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HomeMy WebLinkAboutResolution - 2009-R0151 - Authorize Atmos Energy To Establish Gas Utility, Terms, Rates, Etc. - 04_09_2009Resolution No. 2009-RO151 April 9, 2009 Item No. 6.4 ORDER AND RESOLUTION AN ORDER AND RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LUBBOCK SITTING AS A REGULATORY AUTHORITY PURSUANT TO SECTION 103.001 OF THE TEXAS UTILITIES CODE, WITH REGARD TO A STATEMENT OF INTENT FILED BY THE WEST TEXAS DIVISION OF ATMOS ENERGY CORPORATION FILED WITH THE CITY OF LUBBOCK AND AUTHORIZING THE MAYOR TO EXECUTE AN ASSOCIATED LETTER AGREEMENT WITH ATMOS PERTAINING TO THE STATEMENT OF INTENT. WHEREAS, pursuant to Section 103.001 of the TEXAS UTILITIES CODE, the City of Lubbock has exclusive original jurisdiction over the rates, operations, and services of a gas utility operating within the corporate limits of the City of Lubbock; and WHEREAS, the West Texas Division of Atmos Energy Corporation ("Atmos Energy") has heretofore filed a Statement of Intent to change the retail gas utility rates tor' gas services within the municipal boundaries of the City of Lubbock on March 11, 2009 consisting of a "Rate Review Mechanism" Tariff and a Conservation Program Rider; and WHEREAS, Atmos Energy has represented to the City of Lubbock in its Statement of Intent that the change in the retail utility rates will not increase or decrease the aggregate revenues of Atmos Energy by more than the greater of ,100,000 or 2.5%') and, therefore is not a "major change" as defined by Section 104.101 of the TEXAS UTILITIES CODE; and WHEREAS, Atmos Energy has represented to the City of Lubbock in its Statement of Intent that the change in the retail utility rates will not change the final rate~ to the retail customers and have requested that the change in retail utility rate, be aliuwed to take effect without delay; and WHEREAS, further understandings between Atmos Energy and the City of Lubbock are contained in a Letter Agreement attached hereto; NOW THERLF'ORE: BE IT ORDERED AND RESOLVED BY THE CITY COUNCIL OF THE CITY OF LU13BOCK: 1. THAT, pursuant to the applicable provisions of the TEXAS LI`rII +rws, CODE, Atmos Energy shall be entitled to place into effect for usage the retail gas utility rates, terms and conditions, gas cost adjustment clauses and riders including the Kate Review Mechanism and the Conservation Program rider as outlined in its Statement of Intent filed with the City of Lubbock on March It, 2009 and which is attached hereto and incorporated herein as though set forth fully herein. 2. THAT, based on the representations made by Atmos Energy in its Statement of Intent, the City Council of the City of Lubbock finds, pursuant to the Section 104.104 of the TEXAS UTILITIES CODE, that good cause exists to allow the requested change in retail gas utility rates to take effect immediately. Page 1 of 2 3. THAT the Mayor of the City of Lubhock is hereby authorized and directed to execute the Letter Agreement by and between Atn-tos Energy and the City of Lubbock pertaining to the aforementioned Statement of Intent. which Letter Agreement is attached j hereto and made a part hereof for all purpose,. ORDERED AND RESOLVED by the City Council this 9th day of April. 2009. ATTEST- Rebec a Garza, City Secretary VED AS TO CONTENT_ �7 Gilbreath, Mayor Pro Tern Lt da DeLeon, C®Unellniember, District I APPROVED AS TO FORM: —- Don andiver, City Attorney Don/Res/AunosRateRes034)9 April 3, 2009 try TOM MARTIN, MAYOR Page 2 of 2 TMOS energy April 6, 2009 City of Lubbock 1625 13th Street Lubbock, Texas 79401 Resolution No. 2009--RO151 v 1VED O_Arlt� 0 Zoos C ITY ,Zi Cri1AF1Y C U>t K. EXAS To the Honorable Mayor and City Council of Lubbock, Texas This letter is to confirm the agreement of Atmos Energy Corp's West Texas Division ("Atmos" or "the Company") and the City of Lubbock ("the City" or "Lubbock") on matters relating to the adoption of an annual Rate Review Mechanism for Atmos' use with the City. This Letter Agreement resolves all issues relating to the adoption of a Rate Review Mechanism in the City pursuant to the following terms: In an effort to streamline the regulatory review process, Atmos and the City have agreed to undertake a new mechanism for reviewing the Company's cost of service on an annual basis. The new mechanism is known as the Rate Review Mechanism ("Rider RRM"). Rider RRM provides for an annual rate adjustment to reflect changes in billing determinates, operating and maintenance expense, depreciation expense, other taxes expense, and revenues as well as changes in the capital investment and associated changes in gross revenue and taxes. See Attachment A-i for a copy of the Statement of Intent that was filed with the City Secretary's office on March 11, 2009 which includes a copy of Rider RPM in Exhibit E. 2. Atmos and the City agree that the Rider RRM shall be implemented annually over a three-year trial period. On or after December 31, 2011, if the City opposes the continued use of the Rider RRM to set rates for areas within its original jurisdiction, it shall provide written notification to the Company of this fact. Such notice shall be provided no later than January 31, 2012. Upon receipt of such written notification, Atmos shall cease making an annual Rider RRM filing with the City and instead, shall file a general rate case with the City within one hundred twenty (120) days from the date the notification is received by the Company. The last effective rates under the Rider RRM shall remain in effect for the City until such time as new rates are established for the City in a general rate case. In the absence of such notification, Rider RRM shall continue subject to any changes that may be agreed to in writing between the City and Atmos. Letter Agreement City of Lubbock — RRM April 6, 2009 3. Atmos agrees that effective with the implementation of the first RRM rates adjustment, Atmos shall file with the City a revised Residential Gas Service Tariff to reduce