAND RAPIDS 8/1/2018 CCFH 4 0.33 0GRAND RAPIDS 4061 LEONARD ST NW GRAND RAPIDS 8/1/2018 CCFH 16 2.64 0GRAND RAPIDS 7802 COTTONWOOD DR JENISON 8/2/2018 CCFH 16 0.29 0GRAND RAPIDS 315 DONALD ST ROCKFORD 8/2/2018 MCF 16 0 25.97



GRAND RAPIDS 409 E NORTH ST GREENVILLE 8/3/2018 CCFH 34 9.86 0GRAND RAPIDS 1056 SYDNEY DR NW WALKER 8/3/2018 CCFH 16 3.48 0GRAND RAPIDS 1625 LAKE DR SE GRAND RAPIDS 8/3/2018 CCFH 4 0.58 0GRAND RAPIDS 2058 KALAMAZOO AVE SW GRAND RAPIDS 8/4/2018 MCF 4 0 270.27MUSKEGON 414 HOUSTON AVE MUSKEGON 8/2/2018 CCFH 4 1.14 0LYNCH RD 3500 W OUTER DR DETROIT 8/6/2018 CCFH 4 3.48 0LYNCH RD 19660 LICHFIELD DETROIT 8/9/2018 CCFH 4 1.74 0GRAYLING 113 SHAWNEE 7/30/2018 CCFH 34 2.64 0ALLEN RD 12800 APPLETON ST DETROIT 8/6/2018 MCF 10 0.45 0ALLEN RD 9682 SHARON ST TAYLOR 8/6/2018 CCFH 29 4.21 0ALLEN RD 8654 CARTER AVE ALLEN PARK 8/6/2018 CCFH 16 2.09 0ALLEN RD 22334 RYEGATE ST WOODHAVEN 8/7/2018 CCFH 29 16.82 0ALLEN RD 1156 FORT PARK ST LINCOLN PARK 8/7/2018 MCF 16 176.02 0ALLEN RD 15743 MANSFIELD ST DETROIT 8/8/2018 CCFH 4 1.16 0ALLEN RD 3625 S ANNABELLE ST DETROIT 8/11/2018 CCFH 5 1.45 0LYNCH RD 726 NORTE DAME GROSSE POINTE 8/8/2018 CCFH 4 1.16 0GRAND RAPIDS 4103 LEONARD ST NW GRAND RAPIDS 8/8/2018 CCFH 16 2.32 0GRAND RAPIDS 1451 EDGEWOOD AVE SE GRAND RAPIDS 8/9/2018 CCFH 16 4.65 0GRAND RAPIDS 4950 3 MILE ROAD GRAND RAPIDS 8/10/2018 CCFH 34 9.86 0GRAND RAPIDS 7912 COTTONWOOD JENISON 8/10/2018 MCF 16 0 440.28ESCANABA 8181 HWY US 32 RAPID RIVER 7/31/2018 CCFH 34 9.86 0KINGSFORD 1517 WOODWARD AVE KINGSFORD 8/6/2018 CCFH 34 9.86 0ALLEN RD 23668 SIBLEY BROWNSTOWN 8/3/2018 CCFH 29 8.41 0MICHIGAN AVE 13031 JOSLIN LAKE RD LYNDON TWP 8/2/2018 CCFH 34 4.64 0MICHIGAN AVE 42626 BEECHWOOD DR CANTON 8/12/2018 CCFH 34 14.79 0ALLEN RD 24632 HALLEY CRESCENT DR GROSSE ILE 8/13/2018 CCFH 34 9.86 0ALLEN RD 1838 MCKINLEY ST WYANDOTTE 8/15/2018 CCFH 16 4.64 0ALLEN RD 7388 W OUTER DR DETROIT 8/15/2018 MCF 2 0 64.37ALLEN RD 3852 15TH WYANDOTTE 8/12/2018 CCFH 16 4.64 0ALLEN RD 7211 W OUTER DR DETROIT 8/15/2018 CCFH 4 1.74 0ALLEN RD 4774 WALWIT ST DEARBORN 8/15/2018 CCFH 34 29.58 0ALLEN RD 8953 KATHERINE ST TAYLOR 8/16/2018 CCFH 16 6.96 0ALLEN RD 3204 LAFAYETTE DR TRENTON 8/17/2018 CCFH 16 9.28 0ALLEN RD 22418 RYEGATE ST WOODHAVEN 8/17/2018 CCFH 24 6.96 0LYNCH RD 4415 35TH ST DETROIT 8/13/2018 CCFH 4 2.32 0LYNCH RD 20480 OLD HOMESTEAD DR HARPER

WOODS8/15/2018 CCFH 4 2.32 0

LYNCH RD 6633 ROHNS ST DETROIT 8/17/2018 CCFH 4 2.32 0MICHIGAN AVE 775 TECHNOLOGY PITTSFIELD 8/15/2018 MCF 34 0 293.72GRAND RAPIDS 1570 BRIDGEWATER CT SE GRAND RAPIDS 8/13/2018 CCFH 34 9.86 0GRAND RAPIDS 3704 PIUTE DR SW GRANDVILLE 8/13/2018 CCFH 16 4.64 0GRAND RAPIDS 4120 VALLEY VISTA DR HUDSONVILLE 8/15/2018 MCF 34 0 258.23GRAND RAPIDS 7575 FULTON ST ADA 8/16/2018 CCFH 337 481.48 0GRAND RAPIDS 854 N OTTILLIA ST SE GRAND RAPIDS 8/17/2018 MCF 4 0 68.35GRAND RAPIDS 260 PROSPECT ST ROCKFORD 8/18/2018 CCFH 16 2.32 0MUSKEGON 2118 RUDDIMAN DR MUSKEGON 8/13/2018 CCFH 16 2.29 0ESCANABA 5288 17.5 ROAD

WELLS TOWNSHIP

8/14/2018 CCFH 34 4.93 0CADILLAC 11751 LAKE SHORE DR FIFE LAKE 8/2/2018 CCFH 34 4.86 0ALLEN RD 25045 NORTHLINE TAYLOR 8/2/2018 CCFH 29 8.41 0KINGSFORD 85 BRADY 8/8/2018 CCFH 34 4.93 0MUSKEGON 9996 WALSH RD MONTAGUE 8/4/2018 CCFH 16 2.29 0MUSKEGON 370 MID OAK AVE

NORTH MUSKEGON

8/3/2018 CCFH 16 3.43 0ESCANABA 118 ELM MUNISING 8/6/2018 CCFH 34 1.48 0ALLEN RD 37 MARIE ST ECORSE 8/14/2018 CCFH 4 1.16 0ALLEN RD 9600 STONE DETROIT 8/12/2018 MCF 2 265.12 0LYNCH RD 2117 TROWBRIDGE HAMTRAMCK 8/12/2018 CCFH 4 0.58 0ALLEN RD 10008 CONTINENTAL DR TAYLOR 8/20/2018 CCFH 29 8.41 0ALLEN RD 101 N ROSEVERE AVE DEARBORN 8/20/2018 MCF 10 0.33 0ALLEN RD 20990 WEST RD WOODHAVEN 8/21/2018 CCFH 29 25.23 0ALLEN RD 3120 AMAZON ST DEARBORN 8/24/2018 CCFH 4 0.11 0ALLEN RD 2785 SALINA ST DEARBORN 8/24/2018 CCFH 4 0.58 0ALLEN RD 17540 ANNCHESTER DETROIT 8/25/2018 CCFH 4 1.16 0LYNCH RD 1451 LAKEPOINTE ST

GROSSE POINTE PARK

8/20/2018 CCFH 16 3.48 0LYNCH RD 107 MELBOURNE ST DETROIT 8/22/2018 CCFH 16 9.28 0LYNCH RD 5251 15TH DETROIT 8/25/2018 CCFH 16 2.32 0GRAND RAPIDS 1438 HERRICK AVE NE GRAND RAPIDS 8/20/2018 CCFH 4 1.16 0GRAND RAPIDS 1632 LINDEN AVE SE GRAND RAPIDS 8/21/2018 CCFH 4 1.16 0GRAND RAPIDS 509 MERRICK ST BELDING 8/21/2018 MCF 16 0 20.24GRAND RAPIDS 5431 EDGELAWN DR SE KENTWOOD 8/22/2018 CCFH 16 1.16 0GRAND RAPIDS 600 GREENTREE LN NE ADA 8/22/2018 CCFH 34 7.40 0GRAND RAPIDS 6010 PINE ISLAND DR NE

PLAINFIELD TWP

8/24/2018 CCFH 34 256.36 0GRAND RAPIDS 2610 STARR ST SE CASCADE 8/25/2018 CCFH 34 12.33 0MUSKEGON 4068 LE CLARE ST FRUITPORT 8/25/2018 CCFH 16 2.29 0ALLEN RD 3615 SYCKELMOORE ST TRENTON 8/19/2018 CCFH 16 6.96 0CADILLAC 208 4TH ST FIFE LAKE 8/25/2018 CCFH 34 21.83 0TRAVERSE CITY 5705 US 31 N WILLIAMSBURG 8/20/2018 CCFH 34 4.86 0ALLEN RD 15611 JONAS AVE ALLEN PARK 8/27/2018 CCFH 16 2.09 0ALLEN RD 15783 JONAS AVE ALLEN PARK 8/28/2018 CCFH 16 4.64 0ALLEN RD 19207 PARKE LN GROSSE ILE 8/28/2018 CCFH 34 9.86 0ALLEN RD 15745 JONAS AVE ALLEN PARK 8/28/2018 CCFH 16 18.56 0ALLEN RD 15440 JONAS AVE ALLEN PARK 8/29/2018 CCFH 16 9.28 0



ALLEN RD 7761 AUBURN ST DETROIT 8/29/2018 CCFH 4 0.58 0ALLEN RD 23668 SIBLEY RD BROWNSTOWN 8/29/2018 CCFH 29 8.41 0ALLEN RD 16728 MCCANN ST SOUTHGATE 8/30/2018 CCFH 16 4.64 0ALLEN RD 21279 DANBURY ST WOODHAVEN 8/30/2018 CCFH 34 4.93 0ALLEN RD 12821 MOUND RD DETROIT 8/28/2018 CCFH 4 1.16 0LYNCH RD 3537 W OUTER DR DETROIT 8/29/2018 MCF 32 0 4.64LYNCH RD 3565 W OUTER DR DETROIT 8/30/2018 CCFH 4 4.64 0LYNCH RD 9763 DUNDEE ST DETROIT 8/30/2018 CCFH 4 2.32 0ALLEN RD 32130 NEWCASTLE ST ROMULUS 8/27/2018 CCFH 16 9.28 0ALLEN RD 7521 DOVER DR YPSILANTI 8/27/2018 MCF 34 0 531.96ALLEN RD 1335 HILL ST ANN ARBOR 8/29/2018 CCFH 4 1.16 0ALLEN RD

43377 S INTERSTATE 94 SERVICE DR

BELLEVILLE 9/1/2018 CCFH 24 6.96 0MICHIGAN AVE 19010 CRAIG ST NEW BOSTON 9/1/2018 CCFH 16 2.32 0GRAND RAPIDS 5300 BROADMOOR AVE SE GRAND RAPIDS 8/27/2018 CCFH 34 9.86 0GRAND RAPIDS 1150 64TH ST SW BYRON CENTER 8/27/2018 CCFH 34 7.40 0GRAND RAPIDS 711 DICKINSON ST SE GRAND RAPIDS 8/27/2018 CCFH 4 1.16 0GRAND RAPIDS 1925 BRETON RD SE GRAND RAPIDS 8/27/2018 CCFH 16 6.96 0GRAND RAPIDS 2069 INNWOOD DR SE KENTWOOD 8/29/2018 CCFH 34 4.93 0GRAND RAPIDS 914 WOODSPOINTE DR SW BRYON 9/1/2018 CCFH 34 4.64 0ESCANABA 9859 S 75 RD 8/31/2018 CCFH 34 0.49 0TRAVERSE CITY 9122 PENINSULA DR TRAVERSE CITY 8/20/2018 CCFH 34 9.72 0TRAVERSE CITY 1655 E BRENTWOOD GRAWN 8/20/2018 CCFH 34 9.72 0TRAVERSE CITY 3722 APOLLE DR BLAIR 8/23/2018 CCFH 34 4.86 0ALLEN RD 12813 SUPERIOR SOUTHGATE 8/30/2018 CCFH 16 9.28 0GRAYLING 4400 W 4 MILE 8/24/2018 CCFH 34 5.28 0CADILLAC 6815 CROSBY CADILLAC 8/10/2018 CCFH 34 21.83 0ALLEN RD 22418 RYEGATE ST WOODHAVEN 9/4/2018 CCFH 29 8.41 0ALLEN RD 20581 FIVE POINTS REDFORD 9/5/2018 CCFH 16 2.32 0LYNCH RD 11043 FRENCH RD DETROIT 9/4/2018 CCFH 40 11.60 0LYNCH RD 3751 W OUTER DR DETROIT 9/6/2018 CCFH 4 1.16 0LYNCH RD 1415 TRUMBULL ST DETROIT 9/7/2018 CCFH 16 4.64 0LYNCH RD 15362 TULLER ST DETROIT 9/7/2018 CCFH 14 4.06 0LYNCH RD 5565 BLUEHILL ST DETROIT 9/8/2018 CCFH 4 1.74 0GRAND RAPIDS 5955 WING AVE SE GRAND RAPIDS 9/4/2018 CCFH 34 9.86 0GRAND RAPIDS 1233 IONIA AVE SW GRAND RAPIDS 9/4/2018 CCFH 4 1.45 0GRAND RAPIDS 1272 BALDWIN ST JENISON 9/6/2018 CCFH 16 8.12 0GRAND RAPIDS 3869 KNAPP ST GRAND RAPIDS 9/6/2018 CCFH 34 4.93 0GRAND RAPIDS 1475 BEAVER CREEK DR NE BELMONT 9/8/2018 CCFH 34 4.93 0ALLEN RD 21055 WELLINGTON ST WOODHAVEN 9/10/2018 CCFH 29 0.84 0ALLEN RD 24203 WOODLAND DR BROWNSTOWN 9/13/2018 CCFH 29 16.82 0ALLEN RD 14775 DIX TOLEDO RD SOUTHGATE 9/14/2018 MCF 16 5.53 0ALLEN RD 6222 N BEECH DALY RD DEARBORN

HEIGHTS9/14/2018 MCF 16 0 103.49

ALLEN RD 15847 KRAMER ST DETROIT 9/15/2018 CCFH 4 1.74 0LYNCH RD 12376 DUCHESS ST DETROIT 9/11/2018 CCFH 4 3.48 0ALLEN RD 319 RIVARD BLVD GROSSE POINTE 9/11/2018 CCFH 5 1.16 0LYNCH RD 15015 MUIRLAND ST DETROIT 9/12/2018 CCFH 4 4.06 0ALLEN RD 620 NAVAHOE DETROIT 9/13/2018 CCFH 16 4.64 0LYNCH RD 1446 NOTTINGHAM RD

GROSSE POINTE PARK

9/14/2018 CCFH 4 1.74 0LYNCH RD 370 E GRAND BLVD DETROIT 9/14/2018 CCFH 2 2.90 0GRAND RAPIDS 1320 CALLAGHAN ST GREENVILLE 9/11/2018 CCFH 34 9.86 0GRAND RAPIDS 2670 56TH SW WYOMING 9/12/2018 CCFH 34 2.47 0GRAND RAPIDS 6542 ROLLINGVIEW DR HUDSONVILLE 9/12/2018 CCFH 34 4.93 0GRAND RAPIDS 730 FOREST HILLS DR SE GRAND RAPIDS 9/12/2018 CCFH 34 4.93 0GRAND RAPIDS 57 COVELL AVE SW WALKER 9/13/2018 CCFH 16 4.64 0GRAND RAPIDS 7150 KALAMAZOO AVE SE CALEDONIA 9/14/2018 CCFH 34 9.86 0ESCANABA 4708 17TH ROAD

WELLS TOWNSHIP

9/14/2018 CCFH 34 1.97 0ALLEN RD 2596 HONORAH DETROIT 9/11/2018 CCFH 4 1.74 0MT PLEASANT 321 JOHN R ST CLARE 9/13/2018 CCFH 34 9.72 0LYNCH RD 19345 LIVERNOIS DETROIT 9/12/2018 CCFH 34 4.93 0ALLEN RD 8672 LAKE RD GROSSE ILE 9/18/2018 CCFH 34 14.74 0ALLEN RD 9200 W VERNOR HWY DETROIT 9/17/2018 CCFH 16 6.96 0ALLEN RD 19374 FIVE POINTS REDFORD 9/18/2018 CCFH 16 13.92 0ALLEN RD 23020 MURRAY ST DEARBORN 9/19/2018 CCFH 16 9.28 0ALLEN RD 2816 23 RD ST WYANDOTTE 9/19/2018 CCFH 16 9.28 0LYNCH RD 12908 VAUGHAN DETROIT 9/19/2018 CCFH 4 1.74 0ALLEN RD 301 S CAVALRY ST DETROIT 9/19/2018 CCFH 4 1.16 0ALLEN RD 5890 DRIGGS DETROIT 9/19/2018 CCFH 4 1.16 0ALLEN RD 20731 COUNTRY OAKS DR RIVERVIEW 9/20/2018 CCFH 16 4.64 0ALLEN RD 17818 REDFERN ST DETROIT 9/21/2018 CCFH 4 1.16 0ALLEN RD 17311 WOOD ST MELVINDALE 9/21/2018 CCFH 16 4.64 0LYNCH RD 13400 ARLINGTON ST HAMTRAMCK 9/22/2018 CCFH 4 1.16 0LYNCH RD 8126 KERCHEVAL ST DETROIT 9/22/2018 CCFH 4 2.32 0GRAND RAPIDS 320 DICKINSON GRAND RAPIDS 9/17/2018 CCFH 4 0.58 0GRAND RAPIDS 3794 NEW HOLLAND ST HUDSONVILLE 9/17/2018 CCFH 34 9.86 0GRAND RAPIDS 1835 BRETON RD SE GRAND RAPIDS 9/18/2018 CCFH 16 2.32 0GRAND RAPIDS 1734 HANCHETT AVE NW GRAND RAPIDS 9/18/2018 CCFH 16 4.64 0GRAND RAPIDS 4526 KNAPP ST SE GRAND RAPIDS 9/18/2018 CCFH 34 4.93 0GRAND RAPIDS 1355 JUDD AVE SW WYOMING 9/19/2018 CCFH 16 5.80 0GRAND RAPIDS 966 BARNUM ST SW WYOMING 9/20/2018 CCFH 16 2.32 0GRAND RAPIDS 2071 DUNNIGAN AV NE GRAND RAPIDS 9/21/2018 CCFH 34 4.93 0



LUDINGTON 1980 RED APPLE RD MANISTEE 9/17/2018 CCFH 34 3.25 0TAWAS 1741 E US 23 EAST TAWAS 9/21/2018 CCFH 34 1.76 0CADILLAC 5546 BOARDMAN RD 9/20/2018 CCFH 34 16.38 0ALLEN RD 4857 FIRESTONE ST DEARBORN 9/26/2018 CCFH 34 14.79 0ALLEN RD 21295 DANBURY WOODHAVEN 9/28/2018 CCFH 34 9.86 0LYNCH RD 13191 MORAN DETROIT 9/24/2018 CCFH 4 1.16 0ALLEN RD 2500 S STATE ANN ARBOR 9/29/2018 CCFH 34 19.72 0GRAND RAPIDS 2240 LEONARD ST NW GRAND RAPIDS 9/24/2018 CCFH 16 2.32 0GRAND RAPIDS 955 SYDNEY DR NW WALKER 9/25/2018 CCFH 16 2.32 0GRAND RAPIDS 45 COLRAIN ST SW WYOMING 9/25/2018 CCFH 16 4.64 0GRAND RAPIDS 5275 W RIVER CT NE

COMSTOCK PARK

9/27/2018 CCFH 34 4.93 0LUDINGTON 1031 IVANHOE DR MUSKEGON 9/26/2018 CCFH 16 6.86 0ALLEN RD 2427 WEST RD TRENTON 9/5/2018 CCFH 16 13.92 0TRAVERSE CITY 131 N ELMWOOD TRAVERSE CITY 9/19/2018 CCFH 34 9.86 0LYNCH RD 13435 LANGLIN SOUTHGATE 9/23/2018 CCFH 4 1.16 0TRAVERSE CITY 4456 DAISY LN GARFIELD 9/14/2018 MCF 34 0 91.52TRAVERSE CITY 311 W TWELFTH ST TRAVERSE CITY 9/20/2018 CCFH 34 3.21 0LYNCH RD 5240 STANTON DETROIT 9/22/2018 CCFH 16 4.64 0TRAVERSE CITY 2825 N US 31 S GARFIELD 8/29/2018 CCFH 34 3.21 0TRAVERSE CITY 308 FAIRBANKS ELK RAPIDS 9/17/2018 CCFH 34 9.72 0GRAYLING 115 MOHICAN

HOUGHTON LAKE

9/15/2018 MCF 34 0 74CADILLAC 127 W CASS CADILLAC 9/26/2018 CCFH 34 10.92 0GRAND RAPIDS 3856 ROWLAND AVE KENTWOOD 9/7/2018 CCFH 34 2.47 0GRAND RAPIDS 449 BURTON SW GRAND RAPIDS 9/18/2018 CCFH 16 4.64 0ALLEN RD 22140 SIBLEY BROWNSTOWN 10/2/2018 CCFH 29 16.82 0KINGSFORD N3332 PINE MOUNTAIN RD BREITUNG TWP 9/24/2018 CCFH 34 16.12 0CADILLAC 6815 S CROSBY CADILLAC 9/28/2018 CCFH 34 10.92 0GRAYLING 114 OWASSO LN LYON 10/1/2018 CCFH 0 10.57 0ALLEN RD 5555 MILLER RD DEARBORN 10/4/2018 CCFH 34 9.86 0LYNCH RD 11417 MORAN ST HAMTRAMCK 10/4/2018 CCFH 4 1.74 0GRAND RAPIDS 917 SILVERLEAF ST SE KENTWOOD 10/1/2018 CCFH 16 14.93 0GRAND RAPIDS 2127 DURANT DR SE GRAND RAPIDS 10/2/2018 CCFH 4 1.16 0GRAND RAPIDS 56 W BRIDGE ST ROCKFORD 10/2/2018 CCFH 16 3.48 0GRAND RAPIDS 5758 VINTON AV SUITE 2 NW

COMSTOCK PARK

10/5/2018 CCFH 34 9.86 0GRAND RAPIDS 2420 CHICAGO DR HUDSONVILLE 10/5/2018 CCFH 34 9.86 0GRAND RAPIDS 4960 QUIGGLE SE CASCADE 10/6/2018 CCFH 34 7.40 0MUSKEGON 9235 CATALPA NEWAYGO 10/3/2018 CCFH 34 31.72 0ALLEN RD 21295 DANBURY WOODHAVEN 9/28/2018 CCFH 34 9.86 0LYNCH RD 5150 BELMONT ST HAMTRAMCK 10/7/2018 CCFH 4 2.32 0GRAYLING 3897 TEE LAKE RD LEWISTON 9/26/2018 CCFH 34 2.64 0TRAVERSE CITY 231 E 8TH TRAVERSE CITY 9/28/2018 CCFH 34 4.86 0ALLEN RD 21279 DANBURY WOODHAVEN 9/14/2018 CCFH 34 19.72 0ALLEN RD 21600 PENNSYLVANIA RD TAYLOR 10/8/2018 CCFH 24 6.96 0ALLEN RD 14721 SCHAFER CT SOUTHGATE 10/8/2018 CCFH 16 4.64 0ALLEN RD 4515 W OUTER DR DETROIT 10/8/2018 CCFH 4 2.32 0ALLEN RD 23020 MURRAY ST DEARBORN 10/8/2018 CCFH 16 2.32 0ALLEN RD 13507 MORTENVIEW TAYLOR 10/9/2018 CCFH 16 4.64 0ALLEN RD 1721 JUNCTION DETROIT 10/10/2018 CCFH 4 1.16 0ALLEN RD 19540 PARKE LN GROSSE ILE 10/11/2018 CCFH 34 9.86 0ALLEN RD 12222 ASBURY PARK DETROIT 10/12/2018 CCFH 4 1.16 0ALLEN RD 4550 CALHOUN DEARBORN 10/23/2018 CCFH 34 5.29 0ALLEN RD 21412 KNUDSEN GROSSE ILE 10/13/2018 CCFH 34 9.86 0ALLEN RD 19467 STRATHMOOR ST DEARBORN 10/13/2018 CCFH 4 1.16 0LYNCH RD 4867 VAN DYKE DETROIT 10/9/2018 CCFH 4 0.58 0LYNCH RD 5808 EMERALD SPRINGS CIR HAMTRAMCK 10/9/2018 CCFH 16 6.96 0LYNCH RD 126 W ELIZABETH ST DETROIT 10/10/2018 CCFH 16 9.28 0ALLEN RD 20292 KENOSHA ST

HARPER WOODS

10/10/2018 CCFH 4 2.32 0ALLEN RD 313 E BALTIMORE ST DETROIT 10/11/2018 CCFH 16 4.64 0LYNCH RD 7 SHAWCROSS PL

HIGHLAND PARK

10/12/2018 CCFH 4 1.16 0ALLEN RD 1415 TRUMBULL ST STE 1 DETROIT 10/13/2018 CCFH 16 4.64 0ALLEN RD 4353 W BUENA VISTA ST APT 1 DETROIT 10/13/2018 CCFH 4 1.16 0ALLEN RD 3318 GREEN RD ANN ARBOR 10/11/2018 CCFH 25 10.88 0GRAND RAPIDS 143 MONTROSE NE GRAND RAPIDS 10/8/2018 CCFH 4 1.16 0GRAND RAPIDS 3512 56TH ST SW GRAND RAPIDS 10/8/2018 CCFH 34 9.86 0GRAND RAPIDS 1502 MILLBANK ST SE GRAND RAPIDS 10/9/2018 CCFH 16 2.32 0GRAND RAPIDS PINE ISLAND DR NE GRAND RAPIDS 10/11/2018 MCF 34 0 2514.8GRAND RAPIDS 352 SUMMIT AVE NE ROCKFORD 10/11/2018 CCFH 16 2.24 0GRAND RAPIDS 816 S ALEXANDER ST GREENVILLE 10/12/2018 CCFH 0 8.96 0LYNCH RD 5814 EMERALD SPRINGS HAMTRAMCK 10/12/2018 CCFH 16 23.20 0LYNCH RD 18233 FAIRFIELD ST DETROIT 6/28/2018 CCFH 4 2.90 0LYNCH RD 13490 ARLINGTON ST HAMTRAMCK 10/24/2018 MCF 4 0 1.16ALLEN RD 4696 WALWIT ST DEARBORN 10/16/2018 CCFH 34 0.49 0ALLEN RD 16651 LAUDER ST DETROIT 10/16/2018 MCF 4 0 0.86ALLEN RD 16611 LAUDER ST DETROIT 10/16/2018 CCFH 4 1.16 0ALLEN RD 4631 FIRESTONE ST DEARBORN 10/18/2018 CCFH 34 24.65 0ALLEN RD 1563 WILSON AVE LINCOLN PARK 10/18/2018 CCFH 1 0.23 0ALLEN RD 10024 METTETAL DETROIT 10/18/2018 CCFH 4 2.32 0TRAVERSE CITY LAKE AVE & CASS TRAVERSE CITY 9/29/2018 MCF 60 0 $180TRAVERSE CITY 210 N OAK ST TRAVERSE CITY 10/8/2018 CCFH 34 1.62 0ALLEN RD 20522 STRATHMOOR ST DETROIT 10/19/2018 CCFH 4 1.24 0



LYNCH RD 18559 WOODLANDHARPER WOODS

10/17/2018 CCFH 4 1.16 0LYNCH RD 19723 SYRACUSE DETROIT 10/18/2018 CCFH 4 4.64 0LYNCH RD 20120 CARRIE DETROIT 10/19/2018 CCFH 4 2.03 0GRAND RAPIDS 480 STEKETEE RD NE ADA 10/17/2018 CCFH 34 5.29 0GRAND RAPIDS 1637 RIDGEVIEW ST SE GRAND RAPIDS 10/17/2018 MCF 2 0 46.65GRAND RAPIDS 68 MONTROSE ST NE GRAND RAPIDS 10/18/2018 CCFH 4 0.19 0GRAND RAPIDS 1100 58TH ST WYOMING 10/19/2018 MCF 0 0 641.49MICHIGAN AVE 16 RIVERSIDE LN SALINE 10/22/2018 CCFH 69 21.32 0LYNCH RD 19202 SYRACUSE ST DETROIT 10/22/2018 CCFH 4 1.74 0MUSKEGON 2653 RENYOLDS ST

MUSKEGON HEIGHTS

10/15/2018 CCFH 16 2.29 0LYNCH RD 6155 WOODHALL DETROIT 10/12/2018 CCFH 4 0.58 0LYNCH RD 1181 MORRELL ST DETROIT 5/24/2018 CCFH 4 3.48 0LYNCH RD 18093 WILDEMERE ST DETROIT 10/22/2018 MCF 34 0 715.27ALLEN RD 20665 TELEGRAPH RD TRLR 135 BROWNSTOWN 10/12/2018 CCFH 20 5.80 0ALLEN RD 23251 CHERRY HILL ST DEARBORN 10/24/2018 CCFH 16 4.98 0GRAND RAPIDS 2708 DONCASTER AVE SW WYOMING 10/25/2018 CCFH 16 0.08 0ALLEN RD 19547 WESTPHALIA DETROIT 10/8/2018 CCFH 4 2.32 0ALLEN RD 4433 SOBRESKI DETROIT 10/8/2018 CCFH 4 3.48 0ALLEN RD 14632 ROBSON DETROIT 10/9/2018 CCFH 4 1.16 0ALLEN RD 14721 SCHAEFER SOUTHGATE 10/8/2018 CCFH 16 4.64 0LYNCH RD 88 KENDALL

HIGHLAND PARK

10/10/2018 CCFH 4 1.16 0GRAND RAPIDS 103 MARTINDALE ST SPARTA 10/8/2018 CCFH 16 4.98 0CADILLAC 415 N MICHIGAN AVE MANTON 10/25/2018 CCFH 34 9.86 0CADILLAC 610 N MICHIGAN AVE MANTON 10/25/2018 CCFH 34 45.77 0GRAND RAPIDS 597 FRESNO CIR SE GAINES 10/18/2018 CCFH 16 0.39 0ESCANABA 4280 CO RD 416 GLADSTONE 11/2/2018 CCFH 34 1.04 0LYNCH RD 2604 PURITAN DETROIT 11/5/2018 CCFH 4 2.32 0GRAND RAPIDS 7953 COTTONWOOD DR JENISON 11/5/2018 CCFH 16 0.39 0GRAND RAPIDS 2071 DUNNIGAN AVE NE GRAND RAPIDS 11/5/2018 CCFH 34 4.93 0GRAND RAPIDS 233 MAPLELAWN ST SE GRAND RAPIDS 11/5/2018 CCFH 16 1.55 0GRAND RAPIDS 6389 BURTON ST SE GRAND RAPIDS 11/4/2018 CCFH 34 5.29 0TRAVERSE CITY 443 ROGERS RD TRAVERSE CITY 11/3/2018 CCFH 34 1.76 0TRAVERSE CITY 5385 LONE BEECH DR GARFIELD 11/2/2018 CCFH 34 3.52 0GRAND RAPIDS 8197 COTTONWOOD DR JENISON 11/1/2018 CCFH 16 2.49 0BIG RAPIDS 327 S OAK ST BIG RAPIDS 10/31/2018 CCFH 34 9.86 0MICHIGAN AVE 8225 JACKSON RD ANN ARBOR 10/30/2018 CCFH 34 7.05 0MICHIGAN AVE 28245 KING RD HURON TWP. 10/30/2018 CCFH 4 2.32 0ALLEN RD 11409 PATTON ST DETROIT 10/30/2018 CCFH 4 3.21 0ALLEN RD 3178 APPLERIDGE DR PITTSFIELD 10/30/2018 CCFH 34 10.57 0GRAND RAPIDS 228 THURSTON ST SW WYOMING 10/30/2018 CCFH 16 1.55 0GRAND RAPIDS 4190 PRAIRIE ST SW GRANDVILLE 10/29/2018 CCFH 16 3.71 0ALLEN RD 19451 STRATHMOOR ST DETROIT 10/29/2018 CCFH 4 1.16 0ALLEN RD 4571 FIRESTONE ST DEARBORN 10/29/2018 CCFH 34 10.57 0GRAYLING 1116 HOUSEMAN AV NE GRAND RAPIDS 10/29/2018 CCFH 4 0.58 0GRAND RAPIDS 4417 STADIUM DR ALLENDALE 10/29/2018 CCFH 4 0.58 0MUSKEGON 5551 FRONT ST NEWAYGO 10/25/2018 CCFH 34 26.44 0ALLEN RD 4550 CALHOUN ST DEARBORN 10/23/2018 CCFH 34 5.29 0TAWAS 2045 E US 23 BALDWIN 10/23/2018 CCFH 34 5.29 0GRAND RAPIDS 1856 HERRICK AVE NE GRAND RAPIDS 10/8/2018 CCFH 4 1.16 0GRAND RAPIDS 912 SILVERLEAF ST SE KENTWOOD 10/1/2018 CCFH 16 13.91 0GRAND RAPIDS 312 DANTE DR ROSCOMMON 11/3/2018 CCFH 34 10.58 0GRAND RAPIDS 1022 CAUKFIELD AV SW GRAND RAPIDS 11/9/2018 CCFH 4 0.10 0GRAND RAPIDS 1413 GRAND RIVER DR NE ADA 11/9/2018 CCFH 34 5.29 0GRAND RAPIDS 6975 BYRON CENTER AV SW BRYON 11/9/2018 CCFH 34 21.15 0GRAND RAPIDS 35 FAWN CAVE CT NE ROCKFORD 10/17/2018 CCFH 16 4.64 0GRAND RAPIDS 50 STRAIGHT AVE NW GRAND RAPIDS 10/21/2018 CCFH 4 1.16 0GRAND RAPIDS 1247 IONIA AVE SW GRAND RAPIDS 10/25/2018 CCFH 4 0.29 0GRAND RAPIDS 2341 CASCADE POINT CASCADE 10/26/2018 CCFH 34 59.16 0GRAND RAPIDS 119 34TH ST SE WYOMING 10/31/2018 MCF 4 1.16 0GRAND RAPIDS 4208 JEFFERSON AV SE KENTWOOD 10/31/2018 CCFH 16 2.32 0GRAND RAPIDS 1689 WILSON AVE SW GRAND RAPIDS 11/7/2018 CCFH 34 29.58 0GRAND RAPIDS 2347 DUNNIGAN AVE NE GRAND RAPIDS 11/7/2018 CCFH 34 0.88 0GRAND RAPIDS 1629 MAYFLOWER DR SW WYOMING 11/12/2018 CCFH 0 0 488.59LYNCH RD 20075 BALTREE CT GROSSE POINTE

WOODS11/12/2018 CCFH 34 21.15 0

LYNCH RD 2354 ANDRUS ST HAMTRAMCK 11/12/2018 CCFH 2 2.32 0GRAND RAPIDS

8245 COTTONWOOD DR APT 1 SE

JENISON 11/1/2018 CCFH 16 2.32 0ALLEN RD 19233 LAHSER RD DETROIT 11/14/2018 CCFH 4 2.90 0ALLEN RD 318 STATE ST DETROIT 11/15/2018 CCFH 16 0.77 0LYNCH RD 3916 MCGRAW ST DETROIT 11/16/2018 CCFH 4 1.16 0GRAND RAPIDS 5500 CLYDE PARK AVE SW GRAND RAPIDS 11/14/2018 MCF 60 0 24.6LYNCH RD 2401 ANDRUS HAMTRAMCK 11/14/2018 CCFH 4 1.16 0GRAND RAPIDS 1064 CAULFIELD GRAND RAPIDS 11/7/2018 CCFH 4 0.58 0LYNCH RD 556 E BETHUNE ST DETROIT 6/11/2018 CCFH 4 2.32 0LYNCH RD 3454 BAGLEY DETROIT 11/23/2018 CCFH 16 18.56 0GRAYLING 8895 W HOUGHTON LAKE DR

HOUGHTON LAKE

11/23/2018 CCFH 51 15.86 0GRAYLING 2813 THIRD ST ST. HELEN 11/22/2018 CCFH 34 10.58 0LYNCH RD 11900 GREINER ST DETROIT 11/27/2018 CCFH 4 1.24 0GRAND RAPIDS 420 HIGHLAND ST SE GRAND RAPIDS 11/25/2018 CCFH 4 1.24 0GRAND RAPIDS 4256 13 MILE RD NE ROCKFORD 11/29/2018 CCFH 34 5.29 0GRAND RAPIDS 2822 QUINCY ST JAMESTOWN 11/29/2018 CCFH 34 10.57 0



ALLEN RD 7481 N VERNONDEARBORN HEIGHTS

11/28/2018 CCFH 16 9.28 0LYNCH RD 20489 WOODSIDE ST

HARPER WOODS

11/11/2018 CCFH 34 9.89 0MICHIGAN AVE 315 S MAIN ANN ARBOR 10/27/2018 CCFH 16 4.64 0GRAND RAPIDS 1004 NORWICH SW GRAND RAPIDS 12/3/2018 MCF 2 0 32.6LYNCH RD 20433 STOTTER ST DETROIT 12/3/2018 CCFH 4 0.04 0GRAND RAPIDS 5226 VILLAGE DR SW WYOMING 12/3/2018 CCFH 34 0.18 0GRAND RAPIDS 2425 PARKVIEW ST SW GRAND RAPIDS 12/4/2018 CCFH 34 5.29 0LYNCH RD 407 TOURAINE RD

GROSSE POINTE FARMS

12/5/2018 CCFH 34 0.35 0MICHIGAN AVE 215 N MAPLE RD ANN ARBOR 12/6/2018 CCFH 16 14.93 0LYNCH RD 10974 HAVERHILL ST DETROIT 12/7/2018 CCFH 4 1.24 0ALLEN RD 4110 GRAY ST DETROIT 12/10/2018 CCFH 4 1.16 0BIG RAPIDS 15065 2ND ST HOWARD CITY 9/7/2018 CCFH 34 4.93 0GRAND RAPIDS OTTAWA / NEW BERRY GRAND RAPIDS 11/9/2018 MCF 10 0 48.4LYNCH RD 190 MIDLAND

HIGHLAND PARK

12/12/2018 CCFH 16 7.46 0GRAND RAPIDS 1514 SCOTT CREEK DR NE BELMONT 12/6/2018 CCFH 34 4.93 0GRAND RAPIDS 6170 VALLEY LANE DR SE GRAND RAPIDS 12/6/2018 CCFH 34 9.86 0GRAND RAPIDS 11930 LINCOLN LAKE RD NE GREENVILLE 12/11/2018 CCFH 34 7.40 0GRAND RAPIDS 930 FRANKLIN ST SE GRAND RAPIDS 12/19/2018 CCFH 4 0.29 0BIG RAPIDS 1124 S STATE ST BIG RAPIDS 12/20/2018 MCF 34 261.40 0GRAND RAPIDS 506 HALL ST SW GRAND RAPIDS 12/27/2018 MCF 4 0 469.33LYNCH RD 4757 CHENE ST DETROIT 12/27/2018 CCFH 4 1.74 0GRAND RAPIDS 1906 17 MILE RD KENT CITY 12/29/2018 MCF 34 136.29 0GRAND RAPIDS 4317 KALAMAZOO GRAND RAPIDS 12/18/2018 CCFH 16 4.64 0GRAND RAPIDS 6443 CROSSBOW SW BYRON CENTER 12/31/2018 CCFH 16 2.32 0



YEAR # of DAMAGES AVG. COST SUM2016 1498 1,502.00 $2,182,202.502017 1344 1,514.00 $2,102,840.002018 1609 1,441.00 $2,167,140.752019* 911 1,543.00 $1,196,893.60*Jan‐Aug





Page:

U-20642StaffCLC-2.2aA. D. Dewey1 of 1

Question: With reference to the testimony of Company witness Andrew Dewey, page8, lines 1-8, regarding Turn Key service:

2. Quantify the increase cost related to the use of contractor turn keyservices. Specifically,

a. What was the estimated capital expenditure level to complete thecontracted work with DTE resources?

Answer: In 2019, we contracted out 1,692 turn key services. This is less than theprojection of 3,000 in Witness Dewey’s testimony due to additional internalresources from other groups being allocated in the last quarter of 2019. DTEdid not have sufficient internal labor resources available to complete the1,692 services. To complete this work with internal resources, DTE wouldhave had to bring on two additional crews at a cost of $2.1 million (fullyloaded including supervision, benefits and overheads) and purchaseadditional equipment for $2.5 million as no equipment would have beenavailable for these employees to utilize to complete the work. The totalcapital expenditure would have been estimated at $4.8 million in 2019 tocomplete the contracted work with DTE resources. This would have beenmore costly than contracting these services. It was also not feasible to hirethe experienced resources necessary to complete the work.

Attachments: None





Page:

U-20642StaffCLC-2.2bA. D. Dewey1 of 1

Question: With reference to the testimony of Company witness Andrew Dewey, page8, lines 1-8, regarding Turn Key service:

2. Quantify the increase cost related to the use of contractor turn keyservices. Specifically,

b. Was the contracted cost in lieu of those expenditures?

Answer: Yes, the $3.9 million contracted cost was in lieu of the $4.8 million it wouldhave cost to bring on additional internal resources to do the 1,692 turn keyservices. We had anticipated $9 million in contractor cost in 2019 tocomplete approximately 3,000 turn key services. Additional DTE resourcesfrom other groups were allocated in the last quarter of 2019 to reduce thenumber of contractor turn key services to 1,692. We were able to createfurther savings by optimizing the 1,692 services to have the contractors dolower cost units (more retest and tie overs versus service renewals)reducing the turn key cost per unit to $2,300 per unit versus the anticipated$3,000 per unit, for a total contractor turn key cost of $3.9 million in 2019.

Attachments: None



Monthly MPSC Meter Assembly

Check and Meter Move-Out

Reporting

January, 2019



Trending Meter Assembly Check backlog and total

completions

21. Completions are of the overdue backlog, newly expired and MACs not due yet

138,813

Jan 2016

117,800

Jul 2017Jul 2016 Jan 2017

106,445

Jan 2018 Jul 2018 Jan 2019

161,811

153,625

143,341

129,305

-34%

MAC Backlog

MAC

Completions1

19,86622,222 21,206

17,13919,786

21,58519,343

20,620

24,060 23,37720,705

18,626

2017

Q2

2016

Q1

2016

Q2

2016

Q3

2016

Q4

2017

Q1

2017

Q4

2017

Q3

2018

Q1

2018

Q2

2018

Q3

2018

Q4

82,449 83,351 88,786



Monthly plan for all inside meters moved outside

3Note: True-up of inside meters moved outside may occur during or at the end of the year

1,034 935

1,4721,692 1,805 1,698

1,450

2,011 1,937

2,464

2,055

1,399

2,969 3,017

1,904

AprJan Feb Jun OctMar May AugJul Sep Nov Dec

Monthly Actuals

Monthly Target

Total Monthly Completions/Target

1,0341,969

3,4415,133

6,9388,636

10,08612,097

14,034

16,49818,553

19,952

0

5,000

10,000

15,000

20,000

Feb DecJan Mar JunApr AugMay Jul Sep Oct Nov

Total Cumulative Completions

Cumulative Actuals



MMO & MRP targets and actual completions- MMO and MRP moved a total of 13,911 inside meters outside

in 2018

4Note: True-up of inside meters moved outside may occur during or at the end of the year.

Note: Total meter counts and allocation of inside meters between the MMO & MRP programs will be

finalized in the March 31st report.

717

541697

807

1,118

887765

1,2891,214

1,510

1,913 1,980

1,134

DecAugAprJan JunFeb OctMar JulMay Sep Nov

1,610

1,148

Monthly Actuals

Monthly Target

MMO Monthly Completions/Target

7171,258

1,9552,762

3,8804,767

5,532

6,8218,035

9,545

11,15512,303

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

Mar AugJan JulFeb Apr May Jun Sep Oct Nov Dec

MMO Cumulative Completions

Cumulative Actuals

103113

95 88105

177

230

200210 206

81

195

224

74

Mar JulJunJan Feb AugApr May NovSep Oct Dec

0

MRP Monthly Completions/Target

MRP Cumulative Completions

0103

216311

399504

681

911

1,111

1,321

1,5271,608

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

Jan AugFeb Apr MayMar NovJun Jul Sep Oct Dec



Routine1 forecast & MAC-MMO targets and actual

completions

51. Due to being customer generated work, routine targets will be re-forecasted on a monthly basis

as work is completed

Note: True-up of inside meters moved outside may occur during or at the end of the year

317

250

491530

316296

224248 231

259

179 168

509

413

226

Jun DecJan MayFeb JulMar Apr Aug Sep Oct Nov

Routine Monthly Completions/Forecast

317567

1,5881,904

2,2002,424

2,6722,903

3,1623,341

3,509

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

MarFeb JunJan Apr May Jul Aug Sep Oct Nov Dec

1,058

Routine Cumulative Completions

41

171

260283

410

284244

292

485

60

2

352

400

470

Jan Jun NovAprFeb Mar May Jul Aug Sep Oct Dec

MAC-MMO Monthly Completions/Target

MAC-MMO Cumulative Completions

41212

472

755

1,165

1,4491,693

2,470 2,530 2,532

0

500

1,000

1,500

2,000

2,500

3,000

Mar MayJan AugFeb JunApr Jul Sep Oct Nov Dec

1,985

Monthly Actuals

Monthly Target

Cumulative Actuals



Monthly MPSC Meter Assembly Check and Meter Move-Out Reporting

January, 2020



Trending Meter Assembly Check backlog and total completions

1. Completions are of the overdue backlog, newly expired and MACs not due yet 2

129,305

Jan 2017

117,800

106,445

Jul 2019Jul 2017 Jan 2020Jul 2018

138,813

82,328

Jan 2019

92,146

Jan 2018

143,341

MAC Backlog

MAC Completions1 19,78621,585

19,343 20,62024,060 23,377

20,70518,626

22,229

26,790

16,80714,256

2018

Q4

2017

Q2

2019

Q3

2017

Q1

2018

Q1

2017

Q4

2017

Q3

2018Q2

2018

Q3

2019

Q1

2019

Q2

2019

Q4

83,351 88,786 80,082




Note: True-up of inside meters moved outside may occur during or at the end of the year1. Monthly and cumulative targets were reported using an internal stretch target for MRP January through July. Beginning in August and

throughout the rest of the year, targets will be shown as approved in U-18999.3

1,503 1,385

2,2152,394 2,351

2,0312,305

2,906 2,782

3,261

2,231

1,537

993

1,390 1,519

2,699 2,712 2,7623,087

3,2482,973

2,691

1,996

620

MayJan Feb Mar OctJunApr AugJul Sep Nov Dec

Total Monthly Completions/Target1

26,901

26,690

0

5,000

10,000

15,000

20,000

25,000

30,000

OctJan AugFeb AprMar May JulJun Sep Nov Dec

Total Cumulative Completions1

Monthly Actuals Monthly Target Cumulative Actuals Monthly Target



MMO & MRP targets and actual completions

4

653 691

985 965836

977

1,866

1,360

985

334

586736

1,191 1,224 1,162

1,508

1,701

1,4851,573

151

JulMayMarJan DecAug OctFeb Apr Jun Sep Nov

1,202 1,179

1,477

1,139


13,176

12,790

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

MarJan AugJunFeb JulApr May Sep Oct Nov Dec


37

195

248

121

188

264

197

271

150

5850

173

78 87110

210

147

84

156170

85

50

Jan Feb Mar AugApr OctMay Jun Jul Sep Nov Dec

0 0

MRP Monthly Completions/Target1

MRP Cumulative Completions1

1,729

1,400

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

FebJan MayMar Apr Jun Jul NovAug Sep Oct Dec

Note: True-up of inside meters moved outside may occur during or at the end of the year.Note: Total meter counts and allocation of inside meters between the MMO & MRP programs will be finalized in the March 31st report.1. Monthly and cumulative targets were reported using an internal stretch target for MRP January through July. Beginning in August and throughout the rest of the year, targets will be shown as approved in U-18999.

Cumulative Actuals Cumulative TargetMonthly TargetMonthly Actuals



Routine1 forecast & MAC-MMO targets and actual completions

Note: True-up of inside meters moved outside may occur during or at the end of the year1. Due to being customer generated work, routine targets will be re-forecasted on a monthly basis as work is completed 5

279324

514547

460

345

280

341

269299

124

193

334356

430451

408 420462

493

362

308257

219

JulJan MayMarFeb Apr Jun Aug Sep Oct Nov Dec


3,975

4,500

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

Jan MayFeb JulMar JunApr Aug Sep Oct Nov Dec


571

370

679 687

807

588635

1,122

839 825

597

301275 275 275

970 970 970 970 970 970

640

515

200

JunJan Feb OctJulMar Apr May Aug Sep Nov Dec



8,021

8,000

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

MayJan AprFeb Jul OctJunMar Aug Sep Nov Dec

Monthly Actuals Monthly Target Cumulative Actuals Cumulative Get Home Cumulative Target



Monthly MPSC Meter Assembly Check and Meter Move-Out Reporting

February 2020



Trending Meter Assembly Check backlog and total completions

1. Completions are of the overdue backlog, newly expired and MACs not due yet 2

129,305

Jan 2017 Jul 2017 Jul 2018Jan 2018 Jan 2019

82,272

Jul 2019

78,106

Jan 2020

143,341138,813

117,800

106,445

92,146

Mar 2020

MAC Backlog

MAC Completions1 19,78621,585

19,343 20,62024,060 23,377

20,70518,626

22,229

26,790

16,80714,256

17,535

2018

Q4

2017

Q3

2017

Q1

2017

Q4

2017

Q2

2018

Q1

2018Q2

2018

Q3

2019

Q1

2019

Q2

2019

Q3

2019

Q4

2020

Q1

83,351 88,786 80,082




Note: True-up of inside meters moved outside may occur during or at the end of the year1. Monthly and cumulative targets were reported using an internal stretch target for MRP January through July. Beginning in August and

throughout the rest of the year, targets will be shown as approved in U-18999.3

1,7852,019

1,4931,742

1,934

3,153

2,5502,734

3,363

2,667 2,568 2,720

1,641

725

AugApr MayMarJan Feb JulJun NovSep Oct Dec

Total Monthly Completions/Target1

3,804 5,1698,322

10,87213,606

16,96919,636

22,20424,924

26,565 27,290

0

5,000

10,000

15,000

20,000

25,000

30,000

MayMarFebJan Apr SepJun AugJul DecOct Nov

3,235

Total Cumulative Completions1

Monthly Actuals Monthly Target Monthly TargetCumulative Actuals



MMO & MRP targets and actual completions

4

932 966

642763

933

1,241

1,053

1,328

1,646

1,2661,144

1,593

857

324

AprFebJan Mar May AugJun Jul OctSep Nov Dec


1,898 2,3383,579

4,632

5,960

7,6068,872

11,60912,466 12,790

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

MayJan Mar JunFeb Apr SepAugJul

10,016

Oct Nov Dec

1,405


45 51

102

226249

373

252 250

146

104 97128

73

Jan AugFeb JunMayMar DecApr Jul Sep Oct Nov

0

MRP Monthly Completions/Target1

MRP Cumulative Completions1

96

328

577

950

1,202

1,4521,598

1,7021,799

1,927 2,000 2,000

0

500

1,000

1,500

2,000

Jan Feb Jun OctMar Apr May Jul Aug Sep Nov Dec

Note: True-up of inside meters moved outside may occur during or at the end of the year.Note: Total meter counts and allocation of inside meters between the MMO & MRP programs will be finalized in the March 31st report.1. Monthly and cumulative targets were reported using an internal stretch target for MRP January through July. Beginning in August and throughout the rest of the year, targets will be shown as approved in U-18999.

Cumulative TargetCumulative ActualsMonthly Actuals Monthly Target



Routine1 forecast & MAC-MMO targets and actual completions

Note: True-up of inside meters moved outside may occur during or at the end of the year1. Due to being customer generated work, routine targets will be re-forecasted on a monthly basis as work is completed 5

234

362

425

353 344

554

390

336

587

441

365

295

236

174

MarJan Feb AugApr JulJunMay Sep Oct Nov Dec


596

7781,122

1,6762,066

2,402

2,989

3,4303,795

4,0904,326

4,500

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

JulJan JunMarFeb MayApr Aug Sep Oct Nov Dec


574640

324400 408

985

855 820

984

856

962

704

475

227

May DecAugApr NovJan Feb Mar Jun Jul Sep Oct



1,214 1,132

2,117

2,972

3,792

4,776

5,632

6,5947,298

7,773 8,000

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

FebJan Mar Apr AugMay Jun Jul Sep Oct Nov Dec

724

Monthly Actuals Monthly Target Cumulative TargetCumulative Actuals





Page:

U-20642StaffCLC-17.1H. J. Decker1 of 1

Question: With reference to the testimony of Company witness Henry Decker, pages64-65, regarding the Customer Attachment Program (CAP) monthlysurcharge, please complete the following table for monthly surchargeamounts related to the customer contribution amount and the length of thesurcharge recovery period.

1 Year 5 Year 10 Year 15 Year 20 Year

$1,000 $93.96 $22.40 $13.74 $11.04 $9.83

$2,000 $177.59 $42.34 $25.97 $20.87 $18.57

$5,000 $438.01 $104.44 $64.04 $51.58 $45.81

$10,000 $875.59 $208.78 $128.02 $102.91 $91.58

Answer: As requested, please see above table for associated surcharge amounts.

Attachments: none



Michigan Public Service Commission Case No.: U-20642DTE Gas Company Exhibit: S-16.11Staff Comparison of Monthly Finance Charge Periods to Annual Propane Savings Witness: C. Creisher

Page: 1 of 1

(a) (b) (c) (d) (e)

LineNo. Description 1,000$ 2,000$ 5,000$ 10,000$

1 10-Year Surcharge - Monthly Payment 13.74$ 25.97$ 64.04$ 128.02$ 2 10-Year Surcharge - Total Payments 1,649$ 3,116$ 7,685$ 15,362$

Cost Savings Over 20-Year Period3 750 Gallons of Propane Annually 14,356$ 12,889$ 8,320$ 643$ 4 1,000 Gallons of Propane Annually 20,583$ 19,116$ 14,547$ 6,870$ 5 1,250 Gallons of Propane Annually 26,810$ 25,343$ 20,774$ 13,097$

6 20-Year Surcharge - Monthly Payment 9.83$ 18.57$ 45.81$ 91.58$ 7 20-Year Surcharge - Total Payments 2,359$ 4,457$ 10,994$ 21,979$

Cost Savings Over 20-Year Period8 750 Gallons of Propane Annually 13,646$ 11,548$ 5,011$ (5,974)$ 9 1,000 Gallons of Propane Annually 19,873$ 17,775$ 11,238$ 253$ 10 1,250 Gallons of Propane Annually 26,100$ 24,002$ 17,465$ 6,480$

Natural Gas Conversion Savings Compared to Propane 1/11 750 Gallons of Propane Annually 800.25$ 12 1,000 Gallons of Propane Annually 1,111.60$ 13 1,250 Gallons of Propane Annually 1,422.96$

1/ Calculated with a propane price of $1.81 per gallon based on MPSC SHOPP reportusing the "Calculate Your Potential Savings" tool accessed from the Company's website.

Customer Contribution Amount

NOTICE: This report is required by 49 CFR Part 191. Failure to report can result in a civil penalty not to exceed 100,000 for each violation for each day that such violation persists except that the maximum civil penalty shall not exceed $1,000,000 as provided in 49 USC 60122.

OMB NO: 2137-0629EXPIRATION DATE: 10/31/2021

U.S Department of Transportation Pipeline and Hazardous Materials Safety Administration

Initial DateSubmitted:

03/13/2019

Form Type: INITIAL

Date Submitted:

ANNUAL REPORT FORCALENDAR YEAR 2018

GAS DISTRIBUTION SYSTEMA federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure to comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays a current valid OMB Control Number. The OMB Control Number for this information collection is 2137-0629. Public reporting for this collection of information is estimated to be approximately 16 hours per response, including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. All responses to this collection of information are mandatory. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Information Collection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200 New Jersey Avenue, SE, Washington, D.C. 20590.

Important: Please read the separate instructions for completing this form before you begin. They clarify the information requested and provide specific examples. If you do not have a copy of the instructions, you can obtain one from the PHMSA Pipeline Safety Community Web Page at http://www.phmsa.dot.gov/pipeline/library/forms.

PART A - OPERATOR INFORMATION (DOT use only) 20190655-38094

1. Name of Operator DTE GAS COMPANY

2. LOCATION OF OFFICE (WHERE ADDITIONAL INFORMATION MAY BE OBTAINED)

2a. Street Address 17150 Allen Road

2b. City and County Melvindale

2c. State MI

2d. Zip Code 48122

3. OPERATOR'S 5 DIGIT IDENTIFICATION NUMBER 12408

4. HEADQUARTERS NAME & ADDRESS

4a. Street Address ONE ENERGY PLAZA

4b. City and County DETROIT

4c. State MI

4d. Zip Code 48226

5. STATE IN WHICH SYSTEM OPERATES MI

6. THIS REPORT PERTAINS TO THE FOLLOWING COMMODITY GROUP (Select Commodity Group based on the predominant gas carried and complete the report for that Commodity Group. File a separate report for each Commodity Group included in this OPID.)

Natural Gas

7. THIS REPORT PERTAINS TO THE FOLLOWING TYPE OF OPERATOR (Select Type of Operator based on the structure of the company included in this OPID for which this report is being submitted.):

Investor Owned

PART B - SYSTEM DESCRIPTION

1.GENERAL

STEEL

PLASTICCAST/

WROUGHTIRON

DUCTILEIRON COPPER OTHER

RECONDITIONED

CAST IRON

SYSTEMTOTAL

UNPROTECTEDCATHODICALLY

PROTECTED

BARE COATED BARE COATED

MILES OF MAIN 154.681 1203.265 60.496 5133.799 11536.905 1987.138 0 0 5.655 0.248 20082.187

NO. OF SERVICES 16678 99248 299 65755 906192 11 0 100996 20563 0 1209742



http://www.phmsa.dot.gov/pipeline/library/forms


2.MILES OF MAINS IN SYSTEM AT END OF YEAR

MATERIAL UNKNOWN 2" OR LESS OVER 2"THRU 4"

OVER 4"THRU 8"

OVER 8"THRU 12" OVER 12" SYSTEM

TOTALS

STEEL 0 1740.350 2603.951 1634.111 305.616 268.213 6552.241

DUCTILE IRON 0 0 0 0 0 0 0

COPPER 0 0 0 0 0 0 0

CAST/WROUGHT IRON

0 .252 1388.617 376.314 166.277 55.678 1987.138

PLASTIC PVC 0 0 0 0 0 0 0

PLASTIC PE .020 7045.192 3703.609 783.747 4.337 0 11536.905

PLASTIC ABS 0 0 0 0 0 0 0

PLASTIC OTHER 0 0 0 0 0 0 0

OTHER 0 2.086 2.448 1.051 .069 .001 5.655

RECONDITIONED CAST IRON

0 0 0 .248 0 0 .248

TOTAL .02 8787.88 7698.625 2795.471 476.299 323.892 20082.187

Describe Other Material: Is Unknown Material

3.NUMBER OF SERVICES IN SYSTEM AT END OF YEAR AVERAGE SERVICE LENGTH: 90.41


OVER 2"THRU 4"


TOTALS

STEEL 198 131174 47837 2342 402 27 181980


COPPER 146 98657 2193 0 0 0 100996

CAST/WROUGHT IRON

0 0 2 7 2 0 11


PLASTIC PE 6481 681127 206782 2610 155 0 897155


PLASTIC OTHER 7 8122 908 0 0 0 9037

OTHER 14725 5058 685 93 2 0 20563


0 0 0 0 0 0 0

TOTAL 21557 924138 258407 5052 561 27 1209742

Describe Other Material: Other plastic is CAB Other is unknown

4.MILES OF MAIN AND NUMBER OF SERVICES BY DECADE OF INSTALLATION

UNKNOWN PRE-1940

1940-1949 1950-1959 1960-1969 1970-1979 1980-1989 1990-1999 2000-2009 2010-2019 TOTAL



MILES OF MAIN

370.0181616.58

4745.451 1995.676 3310.370 2176.455 1456.818 4401.293 2031.651 1977.871 20082.187

NUMBER OF

SERVICES21915 16096 38442 138625 126798 174557 119410 202007 152091 219801 1209742

PART C - TOTAL LEAKS AND HAZARDOUS LEAKS ELIMINATED/REPAIRED DURING THE YEAR

CAUSE OF LEAK MAINS SERVICES

TOTAL HAZARDOUS TOTAL HAZARDOUS

CORROSION FAILURE 2071 142 1578 498

NATURAL FORCE DAMAGE 215 44 235 112

EXCAVATION DAMAGE 160 160 1131 1131

OTHER OUTSIDE FORCE DAMAGE 4 0 40 29

PIPE, WELD OR JOINT FAILURE 52 4 60 13

EQUIPMENT FAILURE 104 5 117 41

INCORRECT OPERATIONS 9 0 15 7

OTHER CAUSE 1148 100 1285 406

NUMBER OF KNOWN SYSTEM LEAKS AT END OF YEAR SCHEDULED FOR REPAIR : 586

PART D - EXCAVATION DAMAGE PART E - EXCESS FLOW VALUE (EFV) AND SERVICE VALVE DATA

1. TOTAL NUMBER OF EXCAVATION DAMAGES BY APPARENT ROOT CAUSE: 1608

Total Number Of Services with EFV Installed During Year: 16026

Estimated Number Of Services with EFV In the System At End Of Year:141854

* Total Number of Manual Service Line Shut-off Valves Installed During Year: 80

* Estimated Number of Services with Manual Service Line Shut-off Valves Installed in the System at End of Year: 179

*These questions only pertain to reporting years 2017 & beyond.

a. One-Call Notification Practices Not Sufficient: 481

b. Locating Practices Not Sufficient: 234

c. Excavation Practices Not Sufficient: 737

d. Other: 156

2. NUMBER OF EXCAVATION TICKETS : 296631

PART F - LEAKS ON FEDERAL LAND PART G-PERCENT OF UNACCOUNTED FOR GAS

TOTAL NUMBER OF LEAKS ON FEDERAL LAND REPAIRED OR SCHEDULED TO REPAIR: 0

UNACCOUNTED FOR GAS AS A PERCENT OF TOTAL CONSUMPTION FOR THE 12 MONTHS ENDING JUNE 30 OF THE REPORTING YEAR.

[(PURCHASED GAS + PRODUCED GAS) MINUS (CUSTOMER USE + COMPANY USE + APPROPRIATE ADJUSTMENTS)] DIVIDED BY (CUSTOMER USE + COMPANY USE + APPROPRIATE ADJUSTMENTS) TIMES 100 EQUALS PERCENT UNACCOUNTED FOR.

FOR YEAR ENDING 6/30: 0.82%

PART H - ADDITIONAL INFORMATION



PART I - PREPARER

Vincent Rodriguez,Staff Engineer(Preparer's Name and Title)

(313)389-7403(Area Code and Telephone Number)

[email protected](Preparer's email address) (Area Code and Facsimile Number)



NOTICE: This report is required by 49 CFR Part 191. Failure to report can result in a civil penalty not to exceed 100,000 for each violation for each day that such violation persists except that the maximum civil penalty shall not exceed $1,000,000 as provided in 49 USC 60122.

OMB NO: 2137-0629EXPIRATION DATE: 10/31/2021

U.S Department of Transportation Pipeline and Hazardous Materials Safety Administration

Initial DateSubmitted:

03/13/2020

Form Type: INITIAL

Date Submitted:

ANNUAL REPORT FORCALENDAR YEAR 2019

GAS DISTRIBUTION SYSTEMA federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure to comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays a current valid OMB Control Number. The OMB Control Number for this information collection is 2137-0629. Public reporting for this collection of information is estimated to be approximately 16 hours per response, including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. All responses to this collection of information are mandatory. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Information Collection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200 New Jersey Avenue, SE, Washington, D.C. 20590.

Important: Please read the separate instructions for completing this form before you begin. They clarify the information requested and provide specific examples. If you do not have a copy of the instructions, you can obtain one from the PHMSA Pipeline Safety Community Web Page at http://www.phmsa.dot.gov/pipeline/library/forms.

PART A - OPERATOR INFORMATION (DOT use only) 20201237-40535

1. Name of Operator DTE GAS COMPANY

2. LOCATION OF OFFICE (WHERE ADDITIONAL INFORMATION MAY BE OBTAINED)

2a. Street Address 17150 ALLEN ROAD

2b. City and County MELVINDALE

2c. State MI

2d. Zip Code 48122

3. OPERATOR'S 5 DIGIT IDENTIFICATION NUMBER 12408

4. HEADQUARTERS NAME & ADDRESS

4a. Street Address ONE ENERGY PLAZA

4b. City and County DETROIT

4c. State MI

4d. Zip Code 48226

5. STATE IN WHICH SYSTEM OPERATES MI

6. THIS REPORT PERTAINS TO THE FOLLOWING COMMODITY GROUP (Select Commodity Group based on the predominant gas carried and complete the report for that Commodity Group. File a separate report for each Commodity Group included in this OPID.)

Natural Gas

7. THIS REPORT PERTAINS TO THE FOLLOWING TYPE OF OPERATOR (Select Type of Operator based on the structure of the company included in this OPID for which this report is being submitted.):

Investor Owned

PART B - SYSTEM DESCRIPTION

1.GENERAL

STEEL

PLASTICCAST/

WROUGHTIRON

DUCTILEIRON COPPER OTHER

RECONDITIONED

CAST IRON

SYSTEMTOTAL

UNPROTECTEDCATHODICALLY

PROTECTED

BARE COATED BARE COATED

MILES OF MAIN 140.601 1173.476 60.313 5132.743 11700.417 1904.781 0 0 5.419 0.245 20117.995

NO. OF SERVICES 14168 92977 283 58301 936288 11 0 92977 19939 0 1214944







2.MILES OF MAINS IN SYSTEM AT END OF YEAR


OVER 4"THRU 8"


TOTALS

STEEL 0 1725.665 2583.802 1624.428 304.399 268.838 6507.132


COPPER 0 0 0 0 0 0 0

CAST/WROUGHT IRON

0 0.252 1322.521 364.864 163.405 53.739 1904.781

PLASTIC PVC 0.020 7121.840 3767.052 807.037 4.468 0 11700.417

PLASTIC PE 0 0 0 0 0 0 0


PLASTIC OTHER 0 0 0 0 0 0 0

OTHER 0 1.929 2.310 1.042 0.069 .069 5.419


0 0 0 .245 0 0 0.245

TOTAL 0.02 8849.686 7675.685 2797.616 472.341 322.646 20117.994

Describe Other Material: Is Unknown Material

3.NUMBER OF SERVICES IN SYSTEM AT END OF YEAR AVERAGE SERVICE LENGTH: 90.97


OVER 2"THRU 4"


TOTALS

STEEL 171 119859 43047 2290 390 26 165783


COPPER 144 90819 2014 0 0 0 92977

CAST/WROUGHT IRON

0 0 2 7 2 0 11


PLASTIC PE 6479 685416 234057 2656 156 0 928764


PLASTIC OTHER 5 6823 696 0 0 0 7524

OTHER 14324 4896 626 91 2 0 19939


0 0 0 0 0 0 0

TOTAL 21123 907813 280442 5044 550 26 1214998

Describe Other Material: Other plastic is CAB Other is unknown

4.MILES OF MAIN AND NUMBER OF SERVICES BY DECADE OF INSTALLATION

UNKNOWN PRE-1940

1940-1949 1950-1959 1960-1969 1970-1979 1980-1989 1990-1999 2000-2009 2010-2019 TOTAL



MILES OF MAIN

112.2842264.59

40 1973.044 3302.092 2174.118 1453.719 4396.000 2018.663 2423.169 20117.683

NUMBER OF

SERVICES21322 47553 0 124982 121231 171909 116843 199224 150147 261787 1214998

PART C - TOTAL LEAKS AND HAZARDOUS LEAKS ELIMINATED/REPAIRED DURING THE YEAR

CAUSE OF LEAK MAINS SERVICES

TOTAL HAZARDOUS TOTAL HAZARDOUS

CORROSION FAILURE 1825 146 1208 387

NATURAL FORCE DAMAGE 188 41 216 105

EXCAVATION DAMAGE 152 152 1161 1161

OTHER OUTSIDE FORCE DAMAGE 4 2 38 29

PIPE, WELD OR JOINT FAILURE 37 3 27 12

EQUIPMENT FAILURE 87 9 119 45

INCORRECT OPERATIONS 10 1 27 12

OTHER CAUSE 1082 105 1310 367

NUMBER OF KNOWN SYSTEM LEAKS AT END OF YEAR SCHEDULED FOR REPAIR : 546

PART D - EXCAVATION DAMAGE PART E - EXCESS FLOW VALUE (EFV) AND SERVICE VALVE DATA

1. TOTAL NUMBER OF EXCAVATION DAMAGES BY APPARENT ROOT CAUSE: 1344

Total Number Of Services with EFV Installed During Year: 18754

Estimated Number Of Services with EFV In the System At End Of Year:162092

* Total Number of Manual Service Line Shut-off Valves Installed During Year: 329

* Estimated Number of Services with Manual Service Line Shut-off Valves Installed in the System at End of Year: 1124

*These questions only pertain to reporting years 2017 & beyond.

a. One-Call Notification Practices Not Sufficient: 501

b. Locating Practices Not Sufficient: 204

c. Excavation Practices Not Sufficient: 311

d. Other: 328

2. NUMBER OF EXCAVATION TICKETS : 336297

PART F - LEAKS ON FEDERAL LAND PART G-PERCENT OF UNACCOUNTED FOR GAS

TOTAL NUMBER OF LEAKS ON FEDERAL LAND REPAIRED OR SCHEDULED TO REPAIR: 0

UNACCOUNTED FOR GAS AS A PERCENT OF TOTAL CONSUMPTION FOR THE 12 MONTHS ENDING JUNE 30 OF THE REPORTING YEAR.

[(PURCHASED GAS + PRODUCED GAS) MINUS (CUSTOMER USE + COMPANY USE + APPROPRIATE ADJUSTMENTS)] DIVIDED BY (CUSTOMER USE + COMPANY USE + APPROPRIATE ADJUSTMENTS) TIMES 100 EQUALS PERCENT UNACCOUNTED FOR.

