GAS UTILITIES DOCKET NO WITHIN THE UNINCORPORATED AREAS SERVED BY SIENERGY, LP IN CENTRAL AND SOUTH TEXAS

Transcription

1

2 GAS UTILITIES DOCKET NO STATEMENT OF INTENT TO INCREASE GAS UTILITY RATES WITHIN THE UNINCORPORATED AREAS SERVED BY SIENERGY, LP IN CENTRAL AND SOUTH TEXAS BEFORE THE RAILROAD COMMISSION OF TEXAS STATEMENT OF INTENT TO INCREASE GAS UTILITY RATES WITHIN THE UNINCORPORATED AREAS SERVED BY SIENERGY, LP IN CENTRAL AND SOUTH TEXAS SiEnergy, LP ( SiEnergy or the Company ), a gas utility under Texas Utilities Code (7), respectfully files this Statement of Intent, pursuant to Subchapter C of Chapter 104 of the Texas Utilities Code and the rules of the Gas Services Department of the Railroad Commission of Texas ( Commission ), to increase gas utility rates within the areas it serves in the unincorporated areas of Central and South Texas, specifically Fort Bend, Harris, Waller, and Travis counties. 1 The Company s proposed rates were developed based on the cost of providing service to all customers served by the Company within these counties. 2 The Company requests that the proposed rate schedules and tariffs, attached as Exhibit A to this Statement of Intent and incorporated herein by reference, become effective on February 9, 2018, which is 35 days from the date of this filing. In support of its request, the Company respectfully shows as follows: I. INTRODUCTION AND SUMMARY OF THE RATE REQUEST SiEnergy calculated the revenue requirement for this filing using the system-wide cost of providing service to all customers served by the Company, which is comprised of certain incorporated and unincorporated areas in Fort Bend, Harris, Waller, and Travis counties. The new rates will affect all SiEnergy customers in Central and South Texas. SiEnergy s customers 1 This pleading uses the terms unincorporated areas and environs interchangeably. 2 Contemporaneously with this filing, SiEnergy is filing a Statement of Intent to Increase Rates with the municipalities of Conroe, Fulshear, Missouri City and Sugarland, which exercise original jurisdiction over the Company s rates and services within their municipal boundaries. 1

3 currently include residential, commercial, and public school customers. For the 12-month period ended September 30, 2017, the Company s overall combined revenue requirement on a systemwide basis totaled approximately $9.5 million, as adjusted. The total base revenue SiEnergy received during the test year from incorporated and unincorporated area customers, adjusted to include additional revenues due to customer growth and the impact of weather experienced during the test year, was approximately $6.5 million, leaving a revenue deficiency on a system-wide basis of $2.984 million. While the Company s rate filing supports recovery of a $2.984 million system-wide revenue deficiency, the Company has chosen to propose new rates designed to recover, on a system-wide basis, only $2.267 million of the overall system-wide revenue deficiency. Adoption of the Company s proposed rates will increase the Company s aggregate revenues, including miscellaneous fee revenues, on a system-wide basis by 22% including gas costs or 35% excluding gas costs. More specifically, the proposed rates will increase the annual revenues from the unincorporated areas served by SiEnergy by approximately $1.9 million or 35% excluding gas costs. Because the proposed rates will increase the Company s total aggregate revenues within the unincorporated areas by more than 2.5%, the proposed rate increase constitutes a major change in rates as that term is defined by Texas Utilities Code The proposed rates will not, however, exceed 115% of the average of all rates for similar services of all municipalities served by the Company within the same county. See Texas Utilities Code The rate schedules and tariffs, attached hereto as Exhibit A to the Rate Filing Package and made a part hereof, evidence the rate changes proposed by the Company. The proposed tariffs would be applicable to all areas served by the Company in Central and South Texas. As part of this rate filing, the Company proposes to consolidate its Commercial and Public School rate tariffs into new rate tariffs Rate GSSI-1 General Service Small, Incorporated and GSSU General 2

4 Service Small, Unincorporated and as shown in Exhibit A. The Company also requests Commission approval of new depreciation rates for distribution and general plant, a revised Weather Normalization Adjustment tariff, amortization of the Company s acquisition adjustment, and the recovery of reasonable rate case expenses associated with this filing through a surcharge on rates. 3 This rate filing will also determine the prudence of SiEnergy s invested capital through September 30, 2017, and establish factors to be used in any future interim rate adjustment filing made pursuant to Section of the Texas Utilities Code. Finally, the Company requests a Commission determination that the equity transaction described in the accompanying Direct Testimony of Ms. June Dively included in Exhibit D is consistent with the public interest pursuant to Texas Utilities Code Additional proposed revisions to the Company s rate schedules and tariffs are detailed in Section III(E) of this Statement of Intent. II. JURISDICTION SiEnergy is a gas utility as that term is defined in (7) of the Texas Utilities Code. Pursuant to Texas Utilities Code (a), the Commission has exclusive original jurisdiction to approve the rates SiEnergy requests for customers in the unincorporated areas of the Company s service territory. Consistent with such jurisdiction, the proposed rates identified in Exhibit A are applicable to the Company s natural gas service within all unincorporated areas. III. DETAILS OF PROPOSED CHANGES A. Rate Filing Package In addition to this Statement of Intent, the Rate Filing Package consists of the following: 3 The exact amount of rate case expenses will not be known until the case is complete. 4 On August 2, 2017, SiEnergy provided the Commission with the required notification that an equity transaction was closed on July 31, A copy of the Company s notification letter to the Commission and the Commission s acknowledgement of its review of the Transaction is attached to the direct testimony of June M. Dively as Exhibit JMD-2. 3