the customer charge per bill from $9.95 per month to $7.00 plus revenue related taxes per month and to increase the volumetric portion of the rate to the appropriate level to reflect the reduction in the customer charge from $9.95 to $7.00, as well as to reflect any change resulting from the RRM implementation. Atmos further agrees that effective with the implementation of the first RRM adjustment, Atmos shall file with the City of Lubbock a revised Commercial Gas Service Tariff to reduce the customer charge per bill from $15.75 to $13.50 plus revenue related taxes per month and to increase the volumetric portion of the rate to the appropriate level to reflect the reduction in customer charge from $15.75 to $13.50, as well as to reflect any change resulting from the RRM implementation. The first RRM rate adjustment shall occur for bills rendered on or after August 15, 2009. Atmos and the City agree that following the initial RRM adjustment any subsequent implementation of RRM adjustments shall be supported as described in the Rider RRM, and shall limit changes to residential and commercial customer charge to no more than 20%. Further, the parties agree that any approved adjustment in excess of the 20% limitation on the residential and commercial customer charge shall be recovered through the volumetric portion of the rates. 4. The following types of expenses shall be removed from all expense and rate base amounts included within Rider RRM filings for each Evaluation Period and corresponding Rate Effective Period: • Amounts incurred for travel, meals, or entertainment of employee spouses • Amounts for air travel that exceed published commercial coach air fares. • Amounts incurred for hotel rooms exceeding $250 per night inclusive of taxes and fees assessed on such rooms. • Amounts for alcoholic beverages • Amounts paid for admission to entertainment, sports, art or cultural events, and all event sponsorship costs. • Amounts for social club dues or fees. 5. With respect to the RRM, Atmos further agrees to pay all reasonable and necessary expenses of the City that are incurred to review the proposed rate for any Rate Effective Period, the Company shall not include (1) any external legal, expert, or consultant costs to prepare and/or provide supportive information related to its filing; or (2) reimbursements to original jurisdiction entities. 6. Notwithstanding paragraph 7 of this Letter Agreement, Atmos and the City agree that in the event of an appeal of a City decision regarding a proposed RRM adjustment, recovery of rate case expenses shall be determined Letter Agreement City of Lubbock — RRM April 6, 2009 according to Chapters 103 and 104, TEX. UTIL. CODE ANN. Further, in the event of such appeal(s), Atmos shall recover any reimbursement made to the City through a surcharge to all customer rates that are subject to the Commission's jurisdiction in that proceeding or proceedings that might be joined therewith, regardless of whether such reimbursements are made during the initial review or appeal period. 7. It is the intention of the Signatories of this Letter Agreement that the City receive the benefit of any letter agreement that Atmos enters into with any other city within Texas regarding the Rider RRM within twelve (12) months of the execution of the Letter Agreement. Therefore, Atmos agrees that if the terms and conditions, or benefits accruing to any city within Texas with respect to the Rider RRM would be more beneficial to the City than the terms of this Letter Agreement, as determined by the City, such more favorable terms and conditions, or benefits shall be made available to the City for adoption. The City's exercise of this right is conditioned upon the City's acceptance of all terms and conditions of any subsequent letter agreement in toto. 8. The City agrees that it will not challenge the legal basis of the rates, terms, and conditions reflected in Attachment A-1, or any annual RRM adjustment that is implemented pursuant to Rider RRM. 9. Atmos and the City further agree that the express terms of the Rider RRM are supplemental to the filing, notice, regulatory review, or appellate procedural process of the ratemaking provisions of Chapter 104 of the Texas Utility Code. If the statute requires a mandatory action on behalf of the municipal regulatory authority or Atmos, the parties will follow the provisions of such statute. If the statute allows discretion on behalf of the municipal regulatory authority, the City agrees that it shall exercise discretion in such a way as to implement the provisions of the RRM tariff. If Atmos appeals an action or inaction of the City regarding an RRM filing to the Railroad Commission, the City agrees that it will not oppose the implementation of interim rates or advocate the imposition of a bond by Atmos consistent with the RRM tariff. Atmos agrees that it will make no filings on behalf of its Lubbock rate division under the provisions of TEX UTIL. CODE ANN. § 104.301 while the Rider RRM is in place, and any such filings pending at the time the RRM is approved will be trued -up for revenue and rate base components prior to implementation of the annual RRM. In the event that a regulatory authority fails to act or enters an adverse decision regarding the proposed annual RRM adjustment, the Railroad Commission of Texas shall, pursuant to the provisions of the Texas Utilities Code, have exclusive appellate jurisdiction to review the action or inaction of the regulatory authority exercising exclusive original jurisdiction over the RRM request. In addition, the Signatories agree that this Letter Agreement shall not be construed as a waiver of the City's Letter Agreement City of Lubbock — RRM April 6, 2009 right to initiate a show cause proceeding or the Company's right to file a Statement of Intent under the provisions of the Texas Utilities Code. 10. Atmos and the City commit that during the Initial Implementation Period, as defined in the RRM tariff, Atmos and the City will not devote resources or efforts to advocate statutory changes involving rate stabilization mechanisms or the Gas Reliability Infrastructure Program that is currently codified under TEX. UTIL. CODE § 104.301. l 1. Atmos and the City agree that expense associated with lost and unaccountable gas shall, based on an annual period, be recoverable through the Company's Rider GCR up to a maximum of five (5) percent of the quantity of metered gas, as provided under Commission Rule 7.5525, Lost and Unaccounted for Gas. 12. Included as part of the attached Statement of Intent, Exhibit C is a new gas conservation program tariff rider. 