FOR YEAR ENDING 6/30: .73%

PART H - ADDITIONAL INFORMATION



PART I - PREPARER

Michael Nee,Staff Engineer(Preparer's Name and Title)

(412) 432-8015(Area Code and Telephone Number)

[email protected](Preparer's email address) (Area Code and Facsimile Number)



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Price

per

Gall

on (U

SD)

Residential Heating Oil and Propane Price Comparison2019/20 vs. 2018/19

Heating Oil 2019/20Heating Oil 2018/19Propane 2019/20Propane 2018/19

1–Oct

14–Oct

28–Oct

11–Nov

25–Nov

9–Dec

23–Dec

6–Jan

20–Jan

3–Feb

17–Feb 3–M

ar17–

Mar$1.50

$2.00

$2.50

$3.00

$3.50



Category Heating Oil 2019/20 Heating Oil 2018/19 Propane 2019/20 Propane 2018/191–Oct 2.94 2.017–Oct 2.65 2.99 1.60 2.0114–Oct 2.63 2.99 1.61 2.0221–Oct 2.61 2.99 1.62 2.0128–Oct 2.61 2.98 1.62 2.004–Nov 2.60 2.96 1.63 2.0111–Nov 2.63 2.92 1.67 2.0018–Nov 2.63 2.88 1.71 2.0025–Nov 2.64 2.77 1.76 2.012–Dec 2.66 2.64 1.81 2.019–Dec 2.66 2.56 1.80 2.0216–Dec 2.66 2.50 1.81 2.0123–Dec 2.62 2.40 1.81 2.0130–Dec 2.60 2.30 1.80 2.016–Jan 2.63 2.27 1.78 2.0313–Jan 2.60 2.27 1.77 2.0320–Jan 2.56 2.42 1.78 2.0427–Jan 2.50 2.47 1.78 2.033–Feb 2.44 2.58 1.77 2.0310–Feb 2.42 2.58 1.77 2.0417–Feb 2.42 2.66 1.77 2.0324–Feb 2.43 2.70 1.76 2.043–Mar 2.32 2.72 1.75 2.0210–Mar 2.27 2.71 1.74 2.0117–Mar 2.69 2.0124–Mar 2.67 1.99

Residential Heating Oil and Propane Price Comparison



Staking & Damage Prevention

Update for MPSC Staff Communication

February 24, 2020



2

Q2 Q3 Q4

• Utilize Miss Dig Metrics rather than Maximo

• Take out additional 3 hours Maximo was adding to all tickets

• Send positive responses for all clear tickets, rather then no response mapped

• Leaders auditing tickets• No longer utilizing

ongoing coordination (unless true)

• SEMI Gas Staking and Damage Prevention weekly PRT

• Mandatory 12 hour days• Distribution assist staking

on weekends• Dedicated Staking days

with Allen Road Distribution

• New teaching of how to Dispatch work

• Staker clearing single address tickets where we do not have gas

• Contractor defect form for employees

• Monthly meetings with all DTE gas locating groups

• Using an API for receiving tickets and posting positive response

• Combine all MCGC codes for SEMI

• Employee Remarks available for Excavators

• 6 New Employees• Retention bonus • Coaching with Contractors• Coaching with Restoration

Contractors• Flag shooters (new tool)• Emergency system down

process created

• Alter URG contract • URG work being directly

routed through Dig Tix• Error tickets emailed out

daily • All New employees out in

the field• Rest API for data

In 2019, we implemented the following countermeasures and exceeded our SOT performance target in September.

Q1

74% 73%

79% 80%83%

77%79%

84%

91%94%

97% 97%

50%

55%

60%

65%

70%

75%

80%

85%

90%

95%

100%

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2019 Gas SOT Performance



Next steps for improvement and associated timeframes are as follows…

3

Short Term Long Term

In process

+ Continue to build a relationship with Dispatch and Miss Dig

+ Continue to educate Contractors on how to call in tickets

2 Months

24-hour coverage for emergency tickets

3 Months

Create dashboard illustrating real time metrics

+ Would allow for dispatch to see when tickets are about to go late

+ Set up the day by tickets rather than regular areas

6 Months

Hire additional employees

- Employees leave after their 1 year bid restriction

- No work for employees during our slow season

- Additional vehicles

1 Year

Raise Staker wage to be more competitive with other locating companies

+ Employees would stay past 1 year bid

1 Year

Combine Field Service and Staking

+ Both groups have different busy seasons

+ Both groups short staffed during busy season

+ Align with what GRMI is already doing

+ Employees already have vehicles

1 Year

Increase the Qualifications of a Staker

+ Allow Stakers to take more work

1.5 Years

Implement Ticket Management System

+ Work would auto dispatch

+ Could set tickets to clear off of key words

+ Work would auto balance

+ Ticket information would all be stored in one place



4

• Audits include a combination of DTE and URG staking in SEMI• Audits are completed by DTE leaders, URG leaders, and our Damage Prevention team

A Staking Auditing Program was implemented in May of 2019 to improve quality

183329 408 334 281

174311 269

100

300

500

700

900

1100

1300

May Jun Jul Aug Sep Oct Nov Dec

Tota

l Sta

kin

g A

ud

its

SEMI Gas Operations Staking Total Audits and FindingsAudit Findings

4%

5%

5%

4%

5%

6%

9%

15%

0 50 100 150 200 250 300 350 400 450

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

SEMI Gas Operations Audit FindingsResponse Codes Photos Remarks Flags / Paint Label Scope



2019 Summary

5

• DTE Gas achieved a damage rate of 3.95 for 2019, which was an improvement of 22% over 2018’s rate of 5.06

• We attribute this success, in part, to the expansion of our team to 6 full time liaisons, increasing our field presence and associated prevention activities

– Proactive field visits, pre-excavation and during excavation

– Delivering excavator safety presentations

– Fielding incoming excavator phone calls / requests for assistance

– Analyzing damage and “near miss” root causes and developing countermeasures to these

• We fully launched our Optimain ticket risk-ranking software which allowed our liaisons to focus resources on locate requests with the highest likelihood of damage

– This focus included increased damage prevention efforts on project tickets, which continued to have a significantly higher damage rate than regular tickets

• Our continued partnership with the MPSC staff has helped our team a drive a culture change, driving an appreciation for the importance of safe digging practices with excavation companies, local municipalities, as well as our customers



DTE Gas 2019 damage prevention efforts resulted in a significant decrease to our damage rate

6



2020 Planned Activities

7

• Added focus on 2nd party contractor damages

• Continue engagement in other damage prevention activities in the community

– Champion the Gold Shovel Standard certification program, and increase our internal use of Gold Shovel damage reporting capabilities

– Participate in the Detroit Infrastructure Coordination sub-committee on compliance, helping develop a coordinated approach to damage reduction

– Partner with DTE Regional Relations to leverage our Public Awareness Program to educate a variety of community members

• Increased “enforcement” on safe digging where needed by increasing billing and collections of damage costs



Michigan Public Service Commission Staff inflation 12 mos. ending 12/31/2019: Staff inflation 9 mos. ending 09/30/2020: Staff inflation 12 mos. ending 09/30/2021:U-20642Capital Expenditures - Routine, Other Capital Projects

and Infrastructure Recovery Mechanism($000)

(a) (b) (c-1) (c-2) (d-1) (d-2) (e-1) (e-2) (g-1) (g-2)

Five Year Company Staff Adjustment Company Projected Staff Adjustment Company Projected Staff Adjustment Company Projected Staff AdjustmentLine Average 12 mos. ended 12 mos. ended 12 mos. ending 12 mos. ending 9 mos. ending 9 mos. ending 12 mos. ending 12 mos. endingNo. 2014-18 12/31/2018 12/31/2018 12/31/2019 12/31/2019 09/30/2020 09/30/2020 09/30/2021 09/30/2021

Routine2 Transmission Plant 5,972$ 3,489$ -$ 8,446$ (1,947)$ 6,424$ 657$ 8,911$ (1,773)$ 3 Storage Plant 22,841 33,139 - 21,900 - 13,767 - 19,194 -

Other Capital Projects8 NEXUS - 22,567$ -$ 5,517$ -$ -$ -$ -$ -$ 9 Belle River Compression 11 - - - - - - - 11 Milford Junction Loop - 3,624 - 1,863 (1,418) D/ - - - - 12 DTE Gas Site Security - - 4,238 (4,238) E/ 2,011 (2,011) E/ 3,239 (3,239) E/13 Traverse City Alpena Reinforcement Project 192 - 6,250 (2,250) F/ 19,833 (7,338) G/ 57,236 (20,040) H/14 Van Born Project - - - - 1,100 - I/ 11,300 (8,775) I/

Infrastructure Recovery Mechanism19 Pipeline Integrity 13,748$ -$ 19,430$ -$ 8,589$ -$ 6,355$ -$

(a) (b) (c-1) (c-2) (d-1) (d-2) (e-1) (e-2) (g-1) (g-2)

Five Year Company Staff Adjustment Company Projected Staff Adjustment Company Projected Staff Adjustment Company Projected Staff AdjustmentLine Average 12 mos. ended 12 mos. ended 12 mos. ending 12 mos. ending 9 Mo. ending 9 Mo. ending 12 mos. ending 12 mos. endingNo. 2014-18 12/31/2018 12/31/2018 12/31/2019 12/31/2019 09/30/2020 09/30/2020 09/30/2021 09/30/2021

Routine Capital RequirementsTransmission Plant

12 Transmission 5/ 7,350$ 3,964$ -$ 8,446$ (1,947)$ A/ 6,424$ 657$ B/ 8,911$ (1,773)$ C/13 Sales & Use Tax Settlement 1/ (1,379) (476) - - - - - - - 13 Total Transmission Plant 5,972$ 3,489$ -$ 8,446$ (1,947)$ 6,424$ 657$ 8,911$ (1,773)$

Storage Plant14 Gas Storage 6,706$ 8,455$ -$ 2,904$ -$ 3,216$ -$ 4,302$ -$ 15 Environmental Projects - Storage 328 398 - 401 - 301 - 425 - 16 Compression - Storage 15,806 24,285 - 18,594 - 10,249 - 14,467 - 17 Total Storage Plant 22,841$ 33,139$ -$ 21,900$ -$ 13,767$ -$ 19,194$ -$

A/ Projected amount derived from using the Five Year Average ($5,972), including the inflation ($108), and 70% of the QA program (70% of $600 = $420).B/ Projected amount derived from using the 12 mos. ending 12/31/2019 ($6080 without the QA program expenses), including the inflation ($91), and 70% of the QA program (70% of $1,300 = $910).C/ Projected amount derived from using the 9 mos. ending 9/30/2020 ($6171 without the QA program expenses), including the inflation ($128), and 70% of the QA program (70% of $1,200 = $840).D/ The proposed adjustment of $1,418 is based on rework the Company had to perform as a result of MPSC Non-Compliance 407141.E/ The proposed adjusments to DTE Gas Site Security are based on the Company providing insufficient documentation for Staff to determine what work was required at each project location.F/ The Company projection of $6,250 contains $170 of contingency. The removal of this contingency is included in the direct testimony of Staff Witness Joy H. Wang and is not duplicated here.

Staff's projection allows for recovery of 63% of the Company's projection (excluding contingency) as referenced in the direct testimony of Staff Witness Nathan J. Miller.G/ The Company projection of $19,833 contains $0 of contingency. Staff's projection allows for recovery of 63% of the Company's projection (excluding contingency) as referenced in the direct testimony of Staff Witness Nathan J. Miller.H/ The Company projection of $57,236 contains $3,073 of contingency. The removal of this contingency is included in the direct testimony of Staff Witness Joy H. Wang and is not duplicated here.

Staff's projection allows for recovery of 63% of the Company's projection (excluding contingency) as referenced in the direct testimony of Staff Witness Nathan J. Miller.I/ The Company projected a total of $1,850 of engineering associated with this project. As it has not yet been submitted for Act 9 approval, Staff is proposing that the Company only be allowed to collect the engineering expenses on this project, capping total recovery at $1,850.

The proposed adjustments here do not include removal of contingency costs, which will be removed by Staff Witness Joy H. Wang.

1.810% 1.500% 2.075%

Description

Description

Capital Expenditures

Historical Year Projected Bridge Year Projected Test YearCapital Expenditures

Historical Year Projected Bridge Year Projected Test Year



Page:

U-20642StaffSTDG-1.12A. D. Sandberg1 of 1

Question: Regarding Lines 22-25 on Page 7 of Company witness Alida D. Sandberg,which states in part that:

“From August 2019 through September 30, 2021, the end of theprojected test year, DTE Gas will have incurred $3.1 million of qualityassurance capital expenditures. Expenditures are projected to be$0.6 million in 2019, $1.7 million in 2020, and $1.0 million in 2021.”

Please provide a spreadsheet (with calculations intact) of how the capitalexpenditures associated with the Quality Assurance Program wasdetermined, with specific line items detailing the individual appropriationsthat results in the provided summation for each year.

Answer: Please reference file attachment “U-20642 STDG–1.12 QualityAssurance Program”.

Attachments: U-20642 STDG–1.12 Quality Assurance Program

Case No.: U-20642 Witness: N. Miller


Case No.: U-20642Discovery Request: STDG 1.12Respondent: A. D. SandbergFile Attachment: U-20642 STDG-1.12 Quality Assurance Program ($ millions)

Projected Test Year

Total QA Program Cost

Quality Assurance Capital Expenditures2019

Projected2020

Projected2021

Projected2019

Projected9 Mos Ending09/30/2020

12 Mos Ending09/30/2021

1/1/2019 - 9/30/2021

Labor (Internal) $ 0.0 $ 0.6 $ 1.0 $ 0.0 $ 0.5 $ 0.9 $ 1.4 Material $ - $ - $ - $ - $ - $ - $ - Contract Services $ 0.6 $ 1.1 $ - $ 0.6 $ 0.8 $ 0.3 $ 1.7 Overheads $ - $ 0.1 $ - $ - $ 0.1 $ 0.0 $ 0.1 Contingency $ - $ - $ - $ - $ - $ - $ - AFUDC $ - $ - $ - $ - $ - $ - $ -

Quality Assurance Program - Total Capital Expenditures

0.6$ 1.7$ 1.0$ 0.6$ 1.3$ 1.2$ 3.1$

STDG-1.12 Quality Assurance Program Projected Bridge Year





Page:

U-20642StaffSTDG-6.3A. D. SandbergT. M. Uzenski1 of 1

Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “BRM Unit #4 Engine Rebuild,” please identify theaccount number that this project is associated with in the Uniform Systemof Accounts Prescribed for Natural Gas Companies.

Answer: Underground Storage Plant - Compressor Station Equipment (Account354).

Attachments: None.



October 10, 2017 Ms. Joi Harris Vice President of Gas Operations DTE Gas Company One Energy Plaza WCB-2365 Detroit, MI 48226-1221 Subject: Non-Compliance 407141 Dear Ms. Harris: On May 1, 2017, Michigan Public Service Commission Staff Engineer Mrs. Karen Krueger inspected construction occurring at the Milford Compressor Station of DTE Gas Company (DTE). As a result of the inspection, it appears that DTE has committed a probable violation of 49 CFR 192.503 entitled “General requirements.” Gas Safety Standards Rule 460.20201 entitled “Pipeline safety standards; adoption by reference” states in part that “an operator shall ensure that a gas pipeline is in compliance with all of the minimum safety standards contained in 49 C.F.R. part 192…” 49 CFR 192.503 states in part that:

(a) No person may operate a new segment of pipeline, or return to service a segment of pipeline that has been relocated or replaced, until— (1) It has been tested in accordance with this subpart and §192.619 to substantiate the maximum allowable operating pressure.

During the inspection, it was understood that pressure testing was completed on Segments 001, 003, 004, and 005 in the pipe yard where they were fabricated. The segments were then cut into smaller sections, hauled to the site, and reassembled. This resulted in a significant number of welds that were subsequently not subject to a pressure test:

• Test segment 001 was cut into 2 sections. • Test segment 003 was cut into 12 sections. • Test segment 004 was cut into 3 sections. • Test segment 005 was cut into 2 sections.



Failure to test a new segment of pipeline in accordance with Subpart J and 49 CFR 192.619 to substantiate the maximum allowable operating pressure is a violation of 49 CFR 192.503(a). The Commission’s jurisdiction in this matter is pursuant to Public Act 165 of 1969, MCL 483.151 et seq. Failure to correct the issues identified in this notice could lead to further enforcement action by the Commission, up to and including a fine of not more than $10,000.00 for each violation, for each day that the violation persists. If you do not wish to contest the findings of probable non-compliance, please send a response within 60 days from the date of this letter indicating how DTE will correct the items identified above, a completion date for the corrections, and how DTE will prevent the reoccurrence of similar non-compliance issues. If you require clarification regarding this notice or wish to contest the findings, please contact Mrs. Krueger at 517-582-8619 or [email protected]. A Staff investigation report, findings, and recommendations will be forthcoming at a later date. Sincerely, David J. Chislea, Manager Gas Operations Section Operations and Wholesale Markets Division Delivery Method: Electronic Mail cc: Brian Ballinger, MPSC

Gas Safety Engineers, MPSC Frenae Smith, DTE Gas Company



mailto:[email protected]




Page:


Question: Regarding “NC 407141 (1st Action) Response” (attached here as Exhibit A)pertaining to probable violations associated with construction at the MilfordCompressor Station and Bypass, DTE committed to the following action toresolve the probable non-compliances:

“Major Enterprise Projects re-evaluated all the Milford CompressorStation valve nest welds and re-classified the 'initial' 46 tie-in weldsto field welds. In addition, the entire valve nest area including a shortsegment of the Milford Loop 'L' Pipeline was subjected to a strengthtest. The revised strength test was executed by DTE Gas on May 13,2017.”

Please provide a spreadsheet (with calculations intact) of the capital andO&M expenditures associated with this action, with specific line itemsdetailing the individual appropriations. Additionally, please specify fromwhere these costs were recovered.

Answer: An excel file does not exist, please see information below.

STDG-1.17 Milford Compressor StationMilford Loop "L" Pipeline and Valve Nest - Revised Strength Test

Capital Expenditures

Project Cost Breakdown ($000)2017

Actuals2018

Actuals2019

Actuals

TotalProject

Cost

Labor (Internal) $237 - - $237

Material $111 - - $111

Contract Services $218 - $1,418 $1,636

Milford Compressor Station - TotalCapital Expenditures

$566 $0 $1,418 $1,984

All expenditures associated with this action were incurred by DTE Gas.

All expenditures were categorized as capital expenditures.

Attachments: None





Page:

U-20642StaffSTDG-6.4AA. D. Sandberg1 of 1

Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “DTE Gas Site Security” that states:

The DTE Gas Site Security Program is a 5-year program thatreduces the risk associated with intentional and unintentionalevents that could affect DTE Gas' infrastructure, affecting thecompany's ability to supply natural gas to its customers. Scope ofwork to be performed includes: installation of new fence, upgradeof existing fences, automation and/or other upgrades of main gates,upgrades of egress gates, brushing/removal of trees along fencelines, installation of cameras for intrusion detection and alarming,new crash rated guardrails, bollards and fences for protection fromvehicular hits, critical area access control through badging systeminstallation and new doors with automatic locking systems.

Please provide the following:

A. A list of all of the specific projects included in this Program.

Answer: Please refer to file attachment “U-20642 STDG-6.4A and C DTE Gas SiteSecurity Projects and Costs” for the list of the specific projects includedin this program.

Attachments: U-20642 STDG-6.4A and C DTE Gas Site Security Projects and Costs





Page:

U-20642StaffSTDG-6.4BA. D. Sandberg1 of 1




B. The specific risk that is associated with the individual projects thatwarrants its inclusion into the Program.

Answer: The need for security measures at DTE Gas sites is taken from a DTEEnergy risk-based approach to protect critical infrastructure. Gas pipelineshave been targeted internationally and within the US, requiring improvedsecurity measures. These improvements, as stated above, are needed toreduce the risk of a malicious or unintentional cyber and/or physical securitybreach at DTE Gas operational facilities that are critical to ensuring reliableservice to its customers.

Attachments: None





Page:

U-20642StaffSTDG-6.4CA. D. Sandberg1 of 1




C. The associated expenditures for each individual project that were/will bespent separated into the following time periods:

Answer: Please refer to the response to discovery request STDG-6.4A

Attachments: None



Case No.: U-20642Discover Request: STDG - 6.4A and CRespondent: A. D. SandbergFile Attachment: U-20642 STDG-6.4A and C DTE Gas Site Security Projects and Costs

Project List - DTE Gas Site Security12 mos. ended

12/31/201812 mos. ended

12/31/20199 mos. ended

9/30/202021 mos. ended

9/30/202012 mos. ended

9/30/2021Belle River Mills Compressor Station $ - 286,534$ 30,771$ 317,306$ 91,286$ Columbus Compressor Station $ - 150,737$ 254,015$ 404,753$ 91,286$ Kalkaska Compressor Station $ - 10,794$ 30,771$ 41,566$ 392,357$ Milford Compressor Station $ - 547,411$ 30,771$ 578,183$ 91,286$ Six Lakes Compressor Station $ - 475,111$ 30,771$ 505,882$ 91,286$ Willow Compressor Station $ - 238,188$ 30,771$ 268,959$ 91,286$ Willow Gate Station $ - 455,267$ 156,054$ 611,322$ 91,286$ Northeastern Gate Station $ - -$ 319,741$ 319,741$ Northwestern Gate Station $ - -$ -$ -$ 140,688$ Loreed-Ludington Gate Station $ - -$ -$ -$ 293,214$ 76th/Byron Station $ - 87,188$ -$ 87,188$ Jenison St District Reg $ - 90,673$ -$ 90,673$ Hall St and Century District Reg $ - 101,950$ -$ 101,950$ Easterday/12th District Reg $ - 81,238$ -$ 81,238$ Gladstone Gate Station $ - 100,385$ -$ 100,385$ District Reg 20075 $ - 91,207$ -$ 91,207$ District Reg 20063 $ - 95,373$ -$ 95,373$ South Grand Rapids Gate $ - 114,884$ -$ 114,884$ 348,214$ Hudsonville Gate $ - 110,422$ -$ 110,422$ 316,813$ Northwestern and Telegraph Hwy $ - 407,214$ -$ 407,214$ Evergreen Station $ - 241,303$ -$ 241,303$ Shafer/Coolidge Station $ - 112,472$ -$ 112,472$ Lynch Rd Station $ - 188,595$ -$ 188,595$ Eureka/Wayne Rd $ - 201,489$ -$ 201,489$ Geddes Rd $ - 49,562$ -$ 49,562$ River Rouge Gate Station $ - -$ 277,332$ 277,332$ SEMI Gate Stations $ - -$ 350,000$ 350,000$ 500,000$ GRMI Gate Stations $ - -$ 300,000$ 300,000$ 500,000$ TSO Gate Stations $ - -$ 200,000$ 200,000$ 200,000$ Total Capital Expenditures - DTE Gas Site Security -$ 4,238,000$ 2,011,000$ 6,249,000$ 3,239,000$

U-20642 STDG - 6.4A and C DTE Gas Site Security Projects and Costs



Michigan Public Service Commission Case No. U-20640DTE Gas Company Exhibit: A-5 Lincoln-Traverse City Pipeline Loop Witness: T.J. Lajiness Estimated Capital Cost Page 1 of 1

Pipeline Stations Total

Land/ROW $1,120,000 $0 $1,120,000Material $2,600,713 $727,820 $3,328,533Engineering/Corp A&G $2,585,918 $576,237 $3,162,155Construction $13,185,563 $1,473,086 $14,658,649AFUDC $1,028,980 $146,604 $1,175,584Contingency $2,923,829 $416,571 $3,340,400

Total $23,445,000 $3,340,000 $26,785,000



Michigan Public Service Commission Case No. U-20641DTE Gas Company Exhibit: A-5 Frankfort Pipeline Loop Witness: T.J. Lajiness Estimated Capital Cost Page 1 of 1

Pipeline Stations Total

Land/ROW $1,300,000 $957 $1,300,957Material $2,050,948 $1,451,550 $3,502,498Engineering/Corp A&G $3,869,798 $937,038 $4,806,836Construction $19,360,542 $2,352,606 $21,713,148AFUDC $1,403,209 $250,334 $1,653,543Contingency $3,987,193 $711,323 $4,698,516

Total $31,971,690 $5,703,808 $37,675,498





Page:

U-20642StaffSTDG-1.1AR. M. TelangA. D. Sandberg1 of 2

Question: Regarding Lines 7-11 on Page 25 of Company witness Rajan M. Telang,which states:

“From December 31, 2018, the end of the historical test year in thelast rate case, through September 30, 2021, the end of the projectedtest year in this case, DTE Gas will have incurred $83.3 million ofTraverse City / Alpena Reinforcement project capital expenditures.These expenditures are illustrated in Exhibit A-12, Schedule B5.1,line 13, columns (f) and (g).”

It is Staff’s understanding that the Traverse City / Alpena ReinforcementProject (TCARP) is comprised of two separate Act 9 applications: U-20640for the 10” Lincoln-Traverse City Pipeline Loop and U-20641 for the 8”Frankfort Pipeline Loop. These pipelines had associated cost estimatessubmitted with their applications of $26,785,000 and $37,675,498,respectively. With that understanding, please provide the following:

A. A spreadsheet (with calculations intact) of how the $83.3 million wascalculated with the following line items included:

i. Land/ROWii. Materialiii. Engineeringiv. Constructionv. AFUDCvi. Contingency





Page:

U-20642StaffSTDG-1.1AR. M. TelangA. D. Sandberg2 of 2

Answer:

Table: U-20642 STDG-1.1 TCARP($ millions)Total Project Cost:1/1/2019-9/30/2021

Lincoln-Traverse City

PipelineLoop

FrankfortPipeline Loop

1/

Interconnectionsand DTE Gas

facilities

TCARP TotalProject Cost

Land/ROW $1.1 $1.3 $0.0 $2.4

Material $3.3 $3.5 $13.0 $19.8

Engineering $3.2 $4.0 $2.2 $9.4

Construction $14.7 $18.1 $13.3 $46.1

AFUDC $1.2 $0.6 $0.5 $2.3

Contingency $3.3 $0.0 $0.0 $3.3

Total Capital Expenditures $26.8 $27.5 $29.0 $83.3

1/ U-20641 Frankfort Pipeline Loop Act 9 filing of $37.7 million represents the total project costfrom 2018 - 2022. The $27.5 million for the Frankfort Pipeline Loop shown in table "U-20642STDG-1.1 TCARP" above represents the total project cost for the period 1/1/2019 - 9/30/2021.The remainder $10.2 million of the Frankfort Pipeline Loop is outside of the projected bridge andtest year in this proceeding.

Attachments: None





Page:

U-20642StaffSTDG-1.1BR. M. TelangA. D. Sandberg1 of 1

Question: Regarding Lines 7-11 on Page 25 of Company witness Rajan M. Telang,which states:

“From December 31, 2018, the end of the historical test year in thelast rate case, through September 30, 2021, the end of the projectedtest year in this case, DTE Gas will have incurred $83.3 million ofTraverse City / Alpena Reinforcement project capital expenditures.These expenditures are illustrated in Exhibit A-12, Schedule B5.1,line 13, columns (f) and (g).”

It is Staff’s understanding that the Traverse City / Alpena ReinforcementProject (TCARP) is comprised of two separate Act 9 applications: U-20640for the 10” Lincoln-Traverse City Pipeline Loop and U-20641 for the 8”Frankfort Pipeline Loop. These pipelines had associated cost estimatessubmitted with their applications of $26,785,000 and $37,675,498,respectively. With that understanding, please provide the following:

B. A narrative of why the requested $83.3 million is greater than the sumof the two cost estimates of the 10” Lincoln-Traverse City Pipeline Loopand 8” Frankfort Pipeline Loop as presented in Docket Nos. U-20640and U-20641 ($64.5 million).

Answer: In addition to the footnote in response STDG-1.1A, the 10” Lincoln-TraverseCity Pipeline Loop ($26.8M) and the 8” Frankfort Pipeline Loop ($27.5M)are a portion of the overall TCARP project cost in this proceeding.Additional capital expenditures of $29.0M included in the $83.3M are for theproposed interconnections with DTE Michigan Gathering HoldingCompany, new DTE Gas facilities and modifications to existing facilities tosupport the improved reliability of our system and reduce the number ofpotential outages (see table in STDG-1.1A for a detailed breakout of costsas well as Exhibit A-12). Construction completion of the 8” FrankfortPipeline Loop and the interconnections is after the end of the projected testyear.

Attachments: None





Page:


Question: Regarding Lines 12-14 on Page 42 of Company witness Alida D. Sandberg,which states in part that:

“From December 31, 2018, the end of the historical test year, throughSeptember 30, 2021, the end of the projected test year, DTE Gas willhave incurred $12.4 million of Van Born Project capitalexpenditures.”

Because this project has not yet been submitted before the MPSC for Act 9certification, please provide a cost estimate for the Van Born Projectconsistent with what DTE provided in their Act 9 application for the 10”Lincoln-Traverse City Pipeline Loop (U-20640, Exhibit A-5) and the 8”Frankfort Pipeline Loop (U-20641, Exhibit A-5).

Answer:

STDG-1.19 Van Born PipelineTotal Project

Cost

Project Cost Breakdown ($000s)1/1/2019-9/30/2021

Land/ROW $1,600

Material $1,500

Engineering $1,850

Construction $5,383

AFUDC $292

Contingency $1,775

Total Project Cost - Van Born $12,400

Attachments: None





Page:

U-20642StaffSTDG-1.5M. C. Johnson1 of 2

Question: Regarding Lines 3-12 on Page 14 of Company witness Mark C. Johnson,which states in part that:

“Five known and measurable adjustments, other than inflation, areassumed within Transmission expense (See Exhibit A-13, ScheduleC5.2). These adjustments are related to:

1. Pipeline Integrity: $8.4 million (line 3, column(j))2. MAOP Transmission Records Remediation: $4.6 million (line 10,

column (j))3. Blue Lake transmission: $0.9 million (line 10, column (j))4. Pipeline Safety Management Systems: $1.1 million (line 10,

column (j))5. QA Third Party Support: $0.1 million (line 10, column (j))6. Cyber security and additional nominations support: $1.5 million

(line 10, column (j))”

Please provide a spreadsheet (with calculations intact) of how eachexpense (1-6 above) was determined with specific line items detailing theindividual appropriations that results in the provided summation.

Answer: Item 1: See file attachment “U-20642 STDG-1.5 Pipeline Integrity andMAOP Transmission Records O&M”, tab labeled STDG-1.5 1.Pipeline Integrity

Item 2: See file attachment “U-20642 STDG-1.5 Pipeline Integrity andMAOP Transmission Records O&M”, tab labeled STDG-1.5 2.MAOP Trans Records

Item 3. Blue Lake transmission: $0.9 million, please reference “U-20642STDG-1.5.3 Blue Lake Transmission”

Item 4: See file attachment “U-20642 STDG–1.5.4 Pipeline SafetyManagement Systems”

Item 5: See file attachment “U-20642 STDG–1.5.5 QA Third PartySupport”





Page:


Item 6. The $1.5 million referenced in Exhibit A-13 Schedule C5.2represents the total increase for the Gas Control and Planningoperating budget which includes the increase due to CyberSecurity for an increase of $0.40 million, Additional nominationssupport for an increase of $0.96 million, and the hiring of twoemployees to support Nexus operations for $0.14 million. Fordetailing the individual appropriations for Cyber Security andAdditional Nominations, please reference file attachment “U-20642 STDG-1.5.6 Cyber Security and NominationSupport.xlsx”

Attachments: U-20642 STDG-1.05 Pipeline Integrity and MAOP TransmissionRecords O&MU-20642 STDG – 1.5.4 Pipeline Safety Management SystemsU-20642 STDG – 1.5.5 QA 3rd Party Support



Case No.: U‐20642Discovery Request: STDG‐1.5 Item 1Respondent: M. C. JohnsonFile Attachment: U‐20642 STDG‐1.5 Pipeline Integrity and MAOP Transmission Records O&M

Pipeline Integrity O&M Expenses($ milliona)

2018Historical Test

Period

2020Projected

2021Projected

Projected Test Year 12 mos ending 09/30/2021

Labor (Internal) $ 0.9 $ 1.9 $ 2.8 2.6$ Material $ 0.1 $ 3.2 $ 4.6 4.3$ Contract Services $ 7.0 $ 6.5 $ 9.3 8.6$ Other (Non ‐ Labor) $ 0.4 $ 1.3 $ 1.9 1.7$

Pipeline Integrity O&M Expenditures ‐ Total $ 8.4 $ 12.9 $ 18.5 $ 17.1 8.7$ (0.3)$ 8.4$

U‐20642 STDG‐1.5 Item 1 Pipeline Integrity O&M Expense

Projected Increase from 2018 ProjectedSubtraction of InflationOther Adjustments (Line No. 3, column j) for Pipeline Integrity ‐ Total



Case No.: U‐20642Discovery Request: STDG‐1.5 Item 2Respondent: M. C. JohnsonFile Attachment: U‐20642 STDG‐1.5 Pipeline Integrity and MAOP Transmission Records O&M

MAOP Transmission Record Remediation O&M Expenses($ millions)

2020Projected

2021Projected


Labor (Internal) $ 0.1 $ 0.9 0.7$ Material $ 0.2 $ 1.5 1.1$ Contract Services $ 0.4 $ 2.9 2.3$ Other (Non ‐ Labor) $ 0.1 $ 0.6 0.5$

MAOP Transmission Record Remediation ‐ Total 0.8$ 5.8$ 4.6$

U‐20642 STDG‐1.5 Item 2 MAOP Transmission Record Remediation O&M Expense



Blue Lake Transmission Fees Detail

Jan Feb Mar Jan‐Mar Total

ANR TransportationVariable ChargesTotal ACA $'s $14,045 $22,661 $24,675 $61,382Fuel Volume 9,723 15,687 17,082BTU Factor 1.05113 1.05284 1.05350Jurisdictional Rate $3.20000 $3.20000 $3.35000Sales Tax 1.06000 1.06000 1.06000Fuel $'s $31,376 $50,540 $57,578 $139,494Total $45,421 $73,201 $82,253

Bluelake StorageMonthly Reservation Charge $179,777 $179,777 $179,777 $539,332Variable ChargesTotal ACA $'s $13,073 $2,025 $24,224 $39,323Fuel Volume 7,247 11,689 13,079BTU Factor 1.05113 1.05284 1.05350Jurisdictional Rate ($/Mcf) $3.20000 $3.20000 $3.35000Sales Tax 1.06000 1.06000 1.06000Fuel $'s $23,386 $37,659 $44,085 $105,130Total $216,236 $219,462 $248,087

Total Blue Lake transmission known and measurable adjustment $261,658 $292,663 $330,340 $884,661

2019 Actual as proxy for test period



Case No.: U‐20642Discovery Request: STDG‐1.5 Item 4Respondent: M. C. JohnsonFile Attachment: U‐20642 STDG‐1.5.4 Pipeline Safety Management Systems ($ millions)

Pipeline Safety Management Systems2019

Projected2020

Projected2021

Projected


Labor (Internal) $ 0.0 $ 0.7 $ 1.0 0.9$ Material $ ‐ $ ‐ $ ‐ ‐$ Contract Services $ 0.5 $ 0.5 $ ‐ 0.1$ Other (Non ‐ Labor) $ ‐ $ 0.0 $ ‐ 0.0$

Pipeline Safety Management Systems ‐ Total 0.5$ 1.3$ 1.0$ 1.1$

U‐20642 STDG‐1.5 Item 4 Pipeline Safety Management Systems



Case No.: U‐20642Discovery Request: STDG 1.5 Item 5Respondent: M. C JohnsonFile Attachment: U‐20642 STDG‐1.5.5 QA 3rd Party Support ($ millions)

QA Third Party Support Projected 2020 Projected 2021Projected Test Year 12 mos. ending 09/30/2021

Labor (Internal) $ 0.0 $ ‐ 0.0$ Material $ ‐ $ ‐ ‐$ Contract Services $ 0.5 $ ‐ 0.1$ Other (Non ‐ Labor) $ ‐ $ ‐ ‐$

QA Third Party Support ‐ Total 0.5$ ‐$ 0.1$

U‐20642 STDG‐1.5 Item 5 QA Third Party Support





Page:

U-20642StaffSTDG-1.3AM. C. Johnson1 of 1

Question: Regarding Lines 2-9 on Page 4 of Company witness Larisa Abayev, whichstates:

“There are a number of contributors to LAUF gas including:1. Metering inaccuracy…2. Leaks and theft…3. Other metering and billing issues….”

Please provide, from 2018-2019, a breakdown of all of the gas that was lostdue to the following events:

A. Emergency shutdowns at compressor stations where the compressorstation vented gas when there was not a fire or release of gas at thestation that precipitated the shutdown.

As part of this breakdown, please list each event, the date of each event,the quantity of gas lost, the value of the gas that was lost, and from wherethe cost of these events was recovered (for example, LAUF, billed tocontractor, etc.).

Answer: See attachment U-20642 STDG-1.3A-01 Emergency Shutdown Gas

Attachments: U-20642 STDG-1.3A-01 Emergency Shutdown Gas



Event Date Event Quantity (MCF) Lost Value of Gas Lost Cost Recovered As1/1/2018 Planned Station ESD Total For Year 2,229 7,740.61$ Company Use 1/1/2018 Planned Station ESD Total For Year 815 2,831.59$ Company Use 1/1/2018 Unplanned Station ESD 12 40.41$ Company Use 4/1/2018 Station ESD 241 804.36$ Company Use 4/23/2018 Planned Station ESD 12,050 40,251.11$ Lost Gas 7/9/2018 Planned Station ESD 16,944 56,600.41$ Lost Gas 9/20/2018 Unplanned Station ESD 38 127.72$ Lost Gas 9/26/2018 Station ESD 332 1,110.20$ Lost Gas 9/26/2018 Unplanned Station ESD 11,098 37,071.05$ Lost Gas 1/1/2019 Planned Station ESD Total For Year 3,248 10,849.62$ Company Use 1/1/2019 Planned Station ESD Total For Year 698 2,331.60$ Company Use 5/6/2019 Planned Station ESD 12,050 35,546.88$ Lost Gas 7/8/2019 Planned Station ESD 20,613 60,808.12$ Lost Gas 9/27/2019 Unplanned Station ESD 316 932.57$ Company Use





Page:

U-20642StaffSTDG-5.1BA.D. SandbergT. Uzenski1 of 1

Question: Regarding Lines 14-24 on Page 48 and Lines 1-2 on Page 49 of Companywitness Alida D. Sandberg, which states in part that:

Pipeline integrity is the program used by DTE Gas to manage and ensure the integrity of the gastransmission system as prescribed in Subpart O of the MGSS, Pipeline Integrity Management. Theregulatory requirements contained in Subpart O of MGSS prescribe minimum requirements for atransmission pipeline integrity management program. The sub-programs of DTE Gas’s PipelineIntegrity Management Program are:

(i) Pipeline Integrity Assessments(ii) In-Line-Inspection (ILI) Expansion(iii) Remote Control Valves (RCV)(iv)Maximum Allowable Operating Pressure (MAOP) Record Review(v) Records Management System Development.

Item (i) are O&M expenses covered in Company Witness Mr. M. Johnson’s testimony. This testimonywill address the capital expenditures, items (ii – v).

B. Please provide the account number that each activity (items (ii)through (v)) is associated with in the Uniform System of AccountsPrescribed for Natural Gas Companies.

Answer:Pipeline Integrity

Sub-programPlant Classification Account

(ii) In-Line Inspection (ILI)Expansion

TransmissionMeasuring and RegulatingStation Equipment (369)

(iii) Remote Control Valves(RCV)

TransmissionMeasuring and RegulatingStation Equipment (369)

(iv) Maximum AllowableOperating Pressure (MAOP)Record Review

IntangibleMiscellaneous Intangibles 5Yrs (303)

(v) Records ManagementSystem Development

IntangibleMiscellaneous Intangibles 5Yrs (303)

Note: The rate case model classified all projected expenditures for Pipeline Integritywithin the Transmission plant classification.

Attachments: None



498

SUBCHAPTER F—ACCOUNTS, NATURAL GAS ACT

PART 201—UNIFORM SYSTEM OFACCOUNTS PRESCRIBED FORNATURAL GAS COMPANIES SUB-JECT TO THE PROVISIONS OF THENATURAL GAS ACT

AUTHORITY: 15 U.S.C. 717–717w, 3301–3432; 42U.S.C. 7101–7352, 7651–7651o.

SOURCE: Order 219, 25 FR 5616, June 21, 1960.EDITORIAL NOTE: For FEDERAL REGISTER ci-

tations affecting part 201, see the List ofCFR Sections Affected in the Finding Aidssection of this volume.

EFFECTIVE DATE NOTE: At 58 FR 18006,April 7, 1993, part 201 was amended by redes-ignating definitions 31 through 39 as 32through 40 and adding new definition 31; Ac-counts 182.3 and 254 were added under Bal-ance Sheet Accounts; and Accounts 407.3 and407.4 were added under Income Accounts. Theinformation collection provisions, will notbecome effective until approved by the Officeof Management and Budget. A notice will bepublished in the FEDERAL REGISTER once ap-proval has been obtained.

NOTE: Order 141, 12 FR 8504, Dec. 19, 1947,provides in part as follows:

Prescribing a system of accounts for naturalgas companies under the Natural Gas Act. TheFederal Power Commission acting pursuantto authority granted by the Natural Gas Act(58) Stat. 821, as amended; 15 U.S.C. and Sup.717 et seq.), particularly sections 8(a), 10(a)and 16 thereof, and finding such action nec-essary and appropriate for carrying out theprovisions of said Act, ordered that:

(a) The accompanying system of accounts,entitled ‘‘Uniform System of Accounts Pre-scribed for Natural Gas Companies Subjectto the Provisions of the Natural Gas Act,’’and the rules and regulations containedtherein, be adopted;

(b) Said system of accounts and said rulesand regulations contained therein be and thesame are hereby prescribed and promulgatedas the system of accounts and rules and reg-ulations of the Commission to be kept andobserved by natural gas companies subject tothe jurisdiction of the Commission, to theextent and in the manner set forth therein;

(c) Said system of accounts and rules andregulations therein contained as to all natu-ral gas companies now subject to the juris-diction of the Commission, became effectiveon January 1, 1940, and as to any natural gascompany which may hereafter become sub-ject to the jurisdiction of the Commission,they shall become effective as of the datewhen such natural gas company becomes

subject to the jurisdiction of the Commis-sion.

Uniform System of Accounts Prescribed forNatural Gas Companies Subject to theProvisions of the Natural Gas Act

Definitions

When used in this system of ac-counts:

1. Accounts means the accounts pre-scribed in this system of accounts.

2. Actually issued, as applied to secu-rities issued or assumed by the utility,means those which have been sold tobona fide purchasers for a valuable con-sideration, those issued as dividends onstock, and those which have beenissued in accordance with contractualrequirements direct to trustees of sink-ing funds.

3. Actually outstanding, as applied tosecurities issued or assumed by theutility, means those which have beenactually issued and are neither retirednor held by or for the utility; provided,however, that securities held by trust-ees shall be considered as actually out-standing.

4. Amortization means the gradual ex-tinguishment of an amount in an ac-count by distributing such amountover a fixed period, over the life of theasset or liability to which it applies, orover the period during which it is an-ticipated the benefit will be realized.

5. A. Associated (affiliated) companiesmeans companies or persons that di-rectly or indirectly, through one ormore intermediaries, control, or arecontrolled by, or are under commoncontrol with the accounting company.

B. Control (including the terms ‘‘con-trolling,’’ ‘‘controlled by,’’ and ‘‘undercommon control with’’) means the pos-session, directly or indirectly, of thepower to direct or cause the directionof the management and policies of acompany, whether such power is exer-cised through one or more inter-mediary companies, or alone, or in con-junction with, or pursuant to an agree-ment, and whether such power is estab-lished through a majority or minority



499

Federal Energy Regulatory Commission Pt. 201

ownership or voting of securities, com-mon directors, officers, or stockhold-ers, voting trusts, holding trusts, asso-ciated companies, contract or anyother direct or indirect means.

6. Book cost means the amount atwhich property is recorded in these ac-counts without deduction of relatedprovisions for accrued depreciation, de-pletion, amortization, or for other pur-poses.

7. Commission, means the Federal En-ergy Regulatory Commission.

8. Continuing plant inventory recordmeans company plant records for re-tirement units and mass property thatprovide, as either a single record, or inseparate records readily obtainable byreferences made in a single record, thefollowing information:

A. For each retirement unit;(1) The name or description of the

unit, or both;(2) The location of the unit;(3) The date the unit was placed in

service;(4) The cost of the unit as set forth in

Plant Instructions 2 and 3 of this part;and

(5) The plant control account towhich the cost of the units is charged;and

B. For each category of mass prop-erty;

(1) A general description of the prop-erty and quantity;

(2) The quantity placed in service byvintage year;

(3) The average cost as set forth inPlant Instructions 2 and 3 of this part;and

(4) The plant control account towhich the costs are charged.

9. Cost means the amount of moneyactually paid for property or services.When the consideration given is otherthan cash in a purchase and sale trans-action, as distinguished from a trans-action involving the issuance of com-mon stock in a merger or a pooling ofinterest, the value of such consider-ation shall be determined on a cashbasis.

10. Cost of removal means the cost ofdemolishing, dismantling, tearingdown or otherwise removing gas plant,including the cost of transportationand handling incidental thereto.

11. Debt expense means all expenses inconnection with the issuance and ini-tial sale of evidences of debt, such asfees for drafting mortgages and trustdeeds; fees and taxes for issuing or re-cording evidences of debt; cost of en-graving and printing bonds and certifi-cates of indebtedness; fees paid trust-ees; specific costs of obtaining govern-mental authority; fees for legal serv-ices; fees and commissions paid under-writers, brokers, and salesmen for mar-keting such evidences of debt; fees andexpenses of listing on exchanges; andother like costs.

12. A. Depletion, as applied to naturalgas producing land and land rights,means the loss in service value in-curred in connection with the exhaus-tion of the natural resource in thecourse of service.

B. Depreciation, as applied to depre-ciable gas plant, means the loss inservice value not restored by currentmaintenance, incurred in connectionwith the consumption or prospectiveretirement of gas plant in the course ofservice from causes which are knownto be in current operation and againstwhich the utility is not protected byinsurance. Among the causes to begiven consideration are wear and tear,decay, action of the elements, inad-equacy, obsolescence, changes in theart, changes in demand and require-ments of public authorities, and, in thecase of natural gas companies, the ex-haustion of natural resources.

13. Development costs, when used withrespect to hydrocarbons, include allcosts incurred in the readying of hy-drocarbon deposits for commercial pro-duction including developmental welldrilling costs.

14. Discount, as applied to the securi-ties, issued or assumed by the utility,means the excess of the par (statedvalue of no-par stocks) or fact value ofthe securities plus interest or dividendsaccrued at the date of the sale over thecash value of the consideration re-ceived from their sale.

15. Exploration costs, include all costsincurred in proving the existence of hy-drocarbon deposits including geologi-cal, geophysical, lease acquisition (in-cluding delay rentals), administrativeand general, and exploratory well drill-ing costs.



500

18 CFR Ch. I (4–1–98 Edition) Pt. 201

16. Full-cost accounting for explorationand development costs, means the cap-italization of all exploration and devel-opment costs incurred on or related tohydrocarbon leases, on properties inthe contiguous 48 States and the Stateof Alaska, acquired after October 7,1969.

17. Investment advances means ad-vances, represented by notes or bybook accounts only, with respect towhich it is mutually agreed or intendedbetween the creditor and debtor thatthey shall be settled by the issuance ofsecurities or shall not be subject tocurrent settlement.

18. Lease, capital means a lease ofproperty used in utility or non-utilityoperations, which meets one or more ofthe criteria stated in General Instruc-tion 19.

19. Lease, operating means a lease ofproperty used in utility or non-utilityoperations, which does not meet any ofthe criteria stated in General Instruc-tion 19.

20. Minor items of property means theassociated parts or items of which re-tirement units are composed.

21. Natural gas means either naturalgas unmixed, or any mixture of naturaland artificial gas.

22. Natural gas company means a per-son engaged in the transportation ofnatural gas in interstate commerce, orthe sale in interstate commerce of suchgas for resale.

23. Net salvage value means the sal-vage value of property retired less thecost of removal.

24. Nominally issued, as applied to se-curities issued or assumed by the util-ity, means those which have beensigned, certified, or otherwise exe-cuted, and placed with the proper offi-cer for sale and delivery, or pledged, orotherwise placed in some special fundof the utility, but which have not beensold, or issued direct to trustees ofsinking funds in accordance with con-tractual requirements.

25. Nominally outstanding, as appliedto securities issued or assumed by theutility, means those which, after beingactually issued, have been reacquiredby or for the utility under cir-cumstances which require them to beconsidered as held alive and not re-tired, provided, however, that securi-

ties held by trustees shall be consid-ered as actually outstanding.

26. Original cost, as applied to gasplant, means the cost of such propertyto the person first devoting it to publicservice.

27. Person means an individual, a cor-poration, a partnership, an association,a joint stock company, a businesstrust, or any organized group of per-sons, whether incorporated or not, orany receiver or trustee.

28. Premium, as applied to securitiesissued or assumed by the utility,means the excess of the cash value ofthe consideration received from theirsale over the sum of their par (statedvalue of no-par stocks) or face valueand interest or dividends accrued atthe date of sale.

29. Production, transmission, and dis-tribution plant. For the purposes of thissystem of accounts:

A. Production system shall consist ofplant and equipment used in the pro-duction of gas. It shall include produc-ing lands and leaseholds, gas rights,other land rights, structures, drillingand clearing equipment, gas wells, wellhead equipment, separation and otherfacilities used in the production of nat-ural gas. The production system endswhere the gas enters a gathering sys-tem, transmission system or distribu-tion system, as applicable, in accord-ance with the practices in the pricingarea where such system is located.

B. Transmission system means theland, structures, mains, valves, meters,boosters, regulators, tanks, compres-sors, and their driving units and appur-tenances, and other equipment usedprimarily for transmitting gas from aproduction plant, delivery point of pur-chased gas, gathering system, storagearea, or other wholesale source of gas,to one or more distribution areas. Thetransmission system begins at the out-let side of the valve at the connectionto the last equipment in a manufac-tured gas plant, the connection togathering lines or delivery point ofpurchased gas, and includes the equip-ment at such connection that is usedto bring the gas to transmission pres-sure, and ends at the outlet side of theequipment which meters or regulatesthe entry of gas into the distributionsystem or into a storage area. It does



501


not include storage land, structures orequipment. Pipeline companies, includ-ing those companies which measure de-liveries of gas to their own distributionsystems, shall include city gate andmain line industrial measuring andregulating stations in the transmissionfunction.

C. Distribution system means themains which are provided primarily fordistributing gas within a distributionarea, together with land, structures,valves, regulators, services and meas-uring devices, including the mains fortransportation of gas from productionplants or points of receipt locatedwithin such distribution area to otherpoints therein. The distribution systemowned by companies having no trans-mission facilities connected to suchdistribution system begins at the inletside of the distribution system equip-ment which meters or regulates theentry of gas into the distribution sys-tem and ends with and includes prop-erty on the customer’s premises. Forcompanies which own both trans-mission and distribution facilities on acontinuous line, the distribution sys-tem begins at the outlet side of theequipment which meters or regulatesthe entry of gas into the distributionsystem and ends with and includesproperty on the customer’s premises.The distribution system does not in-clude storage land, structures, orequipment.

D. Distribution area means a metro-politan area or other urban area com-prising one or more adjacent or nearbycities, villages or unincorporatedareas, including developed areas con-tiguous to main highways.

30. Property retired, as applied to gasplant, means property which has beenremoved, sold, abandoned, destroyed,or which for any cause has been with-drawn from service.

31. Regulatory Assets and Liabilities areassets and liabilities that result fromrate actions of regulatory agencies.Regulatory assets and liabilities arisefrom specific revenues, expenses, gains,or losses that would have been includedin net income determinations in oneperiod under the general requirementsof the Uniform System of Accounts butfor it being probable: 1) that such itemswill be included in a different period(s)

for purposes of developing the rates theutility is authorized to charge for itsutility services; or 2) in the case of reg-ulatory liabilities, that refunds to cus-tomers, not provided for in other ac-counts, will be required.

32. A. Replacing or replacement, whennot otherwise indicated in the context,means the construction or installationof gas plant in place of property re-tired, together with the removal of theproperty retired.

B. Research, Development, and Dem-onstration (RD&D), means expendituresincurred by natural gas companies ei-ther directly or through another per-son or organization (such as researchinstitute, industry association, founda-tion, university, engineering company,or similar contractor) in pursuing re-search, development, and demonstra-tion activities including experiment,design, installation, construction, oroperation. This definition includes ex-penditures for the implementation ordevelopment of new and/or existingconcepts until technically feasible andcommercially feasible operations areverified. Such research, development,and demonstration costs should be rea-sonably related to the existing or fu-ture utility business, broadly defined,of the public utility or licensee or inthe environment in which it operatesor expects to operate. The term in-cludes, but is not limited to: All suchcosts incidental to the design, develop-ment or implementation of an experi-mental facility, a plant process, a prod-uct, a formula, an invention, a systemor similar items, and the improvementof already existing items of a like na-ture; amounts expended in connectionwith the proposed development and/orproposed delivery of substitute or syn-thetic gas supplies (alternate fuelsources for example, an experimentalcoal gasification plant or an experi-mental plant synthetically producinggas from liquid hydrocarbons); and thecosts of obtaining its own patent, suchas attorney’s fees expended in makingand perfecting a patent application.The term includes preliminary inves-tigations and detailed planning of spe-cific projects for securing for cus-tomers non-conventional pipeline gassupplies that rely on technology thathas not been verified previously to be



502


feasible. The term does not include ex-penditures for efficiency surveys; stud-ies of management, management tech-niques and organization; consumer sur-veys, advertising, promotions, or itemsof a like nature.

33. Retained earnings (formerly earnedsurplus) means the accumulated net in-come of the utility less distribution tostockholders and transfers to othercapital accounts.

34. Retirement units means thoseitems of gas plant which, when retired,with or without replacement, are ac-counted for by crediting the book costthereof to the gas plant account inwhich included.

35. Salvage value means the amountreceived for property retired, less anyexpenses incurred in connection withthe sale or in preparing the propertyfor sale; or, if retained, the amount atwhich the material recoverable ischargeable to Materials and Supplies,or other appropriate account.

36. Service life means the time be-tween the date gas plant is includiblein gas plant in service, or gas plantleased to others, and the date of its re-tirement. If depreciation is accountedfor on a production basis rather thanon a time basis, then service life shouldbe measured in terms of the appro-priate unit of production.

37. Service value means the differencebetween original cost and net salvagevalue of gas plant.

38. Unsuccessful exploration and devel-opment costs, means exploration and de-velopment costs related to effortswhich do not directly result in the dis-covery of commercially recoverable hy-drocarbon reserves.

39. Subsidiary company, means a com-pany which is controlled by the utilitythrough ownership of voting stock.(See ‘‘Definitions’’—item 5B ‘‘Con-trol’’). A corporate joint venture inwhich a corporation is owned by asmall group of businesses as a separateand specific business or project for themutual benefit of the members of thegroup is a subsidiary company for thepurposes of this system of accounts.

40. Utility, as used herein and whennot otherwise indicated in the context,means any natural gas company towhich this system of accounts is appli-cable.

General Instructions

1. Applicability. Each natural gascompany must apply the system of ac-counts prescribed by the Commission.

Major —Each natural gas company asdefined in the Natural Gas Act, whosecombined gas sold for resale and gastransported or stored for a fee exceeds50 million Mcf at 14.73 psi (60° F) ineach of the three previous calendaryears.

Nonmajor—Natural gas companiesthat are not classified as a ‘‘majorcompany’’ (as defined above), and hadtotal gas sales or volume transactionsexceeding 200,000 Mcf at 14.73 psi (60 °F)in each of the three previous calendaryears.

B. This system applies to both Majorand Nonmajor natural gas companies.Provisions have been incorporated intothis system for those entities whichprior to January 1, 1984, were applyingthe Commission’s Uniform System ofAccounts Prescribed for Class C andClass D (part 104 of this chapter) nowrevoked. The notations ‘‘(Nonmajor)’’and ‘‘(Major)’’ have been used to indi-cate those instructions and accountsfrom the previous systems and classi-fications, which by definition, are notinterchangeable without causing a lossof detail for the Major (previous ClassA and Class B) or an increase in detailburden for the Nonmajor (previous ClassC and Class D).

C. The class to which any natural gascompany belongs shall originally be de-termined by its annual gas volume ineach of the last three consecutiveyears, or, in the case of a newly estab-lished entity, the projected data shallbe the basis. Subsequent changes inclassification shall be made when thevolume for each of the three imme-diately preceding years exceeds theupper limit, or is less than the lowerlimit of the classification previouslyapplicable to the natural gas company.

D. Any utility may, at its option,adopt the system of accounts pre-scribed by the Commission for anylarger class of utilities.

2. Records. A. Each utility shall keepits books of account, and all otherbooks, records, and memoranda which



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support the entries in such books of ac-count so as to be able to furnish read-ily full information as to any item in-cluded in any account. Each entryshall be supported by such detailed in-formation as will permit ready identi-fication, analysis, and verification ofall facts relevant thereto.

B. The books and records referred toherein include not only accountingrecords in a limited technical sense,but all other records, such as minutebooks, stock books, reports, cor-respondence, memoranda, etc., whichmay be useful in developing the historyof or facts regarding any transaction.

C. No utility shall destroy any suchbooks or records unless the destructionthereof is permitted by rules and regu-lations of the Commission.

D. In addition to prescribed accounts,clearing accounts, temporary or exper-imental accounts, and subdivisions ofany accounts, may be kept, providedthe integrity of the prescribed ac-counts is not impaired.

E. All amounts included in the ac-counts prescribed herein for gas plantand operating expenses shall be justand reasonable and any payments oraccruals by the utility in excess of justand reasonable charges shall be in-cluded in account 426.5, Other Deduc-tions.

F. The arrangement or sequence ofthe accounts prescribed herein shallnot be controlling as to the arrange-ment or sequence in report formswhich may be prescribed by the Com-mission.

3. Numbering system. A. The accountnumbering plan used herein consists ofa system of three-digit whole numbersas follows:100–199 Assets and Other Debits.200–299 Liabilities and Other Credits.300–399 Plant Accounts.400–432, 434–435 Income Accounts.433, 436–439 Retained Earnings Accounts.480–499 Revenue Accounts.700–899 Production, Transmission and Dis-

tribution Expenses.900–949 Customer Accounts, Customer Serv-

ice and Informational, Sales and Generaland Administrative Expenses.

B. In certain instances, numbers havebeen skipped in order to allow for pos-sible later expansion or to permit bet-ter coordination with the numberingsystem for other utility departments.

C. The numbers prefixed to accounttitles are to be considered as part ofthe titles. Each utility, however, mayadopt for its own purposes a differentsystem of account numbers (See alsogeneral instruction 2D) provided thatthe numbers herein prescribed shall ap-pear in the descriptive headings of theledger accounts and in the varioussources of original entry; however, if autility uses a different group of ac-count numbers and it is not practicableto show the prescribed account num-bers in the various sources of originalentry, such reference to the prescribedaccount numbers may be omitted fromthe various sources of original entry.Moreover, each utility using differentaccount numbers for its own purposesshall keep readily available a list ofsuch account numbers which it usesand a reconciliation of such accountnumbers with the account numbersprovided herein. It is intended that theutility’s records shall be so kept as topermit ready analysis by prescribed ac-counts (by direct reference to sourcesof original entry to the extent prac-ticable) and to permit preparation offinancial and operating statements di-rectly from such records at the end ofeach accounting period according tothe prescribed accounts.

4. Accounting period. Each utilityshall keep its books on a monthly basisso that for each month all transactionsapplicable thereto, as nearly as may beascertained, shall be entered in thebooks of the utility. Amounts applica-ble or assignable to specific utility de-partments shall be so segregatedmonthly. Each utility shall close itsbooks at the end of each calendar yearunless otherwise authorized by theCommission.

5. Submittal of questions. To maintainuniformity of accounting, utilitiesshall submit questions of doubtful in-terpretation to the Commission forconsideration and decision.

6. Item lists. Lists of ‘‘items’’ appear-ing in the texts of the accounts or else-where herein are for the purpose ofmore clearly indicating the applicationof the prescribed accounting. The listsare intended to be representative, butnot exhaustive. The appearance of anitem in a list warrants the inclusion ofthe item in the account mentioned



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only when the text of the account alsoindicates inclusion inasmuch as thesame item frequently appears in morethan one list. The proper entry in eachinstance must be determined by thetexts of the accounts.

7. Extraordinary items. It is the intentthat net income shall reflect all itemsof profit and loss during the periodwith the exception of prior period ad-justments as described in paragraph 7.1and long-term debt as described inparagraph 17 below. Those items relat-ed to the effects of events and trans-actions which have occurred during thecurrent period and which are of un-usual nature and infrequent occurrenceshall be considered extraordinaryitems. Accordingly, they will be eventsand transactions of significant effectwhich are abnormal and significantlydifferent from the ordinary and typicalactivities of the company, and whichwould not reasonably be expected torecur in the foreseeable future. (In de-termining significance, items should beconsidered individually and not in theaggregate. However, the effects of a se-ries of related transactions arisingfrom a single specific and identifiableevent or plan of action should be con-sidered in the aggregate.) To be consid-ered as extraordinary under the aboveguidelines, an item should be morethan approximately 5 percent of in-come, computed before extraordinaryitems. Commission approval must beobtained to treat an item of less than5 percent, as extraordinary. (See ac-counts 434 and 435.)

7.1 Prior period items. A. Items ofprofit and loss related to the followingshall be accounted for as prior periodadjustments and excluded from the de-termination of net income for the cur-rent year.

(1) Correction of an error in the fi-nancial statements of a prior year.

(2) Adjustments that result from re-alization of income tax benefits of pre-acquisition operating losscarryforwards of purchased subsidi-aries.

B. All other items of profit and lossrecognized during the year shall be in-cluded in the determination of net in-come for that year.

8. Unaudited items. Whenever a finan-cial statement is required by the Com-

mission, if it is known that a trans-action has occurred which affects theaccounts but the amount involved inthe transaction and its effect upon theaccounts cannot be determined withabsolute accuracy, the amount shall beestimated and such estimated amountincluded in the proper accounts. Theutility is not required to anticipateminor items which would not appre-ciably affect the accounts.

9. Distribution of pay and expenses ofemployees. The charges to gas plant, op-erating expense and other accounts forservices and expenses of employees en-gaged in activities chargeable to var-ious accounts, such as construction,maintenance, and operations, shall bebased upon the actual time engaged inthe respective classes of work, or incase that method is impracticable,upon the basis of a study of the timeactually engaged during a representa-tive period.

10. Payroll distribution. Underlying ac-counting data shall be maintained sothat the distribution of the cost oflabor charged direct to the various ac-counts will be readily available. Suchunderlying data shall permit a reason-ably accurate distribution to be madeof the cost of labor charged initially toclearing accounts so that the totallabor cost may be classified amongconstruction, cost of removal, gas oper-ating functions (manufactured gas pro-duction, natural gas production andgathering, products extraction, under-ground storage, transmission, distribu-tion, etc.), and nonutility operations.

11. Accounting to be on accrual basis.A. The utility is required to keep itsaccounts on the accrual basis. This re-quires the inclusion in its accounts ofall known transactions of appreciableamount which affect the accounts. Ifbills covering such transactions havenot been received or rendered, theamounts shall be estimated and appro-priate adjustments made when the billsare received.

B. When payments are made in ad-vance for items such as insurance,rents, taxes or interest, the amount ap-plicable to future periods shall becharged to account 165, Prepayments,and spread over the periods to whichapplicable by credits to account 165,



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and charges to the accounts appro-priate for the expenditure.

12. Records for each plant. A. Separaterecords shall be maintained by gasplant accounts of the book cost of eachplant owned, including additions by theutility to plant leased from others, andof the cost of operating and maintain-ing each plant owned or operated. Theterm ‘‘plant,’’ as here used, means eachmanufactured gas production plant,the wells and gathering lines of eachdistinct production area, each systemof interconnected transmission mains,each system of wells and lines of an un-derground storage project, each largepurification or dehydration plant, eachcompressor station, other than a dis-tribution compressor station, and eachproducts extraction plant.

B. A natural gas company may, withthe approval of the Commission, groupcertain of its systems of gatheringlines and wells, small compressor sta-tions, systems of underground storagelines and wells, and systems of inter-connected transmission mains for thepurpose of complying with the portionof this instruction requiring a segrega-tion of the cost of operating and main-taining each plant.

NOTE A: Where manufactured gas is pro-duced by two or more processes at one loca-tion, each process shall be accounted for sep-arately.

NOTE B: Each natural gas company shallmaintain operating or accounting records foreach well showing (a) acreage on whichdrilled, (b) dates of drilling period, (c) cost ofdrilling, (d) depth of well, (e) particulars anddepth of each stratum drilled through, (f) ge-ological formation from which gas is ob-tained, (g) initial rock pressure and openflow capacity, (h) sizes of casing used and thelengths of each size, (i) total cost of well asrecorded in gas plant accounts, (j) date wellabandoned, for wells once productive, (k)date transferred to underground storageplant, for wells converted to storage use, and(l) date drilling discontinued, for wells deter-mined to be nonproductive. The foregoingdata, as appropriate, shall also be main-tained for each subsequent change in thedepth of each well.

13. Accounting for other departments. Ifthe utility also operates other utilitydepartments, such as electric, water,etc., it shall keep such accounts for theother departments as may be pre-scribed by proper authority and in the

absence of prescribed accounts, it shallkeep such accounts as are proper ornecessary to reflect the results of oper-ating each such department. It is notintended that proprietary and similaraccounts which apply to the utility asa whole shall be departmentalized.

14. Transactions with associated compa-nies. Each utility shall keep its ac-counts and records so as to be able tofurnish accurately and expeditiouslystatements of all transactions with as-sociated companies. The statementsmay be required to show the generalnature of the transactions, theamounts involved therein and theamounts included in each account pre-scribed herein with respect to suchtransactions. Transactions with associ-ated companies shall be recorded in theappropriate accounts for transactionsof the same nature. Nothing hereincontained, however, shall be construedas restraining the utility from sub-dividing accounts for the purpose of re-cording separately transactions withassociated companies.

15. Contingent assets and liabilities.Contingent assets represent a possiblesource of value to the utility contin-gent upon the fulfillment of conditionsregarded as uncertain. Contingent li-abilities include items which mayunder certain conditions become obli-gations of the utility but which areneither direct nor assumed liabilitiesat the date of the balance sheet. Theutility shall be prepared to give a com-plete statement of significant contin-gent assets and liabilities (includingcumulative dividends on preferencestock) in its annual report and at suchother times as may be requested by theCommission.

16. [Reserved]17. Long-term debt: Premium, discount

and expense, and gain or loss on reacqui-sition— A. Premium, discount and ex-pense. A separate premium, discountand expense account shall be main-tained for each class and series of long-term debt (including receivers’ certifi-cates) issued or assumed by the utility.The premium will be recorded in ac-count 225, Unamortized Premium onLong-Term Debt, the discount will berecorded in account 226, UnamortizedDiscount on Long-Term Debt—Debit,



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and the expense of issuance shall be re-corded in account 181, UnamortizedDebt Expense.

The premium, discount and expenseshall be amortized over the life of therespective issues under a plan whichwill distribute the amounts equitablyover the life of the securities. The am-ortization shall be on a monthly basis,and amounts thereof relating to dis-count and expense shall be charged toaccount 428, Amortization of Debt Dis-count and Expense. The amounts relat-ing to premium shall be credited to ac-count 429, Amortization of Premium onDebt—Credit.

B. Reacquisition, without refunding.When long-term debt is reacquired orredeemed without being converted intoanother form of long-term debt andwhen the transaction is not in connec-tion with a refunding operation (pri-marily redemptions for sinking fundpurposes), the difference between theamount paid upon reacquisition andthe face value; plus any un- amortizedpremium less any related unamortizeddebt expense and reacquisition costs;or less any unamortized discount, re-lated debt expense and reacquisitioncosts applicable to the debt redeemed,retired and canceled, shall be includedin account 189, Unamortized Loss onReacquired Debt, or account 257,Unamortized Gain on Reacquired Debt,as appropriate. The utility shall amor-tize the recorded amounts equally on amonthly basis over the remaining lifeof the respective security issues (oldoriginal debt). The amounts so amor-tized shall be charged to account 428.1,Amortization of Loss on ReacquiredDebt, or credited to account 429.1, Am-ortization of Gain on ReacquiredDebt—Credit, as appropriate.

C. Reacquisition, with refunding. Whenthe redemption of one issue or series ofbonds or other long-term obligations isfinanced by another issue or series be-fore the maturity date of the firstissue, the difference between theamount paid upon refunding and theface value; plus any unamortized pre-mium less related debt expense or lessany unamortized discount and relateddebt expense, applicable to the debt re-funded, shall be included in account189, Unamortized Loss on ReacquiredDebt, or account 257, Unamortized Gain

on Reacquired Debt, as appropriate.The utility may elect to account forsuch amounts as follows:

(1) Write them off immediately whenthe amounts are insignificant.

(2) Amortize them by equal monthlyamounts over the remainder of theoriginal life of the issue retired, or

(3) Amortize them by equal monthlyamounts over the life of the new issue.

Once an election is made, it shall beapplied on a consistent basis. Theamounts in (1), (2), or (3) above shall becharged to account 428.1, Amortizationof Loss on Reacquired Debt, or creditedto account 429.1, Amortization of Gainon Reacquired Debt—Credit, as appro-priate.

D. Under methods (2) and (3) above,the increase or reduction in current in-come taxes resulting from the reacqui-sition should be apportioned over theremainder of the original life of theissue retired or over the life of the newissue, as appropriate, as directed morespecifically in paragraphs E and Fbelow.

E. When the utility recognizes theloss in the year of reacquisition as atax deduction, account 410.1, Provisionfor Deferred Income Taxes, Utility Op-erating Income, shall be debited andaccount 283, Accumulated Deferred In-come Taxes—Other, shall be creditedwith the amount of the related tax ef-fect, such amount to be allocated tothe periods affected in accordance withthe provisions of account 283.

F. When the utility chooses to recog-nize the gain in the year of reacquisi-tion as a taxable gain, account 411.1,Provision for Deferred Income Taxes—Credit, Utility Operating Income, shallbe credited and account 190, Accumu-lated Deferred Income Taxes, shall bedebited with the amount of the relatedtax effect, such amount to be allocatedto the periods affected in accordancewith the provisions of account 190.