5 B. Test Year SOI Exhibit A Proposed Rate Schedules and Tariffs SOI Exhibit B Proposed Revenue Increase by Class SOI Exhibit C Average Bill Impact by Class SOI Exhibit D Direct Testimony SOI Exhibit E Proposed Notice SOI Exhibit F Proposed Protective Order SOI Exhibit G Cost of Service Schedules and Class Cost of Service Study SOI Exhibit H Workpapers The Company s proposed cost of service, as set forth in this Statement of Intent and Rate Filing Package, is based on the 12-month period ended September 30, 2017, updated for known changes and conditions that are measurable with reasonable accuracy. C. Effective Date The Company requests that the Commission order the proposed rates to be effective for bills rendered on and after February 9, D. Class and Number of Customers Affected The proposed changes to the Company s rate schedules will affect all customers in the incorporated and unincorporated areas served by the Company in Central and South Texas. The table below shows the approximate number of customers in the unincorporated areas by class that will be affected by the proposed rate changes. All Current Company Classes Environs Residential 14,598 Commercial 33 Public School 9 4

6 Exhibits B and C, attached, show the amount of the proposed increase and the effect of the proposed increase on the average bill for each class of customers. E. Proposed Rate Schedules and Tariffs SiEnergy proposes changes to the following rate schedules and tariffs, which are attached to this Statement of Intent as Exhibit A and incorporated herein by reference: (a) (b) (c) (d) (e) (f) Proposed Rates for Residential and Small General Service Customers (customers using 30,000 Ccf per year or less): For Residential Customers, SiEnergy proposes the new rates shown in the attached rate tariffs Rate RSI-1 Residential Sales, Incorporated Areas and Rate RSU Residential Sales, Unincorporated Areas. The Company currently has separate tariffs for Commercial and Public School customers; however, those tariffs reflect the same rates for both groups of customers. Therefore, the Company proposes to consolidate the two groups of customers and apply the proposed rates shown in attached rate tariffs Rate GSSI-1 General Service Small, Incorporated and GSSU General Service Small, Unincorporated to customers currently served under the Company s current, separate Commercial and Public School tariffs. Rate Schedule WNA: In proposed Rate Schedule WNA, the Company seeks to modernize the Weather Normalization Adjustment ( WNA ) clause consistent with the WNA clause that is in effect for other natural gas distribution companies in Texas. Rate Schedule RCE Rate Case Expenses: The Company seeks approval of Rider RCE to allow for the recovery of all rate case expenses determined by the Commission to be reasonably incurred. Rate Schedule PSF Pipeline Safety Fee: Rate Schedule PSF currently references the applicable section of the Texas Administrative Code ( TAC ) 5 and also currently incorporates several sections of that code, one of which has been updated in the actual TAC since the original tariff language was adopted. Therefore, the Company proposes to delete the language in Rate Schedule PSF that constitutes a partial reproduction of the applicable Commission rule and simply reference the applicable code. Rate Schedule TFF Taxes and Franchise Fees: Rate Schedule TFF contains language relating to taxes and fees that is applicable to specific rate schedules, rather than duplicating that detailed language on each schedule. Rate Schedule M Miscellaneous Fees and Deposits: The Company seeks approval of a minimum level of residential and small general service customer deposits. Additionally, so that customers requiring specific services more directly bear the cost of providing those services, the Company is requesting approval of increases to several miscellaneous fees, including increases to connection and reconnection fees, 5 16 Tex. Admin. Code

7 service fees, the special field read of meter fee, the meter testing fee, and the fee to relocate or upgrade meters or add a second meter at the same location. The Company is also requesting approval of several new fees and charges including a fee to expedite service, an account history research or printing fee, a fee for failure to provide the Company with access to its own property, a fee to recover the cost of a police escort, and a fee to be assessed in the course of disconnecting customers for non-payment under specific circumstances. In addition, the Company requests approval of the ability to recover from customers the actual incremental cost required to support standby gas generation service. Lastly, the Company is proposing to eliminate builder tap fees as a miscellaneous revenue item. The Company is not proposing any changes to Rate Schedule PGA Purchased Gas Adjustment or to its Rules of Service. F. Effect of Proposed Rate Changes The specific proposed changes to the Company s rates are shown in the following side-byside comparison of existing and proposed rates for environs customers: Customer Class Existing Rate Proposed Rate Residential Customer Charge $ $ Volumetric Charge per Ccf $ $ Commercial and Public Authority Customer Charge $ $ Volumetric Charge per Ccf $ $ Exhibit C shows the average bill impact by customer class. G. Witness Testimony Attached as Exhibit D to the Statement of Intent is the direct testimony supporting the Company s requested revenue requirement. The attached testimony includes the following witnesses: June Dively is the Chief Executive Officer of SiEnergy. Ms. Dively s testimony describes the main drivers for the Company s request to increase rates, provides an overview of the filing and requested relief, describes the Company s compliance with Commission requirements regarding the Company s books and records, and supports the Company s request for a Commission finding that the recent equity transaction is in the public interest. Paul Kennedy is Senior Vice-President of Operations for SiEnergy. Mr. Kennedy provides an overview of the Company s operations, supports the reasonableness 6

