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R-2018-5914 - 9/27/2018 RESOLUTION NO. R-2018-5914 RESOLUTION BY THE CITY OF ROUND ROCK, TEXAS ("CITY") DENYING A PROPOSED INCREASE SOUGHT BY ATMOS ENERGY-MIDTEX DIVISION IN CONNECTION WITH THE RATE INCREASE FILING IT MADE ON ABOUT JUNE 19 2018; APPROVING AN ALTERNATIVE INCREASE IN RATES; DIRECTING ATMOS TO FILE CONFORMING TARIFFS AND TO REIMBURSE THE CITY'S RATE CASE EXPENSES; MAKING OTHER FINDINGS AND PROVISIONS RELATED TO THE SUBJECT; FINDING THAT THE MEETING COMPLIES WITH THE OPEN MEETINGS ACT; AND DECLARING AN EFFECTIVE DATE WHEREAS, Atmos Energy ("Atmos Energy," "Atmos," or "Company") filed a Statement of Intent with the City on or about June 1, 2018, to increase its annual revenue by approximately $4.5 million in the cities known as Atmos Texas Municipalities ("ATM"), which equates to an increase in annual revenue of approximately 8.0 percent, and is the equivalent of an increase of about $46.0 million on a system-wide basis; and WHEREAS, the City is a regulatory authority under the Gas Utility Regulatory Act ("GURA") and under Chapter 104, §103.001 et seq. of GURA has exclusive original jurisdiction over Atmos's rates, operations, and services within the municipality; and WHEREAS, in order to maximize the efficient use of resources and expertise in reviewing, analyzing and investigating Atmos's rate request and its changes in tariffs it is prudent to coordinate the City's efforts with a coalition of similarly situated municipalities; and WHEREAS, the City, in matters regarding applications by Atmos to change rates, has in the past joined with other local regulatory authorities to form an alliance of cities known as Atmos Texas Municipalities ("ATM"), and hereby continues its participation in ATM; and 1 of 6 0112.1804;00409578 Atmos MidTex 2018 Statement of Intent Final Action WHEREAS, Atmos's rate request consists of a voluminous amount of information including Atmos's rate-filing package, exhibits, schedules, and workpapers; and WHEREAS, Atmos's rate application is the Company's first general rate case since about 2012, and follows annual increases approved under the now-expired tariff known as the "Rate Review Mechanism" ("RRM"); and WHEREAS, Atmos proposed July 6, 2018, as the effective date for its requested increase in rates; and WHEREAS, the City previously suspended Atmos' proposed effective from July 6, 2018, to October 4, 2018; and WHEREAS, the City, exercising its duties as a local regulatory authority with regard to Atmos' rates, services, and operations, through ATM engaged the law firm of Herrera Law & Associates as Special Counsel and rate experts from the consulting firms of the Garrett Group, LLC, GDS and Associates, Inc., and J. Randall Woolridge, Ph.D, to review Atmos' rate filing package; and WHEREAS, Atmos failed to establish the need for an increase of about $46 million and the specific rates Atmos proposed; and WHEREAS, merits at most an increase of about $12.81 million, which is approximately an increase of$1.25 million in the ATM cities, and the specific rates set forth in Exhibit A to this Resolution, and made a part of this Resolution as if fully set out in its body; and WHEREAS, Atmos failed to establish the reasonableness of its proposed rate design; and WHEREAS, a reasonable rate design is as set forth in Exhibit A; and 2 of 6 WHEREAS, Atmos failed to establish the reasonableness of its proposed cost of capital, including Atmos' proposed capital structure; and WHEREAS, a reasonable cost of capital and capital structure is as set forth in Exhibit A to this Resolution; and WHEREAS, pursuant to Gas Utility Regulatory Act § 103.022, cities have a statutory right to recover their reasonable rate case expenses. NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ROUND ROCK, TEXAS THAT: Section 1. The findings set out in the preamble are in all things approved and incorporated herein as if fully set forth. Section 2. Atmos failed to establish that its requested increase in revenue of about $46 million, and its proposed changes in rates as set forth in its Statement of Intent submitted to the City on about June 1, 2018, result in just and reasonable rates, and are therefore, hereby DENIED. Section 3. An increase of about $12.81 million as shown in Exhibit A, and as detailed in Exhibit B to this Resolution, each of which is hereby incorporated by reference, and the rates shown below, are hereby APPROVED, to wit: Approved Increase in Annual Revenue(System Wide—MidTex Division) $12,807,858 Customer Class/Rate APPROVED RATE Rate R-Residential Customer Charge per month $17.89 Consumption Charge(per CCF) $0.16052 Rate C-Commercial Customer Charge per month $37.85 3 of 6 Consumption Charge(per CCF) $0.10081 Rate I& T—Indus.