G. When the utility chooses to usethe optional privilege of deferring thetax on the gain attributable to the re-acquisition of debt by reducing the de-preciable basis of utility property fortax purposes, pursuant to Section 108of the Internal Revenue Code, the re-lated tax effects shall be deferred asthe income is recognized for account-ing purposes, and the deferred amounts



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shall be amortized over the life of theassociated property on a vintage yearbasis. Account 410.1, Provision for De-ferred Income Taxes, Utility OperatingIncome, shall be debited, and account282, Accumulated Deferred IncomeTaxes—Other Property, shall be cred-ited with an amount equal to the esti-mated income tax effect applicable tothe portion of the income, attributableto reacquired debt, recognized for ac-counting purposes during the period.Account 282 shall be debited and ac-count 411.1, Provision for Deferred In-come Taxes—Credit, Utility OperatingIncome, shall be credited with anamount equal to the estimated incometax effects, during the life of the prop-erty, attributable to the reduction inthe depreciable basis for tax purposes.

H. The tax effects relating to gain orloss shall be allocated as above to util-ity operations except in cases where aportion of the debt reacquired is di-rectly applicable to nonutility oper-ations. In that event, the related por-tion of the tax effects shall be allo-cated to nonutility operations. Whereit can be established that reacquireddebt is generally applicable to bothutility and nonutility operations, thetax effects shall be allocated betweenutility and nonutility operations basedon the ratio of net investment in util-ity plant to net investment in non-utility plant.

I. Premium, discount, or expense ondebt shall not be included as an ele-ment in the cost of construction or ac-quisition of property (tangible or in-tangible), except under the provisionsof account 432, Allowance for BorrowedFunds Used During Construction—Credit.

J. Alternate method. Where a regu-latory authority or a group of regu-latory authorities having prime ratejur- isdiction over the utility specifi-cally disallows the rate principle ofamortizing gains or losses on reacquisi-tion of long-term debt without refund-ing, and does not apply the gain or lossto reduce interest charges in comput-ing the allowed rate of return for ratepurposes, then the following alternatemethod may be used to account forgains or losses relating to reacquisition

of long-term debt, with or without re-funding.

(1) The difference between theamount paid upon reacquisition of anylong-term debt and the face value, ad-justed for unamortized discount, ex-penses or premium, as the case may be,applicable to the debt redeemed shallbe recognized currently in income andrecorded in account 421, MiscellaneousNonoperating Income, or account 426.5,Other Deductions.

(2) When this alternate method of ac-counting is used, the utility shall in-clude a footnote to each financialstatement, prepared for public use, ex-plaining why this method is being usedalong with the treatment given forratemaking purposes.

18. Comprehensive interperiod incometax allocation. A. Where there are tim-ing differences between the periods inwhich transactions affect taxable in-come and the periods in which theyenter into the determination of pretaxaccounting income, the income tax ef-fects of such transactions are to be rec-ognized in the periods in which the dif-ferences between book accounting in-come and taxable income arise and inthe periods in which the differences re-verse using the deferred tax method. Ingeneral, comprehensive interperiod taxallocation should be followed whenevertransactions enter into the determina-tion of pretax accounting income forthe period even though some trans-actions may affect the determinationof taxes payable in a different period,as further qualified below.

B. Utilities are not required to utilizecomprehensive interperiod income taxallocation until the deferred incometaxes are included as an expense in therate level by the regulatory authorityhaving rate jurisdiction over the util-ity. Where comprehensive interperiodtax allocation accounting is not prac-ticed the utility shall include as a noteto each financial statement, preparedfor public use, a footnote explanationsetting forth the utility’s accountingpolicies with respect to interperiod taxallocation and describing the treat-ment for ratemaking purposes of thetax timing differences by regulatoryauthorities having rate jurisdiction.



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C. Should the utility be subject tomore than one agency having rate ju-risdiction, its accounts shall appro-priately reflect the ratemaking treat-ment (deferral or flow through) of e-each jurisdiction.

D. Once comprehensive interperiodtax allocation has been initiated eitherin whole or in part it shall be practicedon a consistent basis and shall not bechanged or discontinued without priorCommission approval.

E. Tax effects deferred currently willbe recorded as deferred debits or de-ferred credits in accounts 190, Accumu-lated Deferred Income Taxes, 281, Accu-mulated Deferred Income Taxes—Ac-celerated Amortization Property, 282,Accumulated Deferred Income Taxes—Other Property, and 283, AccumulatedDeferred Income Taxes—Other, as ap-propriate. The resulting amounts re-corded in these accounts shall be dis-posed of as prescribed in this system ofaccounts or as otherwise authorized bythe Commission.

19. Criteria for classifying leases. A. Ifat its inception a lease meets one ormore of the following criteria, thelease shall be classified as a capitallease. Otherwise, it shall be classifiedas an operating lease.

(1) The lease transfers ownership ofthe property to the leasee by the end ofthe lease term.

(2) The lease contains a bargain pur-chase option.

(3) The lease term is equal to 75 per-cent or more of the estimated eco-nomic life of the leased property. How-ever, if the beginning of the lease termfalls within the last 25 percent of thetotal estimated economic life of thelease property, including earlier yearsof use, this criterion shall not be usedfor purposes of classifying the lease.

(4) the present value at the beginningof the lease term of the minimum leasepayments, excluding that portion ofthe payments representing executorycosts such as insurance, maintenance,and taxes to be paid by the lessor, in-cluding any profit thereon, equals orexceeds 90 percent of the excess of thefair value of the leased property to thelessor at the inception of the lease overany related investment tax credit re-tained by the lessor and expected to berealized by the lessor. However, if the

beginning of the lease term falls withinthe last 25 percent of the total esti-mated economic life of the lease prop-erty, including earlier years of use,this criterion shall not be used for pur-poses of classifying the lease. The les-see utility shall compute the presentvalue of the minimum lease paymentsusing his incremental borrowing raate,unless (a) it is practicable for the util-ity to learn the implicit rate computedby the lessor, and (b) the implicit ratecomputed by the lessor is less than thelessee’s incremental borrowing rate. Ifboth of those conditions are met, thelessee shall use the implicit rate.

B. If at any time the lessee and lessoragree to change the provisions of thelease, other than by renewing the leaseor extending its term, in a manner thatwould have resulted in a different clas-sification of the lease under the cri-teria in paragraph A had the changedterms been in effect at the inception ofthe lease, the revised agreement shallbe considered as a new agreement overits term, and the criteria in paragraphA shall be applied for purposes ofclassifying the lease. Likewise, any ac-tion that extends the lease beyond theexpiration of the existing lease term,such as the exercise of a lease renewaloption other than those already in-cluded in the lease term, shall be con-sidered as a new agreement, and shallbe classified according to the aboveprovisions, Changes in estimates (forexample, changes in estimates of theeconomic life or of the residual valueof the leased property) or changes incircumstances (for example, default bythe lessee), shall not give rise to a newclassification of a lease for accountingpurposes.

20. Accounting for leases. A. All leasesshall be classified as either capital oroperating leases. The accounting forcapitalized leases is effective January1, 1984, except for the retroactive clas-sification of certian leases which, inaccordance with FASB No. 71, will notbe required to be capitalized until aftera three year transition period. For thepurpose of reporting to the FERC, thetransition period shall be deemed toend December 31, 1986.

B. The utility shall record a capitallease as an asset in account 101.1, Prop-erty under Capital Leases (or account



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121, Non-utility Property, if appro-priate), and an obligation in account227, Obligations under Capital Leases—Noncurrent, or account 243, Obligationsunder Capital Leases—Current, at anamount equal to the present value atthe beginning of the lease term of min-imum lease payments during the leaseterm, excluding that portion of thepayments representing executory costssuch as insurance, maintenance, andtaxes to be paid by the lessor, togetherwith any profit thereon. However, ifthe amount so determined exceeds thefair value of the leased property at theinception of the lease, the amount re-corded as the asset and obligation shallbe the fair value.

C. Rental payments on all leasesshall be charged to rent expense, fuelexpense, construction work in progress,or other appropriate accounts as theybecome payable.

D. For a capital lease, for each periodduring the lease term, the amounts re-corded for the asset and obligationshall be reduced by an amount equal tothe portion of each lease paymentwhich would have been allocated to thereduction of the obligation, if the pay-ment had been treated as a payment onan installment obligation (liability)and allocated between interest expenseand a reduction of the obligation so asto produce a constant periodic rate ofinterest on the remaining balance.

21. Gas well records. Each utility withnatural gas operations shall maintainoperating or accounting records foreach well showing: (a) Acreage onwhich drilled, (b) dates of drilling pe-riod, (c) cost of drilling, (d) depth ofwell, (e) particulars and depth of eachstratum drilled through, (f) geologicalformation from which gas is obtained,(g) initial rock pressure and open flowcapacity, (h) sizes of casing used andlengths of each size, (i) total cost ofwell as recorded in gas plant accounts,(j) date well abandoned, for wells onceproductive, (k) date transferred to un-derground storage plant, for wells con-verted to storage use, and (l) date drill-ing discontinued, for wells determinedto be nonproductive. The foregoingdata, as appropriate, shall also bemaintained for each subsequent changein the depth of each well.

Gas Plant Instructions

1. Classification of gas plant at the ef-fective date of the system of accounts.

A. The gas plant accounts providedherein are generally the same as thosecontained in the prior system of ac-counts except for some changes in clas-sification in the general equipment ac-counts. Except for these changes, thebalances in the various plant accounts,as determined under the prior systemof accounts, should be carried forward.Any remaining balance of plant whichhas not yet been classified pursuant tothe requirements of the prior system,shall be classified in accordance withthe following instructions.

B. The cost to the utility of its un-classified plant shall be ascertained byanalysis of the utility’s records. Ad-justments shall not be made to recordin utility plant accounts amounts pre-viously charged to operating expensesor to income deductions in accordancewith the uniform system of accounts ineffect at the time or in accordancewith the discretion of management asexercised under a uniform system ofaccounts, or under accounting prac-tices previously followed.

C. The detailed gas plant accounts(301 to 399, inclusive) shall be stated onthe basis of cost to the utility of plantconstructed by it and the original cost,estimated if not known, of plant ac-quired as an operating unit or system.The difference between the originalcost as above, and the cost to the util-ity of gas plant after giving effect toany accumulated provision for depre-ciation, depletion, or amortizationshall be recorded in account 114, GasPlant Acquisition Adjustments. Theoriginal cost of gas plant shall be de-termined by analysis of the utility’srecords or those of the predecessor orvendor companies with respect to gasplant previously acquired as operatingunits or systems and the differences be-tween the original cost so determined,less accumulated provisions for depre-ciation, depletion and amortization,and the cost to the utility, with nec-essary adjustments for retirementsfrom the date of acquisition, shall beentered in account 114, Gas Plant Ac-quisition Adjustments. Any differencebetween the cost of gas plant and its



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book cost, when not properly includ-able in other accounts, shall be re-corded in account 116, Other Gas PlantAdjustments.

D. Plant acquired by lease whichqualifies as capital lease propertyunder General Instruction 19. Criteriafor Classifying Leases, shall be recordedin Account 101.1, Property under Cap-ital Leases.

2. Gas plant to be recorded at cost. A.All amounts included in the accountsfor gas plant acquired as an operatingunit or system, except as otherwiseprovided in the texts of the intangibleplant accounts, shall be stated at thecost incurred by the person who firstdevoted the property to utility service.All other gas plant shall be included inthe accounts at the cost incurred bythe utility, except for property ac-quired by lease which qualifies as cap-ital lease property under General In-struction 19. Criteria for ClassifyingLeases, and is recorded in Account101.1, Property under Capital Leases.Where the term ‘‘cost’’ is used in thedetailed plant accounts, it shall havethe meaning stated in this paragraph.

B. When the consideration given forproperty is other than cash, the valueof such consideration shall be deter-mined on a cash basis. (See, however,definition 8.) In the entry recordingsuch transaction, the actual consider-ation shall be described with sufficientparticularity to identify it. The utilityshall be prepared to furnish the Com-mission the particulars of its deter-mination of the cash value of the con-sideration if other than cash.

C. When property is purchased undera plan involving deferred payments, nocharge shall be made to the gas plantaccounts for interest, insurance, orother expenditures occasioned solelyby such form of payment.

D. The gas plant accounts shall notinclude the cost or other value of gasplant contributed to the company. Con-tributions in the form of money or itsequivalent toward the construction ofgas plant shall be credited to the ac-counts charged with the cost of suchconstruction. Plant constructed fromcontributions of cash or its equivalentshall be shown as a reduction to grossplant constructed when assemblingcost data in work orders for posting to

plant ledger of accounts. The accumu-lated gross costs of plant accumulatedin the work order shall be recorded asa debit in the plant ledger of accountsalong with the related amount of con-tributions concurrently being recordedas a credit.

3. Components of construction cost. A.The cost of construction properly in-cludable in the gas plant accounts shallinclude, where applicable, the directand overhead costs as listed and de-fined hereunder:

(1) ‘‘Contract work’’ includesamounts paid for work performedunder contract by other companies,firms, or individuals, costs incident tothe award of such contracts, and theinspection of such work.

(2) ‘‘Labor’’ includes the pay and ex-penses of employees of the utility en-gaged on construction work, and relat-ed workmen’s compensation insurance,payroll taxes and similar items of ex-pense. It does not include the pay andexpenses of employees which are dis-tributed to construction through clear-ing accounts nor the pay and expensesincluded in other items hereunder.

(3) ‘‘Materials and supplies’’ includesthe purchase price at the point of freedelivery plus customs duties, excisetaxes, the cost of inspection, loadingand transportation, the related storesexpenses, and the cost of fabricatedmaterials from the utility’s shop. Indetermining the cost of materials andsupplies used for construction, properallowance shall be made for unusedmaterials and supplies, for materialsrecovered from temporary structuresused in performing the work involved,and for discounts allowed and realizedin the purchase of materials and sup-plies.

NOTE: The cost of individual items ofequipment of small value (for example, $500or less) or of short life, including small port-able tools and implements, shall not becharged to utility plant accounts unless thecorrectness of the accounting therefor isverified by current inventories. The costshall be charged to the appropriate operatingexpense or clearing accounts, according tothe use of such items, or, if such items areconsumed directly in construction work, thecost shall be included as part of the cost ofthe construction.



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(4) ‘‘Transportation’’ includes thecost of transporting employees, mate-rials and supplies, tools, purchasedequipment, and other work equipment(when not under own power) to andfrom points of construction. It includesamounts paid to others as well as thecost of operating the utility’s owntransportation equipment. (See item 5following.)

(5) ‘‘Special machine service’’ in-cludes the cost of labor (optional), ma-terials and supplies, depreciation, andother expenses incurred in the mainte-nance, operation and use of special ma-chines, such as steam shovels, piledrivers, derricks, ditchers, scrapers,material unloaders, and other laborsaving machines; also expenditures forrental maintenance and operation ofmachines of others. It does not includethe cost of small tools and other indi-vidual items of small value or shortlife which are included in the cost ofmaterials and supplies. (See item 3,above.) When a particular constructionjob requires the use for an extended pe-riod of time of special machines, trans-portation or other equipment, the netbook cost thereof, less the appraised orsalvage value at time of release fromthe job, shall be included in the cost ofconstruction.

(6) ‘‘Shop service’’ includes the pro-portion of the expense of the utility’sshop department assignable to con-struction work except that the cost offabricated materials from the utility’sshop shall be included in ‘‘materialsand supplies.’’

(7) ‘‘Protection’’ includes the cost ofprotecting the utility’s property fromfire or other casualties and the cost ofpreventing damages to others, or to theproperty of others, including paymentsfor discovery or extinguishment offires, cost of apprehending and pros-ecuting incendiaries, witness fees in re-lation thereto, amounts paid to mu-nicipalities and others for fire protec-tion, and other analogous items of ex-penditures in connection with con-struction work.

(8) ‘‘Injuries and damages’’ includesexpenditures or losses in connectionwith the construction work on accountof injuries to persons and damages tothe property of others; also the cost ofinvestigation of and defense against ac-

tions for such injuries and damages. In-surance recovered or recoverable on ac-count of compensation paid for injuriesto persons incident to constructionshall be credited to the account or ac-counts to which such compensation ischarged. Insurance recovered or recov-erable on account of property damagesincident to construction shall be cred-ited to the account or accountscharged with the cost of the damages.

(9) ‘‘Privileges and permits’’ includespayments for and expenses incurred insecuring temporary privileges, permitsor rights in connection with construc-tion work, such as for the use of pri-vate or public property, streets, orhighways, but it does not include rents,or amounts chargeable as franchisesand consents for which see account 302,Franchises and Consents.

(10) ‘‘Rents’’ includes amounts paidfor the use of construction quartersand office space occupied by construc-tion forces and amounts properly in-cludible in construction costs for suchfacilities jointly used.

(11) ‘‘Engineering and supervision’’includes the portion of the pay and ex-penses of engineers, surveyors,draftsmen, inspectors, superintendentsand their assistants applicable to con-struction work.

(12) ‘‘General administration capital-ized’’ includes the portion of the payand expenses of the general officers andadministrative and general expensesapplicable to construction work.

(13) ‘‘Engineering services’’ includesamounts paid to other companies,firms, or individuals engaged by theutility to plan, design, prepare esti-mates, supervise, inspect, or give gen-eral advice and assistance in connec-tion with construction work.

(14) ‘‘Insurance’’ includes premiumspaid or amounts provided or reservedas self-insurance for the protectionagainst loss and damages in connectionwith construction, by fire or other cas-ualty, injury to or death of personsother than employees, damages toproperty of others, defalcation of em-ployees and agents, and the non-performance of contractual obligationsof others. It does not include work-men’s compensation or similar insur-ance on employees included as ‘‘labor’’in item 2, above.



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(15) ‘‘Law expenditures’’ includes thegeneral law expenditures incurred inconnection with construction and thecourt and legal costs directly relatedthereto, other than law expenses in-cluded in protection, item 7, and in in-juries and damages, item 8.

(16) ‘‘Taxes’’ includes taxes on phys-ical property (including land) duringthe period of construction and othertaxes properly includible in construc-tion costs before the facilities becomeavailable for service.

(17) ‘‘Allowance for funds used duringconstruction’’ includes the net cost forthe period of construction of borrowedfunds used for construction purposesand a reasonable rate on other fundswhen so used, not to exceed withoutprior approval of the Commission al-lowances computed in accordance withthe formula prescribed in paragraph (a)below, except when such other fundsare used for exploration and develop-ment or leases acquired after October7, 1969, no allowance on such otherfunds shall be included in these ac-counts. No allowance for funds usedduring construction charges shall beincluded in these accounts upon ex-penditures for construction projectswhich have been abandoned.

(a) The formula and elements for thecomputation of the allowance for fundsused during construction shall be:

A s SW

d DD+P+C

SW

A SW

p PD+P+C

c CD+P+C

i

e

= ⎛⎝

⎞⎠ + ⎛

⎝⎞⎠ −⎛⎝

⎞⎠

= −⎡⎣⎢

⎤⎦⎥

⎛⎝

⎞⎠ + ⎛

⎝⎞⎠

⎡⎣⎢

⎤⎦⎥

1

1

Ai=Gross allowance for borrowed funds usedduring construction rate.

Ae=Allowance for other funds used duringconstruction rate.

S=Average short-term debt.s=Short-term debt interest rate.D=Long-term debt.d=Long-term debt interest rate.P=Preferred stock.p=Preferred stock cost rate.C=Common equity.c=Common equity cost rate.W=Average balance in construction work in

progress.

(b) The rates shall be determined an-nually. The balances for long-term

debt, preferred stock and common eq-uity shall be the actual book balancesas of the end of the prior year. The costrates for long-term debt and preferredstock shall be the weighted averagecost determined in the manner indi-cated in subpart D of part 154 of theCommission’s Regulations Under theNatural Gas Act. The cost rate forcommon equity shall be the rate grant-ed common equity in the last rate pro-ceeding before the ratemaking bodyhaving primary rate jurisdiction. Ifsuch cost rate is not available, the av-erage rate actually earned during thepreceding three years shall be used.The short-term debt balances and re-lated cost and the average balance forconstruction work in progress shall beestimated for the current year with ap-propriate adjustments as actual databecomes available.

NOTE: When a part only of a plant orproject is placed in operation or is completedand ready for service but the constructionwork as a whole is incomplete, that part ofthe cost of the property placed in operation,or ready for service, shall be treated as ‘‘GasUtility Plant’’ and allowance for funds usedduring construction thereon as a charge toconstruction shall cease. Allowance for fundsused during construction on that part of thecost of the plant which is incomplete may becontinued as a charge to construction untilsuch time as it is placed in operation or isready for service, except as limited in item17, above.

(18) ‘‘Earnings and expenses duringconstruction’’ includes (a) all revenuesderived during the construction periodfrom property which is included in thecost of a project under constructionand (b) all expenses which are attrib-utable to the revenues received.

(19) ‘‘Training costs’’. When it is nec-essary that employees be trained to op-erate or maintain plant facilities thatare being constructed and such facili-ties are not conventional in nature orare new to the company’s operations,these costs may be capitalized as acomponent of construction cost. Onceplant is placed in service, the capital-ization of training costs shall cease,and subsequent training costs shall beexpensed. (See Operating Expense In-struction 4.)

(20) ‘‘Line pack gas.’’ Line pack in-cludes the first cost of that quantity of



513


gas introduced into the utility’s sys-tem necessary to bring the system upto its designed operating capacity orincreases therein and which must bemaintained in the system in order tosustain such design operating capacity.

(21) LNG ‘‘heel’’ is the first cost ofthat minimum quantity of liquefiednatural gas necessary to be retained inholding tanks and other facilities forpurposes of temperature and/or pres-sure maintenance.

(22) ‘‘Studies’’ includes the costs ofstudies such as operational, safety orenvironmental studies relative to plantunder construction. Studies mandatedby regulatory bodies relative to facili-ties in service, shall be charged to Ac-count 183.2, Other Preliminary Surveyand Investigation Charges.

4. Overhead construction costs. A. Alloverhead construction costs, such asengineering, supervision, general officesalaries and expenses, construction en-gineering and supervision by othersthan the accounting utility, law ex-penses, insurance, injuries and dam-ages, relief and pensions, taxes and in-terest, shall be charged to particularjobs or units on the basis of theamounts of such overheads reasonablyapplicable thereto, to the end that eachjob or unit shall bear its equitable pro-portion of such costs and that the en-tire cost of the unit, both direct andoverhead, shall be deducted from theplant accounts at the time the prop-erty is retired.

B. As far as practicable, the deter-mination of pay roll charges includiblein construction overheads shall bebased on time card distributions there-of. Where this procedure is impractical,special studies shall be made periodi-cally of the time of supervisory em-ployees devoted to construction activi-ties to the end that only such overheadcosts as have a definite relation to con-struction shall be capitalized. The ad-dition to direct construction costs ofarbitrary percentages or amounts tocover assumed overhead costs is notpermitted.

C. The record supporting the entriesfor overhead construction costs shallbe so kept as to show the total amountof each overhead for each year, the na-ture and amount of each overhead ex-penditure charged to each construction

work order and to each utility plantaccount, and the bases of distributionof such costs.

5. Gas plant purchased or sold. A.When gas plant constituting an operat-ing unit or system is acquired by pur-chase, merger, consolidation, liquida-tion, or otherwise, after the effectivedate of this system of accounts, thecosts of acquisition, including expensesincidental thereto properly includiblein gas plant, shall be charged to ac-count 102, Gas Plant Purchased or Sold.

B. The accounting for the acquisitionshall then be completed as follows:

(1) The original cost of plant, esti-mated if not known, shall be creditedto account 102, Gas Plant Purchased orSold, and concurrently charged to theappropriate gas plant in service ac-counts and to account 104, Gas PlantLeased to Others, account 105, GasPlant Held for Future Use, 105.1, Pro-duction Properties Held for FutureUse, and account 107, ConstructionWork in Progress—Gas, as appropriate.

(2) The depreciation, depletion, andamortization applicable to the originalcost of the properties purchased, shallbe charged to account 102, Gas PlantPurchased or Sold, and concurrentlycredited to the appropriate account foraccumulated provision for deprecia-tion, depletion or amortization.

(3) The cost to the utility of anyproperty includible in account 121,Nonutility Property, shall be trans-ferred thereto.

(4) The amount remaining in account102, Gas Plant Purchased or Sold, shallthen be closed to account 114, GasPlant Acquisition Adjustments.

C. If property acquired in the pur-chase of an operating unit or system isin such physical condition when ac-quired that it is necessary substan-tially to rehabilitate it in order tobring the property up to the standardsof the utility, the cost of such work,except replacements, shall be ac-counted for as a part of the purchaseprice of the property.

D. When any property acquired as anoperating unit or system includes du-plicate or other plant which will be re-tired by the accounting utility in thereconstruction of the acquired propertyor its consolidation with previously



514


owned property, the proposed account-ing for such property shall be presentedto the Commission.

E. In connection with the acquisitionof gas plant constituting an operatingunit or system, the utility shall pro-cure, if possible, all existing records re-lating to the property acquired, or cer-tified copies thereof, and shall preservesuch records in conformity with regu-lations or practices governing the pres-ervation of records of its own construc-tion.

F. When gas plant constituting anoperating unit or system is sold, con-veyed, or transferred to another bysale, merger, consolidation, or other-wise, the book cost of the property soldor transferred to another shall be cred-ited to the appropriate utility plant ac-counts, including amounts carried inaccount 114, Gas Plant Acquisition Ad-justments. The amounts (estimated ifnot known) carried with respect there-to in the accounts for accumulated pro-vision for depreciation, depletion, andamortization and in account 252, Cus-tomer Advances for Construction, shallbe charged to such accounts and thecontra entries made to account 102,Gas Plant Purchased or Sold. Unlessotherwise ordered by the Commission,the difference, if any, between (a) thenet amount of debits and credits and(b) the consideration received for theproperty (less commissions and otherexpenses of making the sale) shall beincluded in account 421.1, Gain on Dis-position of Property, or account 421.2,Loss on Disposition of Property. (Seeaccount 102, Gas Plant Purchased orSold.)

NOTE: In cases where existing utilitiesmerge or consolidate because of financial oroperating reasons or statutory requirementsrather than as a means of transferring titleof purchased properties to a new owner, theaccounts of the constituent utilities, withthe approval of the Commission, may becombined. In the event original cost has notbeen determined, the resulting utility shallproceed to determine such cost as outlinedherein.

6. Expenditures on leased property. A.The cost of substantial initial improve-ments (including repairs, rearrange-ments, additions, and betterments)made in the course of preparing forutility service property leased for a pe-riod of more than one year, and the

cost of subsequent substantial addi-tions, replacements, or betterments tosuch property, shall be charged to thegas plant account appropriate for theclass of property leased. If the servicelife of the improvements is terminableby action of the lease, the cost, less netsalvage, of the improvements shall bespread over the life of the lease bycharges to account 404.3, Amortizationof Other Limited-Term Gas Plant.However, if the service life is not ter-minated by action of the lease but bydepreciation proper, the cost of the im-provements, less net salvage, shall beaccounted for as depreciable plant. Theprovisions of this paragraph are appli-cable to property leased under eithercapital leases or operating leases.

B. If improvements made to propertyleased for a period of more than oneyear are of relatively minor cost, or ifthe lease is for a period of not morethan one year, the cost of the improve-ments shall be charged to the accountin which the rent is included, either di-rectly or by amortization thereof.

7. Land and land rights. A. The ac-counts for land and land rights shallinclude the cost of land owned in fee bythe utility and rights, interests, andprivileges held by the utility in landowned by others, such as leaseholds,easements, rights-of-way, natural gasrights, and other like interests in land.Do not include in the accounts for landand land rights and rights-of-way costsincurred in connection with first clear-ing and grading of land and rights-of-way and the damage costs associatedwith the construction and installationof plant. Such costs shall be includedin the appropriate plant accounts di-rectly benefited.

B. Where special assessments for pub-lic improvements provide for deferredpayments, the full amount of the as-sessments shall be charged to the ap-propriate land account and the unpaidbalance shall be carried in an appro-priate liability account. Interest on un-paid balances shall be charged to theappropriate interest account. If anypart of the cost of public improvementis included in the general tax levy, theamount thereof shall be charged to theappropriate tax account.

C. The net profit from the sale oftimber, cord wood, sand, gravel, other



515


resources or other property acquiredwith the rights-of-way or other landsshall be credited to the appropriateplant account to which related. Whereland is held for a considerable period oftime and timber and other natural re-sources on the land at the time of pur-chase increases in value, the net profit(after giving effect to the cost of thenatural resources) from the sales oftimber or its products or other naturalresources shall be credited to the ap-propriate utility operating income ac-count when such land has been re-corded in account 105, Gas Plant Heldfor Future Use, account 105.1, Produc-tion Properties Held for Future Use, orclassified as plant in service otherwiseto account 421, Miscellaneous Non-operating Income.

D. Separate entries shall be made forthe acquisition, transfer, or retirementof each parcel of land, and each landright, or gas right (except rights-of-way for distribution mains), having alife of more than one year. A recordshall be maintained showing the natureof ownership, full legal description,area, map reference, purpose for whichused, city, county, and tax district inwhich situated, from whom purchasedor to whom sold, payment given or re-ceived, other costs, contract date andnumber, date of recording of deed, andbook and page of record. Entries trans-ferring or retiring land or land rightsshall refer to the original entry record-ing its acquisition. A parcel of land ac-quired and carried on the books as aunit is not required to be subdividedwith transfers to other land accountsmerely because of the erection thereonof an incidental structure to be used ingas operations but for a purpose differ-ing from that for which the land ischiefly employed; for example, a smallstorehouse on production plant land.

E. Any difference between theamount received from the sale of landor land rights, less agents’ commis-sions and other costs incident to thesale, and the book cost of such land orrights shall be included in account411.6, Gains from Disposition of UtilityPlant or 411.7, Losses from Dispositionof Utility Plant when such propertyhas been recorded in account 105, GasPlant Held for Future Use, 105.1, Pro-duction Properties Held for Future

Use, otherwise to account 421.1, Gainon Disposition of Property or 421.2,Loss on Disposition of Property, as ap-propriate, unless a reserve therefor hasbeen authorized and provided. Appro-priate adjustments of the accountsshall be made with respect to anystructures or improvements located onland sold.

F. The cost of buildings and otherimprovements (other than public im-provements) shall not be included inthe land accounts. If at the time of ac-quisition of an interest in land such in-terest extends to buildings or other im-provements (other than public im-provements), which are then devoted toutility operations, the land and im-provements shall be separately ap-praised and the cost allocated to landand buildings or improvements on thebasis of the appraisals. If the improve-ments are removed or wrecked withoutbeing used in operations, the cost of re-moving or wrecking shall be chargedand the salvage credited to the accountin which the cost of the land is re-corded.

G. When the purchase of land for gasoperations requires the purchase ofmore land than needed for such pur-poses, the charge to the specific landaccount shall be based upon the cost ofthe land purchased, less the fair mar-ket value of that portion of the landwhich is not to be used in utility oper-ations. The portion of the cost meas-ured by the fair market value of theland not to be used shall be included inaccount 105, Gas Plant Held for FutureUse or, account 121, Nonutility Prop-erty, as appropriate. Regarding landand land rights held for the productionof natural gas, account 101, Gas Plantin Service, shall include (1) the cost oflands owned in fee upon which produc-ing natural gas wells are located onlands owned in fee which are beingdrained through the operation by theutility of wells on the other land, and(2) the first cost of lands held underlease upon which the utility pays roy-alties for the natural gas obtainedtherefrom. The cost of all other landand land rights held for the productionof natural gas under a plant for suchuse shall be included in account 105,Gas Plant Held for Future Use, or 105.1,



516


Production Properties Held for FutureUse, as appropriate.

NOTE: In addition to the accountingrecords prescribed herein, supplementalrecords of land and land rights held for fu-ture use shall be kept in such manner as topermit the segregation within a reasonabletime of the land and land rights constituting(1) productive but nonproducing fields, (2)unproven or undeveloped fields, and (3) stor-age fields, and to show the following datawith respect to each natural gas lease, re-gardless of the accounting treatment ac-corded the lease costs; (a) name of lessor, (b)location of leasehold and number or otheridentification assigned thereto, (c) date andperiod of lease agreement, (d) first cost oflease including details of the elements ofsuch cost, (e) annual rental provisions, (f)date and cost of drilling, (g) date gas deter-mined to exist, (h) date of completion of firstwell drilled by the utility in each pool of gas,(i) royalty provisions, (j) amortization anddepletion provisions, and (k) date of aban-donment of lease.

H. Provision shall be made for amor-tizing amounts carried in the accountsfor limited-term interests in land, so asto apportion equitably the cost of eachinterest over the life thereof. For thepurposes of amortization of natural gasrights, separate interests in land whichcomprise an interest in a productionarea may be grouped to form a deple-tion unit. (See account 111, Accumu-lated Provision for Amortization andDepletion of Gas Utility Plant, account404.1, Amortization and Depletion ofProducing Natural Gas Land and LandRights, account 404.3, Amortization ofOther Limited-Term Gas Plant, and ac-count 797, Abandonment, leases.)

I. The items of cost to be included inthe accounts for land and land rightsare as follows:

1. Bulkheads, buried, not requiring mainte-nance or replacement.

2. Cost, first, of acquisition includingmortgages and other liens assumed (but notsubsequent interest thereon).

3. [Reserved]4. Condemnation proceedings, including

court and counsel costs.5. Consents and abutting damages, pay-

ment for.6. Conveyancers’ and notaries’ fees.7. Fees, commissions, and salaries to bro-

kers, agents, and others in connection withthe acquisition of the land or land rights.

8. [Reserved]

9. Leases, cost of voiding upon purchase tosecure possession of land.

10. Removing, relocating, or reconstruct-ing, property of others, such as buildings,highways, railroads, bridges, cemeteries,churches, telephone and power lines, etc., inorder to acquire quiet possession.

11. Retaining walls unless identified withstructures.

12. Special assessments levied by public au-thorities for public improvements on thebasis of benefits for new roads, new bridges,new sewers, new curbing, new pavements,and other public improvements, but nottaxes levied to provide for the maintenanceof such improvements.

13. Surveys in connection with the acquisi-tion, but not amounts paid for topographicalsurveys and maps where such costs are at-tributable to structures or plant equipmenterected or to be erected or installed on suchland.

14. Taxes assumed, accrued to date oftransfer of title.

15. Title, examining, clearing, insuring,and registering in connection with the acqui-sition and defending against claims relatingto the period prior to the acquisition.

16. Appraisals prior to closing title.17. Cost of dealing with distributees or

legatees residing outside of the state orcounty, such as recording power of attorney,recording will or exemplification of will, re-cording satisfaction of state tax.

18. Filing satisfaction of mortgage.19. Documentary stamps.20. Photographs of property at acquisition.21. Fees and expenses incurred in the ac-

quisition of water rights, and grants.22. Cost of fill to extend bulkhead line over

land under water, where riparian rights areheld, which is not occasioned by the erectionof a structure.

23. Sidewalks and curbs constructed by theutility on public property.

24. Labor and expenses in connection withsecuring rights of way, where performed bycompany employees and company agents.

8. Structures and improvements. A. Theaccounts for structures and improve-ments shall include the cost of allbuildings and facilities to house, sup-port, or safeguard property or persons,including all fixtures permanently at-tached to and made a part of buildingsand which cannot be removed there-from without cutting into the walls,ceilings, or floors, or without in someway impairing the buildings, and im-provements of a permanent characteron or to land. Also include those costsincurred in connection with the firstclearing and grading of land and rights-



517


of-way, and the damage costs associ-ated with construction and installationof plant.

B. The cost of specially providedfoundations not intended to outlast themachinery or apparatus for which pro-vided, and the cost of angle irons, cast-ings, etc., installed at the base of anitem of equipment, shall be charged tothe same account as the cost of themachinery, apparatus, or equipment.

C. Minor buildings and structuresmay be considered a part of the facilityin connection with which constructedor operated and the cost thereof ac-counted for accordingly when the na-ture of the structure and facility indi-cates the correctness of such account-ing.

D. Where furnaces and boilers areused primarily for furnishing steam forsome particular department and onlyincidentally for furnishing steam forheating a building and operating theequipment therein, the entire cost ofsuch furnaces and boilers shall becharged to the appropriate plant ac-count, and no part to the building ac-count.

E. The cost of disposing of materialsexcavated in connection with construc-tion of structures shall be consideredas a part of the cost of such work, ex-cept as follows: (a) When such materialis used for filling, the cost of loading,hauling, and dumping shall be equi-tably apportioned between the work inconnection with which the removal oc-curs and the work in connection withwhich the material is used; (b) whensuch material is sold, the net amountrealized from such sales shall be cred-ited to the work in connection withwhich the removal occurs. If theamount realized from the sale of exca-vated materials exceeds the removalcosts and the costs in connection withthe sale, the excess shall be credited tothe land account in which the site iscarried.

F. Lighting or other fixtures tempo-rarily attached to buildings for pur-poses of display or demonstration shallnot be included in the cost of the build-ing but in the appropriate equipmentaccount.

G. The items of cost to be included inthe accounts for structures and im-provements are as follows:

1. Architects’ plans and specifications in-cluding supervision.

2. Ash pits (when located within the build-ing).

3. Athletic field structures and improve-ments.

4. Boilers, furnaces, piping, wiring, fix-tures, and machinery for heating, lighting,signaling, ventilating, and air conditioningsystems, plumbing, vacuum cleaning sys-tems, incinerator and smoke pipe, flues, etc.

5. Bulkheads, including dredging, riprapfill, piling, decking, concrete, fenders, etc.,when exposed and subject to maintenanceand replacement.

6. Chimneys.7. Coal bins and bunkers.8. Commissions and fees to brokers, agents,

architects and others.9. Conduit (not to be removed) with its

contents.10. Damages to abutting property during

construction.11. Docks.12. Door checks and door stops.13. Drainage and sewerage systems.14. Elevators, cranes, hoists, etc., and the

machinery for operating them.15. Excavation, including shoring, bracing,

bridging, refill, and disposal of excess exca-vated material, cofferdams around founda-tion, pumping water from cofferdam duringconstruction, and test borings.

16. Fences and fence curbs (not includingprotective fences insolating items of equip-ment, which shall be charged to the appro-priate equipment account).

17. Fire protection systems when forming apart of a structure.

18. Flagpole.19. Floor covering (permanently attached).20. Foundations and piers for machinery,

constructed as a permanent part of a build-ing or other items listed herein.

21. Grading and clearing when directly oc-casioned by the building of a structure.

22. Holders—Relief.23. Intrasite communication system, poles,

pole fixtures, wires and cables.24. Landscaping, lawns, shrubbery, etc.25. Leases, voiding upon purchase to secure

possession of structures.26. Leased property, expenditures on.27. Lighting fixtures and outside lighting

system.28. Mailchutes when part of a building.29. Marquee, permanently attached to

building.30. Painting, first coat.31. Permanent paving, concrete, brick,

flagstone, asphalt, etc. within the propertylines.

32. Partitions, including movable.33. Permits and privileges.34. Platforms, railings and gratings when

constructed as a part of a structure.35. Power boards for services to a building.



518


36. Refrigerating systems for general use.37. Retaining walls except when identified

with land.38. Roadways, railroads, bridges, and tres-

tles, intrasite, except railroads provided forin equipment accounts.

39. Roofs.40. Scales, connected to and forming a part

of a structure.41. Screens.42. Sewer systems, for general use.43. Sidewalks, culverts, curbs and streets

constructed by the utility on its property.44. Sprinkling systems.45. Sump pumps and pits.46. Stacks—brick, steel, or concrete, when

set on foundation forming part of generalfoundation and steelwork of a building.

47. Steel inspection during construction.48. Storage facilities constituting a part of

a building.49. Storm doors and windows.50. Subways, areaways, and tunnels, di-

rectly connected to and forming part of astructure.

51. Tanks, constructed as part of a buildingor as a distinct structural unit.

52. Temporary heating during construction(net cost).

53. Temporary water connection duringconstruction (net cost).

54. Temporary shanties and other facilitiesused during construction (net cost).

55. Topographical maps.56. Tunnels, intake and discharge, when

constructed as part of a structure, includingsluice gates, and those constructed to housemains.

57. Vaults constructed as part of a build-ing.

58. Watchmen’s sheds and clock systems(net cost when used during constructiononly).

59. Water basins or reservoirs.60. Water front improvements.61. Water meters and supply system for a

building or for general company purposes.62. Water supply piping, hydrants and

wells.63. Wharves.64. Window shades and ventilators.65. Yard drainage system.66. Yard lighting system.67. Yard surfacing, gravel, concrete, or oil

(First cost only).NOTE: Structures and Improvements ac-

counts shall be credited with the cost of coalbunkers, stacks, foundations, subways, tun-nels, etc., the use of which has terminatedwith the removal of the equipment withwhich they are associated even though theyhave not been physically removed.

9. Equipment. A. The cost of equip-ment chargeable to the gas plant ac-counts, unless otherwise indicated in

the text of an equipment account, in-cludes the net purchase price thereof,sales taxes, investigation and inspec-tion expenses necessary to such pur-chase, expenses of transportation whenborne by the utility, labor employed,materials and supplies consumed, andexpenses incurred by the utility in un-loading and placing the equipment inreadiness to operate. Also includethose costs incurred in connection withthe first clearing and grading of landand rights-of-way and the damage costsassociated with construction and in-stallation of plant.

B. Exclude from equipment accountshand and other portable tools whichare likely to be lost or stolen or whichhave relatively small value (for exam-ple, $500 or less) or short life, unlessthe correctness of the accountingtherefor as gas plant is verified by cur-rent inventories. Special tools acquiredand included in the purchase price ofequipment shall be included in the ap-propriate plant account. Portable drillsand similar tool equipment when usedin connection with the operation andmaintenance of a particular plant ordepartment, such as production, trans-mission, distribution, etc., or in‘‘stores,’’ shall be charged to the plantaccount appropriate for their use.

C. The equipment accounts shall in-clude angle irons and similar itemswhich are installed at the base of anitem of equipment, but piers and foun-dations which are designed to be aspermanent as the buildings whichhouse the equipment, or which are con-structed as a part of the building andwhich cannot be removed without cut-ting into the walls, ceilings or floors orwithout in some way impairing thebuilding, shall be included in the build-ing accounts.

D. The equipment accounts shall in-clude the necessary costs of testing orrunning a plant or part thereof duringan experimental or test period prior tobecoming available for service. Theutility shall furnish the Commissionwith full particulars of and justifica-tion for any test or experimental runextending beyond a period of thirtydays.

E. The cost of efficiency or othertests made subsequent to the date



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equipment becomes available for serv-ice shall be charged to the appropriateexpense accounts, except that tests todetermine whether equipment meetsthe specifications and requirements asto efficiency, performance, etc., guar-anteed by manufacturers, made afteroperations have commenced and withinthe period specified in the agreementor contract of purchase, may becharged to the appropriate gas plantaccount.

10. Additions and retirements of gasplant.

A. For the purpose of avoiding unduerefinement in accounting for additionsto and retirements and replacements ofgas plant, all property shall be consid-ered as consisting of (1) retirementunits and (2) minor items of property.Each utility shall maintain a writtenproperty units listing for use in ac-counting for additions and retirementsof gas plant and apply the listing con-sistently.

B. The addition and retirement of re-tirement units shall be accounted foras follows:

(1) When a retirement unit is addedto gas plant, the cost thereof shall beadded to the appropriate gas plant ac-count, except that when units are ac-quired in the acquisition of any gasplant constituting an operating sys-tem, they shall be accounted for as pro-vided in gas plant instruction 5.

(2) When a retirement unit is retiredfrom gas plant, with or without re-placement, the book cost thereof shallbe credited to the gas plant account inwhich it is included, determined in themanner set forth in paragraph D,below. If the retirement unit is of a de-preciable class, the book cost of theunit retired and credited to gas plantshall be charged to the accumulatedprovision for depreciation applicable tosuch property. The cost of removal andthe salvage shall be charged or cred-ited, as appropriate, to such deprecia-tion account.

C. The addition and retirement ofminor items of property shall be ac-counted for as follows:

(1) When a minor item of propertywhich did not previously exist is addedto plant, the cost thereof shall be ac-counted for in the same manner as forthe addition of a retirement unit, as

set forth in paragraph B(1), above, if asubstantial addition results, otherwisethe charge shall be to the appropriatemaintenance expense account.

(2) When a minor item of property isretired and not replaced, the book costthereof shall be credited to the gasplant account in which it is included;and, in the event the minor item is apart of depreciable plant, the accountfor accumulated provision for deprecia-tion shall be charged with the bookcost and cost of removal and creditedwith the salvage. If, however, the bookcost of the minor item retired and notreplaced has been or will be accountedfor by its inclusion in the retirementunit of which it is a part when suchunit is retired, no separate credit tothe property account is required whensuch minor item is retired.

(3) When a minor item of depreciableproperty is replaced independently ofthe retirement unit of which it is apart, the cost of replacement shall becharged to the maintenance accountappropriate for the item, except that ifthe replacement effects a substantialbetterment (the primary aim of whichis to make the property affected moreuseful, more efficient, or of greater du-rability, or of greater capacity), the ex-cess cost of the replacement over theestimated cost at current prices of re-placing without betterment shall becharged to the appropriate gas plantaccount.

D. The book cost of gas plant retiredshall be the amount at which suchproperty is included in the gas plantaccounts, including all components ofconstruction costs. The book cost shallbe determined from the utility’srecords and if this cannot be done itshall be estimated. Utilities must fur-nish the particulars of such estimatesto the Commission, if requested. Whenit is impracticable to determine thebook cost of each unit, due to the rel-atively large number or small costthereof, an appropriate average bookcost of the units, with due allowancefor any differences in size and char-acter, shall be used as the book cost ofthe units retired.

E. The book cost of land retired shallbe credited to the appropriate land ac-count. If the land is sold, the difference



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between the book cost (less any accu-mulated provision for depreciation, de-pletion or amortization therefor whichhas been authorized and provided) andthe sale price of the land (less commis-sions and other expenses of making thesale) shall be recorded in account 411.6,Gains from Disposition of Utility Plantor 411.7, Losses from Disposition ofUtility Plant when the property hasbeen recorded in account 105, Gas PlantHeld for Future Use account 105.1, Pro-duction Properties Held for FutureUse, otherwise to accounts 421.1, Gainon Disposition of Property or 421.2,Loss on Disposition of Property, as ap-propriate. If the land is not used inutility service but is retained by theutility, the book cost shall be chargedto account 105, Gas Plant Held for Fu-ture Use, or account 121, NonutilityProperty as appropriate.

F. The book cost less net salvage ofdepreciable gas plant retired shall becharged in its entirety to account 108.Accumulated Provision for Deprecia-tion of Gas Plant in Service. Anyamounts which, by approval or order ofthe Commission, are charged to ac-count 182, Extraordinary PropertyLosses, shall be credited to account 108.

G. The accounting for the retirementof amounts included in account 302,Franchises and Consents, and account303, Miscellaneous Intangible Plant,and the item of limited-term interestin land included in the accounts forland and land rights, shall be as pro-vided for in the text of account 111, Ac-cumulated Provision for Amortizationand Depletion of Gas Utility Plant, ac-count 404.3, Amortization of OtherLimited-Term Gas Plant, and account405, Amortization of Other Gas Plant.

11. Work order and property record sys-tem required. A. Each utility shallrecord all construction and retirementsof gas plant by means of work orders orjob orders. Separate work orders maybe opened for additions to and retire-ments of gas plant or the retirementsmay be included with the constructionwork order, provided, however, that allitems relating to the retirements shallbe kept separate from those relating toconstruction and provided, further,that any maintenance costs involved inthe work shall likewise be segregated.

B. Each utility shall keep its workorder system so as to show the natureof each addition to or retirement of gasplant, the total cost thereof, the sourceor sources of costs, and the gas plantaccount or accounts to which chargedor credited. Work orders covering jobsof short duration may be clearedmonthly.

C. Each utility shall maintainrecords in which, for each plant ac-count, the amounts of the annual addi-tions and retirements are classified soas to show the number and cost of thevarious record units or retirementunits.

12. Transfers of property. When prop-erty is transferred from one gas plantaccount to another, from one utilitydepartment to another (such as fromgas to electric), from one operating di-vision or area to another, to or fromaccount 101, Gas Plant in Service, 104,Gas Plant Leased to Others, 105, GasPlant Held for Future Use, 105.1, Pro-duction Properties held for Future Use,and 121, Nonutility Property, the trans-fer shall be recorded by transferringthe original cost thereof from the oneaccount, department, or location to theother. Any related amounts carried inthe accounts for accumulated provi-sions for depreciation, depletion, oramortization shall be transferred in ac-cordance with the segregation of suchaccounts.

NOTE Amounts included in account 111, Ac-cumulated Provision for Amortization andDepletion of Gas Utility Plant, shall not berelated to a particular natural gas lease, andtherefore, shall not be transferred under theprovisions of this instruction.

13. Common utility plant. A. If the util-ity is engaged in more than one utilityservice such as gas, electric, and water,and any of its utility plant is used incommon for several utility services orfor other purposes to such an extentand in such manner that it is imprac-ticable to segregate it by utility serv-ices currently in the accounts, suchproperty, with the approval of theCommission, may be designated andclassified as ‘‘common utility plant.’’

B. The book amount of utility plantdesignated as common plant shall beincluded in account 118, Other UtilityPlant, and if applicable in part to gas



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department, shall be segregated and ac-counted for in subaccounts as gas plantis accounted for in accounts 101 to 107,inclusive, and gas plant adjustments inaccount 116; any amounts classifiableas common plant acquisition adjust-ments or common plant adjustmentsshall be subject to disposition as pro-vided in paragraph C and B of accounts114 and 116, respectively, for amountsclassified in those accounts. The origi-nal cost of common utility plant inservice shall be classified according todetailed utility plant accounts appro-priate for the property.

C. The utility shall be prepared toshow at any time and to report to theCommission annually, or more fre-quently, if required, and by utilityplant accounts (301 to 399) the follow-ing: (1) The book cost of common util-ity plant, (2) the allocation of such costto the respective departments usingthe common utility plant, and (3) thebasis of the allocation.

D. The accumulated provision for de-preciation and amortization of the util-ity shall be segregated so as to showthe amount applicable to the propertyclassified as common utility plant.

E. The expenses of operation mainte-nance, rents, depreciation and amorti-zation of common utility plant shall berecorded in the accounts prescribedherein, but designated as common ex-penses, and the allocation of such ex-penses to the departments using thecommon utility plant shall be sup-ported in such manner as to reflectreadily the basis of allocation used.

14. Employee villages and living quar-ters. Where employee villages or livingquarters are provided for operators andattendants of a functional installationsuch as a compressor station or gaso-line plant, the structures and improve-ments shall be classified in the relatedfunctional structures and improve-ments account. The furnishings of suchresidential and recreational facilitiesshall be classified in the equipment ac-count of the related function.

15. Fees for applications filed with theCommission. A. Fees for applications in-volving construction of property shallbe accounted for as follows:

(1) All fees paid prior to the final dis-position of the certificate application

shall be charged to account 186, Mis-cellaneous Deferred Debits.

(2) If the certificate is granted andaccepted, the amounts recorded in ac-count 186 shall be cleared to account107, Construction Work in Progress—Gas, and subsequently cleared to theappropriate plant accounts.

(3) If the certificate requested is notgranted or is not accepted by the appli-cant, the fees recorded in account 186shall be cleared to account 928, Regu-latory Commission Expenses.

(4) All amounts paid after the Com-mission has granted the certificateshall be recorded in account 107, Con-struction Work in Progress—Gas, andsubsequently cleared to the appro-priate plant accounts.

B. All amounts paid related to cer-tificate applications involving the ac-quisitions of facilities including thoseacquired by merger or pooling of inter-ests shall be charged to account 928,Regulatory Commission Expenses.

C. All other fees for applications notinvolving construction or acquisitionof facilities shall be charged to account928, Regulatory Commission Expenses.

Operating Expense Instructions

1. Supervision and engineering. The su-pervision and engineering includible inthe operating expense accounts shallconsist of the pay and expenses of su-perintendents, engineers, clerks, otheremployees and consultants engaged insupervising and directing the operationand maintenance of each utility func-tion. Wherever allocations are nec-essary in order to arrive at the amountto be included in any account themethod and basis of allocation shall bereflected by underlying records.

ITEMS

Labor:1. Special tests to determine efficiency of

equipment operation.2. Preparing or reviewing budgets, esti-

mates, and drawings relating to operation ormaintenance for departmental approval.

3. Preparing instructions for operationsand maintenance activities.

4. Reviewing and analyzing operating re-sults.

5. Establishing organizational setup of de-partments and executing changes therein.

6. Formulating and reviewing routines ofdepartments and executing changes therein.



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7. General training and instruction of em-ployees by supervisors whose pay is charge-able hereto. Specific instruction and train-ing in a particular type of work is chargeableto the appropriate functional account. (SeeGas Plant Instruction 3(19).)

8. Secretarial work for supervisory person-nel, but not general clerical and steno-graphic work chargeable to other accounts.Expenses:

9. Consultants’ fees and expenses.10. Meals, traveling and incidental ex-

penses.

2. Maintenance. A. The cost of main-tenance chargeable to the various oper-ating expense and clearing accounts,includes labor, materials, overheadsand other expenses incurred in mainte-nance work. A list of work operationsapplicable generally to utility plant isincluded hereunder. Other work oper-ations applicable to specific classes ofplant are listed in functional mainte-nance expense accounts.

B. Materials recovered in connectionwith the maintenance of property shallbe credited to the same account towhich the maintenance cost wascharged.

C. If the book cost of any property iscarried in account 102, Gas Plant Pur-chased or Sold, the cost of maintainingsuch property shall be charged to theaccounts for maintenance of propertyof the same class and use, the bookcost of which is carried in other gasplant in service accounts. Maintenanceof property leased from others shall betreated as provided in operating ex-pense instruction 3.

ITEMS

1. Direct field supervision of maintenance.2. Inspecting, testing, and reporting on

condition of plant specifically to determinethe need for repairs, replacements, re-arrangements and changes and inspectingand testing the adequacy of repairs whichhave been made.

3. Work performed specifically for the pur-pose of preventing failure, restoring service-ability or maintaining life of plant.

4. Rearranging and changing the locationof plant not retired.

5. Repairing for reuse materials recoveredfrom plant.

6. Testing for, locating and clearing trou-ble.

7. Net cost of installing, maintaining, andremoving temporary facilities to preventinterruptions in service.

8. Replacing or adding minor items of plantwhich do not constitute a retirement unit.(See gas plant instruction 10.)

3. Rents. A. The rent expense ac-counts provided under the several func-tional groups of expense accounts shallinclude all rents, including taxes paidby the lessee on leased property, forproperty used in utility operations, ex-cept (1) minor amounts paid for occa-sional or infrequent use of any prop-erty or equipment and all amountspaid for use of equipment that, ifowned, would be includible in plant ac-counts 391 to 398, inclusive, which shallbe treated as an expense item and in-cluded in the appropriate functionalaccount and (2) rents which are charge-able to clearing accounts, and distrib-uted therefrom to the appropriate ac-count. If rents cover property used formore than one function, such as pro-duction and transmission, or by morethan one department, the rents shall beapportioned to the appropriate rent ex-pense or clearing accounts of each de-partment on an actual, or, if necessary,an estimated basis.

B. When a portion of property orequipment rented from others for usein connection with utility operations issubleased, the revenue derived fromsuch subleasing shall be credited to therent revenue account in operating reve-nues: Provided, however, That in casethe rent was charged to a clearing ac-count, amounts received from subleas-ing the property shall be credited tosuch clearing account.

C. The cost, when incurred by the les-see, of operating and maintainingleased property, shall be charged to theaccounts appropriate for the expense ifthe property were owned.

D. The cost incurred by the lessee ofadditions and replacements to gasplant leased from other shall be ac-counted for as provided in gas plant in-struction 6.

4. Training costs. When it is necessarythat employees be trained to specifi-cally operate or maintain plant facili-ties that are being constructed, the re-lated costs shall be accounted for as acurrent operating and maintenance ex-pense. These expenses shall be chargedto the appropriate functional accountscurrently as they are incurred. How-ever, when the training costs involved



523


relate to facilities which are not con-ventional in nature, or are new to thecompany’s operations, then see GasPlant Instruction 3(19) for accounting.

Balance Sheet Chart of Accounts

ASSETS AND OTHER DEBITS

1. UTILITY PLANT

101 Gas plant in service.101.1 Property under capital leases.102 Gas plant purchased or sold.103 Experimental gas plant unclassified.104 Gas plant leased to others.105 Gas plant held for future use.105.1 Production properties held for future

use.106 Completed construction not classified—

Gas.107 Construction work in progress—Gas.108 Accumulated provision for depreciation

of gas utility plant.109 [Reserved]111 Accumulated provision for amortization

and depletion of gas utility plant.111.1—111.2 [Reserved]112 [Reserved]113.1—113.2 [Reserved]114 Gas plant acquisition adjustments.115 Accumulated provision for amortization

of gas plant acquisition adjustments.116 Other gas plant adjustments.117.1 Gas stored-Base gas.117.2 System balancing gas.117.3 Gas stored in reservoirs and pipelines-

noncurrent.117.4 Gas owed to system gas.118 Other utility plant.119 Accumulated provision for depreciation

and amortization of other utility plant.

2. OTHER PROPERTY AND INVESTMENTS

121 Nonutility property.122 Accumulated provision for depreciation

and amortization of nonutility property.123 Investment in associated companies.123.1 Investment in subsidiary companies.124 Other investments.125 Sinking funds.126 Depreciation fund.128 Other special funds.

3. CURRENT AND ACCRUED ASSETS

131 Cash.132 Interest special deposits.133 Dividend special deposits.134 Other special deposits.135 Working funds.136 Temporary cash investments.141 Notes receivable.142 Customer accounts receivable.143 Other accounts receivable.144 Accumulated provision for uncollectible

accounts—Cr.

145 Notes receivable from associated com-panies.

146 Accounts receivable from associatedcompanies.

151 Fuel stock.152 Fuel stock expenses undistributed.153 Residuals and extracted products.154 Plant materials and operating supplies

(Major only).155 Merchandise.156 Other materials and supplies.163 Stores expense undistributed.164.1 Gas stored—current.164.2 Liquefied natural gas stored.164.3 Liquefied natural gas held for process-

ing.165 Prepayments.166 Advances for gas exploration, develop-

ment, and production.167 Other advances for gas.171 Interest and dividends receivable.172 Rents receivable.173 Accrued utility revenues.174 Miscellaneous current and accrued as-

sets.

4. DEFERRED DEBITS

181 Unamortized debt expense.182.1 Extraordinary property losses.182.2 Unrecovered plant and regulatory

study costs.182.3 Other regulatory assets.183.1 Preliminary natural gas survey and

investigation charges.183.2 Other preliminary survey and inves-

tigation charges.184 Clearing accounts.185 Temporary facilities.186 Miscellaneous deferred debits.187 Deferred losses from disposition of util-

ity plant.188 Research, development, and demonstra-

tion expenditures.189 Unamortized loss on reacquired debt.190 Accumulated deferred income taxes.191 Unrecovered purchased gas costs.

LIABILITIES AND OTHER CREDIT

5. PROPRIETARY CAPITAL

201 Common stock issued.202 Common stock subscribed.203 Common stock liability for conversion.204 Preferred stock issued.205 Preferred stock subscribed.206 Preferred stock liability for conversion.207 Premium on capital stock.208 Donations received from stockholders.209 Reduction in par or stated value of cap-

ital stock.210 Gain on resale or cancellation of reac-

quired capital stock.211 Miscellaneous paid-in capital.212 Installments received on capital stock.213 Discount on capital stock.214 Capital stock expense.215 Appropriated retained earnings.



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216 Unappropriated retained earnings.216.1 Unappropriated undistributed subsidi-

ary earnings.217 Reacquired capital stock.

6. LONG–TERM DEBT

221 Bonds.222 Reacquired bonds.223 Advances from associated companies.224 Other long-term debt.225 Unamortized premium on long-term

debt.226 Unamortized discount on long-term

debt—Debit.

7. OTHER NONCURRENT LIABILITIES.

227 Obligations under capital leases—non-current.

228.1 Accumulated provision for propertyinsurance.

228.2 Accumulated provision for injuriesand damages.

228.3 Accumulated provision for pensionsand benefits.

228.4 Accumulated miscellaneous operatingprovisions.

229 Accumulated provision for rate refunds.

8. CURRENT AND ACCRUED LIABILITIES

231 Notes payable.232 Accounts payable.233 Notes payable to associated companies.234 Accounts payable to associated compa-

nies.235 Customer deposits.236 Taxes accrued.237 Interest accrued.238 Dividends declared.239 Matured long-term debt.240 Matured interest.241 Tax collections payable.242 Miscellaneous current and accrued li-

abilities.243 Obligations under capital leases—cur-

rent.

9. DEFERRED CREDITS

252 Customer advances for construction.253 Other deferred credits.254 Other regulatory liabilities.255 Accumulated deferred investment tax

credits.256 Deferred gains from disposition of util-

ity plant.257 Unamortized gain on reacquired debt.281 Accumulated deferred income taxes—

Accelerated amortization property.282 Accumulated deferred income taxes—

Other property.283 Accumulated deferred income taxes—

Other.

Balance Sheet Accounts

101 Gas plant in service.

A. This account shall include theoriginal cost of gas plant, included inaccounts 301 to 399 prescribed herein,owned and used by the utility in its gasoperations, and having an expectationof life in service of more than one yearfrom date of installation. Includingsuch property owned by the utility butheld by nominees. (See also account 106for unclassified construction costs ofcompleted plant actually in service.)

B. The cost of additions to and bet-terments of property leased from oth-ers, which are includible in this ac-count, shall be recorded in subdivisionsseparate and distinct from those relat-ing to owned property. (See gas plantinstruction 6.)

101.1 Property under capital leases.

A. This account shall include theamount recorded under capital leasesfor plant leased from others and usedby the utility in its utility operations.

B. The gas property included in thisaccount shall be classified separatelyaccording to the detailed accounts (301to 399) prescribed for gas plant in serv-ice.

C. Records shall be maintained withrespect to each capital lease reflecting:(1) Name of lessor, (2) basic details oflease, (3) terminal date, (4) originalcost fair market value of propertyleased, (5) future minimum lease pay-ments, (6) executory costs, (7) presentvalue of minimum lease payments, (8)the amounts representing interest andthe interest rate used, and (9) expensespaid.

102 Gas plant purchased or sold.

A. This account shall be charged withthe cost of gas plant acquired as an op-erating unit or system by purchase,merger, consolidation, liquidation, orotherwise, and shall be credited withthe selling price of like property trans-ferred to others pending the distribu-tion to appropriate accounts in accord-ance with gas plant instruction 5.

B. Within six months from the dateof acquisition or sale of property re-corded herein, the utility shall filewith the Commission the proposed



525


journal entries to clear from this ac-count the amounts recorded herein.

103 Experimental gas plant unclassi-fied.

A. This account shall include thecost of gas plant which was con-structed as a research, development,and demonstration project under theprovisions of paragraph C, Account 107,Construction Work in Progress—Gas,and due to the nature of the plant it isdesirous to operate it for a period oftime in an experimental status.

B. Amounts in this account shall betransferred to Account 101, Gas Plantin Service, or Account 121, NonutilityProperty, as appropriate, when theproject is no longer considered as ex-perimental. Prior to transfer to ac-count 101 the subject plant must becertified by the Commission for use asgas plant in service.

C. The depreciation on property inthis account shall be charged to Ac-count 403, Depreciation Expense, andcredited to Account 108, AccumulatedProvision for Depreciation of Gas Util-ity Plant. The amounts herein shall bedepreciated over a period which wouldcorrespond to the estimated useful lifeof the relevant project considering theexperimental characteristics involved.However, when projects are transferredto Account 101, Gas Plant in Service, anew depreciation rate based on the re-maining service life and undepreciatedamounts, will be established.

D. Records shall be maintained withrespect to each unit of experiment sothat full details may be obtained as tothe cost, depreciation, and the experi-mental status.

E. Should it be determined that ex-perimental plants recorded in this ac-count will fail to satisfactorily performits function, the costs thereof shall beaccounted for as directed or authorizedby the Commission.

104 Gas plant leased to others.A. This account shall include the

original cost of gas plant owned by theutility but leased to others as operat-ing units or systems, where the lesseehas exclusive possession.

B. The property included in this ac-count shall be classified according tothe detailed accounts (301 to 399) pre-

scribed for gas plant in service and thisaccount shall be maintained in such de-tail as though the property were usedby the owner in its utility operations.

105 Gas plant held for future use.

A. This account shall include theoriginal cost of gas plant (except landand land rights) owned and held for fu-ture use in gas service under a definiteplan for such use, to include: (1) Prop-erty acquired (except land and landrights) but never used by the utility ingas service, but held for such service inthe future under a definite plan, and (2)property (except land and land rights)previously used by the utility in gasservice, but retired from such serviceand held pending its reuse in the fu-ture, under a definite plan, in gas serv-ice. This includes production propertiesrelating to leases acquired on or beforeOctober 7, 1969.

B. This account shall also include theoriginal cost of land and land rightsowned and held for future use in gasservice relating to leases acquired onor before October 7, 1969, under a planfor such use, to include land and landrights: (1) Acquired but never used bythe utility in gas service, but held forsuch service in the future under a plan,and (2) previously held by the utility ingas service, but retired from such serv-ice and held pending its reuse in the fu-ture under a plan, in gas service. (SeeGas Plant Instruction 7.)

C. In the event that property re-corded in this account shall no longerbe needed or appropriate for futureutility operations, the company shallrequest Commission approval of jour-nal entries to remove such propertyfrom this account when the gain real-ized from the sale or other dispositionof the property is $100,000 or more,prior to their being recorded. Such fil-ings shall include the description andoriginal cost of individual propertiesremoved from this account, the ac-counts charged upon removal, and anyassociated gains realized upon disposi-tion of such property.

D. Gains or losses from the sale ofland and land rights or other disposi-tion of such property previously re-corded in this account and not placed



526


in utility service shall be recorded di-rectly in accounts 411.6 or 411.7, as ap-propriate, except when determined tobe significant by the Commission.Upon such a determination, theamounts shall be transferred to ac-count 256, Deferred Gains from Disposi-tion of Utility Plant, or account 187,Deferred Losses from Disposition ofUtility Plant, and amortized to ac-counts 411.6, Gains from Disposition ofUtility Plant, or 411.7, Losses from Dis-position of Utility Plant, as appro-priate.

E. The property included in this ac-count shall be classified according tothe detail accounts (301 to 399) pre-scribed for gas plant in service and theaccount shall be maintained in such de-tail as though the property were inservice.

NOTE A: Materials and supplies, meters andhouse regulators held in reserve, and normalspare capacity of plant in service shall notbe included in this account.

NOTE B: Include in this account naturalgas wells shut in after construction whichhave not been connected with the line; also,natural gas wells which have been connectedwith the line but which are shut in for anyreason except seasonal excess capacity orgovernmental proration requirements or forrepairs, provided that the related productionleases were acquired on or before October 7,1969.

NOTE C (NONMAJOR ONLY): The loss onabandonment of natural gas leases acquiredafter October 7, 1969, shall be charged to Ac-count 338, Unsuccessful Exploration and De-velopment Costs.

105.1 Production properties held forfuture use.

A. This account shall include thecost of production properties (exceptland and land rights) relating to leasesacquired on or after October 8, 1969,held under a definite plan for futureuse to insure a future supply of naturalgas for use in pipeline operations, toinclude: (1) Production property (ex-cept land and land rights) acquired butnever used by the utility in gas service,but held for such service in the futureunder a definite plan, and (2) produc-tion property (except land and landrights) previously used by the utilityin gas service, but retired from suchservice and held pending its reuse inthe future, under a definite plan, in gasservice.

B. This account shall also include theoriginal cost of land and land rightsheld under a plan for future use to in-sure a future supply of natural gas foruse in pipeline operations, relating toleases acquired on or after October 8,1969, to include land and land rights: (1)Acquired but never used by the utilityin gas service, but held for service inthe future under a plan, and (2) pre-viously used by the utility in gas serv-ice, but retired from such service andheld pending its reuse in the futureunder a plan, in gas service. (See GasPlant Instruction 7.)

C. In the event that property re-corded in this account shall no longerbe needed or appropriate for futureutility operations, the company shallrequest Commission approval of jour-nal entries to remove such propertyfrom this account when the gain real-ized from the sale or other dispositionof the property is $100,000 or more,prior to their being recorded. Such fil-ings shall include the description andoriginal cost of individual propertiesremoved from this account, the ac-counts charged upon removal, and anyassociated gains realized upon disposi-tion of such property.

D. Gains or losses from the sale ofland and land rights or other disposi-tion of such property previously re-corded in this account and not placedin utility service shall be recorded di-rectly in accounts 411.6 or 411.7, as ap-propriate, except when determined tobe significant by the Commission.Upon such determination, the amountsshall be transferred to account 256, De-ferred Gains from Sale of Utility Plant,or account 187, Deferred Losses fromSale of Utility Plant, and amortized toaccounts 411.6, Gains from Dispositionof Utility Plant or 411.7, Losses fromDisposition of Utility Plant, as appro-priate.

E. The property included in this ac-count shall be classified according tothe detailed accounts prescribed fornatural gas production and gatheringplant in service and such classificationshall be maintained in the same detailas though the property were in serv-ice.

NOTE: Unsuccessful exploration and devel-opment costs incurred on leases acquired



527


after October 7, 1969, shall be charged to ac-count 338, Unsuccessful Exploration and De-velopment Costs.

106 Completed construction not classi-fied—Gas.

At the end of the year or such otherdate as a balance sheet may be re-quired by the Commission, this ac-count shall include the total of the bal-ances of work orders for gas plantwhich have been completed and placedin service but which work orders havenot been classified for transfer to thedetailed gas plant accounts.

NOTE: For the purpose of reporting to theCommission the classification of gas plant inservice by accounts is required, the utilityshall also report the balance in this accounttentatively classified as accurately as prac-ticable according to prescribed account clas-sifications. The purpose of this provision isto avoid any significant omissions in re-ported amounts of gas plant in service.

107 Construction work in progress—Gas.

A. This account shall include thetotal of the balances of work orders forgas plant in process of construction.

B. Work orders shall be cleared fromthis account as soon as practicableafter completion of the job. Further, ifa project, such as a gas productionplant, a compressor station, or a trans-mission line, is designed to consist oftwo or more units which may be placedin service at different dates, any ex-penditures which are common to andwhich will be used in the operation ofthe project as a whole shall be includedin gas plant in service upon the com-pletion and the readiness for service ofthe first unit. Any expenditures whichare identified exclusively with units ofproperty not yet in service shall be in-cluded in this account.