8 and necessity of the Company s capital investment made to serve its customers, and explains that the equity transaction has had no impact on the day-to-day operations of the Company. Janet Simpson is Vice President for Dively Energy Services Company, which provides consulting services to utilities within the energy sector. Ms. Simpson provides an overview of the cost of service and overall revenue requirement calculation; explains and supports the Company s rate base, expenses, revenues, and related adjustments; describes the Company s requested tariff changes; and supports the Company s request for rate case expenses recovery, including affiliate costs contained within rate case expenses. Dane Watson is Managing Partner of Alliance Consulting Group. Mr. Watson sponsors the Company s proposed depreciation rates and underlying depreciation study. Bruce Fairchild is a principal with Financial Concepts and Applications, Inc. Dr. Fairchild addresses and supports the Company s requested return on equity, cost of debt, capital structure, and overall return on invested capital (weighted average cost of capital). IV. REQUEST FOR PUBLIC INTEREST FINDING On July 31, 2017, SiEnergy closed an equity transaction. 6 The Company respectfully requests that the Commission find that the transaction is consistent with the public interest pursuant to Texas Utilities Code V. RATE CASE EXPENSES Pursuant to Texas Utilities Code and Commission Substantive Rule , SiEnergy requests recovery of all reasonable and necessary rate case expenses from affected customers through a surcharge to the final approved rates. VI. PUBLIC NOTICE AND REQUEST FOR APPROVAL OF FORM OF NOTICE The Company will promptly undertake to notify the public of the proposed changes in its gas rates consistent with the requirements of Texas Utilities Code and Commission Substantive Rules and The public notice that SiEnergy proposes to provide 6 See Application filed by SiEnergy, LP to Report the Sale of Assets to IX Si Investment Co., LLC. Under Tex. Util. Code , GUD No (Aug. 7, 2017). 7

9 regarding the proposed increase in rates is attached as Exhibit E to the Statement of Intent. SiEnergy asks that the Commission approve its form of notice prior to providing notice to affected customers, and the Company will submit proof of notice to the Commission promptly upon completion thereof. VII. COMPANY REPRESENTATIVES FOR NOTIFICATION SiEnergy s authorized representatives are: June M. Dively SiEnergy, LP 3 Lakeway Centre CT, Suite 110 Lakeway, Texas Janet M. Simpson Dively Energy Services 3 Lakeway Centre CT, Suite 110 Lakeway, Texas and Ann M. Coffin Kate Norman Coffin Renner LLP P.O. Box Austin, Texas (fax) VIII. REQUEST FOR APPROVAL OF PROTECTIVE ORDER The Company s Rate Filing Package includes certain confidential materials. In addition, the scope of discovery in this case may require the production of additional confidential material. Accordingly, SiEnergy attaches as Exhibit F to this Statement of Intent a proposed Protective Order and respectfully requests that the Commission issue an order approving the Protective Order. SiEnergy will provide confidential material upon execution of Exhibit A attached to the Protective Order. 8

10 IX. CONCLUSION SiEnergy requests that the Commission: (1) approve rates and tariffs consistent with those proposed herein to become effective for bills rendered on and after February 9, 2018; (2) approve new depreciation rates for the Company's plant in service; (3) approve the prudence of the Company's capital investment through September 30, 2017; (4) issue a favorable public interest determination regarding the equity transaction described in this Statement of Intent; ( 5) authorize the Company to amortize its acquisition adjustment; ( 6) authorize the Company to recover all reasonable rate case expenses incurred in connection with this Statement of Intent filing; and (7) grant such further relief to which the Company may be entitled. Kate Norman State Bar No Coffin Renner LLP P.O. Box Austin, Texas (fax) ann.coffin@crtxlaw.com kate.norman@crtxlaw.com ATTORNEYS FOR SIENERGY, LP 9

11 SIENERGY, LP SOI Exhibit A Page 1 of 37 Rate Schedule TOC TOC - TABLE OF CONTENTS Applicable to: Entire System Effective Date: February 9, 2018 Page 1 of 1 Rate Schedules TOC SA DEF MFD RSI RSU GSSI GSSU PGA WNA RCE PSF TFF QSR Table of Contents Service Areas and Applicability of Rate Schedules Definitions Miscellaneous Fees and Deposits Residential Sales, Incorporated Areas Residential Sales, Unincorporated Areas General Service Small, Incorporated Areas General Service Small, Unincorporated Areas Purchased Gas Adjustment Weather Normalization Adjustment Rate Case Expense Pipeline Safety Fee Taxes and Franchise Fees Quality of Service Rules Communications regarding this Tariff should be addressed to: SiEnergy, LP, 3 Lakeway Centre Court Blvd, Ste 110, Lakeway, Texas 78734