13. Atmos and the City agree that Atmos may make all future filings, including, but not limited to, the annual RRM adjustment and any Statement of Intent filing with the City on an electronic basis, rather than by paper copy. Electronic Filings shall fulfill the requirements of TEX. UTIL. CODE § 104.103. Atmos further agrees to make paper copies of filings available to the City upon request. 14. In the spirit of improving communication and cooperation, Atmos agrees to initiate meetings with the City to provide information, answer questions, and receive input from the City. As part of theses meetings, Atmos will update the City of its significant activities as well as any service related issues associated with the provision of gas services. 15. Atmos and the City agree that the City should approve this Letter Agreement and adopt an ordinance or resolution to implement the rates, terms, and conditions reflected in the tariffs attached to the Letter Agreement as Attachment A-1 . 16. The Signatories agree that the terms of this Letter Agreement are interdependent and indivisible, and that if the City enters an order that is inconsistent with this Letter Agreement, then any Signatory may withdraw without being deemed to have waived any procedural right or to have taken any substantive position on any fact or issue by virtue of that Signatory's entry into the Letter Agreement or its subsequent withdrawal. If the City rejects this Letter Agreement, then this Letter Agreement shall be void ab inilio. 4 Letter Agreement City of Lubbock — RRM April 6, 2009 17. The Signatories agree that neither this Letter Agreement nor any oral or written statements made during the course of settlement negotiations may be used for any purpose other than as necessary to support the entry by the City of an ordinance or resolution implementing this Letter Agreement. 18. The Signatories agree that this Letter Agreement is binding on each Signatory only for the purpose of settling the issues set forth herein and for no other purposes, and, except to the extent the Letter Agreement governs a Signatory's rights and obligations for future periods, this Letter Agreement shall not be binding or precedential upon a Signatory outside this proceeding. 19. The Signatories agree that this Letter Agreement may be executed in multiple counterparts and may be filed with facsimile signatories. Agreed to this day of /21 L 2009, By: Bill Guy Vice President, Rates anegulatory Affairs West Texas Division City Representative(s) sign below: Agreed to this 9th day of April , 2009. By: q�-- A 4;,e— dr2eq oA 5 RECEIVED AHN 0 8 2009 CI T Y SECRETARY Lt3E1,e30CK, TEYAS Resolution No. 2009-RO151 STATEMENT OF INTENT TO CHANGE GAS RATES Attachment A-1 Atmos Energy Company (Atmos), a "gas utility" as defined by Section 101.003(7) of the TEXAS UTILITIES CODE ("TUC"), hereby states its intent to implement the revised gas tariffs attached hereto as Exhibits A, B, and C and incorporated herein to be effective for gas service within the city limits of Lubbock, Texas (hereinafter the "City") on April 22, 2009, or 35 days after filing with the City, whichever is later. The proposed revisions and additions to the current Atmos rate schedules are indicated by bold print. Summary of Proposed Changes Atmos proposes to restructure its gas rates to institute a more formulaic methodology in the calculating and testing of the Company's earned rate of return. The proposed tariffs will also provide for auditable annual financial reporting within a framework that is consistent with the aggressive promotion of energy conservation and efficiency. The Company also proposes a new Rider to support the Rate Review Mechanism (RRM) tariff which allows for annual review of the actual and adjusted rate of return experienced by the Company with adjustments both upward and downward to a preset rate of return (Please see Exhibit B). In addition, the Company proposes a new Rider to support the Conservation Program tariff wIvch provides for the funding of weatherization services directly to the City of Lubbock (PIease see Exhibit Q. For comparative purposes, existing tariffs are shown in Exhibit D. Number of Customers Affected And Expected Revenue Change The proposed changes will affect all classes of tariff customers including Residential, Commercial, Public Authority, Small Industrial, and State Institutions customers who elect gas service from Atmos. There are approximately 70,000 Atmos tariff customers within the City and in the City's environs. The proposed changes set out in Exhibit A are revenue neutral and result in no increase or decrease in the Company's annual gross revenues for all classes of customers. Public Notice Because the proposed changes do not constitute an increase in rates, public notice is not required. Attachment A-1 The Proposed Change is Not A "Major Change" The proposed rate change will not increase or decrease the aggregate revenues of the Company by more than the greater of $100,000 or 2.5% and, therefore is not a "major change" as defined by Section 104.101 of the TUC. Company Representative For Notification Notices of Hearings and other communications related to this proposal should be directed to: Mr. Bill Guy Vice President of Rates and Regulatory Affairs 5110 80"' Street, P.O. Box 1121 Lubbock, Texas 79408-1121 Tele. (806) 798-4457 Fax (806) 798-4494 