C. Expenditures on research, develop-ment, and demonstration projects forconstruction of utility facilities are tobe included in a separate subdivision inthis account. Records must be main-tained to show separately each projectalong with complete detail of the na-ture and purpose of the research, devel-opment, and demonstration project to-gether with the related costs.

NOTE A: This account shall include certifi-cate application fees paid to the Federal En-

ergy Regulatory Commission as provided forin gas plant instruction 15.

NOTE B: Unsuccessful exploration and de-velopment costs incurred on leases acquiredafter October 7, 1969, shall be transferred toaccount 338, Unsuccessful Exploration andDevelopment Costs.

108 Accumulated provision for depre-ciation of gas utility plant.

A. This account shall be creditedwith the following:

(1) Amounts charged to account 403,Depreciation Expense, or to clearingaccounts for current depreciation ex-pense for gas plant in service.

(2) Amounts charged to account 421,Miscellaneous Nonoperating Income,for depreciation expense on propertyincluded in account 105, Gas Plant Heldfor Future Use, or 105.1, ProductionProperties Held for Future Use. Includealso, the balance of accumulated provi-sion for depreciation on property whentransferred to account 105 or 105.1,from other property accounts. Nor-mally, account 108 will not be used forcurrent depreciation provisions be-cause, as provided herein, the servicelife during which depreciation is com-puted commences with the date prop-erty is includible in gas plant in serv-ice; however, if special circumstancesindicate the propriety of current accru-als for depreciation, such charges shallbe made to account 421, MiscellaneousNonoperating Income.

(3) Amounts charged to account 413,Expenses of Gas Plant Leased to Oth-ers, for gas plant included in account104, Gas Plant Leased to Others.

(4) Amounts charged to account 416,Costs and Expenses of Merchandising,Jobbing and Contract Work, or toclearing accounts for current deprecia-tion expense.

(5) Amounts of depreciation applica-ble to gas properties acquired as oper-ating units or systems. (See gas plantinstruction 5.)

(6) Amounts charged to account 182.1,Extraordinary Property Losses, whenauthorized by the Commission.

(7) Amounts of depreciation applica-ble to gas plant donated to the utility.(The utility shall maintain separatesubaccounts for depreciation applicableto gas plant in service, gas plant leased



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to others and gas plant held for futureuse.)

B. At the time of retirement of depre-ciable gas utility plant, this accountshall be charged with the book cost ofthe property retired and the cost of re-moval and shall be credited with thesalvage value and any other amountsrecovered, such as insurance. When re-tirements, cost of removal and salvageare entered originally in retirementwork orders, the net total of such workorders may be included in a separatesubaccount hereunder. Upon comple-tion of the work order, the proper dis-tribution to subdivision of this accountshall be made as provided in the follow-ing paragraph.

C. For general ledger and balancesheet purposes, this account shall beregarded and treated as a single com-posite provision for depreciation. Forpurposes of analysis, however, eachutility shall maintain subsidiaryrecords in which this account is seg-regating according to the followingfunctional classification for gas plant:

(1) Production—manufactured gas, (2)production and gathering—natural gas,(3) products extraction—natural gas,(4) underground gas storage, (5) otherstorage, (6) base load LNG terminalingand processing plant, (7) transmission,(8) distribution, and (9) general. Thesesubsidiary records shall reflect the cur-rent credits and debits to this accountin sufficient detail to show separatelyfor each such functional classification(a) the amount of provision for depre-ciation, (b) the book cost of propertyretired, (c) cost of removal, (d) salvage,and (e) other items, including recover-ies from insurance.

D. When transfers of plant are madefrom one gas plant account to another,or from or to another utility depart-ment, or from or to nonutility propertyaccounts, the accounting for the relat-ed accumulated provision for deprecia-tion shall be as provided in gas plantinstruction 12.

E. The utility is restricted in its useof the provision for depreciation to thepurposes set forth above. It shall nottransfer any portion of this account toretained earnings or make any otheruse thereof without authorization bythe Commission.

109 [Reserved]

111 Accumulated provision for amorti-zation and depletion of gas utilityplant.

A. This account shall be creditedwith the following:

(1) Amounts charged to account 404.1,Amortization and Depletion of Produc-ing Natural Gas Land and Land Rights,for current amortization and depletionof such land and land rights.

(2) Amounts charged to account 404.2,Amortization of Underground StorageLand and Land Rights, for current am-ortization.

(3) Amounts charged to account 404.3,Amortization of Other Limited-TermGas Plant, for the current amortiza-tion of limited-term gas plant.

(4) Amounts charged to account 421,Miscellaneous Nonoperating Income,for amortization expense on propertyincluded in account 105, Gas Plant Heldfor Future Use, or 105.1, ProductionProperties Held for Future Use. Includealso, the balance of accumulated provi-sion for amortization on property whentransferred to account 105 or 105.1 fromother property accounts.

NOTE: See also paragraph A(2), of account108, Accumulated Provision for Depreciationof Gas Utility Plant.

(5) Amounts charged to account 405,Amortization of Other Gas Plant.

(6) Amounts charged to account 413,Expenses of Gas Plant Leased to Oth-ers, for current amortization thereof.

(7) Amounts charged to account 797,Abandoned Leases, to provide for theabandonment of nonproductive naturalgas leases.

(8) Amounts charged to account 425,Miscellaneous Amortization, for theamortization of intangible or other gasplant which does not have a definite orterminable life and is not subject tocharges for depreciation expense, withCommission approval.(The utility shall maintain sub-accounts of this account for the amor-tization applicable to producing natu-ral gas land and land rights, other gasplant in service, gas plant leased toothers, abandonment of leases and gasplant held for future use.)

B. When any property to which thisaccount applies is sold, relinquished, or



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otherwise retired from service, this ac-count shall be charged with theamount previously credited in respectto such property. The book cost of theproperty so retired less the amountchargeable to this account and less thenet proceeds realized at retirementshall be included in account 421.1, Gainon Disposition of Property, or account421.2, Loss on Disposition of Property,as appropriate.

C. For general ledger and balancesheet purposes, this account shall beregarded and treated as a single com-posite provision for amortization.For purposes of analysis, however, eachutility shall maintain subsidiaryrecords in which this account is seg-regating according to the followingfunctional classification for gas plant:

(1) Production—manufactured gas, (2)production and gathering—natural gas,(3) products extraction—natural gas,(4) underground gas storage, (5) otherstorage, (6) base load LNG terminalingand processing plant, (7) transmission,(8) distribution, and (9) general. Thesesubsidiary records shall reflect the cur-rent credits and debits to this accountin sufficient detail to show separatelyfor each such functional classification(a) the amount of provision for amorti-zation, (b) the book cost of property re-tired, (c) cost of removal, (d) salvage,and (e) other items, including recover-ies from insurance. Records shall bemaintained so as to show separatelythe balance applicable to each item ofland and land rights which is being am-ortized or depleted except that naturalgas land and land rights which com-prise an interest in a production areamay be grouped to form a unit for am-ortization and depletion and the accu-mulated provision applicable theretoneed not be segregated to show theamount related to each gas right in-cluded therein. Records shall also bemaintained so as to show separatelythe balance applicable to each under-ground gas storage project.

D. The utility is restricted in its useof the accumulated provision for amor-tization to the purposes set forthabove. It shall not transfer any portionof this account to retained earnings ormake any other use thereof withoutauthorization by the Commission.

112—113 [Reserved]

114 Gas plant acquisition adjustments.

A. This account shall include the dif-ference between (a) the cost to the ac-counting utility of gas plant acquiredas an operating unit or system by pur-chase, merger, consolidation, liquida-tion, or otherwise, and (b) the originalcost, estimated, if not known, of suchproperty, less the amount or amountscredited by the accounting utility atthe time of acquisition to accumulatedprovisions for depreciation, depletion,and amortization and contributions inaid of construction with respect tosuch property.

B. With respect to acquisitions afterthe effective date of this system of ac-counts, this account shall be sub-divided so as to show the amounts in-cluded herein for each property acqui-sition and to gas plant in service, gasplant held for future use and gas plantleased to others. (See gas plant instruc-tion 5.)

C. Debit amounts recorded in this ac-count related to plant and land acquisi-tion may be amortized to account 425,Miscellaneous Amortization, over a pe-riod not longer than the estimated re-maining life of the properties to whichsuch amounts relate. Amounts relatedto the acquisition of land only may beamortized to account 425 over a periodof not more than 15 years. Should autility wish to account for debitamounts in this account in any othermanner, it shall petition the Commis-sion for authority to do so. Creditamounts recorded in this account shallbe accounted for as directed by theCommission.

115 Accumulated provision for amorti-zation of gas plant acquisition ad-justments.

This account shall be credited or deb-ited with amounts which are includiblein account 406, Amortization of GasPlant Acquisition Adjustments or ac-count 425, Miscellaneous Amortization,for the purpose of providing for the ex-tinguishment of amounts in account114, Gas Plant Acquisition Adjust-ments, in instances where the amorti-zation of account 114 is not being madeby direct write-off of the account.



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116 Other gas plant adjustments.A. This account shall include the dif-

ference between the original cost, esti-mated if not known, and the book costof gas plant to the extent that such dif-ference is not properly includible in ac-count 114 Gas Plant Acquisition Ad-justments. (See gas plant instruction1C.)

B. Amounts included in this accountshall be classified in such manner as toshow the origin of each amount andshall be disposed of as the Commissionmay approve or direct.

NOTE: The provisions of this account shallnot be construed as approving or authorizingthe recording of appreciation of gas plant.

Special Instructions to Accounts 117.1,117.2 and 117.3

The investment in and use of systemgas included in Account 117.1, GasStored—Base Gas, and Account 117.2,System Balancing Gas, may be ac-counted for using either the ‘‘fixedasset’’ method or an ‘‘inventory’’method as set forth below. The cost ofstored gas included in Account 117.3must be accounted for using an inven-tory method.

(a) Inventory Method—Gas stored dur-ing the year must be priced at cost ac-cording to generally accepted methodsof cost determination consistently ap-plied from year to year. Transmissionexpenses for facilities of the utilityused in moving the gas to the storagearea and expenses of storage facilitiescannot be included in the inventory ofgas except as may be authorized or di-rected by the Commission.

Withdrawals of gas must be pricedusing the first-in-first-out, last-in-first-out, or weighted average costmethod, provided the method adoptedby the utility is used consistently fromyear to year and appropriate inventoryrecords are maintained. Approval ofthe Commission must be obtained forany other pricing method, or change inthe pricing method adopted by the util-ity.

Adjustments for inventory losses re-lated to gas held in underground res-ervoirs due to cumulative inaccuraciesof gas measurements, or from othercauses, must be charged to Account823, Gas Losses. Losses of system gas

not associated with underground res-ervoirs must be charged to Account813, Other Gas Supply Expenses.

(b) Fixed Asset Method—When replace-ment of the gas is made, the amountcarried in Account 117.4 for such vol-umes must be cleared with a contraentry to Account 808.2, Gas Deliveredto Storage—Credit. Any difference be-tween the utility’s cost of replacementgas volumes and the amount clearedfrom Account 117.4 must be recognizedas a gain in Account 495, Other gas rev-enues, or as a loss in Account 813,Other gas supply expenses, with contraentries to Account 808.2.

Adjustments for inventory losses re-lated to gas held in underground res-ervoirs due to cumulative inaccuraciesof gas measurements, or from othercauses, must be charged to Account823, Gas Losses. Losses of system gasnot associated with underground res-ervoirs must be charged to Account813, Other Gas Supply Expenses. Gaslosses must be priced at the marketprice of gas available to the utility inthe month the loss is recognized.

Gas owned by the utility and injectedinto its system will be deemed to sat-isfy any encroachment on system gasfirst before any other use.

117.1 Gas stored-base gas.This account is to include the cost of

recoverable gas volumes that are nec-essary, in addition to those volumes forwhich cost are properly includable inAccount 101, Gas plant in service, tomaintain pressure and deliverabilityrequirements for each storage facility.Nonrecoverable gas volumes used forthis purpose are to be recorded in Ac-count 352.3, Nonrecoverable naturalgas. For utilities using the fixed assetmethod of accounting, the cost of basegas applicable to each gas storage fa-cility shall not be changed from theamount initially recorded except to re-flect changes in volumes designated asbase gas. If an inventory method isused to account for gas included here-in, the utility may, at its election,price withdrawals in accordance withthe instructions to Account 117.4.

117.2 System balancing gas.This account is to be used to record

the cost of system gas designated as



531


available for transmission load bal-ancing (including no-notice transpor-tation) and other uses associated withmaintaining efficient transmission op-erations other than gas properly re-cordable in Account 117.1 or the plantaccounts. Detailed records must bekept separately identifying volumesand unit prices of system gas held inunderground storage facilities and heldin pipelines.

For utilities using fixed asset ac-counting, the cost initially recordedherein cannot be changed except for ad-justments to volumes designated assystem gas. Encroachments upon sys-tem gas must be accounted for in ac-cordance with the instructions to Ac-count 117.4, Gas owed to system gas.

117.3 Gas stored in reservoirs andpipelines—noncurrent.

This account is to include the cost ofstored gas owned by the utility andavailable for sale or other purposes.Gas included in this account must beaccounted for using an inventory meth-od in accordance with the Special In-structions to Accounts 117.1, 117.2, and117.3 above.

117.4 Gas owed to system gas.

This account is to be used to recordencroachments of system gas under thefixed asset method. This account mayalso be used to record encroachmentsof base gas for utilities electing to usean inventory method of accounting forsystem gas. Utilities may revalve cu-mulative net imbalances, net all trans-actions, and record one monthly entrywith one month-end price for valuationpurposes.

118 Other utility plant.

This account shall include the bal-ance in accounts for utility plant,other than gas plant, such as electric,railway, etc.

119 Accumulated provision for depre-ciation and amortization of otherutility plant.

This account shall include the accu-mulated provision for depreciation andamortization applicable to utilityproperty other than gas plant.

121 Nonutility property.

A. This account shall include thebook cost of land, structures, equip-ment or other tangible or intangibleproperty owned by the utility, but notused in utility service and not properlyincludible in account 105, Gas PlantHeld for Future Use.

B. This account shall also include theamount recorded under capital leasesfor property leased from others andused by the utility in its nonutility op-erations. Records shall be maintainedwith respect to each lease reflecting:(1) name of lessor, (2) basic details oflease, (3) terminal date, (4) originalcost or fair market value of propertyleased, (5) future minimum lease pay-ments, (6) executory costs, (7) presentvalue of minimum lease payments, (8)the amount representing interest andthe interest rate used, and (9) expensespaid.

C. This account shall be subdividedso as to show the amount of propertyused in operations which are nonutilityin character but nevertheless con-stitute a distinct operating activity ofthe company (such as operation of anice department where such activity isnot classed as a utility) and theamount of miscellaneous property notused in operations. The records in sup-port of each subaccount shall be main-tained so as to show an appropriateclassification of the property.

NOTE: In the event of the subsequent saleor other disposition of property included inthis account which had been previously re-corded in account 105, Gas Plant Held for Fu-ture Use, or account 105.1, Production Prop-erties Held for Future Use, such propertycosts shall be accounted for in accordancewith paragraph C of accounts 105 and 105.1,respectively.

122 Accumulated provision for depre-ciation and amortization of nonutil-ity property.

This account shall include the accu-mulated provision for depreciation andamortization applicable to nonutilityproperty.

123 Investment in associated compa-nies.

A. This account shall include thebook cost of investments in securities



532


issued or assumed by associated com-panies and investment advances tosuch companies, including interest ac-crued thereon when such interest is notsubject to current settlement, providedthat the investment does not relate toa subsidiary company. (If the invest-ment relates to a subsidiary companyit shall be included in account entry tothe recording of amortization of dis-count or premium on interest bearinginvestments. Include herein the offset-ting 123.1, Investment in SubsidiaryCompanies.) (See account 419, Interestand Dividend Income.)

B. This account shall be maintainedin such manner as to show the invest-ment in securities of, and advances to,each associated company together withfull particulars regarding any of suchinvestments that are pledged.

NOTE A: Securities and advances of associ-ated companies owned and pledged shall beincluded in this account, but such securities,if held in special deposits or in special funds,shall be included in the appropriate depositor fund account. A complete record of securi-ties pledged shall be maintained.

NOTE B: Securities of associated companiesheld as temporary cash investments are in-cludible in account 136, Temporary Cash In-vestments.

NOTE C: Balances in open accounts with as-sociated companies, which are subject tocurrent settlement, are includible in account146, Accounts Receivable from AssociatedCompanies.

NOTE D: The utility may write down thecost of any security in recognition of a de-cline in the value thereof. Securities shall bewritten off or written down to a nominalvalue if there be no reasonable prospect ofsubstantial value. Fluctuations in marketvalue shall not be recorded but a permanentimpairment in the value of securities shallbe recognized in the accounts. When securi-ties are written off or written down, theamount of the adjustment shall be chargedto account 426.5, Other Deductions, or to anappropriate account for accumulated provi-sions for loss in value established as a sepa-rate subdivision of this account.

123.1 Investment in subsidiary compa-nies.

A. This account shall include thecost of investments in securities issuedor assumed by subsidiary companiesand investment advances to such com-panies, including interest accruedthereon when such interest is not sub-ject to current settlement plus the eq-

uity in undistributed earnings or lossesof such subsidiary companies since ac-quisition. This account shall be cred-ited with any dividends declared bysuch subsidiaries.

B. This account shall be maintainedin such a manner as to show separatelyfor each subsidiary: The cost of suchinvestments in the securities of thesubsidiary at the time of acquisition;the amount of equity in the subsidi-ary’s undistributed net earnings or netlosses since acquisition; advances orloans to such subsidiary; and full par-ticulars regarding any such invest-ments that are pledged.

124 Other investments.A. This account shall include the

book cost of investments in securitiesissued or assumed by nonassociatedcompanies, investment advances tosuch companies, and any investmentsnot accounted for elsewhere. Includealso the offsetting entry to the record-ing of amortization of discount or pre-mium on interest bearing investments.(See account 419, Interest and DividendIncome.)

B. The cost of capital stock of theutility reacquired by it under a definiteplan for resale pursuant to authoriza-tion by the Board of Directors may, ifpermitted by statutes, be included in aseparate subdivision of this account.(See also account 210, Gain on Resaleor Cancellation of Reacquired CapitalStock, and account 217, ReacquiredCapital Stock.)

C. The records shall be maintained insuch manner as to show the amount ofeach investment and the investmentadvances to each person.

NOTE A: Securities owned and pledged shallbe included in this account, but securitiesheld in special deposits or in special fundsshall be included in appropriate deposit orfund accounts. A complete record of securi-ties pledged shall be maintained.

NOTE B: Securities held as temporary cashinvestments shall not be included in this ac-count.

NOTE C: See Note D of account 123.

125 Sinking funds.This account shall include the

amount of cash and book cost of in-vestments held in sinking funds. A sep-arate account, with appropriate title,



533


shall be kept for each sinking fund.Transfers from this account to specialdeposit accounts, may be made as nec-essary for the purpose of paying ma-tured sinking-fund obligations, or obli-gations called for redemption but notpresented, or the interest thereon.

126 Depreciation fund.

This account shall include theamount of cash and the book cost of in-vestments which have been segregatedin a special fund for the purpose ofidentifying such assets with the accu-mulated provisions for depreciation.

128 Other special funds.

This account shall include theamount of cash and book cost of in-vestments which have been segregatedin special funds for insurance, em-ployee pensions, savings, relief, hos-pital, and other purposes not providedfor elsewhere. A separate account, withappropriate title shall be kept for eachfund.

NOTE: Amounts deposited with a trusteeunder the terms of an irrevocable trustagreement for pensions or other employeebenefits shall not be included in this ac-count.

SPECIAL INSTRUCTIONS FOR CURRENT ANDACCRUED ASSETS

Current and accrued assets are cash, thoseassets which are readily convertible intocash or are held for current use in operationsor construction, current claims against oth-ers, payment of which is reasonably assured,and amounts accruing to the utility whichare subject to current settlement, exceptsuch items for which accounts other thanthose designated as current and accrued as-sets are provided. There shall not be includedin the group of accounts designated as cur-rent and accrued assets any item, theamount or collectibility of which is not rea-sonably assured, unless an adequate provi-sion for possible loss has been made therefor.Items of current character but of doubtfulvalue may be written down and for recordpurposes carried in these accounts at nomi-nal value.

131 Cash.

This account shall include theamount of current cash funds exceptworking funds.

132 Interest special deposits.

This account shall include special de-posits with fiscal agents or others forthe payment of interest.

133 Dividend special deposits.

This account shall include special de-posits with fiscal agents or others forthe payment of dividends.

134 Other special deposits.

This account shall include depositswith fiscal agents or others for specialpurposes other than the payment of in-terest and dividends. Such special de-posits may include cash deposited withfederal, state, or municipal authoritiesas a guaranty for the fulfillment of ob-ligations; cash deposited with trusteesto be held until mortgaged propertysold, destroyed, or otherwise disposedof is replaced; cash realized from thesale of the accounting utility’s securi-ties and deposited with trustees to beheld until invested in property of theutility, etc. Entries to this accountshall specify the purpose for which thedeposit is made.

NOTE: Assets available for general cor-porate purposes shall not be included in thisaccount. Further, deposits for more than oneyear, which are not offset by current liabil-ities, shall not be charged to this accountbut to account 128, Other Special Funds.

135 Working funds.

This account shall include cash ad-vanced to officers, agents, employees,and others as petty cash or workingfunds.

136 Temporary cash investments.

A. This account shall include thebook cost of investments, such as de-mand and time loans, bankers’ accept-ances, United States Treasury certifi-cates, marketable securities, and othersimilar investments, acquired for thepurpose of temporarily investing cash.

B. This account shall be so main-tained as to show separately temporarycash investments in securities of asso-ciated companies and of others.Records shall be kept of any pledgedinvestments.



534


141 Notes receivable.This account shall include the book

cost, not includible elsewhere, of allcollectible obligations in the form ofnotes receivable and similar evidences(except interest coupons) of money dueon demand or within one year from thedate of issue, except, however, notes re-ceivable from associated companies.(See account 136, Temporary Cash In-vestments, and account 145, Notes Re-ceivable from Associated Companies.)

NOTE: The face amount of notes receivablediscounted, sold, or transferred without re-leasing the utility from liability as endorserthereon, shall be credited to a separate sub-division of this account and appropriate dis-closure shall be made in financial state-ments of any contingent liability arisingfrom such transactions.

142 Customer accounts receivable.A. This account shall include

amounts due from customers for util-ity service, and for merchandising, job-bing, and contract work. This accountshall not include amounts due from as-sociated companies.

B. This account shall be maintainedso as to permit ready segregation ofthe amounts due for merchandising,jobbing, and contract work.

143 Other accounts receivable.A. This account shall include

amounts due the utility upon open ac-counts, other than amounts due fromassociated companies and from cus-tomers for utility services and mer-chandising, jobbing, and contractwork.

B. This account shall be maintainedso as to show separately amounts dueon subscriptions to capital stock andfrom officers and employees, but theaccount shall not include amounts ad-vanced to officers or others as workingfunds. (See account 135, WorkingFunds.)

144 Accumulated provision foruncollectible accounts—Cr.

A. This account shall be creditedwith amounts provided for losses on ac-counts receivable which may becomeuncollectible, and also with collectionson accounts previously charged hereto.Concurrent charges shall be made to

account 904, Uncollectible Accounts,for amounts applicable to utility oper-ations, and to corresponding accountsfor other operations. Records shall bemaintained so as to show the write-offsof accounts receivable for each utilitydepartment.

B. This account shall be subdividedto show the provision applicable to thefollowing classes of accounts receiv-able:Utility Customers.Merchandising, Jobbing and Contract Work.Officers and Employees.Others.

NOTE A: Accretions to this account shallnot be made in excess of a reasonable provi-sion against losses of the character providedfor.

NOTE B: If provisions for uncollectiblenotes receivable or for uncollectible receiv-ables from associated companies are nec-essary, separate subaccounts therefor shallbe established under the account in whichthe receivable is carried.

145 Notes receivable from associatedcompanies.

146 Accounts receivable from associ-ated companies.

These accounts shall include notesand drafts upon which associated com-panies are liable, and which matureand are expected to be paid in full notlater than one year from date of issue,together with any interest thereon,and debit balances subject to currentsettlement in open accounts with asso-ciated companies. Items which do notbear a specified due date but whichhave been carried for more than twelvemonths and items which are not paidwithin twelve months from due dateshall be transferred to account 123, In-vestment in Associated Companies.

NOTE A: On the balance sheet, accounts re-ceivable from an associated company may beset off against accounts payable to the samecompany.

NOTE B: The face amount of notes receiv-able discounted, sold or transferred withoutreleasing the utility from liability as en-dorser thereon, shall be credited to a sepa-rate subdivision of this account and appro-priate disclosure shall be made in financialstatements of any contingent liability aris-ing from such transactions.



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151 Fuel stock.This account shall include the book

cost of fuel on hand.ITEMS

1. Invoice price of fuel less any cash orother discounts.

2. Freight, switching, demurrage and othertransportation charges, not including, how-ever, any charges for unloading from theshipping medium.

3. Excise taxes, purchasing agents’ com-missions, insurance and other expenses di-rectly assignable to cost of fuel.

152 Fuel stock expenses undistributed.A. This account may include the cost

of labor and of supplies used and ex-penses incurred in unloading fuel fromthe shipping medium and in the han-dling thereof prior to its use, if suchexpenses are sufficiently significant inamount to warrant being treated as apart of the cost of fuel inventory rath-er than being charged direct to expenseas incurred.

B. Amounts included herein shall becharged to expense as the fuel is usedto the end that the balance herein,shall not exceed the expenses attrib-utable to the inventory of fuel on hand.

ITEMS

Labor:1. Procuring and handling of fuel.2. All routine fuel analyses.3. Unloading from shipping facility and

putting in storage.4. Moving of fuel in storage and transfer-

ring from one station to another.5. Handling from storage or shipping facil-

ity to first bunker, hopper, bucket, tank orholder of boiler house structure.

6. Operation of mechanical equipment,such as locomotives, trucks, cars, boats,barges, cranes, etc.Supplies and Expenses:

7. Tools, lubricants and other supplies.8. Operating supplies for mechanical equip-

ment.9. Transportation and other expenses in

moving fuel.10. Stores expenses applicable to fuel.

153 Residuals and extracted products.This account shall include the book

cost of residuals or extracted productsproduced in the manufacture of gas orin natural gas products extraction op-erations including like products pur-chased for resale.

154 Plant materials and operatingsupplies.

A. This account shall include thecost of materials purchased primarilyfor use in the utility business for con-struction, operation and maintenancepurposes. This account shall includealso the book cost of materials recov-ered in connection with construction,maintenance or the retirement of prop-erty, such materials being credited toconstruction, maintenance or accumu-lated depreciation provision, respec-tively, and included herein as follows:

(1) Reusable materials consisting oflarge individual items shall be includedin this account at original cost, esti-mated if not known. The cost of repair-ing such items shall be charged to themaintenance account appropriate forthe previous use.

(2) Reusable materials consisting ofrelatively small items, the identity ofwhich (from the date of original instal-lation to the final abandonment or salethereof) cannot be ascertained withoutundue refinement in accounting, shallbe included in this account at currentprices new for such items. The cost ofrepairing such items shall be chargedto the appropriate expense account asindicated by previous use.

(3) Scrap and nonusable materials in-cluded in this account shall be carriedat the estimated net amount realizabletherefrom. The difference between theamounts realized for scrap and non-usable materials sold and the netamount at which the materials werecarried in this account, as far as prac-ticable, shall be adjusted to the ac-counts credited when the materialswere charged to this account.

B. Materials and supplies issued shallbe credited hereto and charged to theappropriate construction, operating ex-pense, or other account on the basis ofa unit price determined by the use ofcumulative average, first-in-first out,or such other method of inventory ac-counting as conforms with accepted ac-counting standards consistently ap-plied.

ITEMS

1. Invoice price of materials less cash orother discounts.

2. Freight, switching or other transpor-tation charges when practicable to include



536


as part of the cost of particular materials towhich they relate.

3. Customs duties and excise taxes.4. Costs of inspection and special tests

prior to acceptance.5. Insurance and other directly assignable

charges.NOTE: Where expenses applicable to mate-

rials purchased cannot be directly assignedto particular purchases, they shall becharged to account 163, Stores expenses Un-distributed.

155 Merchandise.This account shall include the book

cost of materials and supplies, and ap-pliances and equipment held primarilyfor merchandising, jobbing, and con-tract work. The principles prescribedin accounting for utility materials andsupplies shall be observed in respect toitems carried in this account.

156 Other materials and supplies.This account shall include the book

cost of materials and supplies held pri-marily for nonutility purposes. Theprinciples prescribed in accounting forutility materials and supplies shall beobserved in respect to items carried inthis account.

163 Stores expense undistributed.A. This account shall include the

cost of supervision, labor and expensesincurred in the operation of generalstorerooms, including purchasing, stor-age, handling and distribution of mate-rials and supplies.

B. This account shall be cleared byadding to the cost of materials andsupplies issued a suitable loadingcharge which will distribute the ex-pense equitably over stores issues. Thebalance in the account at the close ofthe year shall not exceed the amountof stores expenses reasonably attrib-utable to the inventory of materialsand supplies exclusive of fuel, as anyamount applicable to fuel cost shouldbe included in account 152, Fuel StockExpenses Undistributed.

ITEMS

Labor:1. Inspecting and testing materials and

supplies when not assignable to specificitems.

2. Unloading from shipping facility andputting in storage.

3. Supervision of purchasing and stores de-partment to extent assignable to materialshandled through stores.

4. Getting materials from stock and inreadiness to go out.

5. Inventorying stock received or stock onhand by stores employees but not includinginventories by general department employ-ees as part of internal or general audits.

6. Purchasing department activities inchecking material needs, investigatingsources of supply, analyzing prices, prepar-ing and placing orders, and related activitiesto extent applicable to materials handledthrough stores. (Optional. Purchasing de-partment expenses may be included in ad-ministrative and general expenses.)

7. Maintaining stores equipment.8. Cleaning and tidying storerooms and

stores offices.9. Keeping stock records, including record-

ing and posting of material receipts andissues and maintaining inventory record ofstock.

10. Collecting and handling scrap materialsin stores.Supplies and Expenses:

11. Adjustments of inventories of materialsand supplies but not including large dif-ferences which can readily be assigned to im-portant classes of materials and equitablydistributed among the accounts to whichsuch classes of materials have been chargedsince the previous inventory.

12. Cash and other discounts not prac-tically assignable to specific materials.

13. Freight, express, etc., when not assign-able to specific items.

14. Heat, light and power for storeroomsand store offices.

15. Brooms, brushes, sweeping compoundsand other supplies used in cleaning andtidying storerooms and stores offices.

16. Injuries and damages.17. Insurance on materials and supplies and

on stores equipment.18. Losses due to breakage, leakage, evapo-

ration, fire or other causes, less credits foramounts received from insurance, transpor-tation companies or others in compensationof such losses.

19. Postage, printing, stationery and officesupplies.

20. Rent of storage space and facilities.21. Communication service.22. Excise and other similar taxes not as-

signable to specific materials.23. Transportation expense on inward

movement of stores and on transfer betweenstorerooms but not including charges on ma-terials recovered from retirements whichshall be accounted for as part of cost of re-moval.

NOTE: A physical inventory of each class ofmaterials and supplies shall be made at leastevery two years.



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164.1 Gas stored—current.This account shall be debited with

such amounts as are credited to Ac-count 117.2, System balancing gas, (forutilities using an inventory method ofaccounting for system gas) and Ac-count 117.3, Gas Stored in Reservoirsand Pipelines-Noncurrent, to reflectclassification for balance sheet pur-poses of such portion of the inventoryof gas stored as represents a currentasset according to conventional rulesfor classification of current assets.

NOTE: It shall not be considered conform-ity to conventional rules of current assetclassification if the amount included in thisaccount exceeds an amount equal to the costof estimated withdrawals of gas from storagewithin the 24-month period from date of thebalance sheet, or if the amount represents avolume of gas which, in fact, could not bewithdrawn from storage without impairingpressure levels needed for normal operatingpurposes.

164.2 Liquefied natural gas stored.A. This account shall include the

cost of liquefied natural gas stored inabove or below ground facilities.

B. Natural gas purchased in a lique-fied form shall be priced at the cost ofsuch gas to the utility. Natural gas liq-uefied by the utility shall be priced ac-cording to generally accepted methodsof cost determination consistently ap-plied from year to year. Transmissionexpenses for facilities to the utilityused in moving the gas to the storagefacilities shall not be included in theinventory of gas except as may be au-thorized by the Commission.

C. Amounts debited to this accountfor natural gas placed in stored shall becredited to account 808.2, Gas Deliveredto Storage—Credit. Amounts creditedto this account for gas withdrawn fromstorage shall be debited to account808.1, Gas Withdrawn from Storage—Debit.

D. Withdrawals of gas may be pricedaccording to the first-in-first-out, last-in-first-out, or weighted average costmethod provided the method adoptedby the utility is used consistently fromyear to year and inventory records aremaintained in accordance therewith.Commission approval must be obtainedfor any other pricing method or for anychange in the pricing method adopted

by the utility. Separate records shallbe maintained for each storage projectof the Dth of gas delivered to storageand remaining in storage.

E. Adjustments for inventory lossesshall be charged to account 842.3, GasLosses.

164.3 Liquefied natural gas held forprocessing.

A. This account shall include thecost of base load liquefied natural gasavailable for vaporization and injectioninto the utility’s natural gas system.

B. Natural gas purchased in a lique-fied form shall be priced at the cost ofsuch gas to the utility.

C. Amounts debited to this accountfor liquefied natural gas purchased forprocessing shall be credited to account809.2, Deliveries of Natural Gas forProcessing—Credit. Amounts creditedfor liquefied natural gas processedshall be debited to account 809.1, With-drawals of Liquefied Natural Gas Heldfor Processing—Debit.

D. Withdrawals of gas held for vapor-ization may be priced according to thefirst-in-first-out, last-in-first-out orweighted average cost method providedthe method adopted by the utility isused consistently from year to yearand inventory records are maintainedin accordance therewith. Commissionapproval must be obtained for anyother pricing method or for any changefrom the pricing method adopted bythe utility. Separate records shall bemaintained for Dth of gas purchasedfor processing, processed, and remain-ing for processing.

E. Adjustments for inventory lossesshall be charged to account 846.1, GasLosses.

165 Prepayments.

A. This account shall include pay-ments for undelivered gas and otherprepayments of rents, taxes, insurance,interest, and like disbursements madeprior to the period to which they apply.Prepayments for gas are those amountspaid to a seller of gas under ‘‘take orpay’’ provisions of a gas purchase con-tract for a sale certificated by theCommission where future makeup ofthe gas not taken in the current periodis provided for by the contract.



538


B. As the periods covered by suchprepayments expire, credit this ac-count and charge the proper operatingexpense or other appropriate accountwith the amount applicable to the pe-riod.

C. This account shall be kept or sup-ported in such a manner as to disclosethe amount of each class of prepay-ments.

166 Advances for gas exploration, de-velopment and production.

A. This account shall include all ad-vances made for gas (whether called‘‘advances,’’ ‘‘contributions’’ or other-wise) to independent producers, affili-ated or associated companies, or othersoperating within the lower 48 statesand Alaska; for exploration, develop-ment or production (but not to includelease acquisition) of natural gas. Undereach agreement with payee, such pay-ments must be made prior to initialgas deliveries, or if the agreement pro-vides for advances on a well by wellbasis, each incremental payment mustbe made prior to deliveries from an in-cremental well, or prior to Federal and/or State authorization, as appropriate.All agreements executed after June 17,1975, (issuance date of Order No. 529)shall specify that (1) the pipeline shallhave first call on any gas produced, at-tributable to the advance payment,under a long-term contract which is fora minimum initial term computed asthe lesser of fifteen years or the life ofthe reserve in the field, and (2) the sell-ing price of the gas committed by pro-ducers whose sales are subject to priceregulation shall be governed by andlimited to the area rate or nationalrate or, under appropriate showing ofspecial circumstance, such other rateas may be authorized by the Commis-sion under the provisions of optionalpricing and special relief. As a deter-mination of the initial rate, the time offirst delivery in interstate commerceto the purchaser shall govern. Non-cur-rent advances not to be repaid within atwo-year period shall be reclassifiedand transferred to account 124, OtherInvestments, for balance sheet pur-poses. This transfer is for reportingpurposes only and has no effect on ac-counting and ratemaking.

B. When a pipeline obtains a workinginterest as a result of funds advancedto producers, such amounts shall be in-cluded in appropriate production ac-counts for formal contractual agree-ments executed prior to the date ofissuance of Order No. 499. When an as-sociated company obtains a workinginterest as a result of funds advancedfrom a pipeline company, the pipelineshall include such amounts in Account123, Investment in Associated Compa-nies, or Account 146, Accounts receiv-able from Associated Companies, as ap-propriate, for formal contractual com-mitments made during the period on orafter November 10, 1971 (effective dateof Order 441) but prior to December 29,1972, the date of issuance of Order No.465.

C. Outstanding advances shall befully reduced within 5 years, or as oth-erwise authorized by the Commission,from the date gas deliveries commenceor the date it is determined that recov-ery will be in other than gas. This ac-count shall be credited with advancesnot fully recovered within the five-yearperiod, and the unrecovered portioncharged directly to Account 426.5,Other Deductions. A sufficient portionof all gas taken should be credited tothe related outstanding advance so asto eliminate the advance within the 5-year period or as otherwise authorizedby the Commission upon request by thepipeline company. The reduction of theoutstanding advance should not be de-pendent on a buyer purchasing morethan 100 percent of the minimum takeor pay quantity provided in the con-tract. In those instances where thefive-year recovery period has lapsed,but recovery of the advance continuesbeyond the five-year period, the unre-covered advances shall be removedfrom this account and transferred toAccount 167, Other Advances for Gas.

D. Where recovery is by gas, the re-covered advance shall be credited tothis account and charged to the appro-priate gas purchase account.

E. When an advance which is or hasbeen included in this account and inrate base results in a source of provenreserves of natural gas, gas deliveriescommence but no gas flows to the pipe-line company making such advance,



539


the amount of the advance shall be re-moved from this account (and fromrate base) and recorded in account 167,Other Advances for Gas. Any revenuescollected as a result of the advancebeing included in rate base shall be re-funded by the pipeline company to itscustomers, together with interest, perannum, at the rate established byOrder No. 513, issued October 10, 1974,or as subsequently revised by Commis-sion Order, from the date of paymentuntil refunded, within 12 months afterthe removal of the advance from thisaccount, unless otherwise directed bythe Commission. Where there is partialrecovery of the advance by gas, in thissituation, the amount of the advancetransferred from this account to ac-count 167 and the amount of revenuesrefunded, with interest, shall be appro-priately apportioned.

F. However, if 5 years elapses fromthe time the advance has been includedin this account and during such timeno gas deliveries have commenced orno determination has been made thatthe recovery will be in economic con-sideration other than gas, the pipelineshall at the end of the 5–year period,transfer the advance from this accountto Account 167, and cease rate basetreatment thereof, unless otherwise di-rected by the Commission.

G. Whenever as a result of an ad-vance included in this account, a pipe-line receives any amount in excess of afull recovery of the advance, e.g. inter-est income, such amount must be cred-ited to Account 813, Other Gas SupplyExpenses, or as otherwise directed bythe Commission. If the income or re-turn is received in other than money,it shall be included at the marketvalue of the assets received.

H. If the recipient of an advance isunable to repay it in full, through nofault of the pipeline or contractual pro-visions, in gas or other assets, the un-paid or nonrecoverable portion must becredited to this account at the timesuch amount is recognized as non-recoverable. Nonrecoverable advancessignificant in amount must be elimi-nated within 5 years from the date ofdetermination as nonrecoverable by ei-ther a charge to account 435, Extraor-dinary Deductions, or when authorizedby the Commission, by a transfer to ac-

count 186, Miscellaneous Deferred Deb-its, and amortization to account 813,Other Gas Supply Expenses. Non-recoverable advances insignificant inamount should be charged directly toaccount 813 in the year recognized asnonrecoverable, when authorized bythe Commission.

I. No transfers shall be made to orfrom this account to any other ac-counts, unless otherwise provided here-in, except as specifically authorized bythe Commission upon request by thepipeline company.

J. Three copies of any agreementconcerning advances will be filed withthe Secretary within 30 days of the ini-tial related entry in account 166.

NOTE A: This account may include ad-vances for exploration (including lease ac-quisition costs) made according to the provi-sions of Order Nos. 410 and 410–A, for whicha contractual commitment was made priorto November 10, 1971, (issue date of Order No.441). All advances made pursuant to contrac-tual commitments made prior to November10, 1971, (issue date of Order No. 441) shall besubject to the provisions of Order Nos. 410and 410–A.

NOTE B: This account shall not include ad-vances for exploration (including lease ac-quisition costs) in accordance with Order No.441, for which a contractual commitmentwas made on or after November 10, 1971(issue date of Order No. 441), but prior to De-cember 29, 1972 (issue date of Order No. 465).All advances made pursuant to contractualcommitments made on or after November 10,1971, but prior to December 29, 1972 (issuedate of Order No. 465) shall be subject to theprovisions of Order No. 441.

NOTE C: This account shall not include ad-vances for lease acquisition costs but mayinclude advances for exploration where suchadvances are pursuant to contractual com-mitments made on or after December 29, 1972(issue date of Order No. 465).

NOTE D: All advances made pursuant tocontractual commitments made on or afterDecember 29, 1972 (issue date of Order No.465) but prior to the date of issuance of OrderNo. 499, shall be subject to the provisions ofOrder No. 465.

NOTE E: All advances made pursuant tocontractual commitments made on or afterDecember 28, 1973 (issue date of Order No.499), but prior to the date of issuance ofOrder No. 529, shall be subject to the provi-sions of Order No. 499.

NOTE F: This account shall not include ad-vances expended for delay rentals, non-productive well drilling or abandoned leases



540


where such advances are related to lease ac-quisition, except in accordance with Note Aand Note B to this account.

NOTE G: To keep the Commission informedwhen an advance is nonrecoverable by anymeans the company must submit the full de-tails including copies of Federal and Stateplugging and abandonment reports involvedas soon as such fact becomes known.

167 Other advances for gas.This account shall include all ad-

vances not properly includible in Ac-count 166, exclusive of amounts ad-vanced where a working interest is ob-tained.

171 Interest and dividends receivable.This account shall include the

amount of interest on bonds, mort-gages, notes, commercial paper, loans,open accounts, deposits, etc., the pay-ment of which is reasonably assured,and the amount of dividends declaredor guaranteed on stocks owned.

NOTE A: Interest which is not subject tocurrent settlement shall not be includedherein but in the account in which is carriedthe principal on which the interest is ac-crued.NOTE B: Interest and dividends receivablefrom associated companies shall be includedin account 146. Accounts Receivable from As-sociated Companies.

172 Rents receivable.This account shall include rents re-

ceivable or accrued on property rentedor leased by the utility to others.

NOTE: Rents receivable from associatedcompanies shall be included in account 146.Accounts Receivable From Associated Com-panies.

173 Accrued utility revenues.At the option of the utility, the esti-

mated amount accrued for service ren-dered, but not billed at the end of anyaccounting period, may be includedherein. In case accruals are made forunbilled revenues, they shall be madelikewise for unbilled expenses, such asfor the purchase of gas.

174 Miscellaneous current and ac-crued assets.

A. This account shall include thebook cost of all other current and ac-crued assets, appropriately designated

and supported so as to show the natureof each asset included herein.

B. The utility is to include in a sepa-rate subaccount amounts receivable forgas in unbalanced transactions wheregas is delivered to another party in ex-change, load balancing, or no-noticetransportation transactions. (See Ac-count 806.) If the amount receivable issettled by other than gas, Account 495,Other Gas Revenues must be creditedor Account 813, Other Gas Supply Ex-penses, charged for the difference be-tween the amount of the considerationreceived and the recorded amount ofthe receivable settled. Records are tobe maintained so that there is readilyavailable for each party entering gasexchange, load balancing, or no-noticetransportation transactions, the quan-tity and cost of gas delivered, and theamount and basis of consideration re-ceived, if other than gas.

181 Unamortized debt expense.This account shall include expenses

related to the issuance or assumptionof debt securities. Amounts recorded inthis account shall be amortized overthe life of each respective issue under aplan which will distribute the amountequitably over the life of the security.The amortization shall be on a month-ly basis, and the amounts thereof shallbe charged to account 428, Amortiza-tion of Debt Discount and Expense.Any unamortized amounts outstandingat the time that the related debt is pre-maturely reacquired shall be accountedfor as indicated in General Instruction17.

182.1 Extraordinary property losses.A. When authorized or directed by

the Commission, this account shall in-clude extraordinary losses, which couldnot reasonably have been anticipatedand which are not covered by insuranceor other provisions, such as unforeseendamages to property.

B. Application to the Commission forpermission to use this account shall beaccompanied by a statement giving acomplete explanation with respect tothe items which it is proposed to in-clude herein, the period over which,and the accounts to which it is pro-posed to write off the charges, andother pertinent information.



541


182.2 Unrecovered plant and regu-latory study costs.

A. This account shall include: (1)Nonrecurring costs of studies and anal-yses mandated by regulatory bodies re-lated to plants in service, transferredfrom account 183.2, Other PreliminarySurvey and Investigation Charges, andnot resulting in construction; and (2)when authorized by the Commission,significant unrecovered costs of plantfacilities where construction has beencancelled or which have been pre-maturely retired.

B. This account shall be credited andaccount 407.1, Amortization of Prop-erty Losses, Unrecovered Plant andRegulatory Study Costs, shall be deb-ited, over the period specified by theCommission.

C. Any additional costs incurred, rel-ative to the cancellation or prematureretirement, may be included in this ac-count and amortized over the remain-ing period of the original amortizationperiod. Should any gains of recoveriesbe realized relative to the cancelled orprematurely retired plant, suchamounts shall be used to reduce theunamortized amount of the costs re-corded herein.

D. In the event that the recovery ofcosts included herein is disallowed inrate proceedings, the disallowed costsshall be charged to account 426.5, OtherDeductions, or account 435, Extraor-dinary deductions, in the year of suchdisallowance.

182.3 Other regulatory assets.A. This account shall include the

amounts of regulatory-created assets,not includible in other accounts, re-sulting from the ratemaking actions ofregulatory agencies. (See Definition No.31.)

B. The amounts included in this ac-count are to be established by thosecharges which would have been in-cluded in net income determinations inthe current period under the generalrequirements of the Uniform System ofAccounts but for it being probable thatsuch items will be included in a dif-ferent period(s) for purposes of develop-ing the rates that the utility is author-ized to charge for its utility services.Where specific identification of theparticular source of the regulatory

asset cannot be made, such as in plantphase-ins, rate moderation plans, orrate levelization plans, Account 407.4,Regulatory Credits, shall be credited.The amounts recorded in this accountare generally to be charged, concur-rently with the recovery of theamounts in rates, to the same accountthat would have been charged if in-cluded in income when incurred, exceptall regulatory assets establishedthrough the use of Account 407.4 shallbe charged to Account 407.3, Regu-latory Debits, concurrent with the re-covery of the amounts in rates.

C. If rate recovery of all or part of anamount included in this account is dis-allowed, the disallowed amount shallbe charged to Account 426.5, Other De-ductions, or Account 435, Extraor-dinary Deductions, in the year of thedisallowance.

D. The records supporting the entriesto this account shall be kept so thatthe utility can furnish full informationas to the nature and amount of eachregulatory asset included in this ac-count, including justification for inclu-sion of such amounts in this account.

183.1 Preliminary natural gas surveyand investigation charges.

A. This account shall be charged withall expenditures for preliminary sur-veys, plans, investigations, etc. madefor the purpose of determining the fea-sibility of acquiring land and landrights to provide a future supply ofnatural gas. If such land or land rightsare acquired, this account shall becredited and the appropriate gas plantaccount (see gas plant instruction 7–G)charged with the amount of the ex-penditures relating to such acquisition.If a project is abandoned involving anatural gas lease acquired before Octo-ber 8, 1969, the expenditures relatedthereto shall be charged to account 798,Other Exploration. If a project is aban-doned involving a lease acquired afterOctober 7, 1969, the expenditures relat-ed thereto shall be charged to account338, Unsuccessful Exploration and De-velopment Costs.

B. The records supporting the entriesto this account shall be so kept thatthe utility can furnish, for each inves-tigation, complete information as to



542


the identification and location of terri-tory investigated, the number or otheridentification assigned to the landtract or leasehold acquired, and the na-ture and respective amounts of thecharges.

NOTE: The amount of preliminary surveyand investigation charges transferred to gasplant shall not exceed the expenditureswhich may reasonably be determined to con-tribute directly and immediately and with-out duplication to gas plant.

183.2 Other preliminary survey andinvestigation charges.

A. This account shall be charged withall expenditures for preliminary sur-veys, plans, investigations, etc., madefor the purpose of determining the fea-sibility of utility projects under con-templation, other than the acquisitionof land and land rights to provide a fu-ture supply of natural gas. If construc-tion results, this account shall be cred-ited and the appropriate utility plantaccount charged. If the work is aban-doned, the charge shall be made to ac-count 426.5, Other Deductions, or theappropriate operating expense ac-

count.B. This account shall also include

costs of studies and analyses mandatedby regulatory bodies related to plant inservice. If construction results fromsuch studies, this account shall becredited and the appropriate utilityplant account charged with an equi-table portion of such study costs di-rectly attributible to new construc-tion. The portion of such study costsnot attributible to new construction orthe entire cost if construction does notresult shall be charged to account 182.2,Unrecovered Plant and RegulatoryStudy Costs, or the appropriate operat-ing expense account. The costs of suchstudies relative to plant under con-struction shall be included directly inaccount 107, Construction Work inProgress—Gas.

C. The records supporting the entriesto this account shall be so kept thatthe utility can furnish complete infor-mation as to the nature and the pur-pose of the survey, plans, or investiga-tions and the nature and amounts ofthe several charges.

NOTE: The amount of preliminary surveyand investigation charges transferred to util-ity plant shall not exceed the expenditureswhich may reasonably be determined to con-tribute directly and immediately and with-out duplication to utility plant.

184 Clearing accounts.

This caption shall include undistrib-uted balances in clearing accounts atthe date of the balance sheet. Balancesin clearing accounts shall be substan-tially cleared not later than the end ofthe calendar year unless items heldtherein relate to a future period.

185 Temporary facilities.

This account shall include amountsshown by work orders for plant in-stalled for temporary use in utilityservice for periods of less than oneyear. Such work orders shall becharged with the cost of temporary fa-cilities and credited with payments re-ceived from customers and net salvagerealized on removal of the temporaryfacilities. Any net credit or debit re-sulting shall be cleared to account 488,Miscellaneous Service Revenues.

186 Miscellaneous deferred debits.

A. This account shall include all deb-its not elsewhere provided for, such asmiscellaneous work in progress, con-struction certificate application feespaid prior to final disposition of the ap-plication as provided for in gas plantinstruction 15A, and unusual or ex-traordinary expenses not included inother accounts which are in process ofamortization, and items the final dis-position of which is uncertain.

B. The records supporting the entriesto this account shall be so kept thatthe utility can furnish full informationas to each deferred debit included here-in.

187 Deferred losses from disposition ofutility plant.

This account shall include lossesfrom the sale or other disposition ofproperty previously recorded in ac-count 105, Gas Plant Held for FutureUse and account 105.1, ProductionProperties Held for Future Use, underthe provisions of paragraphs B, C, and



543


D thereof, where such losses are signifi-cant and are to be amortized over a pe-riod of 5 years, unless otherwise au-thorized by the Commission. The amor-tization of the amounts in this accountshall be made by debits to account411.7, Losses from Disposition of Util-ity Plant. Subdivision of this accountshall be maintained so that amountsrelating to account 105, Gas Plant Heldfor Future Use and account 105.1, Pro-duction Properties Held for FutureUse, can be readily identifiable. (Seeaccounts 105, Gas Plant Held for FutureUse and 105.1, Production PropertiesHeld for Future Use.)

188 Research, development, and dem-onstration expenditures.

A. This account shall be charged withthe cost of all expenditures comingwithin the meaning of Research, Devel-opment, and Demonstration (R.D. & D.)of this Uniform Systems of Accounts(see definition 28.B), except those ex-penditures properly chargeable to Ac-count 107, Construction Work inProgress—Gas.

B. Costs that are minor or of a gen-eral or recurring nature shall be trans-ferred from this account to the appro-priate operating expense function or ifsuch costs are common to the overalloperations or cannot be feasibly allo-cated to the various operating ac-counts, then such costs shall be re-corded in account 930.2, MiscellaneousGeneral Expenses.

C. In certain instances a companymay incur large and significant re-search, development, and demonstra-tion expenditures which are non-recurring and which would distort theannual research, development, anddemonstration charges for the period.In such a case the portion of suchamounts that cause the distortion maybe amortized to the appropriate operat-ing expense account over a period notto exceed five years unless otherwiseauthorized by the Commission.

D. The entries in this account mustbe so maintained as to show separatelyeach project along with complete de-tail of the nature and purpose of the re-search, development, and demonstra-tion project together with the relatedcosts.

189 Unamortized loss on reacquireddebt.

This account shall include the losseson long-term debt reacquired or re-deemed. The amounts in this accountshall be amortized in accordance withGeneral Instruction 17.

190 Accumulated deferred incometaxes.

A. This account shall be debited andaccount 411.1, Provision for DeferredIncome Taxes—Credit, Utility Operat-ing Income, or account 411.2, Provisionfor Deferred Income Taxes—Credit,Other Income and Deductions, as ap-propriate, shall be credited with anamount equal to that by which incometaxes payable for the year are higherbecause of the inclusion of certainitems in income for tax purposes,which items for general accountingpurposes will not be fully reflected inthe utility’s determination of annualnet income until subsequent years.

B. This account shall be credited andaccount 410.1, Provision for DeferredIncome Taxes, Utility Operating In-come, or account 410.2, Provision forDeferred Income Taxes, Other Incomeand Deductions, as appropriate, shallbe debited with an amount equal tothat by which income taxes payable forthe year are lower because of prior pay-ment of taxes as provided by paragraphA above, because of difference in tim-ing for tax purposes of particular itemsof income or income deductions fromthat recognized by the utility for gen-eral accounting purposes. Such creditto this account and debit to account410.1 or 410.2 shall, in general, representthe effect on taxes payable in the cur-rent year of the smaller amount ofbook income recognized, or the largerdeduction permitted, for tax purposesas compared to the amount recognizedin the utility’s current accounts withrespect to the item or class of items forwhich deferred tax concept of account-ing is affected.

C. Vintage year records with respectto entries to this account, as describedabove, and the account balance shall beso maintained as to show the factor ofcalculation with respect to each annualamount of the item or class of itemsfor which deferred tax accounting bythe utility is utilized.



544


D. The utility is restricted in its useof this account to the purpose set forthabove. It shall not make use of the bal-ance in this account or any portionthereof except as provided in the textof this account, without prior approvalof the Commission. Any remaining de-ferred tax account balance with respectto an amount for any prior year’s taxdeferral, the amortization of which orother recognition in the utility’s in-come accounts has been completed, orother disposition made, shall be deb-ited to account 410.1, Provision for De-ferred Income Taxes, Utility OperatingIncome, or account 410.2, Provision forDeferred Income Taxes, Other Incomeand Deductions, as appropriate, or oth-erwise disposed of as the Commissionmay authorize or direct. (See GeneralInstruction 18.)

191 Unrecovered purchased gas costs.A. This account shall include pur-

chase gas costs related to Commissionapproved purchased gas adjustmentclauses when such costs are not in-cluded in the utility’s rate schedule onfile with the Commission. This accountshall also include such other costs asauthorized by the Commission.

B. This account shall be debited orcredited, as appropriate, each monthfor increases or decreases in purchasedgas costs with contra entries to Ac-count 805.1, Purchased Gas Cost Adjust-ments.

C. After a change in a rate schedulerecognizing the increases or decreasesin purchased gas costs recorded in thisaccount is approved by the Commis-sion, this account shall be debited orcredited, as appropriate, with contraentries to expense Account 805.1, Pur-chased Gas Cost Adjustments, so thatthe balance accumulated in this ac-count will be amortized on an appro-priate basis over a succeeding 6–monthperiod or over such other periods thatthe Commission may have authorized.Any over or under applied debits orcredits to this account shall be carriedforward to the succeeding period of am-ortization.

D. Separate subaccounts shall bemaintained for the amounts relating tothe period in which the increase or de-crease is accumulated and for the am-ortization of purchase gas increases or

decreases, as applicable, so as to keepeach period separate.

201 Common stock issued.

202 Common stock subscribed.

203 Common stock liability for conver-sion.

204 Preferred stock issued.

A. These accounts shall include thepar value or the stated value of stockwithout par value if such stock has astated value, and, if not, the cash valueof the consideration received for suchnonpar stock, of each class of capitalstock actually issued, including the paror stated value of such capital stock inaccount 124, Other Investments and ac-count 217, Reacquired Capital Stock.

B. When the actual cash value of theconsideration received is more or lessthan the par or stated value of anystock having a par or stated value, thedifference shall be credited or debited,as the case may be, to the premium ordiscount account for the particularclass and series.

C. When capital stock is retired,these accounts shall be charged withthe amount at which such stock is car-ried herein.

D. A separate ledger account, with adescriptive title, shall be maintainedfor each class and series of stock. Thesupporting records shall show theshares nominally issued, actuallyissued, and nominally outstanding.

NOTE: When a levy or assessment, except acall for payment on subscriptions, is madeagainst holders of capital stock, the amountcollected upon such levy or assessment shallbe credited to account 207, Premium on Cap-ital Stock; provided, however, that the cred-it shall be made to account 213, Discount onCapital Stock, to the extent of any remain-ing balance of discount on the issue of stock.

205 Preferred stock subscribed.A. These accounts shall include the

amount of legally enforceable subscrip-tions to capital stock of the utility.They shall be credited with the par orstated value of the stock subscribed,exclusive of accrued dividends, if any.Concurrently, a debit shall be made tosubscriptions to capital stock, includedas a Other Accounts Receivable, for the



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agreed price and any discount or pre-mium shall be debited or credited tothe appropriate discount or premiumaccount. When properly executed stockcertificates have been issued represent-ing the shares subscribed, this accountseparate subdivision of account 143,shall be debited, and the appropriatecapital stock account credited, withthe par or stated value of such stock.

B. The records shall be kept in suchmanner as to show the amount of sub-scriptions to each class and series ofstock.

206 Preferred stock liability for con-version.

A. These accounts shall include thepar value or stated value, as appro-priate, of capital stock which the util-ity has agreed to exchange for out-standing securities of other companiesin connection with the acquisition ofproperties of such companies underterms which allow the holders of thesecurities of the other companies tosurrender such securities and receive inreturn therefor capital stock of the ac-counting utility.

B. When the securities of the othercompanies have been surrendered andcapital stock issued in accordance withthe terms of the exchange, these ac-counts shall be charged and accounts201, Common Stock Issued, or 204, Pre-ferred Stock Issued, as the case maybe, shall be credited.

C. The records shall be kept so as toshow separately the stocks of eachclass and series for which a conversionliability exists.

207 Premium on capital stock.A. This account shall include, in a

separate subdivision for each class andseries of stock, the excess of the actualcash value of the consideration re-ceived on original issues of capitalstock over the par or stated value andaccrued dividends of such stock, to-gether with assessments against stock-holders representing payments re-quired in excess of par or stated values.

B. Premium on capital stock shallnot be set off against expenses. Fur-ther, a premium received on an issue ofa certain class or series of stock shallnot be set off against expenses of an-other issue of the same class or series.

C. When capital stock which has beenactually issued is retired, the amountin this account applicable to the sharesretired shall be transferred to account210, Gain on Resale or Cancellation ofReacquired Capital Stock.

208 Donations received from stock-holders.

This account shall include the bal-ance of credits for donations receivedfrom stockholders consisting of capitalstock of the utility, cancellation or re-duction of debt of the utility, and thecash value of other assets received as adonation.

209 Reduction in par or stated valueof capital stock.

This account shall include the bal-ance of credits arising from a reductionin the par or stated value of capitalstock.

210 Gain on resale or cancellation ofreacquired capital stock.

This account shall include the bal-ance of credits arising from the resaleor cancellation of reacquired capitalstock. (See account 217, ReacquiredCapital Stock.)

211 Miscellaneous paid-in capital.This account shall include the bal-

ance of all other credits for paid.in cap-ital which are not properly includiblein the foregoing accounts. This accountmay include all commissions and ex-penses incurred in connection with theissuance of capital stock.

NOTE: Amounts included in capital surplusat the effective date of this system of ac-counts which cannot be classified as to thesource thereof shall be included in this ac-count.

212 Installments received on capitalstock.

A. This account shall include in aseparate subdivision for each class andseries of capital stock the amount ofinstallments received on capital stockon a partial or installment paymentplan from subscribers who are notbound by legally enforceable subscrip-tion contracts.

B. As subscriptions are paid in fulland certificates issued, this account



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shall be charged and the appropriatecapital stock account credited with thepar or stated value of such stock. Anydiscount or premium on an originalissue shall be included in the appro-priate discount or premium account.

213 Discount on capital stock.A. This account shall include in a

separate subdivision for each class andseries of capital stock all discount onthe original issuance and sale of cap-ital stock, including additional capitalstock of a particular class or series aswell as first issues.

B. When capital stock which has beenactually issued is retired, the amountin this account applicable to the sharesretired shall be written off to account210, Gain on Resale or Cancellation ofReacquired Capital Stock, provided,however, that the amount shall becharged to account 439, Adjustments toRetained Earnings, to the extent thatit exceeds the balance in account 210.

214 Capital stock expense.A. This account shall include in a

separate subdivision for each class andseries of stock all commissions and ex-penses incurred in connection with theoriginal issuance and sale of capitalstock, including additional capitalstock of a particular class or series aswell as first issues. Expenses applicableto capital stock shall not be deductedfrom premium on capital stock.

B. When capital stock which has beenactually issued by the utility is re-tired, the amount in this account ap-plicable to the shares retired shall bewritten off to account 210, Gain on Re-sale or Cancellation of Reacquired Cap-ital Stock, provided, however, that theamount shall be charged to account439, Adjustments to Retained Earnings,to the extent that it exceeds the bal-ance in account 210.

NOTE A: Expenses in connection with thereacquisition or resale of the utility’s cap-ital stock shall not be included herein.

NOTE B: The utility may write off capitalstock expense in whole or in part by chargesto account 211, Miscellaneous Paid-In Cap-ital.

215 Appropriated retained earnings.This account shall include the

amount of earned surplus which has

been appropriated or set aside for spe-cific purposes. Separate subaccountsshall be maintained under such titlesas will designate the purpose for whicheach appropriation was made.

216 Unappropriated retained earn-ings.

This account shall include the bal-ances, either debit or credit, of unap-propriated retained earnings arisingfrom earnings of the utility. This ac-count shall not include any amountsrepresenting the undistributed earn-ings of subsidiary companies.

216.1 Unappropriated undistributedsubsidiary earnings.

This account shall include the bal-ances, either debit or credit, of undis-tributed retained earnings of subsidi-ary companies since their acquisition.When dividends are received from sub-sidiary companies and the balanceshave been included in this account,this account shall be debited and ac-count 216, Unappropriated RetainedEarnings, credited.

217 Reacquired capital stock.A. This account shall include in a

separate subdivision for each class andseries of capital stock, the cost of cap-ital stock actually issued by the utilityand reacquired by it and not retired orcanceled, except, however, stock whichis held by trustees in sinking or otherfunds.

B. When reacquired capital stock isretired or canceled, the difference be-tween its cost, including commissionsand expenses paid in connection withthe reacquisition, and its par or statedvalue plus any premium and less anydiscount and expenses applicable to theshares retired, shall be debited or cred-ited, as appropriate, to account 210,Gain on Resale or Cancellation of Re-acquired Capital Stock, provided, how-ever, that debits shall be charged to ac-count 439, Adjustments to RetainedEarnings, to the extent that they ex-ceed the balance in account 210.

C. When reacquired capital stock isresold by the utility, the difference be-tween the amount received on the re-sale of the stock, less expenses in-curred in the resale, and the cost of thestock included in this account shall be



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accounted for as outlined in paragraphB.

NOTE A: See account 124. Other Invest-ments, for permissive accounting treatmentof stock reacquired under a definite plan forresale.

NOTE B: The accounting for reacquiredstock shall be as prescribed herein unlessotherwise specifically required by statute.

221 Bonds.

This account shall include in a sepa-rate subdivision for each class and se-ries of bonds the face value of the actu-ally issued and unmatured bonds whichhave not been retired or canceled; alsothe face value of such bonds issued byothers the payment of which has beenassumed by the utility.

222 Reacquired bonds.

A. This account shall include the facevalue of bonds actually issued or as-sumed by the utility and reacquired byit and not retired, or canceled. The ac-count for reacquired debt shall not in-clude securities which are held bytrustee in sinking or other funds.

B. When bonds are reacquired, thedifference between face value, adjustedfor unamortized discount, expenses orpremium, and the amount paid uponreacquisition, shall be included in ac-count 189, Unamortized Loss on Reac-quired Debt, or account 257,Unamortized Gain on Reacquired Debt,as appropriate. (See General Instruc-tion 17.)

223 Advances from associated compa-nies.

A. This account shall include the facevalue of notes payable to associatedcompanies and the amount of openbook accounts representing advancesfrom associated companies. It does notinclude notes and open accounts rep-resenting indebtedness subject to cur-rent settlement which are includible inaccount 233, Notes Payable to Associ-ated Companies, or account 234, Ac-counts Payable to Associated Compa-nies.

B. The records supporting the entriesto this account shall be so kept thatthe utility can furnish complete infor-mation concerning each note and openaccount.

224 Other long-term debt.

A. This account shall include, untilmaturity, all long-term debt not other-wise provided for. This covers suchitems as receivers’ certificates, real es-tate mortgages executed or assumed,assessments for public improvements,notes and unsecured certificates of in-debtedness not owned by associatedcompanies, receipts outstanding forlong-term debt, and other obligationsmaturing more than one year fromdate of issue or assumption.

B. Separate accounts shall be main-tained for each class of obligation, andrecords shall be maintained to show foreach class all details as to date of obli-gation, date of maturity, interest datesand rates, security for the obligation,etc.

NOTE: Miscellaneous long-term debt reac-quired shall be accounted for in accordancewith the procedure set forth in account 222,Reacquired Bonds.

225 Unamortized premium on long-term debt.

A. This account shall include the ex-cess of the cash value of considerationreceived over the face value upon theissuance or assumption of long-termdebt securities.

B. Amounts recorded in this accountshall be amortized over the life of eachrespective issue under a plan whichwill distribute the amount equitablyover the life of the security. The amor-tization shall be on a monthly basis,with the amounts thereof to be cred-ited to account 429, Amortization ofPremium on Debt—Credit. (See Gen-eral Instruction 17.)

226 Unamortized discount on long-term debt—Debit.

A. This account shall include the ex-cess of the face value of long-term debtsecurities over the cash value of con-sideration received therefor, related tothe issue or assumption of all typesand classes of debt.

B. Amounts recorded in this accountshall be amortized over the life of therespective issues under a plan whichwill distribute the amount equitablyover the life of the securities. The am-ortization shall be on a monthly basis,with the amounts thereof charged to



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account 428, Amortization of Debt Dis-count and Expense. (See General In-struction 17.)

SPECIAL INSTRUCTIONS FOR CURRENT ANDACCRUED LIABILITIES

Current and accrued liabilities are thoseobligations which have either matured orwhich become due within one year from thedate thereof; except, however, bonds, receiv-ers’ certificates and similar obligationswhich shall be classified as long-term debtuntil date of maturity; accrued taxes, suchas income taxes, which shall be classified asaccrued liabilities even though payable morethan one year from date; compensationawards, which shall be classified as currentliabilities regardless of date due; and minoramounts payable in installments which maybe classified as current liabilities. If a liabil-ity is due more than one year from date ofissuance or assumption by the utility, itshall be credited to a long-term debt accountappropriate for the transaction, except, how-ever, the current liabilities previously men-tioned.

227 Obligations under capital leases—noncurrent.

This account shall include the por-tion not due within one year, of the ob-ligations recorded for the amounts ap-plicable to leased property recorded asassets in account 101.1, Property underCapital Leases, or account 121, Nonutil-ity property.

SPECIAL INSTRUCTIONS TO ACCOUNTS 228.1THROUGH 228.4

No amounts shall be credited to these ac-counts unless authorized by a regulatory au-thority or authorities to be collected in autility’s rate levels.

228.1 Accumulated provision for prop-erty insurance.

A. This account shall includeamounts reserved by the utility forlosses through accident, fire, flood, orother hazards to its own property orproperty leased from others, not cov-ered by insurance. The amountscharged to account 924, Property Insur-ance, or other appropriate accounts tocover such risks shall be credited tothis account. A schedule of risks cov-ered shall be maintained, giving a de-scription of the property involved, thecharacter of the risks covered and therates used.

B. Charges shall be made to this ac-count for losses covered, not to exceedthe account balance. Details of thesecharges shall be maintained accordingto the year the casualty occurredwhich gave rise to the loss.

228.2 Accumulated provision for inju-ries and damages.

A. This account shall be creditedwith amounts charged to account 925,Injuries and Damages, or other appro-priate accounts, to meet the probableliability, not covered by insurance, fordeaths or injuries to employees andothers, and for damages to propertyneither owned nor held under lease bythe utility.

B. When liability for any injury ordamage is admitted by the utility ei-ther voluntarily or because of the deci-sion of a court or other lawful author-ity, such as a workmens’ compensationboard, the admitted liability shall becharged to this account and credited tothe appropriate current liability ac-count. Details of these charges shall bemaintained according to the year thecasualty occurred which gave rise tothe loss.

NOTE: Recoveries or reimbursements forlosses charged to this account shall be cred-ited hereto; the cost of repairs to property ofothers if provided for herein shall be chargedto this account.

228.3 Accumulated provision for pen-sions and benefits.

A. This account shall include provi-sions made by the utility and amountscontributed by employees for pensions,accident and death benefits, savings,relief, hospital and other providentpurposes, where the funds are includedin the assets of the utility either ingeneral or in segregated fund accounts.

B. Amounts paid by the utility forthe purposes for which this liability isestablished shall be charged hereto.

C. A separate account shall be keptfor each kind of provision includedherein.

NOTE: If employee pension or benefit planfunds are not included among the assets ofthe utility but are held by outside trustees,payments into such funds, or accruals there-for, shall not be included in this account.



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228.4 Accumulated miscellaneous op-erating provisions.