12 SIENERGY, LP SOI Exhibit A Page 2 of 37 Rate Schedule SA SERVICE AREAS AND APPLICABILITY OF RATE SCHEDULES Applicable to: Entire System Effective Date: February 9, 2018 Page 1 of 2 Tariff Applicability SiEnergy, LP is a gas utility operating within the State of Texas. The Company will provide service to any person and/or business within its service area in accordance with the rates, terms and conditions provided for in this Tariff, inclusive of the Company s Rate Schedules and Rules of Service. This Tariff supersedes and replaces all tariffs previously approved, other than to the extent to which different tariffs are required to be in effect based upon the rate making actions of a municipality. Determination of Rate Schedules Applicable to Individual Customers Customers will be assigned to rate schedules in accordance with the class of the particular Customer (i.e., Residential or General Service Small) based on the usage that will be made of the gas and that Customer s volume requirements. The Company will advise the Applicant or Customer regarding the most advantageous rate for his usage if more than one rate is applicable. A Customer assigned to a rate schedule will remain on that schedule for a minimum of one (1) year except that an assignment made in error may be corrected immediately. In the event of a question regarding the Customer s classification, the questions will be resolved by reference to the coding of the Customer s primary business in the latest edition of the Standard Industrial Classification Manual of the United States Government s Office Management and Budget. Special Contract Rate Customers Any Customer other than a Residential Customer who expects to use in excess of 30,000 Ccf per year may enter into a separate contract with the Company for the provision of Gas Service or may elect to receive service under Rate Schedule GSSI if located in an incorporated area or under Rate Schedule GSSU if located in an unincorporated area.

13 SIENERGY, LP SOI Exhibit A Page 3 of 37 Rate Schedule SA SERVICE AREAS AND APPLICABILITY OF RATE SCHEDULES Applicable to: Entire System Effective Date: February 9, 2018 Page 2 of 2 Service Areas This Tariff applies to all of SiEnergy, LP s service areas both inside municipalities (incorporated areas) and their environs (unincorporated areas). Within incorporated areas, service under this Tariff is subject to the original jurisdiction of the applicable municipalities and subject to the appellate jurisdiction of the Railroad Commission of Texas. In unincorporated areas, service under this Tariff is subject to the original jurisdiction of the Railroad Commission of Texas. To the extent possible, for each class of Customers, the same rates and rules apply for locations served by the Company, whether incorporated or unincorporated; however, because municipalities have original jurisdiction within their incorporated areas, from time to time, municipalities may approve or require rates and/or rules that differ from the system-wide rates and rules applicable to the remainder of the Company s system. Accordingly, each Rate Schedule included in this Tariff is identified as applicable to one of the following: (1) The Entire system, (2) Locations Subject to System Wide Rates, or (3) Individual Municipalities Locations Subject to System-wide Rates Include the following: Area Incorporated (Municipalities) Unincorporated (Environs) South Texas Missouri City Environs of Missouri City South Texas Fulshear Environs of Fulshear South Texas Sugarland Environs of Sugarland South Texas Conroe Environs of Conroe South Texas Environs of Richmond South Texas Environs of Cypress South Texas Other Fort Bend County Unincorporated South Texas Other Harris County Unincorporated South Texas Other Waller County Unincorporated Central Texas None Environs of Pflugerville Central Texas Other Travis County Unincorporated Locations Subject to Separate Rates and Rules Determined by Individual Municipality None

14 SIENERGY, LP SOI Exhibit A Page 4 of 37 Rate Schedule DEF DEFINITIONS Applicable to: Entire System Effective Date: February 9, 2018 Page 1 of 3 Applicant means any person, organization or group of persons or organizations making a formal request either orally or in writing for gas service from the Company. Btu means British thermal unit(s) and will be calculated on a temperature base of sixty degrees (60 ) Fahrenheit and at the standard pressure base of the applicable service area and on a grossreal-dry basis and will not be corrected for real water vapor as obtained by means commonly acceptable to the industry, and MMBtu will mean one million (1,000,000) Btu. Ccf and Mcf means for Ccf, one hundred (100) Standard Cubic Feet of Gas, where one Standard Cubic Foot of gas is the amount of gas contained in one (1) cubic foot of space at a standard pressure of fourteen and sixty-five hundredths (14.65) pounds per square inch, absolute and a standard temperature of sixty (60) degrees Fahrenheit; and, for Mcf, one thousand (1,000) Standard Cubic Feet of Gas. Commission or The Commission means the Railroad Commission of Texas. Commodity Cost of Gas means the portion of the cost of gas service recovered by the Company through any Purchased Gas Adjustment Rate Schedule. Company means SiEnergy, LP, its successors, and its assigns. Consumer means any person or organization receiving gas service from the Company for his or her own appliances or equipment whether or not the gas is billed directly to him or her. (For example, a rental unit where the utilities are part of the rent, the landlord is a Customer and the tenant is a Consumer.) Customer means any person or organization being billed for gas service whether used by him or her, or by others. Customer also means a Consumer that subscribes to natural gas services provided by SiEnergy. Consumption means the volumes consumed by a Customer during a volumetric read period.

15 SIENERGY, LP SOI Exhibit A Page 5 of 37 Rate Schedule DEF DEFINITIONS Applicable to: Entire System Effective Date: February 9, 2018 Page 2 of 3 Expedited Service means a Customer request for same day or other acceleration of service relative to the Company s standard scheduling process. Gas or Natural Gas means the effluent vapor stream in its natural, gaseous state, including gas-well gas, casing head gas, residue gas resulting from processing both casing head gas and gas-well gas, and all other hydrocarbon and non-hydrocarbon components thereof. General Gas Service means all service other than Residential Gas Service and that includes purchase of the Commodity Cost of Gas from the Company. General Gas Service Consumers include commercial Consumers engaged in the sale or furnishing of goods and services; industrial Consumers engaged primarily in processes that change raw or unfinished materials into another form of product; public authorities, including all governmental agencies and authorities; schools whether public or privately held; and, Consumers utilizing gas for any other purpose not otherwise provided for herein. General Service Customer means any person, individual, family, partnership, association, joint venture, corporation, etc., or governmental agency or organization being billed for General Gas Service. A General Service Customer also includes any Consumer that subscribes to natural gas services provided by SiEnergy for purposes of General Gas Service. Month means the period beginning at 9:00 a.m. Central clock time on the first Day of each calendar month and ending at 9:00 a.m. Central clock time on the first Day of the next succeeding calendar month. Overtime Fee means the fee charged by the Company to perform work outside its normal business hours or on holidays and includes changes to previously scheduled work that must be performed outside Company s normal business hours. Rate Schedule means a statement of the method of determining charges for gas service, including the conditions under which such method applies. Regulatory Authority means the City Council or equivalent municipal governing body of each respective city in the Company s Service Area, or the Railroad Commission of Texas, as applicable.