Relief Requested Wherefore, At2nos respectfully requests that the gas rates, terms and conditions, gas cost adjustment clauses and riders proposed herein as Exhibits A and B be allowed to take effect without delay. Respectfully submitted, Atmos Energy Company, By its Vice President of Rates and Regulatory Affairs C.W. `Bill" Guy FILED WITH THE CITY ON MARCH 11, 2009. Atmos Energy Corp., West Texas Division Attachment A-9 Lubbock Rate Division - ICL EXHIBIT A Page, I of 5 RESIDENTIAL GAS SERVICE AVAA.AI3TLITY This schedule is applicable to general use by Residential customers for heating, cooking, refrigeration, water heating and other similar type uses. This schedule is not available for service to premises with an alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 9.95 Commodity Charge: All Consuunption $ 0,09668 per Caf The Lubbock System Gas Cost Adjustment Rider applies to this schedule. The Lubbock System Weather Normalization Adjustment Rider applies to this schedule. The Lubbock Rate Review Mechanism (RRI) Adjustment Rider applies to this schedule. The Lubbock Conseiryation Program Adjustment Rider applies to this schedule, EFFECTIVE: For Bills Rendered after Apail 22, 2009 inside city limits ISSUED BY: C.W. Gary, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Distribution System - ICL EXHIBIT A Page 2 of 5 RFTCCTIVE: For Bills Rendered after April 22, 2009 inside city limits ISSUED BY: C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Atmos Energy Coyp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT A Page 3 of 5 SMALL INDUSTRIAL GAS SERVICE AVAILABILITY This schedule is applicable to the sales of any industrial or commercial customer whose predominant use of natural gas is other than space heating, cooking, water heating or other similar type uses. Service under this schedule is available to eligible customers following execution of a contract specifying the maximum hourly load. This schedule is not available for service to premises with an alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 6896 Commodity Charge: 1st 1000 $ 0.0965 per Cef All over 1000 $ 0.0750 per Ccf The Lubbock System Gas Cost Adjustment Rider applies to this schedule. The Lubbock Rate Review Mechanism (RRM) Adjustment Rider applies to this schedule. The Lubbock Conservation Program Adjustment Rider applies to this schedule. EFFECTIVE: Fdr Bills Rendered after April 22, 2009 inside city limits ISSUED BY: C.W. Guy,' Vice President - Rates & Regulatory Affairs AUTHORIZATION: Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT A Page 4 of 5 STATE [NSTITUTION GAS SERVICE - AVAILABILITY This schedule is applicable to gas service to state agencies (as provided in Texas Utilities Code, Section 104,202) including, but not limited to, state college and universities, Ml-lMR schools, agriculture, highway and public safety departments, prisons, and other facilities owned or operated by the State of Texas for the purpose of heating, couking, refrigeration, water heating and other similar type uses_ MONTHLY RATE Customer Charge: 44.41 Commodity Charge: All Consumption S 0.08645 per Ccf The Lubbock System Gas Cost Adjustment Rider applies to this schedule. The Lubbock System Weather Normalization Adjustment Rider applies to this soltedule. The Lubbock Rate Review Mechanism (RRM) Adjustment Rider applies to this schedule. The Lubbock Conservation Program Adjustment Rider applies to this schedule. . EFFECTIVE: For Bills Rendered after April 22, 2009 inside city limits ISSUED BY: C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT A Page 5 of 5 PUBLIC AUT14ORITY GAS SERVICE AVAILABILITY This schedule is applicable to general use by Public Authority type customers, including public schools, for heating, cooking, refrigeration, water heating and other similar type uses. This schedule is not available for service to premises with an alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 47.22 Commodity Charge: All Consumption $ 0.091 per Ccf The Lubbock System Gas Cost Adjustment Rider applies to this schedule. The Lubbock System Weather Normalization Adjushment Rider applies to this schedule. The Lubbock Rate Review Mechanism (RRM) Adjustment hider applies to this schedule. The Lubboelt Conservation Program Adjustment Rider applies.to this schedule. EFFECTIVE: For Bills Rendered after April 22, 2009 inside city lirnits ISSUED BY: C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Resolution No. 2009—RO151 EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: I of 9 October 1, 2009 RIDER RRM — RATE REVIEW MECHANISM P_ urpose: This mechanism is designed to provide annual earnings transparency. All rate calculations under this tariff shall be made on a system wide basis. If, through the implementation of the provisions of this mechanism, it is determined that rates should be decreased or increased, then rates will be adjusted accordingly in the manner set forth herein. The rate adjustments implemented under this mechanism will reflect annual changes in the Company's cost of service and rate base. This adjustment will be authorized for an Initial Implementation Period. With the conclusion of the final rate adjustment, if any, for the Initial Implementation Period, each entity having original jurisdiction may revoke, amend, or approve Subsequent Implementation Period(s) for, the mechanism. Definitions a) The Annual Evaluation Date shall be the date the Company will make its annual filing under this mechanism. The Annual Evaluation Date shall be no later than April 1, of each year. This filing shall be effective in electronic form where practicable. The initial filing shall be made no later than April 15, 2009. b) Audited Financial Data shall mean the Company's books and records related to the Company's Lubbock operating area and shared services operations. Audited Financial Data shall not require the schedules and information provided under this tariff to undergo a separate financial audit by an outside auditing firm similar to the Company's annual financial audit. c) The Evaluation Period is defined as the twelve month period ending December 31, of each calendar year. The initial Evaluation Period shall be calendar year 2008. d) The Rate Effective Period is defined as the earlier of the twelve month period for which rates determined under this mechanism will be in effect or subsequent rates are implemented. e) Per Connection Basis is defined as the existing average number of Lubbock Rate Division active meters to customers during the Evaluation Period. 