A. This account shall include all op-erating provisions which are not pro-vided for elsewhere.

B. This account shall be maintainedin such manner as to show the amountof each separate provision and the na-ture and amounts of the debits andcredits thereto.

NOTE: This account includes only provi-sions as may be created for operating pur-poses and does not include any reservationsof income the credits for which should becarried in account 215, Appropriated Re-tained Earnings.

229 Accumulated provision for rate re-funds.

A. This account shall be creditedwith amounts charged to Account 496,Provision for Rate Refunds, to providefor estimated refunds where the utilityis collecting amounts in rates subjectto refund.

B. When a refund of any amount re-corded in this account is ordered by aregulatory authority, such amountshall be charged hereto and credited toAccount 242, Miscellaneous Currentand Accrued Liabilities.

C. Records supporting the entries tothis account shall be kept so as toidentify each amount recorded by therespective rate filing docket number.

231 Notes payable.This account shall include the face

value of all notes, drafts, acceptances,or other similar evidences of indebted-ness, payable on demand or within atime not exceeding one year from dateof issue, to other than associated com-panies.

232 Accounts payable.This account shall include all

amounts payable by the utility withinone year, which are not provided for inother accounts.

233 Notes payable to associated com-panies.

234 Accounts payable to associatedcompanies.

These accounts shall includeamounts owing to associated compa-

nies on notes, drafts, acceptances, orother similar evidences of indebted-ness, and open accounts payable on de-mand or not more than one year fromdate of issue or creation.

NOTE: Exclude from these accounts notesand accounts which are includible in account223, Advances from Associated Companies.

235 Customer deposits.This account shall include all

amounts deposited with the utility bycustomers as security for the paymentof bills.

236 Taxes accrued.A. This account shall be credited

with the amount of taxes accrued dur-ing the accounting period, correspond-ing debits being made to the appro-priate accounts for tax charges. Suchcredits may be based upon estimates,but from time to time during the yearas the facts become known, the amountof the periodic credits shall be adjustedso as to include as nearly as can be de-termined in each year the taxes appli-cable thereto. Any amount represent-ing a prepayment of taxes applicable tothe period subsequent to the date ofthe balance sheet, shall be shown underaccount 165, Prepayments.

B. If accruals for taxes are found tobe insufficient or excessive, correctiontherefor shall be made through currenttax accruals.

C. Accruals for taxes shall be basedupon the net amounts payable aftercredit for any discounts, and shall notinclude any amounts for interest ontax deficiencies or refunds. Interest re-ceived on refunds shall be credited toaccount 419, Interest and Dividend In-come, and interest paid on deficienciesshall be charged to account 431, OtherInterest Expense.

D. The records supporting the entriesto this account shall be kept so as toshow for each class of taxes, theamount accrued, the basis for the ac-crual, the accounts to which charged,and the amount of tax paid.

237 Interest accrued.This account shall include the

amount of interest accrued but not ma-tured on all liabilities of the utilitynot including, however, interest which



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is added to the principal of the debt onwhich incurred. Supporting recordsshall be maintained so as to show theamount of interest accrued on each ob-ligation.

238 Dividends declared.This account shall include the

amount of dividends which have beendeclared but not paid. Dividends shallbe credited to this account when theybecome a liability.

239 Matured long-term debt.This account shall include the

amount of long-term debt (includingany obligation for premiums) maturedand unpaid, without specific agreementfor extension of the time of paymentand bonds called for redemption butnot presented.

240 Matured interest.This account shall include the

amount of matured interest on long-term debt or other obligations of theutility at the date of the balance sheetunless such interest is added to theprincipal of the debt on which incurred.

241 Tax collections payable.This account shall include the

amount of taxes collected by the util-ity through payroll deductions or oth-erwise pending transmittal of suchtaxes to the proper taxing authority.

NOTE: Do not include liability for taxes as-sessed directly against the utility which areaccounted for as part of the utility’s own taxexpense.

242 Miscellaneous current and ac-crued liabilities.

A. This account shall include theamount of all other current and ac-crued liabilities not provided for else-where appropriately designated andsupported as to show the nature ofeach liability.

B. The utility is to include in a sepa-rate subaccount amounts payable forgas in unbalanced transactions wheregas is received from another party inexchange, load balancing, or no-noticetransportation transactions. (See Ac-count 806.) If the amount payable issettled by other than gas, Account 495,Other Gas Revenues, must be credited

or Account 813, Other gas supply ex-penses, charged for the difference be-tween the amount of the considerationpaid and the recorded amount of thepayable settled. Records are to bemaintained so that there is readilyavailable for each party entering gasexchange, load balancing, or no-noticetransportation transactions, the quan-tity and cost of gas received and theamount and basis of consideration paidif other than gas.

243 Obligations under capital leases—current.

This account shall include the por-tion due within one year, of the obliga-tions recorded for the amounts applica-ble to leased property recorded as as-sets in account 101.1, Property underCapital Leases, or account 121, Non-Utility Property.

252 Customer advances for construc-tion.

This account shall include advancesby customers for construction whichare to be refunded either wholly or inpart. When a customer is refunded theentire amount to which he is entitled,according to the agreement or ruleunder which the advance was made, thebalance, if any, remaining in this ac-count shall be credited to the respec-tive plant account.

253 Other deferred credits.This account shall include advance

billings and receipts and other deferredcredit items, not provided for else-where, including amounts which can-not be entirely cleared or disposed ofuntil additional information has beenreceived.

254 Other regulatory liabilities.A. This account shall include the

amounts of regulatory liabilities, notincludible in other accounts, imposedon the utility by the ratemaking ac-tions of regulatory agencies. (See Defi-nition No. 30.)

B. The amounts included in this ac-count are to be established by thosecredits which would have been includedin net income determinations in thecurrent period under the general re-quirements of the Uniform System ofAccounts but for it being probable



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that: (1) Such items will be included ina different period(s) for purposes of de-veloping the rates that the utility isauthorized to charge for its utilityservices; or (2) refunds to customers,not provided for in other accounts, willbe required. When specific identifica-tion of the particular source of the reg-ulatory liability cannot be made orwhen the liability arises from revenuescollected pursuant to tariffs on file ata regulatory agency, Account 407.3,Regulatory Debits, shall be debited.The amounts recorded in this accountgenerally are to be credited to thesame account that would have beencredited if included in income whenearned except: (1) All regulatory liabil-ities established through the use of Ac-count 407.3 shall be credited to Account407.4, Regulatory Credits; and (2) in thecase of refunds, a cash account or otherappropriate account should be creditedwhen the obligation is satisfied.

C. If it is later determined that theamounts recorded in this account willnot be returned to customers throughrates or refunds, such amounts shall becredited to Account 421, MiscellaneousNonoperating Income, or Account 434,Extraordinary Income, as appropriate,in the year such determination ismade.

D. The records supporting the entriesto this account shall be so kept thatthe utility can furnish full informationas to the nature and amount of eachregulatory liability included in this ac-count, including justification for inclu-sion of such amounts in this account.

255 Accumulated deferred investmenttax credits.

A. This account shall be creditedwith all investment tax credits de-ferred by companies which have electedto follow deferral accounting, partialor full, rather than recognizing in theincome statement the total benefits ofthe tax credit as realized. After suchelection, a company may not transferamounts from this account, except asauthorized herein and in accounts 411.4,Investment Tax Credit Adjustments,Utility Operations, 411.5, InvestmentTax Credit Adjustments, NonutilityOperations, and 420, Investment TaxCredits, or with approval of the Com-mission.

B. Where the company’s accountingprovides that investment tax creditsare to be passed on to customers, thisaccount shall be debited and account411.4 credited with a proportionateamount determined in relation to theaverage useful life of gas utility plantto which the tax credits relate to suchlesser period of time as allowed by aregulatory agency having rate jurisdic-tion. If, however, the deferral proce-dure provides that investment taxcredits are not to be passed on to cus-tomers the proportionate restorationsto income shall be credited to account420.

C. If any of the investment tax cred-its to be deferred are related to utilityoperations other than gas or to non-utility operations, appropriate subdivi-sions of this account shall be main-tained. Contra entries affecting suchsubdivisions shall be appropriately re-corded in accounts 413, Expenses of GasPlant Leased to Others; or 414, OtherUtility Operating Income.

D. Records shall be maintained iden-tifying the properties related to the in-vestment tax credits for each year, theweighted average service life of suchproperties, and any unused balance ofsuch credits. Such records are not nec-essary unless the credits are deferred.

256 Deferred gains from disposition ofutility plant.

This account shall include gains fromthe sale or other disposition of prop-erty previously recorded in account105, Gas Plant Held for Future Use andaccount 105.1, Production PropertiesHeld for Future Use, under the provi-sions of paragraphs B, C, and D thereof,where such gains are significant andare to be amortized over a period of 5years, unless otherwise authorized bythe Commission. The amortization ofthe amounts in this account shall bemade by credits to account 411.6, Gainsfrom Disposition of Utility Plant. Sub-division of this account shall be main-tained so that amounts relating to ac-count 105, Gas Plant Held for FutureUse and account 105.1, ProductionProperties Held for Future Use, can bereadily identifiable. (See accounts 105,Gas Plant Held for Future Use and ac-count 105.1, Production Properties Heldfor Future Use.)



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257 Unamortized gain on reacquireddebt.

This account shall include theamounts of discount realized upon re-acquisition or redemption of long-termdebt. The amounts in this accountshall be amortized in accordance withGeneral Instruction 17.

SPECIAL INSTRUCTIONS

Accumulated Deferred Income Taxes

A. Before using the deferred tax accountsprovided below refer to General Instruction18. Comprehensive Interperiod Income Tax Allo-cation.

B. The text of these accounts are designedprimarily to cover deferrals of Federal in-come taxes. However, they are also to beused when making deferrals of State andlocal income taxes. Natural gas companieswhich, in addition to a gas utility depart-ment, have another utility department, elec-tric, water, etc., and nonutility propertywhich have deferred taxes on income with re-spect thereto shall separately classify suchdeferrals in the accounts provided below soas to allow ready identification of items re-lating to each utility department and toOther Income and Deductions.

281 Accumulated deferred incometaxes—Accelerated amortizationproperty.

A. This account shall include tax de-ferrals resulting from adoption of theprinciples of comprehensive interpe-riod tax allocation described in Gen-eral Instruction 18 of this system of ac-counts that relate to property forwhich the utility has availed itself ofthe use of accelerated (5-year) amorti-zation of (1) certified defense facilitiesas permitted by Section 168 of the In-ternal Revenue Code and (2) certifiedpollution control facilities as per-mitted by Section 169 of the InternalRevenue Code.

B. This account shall be credited andaccounts 410.1, Provision for DeferredIncome Taxes, Utility Operating In-come, or 410.2, Provision for DeferredIncome Taxes, Other Income and De-ductions, as appropriate, shall be deb-ited with tax effects related to prop-erty described in paragraph A abovewhere taxable income is lower thanpretax accounting income due to dif-ferences between the periods in whichrevenue and expense transactions af-

fect taxable income and the periods inwhich they enter into the determina-tion of pretax accounting income.

C. This account shall be debited andaccounts 411.1, Provision for DeferredIncome Taxes—Credit, Utility Operat-ing Income, or 411.2, Provision for De-ferred Income Taxes—Credit, Other In-come and Deductions, as appropriate,shall be credited with tax effects relat-ed to property described in paragraphA above where taxable income is higherthan pretax accounting income due todifferences between the periods inwhich revenue and expense trans-actions affect taxable income and theperiods in which they enter into the de-termination of pretax accounting in-come.

D. The utility is restricted in its useof this account to the purposes setforth above. It shall not transfer thebalance in this account or any portionthereof to retained earnings or makeany use thereof except as provided inthe text of this account without priorapproval of the Commission. Upon thedisposition by sale, exchange, transfer,abandonment or premature retirementof plant on which there is a related bal-ance herein, this account shall becharged with an amount equal to therelated income tax expense, if any,arising from such disposition and ac-count 411.1, Provision for Deferred In-come Taxes—Credit, Utility OperatingIncome, or 411.2, Provision for DeferredIncome Taxes—Credit, Other Incomeand Deductions, as appropriate, shallbe credited. When the remaining bal-ance, after consideration of any relatedincome tax expense, is less than $25,000,this account shall be charged and ac-count 411.1 or 411.2, as appropriate,credited with such balance. If afterconsideration of any related incometax expense, there is a remainingamount of $25,000 or more, the Commis-sion shall authorize or direct how suchamount shall be accounted for at thetime approval for the disposition of ac-counting is granted. When plant is dis-posed of by transfer to a wholly ownedsubsidiary the related balance in thisaccount shall also be transferred. Whenthe disposition relates to retirement ofan item or items under a group methodof depreciation where there is no tax



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effect in the year of retirement, no en-tries are required in this account if itcan be determined that the related bal-ances would be necessary to be re-tained to offset future group item taxdeficiencies.

282 Accumulated deferred incometaxes—Other property.

A. This account shall include the taxdeferrals resulting from adoption of theprinciple of comprehensive interperiodincome tax allocation described inGeneral Instruction 18 of this system ofaccounts which are related to all prop-erty other than accelerated amortiza-tion property.

B. This account shall be credited andaccounts 410.1, Provision for DeferredIncome Taxes, Utility Operating In-come, or 410.2, Provision for DeferredIncome Taxes, Other Income and De-ductions, as appropriate, shall be deb-ited with tax effects related to prop-erty described in paragraph A abovewhere taxable income is lower thanpretax accounting income due to dif-ferences between the periods in whichrevenue and expense transactions af-fect taxable income and the periods inwhich they enter into the determina-tion of pretax accounting income.

C. This account shall be debited andaccounts 411.1, Provision for DeferredIncome Taxes—Credit, Utility Operat-ing Income, or 411.2, Provision for De-ferred Income Taxes—Credit, Other In-come and Deductions, as appropriate,shall be credited with tax effects relat-ed to property described in paragraphA above where taxable income is higherthan pretax accounting income due todifferences between the periods inwhich revenue and expense trans-actions affect taxable income and theperiods in which they enter into the de-termination of pretax accounting in-come.

D. The utility is restricted in its useof this account to the purposes setforth above. It shall not transfer thebalance in this account or any portionthereof to retained earnings or makeany use thereof except as provided inthe text of this account without priorapproval of the Commission. Upon thedisposition by sale, exchange, transfer,abandonment or premature retirementof plant on which there is a related bal-

ance herein, this account shall becharged with an amount equal to therelated income tax expense, if any,arising from such disposition and ac-count 411.1, Income Taxes Deferred inPrior Years—Credit, Utility OperatingIncome, or 411.2, Income Taxes De-ferred in Prior Years—Credit, Other In-come and Deductions, shall be credited.When the remaining balance, after con-sideration of any related tax expenses,is less than $25,000, this account shallbe charged and account 411.1 or 411.2, asappropriate, credited with such bal-ance. If after consideration of any re-lated income tax expense, there is a re-maining amount of $25,000 or more, theCommission shall authorize or directhow such amount shall be accountedfor at the time approval for the disposi-tion of accounting is granted. Whenplant disposed of by transfer to a whol-ly owned subsidiary, the related bal-ance in this account shall also betransferred. When the disposition re-lates to retirement of an item or itemsunder a group method of depreciationwhere there is no tax effect in the yearof retirement, no entries are requiredin this account if it can be determinedthat the related balance would be nec-essary to be retained to offset futuregroup item tax deficiencies.

283 Accumulated deferred incometaxes—Other.

A. This account shall include allcredit tax deferrals resulting from theadoption of the principles of com-prehensive interperiod income tax allo-cation described in General Instruction18 of this system of accounts otherthan those deferrals which are includ-ible in Accounts 281, Accumulated De-ferred Income Taxes—Accelerated Am-ortization Property and 282, Accumu-lated Deferred Income Taxes—OtherProperty.

B. This account shall be credited andaccounts 410.1 Provision for DeferredIncome Taxes, Utility Operating In-come, or 410.2, Provision for DeferredIncome Taxes, Other Income and De-ductions, as appropriate, shall be deb-ited with tax effects related to itemsdescribed in paragraph A above wheretaxable income is lower than pretax ac-counting income due to differences be-tween the periods in which revenue and



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expense transactions affect taxable in-come and the periods in which theyenter into the determination of pretaxaccounting income.

C. This account shall be debited andaccounts 411.1, Provision for DeferredIncome Taxes—Credit, Utility Operat-ing Income or 411.2, Provision for De-ferred Income Taxes—Credit, Other In-come and Deductions, as appropriateshall be credited with tax effects relat-ed to items described in paragraph Aabove where taxable income is higherthan pretax accounting income due todifferences between the periods inwhich revenue and expense trans-actions affect taxable income and theperiods in which they enter into the de-termination of pretax accounting in-come.

D. Records with respect to entries tothis account, as described above, andthe account balance, shall be so main-tained as to show the factors of cal-culation with respect to each annualamount of the item or class of items.

E. The utility is restricted in its useof this account to the purposes setforth above. It shall not transfer thebalance in the account or any portionthereof to retained earnings or to anyother account or make any use thereofexcept as provided in the text of thisaccount, without prior approval of theCommission. Upon the disposition bysale, exchange, transfer, abandonmentor premature retirement of items onwhich there is a related balance herein,this account shall be charged with anamount equal to the related incometax effect, if any, arising from such dis-position and account 411.1, ProvisionFor Deferred Income Taxes—Credit,Utility Operating Income, or 411.2, Pro-vision For Deferred Income Taxes—Credit, Other Income and Deductions,as appropriate, shall be credited. Whenthe remaining balance, after consider-ation of any related tax expenses, isless than $25,000, this account shall becharged and account 411.1 or 411.2, asappropriate, credited with such bal-ance. If after consideration of any re-lated income tax expense, there is a re-maining amount of $25,000 or more, theCommission shall authorize or directhow such amount shall be accountedfor at the time approval for the dis-position of accounting is granted.

When plant is disposed of by transfer toa wholly owned subsidiary, the relatedbalance in this account shall also betransferred. When the disposition re-lates to retirement of an item or itemsunder a group method of depreciationwhere there is no tax effect in the yearof retirement, no entries are requiredin this account if it can be determinedthat the related balance would be nec-essary to be retained to offset futuregroup item tax deficiencies.

Gas Plant Accounts

1. INTANGIBLE PLANT

301 Organization.302 Franchises and consents.303 Miscellaneous intangible plant.

2. PRODUCTION PLANT

A. MANUFACTURED GAS PRODUCTION PLANT

304 Land and land rights.305 Structures and improvements.306 Boiler plant equipment.307 Other power equipment.308 Coke ovens.309 Producer gas equipment.310 Water gas generating equipment.311 Liquefied petroleum gas equipment.312 Oil gas generating equipment.313 Generating equipment—Other processes.314 Coal, coke, and ash handling equipment.315 Catalytic cracking equipment.316 Other reforming equipment.317 Purification equipment.318 Residual refining equipment.319 Gas mixing equipment.320 Other equipment.

B. NATURAL GAS PRODUCTION PLANT

B.1. Natural Gas Production and GatheringPlant

325.1 Producing lands.325.2 Producing leaseholds.325.3 Gas rights.325.4 Rights-of-way.325.5 Other land and land rights.326 Gas well structures.327 Field compressor station structures.328 Field measuring and regulating station

structures.329 Other structures.330 Producing gas wells—Well construction.331 Producing gas wells—Well equipment.332 Field lines.333 Field compressor station equipment.334 Field measuring and regulating station

equipment.335 Drilling and cleaning equipment.336 Purification equipment.337 Other equipment.



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338 Unsuccessful exploration and develop-ment costs.

B.2. Products Extraction Plant340 Land and land rights.341 Structures and improvements.342 Extraction and refining equipment.343 Pipe lines.344 Extracted product storage equipment.345 Compressor equipment.346 Gas measuring and regulating equip-

ment.347 Other equipment.

3. NATURAL GAS STORAGE AND PROCESSINGPLANT

A. UNDERGROUND STORAGE PLANT

350.1 Land.350.2 Rights-of-way.351 Structures and improvements.352 Wells.352.1 Storage leaseholds and rights.352.2 Reservoirs.352.3 Nonrecoverable natural gas.353 Lines.354 Compressor station equipment.355 Measuring and regulating equipment.356 Purification equipment.357 Other equipment.

B. OTHER STORAGE PLANT

360 Land and land rights.361 Structures and improvements.362 Gas holders.363 Purification equipment.363.1 Liquefaction equipment.363.2 Vaporizing equipment.363.3 Compressor equipment.363.4 Measuring and regulating equipment.363.5 Other equipment.

C. BASE LOAD LIQUEFIED NATURAL GASTERMINALING AND PROCESSING PLANT

364.1 Land and land rights .364.2 Structures and improvements.364.3 LNG processing terminal equipment.364.4 LNG transportation equipment.364.5 Measuring and regulating equipment.364.6 Compressor station equipment.364.7 Communication equipment.364.8 Other equipment.

4. TRANSMISSION PLANT

365.1 Land and land rights.365.2 Rights-of-way.366 Structures and improvements.367 Mains.368 Compressor station equipment.369 Measuring and regulating station equip-

ment.370 Communication equipment.371 Other equipment.

5. DISTRIBUTION PLANT

374 Land and land rights.

375 Structures and improvements.376 Mains.377 Compressor station equipment.378 Measuring and regulating station equip-

ment—General.379 Measuring and regulating station equip-

ment—City gate check stations.380 Services.381 Meters.382 Meter installations.383 House regulators.384 House regulatory installations.385 Industrial measuring and regulating

station equipment.386 Other property on customers’ premises.387 Other equipment.

6. GENERAL PLANT

389 Land and land rights.390 Structures and improvements.391 Office furniture and equipment.392 Transportation equipment.393 Stores equipment.394 Tools, shop and garage equipment.395 Laboratory equipment.396 Power operated equipment.397 Communication equipment.398 Miscellaneous equipment.399 Other tangible property.

Gas Plant Accounts

301 Organization.This account shall include all fees

paid to Federal or State governmentsfor the privilege of incorporation andexpenditures incident to organizing thecorporation, partnership, or other en-terprises and putting it into readinessto do business.

ITEMS

1. Cost of obtaining certificates authoriz-ing an enterprise to engage in the publicutility business.

2. Fees and expenses for incorporation.3. Fees and expenses for mergers or con-

solidations.4. Office expenses incident to organizing

the utility.5. Stock and minute books and corporate

seal.NOTE A: This account shall not include any

discounts upon securities issued or assumed;nor shall it include any costs incident to ne-gotiating loans, selling bonds or other evi-dences of debt, or expenses in connectionwith the authorization, issuance, or sale ofcapital stock.

NOTE B: Exclude from this account and in-clude in the appropriate expense account thecost of preparing and filing papers in connec-tion with the extension of the term of incor-poration unless the first organization costshave been written off. When charges are



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made to this account for expenses incurredin mergers, consolidations, or reorganiza-tions, amounts previously included herein orin similar accounts in the books of the com-panies concerned shall be excluded from thisaccount.

302 Franchises and consents.A. This account shall include

amounts paid to the Federal Govern-ment, to a State or to a political sub-division thereof in consideration forfranchises, consents, or certificates,running in perpetuity or for a specifiedterm of more than 1 year, togetherwith necessary and reasonable expensesincident to procuring such franchises,consents, or certificates of permissionand approval, including expenses of or-ganizing and merging separate corpora-tions, where statutes require, solely forthe purpose of acquiring franchises.

B. If a franchise, consent, or certifi-cate is acquired by assignment, thecharge to this account in respect there-of shall not exceed the amount paidtherefor by the utility to the assignor,nor shall it exceed the amount paid bythe original grantee, plus the expenseof acquisition to such grantee. Any ex-cess of the amount actually paid by theutility over the amount above specifiedshall be charged to account 426.5, OtherDeductions.

C. When any franchise has expired,the book cost thereof shall be creditedhereto and charged to account 426.5,Other Deductions, or to account 111,Accumulated Provision for Amortiza-tion and Depletion of Gas UtilityPlant, as appropriate.

D. Records supporting this accountshall be kept so as to show separatelythe book cost of each franchise or con-sent.

NOTE: Annual or other periodic paymentsunder franchises shall not be included hereinbut in the appropriate operating expense ac-count.

303 Miscellaneous intangible plant.A. This account shall include the

cost of patent rights, licenses, privi-leges, and other intangible propertynecessary or valuable in the conduct ofthe utility’s gas operations and notspecifically chargeable to any other ac-count.

B. When any item included in this ac-count is retired or expires, the book

cost thereof shall be credited heretoand charged to account 426.5, Other De-ductions, or account 111, AccumulatedProvision for Amortization and Deple-tion of Gas Utility Plant, as appro-priate.

C. This account shall be maintainedin such a manner that the utility canfurnish full information with respect tothe amounts included herein.

304 Land and land rights.This account shall include the cost of

land and land rights used in connectionwith manufactured gas production.(See gas plant instruction 7.)

305 Structures and improvements.This account shall include the cost of

structures and improvements used inconnection with manufactured gas pro-duction. (See gas plant instruction 8.)

NOTE: Include relief holders in this ac-count.

306 Boiler plant equipment.This account shall include the cost

installed of furnaces, boilers, steamand feed water piping, boiler apparatus,and accessories used in the productionof steam at gas production plants.

ITEMS

1. Accumulators.2. Air preheaters, including fans and

drives, and ducts not part of building.3. Ash disposal equipment, including

sluiceways not part of a building, pumps andpiping, crane, ash bucket conveyor anddrives, ash cars, etc.

4. Belt conveyors, including drives.5. Blast gate valves.6. Blow-down tanks and piping.7. Boilers, including valves attached there-

to, casings, safety valves, soot blowers, soothoppers, superheaters, and feed water regu-lators.

8. Cinder and dust catcher system, includ-ing mechanical and electric types.

9. Coal and coke handling equipment, in-cluding hoppers, lorries, etc., used wholly forboilers.

10. Combustion control system, includingall apparatus installed for the regulation andcontrol of the supply of fuel or air to boilers.

11. Control apparatus.12. Cranes, hoists, etc., wholly identified

with apparatus listed herein.13. Desuperheaters and reducing valves.14. Draft apparatus, including forced, in-

duced, and other draft systems, with blow-ers, fans, and ducts not part of building.



557


15. Economizers.16. Emergency lighting systems, not part

of building, keep-a-lite systems, etc.17. Emergency signal systems, in connec-

tion with boiler operation.18. Feed water heaters, including primary

and stage.19. Flues, uptakes, and breeching, whether

or not stacks are included in this account.20. Foundations and settings, specially

constructed for and not intended to outlastthe apparatus for which provided.

21. Furnaces.22. Gas firing system, including gas lines,

burners, etc., for gas fired boilers.23. Injectors.24. Mechanical stoker and feeding systems,

clinker grinders, including drives.25. Meters, gauges, recording instruments,

etc.26. Oil burning equipment, including tanks,

heaters, pumps with drives, burner equip-ment, piping, and conditioning apparatus.

27. Painting, first cost.28. Panels, control (for operating apparatus

listed herein).29. Piping system, steam header and ex-

haust header, including accessory pipe hang-ers, steam traps, etc., make-up water, feedwater, drip, blow-off, water pipe lines usedfor steam plant, and valve control system.

30. Platforms, railings, steps, gratings,etc., appurtenant to apparatus listed herein.

31. Pulverizing equipment.32. Pumps and driving units, for feed water,

heater condensate, condenser water, anddrip.

33. Stacks—brick, steel, and concrete,when set on separate foundations independ-ent of substructure or superstructure ofbuilding.

34. Steam reheaters.35. Steelwork, especially constructed for

apparatus listed herein.36. Tanks, including surge, weighing, re-

turn, blow-off, feed water storage.37. Tar burning equipment for utilization

of tar as boiler fuel, including tanks, pumps,burner equipment, piping, etc.

38. Waste heat boilers and accessories—stack valve and stack irrespective of loca-tion.

39. Water treatment system, including pu-rifiers, settling tanks, filters, chemical mix-ing and dosing apparatus, etc.

NOTE A: This account shall not includeboilers or steam pipes whose primary pur-pose is the heating of buildings.

NOTE B: When the system for supplyingboiler or condenser water is elaborate, aswhen it includes a dam, reservoir, canal, orpipe line, the cost shall not be charged tothis account but to a special subdivision ofaccount 305, Structures and Improvements—Manufactured Gas.

307 Other power equipment.A. This account shall include the

cost installed of electric generatingand accessory equipment used for sup-plying electricity in gas productionplants.

B. This account shall also include thecost installed of miscellaneous powerequipment at gas production plantswhich is not included in any other ac-count.

ITEMS

1. Acid proofing of battery rooms.2. Air duct runs in battery rooms.3. Air pump, streamjet.4. Batteries for control and general station

use.5. Belts, pulleys, hangers, shafts, and

countershafts.6. Cables between generators and switch-

boards.7. Cabinets, control.8. Compartments, including buses, connec-

tions, and items permanently attached.9. Enclosure equipment not an integral

part of building.10. Engines, including steam rotary or re-

ciprocating, steam turbines, and internalcombustion engines.

11. Foundations and settings, speciallyconstructed for and not intended to outlastthe apparatus for which provided.

12. Generators, a.c. or d.c., including exci-tation system.

13. Ground connections, for main stationground.

14. Lightning arresters.15. Motor generators, frequency changers

and converters.16. Overhead power lines, including poles,

crossarms, insulators, conductors, etc.17. Panels, control, including supports and

instruments.18. Piping applicable to apparatus listed

herein.19. Reactors.20. Rectifiers.21. Safety equipment, including rubber

mats, remote closing devices, glove cabinets.22. Switchboards, including frames, panels,

meters, and instruments.23. Switching equipment, including oil cir-

cuit breakers, disconnecting switches, andconnections.

24. Synchronous converters.25. Transformers, including transformer

platforms.26. Underground conduit system, including

manholes and conductors.NOTE: When any unit of equipment listed

herein is wholly used to furnish power toequipment included in another single ac-count, its cost shall be included in such ac-count.



558


308 Coke ovens.This account shall include the cost

installed of coke ovens used for theproduction of gas.

ITEMS

1. Apparatus for placing coal in ovens.2. Bins, if not part of a building.3. Cabinets, control.4. Calorimeters.5. Cars, quenching.6. Charging lorry.7. Clay mixers.8. Coke guide.9. Coke and pusher benches.10. Collecting mains.11. Control apparatus.12. Conveyor, flight.13. Cover lifting machinery.14. Door handling machine.15. Door luting machine.16. Driving units for coke oven machinery.17. Enclosures for machinery.18. Engines, when not an integral part of

the driven equipment.19. Firing equipment.20. Flues, uptakes, and breeching.21. Foundations.22. Fuel handling equipment used exclu-

sively for coal to be carbonized in ovens.23. Fuel systems under ovens.24. Hot coke wharves.25. Hot coke cars.26. Instruments or meters, electrical.27. Locomotives.28. Mud mill.29. Motor control equipment.30. Ovens.31. Panel, control.32. Piping, including ascension pipes, hy-

draulic main, liquor flushing decanter tank,liquor pump, and return line to hydraulicmain.

33. Pushers, including tracks and drivingequipment.

34. Quenching station including structure,tank, well, piping, etc.

35. Quenching towers, piping, etc.36. Regenerator, from bottom of oven floor

tile to battery foundation.37. Reversing machine, with enclosure.38. Scale, platform.39. Signal system.40. Skip hoist.41. Stacks.42. Steel and iron work supports, plat-

forms, stairways, etc.43. Switches and switchboards.

309 Producer gas equipment.This account shall include the cost

installed of equipment used for the pro-duction of producer gas.

ITEMS

1. Ash handling equipment, used exclu-sively for producers.

2. Blast apparatus, including blowers, driv-ing units, and blast mains.

3. Control apparatus.4. Coolers and scrubbers.5. Driving apparatus for producers.6. Foundations and settings, specially con-

structed for and not intended to outlast theapparatus for which provided.

7. Fuel handling equipment, used exclu-sively for producers.

8. Humidifiers.9. Piping—air, steam (commencing at

steam header), water (inside of building), andproducer gas (up to outlet of final piece ofapparatus in building).

10. Producer boosters, including drivingunits.

11. Producers.12. Water separators.

310 Water gas generating equipment.

This account shall include the costinstalled of equipment used in the gen-eration of water gas.

ITEMS

1. Automatic operation equipment.2. Back-run installations.3. Blast equipment, including blowers and

driving units, piping and supports.4. Bridge, coal shed to generator house.5. Carburetors.6. Charging equipment, fuel.7. Circulating water pumps.8. Concrete or brick pits, including cover,

not part of building.9. Control apparatus.10. Conveyors.11. Dust collectors.12. Enclosures for equipment (barriers, fire

walls, guards, housings, screens, etc.).13. Flow meters.14. Foundations and settings, specially


15. Fuel handling equipment used exclu-sively for fuel for this account.

16. Gauges, indicating and recording.17. Generators.18. Hot valves.19. Hydraulic operation equipment.20. Instruments and meters, electrical.21. Oil handling and storage apparatus used

solely for water gas apparatus (tanks, pumpsand oil lines, oil heaters, manholes, valvepits, regulators, strainers, etc.).

22. Oil spray.23. Operating floors and supports, stair-

ways, etc.24. Piling under foundations.



559


25. Piping and valves—steam (commencingat steam header) tar (to decanter) water (in-side of building), and gas up to outlet of finalpieces of apparatus in building).

26. Pressure regulators.27. Scales, when used in connection with

items in this account.28. Seal pots.29. Superheaters and superheater stacks.30. Tanks, hydraulic pressure.31. Valve operating mechanisms.32. Wash boxes.

311 Liquefied petroleum gas equip-ment.

A. This account shall include thecost installed of equipment used for theproduction of gas from petroleum de-rivatives, such as propane, butane, orgasoline.

B. Subdivisions of this account shallbe maintained for each producing proc-ess for which this account is provided.A separate subaccount shall be main-tained also for bottling equipment in-cluded herein.

ITEMS

1. Blowers.2. Boilers.3. Calorimixer.4. Carbureting equipment.5. Compression equipment.6. Controller.7. Control apparatus.8. Enclosures and protective fences.9. Foundations and settings, specially con-


10. Heat exchanger.11. Gauges and instruments.12. Mixing or proportioning equipment.13. Motors, not an integral part of driven

equipment.14. Odorizing equipment.15. Oil separator.16. Piping—steam (commencing at steam

header), water (inside of building), oil (fromsupply tank), and gas (up to outlet of finalpiece of apparatus in building).

17. Pits.18. Prime movers.19. Pumps, including driving units.20. Regulator.21. Stairs, platforms, and ladders.22. Storage equipment, tanks, etc.23. Superheater.24. Traps.25. Valves—regulating and check.26. Vaporizing equipment.

312 Oil gas generating equipment.This account shall include the cost

installed of equipment used for gener-ating oil gas.

ITEMS

1. Air blast equipment, including blowersand driving units, piping and supports.

2. Air inlet louvres and filters.3. Foundations and settings, specially con-


4. Generating equipment, including auto-matic cycle controls, generators, operatingfloor, superheaters and wash boxes.

5. Instruments and instrument boards,complete with signal lights andthermocouples and including gauge board,pressure gauges, and pyrometers.

6. Meters and regulators, such as, air flowmeter, generator oil meter, steam flowmeter, and steam regulator.

7. Piping and valves, air, steam (commenc-ing at steam header), water (inside building),and oil gas (up to outlet of final piece of ap-paratus in building).

8. Pumps, hydraulic and oil.9. Tanks, hydraulic accumulator, hydraulic

return, oil and steam accumulator.

313 Generating equipment—Otherprocesses.

This account shall include, with sub-divisions for each type of gas produced,the cost installed of generating equip-ment which is not included in any ofthe foregoing accounts, such as bench-es and retorts for the production ofcoal gas, equipment used for generat-ing acetylene gas, etc.

ITEMS

As to coal gas production equipment:1. Benches.2. Charging and drawing machines.3. Control apparatus.4. Equipment for steaming retorts.5. Flues, uptakes and breeching, whether

or not stacks are included in this account.6. Foundations.7. Fuel handling equipment used exclu-

sively for retorts, including weight lorries,tracks, etc., and grinders, breakers, andscreens located in retort house.

8. Fuel system under retorts, includingbuilt-in producers.

9. Piping, including ascension pipes, hy-draulic main, liquor flushing decanter tank.liquor pump, and return line to hydraulicmain.

10. Primary atmospheric condensers.11. Retorts.12. Stacks—brick, steel, and concrete when

set on separate foundations independent of



560


substructure or superstructure of buildings,including lightning arresters.

314 Coal, coke, and ash handlingequipment.

This account shall include the costinstalled of structures or equipmentused for the transportation, storage,washing, and treatment of coal, coke,and ashes, when used for general gasplant operations.

ITEMS

1. Bins—mixing, refuse, storage, etc.2. Boom operating mechanism.3. Breaker equipment.4. Bridges, bridge track, and machinery.5. Bucket conveyors and supports.6. Capstan.7. Cars.8. Chutes.9. Circuit breakers.10. Coal loaders.11. Coal preparation machinery, including

washing and drying equipment.12. Conduit, electrical.13. Conveyors and supports.14. Crane, caterpillar.15. Driving apparatus for equipment listed

herein.16. Elevators.17. Enclosure equipment.18. Engines, not an integral part of driven

equipment.19. Foundations and settings, specially


20. Gravity swing unloader.21. Hoppers.22. Instruments or meters, electrical.23. Ladders, fixed.24. Loading towers and equipment.25. Locomotives.26. Motor generators used only for equip-

ment in this account.27. Panel, control.28. Pitts.29. Pulverizing equipment.30. Railroad sidings and yard tracks.31. Sampling equipment.32. Scales.33. Screens.34. Sheds and fencing.35. Shuttle boom.36. Signal system equipment.37. Silo.38. Skip hoist.39. Stairs, railings, etc.40. Transfer cars and trucks.41. Trestles.42. Turntable.43. Unloaders.44. Weightometer.

315 Catalytic cracking equipment.This account shall include the cost

installed of equipment used for produc-ing gas by the catalytic cracking proc-ess.

ITEMS

1. Caloric meters.2. Catalytic furnace, including catalyst and

foundation.3. Combustion air blowers.4. Compressors, air.5. Control equipment.6. Cooling coils, including foundations.7. Cooling towers, including foundations.8. Enclosures.9. Fractionalizing units.10. Piping and valves.11. Preheaters.12. Pressure regulators.13. Proportioning controls.14. Tanks.15. Vaporizers.

316 Other reforming equipment.This account shall include the cost

installed of equipment, other thancatalytic cracking equipment, used pri-marily for reforming gas with result-ant changes in its chemical composi-tion and calorific value.

ITEMS

1. Blast equipment, including blowers anddriving units, piping, and supports.

2. Control apparatus.3. Foundations and settings, specially con-


4. Fuel and ash handling equipment, usedwholly in reforming gas.

5. Oil gas apparatus, used for reforminggas.

6. Piping—steam (commencing at steamheader), water (inside of building), and gas(up to outlet of final piece of apparatus inbuilding).

7. Pumps and driving units.8. Purifiers for gas to be reformed.9. Regulators.10. Water gas generators, used primarily

for reforming gas.

317 Purification equipment.This account shall include the cost

installed of apparatus used for the re-moval of impurities from gas and appa-ratus for conditioning gas, includingpumps, wells, and other accessory ap-paratus.

ITEMS

1. Blowers for revivifying.



561


2. Blowers for activators.3. Condensers and washer coolers.4. Control apparatus—conduit, cable, cabi-

nets, switchboards, etc.5. Crane or cover lifting equipment, not

part of the structure.6. Dehydrators.7. Engines, not an integral part of driven

equipment.8. Foundations and settings, specially con-

structed for and not intended to outlast theequipment for which provided.

9. Instruments and meters, electric.10. Lubricators.11. Naphthalene and light oil scrubbers.12. Other accessory equipment such as

coolers, spray ponds, pumps, platforms, rail-ings, stairs.

13. Oxide elevators and pits, platforms, ta-bles, and trenches.

14. Piping—air, steam, water, gas, conden-sate, liquor, tar, etc., from inlet valve offirst piece of apparatus to outlet valve offinal piece of apparatus (or, in building, fromentrance to building to exit from building).

15. Precipitators.16. Purifiers—iron oxide or liquid, includ-

ing first filling.17. Recording gauges and thermometers.18. Revivifying air ducts.19. Saturator with auxiliary equipment.20. Scrubbers.21. Seal and drip pots.22. Signal system identified with equip-

ment herein.23. Sulphur removal apparatus.24. Tar extractors and Cottrell

precipitators.25. Tar pumps and tanks.26. Track runs for cranes and hoists.27. Wash boxes.28. Water meters, for cooling water.

318 Residual refining equipment.This account shall include the cost

installed of apparatus used in refiningand handling of residuals except wherethe apparatus is necessary for the oper-ation of property included in account317, Purification Equipment.

ITEMS

1. Ammonia stills, condensers, saturators,etc.

2. Apparatus for removal of residuals frompurifier liquids.

3. Coke filter.4. Coke handling and storage facilities used

solely for coke held for sale.5. Condensers.6. Control apparatus.7. Coolers.8. Decanters.9. Foundations specially constructed for

and not intended to outlast the apparatus forwhich provided.

10. Gauges.11. Heating equipment for apparatus in-

cluded in this account.12. Instruments.13. Light oil stills, washers, etc.14. Piping and pumps.15. Platforms, stairs, and ladders.16. Separators.17. Storage tanks.18. Supports.19. Tar dehydrators, stills, etc.

319 Gas mixing equipment.This account shall include the cost

installed of equipment used for mixingmanufactured and natural gas, or themixing of other gases incident to deliv-ery of such mixed gases to the distribu-tion system.

ITEMS

1. Alcohol units.2. Automatic mixing controls.3. Btu adjustor.4. Calorimeter.5. Calorimixer.6. Compressor.7. Gas heater.8. Gas scrubber (air filter, dust cleaner).9. Gauges and instruments.10. Meters.11. Mixing chambers.12. Odorizing equipment.13. Oil pump units.14. Panel and control equipment.15. Piping and valves.16. Regulators, pressure and ratio.17. Safety alarm equipment.

320 Other equipment.This account shall include the cost

installed of equipment used in the pro-duction of gas, when not assignable toany of the foregoing accounts.

ITEMS

1. Cabinet, control.2. Compressed air system.3. Fire hose carts.4. First aid room equipment.5. Foamite system.6. Foundations and settings specially con-


7. Gasoline pumps.8. Hand pumps.9. Machine shop equipment, such as lathes,

pipe cutting and threading machines, visegrinders, power saw, shop motors, shaftingand belting, drill press, shapers, milling ma-chines, planes, etc.

10. Odorizing equipment.11. Office furniture and equipment.12. Oil foggers.



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13. Panel, control.14. Piping—yard, when not includible in

other accounts.15. Pits.16. Platforms.17. Portable scaffolds, ladders, etc.18. Power shovels.19. Production laboratory equipment.20. Scales, not associated with other equip-

ment.21. Special signal equipment.22. Tractors for general plant use.23. Works exhauster including driving unit

and governor.24. Works station meters, including gauges,

piping and accessories.


Costs Related to Leases Acquired After October7, 1969

The net book value of amounts recorded inthe natural gas production accounts incurredon or related to leases acquired after October7, 1969, shall, in general, not exceed the netrealizable value (estimated selling price lessestimated costs of extraction, completion,and disposal) of recoverable hydrocarbon re-serves discovered on such leases. After initi-ation of exploration and development onleases acquired after October 7, 1969, the util-ity must determine after a reasonable periodof time, and annually thereafter, whetherthe net realizable value of such recoverablereserves will be sufficient to absorb the netbook value of amounts recorded in the ac-counts. The recoverable reserves shall be de-termined and attested to by independent ap-praisers no less frequently than every 3years. If the net realizable value of recover-able reserves is not sufficient to absorb thenet book value of amounts in the productionaccounts, the utility shall reduce the netbook value of the amounts in the accounts tonet realizable value of recoverable reserves.The reduction shall be done by first reducingthe unamortized amounts recorded in Ac-count 338, Unsuccessful Exploration and De-velopment Costs, by debiting Account 404.1,Amortization and Depletion of ProducingNatural Gas Land and Land Rights (forNonmajor companies, 403.1, Depreciation andDepletion Expense). Next, if the net bookvalue related to successful costs exceeds thenet realizable value of the recoverable re-serves, the production plant accounts shallbe written down to such net realizable valueby appropriate charges and credits to the ex-pense and valuation accounts.

325.1 Producing lands.This account shall include the cost of

lands held in fee on which producingnatural gas wells are located, and landsheld in fee which are being drained ofnatural gas through the operation by

the utility of wells on other land. (Seegas plant instruction 7–G.)

325.2 Producing leaseholds.A. This account shall include the

cost of acquiring leaseholds on whichthe utility pays royalties for naturalgas obtained therefrom. (See gas plantinstruction 7–G.)

B. Exclude from this account rentspaid periodically for rights obtainedunder leases. Exclude also from this ac-count the cost of leaseholds which ter-minate in one year or less after theybecome effective.

325.3 Gas rights.This account shall include the cost of

natural gas rights used in producingnatural gas, whereby the utility ob-tains ownership in gas underlying landnot owned or leased by the utility. Itdoes not provide for gas rights whichare leased and which are properlychargeable to account 325.2, ProducingLeaseholds.

325.4 Rights-of-way.This account shall include the cost of

all interests in land which terminatemore than 1 year after they become ef-fective and on which are located gath-ering pipelines, telephone pole lines,and like property used in connectionwith the production of natural gas.(See gas plant instruction 7.)

325.5 Other land and land rights.This account shall include the cost of

land and land rights used in connectionwith the production of natural gas,when not properly assignable to any ofthe foregoing accounts. (See gas plantinstruction 7.)

326 Gas well structures.This account shall include the cost of

well structures and improvements usedin connection with the housing of per-manent bailers and other equipmentnecessary to keep the wells in oper-ation. (See gas plant instruction 8.)

327 Field compressor station struc-tures.

This account shall include the cost ofstructures and improvements used inconnection with the housing of com-pressor station equipment used to raise



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the pressure of natural gas before it isconveyed to the terminus of the fieldlines. (See gas plant instruction 8.)

328 Field measuring and regulatingstation structures.

This account shall include the cost ofstructures and improvements used inconnection with the housing of meters,regulators, and appurtenant appliancesfor measuring and regulating naturalgas before the point where it enters thetransmission or distribution system.(See gas plant instruction 8.)

329 Other structures.This account shall include the cost of

structures and improvements used inconnection with natural gas productionand gathering not provided for else-where. (See gas plant instruction 8.)

330 Producing gas wells—Well con-struction.

This account shall include the cost ofdrilling producing gas wells.

ITEMS

1. Clearing well site.2. Hauling, erecting, dismantling, and re-

moving boilers, portable engines, derricks,rigs, and other equipment and tools used indrilling.

3. Drilling contractors’ charges.4. Drive pipe.5. Fuel or power.6. Labor.7. Rent of drilling equipment.8. Water used in drilling, obtained either

by driving wells, piping from springs orstreams, or by purchase.

9. Hauling well equipment.10. Shooting, fracturing, acidizing.

331 Producing gas wells—Well equip-ment.

This account shall include the cost ofequipment in producing gas wells.

ITEMS

1. Bailing equipment.2. Boilers and drives permanently con-

nected.3. Casing.4. Derrick.5. Fence, when solely an enclosure for

equipment.6. Fittings, including shut-in valves,

bradenheads and casing heads.7. Packing.8. Tank, oil or water, etc.9. Tubing.

332 Field lines.

This account shall include the costinstalled of field lines used in convey-ing natural gas from the wells to thepoint where it enters the transmissionor distribution system.

ITEMS

1. Gathering lines, including pipe, valves,fittings, and supports.

2. Cathodic protection equipment.3. Creek crossings, suspension bridges and

other special construction.4. Line drips and separators.5. Line pack gas.

333 Field compressor station equip-ment.

This account shall include the costinstalled of compressor station equip-ment and associated appliances used toraise the pressure of natural gas beforeit is conveyed to the terminus of thefield lines.

ITEMS

1. Boiler plant, coal handling and ash han-dling equipment for steam powered compres-sor station.

2. Compressed air system equipment.3. Compressor equipment and driving

units, including auxiliaries, foundations,guard rails and enclosures, etc.

4. Electric system equipment, includinggenerating equipment and driving units,power wiring, transformers, regulators, bat-tery equipment, switchboard, etc.

5. Fire fighting equipment.6. Gas lines and equipment, including fuel

supply lines, cooling tower and pond and as-sociated equipment, dehydrators, fuel gasmixers, special pipe bends and connections,and associated scrubbers, separators, tanks,gauges and instruments.

7. Laboratory and testing equipment.8. Lubricating oil system, including cen-

trifuge, filter, tanks, purifier, and lubricat-ing oil piping, etc.

9. Office furniture and fixtures and generalequipment such as heating boilers, steellockers, first-aid equipment, gasoline dis-pensing equipment, lawn mowers, inciner-ators, etc.

10. Shop tools and equipment.11. Water supply and circulation system,

including water well, tank, water piping,cooling tower, spray fence, and water treat-ment equipment, etc., but not includingwater system equipment solely for domesticand general use.



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334 Field measuring and regulatingstation equipment.

This account shall include the costinstalled of meters, gauges, and otherequipment used in measuring and regu-lating natural gas collected in fieldlines before the point where it entersthe transmission or distribution sys-tem.

ITEMS

1. Automatic control equipment.2. Boilers, heaters, etc.3. Foundations, pits, etc.4. Gas cleaners, scrubbers, separators,

dehydrators, etc.5. Gauges and instruments, including pip-

ing, fittings, wiring, etc., and panel boards.6. Headers.7. Meters, orifice or positive, including

piping and connections.8. Oil fogging equipment.9. Odorizing equipment.10. Regulators or governors, including con-

trols and instruments.11. Structures of a minor nature or port-

able type.

335 Drilling and cleaning equipment.This account shall include the cost of

implements and equipment used indrilling and cleaning natural gas wells.

ITEMS

1. Bailers.2. Bits and other drilling tools.3. Boilers.4. Derricks.5. Drilling cables.6. Drilling machines.7. Engines.8. Motors.9. Pulling machines.10. Pumps.11. Rigs.12. Tanks.


installed of apparatus used for the re-moval of impurities from gas and appa-ratus for conditioning gas.

ITEMS

1. Condensers and washer coolers.2. Dehydrators.3. Foundations and settings, specially con-


4. Other accessory equipment, such ascoolers, spray ponds, pumps, platforms, rail-ings, stairs.

5. Piping, from inlet valve of first piece ofapparatus to outlet valve of final piece of ap-paratus (or, in building, from entrance tobuilding to exit from building).

6. Scrubbers.7. Sulphur removal apparatus.8. Water supply system.NOTE: In general this account shall include

all dehydrators located in or adjacent to pro-duction areas which are used to removewater and other stray liquids from gas pro-duced by the utility or purchased in or adja-cent to production areas. In some instancessuch dehydrators may be located some dis-tance from the production sources of the gas.Where, however, the utility has no produc-tion and gathering facilities with respect toany of the gas passing through thedehydrators, such as at the purchase point atthe head of a transmission pipe line com-pany, the dehydrators may be included in ac-count 368, Compressor Station Equipment, oraccount 367, Mains, whichever is the mostpracticable and reasonable under the cir-cumstances. Dehydrators which are an ad-junct to products extraction operations shallbe included in account 342, Extraction andRefining Equipment. Dehydrators used inconnection with underground gas storage op-erations shall be included in account 356, Pu-rification Equipment.


installed of equipment used in the pro-duction and gathering of natural gas,when not assignable to any of the fore-going accounts.

ITEMS

1. Calorimeter.2. Control installation.3. Crane.4. Laboratory equipment.5. Odorizing unit.6. Office furniture and equipment.7. Oil fogger.

338 Unsuccessful exploration and de-velopment costs.

A. This account shall include unsuc-cessful exploration and developmentcosts incurred on or related to hydro-carbon leases, on properties in the con-tiguous 48 States and the State of Alas-ka, acquired after October 7, 1969. Itshall also include costs of a prelimi-nary nature incurred in the search fornatural gas in such areas after October7, 1969.

B. The costs recorded in this accountshall be amortized by debiting account



565


404.1, Amortization and Depletion ofProducing Natural Gas Land and LandRights, and crediting this accountusing the unit-of-production or otheracceptable method of amortization ashydrocarbons are extracted from pro-ducing wells.

C. In general, the unamortized costsrecorded in this account shall not ex-ceed the net realizable value (esti-mated selling price less estimatedcosts of extraction, completion and dis-posal) of proven hydrocarbon reserveson leases acquired after October 7, 1969.(See ‘‘Special Instructions—Costs Re-lated to Leases Acquired After October7, 1969,’’ above.)

340 Land and land rights.

This account shall include the cost ofland and land rights used in connectionwith the processing of natural gas forremoval of gasoline, butane, propane,or other salable products. (See gasplant instruction 7.)

341 Structures and improvements.

This account shall include the cost ofstructures and improvements used inconnection with the processing of natu-ral gas for removal of gasoline, butane,propane, or other salable products. (Seegas plant instruction 8.)

342 Extraction and refining equip-ment.

This account shall include the costinstalled of equipment used for the ex-traction from natural gas of gasoline,butane, propane, or other salable prod-ucts and for the refining of such prod-ucts.

ITEMS

1. Boiler plant equipment, including boiler,boiler setting, heat exchangers, etc.

2. Compressed air system, including aircompressor, air storage tank, etc.

3. Cooling equipment such as coolers, cool-ing tower and accessories for gas, extractedproducts, etc.

4. Cranes, trolleys, and hoists.5. Electrical system, including generator

and driving unit, power lines, transformers,switchboard, yard lighting system, etc.

6. Extraction and refining equipment, suchas absorbers, reabsorbers, stills, de-phlegmators, fractionating towers, stabiliz-ing columns, control apparatus.

7. Foundations and structural supports forequipment items not intended to outlast theequipment for which provided.

8. Fuel regulating and measuring equip-ment.

9. Gasoline blending equipment includingdye pot, educator pumps, lead storage tanks,weighing device, etc.

10. Gauges and instruments.11. Loading racks and associated other

equipment.12. Lubricating oil system.13. Pumps of various types, such as boiler

feed water pumps, loading and transferpumps, drip still pumps, oil pumps, skimmerbasin pumps, etc.

14. Tanks of various types such as accumu-lator and dewatering tanks, separator tanks,gasoline feed tanks, compressed air tanks,oil surge tanks, etc., except tanks classifi-able as storage equipment, account 344.

15. Water supply system including waterwell, water tank and supports, water soft-ener or purification apparatus, travelingwater screen and drive.

16. Yard piping, gas, water, steam, com-pressed air, fuel, vapor, extracted products,including headers, valves, etc., but not in-cluding off-site lines includible in account343, Pipe Lines.

343 Pipe lines.This account shall include the cost

installed of gas and liquids pipe linesused in connection with the processingof natural gas for the removal of gaso-line, butane, propane, or other salableproducts, exclusive of runs of pipe ap-propriately includible in other equip-ment accounts, embracing principallyoff-site gas, gasoline gathering, andloading lines not includible as yard pip-ing in account 342, Extraction and Re-fining Equipment.

ITEMS

1. Gas lines, off-site, relating solely to ex-traction operations.

2. Gasoline gathering lines connecting withoff-site sources.

3. Gathering line drips.4. Instruments, indicating and recording.5. Loading lines connecting with remote

off-site loading racks or storage facilities.6. Pumps and driving units.

344 Extracted product storage equip-ment.

This account shall include the costinstalled of storage tanks and associ-ated equipment used in the storing,prior to sale, of gasoline, butane, pro-pane, and other salable products ex-tracted from natural gas.



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ITEMS

1. Foundations.2. Instruments.3. Regulators.4. Storage tanks for partially or fully proc-

essed products.5. Valves.

345 Compressor equipment.This account shall include the cost

installed of compressor equipment andassociated appliances used in connec-tion with the receipt, processing, andreturn of natural gas processed for re-moval of gasoline, butane, propane, orother salable products.

ITEMS

(See account 333 for items.)

346 Gas measuring and regulatingequipment.

This account shall include the costinstalled of meters, gauges, and otherequipment used in measuring or regu-lating natural gas received and/or re-turned from processing for removal ofgasoline, butane, propane, or other sal-able products.

ITEMS



ing, fittings, wiring, etc., and panel boards.6. Headers.7. Meters, orifice or positive, including pip-

ing and connections.8. Oil fogging equipment.9. Odorizing equipment.10. Regulators or governors, including con-


able type.


installed of equipment used in process-ing natural gas and refining gasoline,butane, propane, and other salableproducts extracted from natural gas,when not assignable to any of the fore-going accounts.

ITEMS

1. Fire fighting equipment.2. Laboratory and testing equipment.3. Miscellaneous equipment, such as first-

aid cabinet, gasoline dispensing pump, heat-

ing boiler, incinerator, lawn mower, ware-house truck.

4. Office furniture and equipment.5. Shop tools and equipment.

SPECIAL INSTRUCTIONS—ACCOUNTS 350.1THROUGH 363.5

The above accounts are to be used bythe transmission and distribution com-panies for the classification of storagefacilities used for peak shaving oper-ations. The accounts shall be sub-divided to classify the peak shavingstorage facilities according to thetransmission or distribution function,if the utility operates both trans-mission and distribution systems. Onlybase load liquefied natural gasterminaling and processing facilitiesare to be classified in accounts 364.1through 364.8.

350.1 Land.This account shall include the cost of

lands held in fee on which undergroundstorage wells are located, and otherlands held in fee within an area utilizedfor the underground storage of gas.(See gas plant instruction 7–G.)


all interests in land which do not ter-minate until more than 1 year afterthey become effective and on which arelocated underground storage lines,telephone poles lines, and like propertyused in connection with undergroundgas storage operations. (See gas plantinstruction 7.)

351 Structures and improvements.A. This account shall include the

cost in place of structures and im-provements used wholly or predomi-nantly in connection with undergroundstorage of natural gas. (See gas plantinstruction 8.)

B. This account shall be subdividedas follows:351.1 Well structures.351.2 Compressor station structures.351.3 Measuring and regulating station

structures.351.4 Other structures.

352 Wells.This account shall include the drill-

ing cost of wells used for injection and



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withdrawal of gas from undergroundstorage projects, including wells keptopen and used for observation.

ITEMS

Drilling:1. Clearing well site.2. Hauling, erecting, dismantling, and re-

moving boilers, portable engines, derricks,rigs, and other equipment and tools used indrilling.

3. Drilling contractors’ charges.4. Drive pipe.5. Fuel or power.6. Labor.7. Rent of drilling equipment.8. Water used in drilling, obtained either

by driving wells, piping from springs orstreams, or by purchase.

9. Hauling well equipment.10. Shooting, fracturing, acidizing.

Equipment:11. Bailing equipment.12. Boilers and drives permanently con-

nected.13. Casing.14. Derrick.15. Fence, when solely an enclosure for

equipment.16. Fittings, including shut-in valves,

bradenheads and casing heads.17. Packing.18. Tank, oil or water, etc.19. Tubing.

352.1 Storage leaseholds and rights.A. This account shall include the

cost of leaseholds, storage rights, min-eral deeds, etc. on lands for the purposeof utilizing subsurface reservoirs forunderground gas storage operations.(See gas plant instruction 7–G.)

B. Exclude from this account rents orother charges paid periodically for useof subsurface reservoirs for under-ground gas storage purposes.

NOTE: Items such as buildings, wells, lines,equipment and recoverable gas used in stor-age operations acquired with land or storageleaseholds and rights are to be classified inthe appropriate accounts.

352.2 Reservoirs.This account shall include costs to

prepare underground reservoirs for thestorage of natural gas.

ITEMS

1. Geological, geophysical and seismiccosts.

2. Plugging abandoned wells.3. Fuel and power.

4. Drilling and equipping fresh water wells,disposal wells, and solution wells.

5. Leaching of salt dome caverns.6. Rentals on storage rights and leases in-

curred during construction and developmentperiod.

7. Gas used during the development period.8. Costs incident to maintaining covenants

of production leaseholds during the periodrequired to convert them to storage lease-holds.

9. Other rehabilitation work.

352.3 Nonrecoverable natural gas.

A. This account shall include thecost of gas in underground reservoirs,including depleted gas or oil fields andother underground caverns or res-ervoirs used for the storage of gaswhich will not be recoverable.

B. Such nonrecoverable gas shall bepriced at cost according to generallyaccepted methods of cost determina-tion consistently applied. (See the Spe-cial Instructions to Accounts 117.1,117.2, and 117.3.

353 Lines.

This account shall include the costinstalled of gas pipe lines used whollyor predominantly for conveying gasfrom point of connection with trans-mission or field lines to undergroundstorage wells and from undergroundstorage wells to the point where thegas enters the transmission or distribu-tion system.

ITEMS

1. Cathodic protection equipment.2. Creek crossings, suspension bridges and

other special construction.3. Lines, including pipe, valves, fittings,

and supports.4. Line drips and separators.5. Line pack gas.

354 Compressor station equipment.

This account shall include the costinstalled of compressor station equip-ment used wholly or predominantly forthe purpose of raising the pressure ofgas for delivery to underground storageor to raise the pressure of gas with-drawn from underground storage fordelivery to the transmission or dis-tribution system.



568


ITEMS









9. Office furniture and fixtures and generalequipment such as steel lockers, first-aidequipment, gasoline dispensing equipment,lawn mowers, incinerators, etc.



355 Measuring and regulating equip-ment.

This account shall include the costinstalled if equipment used wholly orpredominantly for the purpose of meas-uring and regulating deliveries of gasto underground storage and withdraw-als of gas from underground storage.

ITEMS






able type.


installed of apparatus used wholly orpredominantly for the removal of im-purities from and the conditioning of,gas delivered to or removed from un-derground storage fields.

ITEMS




5. Piping, from inlet valve of first piece ofapparatus to outlet valve of final piece of ap-paratus (or, in building, from entrance tobuilding to exit from building).

6. Scrubbers.7. Sulphur removal apparatus.8. Water supply system.


installed of equipment used wholly orpredominantly in connection with un-derground storage of gas, when not as-signable to any of the foregoing ac-counts.

ITEMS

1. Calorimeter.2. Control installation.3. Crane.4. Odorizing unit.5. Office furniture and equipment.6. Oil foggers.


land and land rights used in connectionwith the storage of gas in holders. (Seegas plant instruction 7.)

361 Structures and improvements.This account shall include the cost in

place of structures and improvementsused in connection with the storage ofgas in holders. (See gas plant instruc-tion 8.)

362 Gas holders.This account shall include the cost

installed of holders and associated ap-pliances used in the storage of gasabove ground, or in underground recep-tacles.



569


ITEMS

1. Alarm systems.2. Buried piping, tanks or other under-

ground construction for gas storage.3. Flood and fire control equipment.4. Foundations.5. Holder pistons.6. Holders-waterless, including elevators,

tar apparatus, and inlet and outlet connec-tions.

7. Holders-waterseal, including oil skim-mer, heating equipment, drips, and inlet andoutlet connections.

8. Hortonspheres and high pressure tanks,including inlet and outlet connections, ac-cess equipment, etc.

9. Lighting.10. Pumps.11. Ventilating equipment.12. Walkways.NOTE A: If the utility stores gas by the liq-

uefaction process the holders for such liq-uids, whether above or below ground, shallbe included in a separate subaccount here-under.

NOTE B: Relief holders used in connectionwith manufactured gas operations shall beincluded in account 305, Structures and Im-provements.


installed of apparatus used for the re-moval of impurities from gas and appa-ratus for conditioning gas.

ITEMS




5. Piping from inlet valve of first piece ofapparatus to outlet valve of final piece of ap-paratus (or, in building from entrance tobuilding to exit from building).

6. Scrubbers.7. Sulphur removal apparatus.8. Water supply system.

363.1 Liquefaction equipment.This account shall include the cost

installed of equipment used in lique-faction of natural gas.

ITEMS

1. Cold box.2. Heat exchanger.3. Condensers.4. Pumps.5. Tanks.

363.2 Vaporizing equipment.

This account shall include the costinstalled of vaporizing equipment usedin connection with liquefied naturalgas storage.

363.3 Compressor equipment.

This account shall include the costinstalled of compressor equipment andassociated appliances used in connec-tion with other storage plant.

363.4 Measuring and regulating equip-ment.

This account shall include the costinstalled of equipment used to measuredeliveries of gas to other storage andwithdrawals of gas from other storage.

ITEMS






able type.

363.5 Other equipment.

This account shall include the costinstalled of other equipment used inconnection with the storage of gas inholders.

ITEMS

1. Complete inlet and outlet connections.2. Compressor.3. Foundation.4. Gauges and instruments.5. Regulating apparatus.6. Line pack gas.

364.1 Land and land rights.

A. This account shall include thecost of land and land rights used inconnection with liquefied natural gasterminaling and processing operations.(See gas plant instruction 7.)



570


364.2 Structures and improvements.A. This account shall include the

cost in place of structures and im-provements used in connection withliquefied natural gas terminaling andprocessing operations. (See gas plantinstruction 8.)

B. This account shall be subdividedas follows:

1. Docking and harbor facilities.2. LNG processing terminal structures.3. Measuring and regulating structures.4. Compressor station structures.5. Other structures.

364.3 LNG processing terminal equip-ment.

This account shall include the costinstalled of equipment used to receive,hold, and regasify liquefied natural gasfor delivery into the utility’s trans-mission or distribution system.

ITEMS

1. Aftercoolers.2. Air compressors.3. Air coolers.4. Alarm systems.5. Blowers.6. Cold box, condensers.7. Controls and control apparatus.8. Dikes.9. Drums.10. Electrical power and ignition circuits

including wiring and conduits.11. Emission control equipment.12. Fire control devices and equipment.13. Foundations.14. Generators.15. Heat exchangers.16. Heaters and reheaters.17. Instrumentation.18. Intercoolers.19. Liquefaction compressors.20. Liquefied gas holders and storage

tanks.21. Nitrogen system equipment.22. Plant piping including pipe supports.23. Pollution control facilities.24. Pumps and driving units.25. Stacks.26. Tanks, other than LNG storage tanks

(including ladders, stairs, walkways, andlighting).

27. Unloading and loading arms, and appur-tenant equipment.

28. Valves.29. Vaporizers.30. Waste heat recovery units.31. Water craft not to include LNG tankers

and barges.32. Miscellaneous other equipment.33. Line pack gas.

364.4 LNG transportation equipment.This account shall include the cost of

vehicles used for the transportation ofliquefied natural gas.

ITEMS

1. LNG barges.2. LNG maritime tankers.3. LNG tank trucks.4. Other LNG transportation equipment.

364.5 Measuring and regulating equip-ment.

This account shall include the costinstalled of meters, gauges and otherequipment used in base load LNG oper-ations for measuring or regulating nat-ural gas prior to its entrance into theutility’s transmission or distributionsystem.

ITEMS

1. Automatic control equipment.2. Boilers, heaters, etc.3. Foundation, pits, etc.4. Gas analyzer equipment.5. Gas cleaners, scrubbers, separators,




trols and instruments.12. Stabilization equipment.13. Structures of a minor or portable type.14. Other equipment.

364.6 Compressor station equipment.This account shall include the cost

installed of compressor station equip-ment and associated appliances used inconnection with liquefied natural gasoperations prior to entrance of vapor-ized gas into the utility’s transmissionor distribution system.

ITEMS

1. Boiler plant, coal handling, and ash han-dling equipment for steam powered compres-sor station.

2. Compressed air system equipment.3. Compressor equipment and driving units,

including auxiliaries, foundations, guardrails, and enclosures, etc.


5. Fire fighting equipment.



571


6. Gas lines and equipment, including fuelsupply lines, cooling tower and pond and as-sociated equipment, dehydrators, fuel gasmixers, special pipebends and connections,and associated scrubbers, separators, tanks,gauges, and instruments.





including water well, tank, water pipeline,cooling tower, spray fence, and water treat-ment equipment, etc., but not includingwater system equipment used solely for do-mestic and general use.

12. Other equipment.

364.7 Communication equipment.This account shall include the cost

installed of radio, telephone, micro-wave, and other equipment used whollyor predominantly in connection withthe operation and maintenance of theliquefied natural gas system. (See alsoaccounts 370 and 397, CommunicationEquipment.)

ITEMS

1. Carrier terminal equipment including re-peaters, power supply equipment, transmit-ting and receiving sets.

2. Microwave equipment, including powersupply equipment, transmitters, amplifiers,paraboloids, towers, reflectors, receivingequipment, etc.

3. Radio equipment, fixed and mobile, in-cluding antenna, power equipment, transmit-ter units.

4. Telephone equipment including switch-boards, power and testing equipment, con-ductors, pole lines, etc.

5. Other equipment.

364.8 Other equipment.This account shall include the cost

installed of equipment used in liquefiednatural gas operations, when not as-signable to any of the foregoing ac-counts.

ITEMS

1. Garage and service equipment.2. General tools, including power operated

equipment.3. Laboratory equipment.4. Materials handling equipment.5. Office furniture and equipment.6. Power generation equipment.

7. Shop equipment.8. Tools, other than small hand tools.9. Other equipment.

365.1 Land and land rights.This account shall include the cost of

land and land rights except rights-of-way used in connection with trans-mission operations. (See gas plant in-struction 7.)


rights-of-way used in connection withtransmission operations. (See gas plantinstruction 7.)

366 Structures and improvements.A. This account shall include the

cost in place of structures and im-provements used in connection withtransmission operations. (See gas plantinstruction 8.)

B. This account shall be subdividedas follows:

366.1 Compressor station structures.

366.2 Measuring and regulating sta-tion structures.

366.3 Other structures.

367 Mains.A. This account shall include the

cost installed of transmission systemmains.

B. The records supporting this ac-count shall be so kept as to show sepa-rately the cost of mains of differentsizes and types and of each tunnel,bridge, or river crossing.

ITEMS

1. Anti-freeze lubricating equipment.2. Automatic valve operating mechanisms,

including pressure tanks, etc.3. By-pass assembly.4. Caissons, tunnels, trestles, etc., for sub-

marine mains.5. Cathodic protection equipment.6. Drip lines and pots.7. Excavation, including shoring, bracing,

bridging, pumping, backfill, and disposal ofexcess excavated material.

8. Foundations.9. Gas cleaners, scrubbers, etc. when not

part of compressor station or measuring andregulating equipment.

10. Leak clamps. (See gas plant instruction10–C (1).)



572


11. Line pack gas.12. Linewalkers’ bridges.13. Manholes.14. Municipal inspection.15. Pavement disturbed, including cutting

and replacing pavement, pavement base, andsidewalks.

16. Permits.17. Pipe coating.18. Pipe and fittings.19. Pipe laying.20. Pipe supports.21. Protection of street openings.22. River, highway, and railroad crossings,

including revetments, pipe anchors, etc.23. Valves.24. Welding.