16 SIENERGY, LP SOI Exhibit A Page 6 of 37 Rate Schedule DEF DEFINITIONS Applicable to: Entire System Effective Date: February 9, 2018 Page 3 of 3 Residential Gas Service means gas service used directly for domestic purposes including heating, air conditioning, cooking, water heating, pool water heating and other similar purposes, whether in a single dwelling, in a dwelling unit of a multiple dwelling facility, in a residential apartment unit, in a condominium unit, in a dwelling unit that is operated by a public housing agency acting as an administrator of public housing under the direction of the U.S. Department of Housing and Urban Development, or in other similar individual dwelling units. Residential Customer means any person, individual, family, partnership, association, joint venture, corporation, etc., or governmental agency or organization being billed for Residential Gas Service that is individually metered at the point of delivery, whether such service is used by that Customer or by others. A Residential Customer also includes any Consumer that subscribes to natural gas services provided by SiEnergy for purposes of Residential Gas Service. Service Area means the area receiving gas utility service provided by the Company under the terms of this Tariff. Special Rate Schedule means a rate schedule designed for a specific Customer. System means any group of interconnected pipelines and appurtenances owned or operated by the Company and independent from any other such group of facilities. Tariff means every rate schedule, or provision thereof, and all terms, conditions, rules and regulations for furnishing gas service filed with the regulatory authorities or agencies having jurisdiction over the Company or the services provided hereunder. Temporary means any service that will not be utilized continuously at the same location by the same Customer. Year means a period of three hundred sixty-five (365) consecutive Days, or three hundred sixty-six (366) consecutive Days when such period includes a February 29.

17 SIENERGY, LP SOI Exhibit A Page 7 of 37 Rate Schedule M RATE M MISCELLANEOUS FEES AND DEPOSITS Applicable to: All Customers Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 1 of 4 Application of Schedule This Schedule is applicable to all Customers who are located in the incorporated or unincorporated areas listed under Rate Schedule 2-GEN Service Areas, Section or Section The fees and deposits listed shall be assessed in addition to any other charges applicable under the Company s Tariff for Gas Service and will be applied for the conditions and services described. Other services not covered by these standard conditions will be charged on the basis of an estimate for the job or the Company s actual cost plus appropriate surcharges. Missed Appointments If a Customer makes an appointment with the Company for the provision of any of the following services, but fails to appear, the applicable fee will be assessed for the missed appointment(s) as well as being assessed when the service is ultimately provided. Number Name and Description Amount Connection/Reconnection Charge During Business Hours During standard business hours, for each reconnection of gas service where service has been discontinued at the same premises for any reason, for the initial inauguration of service, and for each inauguration of service when the M.1 billable party has changed, with the following exceptions: For a builder who uses gas temporarily during construction or for $ display purposes; Whenever gas service has been temporarily interrupted because of System outage or service work done by Company; or For any reason deemed necessary for Company operations. M.2 Connection/Reconnection Charge After Business Hours After standard business hours, for each reconnection of gas service where service has been discontinued at the same premises for any reason, for the initial inauguration of service, and for each inauguration of service when the billable party has changed, with the following exceptions: For a builder who uses gas temporarily during construction or for display purposes; Whenever gas service has been temporarily interrupted because of System outage or service work done by Company; or For any reason deemed necessary for Company operations. $ 97.00

18 SIENERGY, LP SOI Exhibit A Page 8 of 37 Rate Schedule M RATE M-1 MISCELLANEOUS FEES AND DEPOSITS Applicable to: All Customers Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 2 of 4 M.3 M.4 M.5 M.6 M.7 M.8 M.9 Field Read of Meter Charge to an existing Customer for the Company to read the meter at a currently served location at the request of the existing Customer for any purpose other than connection or reconnection of service by that Customer. For charges to a Customer to initiate or reconnect service, refer to Service Charge 1 Connection/Reconnection and Service Charge 2 Connection /Reconnection After Business Hours. Returned Check Charges Returned check handling charge for each check returned to Company for any reason. Temporary Discontinuance of Service Whenever service has been temporarily disconnected at the request of the Customer, this charge plus the appropriate Connection Charge will be made to reestablish such service for that Customer at the same address. Suspension of Disconnection This fee will be charged if a Customer responds to a delinquent notice after the delinquent due date but prior to completion of a scheduled disconnection and if, at the Company s sole discretion the Company is able to terminate the disconnection order without unreasonably disrupting its scheduled work flow. Meter Testing The Company shall, upon request of a Customer, make a test of the accuracy of the meter serving that Customer. The Company shall inform the Customer of the time and place of the test and permit the Customer or his authorized representative to be present if the Customer so desires. If no such test has been performed within the previous four (4) years for the same Customer at the same location, the test shall be performed without charge. If such test has been performed for the same Customer at the same location within the previous four (4) years, the Company will charge the Meter Testing Fee. The Customer must be properly informed of the result of any test on a meter that services him. Charge for Service Calls During Business Hours A Service Call Charge is made for responding to a service call during standard business hours that is determined to be a Customer related problem rather than a Company or Company facilities problem. Charge for Service Calls After Business Hours A Service Call Charge is made for responding to a service call after standard business hours that is determined to be a Customer related problem rather than a Company or Company facilities problem. $ $ $ $ $ $ $ 90.00