0 Initial Implementation Period is defined as the three (3) year period commencing with the Company's filing under this mechanism for the calendar year 2008, effective October 1, 2009, and shall conclude with the implementation of rate adjustments, if any, for the third Rate Effective Period. g) Subsequent Implementation Period is defined as any three (3) year period after the conclusion of the Initial Implementation Period. h) Final Order is defined as the most recent order establishing the Company's latest effective rates for the area in which the mechanism is implemented, and shall include municipal rate ordinances and resolutions. EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 2 of 9 October I, 2009 Rate Review Mechanism The Company shall file with each regulatory authority having original jurisdiction over the Company's rates the schedules specified below for the Evaluation Period, with the filing to be made by the Annual Evaluation Date following the end of the Evaluation Period. The schedules, which will be based upon the Company's Audited Financial Data, as adjusted, and will include the following: a) Company's 13 month average actual gross plant in service, accumulated depreciation, accumulated deferred income taxes, inventory, working capital, and other rate base components for the Evaluation Period. A 13 month average will be used for these items for the true up calculation; Evaluation Period ending balances for these items will be used for the calculation of rates for the Rate Effective Period. The ratemaking treatments, principles, findings and adjustments included in the Final Order will apply where they are not in conflict or specifically addressed elsewhere in this tariff or the letter agreement. The 4 part allocation methodology as approved for the Mid -Tex Operating Division in GUD 9670 will be used in place of the current 3 part methodology used by the West Texas Operating Division. Regulatory adjustments due to prior regulatory rate base adjustment disallowances will be maintained. The ARM Schedules & Information section of this tariff identifies those ADIT components to be included in the calculation of rate base for both the Evaluation Period and Rate Effective Period calculations. b) The Company's depreciation expense, operating and maintenance expense, and taxes other than income taxes booked in the period will be used for the true -up calculation purposes. Depreciation rates booked in the period will be those approved in the Final Order, or the rate most recently approved. All calculation methodologies will be those approved in the Final Order except where noted or included in this tariff, or in the most recent order addressing the methodology. In addition, the Company shall exclude from operating and maintenance expense the discretionary costs to be disallowed from Rider RRM filings listed in the RRM Schedules and Information section of this tariff. c) Return on Equity (ROE) shall be maintained at 9.6%. d) Cost of debt will reflect actual cost for the Evaluation Period. A 13 month average cost of debt and capital structure will be used for the true up calculation; Evaluation Period ending balances for cost of debt and capital structure will be used for the calculation of rates for the Rate Effective Period. Capital structure will be the actual Evaluation Period ratio of long-term debt and equity, with percentage equity not to exceed 48.1 % equity, based on the calculation methodology outcomes used above. e) All applicable accounting adjustments along with all supporting work papers. Such adjustments may include: 1) Pro -forma adjustments to update and annualize costs and revenue billing determinants for the Rate Effective Period. EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 3 of 9 October I, 2009 2) Pro -forma or other adjustments required to properly account for atypical, unusual, or nonrecurring events recorded during the Evaluation Period. f) Shared Services allocation factors shall be recalculated each year based on the latest component factors used during the Evaluation Period, as referenced in (a) above. Calculation of Rate Adiustment a) The Company shall provide additional schedules indicating the following revenue deficiency/sufficiency calculations using the methodology accepted in the Final Order, a 13 month average will be used for the specified items for the true up calculation, Evaluation Period ending balances will be used for the calculation of rates for the Rate Effective Period. These schedules shall identify the rate adjustments necessary for both a true -up of revenue for the Evaluation Period and the setting of prospective rates for the Rate Effective Period. The net result of these rate adjustments shall be reflected in the proposed new rates to be established for the Rate Effective Period. In calculating the required rate adjustments, such adjustments will be made pro - ratably to the customer charge and usage charge based upon actual revenue generated, as adjusted under the Company's approved Weather Normalization Adjustment (WNA) Rider. Provided, however, that neither the Residential nor the Commercial customer charges may increase more than 20% per year. b) If Company's earnings during the Evaluation Period exceed 9.6% return on common equity, the Company shall calculate a decrease to rates to reduce the revenue required to achieve a return on equity of 9.6% for the Evaluation Period. If Company's earnings during