368 Compressor station equipment.This account shall include the cost

installed of compressor station equip-ment and associated appliances used inconnection with transmission systemoperations.

ITEMS












369 Measuring and regulating stationequipment.

This account shall include the costinstalled of meters, gauges, and otherequipment used in measuring or regu-

lating gas in connection with trans-mission system operations.

ITEMS






able type.NOTE: Pipeline companies, including com-

panies who measure deliveries of gas to theirown distribution system, shall include in thetransmission function classification citygate and main line industrial measuring andregulating stations.

370 Communication equipment.

This account shall include the costinstalled of radio, telephone, micro-wave, and other equipment used whollyor predominantly in connection withthe operation and maintenance of thegas transmission system. (See also ac-count 397, Communication Equipment.)

ITEMS

1. Carrier terminal equipment includ-ing repeaters, power supply equipment,transmitting and receiving sets.

2. Microwave equipment, includingpower supply equipment, transmitters,amplifiers, paraboloids, towers, reflec-tors, receiving equipment, etc.

3. Radio equipment, fixed and mobile,including antenna, power equipment,transmitters and receivers, and port-able receiver-transmitter units.

4. Telephone equipment includingswitchboards, power and testing equip-ment, conductors, pole lines, etc.

371 Other equipment.

This account shall include the costinstalled of equipment used in trans-mission system operations, when notassignable to any of the foregoing ac-counts.



573



land and land rights used in connectionwith distribution operations. (See gasplant instruction 7.)


place of structures and improvementsused in connection with distributionoperations. (See gas plant instruction8.)

376 Mains.A. This account shall include the

cost installed of distribution systemmains.

B. The records supporting this ac-count shall be so kept as to show sepa-rately the cost of mains of differentsizes and types and of each tunnel,bridge, or river crossing.

ITEMS

1. Caissons, tunnels, trestles, etc. for sub-marine mains.

2. Clamps, leak (bell and spigot) when in-stalled at time of construction; when clampsare installed subsequent to construction, theaccounting shall be in accordance with gasplant instruction 10, paragraph (C) 1.

3. Drip lines and pots.4. Electrolysis tests, in connection with

new construction.5. Excavation, including shoring, bracing,


6. Hauling, unloading, and stringing pipe.7. Lamping and watching new construc-

tion.8. Line pack gas.9. Municipal inspection.10. Pavement disturbed, including cutting


11. Permits.12. Pipe coating.13. Pipe and fittings.14. Pipe laying.15. Pipe supports.16. Protection of street openings.17. Relocating city storm and sanitary sew-

ers, catch basins, etc., or protecting same inconnection with new construction.

18. Replacement of municipal drains andculverts in connection with new construc-tion.

19. Roadway boxes.20. Shifting excavated material due to traf-

fic conditions in connection with new con-struction.

21. Sleeves and couplings.

22. Special crossovers, bridges and founda-tions for special construction.

23. Surveying and staking lines.24. Valves not associated with pumping or

regulating equipment.25. Welding.26. Wood blocking.

377 Compressor station equipment.This account shall include the cost

installed of compressor station equip-ment and associated appliances used inconnection with distribution systemoperations.

ITEMS




4. Electric system equipment, includinggenerating equipment and driving unitspower wiring, transformers, regulators, bat-tery equipment, switchboard, etc.







including water well, tank water piping,cooling tower, spray fence and water treat-ment equipment, etc., but not includingwater system equipment solely for domesticand general use.

378 Measuring and regulating stationequipment—General.

This account shall include the costinstalled of meters, gauges and otherequipment used in measuring and regu-lating gas in connection with distribu-tion system operations other than themeasurement of gas deliveries to cus-tomers.

ITEMS

1. Automatic control equipment.2. Foundations.3. Gauges and instruments.



574


4. Governors or regulators.5. Meters.6. Odorizing equipment.7. Oil fogging equipment.8. Piping.9. Pressure relief equipment.10. Vaults or pits, including valves con-

tained therein.NOTE: By-passes outside governor pits are

includible in account 376, Mains.

379 Measuring and regulating stationequipment—City gate check sta-tions.

This account shall include the costinstalled of meters, gauges, and otherequipment used in measuring and regu-lating the receipt of gas at entry pointsto distribution systems.

NOTE: Pipeline companies, including com-panies who measure deliveries of gas to theirown distribution system, shall include in thetransmission function classification citygate and main line industrial measuring andregulating stations.

ITEMS


380 Services.A. This account shall include the

cost installed of service pipes and ac-cessories leading to the customers’premises.

B. A complete service begins with theconnection on the main and extends tobut does not include the connectionwith the customer’s meter. A stubservice extends from the main to theproperty line, or the curb stop.

C. Services which have been used buthave become inactive shall be retiredfrom utility plant in service imme-diately if there is no prospect for reuse,and, in any event, shall be retired bythe end of the second year followingthat during which the service becameinactive unless reused in the interim.

ITEMS

1. Curb valves and curb boxes.2. Excavation, including shoring, bracing,


3. Landscaping, including lawns, andshrubbery.

4. Municipal inspection.5. Pavement disturbed, including cutting


6. Permits.7. Pipe and fittings, including saddle, T, or

other fitting on street main.8. Pipe coating.9. Pipe laying.10. Protection of street openings.11. Service drips.12. Service valves, at head of service, when

installed or furnished by the utility.

381 Meters.A. This account shall include the

cost installed of meters or devices andappurtenances thereto, for use in meas-uring gas delivered to users, whetheractually in service or held in reserve.

B. When a meter is permanently re-tired from service, the installed costincluded herein shall be credited tothis account.

C. The records of meters shall be sokept that the utility can furnish infor-mation as to the number of meters ofeach type and capacity in service andin reserve as well as the location ofeach meter.

ITEMS

1. Meters, including badging and initialtesting.Meter installations:

2. Cocks.3. Labor.4. Locks.5. Meter bars.6. Pipe and fittings.7. Seals.8. Shelves.9. Swivels and bushings.10. Transportation.NOTE A: At the option of the utility, costs

of meter installations may be accounted forseparately from the cost of meters in accord-ance with the provisions of account 382,Meter Installations. The practice of the util-ity, however, shall be consistent from yearto year and throughout the utility’s system.

NOTE B: The cost of removing and resettingmeters shall be charged to account 878,Meter and House Regulator Expenses.

382 Meter installations.A. This account shall include the

cost of labor and materials used, andexpenses incurred in connection withthe original installation of customermeters.

B. When a meter installation is per-manently retired from service, the costthereof shall be credited to this ac-count.



575


ITEMS

1. Cocks.2. Locks.3. Labor.4. Meter bars.5. Pipe and fittings.6. Seals.7. Shelves.8. Swivels and bushings.9. Transportation.NOTE: At the option of the utility, meter

installations may be accounted for as part ofthe cost installed of meters, in accordancewith the provisions of account 381, Meters.The practice of the utility, however, shall beconsistent from year to year and throughoutthe utility’s system.

383 House regulators.A. This account shall include the

cost installed of house regulatorswhether actually in service or held inreserve.

B. When a house regulator is perma-nently retired from service, the in-stalled cost thereof shall be cred-ited to this account.

ITEMS

1. House regulator.House regulator installations:

2. Cocks.3. Labor.4. Locks.5. Pipe and fittings.6. Regulator vents.7. Swivels and bushings.8. Transportation.NOTE: At the option of the utility, costs of

house regulator installations may be ac-counted for separately from the cost of houseregulators in accordance with the provisionsof account 384, House Regulator Installa-tions. The practice of the utility, however,shall be consistent from year to year andthroughout the utility’s system.

384 House regulator installations.A. This account shall include the

cost of labor and materials used andexpenses incurred in connection withthe original installation of house regu-lators.

B. When a house regulator installa-tion is permanently retired from serv-ice, the cost thereof shall be creditedto this account.

ITEMS

1. Cocks.

2. Labor.3. Locks.4. Pipe and fittings.5. Regulator vents.6. Swivels and bushings.7. Transportation.

NOTE: At the option of the utility, houseregulator installations may be accounted foras part of the cost installed of house regu-lators in accordance with the provisions ofaccount 383. House Regulators. The practice,however, shall be consistent from year toyear and throughout the utility’s system.

385 Industrial measuring and regulat-ing station equipment.

This account shall include the cost ofspecial and expensive installations ofmeasuring and regulating stationequipment, located on the distributionsystem, serving large industrial cus-tomers.

ITEMS


NOTE A: Do not include in this accountmeasuring and regulating station equipmentserving main line industrial customers. (Seeaccount 369.

NOTE B: By-passes outside of governor pitsare includible in account 376, Mains.

386 Other property on customers’premises.

This account shall include the cost,including first setting and connecting,of equipment owned by the utility in-stalled on customer premises which isnot includible in other accounts.

387 Other equipment.

This account shall include the costinstalled of all other distribution sys-tem equipment not provided for in theforegoing accounts, including streetlighting equipment.

ITEMS

1. Carbon monoxide tester and indicators.2. Explosimeters.3. Fire extinguisher.4. Gas masks.5. Lockers.6. Portable pump.7. Recording gauges.8. Street lighting equipment.9. Test meters.10. Watchmen’s clocks.



576



land and land rights used for utilitypurposes, the cost of which is not prop-erly includible in other land and landrights accounts. (See gas plant instruc-tion 7.)


place of structures and improvementsused for utility purposes, the cost ofwhich is not properly includible inother structures and improvements ac-counts. (See gas plant instruction 8.)

391 Office furniture and equipment.This account shall include the cost of

office furniture and equipment ownedby the utility and devoted to utilityservice, and not permanently attachedto buildings, except the cost of suchfurniture and equipment which theutility elects to assign to other plantaccounts on a functional basis.

ITEMS

1. Book cases and shelves.2. Desks, chairs, and desk equipment.3. Drafting-room equipment.4. Filing, storage and other cabinets.5. Floor covering.6. Library and library equipment.7. Mechanical office equipment such as ac-

counting machines, typewriters, etc.8. Safes.9. Tables.

392 Transportation equipment.This account shall include the cost of

transportation vehicles used for utilitypurposes.

ITEMS

1. Airplanes.2. Automobiles.3. Bicycles.4. Electrical vehicles.5. Motor trucks.6. Motorcyles.7. Repair cars or trucks.8. Tractors and trailers.9. Other transportation vehicles.

393 Stores equipment.This account shall include the cost of

equipment used for the receiving, ship-ping, handling and storage of materialsand supplies.

ITEMS

1. Chain falls.2. Counters.3. Cranes (portable).4. Elevating and stacking equipment (port-

able).5. Hoists.6. Lockers.7. Scales.8. Shelving.9. Storage bins.10. Trucks, hand and power driven.11. Wheelbarrows.

394 Tools, shop and garage equipment.This account shall include the cost of

tools, implements, and equipment usedin construction, repair work, generalshops and garages and not specificallyprovided for or includible in other ac-counts.

ITEMS

1. Air compressors.2. Anvils.3. Automobile repair shop equipment.4. Battery charging equipment.5. Belts, shafts and countershafts.6. Boilers.7. Cable pulling equipment.8. Concrete mixers.9. Derricks.10. Drill presses.11. Electric equipment.12. Engines.13. Forges.14. Foundations and settings specially con-

structed for equipment in this account andnot expected to outlast the equipment forwhich provided.

15. Furnaces.16. Gas producers.17. Gasoline pumps, oil pumps, and storage

tanks.18. Greasing tools and equipment.19. Hoists.20. Ladders.21. Lathes.22. Machine tools.23. Motor driven tools.24. Motors.25. Pipe threading and cutting tools.26. Pneumatic tools.27. Pumps.28. Riveters.29. Smithing equipment.30. Tool racks.31. Vises.32. Welding apparatus.33. Work benches.

395 Laboratory equipment.This account shall include the cost

installed of laboratory equipment used



577


for general laboratory purposes and notspecially provided for or includible inother departmental or functional plantaccounts.

ITEMS

1. Balances and scales.2. Barometers.3. Calorimeters-bomb, flow, recording

types, etc.4. Electric furnaces.5. Gas burning equipment.6. Gauges.7. Glassware, beakers, burettes, etc.8. Humidity testing apparatus.9. Laboratory hoods.10. Laboratory tables and cabinets.11. Muffles.12. Oil analysis apparatus.13. Piping.14. Specific gravity apparatus.15. Standard bottles for meter prover test-

ing.16. Stills.17. Sulphur and ammonia apparatus.18. Tar analysis apparatus.19. Thermometers—indicating and record-

ing.20. Any other item of equipment for testing

gas, fuel, flue gas, water, residuals, etc.

396 Power operated equipment.This account shall include the cost of

power operated equipment used in con-struction or repair work exclusive ofequipment includible in other ac-counts. Include, also, the tools and ac-cessories acquired for use with suchequipment and the vehicle on whichsuch equipment is mounted.

ITEMS

1. Air compressors, including driving unitand vehicle.

2. Back filling machines.3. Boring machines.4. Bulldozers.5. Cranes and hoists.6. Diggers.7. Engines.8. Pile drivers.9. Pipe cleaning machines.10. Pipe coating or wrapping machines.11. Tractors—Crawler type.12. Trenchers.13. Other power operated equipment.NOTE: It is intended that this account in-

clude only such large units as are generallyself-propelled or mounted on movable equip-ment.

397 Communication equipment.This account shall include the cost

installed of telephone, telegraph and

wireless equipment for general use inconnection with the utility’s gas oper-ations. (See account 370 for commu-nication equipment used wholly or pre-dominantly in connection with oper-ation and maintenance of the trans-mission system.)

ITEMS

1. Carrier terminal equipment including re-peaters, power supply equipment, transmit-ting and receiving sets.

2. Microwave equipment, including powersupply equipment, transmitters, amplifiers,paraboloids, towers, reflectors, receivingequipment, etc.

3. Radio equipment, fixed and mobile, in-cluding antenna, power equipment, transmit-ters and receivers, and portable receiver-transmitter units.

4. Telephone equipment including switch-boards, power and testing equipment, con-ductors, pole lines, etc.

398 Miscellaneous equipment.This account shall include the cost of

equipment, apparatus, etc., used anduseful in gas operations, which is notincludible in any other account.

ITEMS

1. Hospital and infirmary equipment.2. Kitchen equipment.3. Operator’s cottage furnishings.4. Radios.5. Recreation equipment.6. Restaurant equipment.7. Soda fountains.8. Other miscellaneous equipment.NOTE: Miscellaneous equipment of the na-

ture indicated above wherever practicableshall be assigned to the utility plant ac-counts on a functional basis.

399 Other tangible property.This account shall include the cost of

tangible utility plant not provided forelsewhere.

Income Chart of Accounts

1. UTILITY OPERATING INCOME

OPERATING EXPENSES

400 Operating revenues.401 Operation expense.402 Maintenance expense.403 Depreciation expense.404.1 Amortization and depletion of produc-

ing natural gas land and land rights.404.2 Amortization of underground storage

land and land rights.



578


404.3 Amortization of other limited-termgas plant.

405 Amortization of other gas plant.406 Amortization of gas plant acquisition

adjustments.407.1 Amortization of property losses, unre-

covered plant and regulatory study costs.407.2 Amortization of conversion expense.407.3 Regulatory debits.407.4 Regulatory credits.408 [Reserved]408.1 Taxes other than income taxes, utility

operating income.409 [Reserved]409.1 Income taxes, utility operating in-

come.410 [Reserved]410.1 Provision for deferred income taxes,

utility operating income.411 [Reserved]411.1 Provision for deferred income taxes—

Credit, utility operating income.411.3 [Reserved]411.4 Investment tax credit adjustments,

utility operations.411.6 Gains from disposition of utility plant.411.7 Losses from disposition of utility

plant. Total utility operating expenses.

OTHER OPERATING INCOME

412 Revenues from gas plant leased to oth-ers.

413 Expenses of gas plant leased to others.414 Other utility operating income. Net

utility operating income.

2. OTHER INCOME AND DEDUCTIONS

A. OTHER INCOME

415 Revenues from merchandising, jobbingand contract work.

416 Costs and expenses of merchandising,jobbing and contract work.

417 Revenues from nonutility operations.417.1 Expenses of nonutility operations.418 Nonoperating rental income.418.1 Equity in earnings of subsidiary com-

panies.419 Interest and dividend income.419.1 Allowance for other funds used during

construction.421 Miscellaneous nonoperating income.421.1 Gain on disposition of property. Total

other income.

B. OTHER INCOME DEDUCTIONS

421.2 Loss on disposition of property.425 Miscellaneous amortization.426 [Reserved]426.1 Donations.426.2 Life insurance.426.3 Penalties.426.4 Expenditures for certain civic, politi-

cal and related activites.426.5 Other deductions. Total other income

deductions. Total other income and de-ductions.

C. TAXES APPLICABLE TO OTHER INCOME ANDDEDUCTIONS

408.2 Taxes other than income taxes, otherincome and deductions.

409.2 Income taxes, other income and deduc-tions.

410.2 Provision for deferred income taxes,other income and deductions.

411.2 Provision for deferred income taxes—Credit, other income and deductions.

411.5 Investment tax credit adjustments,nonutility operations.

420 Investment tax credits. Total taxes onother income and deductions. Net otherincome and deductions.

3. INTEREST CHARGES

427 Interest on long-term debt.428 Amortization of debt discount and ex-

pense.428.1 Amortization of loss on reacquired

debt.429 Amortization of premium on debt—

Credit.429.1 Amortization of gain on reacquired

debt—Credit.430 Interest on debt to associated compa-

nies.431 Other interest expense.432 Allowance for borrowed funds used dur-

ing construction—Credit. Net interestcharges.

4. EXTRAORDINARY ITEMS

434 Extraordinary income.435 Extraordinary deductions.409.3 Income taxes, extraordinary items.

Net income

Income Accounts

400 Operating revenues.

There shall be shown under this cap-tion the total amount included in thegas operating revenue accounts pro-vided herein.

401 Operation expense.

There shall be shown under this cap-tion the total amount included in thegas operation expense accounts pro-vided herein. (See note to operating ex-pense instruction 3.)

402 Maintenance expense.

There shall be shown under this cap-tion the total amount included in thegas maintenance expense accounts pro-vided herein.



579


403 Depreciation expense.A. This account shall include the

amount of depreciation expense for allclasses of depreciable gas plant in serv-ice except such depreciation expense asis chargeable to clearing accounts or toaccount 416, Costs and Expenses ofMerchandising, Jobbing and ContractWork.

B. The utility shall keep such recordsof property and property retirementsas will reflect the service life of prop-erty which has been retired and aid inestimating probable service life bymortality, turnover, or other appro-priate methods; and also such recordsas will reflect the percentage of sal-vage and cost of removal for propertyretired from each account, or subdivi-sion thereof, for depreciable gas plant.

NOTE A: Depreciation expense applicable toproperty included in account 104, Gas PlantLeased to Others, shall be charged to ac-count 413, Expenses of Gas Plant Leased toOthers.

NOTE B: Depreciation expense applicable totransportation equipment, shop equipment,tools, work equipment, power operatedequipment and other general equipment maybe charged to clearing accounts as necessaryin order to obtain a proper distribution of ex-penses between construction and operation.

404.1 Amortization and depletion ofproducing natural gas land andland rights.

A. This account shall include chargesfor amortization and depletion of pro-ducing natural gas land and landrights. (See account 111, AccumulatedProvision for Amortization and Deple-tion of Gas Utility Plant).

B. The charges to this account shallbe made in such manner as to distrib-ute the cost of producing natural gasland and land rights over the period oftheir benefit to the utility, based uponthe exhaustion of the natural gas de-posits recoverable from such land andland rights.

404.2 Amortization of undergroundstorage land and land rights.

A. This account shall include chargesfor amortization of land and landrights of underground storage projectsfor natural gas. (See account 111, Accu-mulated Provision for Amortizationand Depletion of Gas Utility Plant.)

B. The charges to this account shallbe made in such manner as to distrib-ute the cost of amortizable land andland rights over the period of their ben-efit to the utility, and with respect toany land or land rights which includenative gas in the storage reservoir,such amounts shall be amortized or de-pleted on the basis of production ofsuch native gas after the volume ofstored gas has been withdrawn fromthe reservoir.

404.3 Amortization of other limited-term gas plant.

This account shall include amortiza-tion charges applicable to amounts in-cluded in the gas plant accounts forlimited-term franchises, licenses, pat-ent rights limited-term interests inland, and expenditures on leased prop-erty where the service life of the im-provements is terminable by action ofthe lease. The charges to this accountshall be such as to distribute the bookcost of each investment as evenly asmay be over the period of its benefit tothe utility. (See account 111, Accumu-lated Provision for Amortization andDepletion of Gas Utility Plant.)

405 Amortization of other gas plant.

A. When authorized by the Commis-sion, this account shall include chargesfor amortization of intangible or othergas utility plant, which does not havea definite or terminable life and whichis not subject to charges for deprecia-tion expense.

B. This account shall be supported insuch detail as to show the amortizationapplicable to each investment beingamortized, together with the book costof the investment and the period overwhich it is being written off.

406 Amortization of gas plant acquisi-tion adjustments.

This account shall be debited or cred-ited, as the case may be, with amountsincludible in operating expenses, pur-suant to approval or order of the Com-mission, for the purpose of providingfor the extinguishment of the amountin account 114, Gas Plant AcquisitionAdjustments.



580


407.1 Amortization of property losses,unrecovered plant and regulatorystudy costs.

This account shall be charged withamounts credited to Account 182.1, Ex-traordinary Property Losses, and Ac-count 182.2 Unrecovered Plant and Reg-ulatory Study Costs, when the Com-mission has authorized the amount inthe latter account to be amortized bycharges to gas operating expenses.

407.2 Amortization of conversion ex-penses.

This account shall be charged withamortization of amounts authorized bythe Commission to be included in Ac-count 186, Miscellaneous Deferred Deb-its, for expenses incurred in the conver-sion of distribution plant from manu-factured gas service to natural gasservice.

407.3 Regulatory debits.This account shall be debited, when

appropriate, with the amounts creditedto Account 254, Other Regulatory Li-abilities, to record regulatory liabil-ities imposed on the utility by theratemaking actions of regulatory agen-cies. This account shall also be debited,when appropriate, with the amountscredited to Account 182.3, Other Regu-latory Assets, concurrent with the re-covery of such amounts in rates.

407.4 Regulatory credits.This account shall be credited, when

appropriate, with the amounts debitedto Account 182.3, Other Regulatory As-sets, to establish regulatory assets.This account shall also be credited,when appropriate, with the amountsdebited to Account 254, Other Regu-latory Liabilities, concurrent with thereturn of such amounts to customersthrough rates.

408 [Reserved]


Accounts 408.1 and 408.2A. These accounts shall include the

amounts of ad valorem, gross revenue orgross receipts, taxes, state unemploymentinsurance, franchise taxes, federal excisetaxes, social security taxes, and all othertaxes assessed by federal, state, county, mu-

nicipal, or other local governmental authori-ties, except income taxes.

B. These accounts shall be charged in eachaccounting period with the amounts of taxeswhich are applicable thereto, with concur-rent credits to account 236, Taxes Accrued,or account 165, Prepayments, as appropriate.When it is not possible to determine theexact amounts of taxes, the amounts shall beestimated and adjustments made in currentaccruals as the actual tax levies becomeknown.

C. The charges to these accounts shall bemade or supported so as to show the amountof each tax and the basis upon which eachcharge is made. In the case of a utility ren-dering more than one utility service, taxes ofthe kind includible in these accounts shall beassigned directly to the utility departmentthe operation of which gave rise to the tax inso far as a specific utility department, itshall be distributed among the utility de-partments or nonutility operations on an eq-uitable basis after appropriate study to de-termine such basis.

NOTE A: Special assessments for street andsimilar improvements shall be included inthe appropriate utility plant or nonutilityproperty account.

NOTE B: Taxes specifically applicable toconstruction shall be included in the cost ofconstruction.

NOTE C: Gasoline and other sales taxesshall be charged as far as practicable to thesame amount as the materials on which thetax is levied.

NOTE D: Social security and other forms ofso-called payroll taxes shall be distributed toutility departments and to nonutility func-tions on a basis related to payroll. Amountsapplicable to construction shall be chargedto the appropriate plant accounts.

NOTE E: Interest on tax refunds or defi-ciencies shall not be included in these ac-counts but in account 419, Interest and Divi-dend Income, or 431, Other Interest Expense,as appropriate.

408.1 Taxes other than income taxes,utility operating income.

This account shall include thosetaxes other than income taxes whichrelate to utility operating income Thisaccount shall be maintained so as toallow ready identification of the var-ious classes of taxes relating to UtilityOperating Income (by department),Utility Plant Leased to Others andOther Utility Operating Income.



581


408.2 Taxes other than income taxes,other income and deductions.

This account shall include thosetaxes other than income taxes whichrelate to Other Income and Deductions.

409 [Reserved]


Accounts 409.1, 409.2 and 409.3

A. These accounts shall include theamounts of local, state and federal incometaxes on income properly accruable duringthe period covered by the income statementto meet the actual liability for such taxes.Concurrent credits for the tax accruals shallbe made to account 236, Taxes Accrued, andas the exact amounts of taxes becomeknown, the current tax accruals shall be ad-justed by charges or credits to these ac-counts so that these accounts as nearly ascan be ascertained shall include the actualtaxes payable by the utility.

B. The accruals for income taxes shall beapportioned among utility departments andto Other Income and Deductions so that, asnearly as practicable, each tax shall be in-cluded in the expenses of the utility depart-ment or Other Income and Deductions, theincome from which gave rise to the tax. Thetax effects relating to Interest Charges shallbe allocated between utility and nonutilityoperations. The basis for this allocationshall be the ratio of net investment in util-ity plant to net investment in nonutilityplant.

NOTE A: Taxes assumed by the utility oninterest shall be charged to account 431,Other Interest Expense.

NOTE B: Interest on tax refunds or defi-ciencies shall not be included in these ac-counts but in account 419, Interest and Divi-dend Income, or account 431, Other InterestExpense, as appropriate.

409.1 Income taxes, utility operatingincome.

This account shall include theamount of those local, state and fed-eral income taxes which relate to util-ity operating income. This accountshall be maintained so as to allowready identification of tax effects (bothpositive and negative) relating to Util-ity Operating Income (by department),Utility Plant Leased to Others andOther Utility Operating Income.

409.2 Income taxes, other income anddeductions.

This account shall include theamount of those local, state and fed-eral income taxes (both positive andnegative), which relate to Other In-come and Deductions.

409.3 Income taxes, extraordinaryitems.

This account shall include theamount of those local, state and fed-eral income taxes (both positive andnegative), which relate to Extraor-dinary Items.

410 [Reserved]


Accounts 410.1, 410.2, 411.1 and 411.2

A. Accounts 410.1 and 410.2 shall be debited,and Accumulated Deferred Income Taxesshall be credited with amounts equal to anycurrent deferrals of taxes on income or anyallocations of deferred taxes originating inprior periods, as provided by the texts of ac-counts 190, 281, 282 and 283. There shall not benetted against entries required to be made tothese accounts any credit amounts appro-priately includible in accounts 411.1 or 411.2.

B. Accounts 411.1 and 411.2 shall be cred-ited, and Accumulated Deferred IncomeTaxes shall be debited with amounts equal toany allocations of deferred taxes originatingin prior periods or any current deferrals oftaxes on income, as provided by the texts ofaccounts 190, 281, 282, and 283. There shall notbe netted against entries required to be madeto these accounts any debit amounts appro-priately includible in accounts 410.1 or 410.2.

410.1 Provision for deferred incometaxes, utility operating income.

This account shall include theamounts of those deferrals of taxes andallocations of deferred taxes which re-late to Utility Operating Income (bydepartment).

410.2 Provision for deferred incometaxes, other income and deductions.

This account shall include theamounts of those deferrals of taxes andallocations of deferred taxes which re-late to other income and deductions.



582


411 [Reserved]

411.1 Provision for deferred incometaxes—Credit, utility operating in-come.

This account shall include theamounts of those allocations of de-ferred taxes and deferrals of taxes,credit, which relate to Utility Operat-ing Income (by department).

411.2 Provision for deferred incometaxes—Credit, other income and de-ductions.

This account shall include theamounts of those allocations of de-ferred taxes and deferrals of taxes,credit, which relate to Other Incomeand Deductions.

411.3 [Reserved]


Accounts 411.4 and 411.5A. Account 411.4 shall be debited with the

amounts of investment tax credits related togas utility property that are credited to ac-count 255, Accumulated Deferred InvestmentTax Credits, by companies which do notapply the entire amount of the benefits ofthe investment credit as a reduction of theoverall income tax expense in the year inwhich such credit is realized (see account255).

B. Account 411.4 shall be credited with theamounts debited to account 255 for propor-tionate amounts of tax credit deferrals allo-cated over the average useful life of gas util-ity property to which the tax credits relateor such lesser period of time as may beadopted and consistently followed by thecompany.

C. Account 411.5 shall also be debited andcredited as directed in paragraphs A and B,for investment tax credits related to non-utility property.

411.4 Investment tax credit adjust-ments, utility operations.

This account shall include theamount of those investment tax creditadjustments related to property usedin Utility Operations (by department).

411.5 Investment tax credit adjust-ments, nonutility operations.

This account shall include theamount of those investment tax creditadjustments related to property usedin Nonutility Operations.

411.6 Gains from disposition of utilityplant.

This account shall include, as ap-proved by the Commission, amounts re-lating to gains from the disposition offuture use utility plant includingamounts which were previously re-corded in and transferred from account105, Gas Plant Held for Future Use andaccount 105.1, Production PropertiesHeld for Future Use, under the provi-sions of paragraphs B, C, and D thereof.Income taxes relating to gains recordedin this account shall be recorded in ac-count 409.1, Income Taxes, Utility Op-erating Income.

411.7 Losses from disposition of utilityplant.

This account shall include, as ap-proved by the Commission, amounts re-lating to losses from the disposition offuture use utility plant includingamounts which were previously re-corded in and transferred from account105, Gas Plant Held for Future Use andaccount 105.1, Production PropertiesHeld for Future Use, under the provi-sions of paragraphs B, C, and D thereof.Income taxes relating to losses re-corded in this account shall be re-corded in account 409.1, Income Taxes,Utility Operating Income.

412 Revenues from gas plant leased toothers.

413 Expenses of gas plant leased toothers.

A. These accounts shall include, re-spectively, revenues from gas propertyconstituting a distinct operating unitor system leased by the utility to oth-ers, and which property is properly in-cludible in account 104, Gas PlantLeased to Others, and the expenses at-tributable to such property.

B. The detail of expenses shall bekept or supported so as to show sepa-rately the following:

Operation.Maintenance.Depreciation.Amortization.

NOTE: Related taxes shall be recorded inaccount 408.1, Taxes Other Than IncomeTaxes, Utility Operating Income, or account409.1, Income Taxes, Utility Operating In-come, as appropriate.



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414 Other utility operating income.A. This account shall include the rev-

enues received and expenses incurred inconnection with the operations of util-ity plant, the book cost of which is in-cluded in account 118, Other UtilityPlant.

B. The expenses shall include everyelement of cost incurred in such oper-ations, including depreciation, rents,and insurance.

NOTE: Related taxes shall be recorded inaccount 408.1, Taxes Other Than IncomeTaxes, Utility Operating Income, or account409.1, Income Taxes, Utility Operating In-come, as appropriate.

415 Revenues from merchandising,jobbing and contract work.

416 Costs and expenses of merchandis-ing, jobbing and contract work.

A. These accounts shall include, re-spectively, all revenues derived fromthe sale of merchandise and jobbing orcontract work, including any profit orcommission accruing to the utility onjobbing work performed by it as agentunder contracts whereby it does job-bing work for another for a stipulatedprofit or commission, and all expensesincurred in such activities. Interest re-lated income from installment salesshall be recorded in Account 419, Inter-est and Dividend Income.

B. Records in support of these ac-counts shall be so kept as to permitready summarization of revenues, costsand expenses by such major items asare feasible.

NOTE A: The classification of revenues,costs and expenses of merchandising, jobbingand contract work as nonoperating, and thusinclusion in this account, is for accountingpurposes. It does not preclude considerationfor justification to the contrary for rate-making or other purpose.

NOTE B: Related taxes shall be recorded inaccount 408.2, Taxes Other Than IncomeTaxes, Other Income and Deductions, or ac-count 409.2, Income Taxes, Other Income andDeductions, as appropriate.

ITEMS

Account 415:1. Revenues from sale of merchandise and

from jobbing and contract work.2. Discounts and allowances made in settle-

ment of bills for merchandise and jobbingwork.

Account 416:Labor:

1. Canvassing and demonstrating appli-ances in homes and other places for the pur-pose of selling appliances.

2. Demonstrating and selling activities insales rooms.

3. Installing appliances on customer prem-ises where such work is done only for pur-chasers of appliances from the utility.

4. Installing piping or other property workon a jobbing or contract basis.

5. Preparing advertising materials for ap-pliance sales purposes.

6. Receiving and handling customer ordersfor merchandise or for jobbing services.

7. Cleaning and tidying sales rooms.8. Maintaining display counters and other

equipment used in merchandising.9. Arranging merchandise in sales rooms

and decorating display windows.10. Reconditioning repossessed appliances.11. Bookkeeping and other clerical work in

connection with merchandise and jobbing ac-tivities.

12. Supervising merchandise and jobbingoperations.Materials and expenses:

13. Advertising in newspapers, periodicals,radio, television, etc.

14. Cost of merchandise sold and of mate-rials used in jobbing work.

15. Stores expenses on merchandise andjobbing stocks.

16. Fees and expenses of advertising andcommercial artists’ agencies.

17. Printing booklets, dodgers, and otheradvertising data.

18. Premiums given as inducement to buyappliances.

19. Light, heat, and power.20. Depreciation on equipment used pri-

marily for merchandise and jobbing oper-ations.

21. Rent of sales rooms or of equipment.22. Transportation expense in delivery and

pick-up of appliances by utility’s facilities orby others.

23. Stationery and office supplies and ex-penses.

24. Losses from uncollectible merchandiseand jobbing accounts.

417 Revenues from nonutility oper-ations.

417.1 Expenses of nonutility oper-ations.

A. These accounts shall include reve-nues and expenses applicable to oper-ations which are nonutility in char-acter but nevertheless constitute a dis-tinct operating activity of the enter-prise as a whole, such as the operationof an ice department where applicable



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statutes do not define such operationas a utility, or the operation of a serv-icing organization for furnishing super-vision, management, engineering, andsimilar services to others.

B. The expenses shall include all ele-ments of costs incurred in such oper-ations, and the accounts shall be main-tained so as to permit ready summari-zation as follows:

Operation.Maintenance.Rents.Depreciation.Amortization.NOTE B: Related taxes shall be recorded in

account 408.2, Taxes Other Than IncomeTaxes, Other Income and Deductions, or ac-count 409.2, Income Taxes, Other Income andDeductions, as appropriate.

418 Nonoperating rental income.A. This account shall include all rent

revenues and related expenses of land,buildings, or other property included inaccount 121, Nonutility Property,which is not used in operations coveredby accounts 417 or 417.1.

B. The expenses shall include all ele-ments of costs incurred in the owner-ship and rental of property and the ac-counts shall be maintained so as topermit ready summarization as fol-lows:

Operation.Maintenance.Rents.Depreciation.Amortization.NOTE: Related taxes shall be recorded in

account 408.2, Taxes Other Than IncomeTaxes, Other Income and Deductions, or ac-count 409.2, Income Taxes, Other Income andDeductions, as appropriate.

418.1 Equity in earnings of subsidiarycompanies.

This account shall include the util-ity’s equity in the earnings or losses ofsubsidiary companies for the year.

419 Interest and dividend income.A. This account shall include interest

revenues on securities, loans, notes, ad-vances, special deposits, tax refundsand all other interest-bearing assets,and dividends on stocks of other com-panies, whether the securities on which

the interest and dividends are receivedare carried as investments or includedin sinking or other special fund ac-counts.

B. This account may include the prorata amount necessary to extinguish(during the interval between the dateof acquisition and the date of matu-rity) the difference between the cost tothe utility and the face value of inter-est-bearing securities. Amounts thuscredited or charged shall be concur-rently included in the accounts inwhich the securities are carried.

C. Where significant in amount ex-penses, excluding operating taxes andincome taxes, applicable to security in-vestments and to interest and dividendrevenues thereon shall be charged here-to.

NOTE A: Related taxes shall be recorded inaccount 408.2, Taxes Other Than IncomeTaxes, Other Income and Deductions, or ac-count 409.2, Income Taxes, Other Income andDeductions, as appropriate.

NOTE B: Interest accrued, the payment ofwhich is not reasonably assured, dividendsreceivable which have not been declared orguaranteed, and interest or dividends uponreacquired securities issued or assumed bythe utility shall not be credited to this ac-count.

419.1 Allowance for other funds usedduring construction.

This account shall include concur-rent credits for allowance for otherfunds used during construction, not toexceed amounts computed in accord-ance with the formula prescribed inGas Plant Instruction 3(17).

420 Investment tax credits.This account shall be credited as fol-

lows with investment tax creditamounts not passed on to customers:

(a) By amounts equal to debits to ac-counts 411.4, Investment Tax CreditAdjustments, Utility Operations, and411.5, Investment Tax Credit Adjust-ments, Nonutility Operations, for in-vestment tax credits used in calculat-ing income taxes for the year when thecompany’s accounting provides fornondeferral of all or a portion of suchcredits; and,

(b) By amounts equal to debits to ac-count 255, Accumulated Deferred In-vestment Tax Credits, for propor-tionate amounts of tax credit deferrals



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allocated over the average useful life ofthe property to which the tax creditsrelate, or such lesser period of time asmay be adopted and consistently usedby the company.

421 Miscellaneous nonoperating in-come.

This account shall include all reve-nue and expense items except taxesproperly includible in the income ac-count and not provided for elsewhere.Related taxes shall be recorded in ac-count 408.2, Taxes Other Than IncomeTaxes, Other Income and Deductions,or account 409.2, Income Taxes, OtherIncome and Deductions, as appropriate.

ITEMS

1. Profit on sale of timber. (See gas plantinstruction 7C.)

2. Profits from operations of others real-ized by the utility under contracts.

3. Gains on disposition of investments.Also gains on reacquisition and resale or re-tirement of utilities debt securities when thegain is not amortized and used by a jurisdic-tional regulatory agency to reduce embeddeddebt cost in establishing rates. See GeneralInstruction 17.

421.1 Gain on disposition of property.This account shall be credited with

the gain on the sale, conveyance, ex-change or transfer of utility or otherproperty to another. Amounts relatingto gains on land and land rights heldfor future use recorded in accounts 105,Gas Plant Held for Future Use and105.1, Production Properties Held forFuture Use, will be accounted for asprescribed in paragraphs B, C, and Dthereof. (See gas plant instructions 5F,7E, and 10E.) Income taxes on gains re-corded in this account shall be re-corded in account 409.2, Income Taxes,Other Income and Deductions.

421.2 Loss on disposition of property.This account shall be charged with

the loss on the sale, conveyance, ex-change or transfer of utility or otherproperty to another. Amounts relatingto losses on land and land rights heldfor future use recorded in accounts 105,Gas Plant Held for Future Use and105.1, Production Properties Held forFuture Use, will be accounted for asprescribed in paragraphs B, C, and Dthereof. (See gas plant instructions 5F,

7E, and 10E.) The reduction in incometaxes relating to losses recorded in thisaccount shall be recorded in account409.2, Income Taxes, Other Income andDeductions.

425 Miscellaneous amortization.

This account shall include amortiza-tion charges not includible in other ac-counts which are properly deductible indetermining the income of the utilitybefore interest charges. Charges includ-ible herein, if significant in amount,must be in accordance with an orderlyand systematic amortization program.

ITEMS

1. Amortization of utility plant acquisitionadjustments, or of intangibles included inutility plant in service when not authorizedto be included in utility operating expensesby the Commission.

2. Other miscellaneous amortizationcharges allowed to be included in this ac-count by the Commission.


Accounts 426.1, 426.2, 426.3, 426.4 and 426.5

These accounts shall include miscellaneousexpense items which are nonoperating in na-ture but which are properly deductible beforedetermining total income before interestcharges.

NOTE: The classification of expenses asnonoperating and their inclusion in these ac-counts is for accounting purposes. It doesnot preclude Commission consideration ofproof to the contrary for ratemaking orother purposes.

426.1 Donations.

This account shall include all pay-ments or donations for charitable, so-cial or community welfare purposes.

426.2 Life insurance.

This account shall include all pay-ments for life insurance of officers andemployees where company is bene-ficiary (net premiums less increase incash surrender value of policies).

426.3 Penalties.

This account shall include paymentsby the company for penalties or finesfor violation of any regulatory statutesby the company or its officials.



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426.4 Expenditures for certain civic,political and related activities.

This account shall include expendi-tures for the purpose of influencingpublic opinion with respect to the elec-tion or appointment of public officials,referenda, legislation, or ordinances(either with respect to the possibleadoption of new referenda, legislationor ordinances or repeal or modificationof existing referenda, legislation or or-dinances) or approval, modification, orrevocation of franchises; or for the pur-pose of influencing the decisions ofpublic officials, but shall not includesuch expenditures which are directlyrelated to appearances before regu-latory or other governmental bodies inconnection with the reporting utility’sexisting or proposed operations.

426.5 Other deductions.

This account shall include other mis-cellaneous expenses which are non-operating in nature, but which areproperly deductible before determiningtotal income before interest charges.

ITEMS

1. Loss relating to investments in securi-ties written-off or written-down.

2. Loss on sale of investments.3. Loss on reacquisition, resale or retire-

ment of utility’s debt securities, when theloss is not amortized and used by a jurisdic-tional regulatory agency to increase embed-ded debt cost in establishing rates. See Gen-eral Instruction 17.

4. Preliminary survey and investigation ex-penses related to abandoned projects, whennot written-off to the appropriate operatingexpense account.

5. Costs of preliminary abandonment costsrecorded in accounts 182.1, ExtraordinaryProperty Losses, and 182.2, UnrecoveredPlant and Regulatory Study Costs, not al-lowed to be amortized to account 407.1, Am-ortization of Property Losses, UnrecoveredPlant and Regulatory Study Costs.

427 Interest on long-term debt.

A. This account shall include theamount of interest on outstandinglong-term debt issued or assumed bythe utility, the liability for which is in-cluded in account 221, Bonds, or ac-count 224, Other Long-Term Debt.

B. This account shall be so kept orsupported as to show the interest ac-

cruals on each class and series of long-term debt.

NOTE: This account shall not include inter-est on nominally issued or nominally out-standing long-term debt, including securitiesassumed.

428 Amortization of debt discount andexpense.

A. This account shall include the am-ortization of unamortized debt dis-count and expense on outstanding long-term debt. Amounts charged to this ac-count shall be credited concurrently toaccounts 181, Unamortized Debt Ex-pense, and 226, Unamortized Discounton Long-Term Debt—Debit.

B. This account shall be so kept orsupported as to show the debt discountand expense on each class and series oflong-term debt.

428.1 Amortization of loss on reac-quired debt.

A. This account shall include the am-ortization of the losses on reacquisi-tion of debt. Amounts charged to thisaccount shall be credited concurrentlyto account 189, Unamortized Loss onReacquired Debt.

B. This account shall be maintainedso as to allow ready identification ofthe loss amortized applicable to eachclass and series of long-term debt reac-quired. See General Instruction 17.

429 Amortization of premium ondebt—Credit.

A. This account shall include the am-ortization of unamortized net premiumon outstanding long-term debt.Amounts credited to this account shallbe charged concurrently to account 225,Unamortized Premium on Long-TermDebt.

B. This account shall be so kept orsupported as to show the premium oneach class and series of long-term debt.

429.1 Amortization of gain on reac-quired debt—Credit.

A. This account shall include the am-ortization of the gains realized from re-acquisition of debt. Amounts creditedto this account shall be charged con-currently to account 257, UnamortizedGain on Reacquired Debt.



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B. This account shall be maintainedso as to allow ready identification ofthe gains amortized applicable to eachclass and series of long-term debt reac-quired. See General Instruction 17.

430 Interest on debt to associatedcompanies.

A. This account shall include interestaccrued on amounts included in ac-count 223, Advances from AssociatedCompanies, and on all other obliga-tions to associated companies.

B. The records supporting the entriesto this account shall be so kept as toshow to whom the interest is to bepaid, the period covered by the accrual,the rate of interest and the principalamount of the advances or other obli-gations on which the interest is ac-crued.

431 Other interest expense.

This account shall include all inter-est charges not provided for elsewhere.

ITEMS

1. Interest on notes payable on demand ormaturing one year or less from date and onopen accounts, except notes and accountswith associated companies.

2. Interest on customers’ deposits.3. Interest on claims and judgments, tax

assessments, and assessments for public im-provements past due.

4. Income and other taxes levied uponbondholders of utility and assumed by it.

432 Allowance for borrowed fundsused during construction—Credit.

This account shall include concur-rent credits for allowance for borrowedfunds used during construction, not toexceed amounts computed in accord-ance with the formula prescribed inGas Plant Instruction 3(17).

434 Extraordinary income.

This account shall be credited withgains of unusual nature and infrequentoccurrence, which would significantlydistort the current year’s income com-puted before Extraordinary Items, ifreported other than as extraordinaryitems. Income tax relating to theamounts recorded in this account shallbe recorded in account 409.3, Income

Taxes, Extraordinary Items. (See Gen-eral Instruction 7.)

435 Extraordinary deductions.

This account shall be debited withlosses of unusual nature and infrequentoccurrence, which would significantlydistort the current year’s income com-puted before Extraordinary Items, ifreported other than as extraordinaryitems. Income tax relating to theamounts recorded in this account shallbe recorded in account 409.3, IncomeTaxes, Extraordinary Items. (See Gen-eral Instruction 7.)

Retained Earnings Chart of Accounts

433 Balance transferred from income.436 Appropriations of retained earnings.437 Dividends declared—preferred stock.438 Dividends declared—common stock.439 Adjustments to retained earnings.

Retained Earnings Accounts

433 Balance transferred from income.This account shall include the net

credit or debit transferred from incomefor the year.

436 Appropriations of retained earn-ings.

This account shall include appropria-tions of retained earnings.

ITEMS

1. Appropriations required under terms ofmortgages, orders of courts, contracts, orother agreements.

2. Appropriations required by action of reg-ulatory authorities.

3. Other appropriations made at option ofutility for specific purposes.

437 Dividends declared—preferredstock.

A. This account shall includeamounts declared payable out of re-tained earnings as dividends on actu-ally outstanding preferred or prior liencapital stock issued by the utility.

B. Dividends shall be segregated foreach class and series of preferred stockas to those payable in cash, stock andother forms. If not payable in cash, themedium of payment shall be describedwith sufficient detail to identify it.



588


438 Dividends declared—commonstock.

A. This account shall includeamounts declared payable out of re-tained earnings as dividends on actu-ally outstanding common capital stockissued by the utility.

B. Dividends shall be segregated foreach class of common stock as to thosepayable in cash, stock and other forms.If not payable in cash, the medium ofpayment shall be described with suffi-cient detail to identify it.

439 Adjustments to retained earnings.A. This account shall, with prior

Commission approval, include signifi-cant nonrecurring transactions ac-counted for as prior period adjust-ments, as follows:

(1) Correction of an error in the fi-nancial statements of a prior year.

(2) Adjustments that result from re-alization of income tax benefits of pre-acquisition operating losscarryforwards of purchased subsidi-aries.All other items of profit and loss recog-nized during a year shall be included inthe determination of net income forthat year.

B. Adjustments, charges, or creditsdue to losses on reacquisition, resale orretirement of the company’s own cap-ital stock shall be included in this ac-count. (See account 210, Gain on Resaleor Cancellation of Reacquired CapitalStock, for the treatment of gains.)

Operating Revenue Chart of Accounts

1. SALES OF GAS

480 Residential sales.481 Commercial and industrial sales.482 Other sales to public authorities.483 Sales for resale.484 Interdepartmental sales.485 Intracompany transfers.

2. OTHER OPERATING REVENUES

487 Forfeited discounts.488 Miscellaneous service revenues.489.1 Revenues from transportation of gas

of others through gathering facilities.489.2 Revenues from transportation of gas

of others through transmission facilities.489.3 Revenues from transportation of gas

of others through distribution facilities.489.4 Revenues from storing gas of others.490 Sales of products extracted from natu-

ral gas.

491 Revenues from natural gas processed byothers.

492 Incidental gasoline and oil sales.493 Rent from gas property.494 Interdepartmental rents.495 Other gas revenues.496 Provision for rate refunds.

Operating Revenue Accounts

480 Residential sales.A. This account shall include the net

billing for gas supplied for residentialor domestic purposes.

B. Records shall be maintained sothat the quantity of gas sold and therevenues received under each rateschedule shall be readily available.

NOTE: When gas supplied through a singlemeter is used for both residential and com-mercial purposes, the total revenue shall beincluded in this account or account 481, Com-mercial and Industrial Sales, according tothe rate schedule which is applied. If thesame rate schedules are applicable to bothresidential and commercial service, classi-fication shall be according to principal use.

481 Commercial and industrial sales.A. This account shall include the net

billing for gas supplied to commercialand industrial customers.

B. Records shall be maintained sothat the quantity of gas sold and reve-nue received under each rate scheduleshall be readily available.

C. Records shall be maintained so asto show separately the revenues fromcommercial and industrial customers,as follows:Large commercial and industrial sales(wherein shall be included the revenuesfrom customers which use large vol-umes of gas, generally in excess of200,000 Dth per year or approximately800 Dth per day of normal require-ments. Reasonable deviations are per-missible in order that transfers of cus-tomers between the large and smallclassifications may be minimized).Small commercial and industrial sales(wherein shall be included the revenuesfrom customers which use volumes ofgas generally less than 200,000 Mcf peryear or less than approximately 800Mcf per day of normal requirements).

NOTE: When gas supplied through a singlemeter is used for both commercial and resi-dential purposes, the total revenue shall be



589


included in this account or in account 480,Residential Sales, according to the rateschedule which is applied. If the same rateschedules are applicable to both residentialand commercial service, classification shallbe according to principal use.

482 Other sales to public authorities.

A. This account shall include the netbilling for gas supplied to municipali-ties or divisions or agencies of Federalor State Governments, under specialcontracts or agreements or serviceclassifications, applicable only to pub-lic authorities, for general govern-mental and institutional purposes, ex-cept any revenues under rate schedulesthe revenues from which are includiblein account 481 or 483, and except anyrevenues from gas used for purposessuch as powerplant fuel for publiclyowned electric systems, manufacturingprocesses of arsenals, etc., and othermajor uses of gas which appropriatelymay be classified in account 481, Com-mercial and Industrial Sales.

B. Records shall be maintained sothat the quantity of gas sold and therevenue received from each customerand from each major special contractshall be readily available.

483 Sales for resale.

A. This account shall include the netbilling for gas supplied to other gasutilities or to public authorities for re-sale purposes.

B. Records shall be maintained sothat there shall be readily availablethe revenues for each customer undereach revenue schedule and the billingdeterminants, as applicable, i.e., vol-ume of gas (actual and billing), con-tract demand, maximum actual de-mand, billing demand, and Btu adjust-ment factor.

NOTE: Revenues from gas supplied to otherpublic utilities for use by them and not fordistribution, shall be included in account 481,Commercial and Industrial Sales, unless sup-plied under the same contract as and notreadily separable from revenues includible inthis account.

484 Interdepartmental sales.

A. This account shall includeamounts charged by the gas depart-ment at tariff or other specified rates

for gas supplied by it to other utilitydepartments.

B. Records shall be maintained sothat the quantity of gas supplied eachother department and the charge madetherefor shall be readily available.

485 Intracompany transfers

A. This account shall include, for in-formational purposes only, the amountrecorded for gas supplied by the pro-duction division when the price is notdetermined by a cost-of-service rateproceeding.

B. Records shall be maintained sothat the quality of gas transferredshall be readily available.

487 Forfeited discounts.

This account shall include theamount of discounts forfeited or addi-tional charges imposed because of thefailure of customers to pay gas bills onor before a specified date.

488 Miscellaneous service revenues.

This account shall include revenuesfrom all miscellaneous services andcharges billed to customers which arenot specifically provided for in otheraccounts.

ITEMS

1. Fees for changing, connecting, or dis-connecting service.

2. Profit on maintenance of appliances, pip-ing, gas firing, and other utilization facili-ties, or other installations on customers’premises.

3. Net credit or debit (cost less net salvageand less payment from customers) on closingwork orders for plant installed for temporaryservice of less than 1 year. (See account 185,Temporary Facilities.)

4. Recovery of expenses in connection withgas diversion cases. (Billing for the gas con-sumed shall be included in the appropriategas revenue account.)

5. Services performed for other gas compa-nies for testing and adjusting meters, chang-ing charts, etc.

489.1 Revenues from transportation ofgas of others through gathering fa-cilities.

This account includes revenues fromtransporting gas for other companiesthrough the gathering facilities of theutility.



590


489.2 Revenues from transportation ofgas of others through transmissionfacilities.

This account includes revenues fromtransporting gas for other companiesthrough the transmission facilities ofthe utility.

489.3 Revenues from transportation ofgas of others through distributionfacilities.

This account includes revenues fromtransporting gas for other companiesthrough the distribution facilities ofthe utility.

489.4 Revenues from storing gas ofothers.

This account includes revenues fromstoring gas for other companies.

490 Sales of products extracted fromnatural gas.

A. This account shall include reve-nues from sales of gasoline, butane,propane, and other products extractedfrom natural gas, net of allowances, ad-justments, and discounts, includingsales of similar products purchased forresale.

B. Records shall be maintained sothat the quantity, sales price, and rev-enues for each type of product sold toeach purchaser shall be readily avail-able.

491 Revenues from natural gas proc-essed by others.

A. This account shall include reve-nues from royalties and permits, orother bases of settlement, for permis-sion granted others to remove productsfrom natural gas of the utility.

B. The records supporting this ac-count must be maintained so that fullinformation concerning determinationof the revenues will be readily avail-able concerning each processor of gasof the utility, including as applicable(a) The Dth of gas delivered to suchother party for processing, (b) the Dthof gas received back from the proc-essor, (c) the field, general productionarea , or other source of the gas proc-essed, (d) Dth of gas used for processingfuel, etc., which is chargeable to theutility, (e) total gallons of each prod-uct recovered by the processor and the

utility’s share thereof, (f) the revenuesaccruing to the utility, and (g) thebasis of determination of the revenuesaccruing to the utility. Such recordsshall be maintained even though norevenues are derived from the proc-essor.

492 Incidental gasoline and oil sales.

This account shall include revenuesfrom natural gas gasoline produced di-rect from gas wells or recovered fromdrips or obtained in connection withpurification or dehydration processes,and revenues from oil obtained fromwells which produce oil and gas, the in-vestment in which is carried in ac-counts 330, Producing Gas Wells—WellConstruction, and 331, Producing GasWells—Well Equipment.

493 Rent from gas property.

A. This account shall include rentsreceived for the use by others of land,buildings, and other property devotedto gas operations by the utility.

B. When property owned by the util-ity is operated jointly with othersunder a definite arrangement for shar-ing the actual expenses among the par-ties to the arrangement, any amountreceived by the utility for interest orreturn or in reimbursement of taxes ordepreciation on the property shall becredited to this account.

NOTE: Do not include rent from propertyconstituting an operating unit or system inthis account. (See account 412, RevenuesFrom Gas Plant Leased to Others.)

494 Interdepartmental rents.

This account shall include credits forrental charges made against other de-partments of the utility. In the case ofproperty operated under a definite ar-rangement to allocate actual costsamong the departments using the prop-erty, any allowance to the gas depart-ment for interest or return and depre-ciation and taxes shall be credited tothis account.

495 Other gas revenues.

This account includes revenues de-rived from gas operations not includ-ible in any of the foregoing accounts.



591


ITEMS

1. Commission on sale or distribution ofgas of others when sold under rates filed bysuch others.

2. Compensation for minor or incidentalservices provided for others such as customerbilling, engineering, etc.

3. Profit or loss on sale of material andsupplies not ordinarily purchased for resaleand not handled through merchandising andjobbing accounts.

4. Sales of steam, water, or electricity, in-cluding sales or transfers to other depart-ments of the utility.

5. Miscellaneous royalties received.6. Revenues from dehydration and other

processing of gas of others, except productsextraction where products are received ascompensation and sales of such are includ-ible in account 490, Sales of Products Ex-tracted From Natural Gas, and except com-pression of gas of others, revenues fromwhich are includible in accounts 489.1, 489.2,or 489.3, Revenues from Transportation ofGas of Others.

7. Include in a separate subaccount, reve-nues in payment for rights and/or benefitsreceived from others which are realizedthrough research, development, and dem-onstration ventures.

8. Include in a separate subaccount, gainson settlements of imbalance receivables andpayables (See Accounts 174 and 242) andgains on replacement of encroachment vol-umes (See Account 117.4). Records must bemaintained and readily available to supportthe gains included in this account.

9. Include in a separate subaccount reve-nues from penalties earned pursuant to tariffprovisions, including penalties associatedwith cash-out settlements.

496 Provision for rate refunds.A. This account shall be charged with

provisions for the estimated pretax ef-fects on net income of the portions ofamounts being collected subject to re-fund which are estimated to be re-quired to be refunded. Such provisionsshall be credited to Account 229, Accu-mulated Provision for Rate Refunds.

B. This account shall also be chargedwith amounts refunded when suchamounts had not been previously ac-crued.

C. Income tax effects relating to theamounts recorded in this account shallbe recorded in account 410.1, Provisionfor Deferred Income Taxes, Utility Op-erating Income, or account 411.1, Provi-sion for Deferred Income Taxes—Cred-it, Utility Operating Income, as appro-priate.

Operation and Maintenance ExpenseChart of Accounts

1. PRODUCTION EXPENSES

A. MANUFACTURED GAS PRODUCTION

A.1. Steam Production

Operation700 Operation supervision and engineering.701 Operation labor.702 Boiler fuel.703 Miscellaneous steam expenses.704 Steam transferred—Credit.

Maintenance705 Maintenance supervision and engineer-

ing.706 Maintenance of structures and improve-

ments.707 Maintenance of boiler plant equipment.708 Maintenance of other steam production

plant.

A.2. Manufactured Gas Production

Operation710 Operation supervision and engineering.

PRODUCTION LABOR AND EXPENSES

711 Steam expenses.712 Other power expenses.713 Coke oven expenses.714 Producer gas expenses.715 Water gas generating expenses.716 Oil gas generating expenses.717 Liquefied petroleum gas expenses.718 Other process production expenses.

GAS FUELS

719 Fuel under coke ovens.720 Producer gas fuel.721 Water gas generator fuel.722 Fuel for oil gas.723 Fuel for liquefied petroleum gas proc-

ess.724 Other gas fuels.

GAS RAW MATERIALS

725 Coal carbonized in coke ovens.726 Oil for water gas.727 Oil for oil gas.728 Liquefied petroleum gas.729 Raw materials for other gas processes.730 Residuals expenses.731 Residuals produced—Credit.732 Purification expenses.733 Gas mixing expenses.734 Duplicate charges—Credit.735 Miscellaneous production expenses.736 Rents.


ing.



592


741 Maintenance of structures and improve-ments.

742 Maintenance of production equipment.

B. NATURAL GAS PRODUCTION EXPENSES

B.1. Natural Gas Prodcution and Gathering

Operation750 Operation supervision and engineering.751 Production maps and records.752 Gas wells expenses.753 Field lines expenses.754 Field compressor station expenses.755 Field compressor station fuel and

power.756 Field measuring and regulating station

expenses.757 Purification expenses.758 Gas well royalties.759 Other expenses.760 Rents.



ments.763 Maintenance of producing gas wells.764 Maintenance of field lines.765 Maintenance of field compressor station

equipment.766 Maintenance of field measuring and reg-

ulating station equipment.767 Maintenance of purification equipment.768 Maintenance of drilling and cleaning

equipment.769 Maintenance of other equipment.

B.2. Products Extraction

Operation770 Operation supervision and engineering.771 Operation labor.772 Gas shrinkage.773 Fuel.774 Power.775 Materials.776 Operation supplies and expenses.777 Gas processed by others.778 Royalties on products extracted.779 Marketing expenses.780 Products purchased for resale.781 Variation in products inventory.782 Extracted products used by the utility—

Credit.783 Rents.



ments.786 Maintenance of extraction and refining

equipment.787 Maintenance of pipe lines.

788 Maintenance of extracted products stor-age equipment.

789 Maintenance of compressor equipment.790 Maintenance of gas measuring and regu-

lating equipment.791 Maintenance of other equipment.

C. EXPLORATION AND DEVELOPMENT EXPENSES

Operation795 Delay rentals.796 Nonproductive well drilling.797 Abandoned leases.798 Other exploration.

D. OTHER GAS SUPPLY EXPENSES

Operation800 Natural gas well head purchases.800.1 Natural gas well head purchases,

intracompany transfers.801 Natural gas field line purchases.802 Natural gas gasoline plant outlet pur-

chases.803 Natural gas transmission line pur-

chases.804 Natural gas city gate purchases.804.1 Liquefied natural gas purchases.805 Other gas purchases.805.1 Purchased gas cost adjustments.806 Exchange gas.807 Purchased gas expenses.808.1 Gas withdrawn from storage—Debt.808.2 Gas delivered to storage—Credit.809.1 Withdrawals of liquefied natural gas

held for processing—Debt.809.2 Deliveries of natural gas for process-

ing—Credit.810 Gas used for compressor station fuel—

Credit.811 Gas used for products extraction—Cred-

it.812 Gas used for other utility operations—

Credit.813 Other gas supply expenses.

2. NATURAL GAS STORAGE, TERMINALING ANDPROCESSING EXPENSES

A. UNDERGROUND STORAGE EXPENSES

814 Operation supervision and engineering.815 Maps and records.816 Wells expenses.817 Lines expenses.818 Compressor station expenses.819 Compressor station fuel and power.820 Measuring and regulating station ex-

penses.821 Purification expenses.822 Exploration and development.823 Gas losses.824 Other expenses.825 Storage well royalties.826 Rents.



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ments.832 Maintenance of reservoirs and wells.833 Maintenance of lines.834 Maintenance of compressor station

equipment.835 Maintenance of measuring and regulat-

ing station equipment.836 Maintenance of purification equipment.837 Maintenance of other equipment.

B. OTHER STORAGE EXPENSES

Operation840 Operation supervision and engineering.841 Operation labor and expenses.842 Rents.842.1 Fuel.842.2 Power.842.3 Gas losses.

Maintenance843.1 Maintenance supervision and engineer-

ing.843.2 Maintenance of structures and im-

provements.843.3 Maintenance of gas holders.843.4 Maintenance of purification equip-

ment.843.5 Maintenance of liquefaction equip-

ment.843.6 Maintenance of vaporizing equipment.843.7 Maintenance of compressor equip-

ment.843.8 Maintenance of measuring and regu-

lating equipment.843.9 Maintenance of other equipment.

C. LIQUEFIED NATURAL GAS TERMINALING ANDPROCESSING EXPENSES

Operation844.1 Operation supervision and engineer-

ing.844.2 LNG processing terminal labor and ex-

penses.844.3 Liquefaction processing labor and ex-

penses.844.4 LNG transportation labor and ex-

penses.844.5 Measuring and regulating labor and

expenses.844.6 Compressor station labor and ex-

penses.844.7 Communication system expenses.844.8 System control and load dispatching.845.1 Fuel.845.2 Power.845.3 Rents.845.4 Demurrage charges.845.5 Wharfage receipts—credit.845.6 Processing liquefied or vaporized gas

by others.

846.1 Gas losses.846.2 Other expenses.

Maintenance847.1 Maintenance supervision and engineer-

ing.847.2 Maintenance of structures and im-

provements.847.3 Maintenance of LNG processing termi-

nal equipment.847.4 Maintenance of LNG transportation

equipment.847.5 Maintenance of measuring and regu-

lating equipment.847.6 Maintenance of compressor station

equipment.847.7 Maintenance of communication equip-

ment.847.8 Maintenance of other equipment.

3. TRANSMISSION EXPENSES

Operation850 Operation supervision and engineering.851 System control and load dispatching.852 Communication system expenses.853 Compressor station labor and expenses.854 Gas for compressor station fuel.855 Other fuel and power for compressor

stations.856 Mains expenses.857 Measuring and regulating station ex-

penses.858 Transmission and compression of gas by

others.859 Other expenses.860 Rents.



ments.863 Maintenance of mains.864 Maintenance of compressor station


ing station equipment.866 Maintenance of communication equip-

ment.867 Maintenance of other equipment.870 Operation supervision and engineering.

4. DISTRIBUTION EXPENSES

Operation871 Distribution load dispatching.872 Compressor station labor and expenses.873 Compressor station fuel and power

(Major only).874 Mains and services expenses.875 Measuring and regulating station ex-

penses—General.876 Measuring and regulating station ex-

penses—Industrial.877 Measuring and regulating station ex-

penses—City gate check stations.



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878 Meter and house regulator expenses.879 Customer installations expenses.880 Other expenses.881 Rents.



ments.887 Maintenance of mains.888 Maintenance of compressor station


ing station equipment—General.890 Maintenance of measuring and regulat-

ing station equipment—Industrial.891 Maintenance of measuring and regulat-

ing station equipment—City gate checkstations.

892 Maintenance of services.893 Maintenance of meters and house regu-

lators.894 Maintenance of other equipment.

5. CUSTOMER ACCOUNTS EXPENSES

Operation901 Supervision.902 Meter reading expenses.903 Customer records and collection ex-

penses.904 Uncollectible accounts.905 Miscellaneous customer accounts ex-

penses.

6. CUSTOMER SERVICE AND INFORMATIONALEXPENSES

Operation907 Supervision.908 Customer assistance expenses.909 Informational and instructional adver-

tising expenses.910 Miscellaneous customer service and in-

formational expenses.

7. SALES EXPENSES

Operation911 Supervision.912 Demonstrating and selling expenses.913 Advertising expenses.914 [Reserved]915 [Reserved]916 Miscellaneous sales expenses.

8. ADMINISTRATIVE AND GENERAL EXPENSES

Operation920 Administrative and general salaries.921 Office supplies and expenses.922 Administrative expenses transferred—

Credit.923 Outside services employed.924 Property insurance.925 Injuries and damages.

926 Employee pensions and benefits.927 Franchise requirements.928 Regulatory commission expenses.929 Duplicate charges—Credit.930.1 General advertising expenses.930.2 Miscellaneous general expenses.931 Rents.

Maintenance932 Maintenance of general plant.

Operation and MaintenanceExpense Accounts

700 Operation supervision and engi-neering.

This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of theoperation of steam production. (See op-erating expense instruction 1.)

701 Operation labor.This account shall include the cost of

labor used in boiler rooms and else-where about the premises engaged inthe production of steam or assignableto the production of steam.

ITEMS

1. Blowing flues.2. Cleaning boilers.3. Handling coal, coke, and breeze from

place of storage to boilers.4. Janitorial, messenger, watchmen, and

similar services.5. Operating boilers.6. Operating elevators.7. Pulverizing coal.8. Pumping tar from storage tank to boil-

ers.9. Removing ashes.10. Testing steam meters, gauges, and

other instruments.

702 Boiler fuel.A. This account shall include the

cost of coal, oil, gas, or other fuel usedin the production of steam, includingapplicable amounts of fuel stock ex-penses. It shall also include the netcost of, or the net amount realizedfrom, the disposal of ashes.

B. Records shall be maintained toshow the quantity and cost of eachtype of fuel used. Respective amountsof fuel stock and fuel stock expensesshall be readily available.

NOTE: The cost of fuel, except gas, and re-lated fuel stock expenses, shall be chargedinitially to appropriate fuel accounts carried



595


under accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of fuel used. Seeaccounts 151 and 152 for basis of fuel costsand includible items of fuel stock expenses.

703 Miscellaneous steam expenses.

This account shall include the cost ofmaterials used and expenses incurredin the production of steam, not includ-ible in the foregoing accounts.

ITEMS

1. Boiler compounds.2. Building service expenses.3. Chemicals.4. Communication service.5. Lubricants.6. Miscellaneous supplies.7. Pumping supplies and expenses.8. Purification supplies and expenses.9. Tools, hand.10. Waste.11. Water purchased.12. Research, development, and demonstra-

tion expenses.

704 Steam transferred—Credit.A. This account shall include such

portion of the cost of producing steamas is charged to other gas operating ex-pense accounts, or to others or to a co-ordinate department under a joint fa-cility arrangement.

B. The records supporting the entriesto this account shall be so kept thatthe utility can furnish readily an ex-planation of the bases of the credits tothis account and the amounts chargedto (1) other gas accounts, (2) other util-ity departments, and (3) outside partiesunder a joint facility arrangement. Therecords shall show, likewise, theamounts of steam production operationand steam production maintenance ex-penses, respectively, chargeable toeach of the foregoing.

NOTE A: If the utility produces gas by asingle process at only one plant, credits neednot be made to this account for the cost ofsteam used in such gas production facility.

NOTE B: Where steam is produced by pro-ducer gas equipment or waste heat boilers,and such steam becomes part of the generalplant supply, this account should be chargedand the steam expense account in the appro-priate functional group of accounts (coal gasproduction, water gas production, etc.) cred-ited with the value of such steam. However,if the steam so produced is used in the same

functional operation as that through whichderived, such entries need not be made.

705 Maintenance supervision and en-gineering.

This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of steam production facilities.Direct field supervision of specific jobsshall be charged to the appropriatemaintenance accounts. (See operatingexpense instruction 1.)

706 Maintenance of structures and im-provements.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of struc-tures and improvements used in steamproduction operations, the book cost ofwhich is includible in account 305,Structures and Improvements. (See op-erating expense instruction 2.)

707 Maintenance of boiler plant equip-ment.

This account shall indicate the costof labor, materials used and expensesincurred in the maintenance of equip-ment used in steam production thebook cost of which is includible in ac-count 306, Boiler Plant Equipment.(See operating expense instruction 2.)

708 Maintenance of other steam pro-duction plant.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment used in steam production oper-ations, the book cost of which is in-cludible in account 314, Coal, Coke, andAsh Handling Equipment, or account320, Other Equipment. (See operatingexpense instruction 2.)


A. This account shall include thecost of labor and expenses occurred inthe general supervision and directionof the operation of manufactured gasstations. Direct supervision of specificactivities such as steam productionand power operations, coke oven oper-ations, water gas generation, etc., shall



596


be charged to the appropriate account.(See operating expense instruction 1.)

711 Steam expenses.A. This account shall include the

cost of steam used in manufactured gasproduction. This includes the cost ofsteam transferred from the gas depart-ment’s own supply and charges forsteam transferred from others or fromcoordinate departments under joint fa-cility arrangements. (See account 704,Steam Transferred—Credit.)