19 SIENERGY, LP SOI Exhibit A Page 9 of 37 Rate Schedule M RATE M MISCELLANEOUS FEES AND DEPOSITS Applicable to: All Customers Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 3 of 4 M.10 M.11 M.12 M.13 M.14 M.15 M.16 Tampering Charge No Company Meters, equipment, or other property, whether on Customer s premises or elsewhere, are to be tampered with or interfered with for any reason. A Tampering Charge is made for unauthorized reconnection or other tampering with Company metering facilities or a theft of gas service by a person on the Customer s premises or evidence by whomsoever at Customer s premises. An additional cost for the cost of repairs and/or replacement of damaged facilities and the installation of protective facilities or relocation of meter are made at cost plus appropriate charges as may be detailed in the Company s Service Rules and Regulations. Credit/Debit Card Payments Charge Bill payments using credit cards, debit cards, and electronic checks (includes third-party transaction fees and administrative costs). Pool or Upgraded Meter Installation Charge Fee to install meter and regulators to support higher or multiple pressure requirements on a residential service line. Expedited Service and Overtime Fee A Customer s request for expedited service may be scheduled at any time to fit the Company s work schedule, and an Expedited Service charge will be collected. The Company will not be obligated to provide Expedited Service when the personnel and resources to do so are not reasonably available. This Fee represents the minimum charge for Expedited Service. For Expedited Service requiring more than one hour to perform, the Fee will represent a rate per hour of time multiplied by the total time required to perform the requested Expedited Service, incremented in 15-minute intervals. This fee will be charged in addition to any other applicable fees. History Research Fee A fee will be charged for services related to account history research and/or provision of Customer accounting/billing history documentation. No Access Fee A fee will be charged to a Customer who, through padlocks, fencing, animals or other means, prevents access to the Company s meter or other equipment located on the Customer s premise. Police Escort Fee A fee will be charged for the Company to access a meter when the Company is required to use law enforcement personnel to escort it into locked sites or sites requiring animal control. The Company will charge the stated amounts or current rate charged by the entity providing the police escort for this service. $ Actual Cost $ $ $ $ Actual Cost

20 SIENERGY, LP SOI Exhibit A Page 10 of 37 Rate Schedule M RATE M MISCELLANEOUS FEES AND DEPOSITS Applicable to: All Customers Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 4 of 4 M.17 M.18 M.19 Costs Associated with Certain Stand-By Gas Generators Customers installing stand-by gas generators to provide service in the event of an interruption in electric service in facilities where gas service is not otherwise adequate to operate the stand-by gas generators will reimburse the Company for the actual cost of acquiring and installing the additional and/or upgraded regulator, service line, and meter required to provide gas service for the standby generators. The subsequent gas service provided for the stand-by generators will be billed at the rate applicable for other gas service to the class of Customer making the request. Line Extensions The Company has the right to contract with individual Customers for the installation of gas facilities. Upon the request of a prospective new Customer for service in an area served by SiEnergy, LP, SiEnergy, LP will extend its main lines up to 100 feet from an existing SiEnergy, LP main in the Public Rights of Way, without charge. The 100-foot allowance applies to a single Customer or to a group of Customers requesting service from the same extension. Customers requesting mainline extensions in excess of 100 feet shall bear the actual cost of any additional mainline, the cost of all yard and service lines, and the cost of any appurtenant equipment and other costs necessary to install the extension, including applicable overhead charges. SiEnergy, LP is not required to extend its mains or facilities if the Customer will not use gas for space heating and water heating, or the equivalent load, at a minimum. Customer Deposits Minimum deposit Residential Gas Service Minimum deposit General Gas Service Additional deposits may be required in accordance with Rate Schedule QSR Quality of Service Rules Actual Cost Actual Cost $ $ Taxes and Franchise Fees (Rate Schedule TFF) Other than with respect to M.19 Customer Deposits, the amounts charged under Rate M are subject to all applicable taxes and fees in accordance with the provisions of Rate Schedule TFF Taxes and Franchise Fees.