the Evaluation Period are below 9.6% return on common equity, the Company shall calculate an increase in rates to collect the additional revenue required to increase its return on equity for the Evaluation Period to 9.6%. In order to avoid double -counting of true -up revenues, any true -up revenue booked during the Evaluation Period that is related to prior periods will be removed in determining both the prospective rates for the Rate Effective Period and the true -up increase or decrease related to the current Evaluation Period. The RRM Schedule & Information section of this tariff provides an example calculation. After the prospective rates for the Rate Effective Period are calculated, the true -up element shall be added to or deducted from those rates in order to determine the rates that shall thereafter be recovered. The first true -up will be collected between October 1, 2009 and July 31, 2010 to eliminate overlapping true -up periods. c) The Company may also adjust rates for the Rate Effective Period to include recovery of any known and measurable changes to operating and maintenance costs including, but not limited to, all payroll and compensation expense, all benefit expense, all pension expense, insurance costs, materials and supplies, bad debt costs, all medical expense, transportation and building and lease costs for the Rate Effective Period. Provided, however, that adjustments may only be made for costs that are reasonable and necessary. Additionally, utility plant and rate base for the Rate Effective Period will be established by using the Evaluation Period ending balances, including associated changes in depreciation and amortization expense and taxes, In calculating the Company's known and measurable changes for prospective RRM adjustment purposes, Operating and Maintenance expenses per connection for the Rate Effective Period cannot increase more than the Texas Consumer Price Index ("CPI") per year without specific EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 4 of 9 October 1, 2009 identification and justification. Any proposed adjustment above the Texas CPI per year, is subject to the provisions of the Evaluation Procedures of this tariff. Such procedures provide that the regulatory authority will review the proposed adjustment and that the Company and regulatory authority will work collaboratively to seek agreement on the proposed adjustments to the Company's schedules and proposed rates. Justification for such expenditures over the cap shall include an event or combination of events beyond the control of the Company. The beginning adjusted Operation and Maintenance expense per connection for the 2009 RRM Rate Effective Period will be limited to not exceed the final O&M as established for the 12 month period ended December 31, 2008 divided by the connections for the period. The increase in adjusted Operation and Maintenance expenses per connection for the 2010 Rate Effective Period and subsequent Rate Effective periods cannot exceed the Texas CPI per year, without specific identification and justification. The RRM Schedule & Information section of this tariff provides an example calculation of the Texas CPI limit. The regulatory authority may disallow any net plant investment that is not shown to be prudently incurred. Approval by the regulatory authority of net plant investment pursuant to the provisions of this tariff shall constitute a finding that such net plant investment was prudently incurred. Such finding of prudence shall not be subject to further review in a subsequent Evaluation Period or Statement of Intent filing. d) The Company also shall provide a schedule demonstrating the "proof of revenues" relied upon to calculate the proposed rate for the Rate Effective Period. The proposed rates shall conform as closely as is practicable to the revenue allocation principles approved in the Final Order. Attestation A sworn statement shall be filed by the Company's Chief Officer in Charge of West Texas Operations affirming that the filed schedules are in compliance with the provisions of this mechanism and are true and correct to the best of his/her knowledge, information and belief. No testimony shall be filed. Evaluation Procedures The regulatory authority having original jurisdiction over the Company's rates shall have no less than ninety (90) days to review the Company's filed schedules and work papers. The Company will be prepared to provide all supplemental information as may be requested to ensure adequate review by the relevant regulatory authority. The Company shall not unilaterally impose any limits upon the provision of supplemental information and such information shall be provided within ten (10) working days of the original request. The regulatory authority may propose any adjustments it determines to be required to bring the schedules into compliance with the above provisions. During and following the ninety (90) day review period and a thirty (30) day response period, the Company and the regulatory authority will work collaboratively and seek agreement on, the proposed adjustments to the Company's schedule and proposed rates. If agreement has been reached by the Company and the regulatory authority, the regulatory authority shall authorize an increase or decrease to the Company's rates so as to achieve the revenue levels indicated for the Rate Effective Period. If, at the end of the thirty (30) day response period, the Company and the regulatory authority have not reached agreement on the proposed adjustments, the Company shall have the right to appeal the regulatory authority's action or EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 5 of 9 October 1, 2009 inaction to the Railroad Commission of Texas. Upon the filing of any appeal, the Company shall have the right to implement the proposed RRM rate adjustment, subject to refund. If approved by the entity exercising original jurisdiction, the rates established pursuant to the Rate Review Mechanism for the