B. This account shall be so kept as toshow separately for each source ofsteam the point of delivery, the quan-tity, the charges therefor, and thebases of such charges.

712 Other power expenses.This account shall include the cost of

electricity or other power, exceptsteam, used in manufactured gas oper-ation. This includes the cost of powerpurchased, the operation cost of elec-tricity or other power such as com-pressed air produced by the gas depart-ment and charges from others or fromcoordinate departments for power pro-duced under joint facility arrange-ments.

713 Coke oven expenses.This account shall include the cost of

labor used and expenses incurred in theoperation of coke ovens for the produc-tion of coal gas, exclusive of the cost offuel for the coke ovens and coal car-bonized.

ITEMS

Labor:1. Supervising.2. Work of the following character in oper-

ation of coke ovens:a. Charging and leveling coal.b. Heating ovens to produce coke.c. Pushing, transporting, quenching, and

dumping coke on wharf.d. Reclaiming coke spillage, removing, re-

placing, and luting oven doors and lids.e. Handling and mixing luting mud.f. Controlling oven heats and gas heating

value with dilution gas.g. Controlling flue temperature, stack

drafts, collecting main pressure and the flowof flushing liquor and drains.

h. Operating, cleaning, and lubricatingequipment not incidental to maintenancework, such as: charger, pusher, door operat-ing and luting, mud mixing, gas reversal,

transportation machinery and equipment,quenching pumps and tower, together withvalves, instruments, meters, controls,gauges, and records connected with their op-eration.

i. Tar chasing (spooning tar in hot drains.)j. Cleaning doors, jambs, and stand pipes.3. Handling and transporting coal from

storage or boats to battery bins.4. Operating, cleaning and lubricating me-

chanical equipment, such as: hoist machines,conveyors and their housing, hammermillsand breakers, mixing and battery bins, to-gether with their control valves, instru-ments, etc.

5. Wetting and handling coke to the cokewharf or storage including cleaning and lu-bricating of equipment not incident to main-tenance.

6. Pumping gas from ovens and maintain-ing the proper pressures on the collectingmain and throughout the apparatus train, in-cluding cleaning and lubricating the ovengas exhausters and revivifying blowers, notincident to maintenance.

7. Removing and disposing of carbon, fines,sediment, and waste material.

8. Cleaning ovens and exhauster house, in-cluding janitor service in the employees’locker and wash room within this operatingarea.Materials and expenses:

9. Packing, waste, lubricants, etc.10. Small hand tools.11. Building service, communication serv-

ice, transportation.

714 Producer gas expenses.This account shall include the cost of

labor used and expenses incurred inmaking producer gas exclusive of thecost of fuel for producer gas.

ITEMS

Labor:1. Supervising.2. Work of the following character in con-

nection with operation of producer gas sets(excepting the waste heat boiler and auxil-iaries):

a. Inspecting, testing, clinkering, lightingand starting set.

b. Controlling fire and heats with fuelcharges.

c. Barring, measuring, and rodding fires.d. Observing pyrometers, pressures and CO2

in stack gases.e. Regulating input materials, such as

coke, steam and air and making requiredflow rate and operating cycle changes.

f. Cleaning and removal of ash, dust, sedi-ment and materials from the set and connec-tions, seal pots, duct pockets, bootlegs, col-lectors and pumps.

g. Cleaning and reluting producer setdoors.



597


h. Operating, cleaning and lubricating fuelcharging lorries, grates, jackets and auxil-iaries, ash removal apparatus, and associatedinstruments, meters, gauges, controls, etc.

3. Handling fuel from storage into binswith conveyors.

4. Operating, cleaning and lubricating aux-iliary equipment, not incident to mainte-nance work, such as coolers, pumps, blowers,exhausters or boosters, fuel handling equip-ment, etc.

5. Removing and disposing of ashes, sedi-ment and other waste material.

6. Cleaning the producer and boosterhouses including janitorial and similar serv-ices.Materials and expenses:



715 Water gas generating expenses.This account shall include the cost of

labor used and expenses incurred in theoperation of water gas sets exclusive ofthe cost of fuel and oil for water gasproduction.

ITEMS

Labor:1. Supervising.2. Work of the following character in con-

nection with the operation of water gas sets(excepting the waste heat boiler and auxil-iaries):

a. Inspecting, testing, clinkering, lightingand starting up.

b. Controlling fire and heats with fuelcharges, barring and rodding fires, operatinggrates and jackets, taking stains, observingpyrometers, pressures, seal pot water flowand stack gases, regulating input materialssuch as coke, oil, natural gas, steam and air.

c. Making required flow rate and operatingcycle changes.

d. Cleaning and removing ashes, carbon,and sediment from the set and connections,the wash box, seal pot, oil spray, duct pock-ets, bootlegs, and collectors, and cleaningand reluting producer set doors.

e. Operating, cleaning and lubricating fuelcharging lorries, blowers, valves, automaticoperators, and grates, together with their in-struments, gauges, and controls, also the ashbelts.

3. Operating, cleaning and lubricating aux-iliary equipment, such as hydraulic pumps,circulating water pumps, oil pumps fromstorage to sets, steam accumulators and reg-ulators and reducers on natural gas for re-forming, exhausters, revivifying air blowers,and purifier exhausters.

4. Handling fuel from storage into binswith conveyors.

5. Removing and disposing of ashes, car-bon, sediment, and other waste material.

6. Cleaning of generator and exhausterhouses, including janitorial and similar serv-ices.Materials and expenses:



716 Oil gas generating expenses.This account shall include the cost of

labor used and expenses incurred in theoperation of equipment for the produc-tion of oil gas exclusive of cost of theoil.

ITEMS

Labor:1. Supervising.2. Cleaning, firing and operating oil gas

machines.3. Handling oil from place of storage to oil

gas sets.4. Measuring oil.5. Removing and disposing of carbon depos-

its, and other cleaning and incidental labor.Materials and expenses:



717 Liquefied petroleum gas expenses.This account shall include the cost of

labor used and expenses incurred in theoperation of equipment used for vapor-izing petroleum derivatives such aspropane, butane or gasoline exclusiveof cost of the materials vaporized orused for fuel in the vaporizing process.

ITEMS

Labor:1. Supervising.2. Operating, cleaning and lubricating liq-

uid petroleum vaporizers and injectors.3. Taking pressures and temperatures, and

reading gauges on storage tanks.4. Inspecting and testing equipment and

setting and adjusting controls and regu-lators.

5. Watching pressure gauges, maintainingpressures and relieving excess pressuresthrough lines.

6. Repressuring storage tanks.Materials and expenses:





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718 Other process production ex-penses.

This account shall include the cost oflabor used and expenses incurred in op-erating equipment used for the produc-tion of gas by processes not providedfor in the foregoing accounts.

719 Fuel under coke ovens.

A. This account shall include thecost of gas, other than coke oven gas orproducer gas, or other fuel used undercoke ovens for making coal gas. Con-current credits shall be made to ac-count 734, Duplicate Charges—Credit,for gas made by the utility and so used,or account 812, Gas Used for Other Util-ity Operations—Credit, for other gasused under coke ovens.

B. Records shall be kept to show thequantity and cost of each type of fuelused and fuel handling expenses.

ITEMS

1. Gas made by the utility and used undercoke ovens.

2. Natural and other purchased gas usedunder coke ovens.

720 Producer gas fuel.

A. This account shall include thecost of fuel used in making producergas including applicable amounts offuel stock expenses. It shall also in-clude the net cost of, or the netamount realized from, the disposal ofashes.

B. Records shall be kept to show thequantity and the cost of each type offuel used. Respective amounts of fuelstock and fuel stock expenses shall bereadily available.

NOTE: The cost of fuel and related fuelstock expenses shall be charged initially tothe appropriate fuel account carried underaccounts 151, Fuel Stock, and 152, Fuel StockExpenses Undistributed, and cleared to thisaccount on the basis of fuel used. See ac-counts 151 and 152 for basis of fuel costs andincludible items of fuel stock expenses.

721 Water gas generator fuel.

A. This account shall include thecost of fuel used in making water gas,including applicable amounts of fuelstock expenses. It shall also includethe net cost of, or net proceeds from,the disposal of ashes.

B. Records shall be kept to show thequantity and cost of each type of fuelused. Respective amounts of fuel stockand fuel stock expenses shall be readilyavailable.

NOTE: The cost of fuel and related fuelstock expenses shall be charged initially tothe appropriate fuel account carried underaccounts 151, Fuel Stock, and 152, Fuel StockExpenses Undistributed, and cleared to thisaccount on the basis of fuel used. See ac-counts 151 and 152 for basis of fuel costs andincludible items of fuel stock expenses.

722 Fuel for oil gas.This account shall include the cost of

fuel for the manufacture of gas by theoil gas process.

723 Fuel for liquefied petroleum gasprocess.

This account shall include the cost offuel for vaporization of liquefied petro-leum gas and for the compression of airin liquefied petroleum gas process.

724 Other gas fuels.This account shall include the cost of

fuel for the manufacture of gas byprocesses not provided for in the abovefuel accounts.

725 Coal carbonized in coke ovens.A. This account shall include the

cost of coal used in coke ovens formaking coal gas, including applicableamounts of fuel stock expenses.

B. Records shall be kept to show thetype, quantity, and cost of coal used.Respective amounts of fuel stock andfuel stock expenses shall be readilyavailable.

NOTE: The cost of coal carbonized and re-lated fuel stock expenses shall be chargedinitially to the appropriate account carriedunder accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of coal used. Seeaccounts 151 and 152 for basis of costs and in-cludible items of fuel stock expenses.

726 Oil for water gas.A. This account shall include the

cost of oil used in carbureting watergas, including applicable amounts offuel stock expenses.

B. Records shall be kept to show thetype, quantity, and cost of oil used. Re-spective amounts of fuel stock and fuel



599


stock expenses shall be readily avail-able.

NOTE: The cost of oil and related fuel stockexpenses shall be charged initially to the ap-propriate accounts carried under accounts151, Fuel Stock, and 152, Fuel Stock Ex-penses Undistributed, and cleared to this ac-count on the basis of oil used. See accounts151 and 152 for basis of costs and includibleitems of fuel stock expenses.

727 Oil for oil gas.A. This account shall include the

cost of oil used in making oil gas, in-cluding applicable amounts of fuelstock expenses.

B. Records shall be kept to show thetype, quantity, and cost of oil used. Re-spective amounts of fuel stock and fuelstock expenses shall be readily avail-able.

NOTE: The cost of oil and related fuel stockexpenses shall be charged initially to the ap-propriate raw materials account carriedunder accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of oil used. Seeaccounts 151 and 152 for basis of costs and in-cludible items of fuel stock expenses.

728 Liquefied petroleum gas.A. This account shall include the

cost of liquefied petroleum gas, such aspropane, butane, or gasoline, vaporizedfor mixing with other gases or for saleunmixed, including applicable amountsof fuel stock expenses.

B. Records shall be kept to show thetype, quantity, and cost of liquefied pe-troleum gas. Respective amounts offuel stock and fuel stock expenses shallbe readily available.

NOTE: The cost of liquefied petroleum gasand related fuel stock expenses shall becharged initially to the appropriate accountsunder accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of liquefied pe-troleum gas used. See accounts 151 and 152for basis of costs and includible items of fuelstock expenses.

729 Raw materials for other gas proc-esses.

A. This account shall include thecost of raw materials used in the pro-duction of manufactured gas by anyprocess not provided for by the fore-

going accounts including the produc-tion of coal gas by use of retorts, in-cluding applicable amounts of fuelstock expenses.

B. Records shall be kept to show thetype, quantity, and cost of each rawmaterial used, comparable to the ac-counting specified in the foregoing ac-counts for specified types of gas proc-esses. Respective amount of fuel stockand fuel stock expenses shall be readilyavailable.

NOTE: The cost of raw materials and fuelstock expenses shall be charged initially tothe appropriate accounts carried under ac-counts 151, Fuel Stock, and 152, Fuel StockExpenses Undistributed, and cleared to thisaccount on the basis of raw materials used.See accounts 151 and 152 for basis of raw ma-terials costs and includible items of raw ma-terials stock expenses.

730 Residuals expenses.

A. This account shall include thecost of labor, materials used and ex-penses incurred including uncollectibleaccounts in obtaining, handling, pre-paring, refining, and marketing residu-als produced in manufactured gas pro-duction processes.

B. Divisions of this account shall bemaintained for each of the principaltypes of expenses chargeable heretoand for each residual or by-product car-ried in account 731, Residuals Pro-duced—Credit.

731 Residuals produced—Credit.

A. This account shall be credited andthe appropriate subdivision of account153, Residuals and Extracted Products,debited monthly with the estimatedvalue of residuals and other by-prod-ucts obtained in connection with theproduction of manufactured gas,whether intended for sale or for use inoperations.

B. If the net amount realized fromthe sale of residuals is greater or lessthan the amount at which they wereoriginallly credited hereto, an adjust-ing entry shall be made crediting ordebiting this account and charging orcrediting the appropriate subdivisionof account 153, Residuals and ExtractedProducts, with the difference.



600


732 Purification expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating purification equip-ment and apparatus used for condi-tioning manufactured gas.

ITEMS

Labor:1. Supervising.2. Operating conveyors, condensers, cool-

ers, tar extractors and precipitators, shavingscrubbers and naphthalene and light oilscrubbers.

3. Emptying, rearranging, shifting, clean-ing, purging, and refilling purifier boxes.

4. Removing spent oxide to refuse pile.5. Revivifying oxide.6. Oiling dip sheets of purifier boxes.7. Inspecting, testing, controlling adjust-

ments, and taking stains.8. Cleaning and lubricating purification

equipment.Materials and expenses:

9. Iron oxide.10. Unslacked lime.11. Shavings.12. Soda ash for liquid purifiers.13. Wash oil for naphthalene scrubber.14. Sulphuric acid.

733 Gas mixing expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating equipment for mix-ing natural and manufactured gas, orvaporized liquefied petroleum gases fordelivery to the distribution system.

ITEMS

Labor:1. Supervising.2. Mixing enrichment gas and other gases

or air, including mixing of liquid petroleumgas with air in a liquid petroleum air gasplant, and operation of air jetting equipmentand controls.

3. Operating, cleaning and lubricating ofcleaners, reducers, calorimeters,calorimixers, appliances and mixing appara-tus with their related recorders, gauges,valves and controls, and gravitometers.

4. Inspecting, testing and adjusting mixingequipment.

5. Reading instruments and gauges, chang-ing charts, and recording instrument andgauge readings.Materials and expenses:



734 Duplicate charges—Credit.This account shall include concur-

rent credits for charges which are madeto manufactured gas production oper-ating expenses for manufactured gasnot entering common system supply,steam or electricity used for whichthere is no direct money outlay.

NOTE: For manufactured gas used from thecommon system supply, concurrent creditsshall be made to account 812, Gas Used forOther Utility Operations—Credit.

735 Miscellaneous production ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred in manufacturing gas produc-tion operations not includible in any ofthe foregoing accounts.

ITEMS

Labor:1. Supervising.2. Cleaning gas works yard of coke dust

and other waste materials.3. Humidifying gas or oil fogging gas at the

production plant.4. Cutting grass and care of the grounds

around the gas works.5. Clearing gas works yard of snow.6. Janitor service and messenger service.7. Operating elevators and other convey-

ances for general use at the gas works.8. General clerical and stenographic work

at gas works.9. Guarding and patrolling plant and yard.10. Testing plant instruments not else-

where provided for.11. Laboratory labor, except that charge-

able to other accounts.12. Reading manufactured gas meters, and

calculating and recording hourly volumesproduced.

13. Pumping drips (water) at plant (notprovided for elsewhere).

14. Odorizing manufactured gas.15. Operating, cleaning, and lubricating of

air compressors with their tanks, instru-ments, meters, gauges, and controls whenused to supply compressed air into theplant’s air system.

16. Operating effluent water treatment sys-tems, including chemical treatmentozonation, filter, and related equipment, in-cluding treatment of carbon and residualsludge, and removing spent oxide, and spentfiltering materials.

17. Pumping water for cooling and condens-ing.

18. Cleaning filters and other operating du-ties of water system.Materials and expenses:



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19. Producer gas transferred from cokeoven plant to water gas plant for dilutionpurposes.

20. Building service, communication serv-ice, transportation.

21. First aid supplies and safety equipment.22. Office supplies, printing and station-

ery.23. Meals, travelling and incidental ex-

penses.24. Fuel for heating plant, water for fire

protection or general use, and similar items.25. Lubricants, packing, waste, etc.26. Odorizing chemicals.27. Hand tools, drills, saw blades, files, etc.28. Fire protection supplies.29. Fogging oils, alcohol, etc.30. Chemicals, filter materials, etc., and

payments to others for disposal of planteffluents and waste.

31. Chemicals for water treatment.32. Research, development, and demonstra-

tion expenses.

736 Rents.This account shall include rents for

property of others used, occupied or op-erated in connection with manufac-tured gas production operations. (Seeoperating expense instruction 3.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of manufactured gas produc-tion facilities. Direct field supervisionof specific jobs shall be charged to theappropriate maintenance accounts.(See operating expense instruction 1.)


This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of struc-tures, the book cost of which is includ-ible in account 305, Structures and Im-provements. (See operating expense in-struction 2.)

742 Maintenance of production equip-ment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment for the production of manufac-tured gas, the book cost of which is in-cluded in accounts 306 to 320, inclusive,except such equipment as is used for

the production of steam the mainte-nance of which is includible in ac-counts 707, Maintenance of BoilerPlant Equipment, and 708, Maintenanceof Other Steam Production Plant. (Seeoperating expense instruction 2.)


A. This account shall include thecost of labor and expenses incurred inthe general supervision and directionof the operation of production andgathering systems. Direct supervisionof specific activities such as turning onand shutting off wells, operating meas-uring and regulating stations, etc.,shall be charged to the appropriate ac-count. (See operating expense instruc-tion 1.)

B. For Nonmajor companies, this ac-count shall include the cost of super-vision and labor in the operation of gaswells, lines, compressors and otherequipment of the natural gas produc-tion and gathering system includingmiscellaneous labor such as care ofgrounds, building service, and generalclerical and stenographic work at fieldoffices.

ITEMS

1. Supervision. (See operating expense in-struction 1.)

2. Gas depletion and gas reserve activities.3. Geological activities in connection with

gas production.4. Rights-of-way office activities and su-

pervision, not in connection with construc-tion or retirement work, or storage.

751 Production maps and records.This account shall include the cost of

labor, materials used and expenses in-curred in the preparation and mainte-nance of production maps and records.

ITEMS

Labor:With respect to production maps:

1. Supervising.2. Preparing farm maps, field inventory

maps, well location plats, and other mapsused in connection with natural gas produc-tion and gathering operations.

3. Posting changes and making correctionsof maps.

4. Maintaining files of maps and tracings.5. Surveying deeds, leases, rights-of-way,

well locations, etc., for map revisions.6. Reproducing maps (blueprints, photo-

stats, etc.).



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With respect to land records:7. Supervising.8. Abstracting titles to date for extension

and renewal of leases.9. Adjusting land and well rentals.10. Checking free gas rights.11. Maintaining land and lease records.12. Delivering rental and royalty checks.13. Assigning, pooling, merging, renewing,

and extending leases.14. Patrolling land.15. Preparing expiration calendars.16. Replacing leases (not involving addi-

tional consideration).17. Transferring payees.

Materials and expenses:18. Blueprints, photostats, etc.19. Drafting materials and supplies.20. Surveying materials and supplies.21. Employee transportation and travel ex-

penses.22. Freight, express, parcel post, trucking,

and other transportation.23. Janitor and washroom supplies, etc.24. Office supplies, stationery and printed

forms.25. Utility services: light, water, and tele-

phone.

752 Gas wells expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating producing gaswells.

ITEMS

Labor:1. Supervising.2. Testing, bailing, swabbing, blowing and

gauging producing gas wells.3. Cleaning off old well locations.4. Painting signs, etc.5. Minor upkeep of well roads and fences,

etc.6. Turning wells off and on.7. Pumping wells.

Materials and expenses:8. Gas, gasoline, and oil used in pumping,

bailing, heating, and swabbing.9. Lumber, nails, and other materials used

for upkeep of fences, making signs, etc.10. Materials for upkeep of well roads, etc.11. Well swabs.12. Employees’ transportation and travel

expenses.13. Freight, express, parcel post, trucking

and other transportation.14. Transportation: company and rented

vehicles.

753 Field lines expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating field lines.

ITEMS

Labor:1. Supervising.2. Walking or patrolling lines.3. Attending valves, lubricating valves and

other equipment, blowing and cleaning linesand drips, draining water from lines, operat-ing and cleaning scrubbers, thawing freezes.

4. Taking line pressures, changing pressurecharts, operating alarm gauges.

5. Building and repairing gate boxes, footbridges, stiles, tool boxes, etc., used in lineoperations, erecting line markers and warn-ing signs, repairing old line roads.

6. Cleaning debris, cutting grass and weedson rights-of-way.

7. Inspecting and testing not specifically todetermine necessity for repairs.

8. Protecting utility property during workby others.

9. Standby time of emergency crews, re-sponding to fire calls, etc.

10. Locating valve boxes or drip riserboxes.

11. Cleaning and repairing tools used inmains operations, making tool boxes, etc.

12. Cleaning structures and equipment.13. Driving trucks.

Materials and expenses:14. Line markers and warning signs.15. Lumber, nails, etc., used in building and

repairing gate boxes, foot bridges, stiles, toolboxes, etc.

16. Charts.17. Scrubber oil.18. Hand tools.19. Lubricants, wiping rags, waste, etc.20. Freight, express, parcel post, trucking

and other transportation charges.21. Employees’ transportation and travel

expenses.22. Janitor and washroom supplies.23. Utility services: light, water, telephone.24. Gas used in field line operations.

754 Field compressor station ex-penses.

This account shall include the cost oflabor, materials used, except fuel, andexpenses incurred in operating fieldcompressor stations.

ITEMS

Labor:1. Supervising.2. Operating and checking engines, equip-

ment valves, machinery, gauges, and otherinstruments, including cleaning, wiping, pol-ishing, and lubricating.

3. Operating boilers and boiler accessoryequipment, including fuel handling and ashdisposal, recording fuel used, and unloadingand storing coal and oil.

4. Repacking valves and replacing gaugeglasses, etc.



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5. Recording pressures, replacing charts,keeping logs, and preparing reports of sta-tion operations.

6. Inspecting and testing equipment whennot specifically to determine necessity forrepairs or replacement of parts.

7. Pumping drips at the station.8. Taking dew point readings.9. Testing water.10. Cleaning structures, cutting grass and

weeds, and minor grading around station.11. Cleaning and repairing hand tools used

in operations.12. Driving trucks.13. Watching during shut downs.14. Clerical work at station.

Materials and expenses:15. Scrubber oil.16. Lubricants, wiping rags, and waste.17. Charts and printed forms, etc.18. Gauge glasses.19. Chemicals to test waters.20. Water tests and treatment by other

than employees.21. Janitor and washroom supplies, first

aid supplies, landscaping supplies, etc.22. Employees’ transportation and travel

expenses.23. Freight, express, parcel post, trucking,

and other transportation.24. Utility services: light, water, telephone.

755 Field compressor station fuel andpower.

A. This account shall include thecost of gas, coal, oil, or other fuel, orelectricity, used for the operation offield compressor stations, including ap-plicable amounts of fuel stock ex-penses.

B. Records shall be maintained toshow the quantity of each type of fuelconsumed or electricity used at eachcompressor station, and the cost ofsuch fuel or power. Respective amountsof fuel stock and fuel stock expensesshall be readily available.

NOTE: The cost of fuel, except gas, and re-lated fuel stock expenses shall be chargedinitially to appropriate fuel accounts carriedin accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of fuel used. Seeaccounts 151 and 152 for the basis of fuelcosts and includible fuel stock expenses.

756 Field measuring and regulatingstation expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating field measuring andregulating stations.

ITEMS

Labor:1. Supervising.2. Recording pressures and changing

charts, reading meters, etc.3. Estimating lost meter registrations,

etc., except gas purchases and sales.4. Calculating gas volumes from meter

charts, except for gas purchases and sales.5. Adjusting and calibrating measuring

equipment, changing meters, orifice plates,gauges, clocks, etc., not in connection withmaintenance or construction.

6. Testing gas samples, inspecting and test-ing gas sample tanks and other meter engi-neer’s equipment, determining specific grav-ity and Btu content of gas.

7. Inspecting and testing equipment notspecifically to determine necessity for re-pairs including pulsation tests.

8. Cleaning and lubricating equipment.9. Keeping log and other operating records,

preparing reports of operations, etc.10. Attending boilers and operating other

accessory equipment.11. Installing and removing district gauges

for pressure survey.12. Thawing freeze in gauge pipes.13. Inspecting and pumping drips,

dewatering manholes and pits, inspectingsumps, cleaning pits, etc., blowing meterdrips.

14. Moving equipment, minor structures,etc., not in connection with construction, re-tirement, or maintenance work.Materials and expenses:

15. Charts and printed forms, stationeryand office supplies, etc.

16. Lubricants, wiping rags, waste.17. Employees’ transportation and travel

expense.18. Freight, express, parcel post, trucking



labor, materials used and expenses in-curred in operating equipment used forpurifying, dehydrating, and condi-tioning of natural gas.

ITEMS

Labor:1. Supervising.2. Changing charts on fuel meters.3. Emptying, cleaning and refilling puri-

fier boxes.4. Oiling dip sheets of purifier covers.5. Removing spent oxide to refuse piles.6. Revivifying oxide.7. Taking readings of inlet and outlet pres-

sures and temperature.8. Unloading and storing glycol.9. Watching station and equipment.



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10. Cutting grass and weeds, and minorgrading around equipment and stations.

11. Hauling operating employees, mate-rials, supplies and tools, etc.

12. Inspecting and testing equipment, notspecifically to determine necessity for re-pairs or replacement of parts.

13. Lubricating equipment, valves, etc.14. Operating and checking equipment,

valves, instruments, etc.Materials and expenses:

15. Liquid purifying supplies.16. Iron oxide.17. Odorizing materials.18. Charts, printed forms, etc.19. Employees’ transportation and travel


and other transportation.21. Gas used in operations.22. Janitor, washroom, and landscaping

supplies.23. Lubricants, wiping rags, waste, etc.24. Utility services: light, water, telephone.NOTE: Inclusion of dehydration expenses in

this account shall be consistent with thefunctional classification of dehydrationplant as to which, see the note to account336, Purification Plant, relating to caseswhere dehydrators may be located some dis-tance from the production sources of gas.

758 Gas well royalties.A. This account shall include royal-

ties paid for natural gas produced bythe utility from wells on land owned byothers.

B. Records supporting the entries tothis account shall be so kept that theutility can furnish the name of the par-ties to each contract involving royal-ties, the terms of each contract, the lo-cation of the property involved, themethod of determining the royalties,and the amounts payable.

759 Other expenses.This account shall include the cost of

labor, materials used and expenses in-curred in producing and gathering nat-ural gas and not includible in any ofthe foregoing accounts.

ITEMS

Labor:1. Moving cleaning tools between locations.2. Operating communications system.3. Reading limited and unlimited free gas

meters.Materials and expenses:

4. Miscellaneous small tools, etc.

5. Research, development, and demonstra-tion expenses.

760 Rents.

This account shall include rents forproperty of others used, occupied or op-erated in connection with the produc-tion and gathering of natural gas,other than rentals on land and landrights held for the supply of naturalgas. (See operating expense instruction3.)

NOTE: See account 795, Delay Rentals, forrentals paid on lands held for the purpose ofobtaining a supply of gas in the future.


This account shall include the cost oflabor, materials used and expenses in-curred in the general supervision anddirection of maintenance of the pro-duction and gathering facilities as awhole. Direct field supervision of spe-cific jobs shall be charged to the appro-priate maintenance account. (See oper-ating expense instruction 1.)


This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of struc-tures and improvements, the book costof which is includible in accounts 326,Gas Well Structures, 327, Field Com-pressor Station Structures, 328, FieldMeasuring and Regulating StationStructures, and 329, Other Structures.(See operating expense instruction 2.)

763 Maintenance of producing gaswells.

This account shall include the cost oflabor, materials used and expenses in-curred in maintenance of gas wells andequipment includible in accounts 330.Producing Gas Wells—Well Construc-tion, and 331, Producing Gas Wells—Well Equipment. (See operating ex-pense instruction 2.)

764 Maintenance of field lines.

This account shall include the cost oflabor, materials used and expenses in-curred in maintenance of field lines the



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book cost of which is includible in ac-count 332, Field Lines. (See operatingexpense instruction 2.)

ITEMS

1. Electrolysis and leak inspections (notroutine).

2. Installing and removing temporary lines,when necessitated by maintenance.

3. Lamping and watching while making re-pairs.

4. Lowering and changing location of por-tion of lines, when the same pipe is used.

5. Protecting lines from fires, floods, landslides, etc.

6. Rocking creek crossings.

765 Maintenance of field compressorstation equipment.

This account shall include the cost oflabor and expenses incurred in themaintenance of field compressor sta-tion equipment includible in account333, Field Compressor Station Equip-ment. (See operating expense instruc-tion 2.)

766 Maintenance of field measuringand regulating station equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in maintenance of field measur-ing and regulating station equipmentincludible in account 334, Field Meas-uring and Regulating Station Equip-ment. (See operating expense instruc-tion 2.)

767 Maintenance of purificationequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of purifi-cation equipment includible in account336, Purification Equipment. (See oper-ating expense instruction 2.)

NOTE: Inclusion of dehydration mainte-nance expenses in this account shall be con-sistent with the functional classification ofdehydration plant as to which see the noteto account 336, Purification Equipment, re-lating to cases where dehydrators may be lo-cated some distance from the productionsources of gas.

768 Maintenance of drilling and clean-ing equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of drilling

and cleaning equipment includible inaccount 335, Drilling and CleaningEquipment, except such costs of main-taining drilling tools or other equip-ment which are assignable to the costof drilling wells. (See operating ex-pense instruction 2.)

769 Maintenance of other equipment.This account shall include the cost of

labor, materials used and expenses in-curred in maintenance of other produc-tion and gathering equipment includ-ible in account 337, Other Equipment.(See operating expense instruction 2.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of prod-ucts extraction and refining oper-ations, except supervision of marketingand selling operations which shall becharged to account 779, Marketing Ex-penses. Direct supervision of specificextraction and refining activities shallbe charged to the appropriate account.(See operating expense instruction 1.)

771 Operation labor.This account shall include the cost of

labor used in the operation of facilitiesfor the extraction of gasoline, butane,propane, or other salable products fromnatural gas and for refining such prod-ucts.

ITEMS

Labor:1. Supervising.2. Operating, checking, lubricating, wiping,

polishing, and cleaning engines, equipment,valves, machinery, gauges, and other instru-ments, etc.

3. Inspecting and testing equipment and in-struments, not specifically to determine ne-cessity for repairs or replacement of parts.

4. Reading meters, gauges, and other in-struments, changing charts, preparing oper-ating reports, etc.

5. Testing gasoline samples, water, etc.6. Cleaning structures housing equipment,

cutting grass and weeds and doing minorgrading work around equipment and struc-tures, etc.

7. Driving trucks used in products extrac-tion operations.

8. Cleaning and repairing hand tools usedin operations, etc.

9. Watching plant during shut-down peri-ods.



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10. Making electricity or steam.

772 Gas shrinkage.A. This account shall include the

cost of gas lost or absorbed in the proc-ess of extraction of salable productsfrom natural gas, exclusive of gas usedas fuel, the cost of which shall be in-cluded in account 773, Fuel.

B. Concurrent credits offsettingcharges to this account shall be madeto account 811, Gas Used for ProductsExtraction—Credit.

773 Fuel.A. This account shall include the

cost of natural gas or other fuel used inextracting gasoline, butane, propaneand other salable products from natu-ral gas, including fuel used for genera-tion of electricity or making steam.

B. Concurrent Credits offsettingcharges to this account shall be madeto account 811, Gas Used for ProductsExtraction—Credit.

774 Power.This account shall include the cost of

electricity purchased for operation offacilities used in the extraction of gas-oline, butane, propane, or other salableproducts from natural gas.

775 Materials.This account shall include the cost of

materials used in extracting salableproducts from natural gas and blendingand refining such products.

ITEMS

1. Absorption oil.2. Charcoal.3. Water (payments to others for water).4. Steam (payments to others for steam).5. Blending agents.6. Natural gasoline removed from inven-

tory for blending and refining purposes.7. Tetraethyl lead.

776 Operation supplies and expenses.This account shall include supplies

used and expenses incurred in the oper-ation of facilities for recovering salableproducts from natural gas and blendingand refining such products, not pro-vided for elsewhere.

ITEMS

1. Employee transportation and travel ex-penses.

2. Freight, express, parcel post, truckingand other transportation.

3. Utility services: light, water, telephone.4. Charts, gas measurement, etc.5. Janitor, washroom and landscaping sup-

plies.6. Lubricants: oil and grease, wiping rags

and waste, etc.7. Testing equipment, hand tools, etc., of a

portable nature and relatively minor cost orof short life.

8. Research, development, and demonstra-tion expenses.

777 Gas processed by others.A. This account shall include the

cost of gas shrinkage, gas consumed forfuel, royalties, and other expenses inconnection with the processing of gasof the utility by others for extractionof salable products, for which the relat-ed revenues are includible in account491, Revenues from Natural Gas Proc-essed by Others.

B. Concurrent credits offsettingcharges to this account for the dif-ference between gas delivered to othersfor processing and gas returned afterprocessing, such as shrinkage in theprocessing operations and gas of theutility used for fuel, shall be made toaccount 811, Gas Used for Products Ex-traction of Credit.

C. Records supporting this accountshall be so maintained that full infor-mation will be readily available con-cerning gas shrinkage, gas used forfuel, royalties, and other expenses as-sumed or paid by the utility with re-gard to each processor of gas of theutility. (See paragraph B of account491, Revenues from Natural Gas Proc-essed by Others.)

ITEMS

1. Gas shrinkage, being cost of the reduc-tion in gas from products extraction oper-ations of gas of the utility processed by oth-ers.

2. Gas for fuel, being cost of gas of the util-ity used for fuel in connection with the prod-ucts extraction processing of the utility’sgas by others.

3. Royalties, being payments of fractionalinterests of royalty holders in products ex-tracted by others from gas of the utility.

778 Royalties on products extracted.This account shall include royalties

paid by the utility to others for theright to extract salable products fromnatural gas.



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779 Marketing expenses.A. This account shall include the

cost of labor, materials used and ex-penses incurred in the marketing ofproducts extracted from natural gasand of similar products purchased forresale.

B. The records supporting this ac-count shall be so maintained that sum-maries of the various types of expensesshall be readily available.

ITEMS

Labor:1. Salaries of persons directly engaged in

marketing operations.Materials and expenses:

2. Employee transportation and travel ex-penses.

3. Tank car rentals.4. Freight and hauling charges for products

shipped.5. Miscellaneous marketing expenses.6. Building service charges for space occu-

pied by marketing personnel.7. Uncollectible accounts for extracted

products sold.

780 Products purchased for resale.A. This account shall include the

cost of gasoline, butane, propane, orother salable products purchased fromothers for resale.

B. The records supporting this ac-count shall be so maintained that thekind, quantity, and cost of productspurchased from each vendor are readilyavailable.

781 Variation in products inventory.This account shall include credits for

increases, and debits for decreases inthe inventories of salable products ex-tracted from natural gas or purchasedfor resale. The net debit or credit inthis account shall equal the differencebetween the inventory at the beginningof the accounting year and the end ofthe accounting month.

782 Extracted products used by theutility—Credit.

This account shall include concur-rent credits for charges which are madeof operating expenses or other accountsof the gas department for gasoline orother extracted products which areused from stocks recovered in the natu-ral gas extraction process or purchased

for resale, and for such products usedfor blending and refining processes, thecontra debit for which is account 775,Materials.

783 Rents.

This account shall include all rentsfor the property of others used, occu-pied, or operated in connection withthe extraction of salable products fromnatural gas, exclusive of tank car rent-als and other similar rentals includiblein account 779, Marketing Expenses.(See operating expense instruction 3.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of facilities used in the extrac-tion and refining of salable productsfrom natural gas. Direct field super-vision of specific jobs shall be chargedto the appropriate maintenance ac-count. (See operating expense instruc-tion 1.)



786 Maintenance of extraction and re-fining equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 342, Extraction and Re-fining Equipment. (See operating ex-pense instruction 2.)

787 Maintenance of pipe lines.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 343, Pipe Lines. (See op-erating expense instruction 2.)



608


788 Maintenance of extracted prod-ucts storage equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 344, Extracted ProductsStorage Equipment. (See operating ex-pense instruction 2.)

789 Maintenance of compressor equip-ment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 345, Compressor Equip-ment. (See operating expense instruc-tion 2.)

790 Maintenance of gas measuring andregulating equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 346, Gas Measuring andRegulating Equipment. (See operatingexpense instruction 2.)


labor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 347, Other Equipment.(See operating expense instruction 2.)

795 Delay rentals.A. This account shall be charged with

the amount of rents paid periodicallyon natural gas lands acquired by leasebefore October 8, 1969, in order to holdnatural gas land and land rights for thepurpose of obtaining a supply of gas inthe future.

B. Include also in this account, thecost of obtaining natural gas leases fora period of 1 year or less when suchleases were acquired before October 8,1969.

C. Records supporting this accountshall be so kept that the utility canfurnish complete details of the chargesmade for each natural gas leasehold.(See note to gas plant instruction 7G.)

NOTE: Rents paid periodically on naturalgas lands acquired by lease after October 7,

1969, shall be charged to account 105.1, Pro-duction Properties Held for Future Use.

796 Nonproductive well drilling.This account shall include the net

cost of drilling wells on natural gasleases acquired before October 8, 1969,which prove to be nonproductive.

NOTE A: Records in support of the chargesto this account shall conform, as appro-priate, to Note B of General Instruction 12,Records for Each Plant.

NOTE B: The net cost of drilling wells onnatural gas leases acquired after October 7,1969, which prove to be nonproductive, shallbe charged to account 338, Unsuccessful Ex-ploration and Development Costs.

797 Abandoned leases.A. This account shall be charged with

amounts credited to account 111, Accu-mulated Provision for Amortizationand Depletion of Gas Utility Plant, tocover the probable loss on abandon-ment of natural gas leases acquired be-fore October 8, 1969, included in ac-count 105, Gas Plant Held for FutureUse, which has never been productive.(See account 182.1.)

B. When natural gas leaseholds whichwere acquired before October 8, 1969,and which have never been productiveare abandoned, and the amounts pro-vided in account 111, Accumulated Pro-vision for Amortization and Depletionof Gas Utility Plant, are not sufficientto cover the cost thereof, the defi-ciency shall be charged to this accountunless otherwise authorized or directedby the Commission. (See account 182.1.)

NOTE: Losses on abandonment of naturalgas leases acquired after October 7, 1969,shall be charged to account 338, UnsuccessfulExploration and Development Costs.

798 Other exploration.This account shall be charged with

the cost of abandoned projects involv-ing natural gas leases acquired beforeOctober 8, 1969, on which preliminaryexpenditures were made for the purposeof determining the feasibility of ac-quiring acreage to provide a future sup-ply of natural gas (see account 183.1,Preliminary Natural Gas Survey andInvestigation Charges).

NOTE: Preliminary expenditures on aban-doned projects involving natural gas leases



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acquired after October 7, 1969, shall becharged to account 338, Unsuccessful Explo-ration and Development Costs.

800 Natural gas well head purchases.A. This account shall include the

cost at well head of natural gas pur-chased from producers in gas fields orproduction areas where only the util-ity’s facilities are used in bringing thegas from the well head into the util-ity’s natural gas system.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and well head the quantity of gas,basis of charges, and amount paid forthe gas.

NOTE: If gas purchases are made under onecontract covering both well head and fieldline purchases and such amounts are notreadily separable, the utility may classifysuch purchases according to predominantsource or according to a reasonable estimate.

800.1 Natural gas well-head purchases;intracompany transfers.

A. This account shall include, for in-formational purposes only, the amountrecorded for gas supplied by the pro-duction division when the price is notdetermined by a cost-of-service rateproceeding.

B. The records supporting this ac-count shall be so maintained that therewill be readily available for each well-head, the quantity of gas, the basis ofintracompany charges, and the amountof intracompany charges for gas.

801 Natural gas field line purchases.A. This account shall include the

cost, at point of receipt by the utility,of natural gas purchased in gas fieldsor production areas at points alonggathering lines, and at points along theutility’s transmission lines within fieldor production areas, exclusive of pur-chases at outlets of gasoline plants in-cludible in account 802, where facilitiesof the vendor or others are used inbringing the gas from the well head tothe point of entry into the utility’snatural gas system.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and each point of receipt, the quan-

tity of gas, basis of charges, andamount paid for the gas.

NOTE: If gas purchases are made under onecontract covering both well head and fieldline purchases and such amounts are notreadily separable, the utility may classifysuch purchases according to predominantsource or according to a reasonable estimate.

802 Natural gas gasoline plant outletpurchases.

A. This account shall include thecost, at point of receipt by the utility,of natural gas purchased at the outletside of vendor’s natural gas productsextraction plants.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and for each products extractionplant, the quantity of gas, basis of thecharges, and the amount paid for thegas.

803 Natural gas transmission line pur-chases.

A. This account shall include thecost, at point of receipt by the utility,of natural gas purchased at pointsalong the utility’s transmission linesnot within gas fields or productionareas, excluding purchases at the out-lets of products extraction plants in-cludible in account 802.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and each point of receipt, the quan-tity of gas, basis of charges, and theamount paid for the gas.

804 Natural gas city gate purchases.A. This account shall include the

cost, at point of receipt by the utility,of natural gas purchased which is re-ceived at the entrance to the distribu-tion system of the utility.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and each point of receipt, the quan-tity of gas, basis of the charges, andthe amount paid for the gas.

NOTE: Do not credit this account for gasused in reforming for which the cost ischarged to manufactured gas production ex-penses. Credits for such gas should be madeto account 812, Gas Used for Other UtilityOperations—Credit.



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804.1 Liquefied natural gas purchases.A. This account shall include the

cost, including transportation, at pointof receipt by the utility, of liquefiednatural gas purchased for the purposeof vaporization and injection into theutility’s transmission or distributionsystem for resale.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and point of receipt, the quantityof liquefied natural gas purchased,basis of charges, the amount paid forthe liquefied gas, and transportationcharges incurred up to the point of re-ceipt of the liquefied gas.

805 Other gas purchases.A. This account shall include the

cost, at point of receipt by the utility,of manufactured gas, refinery gas, orany gas other than natural gas, orother than any mixed gas in which thenatural gas is an important proportionof the mixture.

B. The records supporting this ac-count shall be so maintained that thereshall be readily available for each ven-dor and each point of receipt, the kindand quantity of gas, Btu content, basisof the charges, and the amount paid forthe gas.

C. Utilities recognizing revenue forshipper-supplied gas must include thecurrent market price of such gas inthis account. Current market price isthe delivered spot price of gas in theutility’s supply area, as published in arecognized industry journal. The publi-cation used must be the same one iden-tified in the pipeline’s tariff for use inits cash-out provision, if it has one. Ifit has no cash-out provision, the utilitymust use one publication consistently.Contra entries to those recorded hereinmust be made to the appropriate trans-portation revenue account (Account489.1 through Account 489.4). Recordsare to be maintained and readily avail-able that include the name of shipper,quantity of gas, and the publicationand price used to value shipper-sup-plied gas.

D. The value of gas received fromshippers under tariff allowances that isnot consumed in operations nor return-able to customers through rate track-ing mechanisms must be credited to

Account 495, Other Gas Revenues andcharged to this account. Utilities mustsimultaneously charge Accounts 117.3or 117.4 as appropriate, with contracredits to Account 808.2, Gas Deliveredto Storage—Credit. Records are to bemaintained and readily available thatinclude the name of shipper, quantityof gas, and the publication and priceused to value shipper-supplied gas.

805.1 Purchased gas cost adjustments.A. This account shall be debited or

credited with decreases or increases inpurchased gas costs related to Commis-sion approved purchased gas adjust-ment clauses when such costs are notincluded in the utility’s rate scheduleson file with the Commission.

B. This account shall be debited orcredited with amounts amortized fromAccount 191, Unrecovered PurchasedGas Costs.

806 Exchange gas.This account includes debits or cred-

its for the cost of gas in unbalancedtransactions where gas is received fromor delivered to another party in ex-change, load balancing, or no-noticetransportation transactions. The costsare to be determined consistent withthe accounting method adopted by theutility for its system gas. If the utilityhas adopted the inventory method ofaccounting, the amounts to be recordedin Account 806 must be based on thehistorical cost of the gas. If the utilityhas adopted the fixed asset method ofaccounting, the amounts to be recordedin Account 806 must be based on thecurrent market price of gas at the timegas is tendered for transportation. (Seethe Special Instructions to Accounts117.1, 117.2, and 117.3 for a description ofthe inventory and fixed asset methodsand the definition of the current mar-ket price of gas.) Contra entries tothose in this account are to be made toaccount 174, Miscellaneous Current andAccrued Assets, for gas receivable andto account 242, Miscellaneous Currentand Accrued Liabilities, for gas deliv-erable under such transactions. Suchentries must be reversed and appro-priate contra entries made to this ac-count when gas is received or deliveredin satisfaction of the amounts receiv-able or deliverable.



611


807 Purchased gas expenses.A. This account shall include ex-

penses incurred directly in connectionwith the purchase of gas for resale.

B. The utility shall not include aspurchased gas expense, segregated orapportioned expenses of operating andmaintaining gathering system plantwhether such plant is devoted solely orpartially to purchases of gas, exceptthat the utility shall include the costof turning on and off purchase gaswells and operating measuring stationsdevoted exclusively to measuring pur-chased gas.

C. In general, it is intended that thisaccount include only the expenses di-rectly related to purchased gas, includ-ing the expenses of computing volumesof gas purchased, and special items di-rectly related to gas purchases whichare not includible in other accounts.

D. This account shall be subdividedas follows:807.1 Well expenses—Purchased gas.807.2 Operation of purchased gas measuring

stations.807.3 Maintenance of purchased gas measur-

ing stations.807.4 Purchased gas calculations expenses.807.5 Other purchased gas expenses.

808.1 Gas withdrawn from storage-Debit.

A. This account shall include debitsfor the cost of gas withdrawn fromstorage during the year. Contra creditsfor entries to this account shall bemade to accounts 117.1 through 117.4, oraccount 164.2, Liquefied Natural GasStored, as appropriate. (See the SpecialInstructions to accounts 117.1, 117.2,and 117.3).

B. Withdrawal of gas from storageshall not be netted against deliveriesto storage. (See account 808.2.)

NOTE: Adjustments for gas inventory lossesdue to cumulative inaccuracies in gas meas-urement, or from other causes, shall be en-tered in account 823, Gas Losses. If, however,any adjustment is substantial, the utilitymay, with approval of the Commission, am-ortize the amount of the adjustment to ac-count 823 over future operating periods.

808.2 Gas delivered to storage-Credit.A. This account shall include credits

for the cost of gas delivered to storageduring the year. Contra debits for en-

tries to this account shall be made toaccounts 117.1 through 117.4, or account164.2, Liquefied Natural Gas Stored, asappropriate. (See the Special Instruc-tions to accounts 117.1, 117.2, and 117.3).

809.1 Withdrawals of liquefied naturalgas held for processing—Debit.

A. This account shall include debitsfor the cost of liquefied gas withdrawnduring the year. Contra credits for en-tries to this account shall be made toaccount 164.3, Liquefied Natural GasHeld for Processing.

B. Withdrawals of liquefied naturalgas held for processing shall not be net-ted against deliveries. (See account809.2).

NOTE: Adjustments for gas inventory lossesdue to cumulative inaccuracies in gas meas-urement, or from other causes, shall be en-tered in account 846.1, Gas Losses, in themonth determined, if, however, any adjust-ment is substantial, the utility may, withapproval of the Commission, amortize theamount of the adjustment to account 846.1over future operating periods.

809.2 Deliveries of natural gas forprocessing—Credit.

A. This account shall include creditsfor the cost of gas delivered for proc-essing during the year. Contra debitsfor entries to this account shall bemade to account 164.3, Liquefied Natu-ral Gas Held for Processing.

B. Deliveries of natural gas for proc-essing shall not be netted against with-drawals from processing. (See account809.1).

810 Gas used for compressor stationfuel—Credit.

This account shall include concur-rent credits for charges which are madeto operating expenses for gas consumedfor compressor station fuel from thecommon system gas supply.

811 Gas used for products extraction—Credit.

This account shall include concur-rent credits for charges which are madeto products extraction expenses for gasshrinkage and gas used for fuel in prod-ucts extraction operations of the util-ity and for similar uses of gas of theutility by others processing gas of the



612


utility for extraction of salable prod-ucts.

812 Gas used for other utility oper-ations—Credit.

This account shall include concur-rent credits for charges which are madeto operating expenses or other ac-counts of the gas department for gasconsumed from the common systemsupply for operating and utility pur-poses other than uses for which creditsare includible in any of the foregoingaccounts. (See account 484, Inter-departmental Sales, for gas supplied todepartments other than the gas utilitydepartment.)

813 Other gas supply expenses.A. This account shall include the

cost of labor, materials used and ex-penses incurred in connection with gassupply functions not provided for inany of the above accounts, including,research and development expenses.These accounts are to be used by bothtransmission and distribution compa-nies to account for natural gas storageexpenses. If the utility operates bothtransmission and distribution systems,subaccounts shall be maintainedclassifying the expenses to the trans-mission or distribution function.

B. Include in separate subaccounts:(1) losses on settlements of imbalancereceivables and payables (See Account174 and 242) and losses on replacementof encroachment volumes (See the Spe-cial Instructions to Accounts 117.1,117.2 and 117.3); (2) revaluations of stor-age encroachments; and (3) system gaslosses not associated with storage. Ap-propriate records must be maintainedand readily available that include theamount of losses and associated vol-umes in Dth.


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of under-ground storage operations. Direct su-pervision of specific activities such asturning on and shutting off storagewells, compressor station operations,etc., shall be charged to the appro-priate account. (See operating expenseinstruction 1.)

815 Maps and records.This account shall include the cost of

labor, materials used and expenses in-curred in the preparation and mainte-nance of storage maps and landrecords.

ITEMS

Labor:With respect to land records:1. Supervising.2. Abstracting titles to date for extension

and renewal of leases.3. Adjusting land and well rentals.4. Renewing and extending leases or replac-

ing leases not involving additional consider-ation.

5. Transferring, assigning, pooling, andmerging leases.

6. Delivering rental checks.7. Clerical work in maintaining storage

land and lease records.8. Preparing and maintaining lease expira-

tion calendars.With respect to maps:9. Supervising.10. Preparing maps, well location plats,

etc.11. Reproducing maps (blueprints or photo-

stats).12. Posting and revising maps.13. Surveying deeds, leases, rights-of-way,

well locations, etc., for map revisions.14. Maintaining files of maps and tracings.15. Field checking boundaries, markers,

etc. in connection with preparation of maps.Materials and expenses (general):

16. Reproduction of land and lease recordsand maps (blueprints, photostats, etc.).

17. Drafting materials and supplies.18. Surveying materials and supplies.19. Employees’ transportation and travel

expenses.

816 Wells expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating storage gas wells.

ITEMS

Labor:1. Supervising.2. Testing, bailing, swabbing, blowing, and

gauging storage wells.3. Painting signs, etc.4. Minor upkeep of well roads, fences, etc.5. Turning storage wells on and off.6. Moving cleaning out tools between loca-

tions.7. Driving trucks.

Materials and expenses:8. Gas, gasoline, and oil used in pumping,

bailing, heating, and swabbing.



613


9. Lumber, nails, and other materials usedfor repairing old well roads and fences.

10. Well swabs.11. Employees’ transportation and travel


and other transportation.

817 Lines expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating underground stor-age lines.

ITEMS




5. Building and repairing gate boxes, footbridges, stiles, tool boxes, etc., used in lineoperations, erecting line markers and warn-ing signs, repairing old line roads.






11. Cleaning and repairing tools used instorage lines operations.



repairing gate boxes, foot bridges, stiles, etc.16. Charts.17. Scrubber oil.18. Hand tools.19. Lubricants, wiping rags, waste, etc.20. Freight, express, parcel post, trucking

and other transportation.21. Employees’ transportation and travel

expenses.22. Janitor and washroom supplies.23. Utility services: light, water, telephone.24. Gas used in operations.

818 Compressor station expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating underground stor-age compressor stations.

ITEMS


ment, valves, machinery, gauges, and otherinstruments, including cleaning, wiping, pol-ishing, and lubricating.




6. Inspecting and testing equipment whennot specifically to determine necessity forrepairs or replacement of parts.

7. Pumping drips at the station.8. Taking dew point readings.9. Testing water.10. Cleaning structures housing equipment,

cutting grass and weeds, and minor gradingaround station.

11. Cleaning and repairing hand tools usedin operations.

12. Driving trucks13. Watching during shut downs.14. Clerical work at station.

Materials and expenses:15. Scrubber oil.16. Lubricants, wiping rags, and waste.17. Charts and printed forms, etc.18. Gauge glasses.19. Chemicals to test water.20. Water tests and treatment by other





819 Compressor station fuel andpower.

A. This account shall include thecost of gas, coal, oil, or other fuel, orelectricity, used for the operation ofunderground storage compressor sta-tions, including applicable amounts offuel stock expenses.


NOTE: The cost of fuel, except gas, and re-lated fuel stock expenses shall be charged



614


initially to appropriate fuel accounts carriedin accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of fuel used. Seeaccounts 151 and 152 for the basis of fuelcosts and includible fuel stock expenses.

820 Measuring and regulating stationexpenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating underground stor-age measuring and regulating stations.

ITEMS


charts, reading meters, etc.3. Estimating lost meter registrations, etc.

except gas purchases and sales.4. Calculating gas volumes from meter

charts except gas purchases and sales.5. Adjusting and calibrating measuring

equipment, changing meters, orifice plates,gauges, clocks, etc., not in connection withconstruction or maintenance.

6. Testing gas samples, inspecting and test-ing gas sample tanks and other meter engi-neers equipment, determining specific grav-ity and Btu content of gas.

7. Inspecting and testing equipment notspecifically to determine necessity for re-pairs, including pulsation tests.


preparing reports of operation, etc.10. Attending boilers and operating other


for pressure survey.12. Thawing freeze in gauge pipe.13. Inspecting and pumping drips,


14. Moving equipment, minor structures,etc., not in connection with maintenance orconstruction.Materials and expenses:


16. Lubricants, wiping rags, waste.17. Employees’ transportation and travel




labor, materials used and expenses in-curred in operating equipment used forpurifying, dehydrating, and condi-

tioning of natural gas in connectionwith underground storage operations.

ITEMS

Labor:1. Supervising.2. Changing charts on fuel meters.3. Emptying, cleaning and refilling purifier

boxes.4. Oiling dip sheets of purifier covers.5. Removing spent oxide to refuse piles.6. Revivifying oxide.7. Taking readings of inlet and outlet pres-

sures and temperature.8. Unloading and storing glycol.9. Watching station and equipment.10. Cutting grass and weeds, and minor

grading around equipment and stations.11. Hauling operating employees, mate-

rials, supplies and tools, etc.12. Inspecting and testing equipment, not

specifically to determine necessity for re-pairs or replacement of parts.

13. Lubricating equipment, valves, etc.14. Operating and checking equipment,

valves, instruments, etc.Materials and expenses:

15. Liquid purifying supplies.16. Iron oxide.17. Odorizing materials.18. Charts, printed forms, etc.19. Employees’ transportation and travel

expenses in connection with purification anddehydration operations.

20. Freight, express, parcel post, truckingand other transportation.

21. Gas used in operations.22. Janitor, washroom and landscaping

supplies.23. Lubricants, wiping rags, waste, etc.24. Utility services: light, water, telephone.

822 Exploration and development.

This account shall include expensesof investigation, exploration, and de-velopment of underground storageprojects under consideration whichprove not feasible. There also shall beincluded in this account the net cost ofdrilling nonoperative wells within anexisting storage project. (For Majorcompanies see account 183.2, Other Pre-liminary Survey and InvestigationCharges.)

NOTE: Include in account 352, Wells, thecost of wells which may be drilled within astorage project for purposes of pressure ob-servation rather than for injection or with-drawal of gas.



615


823 Gas losses.This account shall include the

amounts of inventory adjustments rep-resenting the cost of gas lost or unac-counted for in underground storage op-erations due to cumulative inaccura-cies of gas measurements or othercauses. (See the Special Instructions toAccounts 117.1, 117.2 and 117.3). If how-ever, any adjustment is substantial,the utility may, with approval of theCommission, amortize the amount ofthe adjustment to this account over fu-ture operating periods.

824 Other expenses.This account shall include the cost of

labor, material used and expenses in-curred in operating underground stor-age plant, and other underground stor-age operating expenses, not includiblein any of the foregoing accounts, in-cluding research, development, anddemonstration expenses.

825 Storage well royalties.A. This account shall include royal-

ties, rents, and other payments includ-ible in operating expenses for gas wellsand gas land acreage located withinand comprising underground storageprojects of the utility. (See operatingexpense instruction 3.)

B. The records supporting this ac-count shall be so maintained that in-formation will be readily available foreach storage project, of the parties toeach contract, basis of the charges, andlocation of wells to which the royaltiesor rents of each contract relate.


property of others used in connectionwith the storage of gas underground,other than rents and royalties paidwith respect to storage wells and gaslands utilized for the holding of gas inunderground storage. (See operatingexpense instruction 3.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of underground storage facili-

ties. Direct field supervision of specificjobs shall be charged to the appropriatemaintenance account. (See operatingexpense instruction 1.)



832 Maintenance of reservoirs andwells.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of storagewells, the book cost of which is in-cluded in account 352, Wells, and themaintenance of reservoirs, the bookcost of which is included in account352.2, Reservoirs. (See operating ex-pense instruction 2.)

833 Maintenance of lines.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of under-ground storage lines, the book cost ofwhich is includible in account 353,Lines. (See operating expense instruc-tion 2.)

834 Maintenance of compressor sta-tion equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 354, Compressor StationEquipment. (See operating expense in-struction 2.)

835 Maintenance of measuring andregulating station equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 355, Measuring and Reg-ulating Equipment. (See operating ex-pense instruction 2.)



616


836 Maintenance of purificationequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of purifi-cation equipment, the book cost ofwhich is includible in account 356, Pu-rification Equipment. (See operatingexpense instruction 2.)


labor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 357, Other Equipment.(See operating expense instruction 2.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of theoperation of other storage facilities.Direct supervision of specific activitiessuch as operation of gas holders shallbe charged to the appropriate account.(See operating expense instruction 1.)

841 Operation labor and expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating storage holders andother storage equipment.

ITEMS

Labor:1. Supervising.2. Operating, checking, lubricating, clean-

ing, and polishing equipment, machinery,valves, instruments, and other local storageequipment.

3. Reading meters, gauges and other in-struments, changing charts, preparing oper-ating reports, etc.

4. Pumping inlet and outlet holder drips.5. Inspecting and testing equipment when

not specifically for repairs or replacement ofparts.

6. Cleaning structures and housing equip-ment, cutting grass and weeds, and doingminor grading work around structures andequipment.

7. Cleaning and repairing hand tools usedfor operations, etc.

8. Operating steam lines for heating stor-age facilities.Materials and expenses:

9. Charts for pressure gauges and meters,printed forms, etc.

10. Lubricants, wiping rags, waste, etc.11. Janitor and washroom supplies, land-

scaping supplies, etc.12. Employee travel and transportation ex-

penses.13. Freight, express, parcel post, trucking,

and other transportation.14. Utility services: light, water, and tele-

phone.15. Chemicals.16. Refrigerants.17. Research, development, and demonstra-

tion expenses.

842 Rents.

This account shall include rents forproperty of others used or operated inconnection with other storage oper-ations. (See operating expense instruc-tion 3.)

842.1 Fuel.

A. This account shall include thecost of natural gas or other fuel used inthe operation of other storage plant.

B. Concurrent credits offsettingcharges to this account for natural gasused for fuel shall be made to account812, Gas Used for Other Utility Oper-ations—Credit.

842.2 Power.

This account shall include the cost ofelectricity consumed for operation offacilities used in the operation of otherstorage plant.

842.3 Gas Losses.

This account shall include theamounts of inventory adjustments rep-resenting the cost of gas lost or unac-counted for in other storage operationsdue to shrinkage or other causes.

843.1 Maintenance supervision and en-gineering.

This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of other storage facilities. Di-rect field supervision of specific jobsshall be charged to the appropriatemaintenance account. (See operatingexpense instruction 1.)



617


843.2 Maintenance of structures andimprovements.


843.3 Maintenance of gas holders.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of gas hold-ers, the book cost of which is includiblein account 362, Gas Holders. (See oper-ating expense instruction 2.)

843.4 Maintenance of purificationequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of purifi-cation equipment, the book cost ofwhich is includible in account 363, Pu-rification Equipment. (See operatingexpense instruction 2.)

843.5 Maintenance of liquefactionequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of lique-faction equipment, the book cost ofwhich is includible in account 363.1,Liquefaction Equipment. (See operat-ing expense instruction 2.)

843.6 Maintenance of vaporizingequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of vaporiz-ing equipment, the book cost of whichis includible in account 363.2, Vaporiz-ing Equipment. (See operating expenseinstruction 2.)

843.7 Maintenance of compressorequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of compres-sor equipment, the book cost of whichis includible in account 363.3, Compres-sor Equipment. (See operating expenseinstruction 2.)

843.8 Maintenance of measuring andregulating equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of measur-ing and regulating equipment, the bookcost of which is includible in account363.4, Measuring and Regulating Equip-ment. (See operating expense instruc-tion 2.)

843.9 Maintenance of other equip-ment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment the book cost of which is includ-ible in account 363.5, Other Equipment.(See operating expense instruction 2.)

844.1 Operations supervision and engi-neering.

This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of oper-ations of liquefied natural gas facili-ties. Direct supervision of specific ac-tivities shall be charged to the appro-priate operations accounts.

844.2 LNG processing terminal laborand expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating liquefied naturalgas processing equipment.

ITEMS

Labor1. Supervising.2. Operating, checking, lubricating, clean-

ing, and polishing equipment, machinery,valves, instruments, and other processingequipment.


4. Inspecting and testing equipment whennot specifically for repairs or replacement ofparts.

5. Cleaning structures housing equipment,cutting grass and weeds, and doing minorgrading work around structures and equip-ment.


7. Operating offshore facilities such aspiers, docks, loading and unloading arms,water craft, etc.Materials and expenses



618


8. Charts for pressure gauges and meters,printed forms, office supplies, etc.

9. Lubricants, wiping rags, cleaning mate-rials, etc.

10. Janitor and washroom supplies, land-scaping supplies, etc.

11. Employee travel and transportation ex-penses.

12. Freight, express, parcel post, trucking,and other transportation.

13. Utility services: light, water, and tele-phone.

14. Chemicals.15. Refrigerants.16. Small hand tools.

844.3 Liquefaction processing laborand expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating natural gas lique-faction equipment.

ITEMS

Labor1. Supervising.2. Operating, checking, lubricating, clean-

ing, and polishing equipment, machinery,valves, instruments, and other processingequipment.


4. Inspecting and testing equipment whennot specifically for repairs or replacement ofparts.

5. Cleaning structures housing equipment,cutting grass and weeds, and doing minorgrading work around structures and equip-ment.


7. Operating offshore facilities such aspiers, docks, loading and unloading arms,water craft, etc.Materials and expenses

8. Charts for pressure gauges and meters,printed forms, office supplies, etc.

9. Lubricants, wiping rags, cleaning mate-rials, etc.

10. Janitor and washroom supplies, land-scaping supplies, etc.

11. Employee travel and transportation ex-penses.


13. Utility services: light, water, and tele-phone.

14. Chemicals.15. Refrigerants.16. Small hand tools.

844.4 LNG transportation labor andexpenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating LNG transpor-tation equipment.

ITEMS

Labor1. Supervision.2. Operating LNG maritime tankers, LNG

barges, LNG tank trucks and other LNGtransportation equipment.

3. Cleaning and lubricating equipment.4. Inspecting and testing equipment.

Materials and expenses5. Charts, printed forms, office supplies,

etc.6. Dry dock charges.7. Lubricants, wiping rags, cleaning mate-

rials, etc.8. Employee’s transportation travel and

temporary housing expenses.

844.5 Measuring and regulating laborand expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating, measuring andregulating stations in connection withliquefied natural gas operations.

ITEMS

Labor1. Supervising.2. Recording pressures and changing



charts, except gas purchases and sales.5. Adjusting and calibrating measuring

equipment, changing meters, orifice plates,gauges, clocks, etc., not in connection withconstruction or maintenance.

6. Testing gas samples, determining spe-cific gravity and Btu content of gas.



preparing records of operations, etc.10. Attending boilers and operating other



dewatering manholes and pits, inspectingsumps, cleaning pits, blowing meter drips,etc.



619


14. Moving equipment, minor structures,etc., not in connection with maintenance orconstruction.Materials and expenses

15. Charts and printed forms.16. Lubricants, wiping rags, waste.17. Employees’ transportation and travel



844.6 Compressor station labor and ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred, including fuel and power, in op-erating compressor stations in connec-tion with liquefied natural gas oper-ations.

ITEMS

Labor1. Supervising.2. Operating and checking engines, equip-

ment valves, machinery, gauges, and otherinstruments, including cleaning, wiping,polishing, and lubricating.

3. Operating boilers and boiler accessoryequipment, including fuel handling, record-ing fuel used, etc.






11. Driving trucks.12. Watching during shutdowns.13. Clerical work at station.

Materials and expenses14. Scrubber oil.15. Lubricants, wiping rags, waste.16. Charts and printed forms, etc.17. Gauge glasses.18. Chemicals to treat water.19. Water tests and treatment by other





844.7 Communication system ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred in connection with the oper-ation of liquefied natural gas commu-nications facilities, such as radio, tele-phone, microwave and other commu-nication systems, including paymentsto others for communications services.

ITEMS

Labor1. Supervising.2. Operating switchboards, radio equip-

ment, power generators, microwave equip-ment, etc. (except general office switch-boards).

3. Tagging telephone poles.4. Testing and replacing telephone bat-

teries, radio tubes, etc.5. Cutting weeds and grass along telephone

rights-of-way and around structures andequipment.

6. Changing radio frequencies.7. Securing FCC authorization to change

frequencies.8. Taking FCC radio operator tests.9. Transferring mobile radios between vehi-

cles and/or vessels.10. Changing locations of telephones and

other communications equipment not in con-nection with maintenance or construction.

11. Inspecting and testing not specificallyto determine necessity for repairs.

12. Cleaning and lubricating equipment.13. Cleaning structures housing equipment.

Materials and expenses14. Payments to others for communica-

tions services.15. Telephone batteries, radio tubes and

other electronic components.16. Radio crystals and other materials used

in changing radio frequencies.17. Lubricants, wiping rags, and waste.18. Employees’ transportation and travel

expenses.19. Freight, express, parcel post, trucking


844.8 System control and load dis-patching.

This account shall include the cost oflabor and expenses incurred in dis-patching and controlling the supplyand flow of liquefied gas and vaporizedgas prior to introduction of such vapor-ized gas into the utility’s transmissionor distribution system.

ITEMS

Labor



620


1. Supervising.2. Analysis of pressures for irregularities,

as received.3. Collecting pressures by telephone and

radio.4. Controlling mixture of various gases to

maintain proper Btu content.5. Correspondence and records, typing and

maintaining files.6. Controlling inputs and withdrawals of

liquefied gas for processing.7. Instructing field men to increase or de-

crease pressures at regulators.8. Maintaining pressures at compressor

stations, key line junctions and regulatingstations to divide the available gas duringheavy demand periods.

9. Maintaining pressure log sheets.10. Maintaining proper compression ratios

at compressor stations, consistent with eco-nomical operations.

11. Maintaining lowest necessary line pres-sures consistent with satisfactory service.

12. Requesting pressure changes at com-pressor stations, regulating stations, andkey line junctions.

13. Rerouting gas during emergencies andplanned shutdowns.Materials and expenses

14. Consultants’ fees and expenses.15. Meals, traveling and incidental ex-

penses in connection with system load dis-patching.

16. Office supplies, stationery and printedforms.

17. Transportation: company and rental ve-hicles.

18. Utility services: light, water, telephone.

845.1 Fuel.A. This account shall include the

cost of gas or other fuel used for theoperation of liquefied natural gasterminaling and processing facilities,except compressor station fuel.

B. Concurrent credits offsettingcharges to this account for natural gasused for fuel shall be made to account812, Gas Used for Other Utility Oper-ations—Credit.

845.2 Power.This account shall include the cost of

purchased power used in operation ofliquefied natural gas processing facili-ties, except compressor station power.

845.3 Rents.This account shall include rents for

property of others used, occupied or op-erated in connection with liquefiednatural gas processing operations. (Seeoperating expense instruction 3.)

845.4 Demurrage charges.

This account shall include demurragecharges incurred by the utility relativeto LNG shipments received or proc-essed by the utility.

845.5 Wharfage receipts—Credit.

This account shall include wharfagereceipts received or receivable fromLNG shippers or other parties relativeto LNG shipments received or proc-essed by the utility.

845.6 Processing of liquefied or vapor-ized gas by others.

A. This account shall includeamounts paid to others for the process-ing of liquefied or vaporized gas of theutility.

B. Records supporting this accountshall be so maintained that there shallbe readily available for each agree-ment, the name of the other party, Dthof gas delivered to the other party forprocessing and the Dth, of gas receivedback by the utility after processing,points of delivery to and receipt of gasfrom the other party, amount and basisof charges for the processing service.

NOTE: If in connection with any gas deliv-ered to another for processing such otherparty also processes the gas for extraction ofgasoline or other salable products, creditsattributable to the products so extractedshall be made to account 491, Revenues fromNatural Gas Processed by Others, to the endthat amounts recorded in this account shallonly be charges for processing other than forextraction of salable products.

846.1 Gas losses.

This account shall include theamounts of inventory adjustments rep-resenting the cost of gas lost or unac-counted for in liquefied natural gas op-erations due to cumulative inaccura-cies of gas measurements or othercauses. (See paragraph E of account164.3, Liquefied Natural Gas Held forProcessing.) If, however, any adjust-ment is substantial, the utility may,with approval of the Commission, am-ortize the amount of the adjustment tothis account over future operating pe-riods.



621


846.2 Other expenses.

This account shall include the cost oflabor, materials used, and expenses in-curred in operating liquefied naturalgas plant not includible elsewhere.