21 SIENERGY, LP SOI Exhibit A Page 11 of 37 Rate Schedule RSI RATE RSI - RESIDENTIAL SALES, INCORPORATED AREAS Applicable to: All Residential Customers Located in Incorporated Areas that are Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 1 of 1 Application of Schedule This Schedule is applicable to all Customers meeting the definition of Residential Customers under Rate Schedule DEF Definitions who are located in incorporated areas that are subject to system wide rates as identified on Rate Schedule SA. Monthly Base Rate Each Customer s base monthly bill will be calculated using the following Customer and Ccf charges: Charge Customer Charge All Amount $19.50 per month, plus $.4684 per Ccf In addition to the base monthly bill calculated using the Monthly Base Rates above, each Customer s monthly bill shall be increased by amounts pursuant to the following: Purchased Gas Adjustment (Rate Schedule PGA) Amounts billed for the commodity cost of gas in accordance with the provisions of Rate Schedule PGA - Purchased Gas Adjustment. Weather Normalization Adjustment (Rate Schedule WNA) Amounts billed to eliminate the effect of non-normal weather in accordance with the provisions of Rate Schedule WNA Weather Normalization Adjustment. Rate Case Expense Recovery (Rate Schedule RCE) Amounts billed for the recovery of rate case expenses in accordance with the provisions of Rate Schedule RCE Rate Case Expense. Taxes and Franchise Fees (Rate Schedule TFF) All applicable taxes and fees in accordance with the provisions of Rate Schedule TFF Taxes and Franchise Fees, including fees pertaining to the Monthly Base Rate bill, PGA charges, WNA charges, RCE charges, and any other charge that is subject to taxes and fees described therein. Other Conditions and Surcharges Subject in all respects to applicable laws, rules and regulations from time to time in effect. In addition to the monthly charges above, each Customer s bill will include amounts required to be billed in accordance with any additional applicable rates, riders, surcharges or fees.

22 SIENERGY, LP SOI Exhibit A Page 12 of 37 Rate Schedule RSU RATE RSU - RESIDENTIAL SALES, UNINCORPORATED AREAS Applicable to: All Residential Customers Located in Unincorporated Areas that are Subject to System Wide Rates as Identified on Rate Schedule SA Effective Date: February 9, 2018 Page 1 of 1 Application of Schedule This Schedule is applicable to all Customers meeting the definition of Residential Customers under Rate Schedule DEF Definitions who are located in unincorporated areas that are subject to system wide rates as identified on Rate Schedule SA. Monthly Base Rate Each Customer s base monthly bill will be calculated using the following Customer and Ccf charges: Charge Customer Charge All Amount $19.50 per month, plus $.4684 per Ccf In addition to the base monthly bill calculated using the Monthly Base Rates above, each Customer s monthly bill shall be increased by amounts pursuant to the following: Purchased Gas Adjustment (Rate Schedule PGA) Amounts billed for the commodity cost of gas in accordance with the provisions of Rate Schedule PGA - Purchased Gas Adjustment. Weather Normalization Adjustment (Rate Schedule WNA) Amounts billed to eliminate the effect of non-normal weather in accordance with the provisions of Rate Schedule WNA Weather Normalization Adjustment. Rate Case Expense Recovery (Rate Schedule RCE) Amounts billed for the recovery of rate case expenses in accordance with the provisions of Rate Schedule RCE Rate Case Expense. Taxes and Franchise Fees (Rate Schedule TFF) All applicable taxes and fees in accordance with the provisions of Rate Schedule TFF Taxes and Franchise Fees, including fees pertaining to the Monthly Base Rate bill, PGA charges, WNA charges, RCE charges, and any other charge that is subject to taxes and fees described therein. Other Conditions and Surcharges Subject in all respects to applicable laws, rules and regulations from time to time in effect. In addition to the monthly charges above, each Customer s bill will include amounts required to be billed in accordance with any additional applicable rates, riders, surcharges or fees.

23 SIENERGY, LP SOI Exhibit A Page 13 of 37 Schedule GSSI RATE GSSI GENERAL SERVICE SMALL, INCORPORATED AREAS Applicable to: All General Service Customers Located in Incorporated Areas that are Subject to System Wide Rates as Identified on Rate Schedule SA and whose Annual Usage is 30,000 Ccf or less. Effective Date: February 9, 2018 Page 1 of 1 Application of Schedule This Schedule is applicable to all Customers meeting the definition of General Service Customers under Rate Schedule DEF Definitions (i.e., non-residential Customers) who are located in incorporated areas that are subject to system wide rates as identified on Rate Schedule SA and whose annual usage is 30,000 Ccf or less. Monthly Base Rate Each Customer s base monthly bill will be calculated using the following Customer and Ccf charges: Charge Customer Charge All Amount $45.00 per month, plus $.5698 per Ccf In addition to the base monthly bill calculated using the Monthly Base Rates above, each Customer s monthly bill shall be increased by amounts pursuant to the following: Purchased Gas Adjustment (Rate Schedule PGA) Amounts billed for the commodity cost of gas in accordance with the provisions of Rate Schedule PGA - Purchased Gas Adjustment. Rate Case Expense Recovery (Rate Schedule RCE) Amounts billed for the recovery of rate case expenses in accordance with the provisions of Rate Schedule RCE Rate Case Expense. Taxes and Franchise Fees (Rate Schedule TFF) All applicable taxes and fees in accordance with the provisions of Rate Schedule TFF Taxes and Franchise Fees, including fees pertaining to the Monthly Base Rate bill, PGA charges, WNA charges, RCE charges, and any other charge that is subject to taxes and fees described therein. Other Conditions and Surcharges Subject in all respects to applicable laws, rules and regulations from time to time in effect. In addition to the monthly charges above, each Customer s bill will include amounts required to be billed in accordance with any additional applicable rates, riders, surcharges or fees.