first Rate Effective Period shall be effective for bills rendered on or after October 1, 2009. Thereafter, rates established pursuant to the Rate Review Mechanism for subsequent Rate Effective Periods, if approved as provided herein, shall be effective on August l of each year. Reconsideration and Appeal Orders issued pursuant to this mechanism are ratemaking orders and shall be subject to appeal under Sections 102.001(b) and 103.021, et seq., of the Texas Utilities Code (Vernon 2007). Notice Notice of the annual Rate Review Mechanism filing shall be provided pursuant to Section 104.103, TEx. UTIL. CODE ANN. no later than forty-five (45) days after the Company makes its annual filing pursuant to this tariff. The notice to customers shall include the following information: a) a description of the proposed revision of rates and schedules; b) the effect the proposed revision of rates is expected to have on the rates applicable to each customer class and on an average bill for each affected customer; c) the service area or areas in which the proposed rate adjustment would apply; d) the date the proposed rate adjustment was filed with the regulatory authority; and e) the Company's address, telephone number and website where information concerning the proposed rate adjustment may be obtained. RRM Schedules and Information Accumulated Deferred Income Tax ("ADIT") Items To Be Recognized in Rate Base The following list identifies those ADIT components to be included in the calculation of rate base for both the Evaluation Period and Rate Effective Period calculations: WTX Rate Division: Gas Plant in Service Insurance Accruals Benefit Accruals Deferred Expense Projects Allowance for Doubtful Accounts EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 6 of 9 October 1, 2009 Accumulated Deferred Income Tax ("ADIT) Items To Be Recognized in Rate Base (continued): Customer Advances Regulatory Asset - West Texas Regulatory Liability - West Texas Other Plant SSU - Customer Support: Gas Plant in Service SSU - General Office: Gas Plant in Service Insurance Accruals Benefits Accruals Deferred Expense Projects Prepaid Expenses Regulatory Liability - Atmos 109 FAS 115 Adjustment Treasury Lock Adjustment State Bonus Depreciation R & D Credit Valuation Allowance Other Plant Discretionary Costs to Be Disallowed from Rider RRM filings The following types of employee reimbursed expenses and directly incurred costs are to be removed from all expense and rate base amounts included within Rider RRM filings for the Evaluation Period and for the Rate Effective Period: Amounts incurred for travel, meals or entertainment of employee spouses. Amounts for air travel that exceed published commercial coach air fares. Amounts incurred for hotel rooms exceeding $250 per night inclusive of taxes and fees assessed on such rooms. Amounts for alcoholic beverages. Amounts paid for admission to entertainment, sports, art or cultural events, and all event sponsorship costs. Amounts for social club dues or fees. EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM --- Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 7 of 9 October I, 2009 Example Calculation A - Revenue for RRM True -Up Portion of Rate "FOR ILLUSTRATION PURPOSES ONLY. AMOUNTS ARE HYPOTHETICAL, AND DO NOT CORRESPOND WITH OTHER EXAMPLE SCHEDULES*" Per Books Revenue, excluding True -Up Revenue from prior Evaluation Periods Per -Books True -Up Revenue based on 2007 Evaluation Period [1] Per -Books True -Up Revenue based on 2008 Evaluation Period [1] Per -Books True -Up Revenue based on 2009 Evaluation Period [I] Total Per -Books Revenue Add / (Subtract): Revenue from Riders GCR, FF. & TAX Surcharges for Rate Case Cost Recovery True -Up Revenue for 2007 Evaluation Period [1] True -Up Revenue for 2008 Evaluation Period [1] Remove out -of -period and unusual items Realized Revenue for True -Up Calculation Revenue Requirement at 9.6% ROE [2] Calendar Calendar Calendar Calendar Calendar 2007 2008 2009 2010 2011 $150,000 $156.000 $157,700 $I58,200 $158,700 800 1,200 (364) (546) 234 351 $150.000 $156,800 $158„536 $157,888 $159,051 (110„000) (111,000) (112,000) (200) (200) (200) (800) (1,200) 364 39,800 44,800 45,500 41,800 43,890 46,085 True -Up Increase (Decrease), subject to Revenue - Related Tax Gross -up $ 2,000 $ (910) $ 585 [1] For illustration purposes, example assumes 40% of the total calculated true -up is collected in the following calendar year. Each true -up is subject to a proof of collection or refund after the collection/refund period, and any residual amount will be refunded or collected in the subsequent period. [2) Since realized revenue for the true -up calculation excludes Riders GCR, FF, and TAX, as well as surcharges for rate case cost recovery, the revenue requirement for purposes of the true -up calculation also excludes all corresponding expenses for the Evaluation Period. EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 8 of 9 October 1, 2009 Example Calculation B - Revenue for RRM Prospective Portion of Rate "FOR ILLUSTRATION PURPOSES ONLY. AMOUNTS ARE HYPOTI IETICAL, AND DO NOT CORRESPOND WITH OTHER EXAMPLE SCHEDULES" Oct 2008 - Sept July 15, 2009 - July 15, 2010 - 2009 July 14, 2010 July 14, 2011 Rate Effective Period Revenue Price -Out at Current Rates [ I ] $ 60,000 S 65,000 $ 68,000 Remove True -Up Portion of Revenue t2] Revenue at Current Rates for Rate Effective Period Deficiency Calculation Revenue Requirement for Rate Effective Period (2,500) 1,100 60,000 62,500 69,100 65,000 69,250 71,663 Rate Effective Period Revenue Increase / (Decrease) before True -Up, subject to Revenue Tax Gross -Up [3] $ 5,000 $ 5,750 S 2,563 [I] To be calculated using pro -forma annualized billing determinants, as provided for in this tariff, priced out at the current rates at the time of the deficiency calculation. [2] To be calculated using pro -forma annualized billing determinants, as provided for in this tariff, priced out at the portion of current rates at the time of the