847.1 Maintenance supervision and en-gineering.

This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of liquefied natural gasterminaling and processing facilities.Direct field supervision of specific jobsshall be charged to the appropriatemaintenance accounts. (See operatingexpense instruction 1.)

847.2 Maintenance of structures andimprovements.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of struc-tures and improvements, the book costof which is included in account 364.2,Structures and Improvements. (See op-erating expense instruction 2.)

847.3 Maintenance of LNG processingterminal equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of LNG ter-minal processing equipment, the bookcost of which is included in account364.3, LNG Processing Terminal Equip-ment. (See operating expense instruc-tion 2.)

847.4 Maintenance of LNG transpor-tation equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of transpor-tation equipment, the book cost ofwhich is included in account 364.4, LNGTransportation Equipment. (See oper-ating expense instruction 2.)

847.5 Maintenance of measuring andregulating equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of measur-ing and regulating equipment, the bookcost of which is included in account364.5, Measuring and Regulating Equip-

ment. (See operating expense instruc-tion 2.)

847.6 Maintenance of compressor sta-tion equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of compres-sor station equipment, the book cost ofwhich is included in account 364.6,Compressor Station Equipment. (Seeoperating expense instruction 2.)

847.7 Maintenance of communicationequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of commu-nication equipment, the book cost ofwhich is included in account 364.7,Communication Equipment. (See oper-ating expense instruction 2.)

847.8 Maintenance of other equip-ment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is in-cluded in account 364.8, Other Equip-ment. (See operating expense instruc-tion 2.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of theoperation of transmission facilities. Di-rect supervision of specific activitiessuch as operation of transmission lines,compressor stations, etc. shall becharged to the appropriate account.(See operating expense instruction 1.)

851 System control and load dispatch-ing.

This account shall include the cost oflabor and expenses incurred in dis-patching and controlling the supplyand flow of gas through the system.

ITEMS

Labor:1. Supervising.2. Analyses of pressures for irregularities,

as received.3. Collecting pressures by telephone and

radio.



622


4. Controlling mixture of various gases tomaintain proper Btu content.

5. Correspondence and records, typing andmaintaining files.

6. Controlling production and storage in-puts and withdrawals.

7. Instructing field men to increase or de-crease pressures at regulators.

8. Maintaining pressures at compressorstations, key line junctions and regulatingstations to divide the available gas duringheavy demand periods.

9. Maintaining pressure log sheets.10. Maintaining proper compression ratios

at compressor stations, consistent with eco-nomical operations.

11. Maintaining lowest necessary line pres-sures consistent with satisfactory service.

12. Maintaining well operation record bywell classification.

13. Requesting pressure changes at com-pressor stations, regulating stations, andkey line junctions.

14. Rerouting gas during emergencies andplanned shut downs.Materials and expenses:

15. Consultants’ fees and expenses.16. Meals, traveling, and incidental ex-

penses in connection with system load dis-patching.

17. Office supplies, stationery and printedforms.

18. Transportation: company and rental ve-hicles.

19. Utility services: light, water, telephone.

852 Communication system expenses.A. This account shall include the

cost of labor, materials used and ex-penses incurred in connection with theoperation of transmission communica-tions facilities, such as radio and tele-phone communications systems, in-cluding payments to others for commu-nications services for transmission andload dispatching operations.

B. Credits shall be made to this ac-count and charges made to production,distribution and other gas utility func-tions and to other utility departmentsfor equitable portions of transmissioncommunications expenses attributableto use of transmission communicationsfacilities other than in connection withgas transmission and load dispatchingoperation.

ITEMS

Labor:1. Supervising.2. Operating switchboards, radio equip-

ment, power generators, microwave equip-ment, etc. (except general office switch-boards.)

3. Tagging telephone poles.4. Testing and replacing telephone bat-

teries, radio tubes, etc.5. Cutting weeds and grass along telephone

rights-of-way and around structures andequipment.

6. Changing radio frequencies.7. Securing FCC authorization to change

frequencies.8. Taking FCC radio operator tests.9. Transferring mobile radios between vehi-

cles.10. Changing locations of telephones and

other communications equipment not in con-nection with maintenance or construction.

11. Inspecting and testing not specificallyto determine necessity for repairs.

12. Cleaning and lubricating equipment.13. Cleaning structures housing equipment.

Materials and expenses:14. Payments to others for communica-

tions services.15. Telephone batteries, radio tubes, etc.16. Radio crystals and other materials used

in changing radio frequencies.17. Lubricants, wiping rags, and waste.18. Employees’ transportation and travel



853 Compressor station labor and ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred (other than fuel and power) inoperating transmission compressor sta-tions.

ITEMS






6. Inspecting and testing equipment notspecifically to determine necessity for re-pairs.





623



12. Driving trucks.13. Watching during shut downs.14. Clerical work at station.

Materials and expenses:15. Scrubber oil.16. Lubricants, wiping rags, and waste.17. Charts and printed forms, etc.18. Gauge glasses.19. Chemicals to treat water.20. Water tests and treatment by other





854 Gas for compressor station fuel.

A. This account shall include thecost of gas used for the operation oftransmission compressor stations.

B. Records shall be maintained toshow the Dth of gas consumed at eachcompressor station, and the cost ofsuch gas.

855 Other fuel and power for compres-sor stations.

A. This account shall include thecost of coal, oil, and other fuel, or elec-tricity, used for the operation of trans-mission compressor stations, includingapplicable amounts of fuel stock ex-penses.


NOTE: The cost of fuel, includible in thisaccount, and related fuel stock expensesshall be charged initially to appropriate fuelaccounts carried in accounts 151, Fuel Stock,and 152, Fuel Stock Expenses Undistributed,and cleared to this account on the basis offuel used. See accounts 151 and 152 for thebasis of fuel costs and includible fuel stockexpenses.

856 Mains expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating transmissionmains.

ITEMS




5. Building and repairing gate boxes, footbridges, stiles, etc., used in line operations,erecting line markers and warning signs, re-pairing old line roads.






11. Cleaning and repairing tools used inmains operations, making tool chests, etc.



repairing gate boxes, foot bridges, stiles, etc.16. Charts.17. Scrubber oil.18. Hand tools.19. Lubricants, wiping rags, waste, etc.20. Freight, express, parcel post, trucking

and other transportation.21. Employees’ transportation and travel

expenses.22. Janitor and washroom supplies.23. Utility services: light, water, telephone.24. Gas used in mains operations.

857 Measuring and regulating stationexpenses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating transmission meas-uring and regulating stations.

ITEMS




charts, except gas purchases and sales.5. Adjusting and calibrating measuring

equipment, changing meters, orifice plates,gauges, clocks, etc. not in connection withconstruction or maintenance.



624


6. Testing gas samples, inspecting and test-ing gas sample tanks and other meter engi-neers’ equipment, determining specific grav-ity and Btu content of gas.



preparing reports of operations, etc.10. Attending boilers and operating other





15. Charts and printed forms.16. Lubricants, wiping rags, waste.17. Employees’ transportation and travel



858 Transmission and compression ofgas by others.

A. This account shall includeamounts paid to others for the trans-mission and compression of gas of theutility.

B. Records supporting this accountshall be so maintained that there shallbe readily available for each agree-ment, name of other party, Dth of gasdelivered to the other party for trans-mission or compression and the Dth ofgas received back by the utility aftertransmission or compression, points ofdelivery to and receipt of gas fromother party, amount and basis ofcharges for the transmission or com-pression service.

NOTE: If in connection with any gas deliv-ered to another for transmission or compres-sion such other party also processes the gasfor extraction of gasoline or other salableproducts, credits attributable to the prod-ucts so extracted shall be made to account491, Revenues from Natural Gas Processed byOthers, to the end that amounts recorded inthis account shall only be charges for trans-portation or compression service.

859 Other expenses.This account shall inlcude the cost of

labor, material used and expenses in-curred in operating transmission sys-tem equipment and other transmissionsystem expenses not includible in anyof the foregoing accounts, including re-search, development, and demonstra-tion expenses.


property of others used, occupied or op-erated in connection with the oper-ation of the transmission system. In-clude herein rentals paid for regulatorsites, railroad crossings, rights-of-way,annual payments to governmental bod-ies and others for use of public or pri-vate lands, and reservations for rights-of-way. (See operating expense instruc-tion 3.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of transmission system facili-ties. Direct field supervision of specificjobs shall be charged to the appropriatemaintenance accounts. (See operatingexpense instruction 1.)



863 Maintenance of mains.This account shall include the cost of

labor, materials used and expenses in-curred in the maintenance of mains,the book cost of which is includible inaccount 367, Mains. (See operating ex-pense instruction 2.)

ITEMS

1. Supervising.2. Electrolysis and leak inspection.3. Installing and removing temporary lines,

when necessitated by maintenance.4. Lamping and watching while making re-

pairs.



625


5. Lowering and changing location of lines,when the same pipe is used.

6. Protecting lines from fires, floods, land-slides, etc.

7. Rocking creek crossings.



865 Maintenance of measuring andregulating station equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 369, Measuring and Reg-ulating Station Equipment. (See oper-ating expense instruction 2.)

866 Maintenance of communicationequipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 370, CommunicationEquipment. (See operating expense in-struction 2.)

867 Maintenance of other equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 371, Other Equipment.(See operating expense instruction 2.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of dis-tribution system operations. Direct su-pervision of specific activities such asload dispatching, mains operation, re-moving and resetting meters, etc.,shall be charged to the appropriate ac-count. (See operating expense instruc-tion 1.)

871 Distribution load dispatching.This account shall include the cost of

labor, materials used and expenses in-curred in dispatching and controllingthe supply and flow of gas through thedistribution system.

ITEMS

Labor:1. Supervising.2. Analyzing pressures for irregularities.3. Collecting pressures by telephone and

radio.4. Controlling mixture of various gases to

maintain proper Btu content.5. Correspondence and records, typing and

maintaining files.6. Controlling gas-make and inputs to dis-

tribution system.7. Maintaining pressures at key points to

divide the available gas during heavy de-mand periods.

8. Maintaining pressure log sheets.9. Maintaining lowest necessary line pres-

sures consistent with satisfactory service.10. Rerouting gas during emergencies and

planned shut downs.Materials and expenses:

11. Consultants’ fees and expenses.12. Meals, traveling, and incidental ex-

penses.13. Office supplies, stationery and printed

forms.14. Transportation: company and rented

vehicles.15. Utility services: light, water, telephone.

872 Compressor station labor and ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred in operating distribution com-pressor stations.

ITEMS






6. Inspecting and testing equipment and in-struments when not specifically to deter-mine necessity for repairs or replacement ofparts.



626



cutting grass and weeds, and doing minorgrading around station.


12. Driving trucks.13. Watching during shut downs.14. Clerical work at station.

Materials and expenses:15. Scrubber oil.16. Lubricants, wiping rags, and waste.17. Charts and printed forms, etc.18. Gauge glasses.19. Chemicals to test water.20. Water tests and treatment by other





873 Compressor station fuel andpower (Major only).

A. This account shall include thecost of gas, coal, oil, or other fuel, orelectricity, used for the operation ofdistribution compressor stations, in-cluding applicable amounts of fuelstock expenses.


NOTE: The cost of fuel, except gas, and re-lated fuel stock expenses shall be chargedinitially to appropriate fuel accounts carriedin accounts 151, Fuel Stock, and 152, FuelStock Expenses Undistributed, and clearedto this account on the basis of fuel used. Seeaccounts 151 and 152 for the basis of fuelcosts and includible fuel stock expenses.

874 Mains and services expenses.This account shall include the cost of

labor, materials used and expenses in-curred in operating distribution systemmains and services.

ITEMS

Labor:1. Supervising.2. Walking or patrolling lines.

3. Attending valves, lubricating valves andother equipment, blowing and cleaning linesand drips, draining water from lines, thawingfreezes.


5. Building and repairing gate boxes, footbridges, stiles, etc. used in distributionmains operations, erecting line markers andwarning signs, etc.


7. Inspecting and testing equipment notspecifically to determine necessity for re-pairs.



10. Locating and inspecting valve boxes ordrip riser boxes, service lines, mains, etc.

11. Cleaning and repairing tools used inmains operations, making tool boxes, etc.

12. Cleaning structures and equipment.13. Driving trucks used in mains and serv-

ice operations.14. Making routine leak survey.15. Oil fogging.

Materials and Expenses:1. Line markers and warning signs.2. Lumber, nails, etc., used in building and

repairing gate boxes (foot bridges, stiles, toolboxes, etc.).

3. Charts and printed forms.4. Scrubber oils.5. Hand tools.6. Lubricants, wiping rags, waste, etc.7. Freight, express, parcel post, trucking

and other transportation.8. Uniforms.9. Employee transportation and travel ex-

penses.10. Janitor and washroom supplies.11. Utility services: light, water, telephone.12. Gas used in mains operation.13. Oil for fogging.

875 Measuring and regulating stationexpenses—General.

This account shall include the cost oflabor, materials used and expenses in-curred in operating general distribu-tion measuring and regulating sta-tions.

ITEMS


charts, reading meters, etc.3. Estimating lost meter registrations, etc.

except purchases and sales.4. Calculating gas volumes from meter

charts, except gas purchases and sales.



627


5. Adjusting and calibrating measuringequipment, changing meters, orifice plates,gauges, clocks, etc.

6. Taking and testing gas samples, inspect-ing and testing valves, regulators, gas sam-ple tanks and other meter engineers’ equip-ment, determining specific gravity and Btucontent of gas.

7. Inspecting and testing equipment and in-struments not specially to determine neces-sity for repairs, including pulsation tests.

8. Cleaning and lubricating equipment.9. Keeping log and other operating records.10. Attending boilers and operating other



dewatering manholes and pits, inspectingsumps, cleaning pits, blowing meter drips,etc.



16. Lubricants, wiping rags, waste.17. Uniforms.18. Employee transportation and travel ex-

penses.19. Freight, express, parcel post, trucking


876 Measuring and regulating stationexpenses—Industrial.

This account shall include the cost oflabor, materials used and expenses in-curred in operating large measuringand regulating stations located onlocal distribution systems to serve spe-cific commercial and industrial cus-tomers.

ITEMS


877 Measuring and regulating stationexpenses—City gate check stations.

This account shall include the cost oflabor, materials used and expenses in-curred in operating measuring and reg-ulating stations used to measure andregulate the receipt of gas at entrypoints to distribution systems.

NOTE: Pipe line companies shall include inthe transmission functional classificationcity gate and main line industrial measuringand regulating stations, except that wherepipe line companies measure deliveries of gasat entry points to their own distribution sys-

tems, they shall have the option, if consist-ently observed, of including such stations ei-ther in the transmission or distributionfunction for accounting purposes.

ITEMS


878 Meter and house regulator ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred in connection with removing,resetting, changing, testing, and serv-icing customer meters and house regu-lators.

ITEMS

Labor:(a) Removing, reinstalling, and changing

or exchanging customer meters and houseregulators:

1. Initiating or terminating service, includ-ing incidental meter reading.

2. Periodic replacement of meters andhouse regulators because of age.

3. Changing or exchanging meters andhouse regulators because of complaints or re-moval for inspection.

4. Resetting meters on existing connec-tions.

5. Handling meters and house regulators toand from customer premises and meter shop.

6. Listing, tagging, and placing meter la-bels, etc., for removed and reset meters.

7. Changing position of meters or houseregulators on the same premises.

8. Installing or removing blank linings.9. Unproductive calls, etc.(b) Turning on and turning off meters, ex-

cept for failures of customers to pay bills:10. Turning on meters, including necessary

time to insure that gas lines are proper touse and that appliances are in usable condi-tion.

11. Turning off meters including time tomake safety precautions.

(c) Other:12. Supervising.13. Clerical work on meter history and as-

sociated equipment record cards, test cards,and reports.

14. Handling and recording meters forstock.

15. Inspecting and testing meters andhouse regulators.

16. Inspecting and adjusting meter testingequipment.

17. Driving trucks used in meter oper-ations.Materials and expenses:

18. Meter locks and seals.19. Lubricants, wiping rags, waste, etc.20. Uniforms.



628



22. Utility services: light, water, telephone,heating.

23. Office supplies, stationery and printing.24. Employees’ transportation expenses.25. Janitor, washroom, first aid supplies,

etc.NOTE: The cost of the first setting of a

meter or house regulator shall be charged toaccount 382, Meter Installations, or account384, House Regulator Installations, as appro-priate.

879 Customer installations expenses.A. This account shall include the

cost of labor, materials used and ex-penses incurred in work on customerpremises other than expenses includ-ible in account 878, Meter and HouseRegulator Expenses, including the costof servicing customer-owned applianceswhen the cost of such work is borne bythe utility.

B. Damage to customer equipment byemployees of the utility whether inci-dental to the work or the result of neg-ligence, shall be charged to the job onwhich the employee was engaged at thetime of damage.

ITEMS

Labor:1. Supervising.2. Altering customer-owned service exten-

sions or meter connections.3. Investigating and correcting pressure

difficulties or stoppages in customer-ownedpiping.

4. Adjusting and repairing burner pilots be-cause of impurities in the gas or failure ofthe distribution system.

5. Oiling or spraying noisy customer me-ters.

6. Investigating and stopping gas leaks oncustomers’ premises caused by defectivemeter, customer-owned piping, or customerappliances.

7. Inspecting new installations to deter-mine that the customers’ equipment and pip-ing are properly installed and connected.

8. Consolidating meter installations, with-out change of size, due to elimination of sep-arate meters for different service classifica-tions.

9. Investigating and adjusting complaintsof service on customers’ premises.

10. Gas load surveys including the inciden-tal preparations and replacement of meters.

11. Unproductive calls.12. Stenographic and clerical work.13. Janitorial services, etc.14. Installing demand or test meters.

15. Inspecting, cleaning, repairing and ad-justing customer-owned appliances for do-mestic, industrial, or commercial use, in-cluding house heating furnaces and otherspace heating appliances, hotel and res-taurant appliances.

16. Replacing defective parts in customer-owned appliances and salvaging reusable ap-pliance parts.Materials and expenses:

17. Lubricants, wiping rags, waste, etc.18. Uniforms.19. Replacement parts for appliances.20. Office supplies, printing and station-

ery.21. Janitor, washroom, first aid supplies,

etc.22. Employees’ transportation and travel

expenses.23. Utility services: light, water, telephone.NOTE: Amounts billed customers for any

work, the cost of which is charged to this ac-count, shall be credited to this account. Anyexcess over costs resulting therefrom shallbe transferred to account 488, MiscellaneousService Revenues.

880 Other expenses.

This account shall include the cost ofdistribution maps and records, dis-tribution office expenses, and the costof labor and materials used andexpenses incurred in distribution sys-tems operations not provided for else-where, including the expenses of oper-ating street lighting systems and re-search, development, and demonstra-tion expenses.


property of others used, occupied or op-erated in connection with the oper-ation of the distribution system. In-clude herein rentals paid for regulatorsites, railroad crossings, rights-of-way,annual payments to governmental bod-ies and others for use of public or pri-vate lands, and reservations for rights-of-way. (See operating expense instruc-tion 3.)


This account shall include the cost oflabor and expenses incurred in the gen-eral supervision and direction of main-tenance of distribution system facili-ties. Direct field supervision of specificjobs shall be charged to the appropriate



629


maintenance accounts. (See operatingexpense instruction 1.)



887 Maintenance of mains.This account shall include the cost of

labor, materials used and expenses in-curred in the maintenance of distribu-tion mains, the book cost of which isincludible in account 376, Mains. (Seeoperating expense instruction 2.)

ITEMS

1. Supervising.2. Trenching, backfilling, and breaking and

restoring pavement in connection with theinstallation of leak or reinforcing clamps.

3. Work performed as the result of munici-pal improvements, such as street widening,sewers, etc., where the gas mains are not re-tired.

4. Municipal inspections relating to main-tenance work.

5. Other work of the following character:a. Locating leaks incident to maintenance.b. Cutting off mains without replacement.

(Minor cuts not retired.)c. Repairing leaking joints.d. Repairing broken mains.e. Repairing leaks on main drip riser or

valve test pipe.f. Bringing main valve box, main drip riser

box, valve test pipe box, or pressure piperoadway box up to grade.

g. Cleaning, repainting, coating, and wrap-ping exposed mains.

h. Repacking main valves.i. Locating and clearing gas main faults.j. Lowering and changing location of

mains.k. Trenching, backfilling, cutting-in or re-

moval of pipe not retired in connection withthe installation of leak clamps, valves, ordrips.

l. Watching and lamping open cuts associ-ated with maintenance.

m. Restoration of permanent pavement inconnection with work chargeable to mainte-nance.

n. Emergency stand-by time associatedwith maintenance.

o. Repairing sewers, drains, walls, etc.,when damaged by maintenance work.

p. Making electrolysis tests to maintainlife of plant.

q. Repairing property of others damaged bymaintenance work.



889 Maintenance of measuring andregulating station equipment—Gen-eral.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 378, Measuring and Reg-ulating Station Equipment—General.(See operating expense instruction 2.)

890 Maintenance of measuring andregulating station equipment—In-dustrial.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 385, Industrial Measur-ing and Regulating Station Equipment.(See operating expense instruction 2.)

891 Maintenance of measuring andregulating station equipment—Citygate check stations.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of equip-ment, the book cost of which is includ-ible in account 379, Measuring and Reg-ulating Station Equipment—City GateCheck Stations. (See operating expenseinstruction 2.)

892 Maintenance of services.This account shall include the cost of

labor, materials used and expenses in-curred in the maintenance of services,the book cost of which is includible inaccount 380, Services. (See operatingexpense instruction 2.)

ITEMS

1. Supervising.2. Testing pipe for leaks and condition of

wrapping.



630


3. Testing for, locating, and clearing trou-ble on company maintained services.

4. Inspecting and testing after repairs havebeen made.

5. Reporting on the condition of gas serv-ices to determine the need for repairs.

6. Making minor repairs and changes.7. Rearranging and changing the location

of services not retired.8. Repairing service valves for reuse.9. Stopping leaks on service pipes and drip

risers.10. Lowering and raising curb boxes to

grade.11. Replacing less than a complete service

when not retired.12. Installing fittings, valves, drips, frost

protection devices, or replacing similaritems on existing services.

13. Cutting and replacing pavement, pave-ment base and sidewalks in connection withmaintenance work.

14. Restoring condition of services dam-aged by fire, storm, leakage, flood, accidentor other casualties.

15. Repairing property of others damagedby maintenance work.

16. Transferring services in connectionwith the installation of new mains.

17. Installing, maintaining, and removingtemporary facilities to prevent the interrup-tion of service.

18. Converting low pressure gas distribu-tion service to medium or high pressure serv-ice.

19. Relocating and rerouting gas servicetemporarily during alterations of buildings.

20. Performing work resulting from munic-ipal improvements, such as street widening,sewers, etc.

21. Replacing service valve box or drip riserbox.

22. Installing, removing or replacing serv-ice valve, drip pot, or drip riser.

23. Repacking service valve.

893 Maintenance of meters and houseregulators.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of metersand house regulators, the book cost ofwhich is includible in accounts 381, Me-ters, and 383, House Regulators. (Seeoperating expense instruction 2.)

ITEMS

1. Inspecting and testing meters and houseregulators on customers’ premises or inshops in connection with repairs.

2. Cleaning, repairing, and painting meters,house regulators, and accessories and equip-ment.

3. Repairing testing equipment.

4. Rebuilding and overhauling meters with-out changing their rated capacities.

5. Resealing house regulators with mer-cury, replacing diaphragms, springs andother defective or worn parts.

6. Replacing or adding any item not con-stituting a retirement unit.

894 Maintenance of other equipment.

This account shall include the cost oflabor, materials used and expenses in-curred in the maintenance of streetlighting equipment and all other dis-tribution system equipment not pro-vided for elsewhere, the book cost ofwhich is includible in accounts 386,Other Property on Customers’ Prem-ises, and 387, Other Equipment. (Seeoperating expense instruction 2.)

901 Supervision.

This account shall include the cost oflabor and expenses incurred in the gen-eral direction and supervision of cus-tomer accounting and collecting ac-tivities. Direct supervision of a specificactivity shall be charged to account902, Meter Reading Expenses, or ac-count 903, Customer Records and Col-lection Expenses, as appropriate. (Seeoperating expense instruction 1.)

902 Meter reading expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in reading customer meters, anddetermining consumption when per-formed by employees engaged in read-ing meters.

ITEMS

Labor:1. Addressing forms for obtaining meter

readings by mail.2. Changing and collecting meter charts

used for billing purposes.3. Inspecting time clocks, checking seals,

etc., when performed by meter readers andthe work represents a minor activity inci-dental to regular meter reading routine.

4. Meter reading—small consumption, andobtaining load information for billing pur-poses. (Exclude and charge to account 878,Meter and House Regulator Expenses, or toaccount 903, Customer Records and Collec-tion Expenses, as applicable, the cost of ob-taining meter readings, first and final, if in-cidental to the operation of removing or re-setting, sealing or locking, and disconnect-ing, or reconnecting meters.)



631


5. Measuring gas—large consumption, in-cluding reading meters, changing charts, cal-culating charts, estimating lost meter reg-istrations, determining specific gravity, etc.,for billing purposes.

6. Computing consumption from meterreader’s book or from reports by mail whendone by employees engaged in reading me-ters.

7. Collecting from prepayment meterswhen incidental to meter reading.

8. Maintaining record of customers’ keys.9. Computing estimated or average con-

sumption when performed by employees en-gaged in reading meters.Materials and expenses:

10. Badges, lamps, and uniforms.11. Demand charts, meter books and bind-

ers and forms for recording readings, but notthe cost of preparation.

12. Postage and supplies used in obtainingmeter readings by mail.

13. Transportation, meals and incidentalexpenses.

903 Customer records and collectionexpenses.

This account shall include the cost oflabor, materials used and expenses in-curred in work on customer applica-tions, contracts, orders, credit inves-tigations, billing and accounting, col-lections and complaints.

ITEMS

Labor:1. Receiving, preparing, recording and han-

dling routine orders for service, disconnec-tions, transfers or meter tests initiated bythe customer, excluding the cost of carryingout such orders, which is chargeable to theaccount appropriate for the work called forby such orders.

2. Investigations of customers’ credit andkeeping of records pertaining thereto, in-cluding records of uncollectible accountswritten off.

3. Receiving, refunding or applying cus-tomer deposits and maintaining customerdeposit, line extension, and other mis-cellaneous records.

4. Checking consumption shown by meterreaders’ reports where incidental to prepara-tion of billing data.

5. Preparing address plates and addressingbills and delinquent notices.

6. Preparing billing data.7. Operating billing and bookkeeping ma-

chines.8. Verifying billing records with contracts

or rate schedules.9. Preparing bills for delivery, and mailing

or delivering bills.

10. Collecting revenues, including collec-tion from prepayment meters unless inciden-tal to meter reading operations.

11. Balancing collections, preparing collec-tions for deposit, and preparing cash reports.

12. Posting collections and other credits orcharges to customer accounts and extendingunpaid balances.

13. Balancing customer accounts and con-trols.

14. Preparing, mailing, or delivering delin-quent notices and preparing reports of delin-quent accounts.

15. Final meter reading of delinquent ac-counts when done by collectors incidental toregular activities.

16. Disconnecting and reconnecting serv-ices because of nonpayment of bills.

17. Receiving, recording, and handling ofinquiries, complaints, and requests for inves-tigations from customers, including prepara-tion of necessary orders, but excluding thecost of carrying out such orders, which ischargeable to the account appropriate forthe work called for by such orders.

18. Statistical and tabulating work on cus-tomer accounts and revenues, but not includ-ing special analyses for sales department,rate department, or other general purposes,unless incidental to regular customer ac-counting routines.

19. Preparing and periodically rewritingmeter reading sheets.

20. Determining consumption and comput-ing estimated or average consumption whenperformed by employees other than those en-gaged in reading meters.Materials and expenses:

21. Address plates and supplies.22. Cash overages and shortages.23. Commissions or fees to others for col-

lecting.24. Payments to credit organizations for

investigations and reports.25. Postage.26. Transportation expenses, including

transportation of customer bills and meterbooks under centralized billing procedure.

27. Transportation, meals, and incidentalexpenses.

28. Bank charges, exchange, and other feesfor cashing and depositing customers’checks.

29. Forms for recording orders for services,removals, etc.

30. Rent of mechanical equipment.NOTE: The cost of work on meter history

and meter location records is chargeable toaccount 878, Meter and House Regulator Ex-penses.

904 Uncollectible accounts.This account shall be charged with

amounts sufficient to provide for lossesfrom uncollectible utility revenues.



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Concurrent credits shall be made to ac-count 144, Accumulated Provision forUncollectible Accounts—Credit. Lossesfrom uncollectible accounts shall becharged to account 144.

905 Miscellaneous customer accountsexpenses.

This account shall include the cost oflabor, materials used and expenses in-curred not provided for in other ac-counts.

ITEMS

Labor:1. General clerical and stenographic work.2. Miscellaneous labor.

Materials and expenses:3. Communication service.4. Miscellaneous office supplies and ex-

penses and stationery and printing otherthan those specifically provided for in ac-counts 902 and 903.

907 Supervision.

This account shall include the cost oflabor and expenses incurred in the gen-eral direction and supervision of cus-tomer service activities, the object ofwhich is to encourage safe, efficientand economical use of the utility’sservice. Direct supervision of a specificactivity within customer service andinformational expense classificationshall be charged to the account where-in the costs of such activity are in-cluded. (See operating expense instruc-tion 1.)

908 Customer assistance expenses.

This account shall include the cost oflabor, materials used, and expenses in-curred in providing instructions or as-sistance to customers, the object ofwhich is to promote safe, efficient andeconomical use of the utility’s service.

ITEMS

Labor:1. Direct supervision of department.2. Processing customer inquiries relating

to the proper use of gas equipment, the re-placement of such equipment and informa-tion related to such equipment.

3. Advice directed to customers as to howthey may achieve the most efficient andsafest use of gas equipment.

4. Demonstrations, exhibits, lectures, andother programs designed to instruct cus-tomers in the safe, economical or efficient

use of gas service, and/or oriented towardconservation of energy.

5. Engineering and technical advice to cus-tomers, the object of which is to promotesafe, efficient and economical use of theutility’s service.Materials and expenses:

6. Supplies and expenses pertaining to dem-onstrations, exhibits, lectures, and otherprograms.

7. Loss in value on equipment and appli-ances used for customer assistance pro-grams.

8. Office supplies and expenses.9. Transportation, meals, and incidental

expenses.NOTE: Do not include in this account ex-

penses that are provided for elsewhere, suchas accounts 416, Costs and Expenses of Mer-chandising, Jobbing and Contract Work, 879,Customer Installations Expenses, and 912,Demonstrating and Selling Expenses.

909 Informational and instructionaladvertising expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in activities which primarilyconvey information as to what the util-ity urges or suggests customers shoulddo in utilizing gas service to protecthealth and safety, to encourage envi-ronmental protection, to utilize theirgas equipment safely and economi-cally, or to conserve natural gas.

ITEMS

Labor:1. Direct supervision of informational ac-

tivities.2. Preparing informational materials for

newspapers, periodicals, billboards, etc., andpreparing and conducting informational mo-tion pictures, radio and television programs.

3. Preparing informational booklets, bul-letins, etc., used in direct mailings.

4. Preparing informational window andother displays.

5. Employing agencies, selecting media andconducting negotiations in connection withthe placement and subject matter of infor-mation programs.Materials and expenses:

6. Use of newspapers, periodicals, bill-boards, radio, etc., for informational pur-poses.

7. Postage on direct mailings to customersexclusive of postage related to billings.

8. Printing of informational booklets,dodgers, bulletins, etc.

9. Supplies and expenses in preparing infor-mational materials by the utility.

10. Office supplies and expenses.



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NOTE A: Exclude from this account andcharge to account 930.2, Miscellaneous Gen-eral Expenses, the cost of publication ofstockholder reports, dividend notices, bondredemption notices, financial statements,and other notices of a general corporatecharacter. Exclude also all expenses of a pro-motional, institutional, goodwill or politicalnature, which are includible in such ac-counts as 913, Advertising Expenses, 930.1,General Advertising Expenses, and 426.4, Ex-penditures for Certain Civic, Political andRelated Activities.

NOTE B: Entries relating to informationaladvertising included in this account shallcontain or refer to supporting documentswhich identify the specific advertising mes-sage. If references are used, copies of the ad-vertising message shall be readily available.

910 Miscellaneous customer serviceand informational expenses.

This account shall include the cost oflabor, materials used and expenses in-curred in connection with customerservice and informational activitieswhich are not includible in other cus-tomer information expense accounts.

ITEMS

Labor:1. General clerical and stenographic work

not assigned to specific customer service andinformation programs.

2. Miscellaneous labor.Materials and expenses:

3. Communication service.4. Printing, postage and office supplies ex-

penses.

911 Supervision.

This account shall include the cost oflabor and expenses incurred in the gen-eral direction and supervision of salesactivities, except merchandising. Di-rect supervision of a specific activity,such as demonstrating, selling, or ad-vertising shall be charged to the ac-count wherein the costs of such activ-ity are included. (See operating ex-pense instruction 1.)

912 Demonstrating and selling ex-penses.

This account shall include the cost oflabor, materials used and expenses in-curred in promotional, demonstrating,and selling activities, except by mer-chandising, the object of which is topromote or retain the use of utility

services by present and prospectivecustomers.

ITEMS

Labor:1. Demonstrating uses of utility services.2. Conducting cooking schools, preparing

recipes, and related home service activities.3. Exhibitions, displays, lectures, and other

programs designed to promote use of utilityservices.

4. Experimental and development work inconnection with new and improved appli-ances and equipment, prior to general publicacceptance.

5. Solicitation of new customers or of addi-tional business from old customers, includ-ing commissions paid employees.

6. Engineering and technical advice topresent or prospective customers in connec-tion with promoting or retaining the use ofutility services.

7. Special customer canvasses when theirprimary purpose is the retention of businessor the promotion of new business.Materials and expenses:

8. Supplies and expenses pertaining to dem-onstration, and experimental and develop-ment activities.

9. Booth and temporary space rental.10. Loss in value on equipment and appli-

ances used for demonstration purposes.11. Transportation, meals, and incidental

expenses.

913 Advertising expenses.This account shall include the cost of

labor, materials used and expenses in-curred in advertising designed to pro-mote or retain the use of utility serv-ice, except advertising the sale of mer-chandise by the utility.

ITEMS

Labor:1. Direct supervision of department.2. Preparing advertising material for news-

papers, periodicals, billboards, etc., and pre-paring and conducting motion pictures, radioand television programs.

3. Preparing booklets, bulletins, etc., usedin direct mail advertising.

4. Preparing window and other displays.5. Clerical and stenographic work.6. Investigating advertising agencies and

media and conducting negotiations in con-nection with the placement and subject mat-ter of sales advertising.Materials and expenses:

7. Advertising in newspapers, periodicals,billboards, radio, etc., for sales promotionpurposes, but not including institutional orgoodwill advertising includible in account930.1, General Advertising Expenses.



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8. Materials and services given as prizes orotherwise in connection with canning, orcooking contests, bazaars, etc., in order topublicize and promote the use of utility serv-ices.

9. Fees and expenses of advertising agen-cies and commercial artists.

10. Novelties for general distribution.11. Postage on direct mail advertising.12. Premiums distributed generally, such

as recipe books, etc., when not offered as in-ducement to purchase appliances.

13. Printing booklets, dodgers, bulletins,etc.

14. Supplies and expenses in preparing ad-vertising material.

15. Office supplies and expenses.NOTE A: The cost of advertisements which

set forth the value or advantages of utilityservice without reference to specific appli-ances, or, if reference is made to appliances,invites the reader to purchase appliancesfrom his dealer, or refer to appliances notcarried for sale by the utility, shall be con-sidered sales promotion advertising andcharged to this account. However, advertise-ments which are limited to specific makes ofappliances sold by the utility and prices,terms, etc., thereof, without referring to thevalue or advantages of utility service, shallbe considered as merchandise advertisingand the cost shall be charged to Costs andExpenses of Merchandising, Jobbing andContract Work, accounts 416.

NOTE B: Advertisements which substan-tially mention or refer to the value or advan-tages of utility service, together with spe-cific reference to makes of appliances sold bythe utility and the price, terms, etc., thereof,and designed for the joint purpose of increas-ing the use of utility service and the sales ofappliances, shall be considered as a combina-tion advertisement and the costs shall bedistributed between this account and ac-count 416 on the basis of space, time, orother proportional factors.

NOTE C: Exclude from this account andcharge to account 930.2, Miscellaneous Gen-eral Expenses, the cost of publication ofstockholder reports, dividend notices, bondredemption notices, financial statements,and other notices of a general corporatecharacter. Exclude also all institutional orgoodwill advertising. (See account 930.1, Gen-eral Advertising Expenses.)

914—915 [Reserved]

916 Miscellaneous sales expenses.This account shall include the cost of

labor, materials used and expenses in-curred in connection with sales activi-ties, except merchandising, which are

not includible in other sales expenseaccounts.

ITEMS

Labor:1. General clerical and stenographic work

not assigned to specific functions.2. Special analysis of customer accounts

and other statistical work for sales purposesnot a part of the regular customer account-ing and billing routine.

3. Miscellaneous labor.Materials and expenses:

4. Communication service.5. Printing, postage, and office supplies and

expenses applicable to sales activities, ex-cept those chargeable to account 913, Adver-tising Expenses.

920 Administrative and general sala-ries.

A. This account shall include thecompensation (salaries, bonuses, andother consideration for services, butnot including directors’ fees) of offi-cers, executives, and other employeesof the utility properly chargeable toutility operations and not chargeabledirectly to a particular operating func-tion.

B. This account may be subdivided inaccordance with a classification appro-priate to the departmental or otherfunctional organization of the utility.

921 Office supplies and expenses.A. This account shall include office

supplies and expenses incurred in con-nection with the general administra-tion of the utility’s operations whichare assignable to specific administra-tive or general departments and arenot specifically provided for in otheraccounts. This includes the expenses ofthe various administrative and generaldepartments, the salaries and wages ofwhich are includible in account 920.

B. This account may be subdivided inaccordance with a classification appro-priate to the departmental or otherfunctional organization of the utility.

NOTE: Office expenses which are clearly ap-plicable to any group of operating expensesother than the administrative and generalgroup shall be included in the appropriateaccount in such group. Further, general ex-penses which apply to the utility as a wholerather than to a particular administrativefunction shall be included in account 930.2,Miscellaneous General Expenses.



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ITEMS

1. Automobile service, including chargesthrough clearing account.

2. Bank messenger and service charges.3. Books, periodicals, bulletins and sub-

scriptions to newspapers, newsletters, taxservices, etc.

4. Building service expenses for customeraccounts, sales, and administrative and gen-eral purposes.

5. Communication service expenses.6. Cost of individual items of office equip-

ment used by general departments which areof small value or short life.

7. Membership fees and dues in trade, tech-nical, and professional associations paid by autility for employees. (Company member-ships are includible in account 930.2.)

8. Office supplies and expenses.9. Payment of court costs, witness fees, and

other expenses of legal department.10. Postage, printing and stationery.11. Meals, traveling and incidental ex-

penses.

922 Administrative expenses trans-ferred—Credit.

This account shall be credited withadministrative expenses recorded in ac-counts 920 and 921 which are trans-ferred to construction costs or to non-utility accounts. (See gas plant in-struction 4.)

923 Outside services employed.A. This account shall include the fees

and expenses of professional consult-ants and others for general serviceswhich are not applicable to a particu-lar operating function or to other ac-counts. It shall include also the payand expenses of persons engaged for aspecial or temporary administrative orgeneral purpose in circumstanceswhere the person so engaged is not con-sidered as an employee of the utility.

B. This account shall be so main-tained as to permit ready summari-zation according to the nature of serv-ice and the person furnishing the same.

ITEMS

1. Fees, pay and expenses of accountantsand auditors, actuaries, appraisers, attor-neys, engineering consultants, managementconsultants, negotiators, public relationscounsel, tax consultants, etc.

2. Supervision fees and expenses paid undercontracts for general management services.

NOTE: Do not include inspection and bro-kerage fees and commissions chargeable toother accounts or fees and expenses in con-

nection with security issues which are in-cludible in the expenses of issuing securities.

924 Property insurance.A. This account shall include the

cost of insurance or reserve accruals toprotect the utility against losses anddamages to owned or leased propertyused in its utility operations. It shallinclude also the cost of labor and relat-ed supplies and expenses incurred inproperty insurance activities.

B. Recoveries from insurance compa-nies or others for property damagesshall be credited to the accountcharged with the cost of the damage. Ifthe damaged property has been retired,the credit shall be to the appropriateaccount for accumulated provision fordepreciation.

C. Records shall be kept so as toshow the amount of coverage for eachclass of insurance carried, the propertycovered, and the applicable premiums.Any dividends distributed by mutualinsurance companies shall be creditedto the accounts to which the insurancepremiums were charged.

ITEMS

1. Premiums payable to insurance compa-nies for fire, storm, burglary, boiler explo-sion, lightning, fidelity, riot, and similar in-surance.

2. Amounts credited to account 228.1, Accu-mulated Provision for Property Insurance;for similar protection.

3. Special costs incurred in procuring in-surance.

4. Insurance inspection service.5. Insurance counsel, brokerage fees, and

expenses.NOTE A: The cost of insurance or reserve

accruals capitalized shall be charged to con-struction either directly or by transfer toconstruction work orders from this account.

NOTE B: The cost of insurance or reserveaccruals for the following classes of propertyshall be charged as indicated.

(1) Materials and supplies and stores equip-ment, to account 163, Stores Expense Undis-tributed or appropriate materials account.

(2) Transportation and other general equip-ment to appropriate clearing accounts thatmay be maintained.

(3) Gas plant leased to others, to account413, Expenses of Gas Plant Leased to Others.

(4) Nonutility property, to the appropriatenonutility income account.

(5) Merchandise and jobbing property, toaccount 416, Costs and Expenses of Mer-chandising, Jobbing and Contract Work.



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NOTE C: The cost of labor and related sup-plies and expenses of administrative and gen-eral employees, who are only incidentallyengaged in property insurance work, may beincluded in accounts 920 and 921, as appro-priate.

925 Injuries and damages.A. This account shall include the

cost of insurance or reserve accruals toprotect the utility against injuries anddamages claims of employees or others,losses of such character not covered byinsurance, and expenses incurred insettlement of injuries and damagesclaims. It shall also include the cost oflabor and related supplies and expensesincurred in injuries and damages ac-tivities.

B. Reimbursements from insurancecompanies or others for expensescharged hereto on account of injuriesand damages and insurance dividendsor refunds shall be credited to this ac-count.

ITEMS

1. Premiums payable to insurance compa-nies for protection against claims from inju-ries and damages by employees or others,such as public liability, property damages,casualty, employee liability, etc., andamounts credited to account 228.2, Accumu-lated Provision for Injuries and Damages; forsimilar protection.

2. Losses not covered by insurance or re-serve accruals on account of injuries ordeaths to employees or others and damagesto the property of others.

3. Fees and expenses of claim investigators.4. Payment of awards to claimants for

court costs and attorneys’ services.5. Medical and hospital service and ex-

penses for employees as the result of occupa-tional injuries, or resulting from claims ofothers.

6. Compensation payments under work-men’s compensation laws.

7. Compensation paid while incapacitatedas the result of occupational injuries. (SeeNote A.)

8. Cost of safety, accident prevention andsimilar educational activities.

NOTE A: Payments to or in behalf of em-ployees for accident or death benefits, hos-pital expenses, medical supplies or for sala-ries while incapacitated for service or onleave of absence beyond periods normally al-lowed, when not the result of occupationalinjuries, shall be charged to account 926, Em-ployee Pensions and Benefits. (See also NoteB of account 926.)

NOTE B: The cost of injuries and damagesor reserve accruals capitalized shall be

charged to construction directly or by trans-fer to construction work orders from this ac-count.

NOTE C: Exclude herefrom the time and ex-penses of employees (except those engaged ininjuries and damages activities) spent in at-tendance at safety and accident preventioneducational meetings, if occurring duringthe regular work period.

NOTE D: The cost of labor and related sup-plies and expenses of administrative and gen-eral employees, who are only incidentallyengaged in injuries and damages activities,may be included in accounts 920 and 921, asappropriate.926 Employee pensions and benefits.

A. This account shall include pen-sions paid to or on behalf of retired em-ployees, or accruals to provide for pen-sions, or payments for the purchase ofannuities for this purpose, when theutility has definitely, by contract,committed itself to a pension planunder which the pension funds are ir-revocably devoted to pension purposes,and payments for employee accident,sickness, hospital, and death benefits,or insurance therefor. Include, also, ex-penses incurred in medical, educationalor recreational activities for the bene-fit of employees, and administrativeexpenses in connection with employeepensions and benefits.

B. The utility shall maintain a com-plete record of accruals or paymentsfor pensions and be prepared to furnishfull information to the Commission ofthe plan under which it has created orproposes to create a pension fund and acopy of the declaration of trust or reso-lution under which the pension plan isestablished.

C. There shall be credited to this ac-count the portion of pensions and bene-fits expenses which is applicable tononutility operations or which ischarged to construction unless suchamounts are distributed directly to theaccounts involved and are not includedherein in the first instance.

D. Records in support of this accountshall be so kept that the total pensionsexpense, the total benefits expense, theadministrative expenses included here-in, and the amounts of pensions andbenefits expenses transferred to con-struction or other accounts will bereadily available.



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ITEMS

1. Payment of pensions under a nonaccrualor nonfunded basis.

2. Accruals for or payments to pensionfunds or to insurance companies for pensionpurposes.

3. Group and life insurance premiums(credit dividends received).

4. Payments for medical and hospital serv-ices and expenses of employees when not theresult of occupational injuries.

5. Payments for accident, sickness, hos-pital, and death benefits or insurance.

6. Payments to employees incapacitatedfor service or on leave of absence beyond pe-riods normally allowed, when not the resultof occupational injuries, or in excess of stat-utory awards.

7. Expenses in connection with educationaland recreational activities for the benefit ofemployees.

NOTE A: The cost of labor and related sup-plies and expenses of administrative and gen-eral employees who are only incidentally en-gaged in employee pension and benefit ac-tivities, may be included in accounts 920 and921, as appropriate.

NOTE B: Salaries paid to employees duringperiods of nonoccupational sickness may becharged to the appropriate labor accountrather than to employee benefits.

927 Franchise requirements.

A. This account shall include pay-ments to municipal or other govern-mental authorities, and the cost of ma-terials, supplies and services furnishedsuch authorities without reimburse-ment in compliance with franchise, or-dinance, or similar requirements; pro-vided, however, that the utility maycharge to this account at regular tariffrates, instead of cost, utility servicefurnished without charge under provi-sions of franchises.

B. When no direct outlay is involved,concurrent credit for such chargesshall be made to account 929, DuplicateCharges—Cr.

C. The account shall be maintainedso as to readily reflect the amounts ofcash outlays, utility service suppliedwithout charge, and other items fur-nished without charge.

NOTE A: Franchise taxes shall not becharged to this account but to account 408.1,Taxes Other Than Income Taxes, Utility Op-erating Income.

NOTE B: Any amount paid as initial consid-eration for a franchise running for more than

one year shall be charged to account 302,Franchises and Consents.

928 Regulatory commission expenses.

A. This account shall include all ex-penses (except pay of regular employ-ees only incidentally engaged in suchwork) properly includible in utility op-erating expenses, incurred by the util-ity in connection with formal cases be-fore regulatory commissions, or otherregulatory bodies, or cases in whichsuch a body is a party, including pay-ments made to a regulatory commis-sion for fees assessed against the util-ity for pay and expenses of such com-mission, its officers, agents, and em-ployees.

B. Amounts of regulatory commis-sion expenses which by approval or di-rection of the Commission are to bespread over future periods shall becharged to account 186, MiscellaneousDeferred Debits, and amortized bycharges to this account.

C. The utility shall be prepared toshow the cost of each formal case.

ITEMS

1. Salaries, fees, retainers, and expenses ofcounsel, solicitors, attorneys, accountants,engineers, clerks, attendants, witnesses, andothers engaged in the prosecution of, or de-fense against petitions or complaints pre-sented to regulatory bodies, or in the valu-ation of property owned or used by the util-ity in connection with such cases.

2. Office supplies and expenses, paymentsto public service or other regulatory com-missions, stationery and printing, travelingexpenses, and other expenses incurred di-rectly in connection with formal cases beforeregulatory commissions.

3. All application fees except those involv-ing construction certificate applicationswhich have been approved. (See Gas PlantInstruction 16.)

NOTE A: Exclude from this account and in-clude in other appropriate operating expenseaccounts, expenses incurred in the improve-ment of service, additional inspection, orrendering reports, which are made necessaryby the rules and regulations, or orders, ofregulatory bodies.

NOTE B: Do not include in this accountamounts includible in account 302, Fran-chises and Consents, account 181,Unamortized Debt Expense, or account 214,Capital Stock Expense.



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929 Duplicate charges—Credit.This account shall include concur-

rent credits for charges which may bemade to operating expenses or to otheraccounts for the use of utility servicefrom its own supply. Include, also, off-setting credits for any other chargesmade to operating expenses for whichthere is no direct money outlay.

930.1 General advertising expenses.This account shall include the cost of

labor, materials used, and expenses in-curred in advertising and related ac-tivities, the cost of which by their con-tent and purpose are not provided forelsewhere.

ITEMS

Labor:1. Supervision.2. Preparing advertising material for news-

papers, periodicals, billboards, etc., and pre-paring or conducting motion pictures, radioand television programs.

3. Preparing booklets, bulletins, etc., usedin direct mail advertising.

4. Preparing window and other displays.5. Clerical and stenographic work.6. Investigating and employing advertising

agencies, selecting media and conducting ne-gotiations in connection with the placementand subject matter of advertising.Materials and expenses:

7. Advertising in newspapers, periodicals,billboards, radio, etc.

8. Advertising matter such as posters, bul-letins, booklets and related items.

9. Fees and expenses of advertising agen-cies and commercial artists.

10. Postage and direct mail advertising.11. Printing of booklets, dodgers, bulletins,

etc.12. Supplies and expenses in preparing ad-

vertising materials.13. Office supplies and expenses.

NOTE A: Properly includible in this ac-count is the cost of advertising activities ona local or national basis of a goodwill or in-stitutional nature, which is primarily de-signed to improve the image of the utility orthe industry, including advertisementswhich inform the public concerning mattersaffecting the company’s operations, such as,the cost of providing service, the company’sefforts to improve the quality of service, thecompany’s efforts to improve and protect theenvironment, etc. Entries relating to adver-tising included in this account shall containor refer to supporting documents which iden-tify the specific advertising message. If ref-erences are used, copies of the advertisingmessage shall be readily available.

NOTE B: Exclude from this account and in-clude in account 426.4. Expenditures for Cer-tain Civic, Political and Related Activities,expenses for advertising activities, which aredesigned to solicit public support or the sup-port of public officials in matters of a politi-cal nature.

930.2 Miscellaneous general expenses.

This account shall include the cost of laborand expenses incurred in connection with thegeneral management of the utility not pro-vided for elsewhere.

ITEMS

Labor:1. Miscellaneous labor not elsewhere pro-

vided for:Expenses:

2. Industry Association dues for companymemberships.

3. Contributions for conventions and meet-ings of the industry.

4. Research, development, and demonstra-tion expenses not charged to other operationand maintenance expense accounts on afunctional basis.

5. Communication service not chargeableto other accounts.

6. Trustee, registrar, and transfer agentfees and expenses.

7. Stockholders meeting expenses.8. Dividend and other financial notices.9. Printing and mailing dividend checks.10. Directors’ fees and expenses.11. Publishing and distributing annual re-

ports to stockholders.12. Public notices of financial, operating,

and other data required by regulatory stat-utes, not including, however, notices re-quired in connection with security issues oracquisitions of property.

931 Rents.This account shall include rents

properly includible in utility operatingexpenses for the property of othersused, occupied, or operated in connec-tion with the customer accounts, cus-tomer service and informational, sales,and general and administrative func-tions of the utility. (See operating ex-pense instruction 3.)

932 Maintenance of general plant.A. This account shall include the

cost assignable to customer accounts,sales and administrative and generalfunctions of labor, materials used andexpenses incurred in the maintenanceof property, the book cost of which isincludible in account 390, Structures



639

Federal Energy Regulatory Commission § 225.2

and Improvements, account 391, OfficeFurniture and Equipment, account 397,Communication Equipment, and ac-count 398, Miscellaneous Equipment.(See operating expense instruction 2.)

B. Maintenance expenses on officefurniture and equipment used else-where than in general, commercial andsales offices shall be charged to the fol-lowing accounts:Manufactured Gas Production, accounts 708,

742Natural Gas Production and Gathering, ac-

count 769Natural Gas ProductionExtraction, account 791Underground Storage, account 837Local Storage, account 846.2Transmission Expenses, account 867Distribution Expenses, account 894Merchandising and Jobbing, account 416Garage, Shops, etc.—appropriate clearing ac-

count, if used.

NOTE: Maintenance of plant included inother general plant equipment accountsshall be included herein unless charged toclearing accounts or to a particular func-tional maintenance expense indicated by theuse of the equipment.

PART 204 [RESERVED]

NOTE: For the Uniform System of Accountsfor Natural Gas Companies subject to theNatural Gas Act, see part 201 of this sub-chapter. (Order 390, 49 FR 32526, Aug. 14, 1984;50 FR 5745, Feb. 12, 1985)

PART 225—PRESERVATION OFRECORDS OF NATURAL GASCOMPANIES

Sec.225.1 Promulgation.225.2 General instructions.225.3 Schedule of records and periods of re-

tention.AUTHORITY: Department of Energy Organi-

zation Act, 42 U.S.C. 7101–7352 (1982); E.O.12009, 3 CFR 142 (1978); Natural Gas Act, 15U.S.C. 717–717w (1982); Natural Gas PolicyAct, 15 U.S.C. 3301–3432 (1982); Federal PowerAct, 16 U.S.C. 792–828c (1982).

§ 225.1 Promulgation.(a) This part is prescribed and pro-

mulgated as the regulations governingthe preservation of records by naturalgas companies subject to the jurisdic-

tion of the Commission, to the extentand in the manner set forth therein;

(b) This part shall, as to all naturalgas companies now subject to the juris-diction of the Commission, become ef-fective as herein revised on January 1,1972. As to any natural gas companywhich may hereafter become subject tothe jurisdiction of the Commission,this part shall become effective as ofthedate when such natural gas com-pany becomes subject to the jurisdic-tion of the Commission.[Order 450, 37 FR 6304, Mar. 28, 1972]

§ 225.2 General instructions.(a) Scope of this part. (1) The regula-

tions in this part apply to all books ofaccount and other records prepared byor on behalf of the natural gas com-pany. See subsection 64 of the schedulefor those records which come into pos-session of the natural gas company inconnection with the acquisition ofproperty, such as purchase, consolida-tion, merger, etc.

(2) The regulations in this part shallnot be construed as excusing compli-ance with any other lawful require-ment for the preservation of records forperiods longer than those prescribedherein.

(3) Unless otherwise specified in theschedule (§ 225.3), duplicate copies ofrecords may be destroyed at any time:Provided, however, That such duplicatecopies contain no significant informa-tion not shown on the originals.

(4) Records other than those listed inthe schedule may be destroyed at theoption of the natural gas company:Provided, however, That records whichare used in lieu of those listed shall bepreserved for the periods prescribed forthe records used for substantially simi-lar purposes. And, provided further,That retention of records pertaining toadded services, functions, plant, etc.,the establishment of which cannot bepresently foreseen, shall conform tothe principles embodied herein.

(5) Notwithstanding the provisions ofthe Records Retention Schedule, theCommission may, upon the request ofthe company, authorize a shorter pe-riod of retention for any record listedtherein upon a showing by the com-pany that preservation of such recordfor a longer period is not necessary or





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“Starting in 2020, $0.5 million per year is included for remediation inpipeline segments that fall within the new rule requirements.”

Please provide a spreadsheet (with calculations intact) of how the O&Massociated with the expansion of integrity assessments in MediumConsequence Areas was determined, with specific line items detailing theindividual appropriations that results in the provided summation of$500,000.

Answer: See file attachment “U-20642 STDG-1.09 MCA Remediation”

Attachments: U-20642 STDG-1.09 MCA Remediation



Case No.: U‐20642Discovery Request: STDG‐1.9Respondent: M. C. JohnsonFile Attachment: U‐20642 STDG‐1.09 MCA Remediation ($ millions)

MCA Remediation O&M expenses2020

Projected2021

Projected


Labor (Internal) $ 0.1 $ 0.1 0.1$ Material $ 0.1 $ 0.1 0.1$ Contract Services $ 0.3 $ 0.3 0.3$ Other (Non ‐ Labor) $ 0.1 $ 0.1 0.1$

MCA Remediation ‐ Total 0.5$ 0.5$ 0.5$

U‐20642 STDG‐1.09 MCA Remediation O&M





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Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “Northeast Belt 24” ILI Expansion” that states:

Please provide a spreadsheet (with calculations intact) of how eachexpense (Labor, Material, Contract Services, Overheads, Contingency, andAFUDC) was determined with specific line items that result in the providedsummations for each time period provided above.

Answer: Please refer to file attachment “U-20642 STDG-6.5 to 6.8 Pipeline IntegrityProject Costs”.

Attachments: U-20642 STDG-6.5 to 6.8 Pipeline Integrity Project Costs





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Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “Southfield 24” Pipe Replacement” that states:


Answer: Please refer to discovery question STDG-6.5






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Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “South Grand Rapids 22” ILI Expansion” thatstates:








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Question: Regarding Exhibit A-12, Schedule B5.3 of Company witness Alida D.Sandberg describing the “Menominee-Powers 16” ILI Expansion” thatstates:






Case No.: U‐20642Discover Request: STDG ‐ 6.5 to STDG ‐ 6.8Respondent: A. D. SandbergFile Attachment: U‐20642 STDG‐6.5 ‐ 6.8 Pipeline Integrity Projects from Top 25($s)

Projected Annual Cost: Project Cost BreakdownTotal Project Cost

2019‐20212019 2020 2021

Labor (Internal) $ 183,079 $ 147,921 $ 35,158 ‐$ Material $ 561,801 $ 561,801 $ ‐ ‐$ Contract Services $ 6,659,725 $ 4,480,925 $ 2,178,800 ‐$ Overheads $ 386,196 $ 198,080 $ 188,116 ‐$ Contingency $ ‐ $ ‐ $ ‐ ‐$ AFUDC $ ‐ $ ‐ $ ‐ ‐$ Total $ 7,790,801 $ 5,388,727 $ 2,402,074 $ ‐

Projected Test Year

Project Cost BreakdownTotal Project Cost01/01/2019 ‐ 09/30/2021

20199 mos ending09/30/2020

12 mos ending09/30/2021

Labor (Internal) $ 183,079 $ 147,921 $ 35,158 $ ‐ Material $ 561,801 $ 561,801 $ ‐ $ ‐ Contract Services $ 6,659,725 $ 4,480,925 $ 2,178,800 $ ‐ Overheads $ 386,196 $ 198,080 $ 188,116 $ ‐ Contingency $ ‐ $ ‐ $ ‐ $ ‐ AFUDC $ ‐ $ ‐ $ ‐ $ ‐ Total $ 7,790,801 $ 5,388,727 $ 2,402,074 $ ‐


2019‐20212019 2020 2021

Labor (Internal) $ 200,000 $ ‐ $ ‐ 200,000$ Material $ 200,000 $ ‐ $ ‐ 200,000$ Contract Services $ 3,570,000 $ ‐ $ ‐ 3,570,000$ Overheads $ 30,000 $ ‐ $ ‐ 30,000$ Contingency $ ‐ $ ‐ $ ‐ ‐$ AFUDC $ ‐ $ ‐ $ ‐ ‐$ Total $ 4,000,000 $ ‐ $ ‐ $ 4,000,000

Projected Test Year


20199 mos ending09/30/2020

12 mos ending09/30/2021

Labor (Internal) $ 200,000 $ ‐ $ ‐ $ 200,000 Material $ 200,000 $ ‐ $ ‐ $ 200,000 Contract Services $ 3,570,000 $ ‐ $ ‐ $ 3,570,000 Overheads $ 30,000 $ ‐ $ ‐ $ 30,000 Contingency $ ‐ $ ‐ $ ‐ $ ‐ AFUDC $ ‐ $ ‐ $ ‐ $ ‐ Total $ 4,000,000 $ ‐ $ ‐ $ 4,000,000

Projected Bridge and Test Year Cost:

Projected Bridge Year

U‐20642 STDG‐6.5 Northeast Belt 24" ILI Expansion

U‐20642 STDG‐6.6 Southfield 24" Pipe Replacement

Projected Bridge YearProjected Bridge and Test Year

Cost:




2019‐20212019 2020 2021

Labor (Internal) $ 100,000 $ ‐ $ 20,000 80,000$ Material $ 1,000,000 $ ‐ $ ‐ 1,000,000$ Contract Services $ 100,000 $ ‐ $ ‐ 100,000$ Overheads $ 1,800,000 $ ‐ $ ‐ 1,800,000$ Contingency $ ‐ $ ‐ $ ‐ ‐$ AFUDC $ ‐ $ ‐ $ ‐ ‐$ Total $ 3,000,000 $ ‐ $ 20,000 $ 2,980,000

Projected Test Year


20199 mos ending09/30/2020

12 mos ending09/30/2021

Labor (Internal) $ 100,000 $ ‐ $ 20,000 $ 80,000 Material $ 1,000,000 $ ‐ $ ‐ $ 1,000,000 Contract Services $ 100,000 $ ‐ $ ‐ $ 100,000 Overheads $ 1,800,000 $ ‐ $ ‐ $ 1,800,000 Contingency $ ‐ $ ‐ $ ‐ $ ‐ AFUDC $ ‐ $ ‐ $ ‐ $ ‐ Total $ 3,000,000 $ ‐ $ 20,000 $ 2,980,000


2019‐20212019 2020 2021

Labor (Internal) $ 170,000 $ 20,000 $ 150,000 ‐$ Material $ 330,000 $ ‐ $ 330,000 ‐$ Contract Services $ 1,770,000 $ ‐ $ 1,770,000 ‐$ Overheads $ 230,000 $ ‐ $ 230,000 ‐$ Contingency $ ‐ $ ‐ $ ‐ ‐$ AFUDC $ ‐ $ ‐ $ ‐ ‐$ Total $ 2,500,000 $ 20,000 $ 2,480,000 $ ‐

Projected Test Year


20199 mos ending09/30/2020

12 mos ending09/30/2021

Labor (Internal) $ 170,000 $ 20,000 $ 150,000 $ ‐ Material $ 330,000 $ ‐ $ 330,000 $ ‐ Contract Services $ 1,770,000 $ ‐ $ 1,770,000 $ ‐ Overheads $ 230,000 $ ‐ $ 230,000 $ ‐ Contingency $ ‐ $ ‐ $ ‐ $ ‐ AFUDC $ ‐ $ ‐ $ ‐ $ ‐ Total $ 2,500,000 $ 20,000 $ 2,480,000 $ ‐

Projected Bridge YearProjected Bridge and Test Year

Cost:

Projected Bridge and Test Year Cost:

South Grand Rapids 22" ILI Expansion

Projected Bridge Year

Menominee‐Powers 16" ILI Expansion





Page:



“The increase in Pipeline Integrity expenses reflects:

* * *2. Increase in the number of actionable anomalies detected due to

advances in technology used to perform the assessments….”

Please provide, for each pipeline that has had multiple in-line inspectionsconducted on it, the following:

A. Line identification.B. Number of “immediate” anomalies based on initial assessment.C. Number of “scheduled” or “1-year” anomalies based on initial

assessment.D. Number of “immediate” anomalies based on most recent

assessment.E. Number of “scheduled” or “1-year” anomalies based on most recent

assessment.F. A succinct description of each anomaly that contains enough

information to verify its categorization as either “immediate,”“scheduled,” or “one-year.”

Answer: See file attachment “U-20642 STDG-1.07 Anomalies”

Attachments: U-20642 STDG-1.07 Anomalies



Line Identification Initial ILI Year Number of “immediate”

anomalies based on initial

assessment.

Description of each "immediate" anomaly

Number of “scheduled” or “1‐year” anomalies

based on initial assessment.

Description of each "scheduled" or 1‐year" anomaly

Number of other anomalies based on initial assessment

Description of other anomalys

Number of other anomalies based

on initial assessment.

Description of other anomalys.

Most Recent ILI Assessment Year

Number of “immediate”

anomalies based on most recent assessment

Description of each "immediate" anomaly.

Number of “scheduled” or “1‐year” anomalies based on most

recent assessment

Description of each "scheduled" or 1‐year" anomaly.

Number of other anomalies based on most recent assessment.

Description of other anomaly

Number of other

anomalies based on most

recent assessment.

Description of other anomaly.

Ann Arbor 2012 0 N/A 0 N/A 0 N/A 13 1‐External corrosion1‐Internal corrosion

3‐Seam weld features

7‐Dents with metal loss

1‐Girth weld anomaly

2019 0 N/A 0 N/A 0 N/A 5 5‐Dents with metal loss

Austin ‐ Detroit A 2005 3 3‐Dents with metal loss

2 2‐External corrosion

26 6‐Girth weld anomaly4‐Internal corrosion validation



15 4‐External corrosion4‐Internal corrosion


4‐Hard spot

2019 1 1‐Dent with metal loss

1 1‐Dent on longitudinal seam

0 N/A 11 5‐Dents with metal loss5‐Dents on longitudinal

seam1‐External corrosion

Austin ‐ Detroit B 2005 0 N/A 1 1‐External corrosion


2‐Girth weld anomaly

18 2‐External corrosion 3‐Hard spot


2019 0 N/A 1 1‐External corrosion

0 N/A 7 3‐Dents with metal loss2‐Dents on longitudinal

seam2‐Dents on girth weld

Austin ‐ Detroit C 2011 0 N/A 0 N/A 0 N/A 16 13‐External corrosion

2‐Seam weld feature

1‐Girth weld feature

2018 0 N/A 0 N/A 0 N/A 10 8‐Seam weld indications2‐External corrosion

Belle River ‐ Detroit 2006 0 N/A 0 N/A 0 N/A 11 9‐External corrosion

1‐Dent with metal loss

1‐Dent

2013 0 N/A 0 N/A 6 6‐External corrosion ‐ monitored


East Outer Drive 2011 0 N/A 0 N/A 8 8‐External corrosion

0 N/A 2018 0 N/A 0 N/A 3 2‐External corrosion ‐ monitored

1‐Tool overspeed validation

0 N/A

Evergreen 2004 0 N/A 0 N/A 6 5‐External corrosion1‐Dent

2017 2 2‐Dents with metal loss

0 N/A 0 N/A 0 N/A

Fort 2012 8 4‐Dents with metal loss

4‐Seam weld corrosion

0 N/A 0 N/A 0 N/A 2019 12 1‐External corrosion


7‐Seam weld corrosion

0 N/A 0 N/A 0 N/A

Kalkaska ‐ Woolfolk Loop 2008 0 N/A 0 N/A 0 N/A 6 6‐Dents 2015 0 N/A 0 N/A 0 N/A 3 1‐External corrosion validation

1‐Dent validation1‐Internal metal loss

validationMilford ‐ Belle River (E) 2007 0 N/A 0 N/A 0 N/A 2 2‐Internal

corrosion2014 0 N/A 2 2‐Dents 1 1‐Internal metal

loss validaton1 1‐Internal metal loss

validationMilford ‐ Belle River (F) (Vector)

2006 0 N/A 0 N/A 0 N/A 2 2‐Manufacturing validation

2013 0 N/A 0 N/A 3 2‐Internal metal loss validation

1‐Manufacturing validation

5 5‐Manufacturing Validation

Milford (K) 2011 1 1‐Dent with metal loss


0 N/A 1 1‐Internal corrosion validation

2018 0 N/A 0 N/A 0 N/A 3 2‐Safety Related Condition‐Dents with Metal Loss1‐External Corrosion Growth Validation

Milford Loop (L) 2007 0 N/A 0 N/A 0 N/A 1 1‐Dent 2014 0 N/A 0 N/A 1 1‐Internal metal loss validaton

Southfield 2009 1 1‐External corrosion

1 1‐Dent on longitudinal sesam


0 N/A 2016 3 1‐Dent with metal loss

2‐Seam weld metal loss

3 3‐Dents >2% on long seam

4 2‐External corrosion ‐ monitored2‐External

corrosion near long seam validation

0 N/A

Van Born 30 2007 0 N/A 0 N/A 1 1‐Dent validation 0 N/A 2014 0 N/A 6 6‐External corrosion

1 1‐Dent validation 0 N/A

Van Born 36 2011 0 N/A 0 N/A 3 2‐External metal loss validation1‐Girth weld anomaly

0 N/A 2018 0 N/A 0 N/A 1 1‐External corrosion validation

0 N/A

Initial not in HCA Most Recent not in HCAInitial in HCA Most Recent in HCA



STATE OF MICHIGAN


* * * * * In the matter of the application of ) DTE GAS COMPANY for authority to increase ) its rates, amend its rate schedules and rules governing ) Case No. U-20642 the distribution and supply of natural gas, and for ) miscellaneous accounting authority ) )

PROOF OF SERVICE

Michelle L. Conarton, being duly sworn, deposes and says that on March 24, 2020, A.D.,

she emailed a copy of the attached MPSC Testimony and Exhibit to the persons as shown

on the attached list.

________________________________ Michelle L. Conarton

Subscribed and sworn to before me this 24th day of March 2020. _________________________________ Lisa Felice, Notary Public State of Michigan County of Eaton My Commission Expires: April 15, 2020

Service List for U-20642

DTE Gas Company: Lauren D. Donofrio Jennifer Schmidt [email protected] [email protected] MPSC Staff: Michael J. Orris Amit T. Singh Daniel Sonneveldt Nicholas Q. Taylor [email protected] [email protected] [email protected] [email protected] Attorney General: Joel B. King Sebastian Coppola [email protected] [email protected] [email protected] ALJ Martin Snider [email protected]

Citizens Against Rate Excess; Citizens Utility Board: John R. Liskey [email protected] ABATE: Michael J. Pattwell Bryan A. Brandenburg Stephan A. Campbell [email protected] [email protected] [email protected] Detroit Thermal, LLC: Arthur J. LeVasseur [email protected] Energy Michigan; Verso Corporation: Laura A. Chapelle Timothy J. Lundgren [email protected] [email protected] Michigan Power Limited Partnership; Retail Energy Supply Association: [email protected] North Bay Energy, LLC: Gregory M. Luyt [email protected] Residential Customer Group: Don L. Keskey Brian W. Coyer [email protected] [email protected]

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