24 SIENERGY, LP SOI Exhibit A Page 14 of 37 Schedule GSSU RATE GSSU GENERAL SERVICE SMALL, UNINCORPORATED AREAS Applicable to: All General Service Customers Located in Unincorporated Areas that are Subject to System Wide Rates as Identified on Rate Schedule SA and whose annual usage is 30,000 Ccf or less. Effective Date: February 9, 2018 Page 1 of 1 Application of Schedule This Schedule is applicable to all Customers meeting the definition of General Service Customers under Rate Schedule DEF Definitions (i.e., non-residential Customers) who are located in unincorporated areas that are subject to system wide rates as identified on Rate Schedule SA and whose annual usage is 30,000 Ccf or less. Monthly Base Rate Each Customer s base monthly bill will be calculated using the following Customer and Ccf charges: Charge Customer Charge All Amount $45.00 per month, plus $.5698 per Ccf In addition to the base monthly bill calculated using the Monthly Base Rates above, each Customer s monthly bill shall be increased by amounts pursuant to the following: Purchased Gas Adjustment (Rate Schedule PGA) Amounts billed for the commodity cost of gas in accordance with the provisions of Rate Schedule PGA - Purchased Gas Adjustment. Rate Case Expense Recovery (Rate Schedule RCE) Amounts billed for the recovery of rate case expenses in accordance with the provisions of Rate Schedule RCE Rate Case Expense. Taxes and Franchise Fees (Rate Schedule TFF) All applicable taxes and fees in accordance with the provisions of Rate Schedule TFF Taxes and Franchise Fees, including fees pertaining to the Monthly Base Rate bill, PGA charges, WNA charges, RCE charges, and any other charge that is subject to taxes and fees described therein. Other Conditions and Surcharges Subject in all respects to applicable laws, rules and regulations from time to time in effect. In addition to the monthly charges above, each Customer s bill will include amounts required to be billed in accordance with any additional applicable rates, riders, surcharges or fees.

25 SIENERGY, LP SOI Exhibit A Page 15 of 37 Rate Schedule PGA RATE PGA PURCHASED GAS ADJUSTMENT Applicable to: Entire System. Effective Date: November 13, 2008 Page 1 of 4 Application of Schedule This Rate Schedule shall apply to all SiEnergy Rate Schedules that incorporate this Rate PGA - Purchased Gas Adjustment provision. Purpose and Intent This provision is intended to allow collection of the gas purchase costs of SiEnergy, L.P., (hereinafter SiEnergy or the Company ) in a manner that will lessen monthly fluctuations in the Purchased Gas Adjustment and ensure that actual costs billed to Customers are fully reconciled with actual costs incurred, subject to limitations for excessive lost and unaccounted-for gas. The billing methods set forth herein are intended to be followed to the extent the goals are realized. To the extent billing methods fail to achieve these goals, the methodology shall be revised and a revised tariff filed to reflect such revisions. SiEnergy will make appropriate regulatory filings and obtain regulatory approvals, as required, before making changes to its rates. Definitions Purchased Gas Volumes - The volumes of gas, expressed in Mcfs, purchased by the Company and received into the Company s distribution systems from all sources, including withdrawals from storage, and excluding gas injected into storage. Purchased Gas Cost(s) - The total cost of Purchased Gas Volumes, as received into the Company s distribution systems, all as more specifically described herein. Weighted Average Cost of Gas - The Purchased Gas Costs divided by the Purchased Gas Volumes, calculated on a monthly basis, and expressed as dollars per Mcf. Billed Gas Volumes - The volumes of gas billed to Customers, plus volumes of gas billed to third parties following losses or damages, expressed in Mcfs. Billed Gas Revenues - The total amount of revenues attributable to billings by SiEnergy for Purchased Gas Costs during a given period, exclusive of any billings for any Reconciliation Adjustment during the same period.

26 SIENERGY, LP SOI Exhibit A Page 16 of 37 Rate Schedule PGA RATE PGA PURCHASED GAS ADJUSTMENT Applicable to: Entire System. Effective Date: November 13, 2008 Page 2 of 4 Lost and Unaccounted-for Gas (LUG) - Purchased Gas Volumes minus the sum of Billed Gas Volumes and metered Company used gas. Purchased Gas Adjustment (PGA) - An Adjustment on each Customer s monthly bill, expressed in dollars per Ccf, to reflect the Purchase Gas Costs and the Reconciliation Adjustment, all as more specifically described herein. Annual Review Period - The 12-month period ending June 30 of each year. Annual Review - An annual review of the Company s records covering the 12-month period ending June 30 to determine LUG volumes and any imbalances between the Purchased Gas Costs and Billed Gas Revenues existing at the end of the Annual Review Period. Annual Imbalance Total - The total amount determined through the Annual Review to be credited or surcharged to Customers bills in order to balance Purchased Gas Costs with Billed Gas Revenues. Reconciliation Adjustment - A credit or surcharge included in the Purchased Gas Adjustment to reflect the pro-rated adjustment in billings for any over or under collections on an annual basis. Record Keeping The Company shall keep accurate records of all gas metered in and out of its system, gas purchases, and Company-owned gas injected into and withdrawn from storage, and any adjustments relative to any imbalances. The records shall include date, quantity, and cost details for all gas handled. Purchased Gas Cost Calculation The Purchased Gas Cost shall be determined for each month to fairly and accurately reflect the cost to the Company at the points of delivery into the Company s distribution systems. The determination shall include, but not be limited to, volumetric and demand charges for Purchased Gas Volumes, fees paid to others where such fees are integrally tied to the purchase or transportation of gas purchased by SiEnergy, pipeline transportation charges (both volumetric and demand), and gas storage charges (both volumetric and demand). The Company shall account for gas injected into and withdrawn from storage on a weighted average cost basis.