deficiency calculation intended to true up prior Evaluation Period(s). [3] This represents the prospective deficiency portion of the RRM adjustment. The true -up adjustment, demonstrated in Example Calculation A, will be combined with this adjustment to determine the total adjustment for the Rate Effective Period. EXHIBIT B Attachment A-1 TARIFF FOR GAS SERVICE ATMOS ENERGY CORP., LUBBOCK RATE DIVISION RIDER: Rider RRM — Rate Review Mechanism APPLICABLE TO: Lubbock Rate Division REVISION DATE: EFFECTIVE DATE: PAGE: 9 of 9 October 1, 2009 Example Calculation C - Operation & Maintenance Expense Cap Test "All Amounts are Hypothetical, and do not correspond with other example calculations" Evalulation Period (Calendar Year) 2007 2008 2009 Benchmark O&M Per Connection (increased 5% annually) Gas Service Connections [11 Maximum O&M &flowed $ 97.23 $ 102.09 $ 107.19 1,553,000 1,560,000 1,567,000 $ 151,000,000 $ 159.260,400 $ 167,966.730 [I ] For illustration purposes only, Gas Service Connections are estimated for 2007 and are assumed to increase 7,000 connections per year. Therefore, `Maximum O&M Allowed' is estimated for 2008 and 2009. Actual Gas Service Connections for 2007 will be used to calculate the 2007 O&M per Connection. For each subsequent Evaluation Period, the prior period O&M per Connection will be increased by 5%, and then multiplied by the actual Gas Service Connections for the same period to derive the `Maximum O&M Allowed'. Resolution No. 2009-RO151 Atmos Energy Corp., West Texas Division. Lubbock Rate Division - ICL CONSERVATION PROGRAM Attachment A-1 Exhibit C Page t of I To promote conservation -related activities, in each RRM Plan year, Atmos Energy Corporation ("Company"), commits to annual funding of conservation expenditures of %Z% of prior calendar year margin revenues (less any revenue related taxes) or $100,000 whichever is greater. a. 100% of this amount will be provided directly to the City of Lubbock for weatherization services by August I", 2009 and August I" each year thereafter through August 1, 2011. b. 50% ofthe expenditures made by Atmos under part (a) will be considered in determining the Company's annual earnings for RRM rate adjustment purposes, EFFECTIVE: For Bills Rendered on or after August 1, 2009 inside city limits ISSUED BY: C.W. Guy, Vice President— Rates & Regulatory Affairs AUTHORIZATION: Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT D Page I of 5 RESIDENTIAL GAS SERVICE AVAILABILITY This schedule is applicable to general use by Residential customers for heating, cooking, refrigeration, water heating and other similar type uses. This schedule is not available for se►•vice to premises with an alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 9.95 Commodity Charge: All Consumption S 0,09668 per Ccf The West Texas System Gas Cost Adjustment Rider applies to this schedule. The Lubbock System Weather Normalization Adjustment Rider applies to this schedule. EFFECTIVE: For Bills Rendered after May 8, 2009 inside city limits ISSUED BY: QW. Guy, Vice President- Rates & Regulatory Affairs AUTHORIZATION: Resolution No. 2008-RO179 Atmos Energy Carp., West Texas Division Attachment A-1 Lubbock Distribution System - ICL EXHIBIT D Page 2 of 5 COMMERCIAL GAS SERVICE AVAILABILITY This schedule is applicable to Commercial type customers, including hospitals and churches, for heating, cooking, refrigeration, wafer heating and other similar type uses, This schedule is not available for service to premises with alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 15.75 Commodity Charge: All Consumption $ 0.0950 per Cef The Lubbock System Gas Cost Adjustment Rider applies to this schedule, The Lubbock System Weather Normalization Adjustment Rider applies to this schedule. EFFECTIVE: For Bills Rendered after May 8, 2008 inside city limits ISSUED BY: C,W, Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Resolution No, 2008-RO179 Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT D Page 3 of 5 SMALL INDUSTRIAL GAS SLRVTCE AVAILABILITY This schedule is applicable to the sales of any industrial or commercial customer whose predominant use of natural gas is other than space heating, cooking, water heating or other similar type uses. Service under this schedule is available to eligible customers following execution of contract specifying the maximum hourly Ioad. This schedule is not available for service to premises with an alternative supply of natural gas. MONTHLY RATE Customer Charge: $ 68.96 Conunodity Charge: 1st 1000 S 0.0965 per Cef All over 1000 $ 0.0750 per Cef The Lubbock System Gas Cost Adjustment Rider applies to this schedule. EFFECTIVE: For Bills Rendered after May 8, 2008 inside city limits ISSUED BY: C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Resolution No. 2008-RO179 Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT D Page 4 of 5 STATE INSTITUTION GAS SERVICE AVAILABILITY This schedule is applicable to gas service to state agencies (as provided in Texas Utilities Code, Section 104,202) including, but not limited to, state college and universities, D4HMR schools, agriculture, highway and public safety departments, prisons, and other facilities owned or operated by the State of Texas for the purpose of heating, cooking, refrigeration, water heating and other similar type uses. MONTHLY RATE Customer Charge: $ 44.41 Commodity Charge: All Consumption $ 0.08645 per Ccf The Lubbock System Gas Cost Adjustment Rider applies to this schedule. The Lubbock System Weather Normalization Adjustment Rider applies to this schedule. EFFECTIVE: For Bills Rendered after May 8, 2008 inside city limits ISSUED BY: C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Resolution No. 2008-RO179 Atmos Energy Corp., West Texas Division Attachment A-1 Lubbock Rate Division - ICL EXHIBIT D Page 5 of 5 EFFECTIVE: For Bills Rendered after May 8, 2009 inside city liniits ISSUED BY; C.W. Guy, Vice President - Rates & Regulatory Affairs AUTHORIZATION: Resolution No. 2008-ROI79