&Transp. Customer Charge per month $619.85 Consumption Chrg-First 1,500 MMBTU $0.3655 Consumption Chrg-Next 3,500 MMBTU $0.2908 Consumption Chrg-Over 5,000 MMBTU $0.0761 Section 4. A rate-case-expense surcharge ("RCE Surcharge") as shown below to allow Atmos to recover the City's rate case expenses is hereby APPROVED, said surcharge per class to be in effect for a period of five (5) years: Rate Class RCE Surcharge Residential $0.00030 per ccf Commercial $0.00011 per ccf Industrial & Transportation $0.0001 per MMbtu Section 5. Atmos is hereby ordered to submit to the City a report detailing the rate- case expenses recovered through the RCE Surcharges, said report to be filed by October 1 of each year until full recovery of the rate case expenses and in no event is Atmos permitted to recover in excess of the rate case expenses approved by this Resolution. Section 6. Atmos' requested return on equity of 10.50% and its proposed capital structure of 60.18% equity and 39.82% long-term debt, are hereby DENIED. Section 7. A return on equity of 9.80%; a cost of long-term debt of 5.45%; and a cost of short-term debt of 1.68%, are hereby APPROVED. Section 8. A capital structure of 53.81% equity; 38.98% long-term debt; and 7.21% short-term debt, yielding a weighted cost of capital of 7.5189%, are hereby APPROVED. Section 9. Atmos is hereby ordered to reimburse the City's rate case expenses incurred as a member of the Atmos Texas Municipalities ("ATM") through August 31, 4 of 6 20185 as set forth in Exhibit B, by no later than thirty (30) days from the effective date of this Resolution. Section 10. Atmos is hereby ordered to reimburse the City's rate case expenses incurred after August 31, 2018, for the City's reasonable costs associated with the City's continued activities related to this rate review or related to proceedings involving Atmos in proceedings before the City or any ATM city, the Railroad Commission of Texas, or any court of law, and that Atmos shall do so on a monthly basis and within 30 days after submission of the City's invoices to Atmos. Section 11. Atmos is directed to submit to the City a set of tariffs modified to correspond to the rates approved by this Resolution and that it do so by no later than fifteen (15) calendar days after the effective date of this Resolution, said submittal to be accompanied by an affidavit from an officer of Atmos Energy attesting that the rates presented in the modified tariffs are in accordance with the rates approved by this Resolution. Section 12. The City shall continue its participation in a coalition of cities known as the Atmos Texas Municipalities ("ATM"), and authorizes intervention in proceedings related to Atmos' Statement of Intent before the Railroad Commission of Texas and related proceedings in courts of law that may have an impact on rates within the City; and Section 13. Subject to the right to terminate employment at any time, the City continues its engagement of and authorizes the law firm of Herrera Law & Associates, PLLC to act as Special Counsel with regard to rate proceedings involving Atmos before the City, the Railroad Commission of Texas, or any court of law, and to retain such experts as may be reasonably necessary for review of Atmos's rate application in such proceedings and subject to approval by the steering committee of the ATM. Section 14. Any relief not expressly granted or approved by this Resolution is expressly denied. 5 of 6 Section 15. A copy of this Resolution shall be sent to Mr. Alfred R. Herrera, Herrera Law & Associates, PLLC, 816 Congress Ave., Suite 950, Austin, Texas 78701, and a courtesy copy to Atmos's local representative. Section 16. Atmos shall implement the rates approved by this Resolution beginning October 4, 2018, for service rendered on and after that date. Section 17. To the extent of an inconsistency between this Resolution and a prior ordinance or resolution related to Atmos' rates, this Resolution governs and supersedes all prior ordinances or resolutions related to Atmos' rates. Section 18. The meeting at which this Resolution was approved was in all things conducted in strict compliance with the Texas Open Meetings Act, Texas Government Code, Chapter 551. Section 19. This Resolution shall become effective from and after its passage. RESOLVED this 27th day of September, 2018. CRAIG ORGA ayor City of ound R , Texas ATTEST: SARA L. WHITE, City Clerk 6 of 6 ,':AABIT Atmos Proposed Increase in Annual Revenue ATM City Approved Increase in Annual Revenue (System Wide—MidTex Division) (System Wide—MidTex Division) $45,993,529 $12,807,858 ATMOS: ATM CITY PROPOSED APPROVED Customer Class/Rate CURRENT RATE RATE Rate R-Residential Customer Charge per month $18.35 $20.21 $17.89 Consumption Charge(per CCF) $0.13734 $0.15701 $0.16052 Rate C-Commercial Customer Charge per month $41.95 $41.85 $37.85 Consumption Charge(per CCF) $0.08746 $0.07729 $0.10081 Rate I&T—Indus.&Transp. Customer Charge per month $752.00 $752.00 $619.85 Consumption Chrg-First 1,500 MMBTU $0.3172 $0.2390 $0.3655 Consumption Chrg-Next 3,500 MMBTU $0.2322 $0.1901 $0.2908 Consumption Chrg-Over 5,000 MMBTU $0.0498 $0.0498 $0.0761 Cost of Capital and Capital Structure Atmos Requested ATM City Approved Return on Equity 10.50% 9.80% Cost of Long-Term Debt 5.45% 5.45% Cost of Short- Term Debt 1.68% 1.68% Capital Structure Ratios Atmos Requested ATM City Approved Equity 60.18% 53.81% Long-Term Debt 39.82% 7.21% Short-Term Debt 0.0% 38.98% Weighted Average Cost of Capital(aka, Rate of Return) Atmos Requested ATM City Approved Weighted Cost 8.3876% 7.5189% Pre-Tax Weighted Cost 10.0674% 8.9207% Atmos MidTex 2018 Statement of Intent—June 1,2018—Approved Change in Revenue, Rates,Cost of Capital and Capital Structure 2 EXHIBIT Nl REQU I RE M E i , T SCHEDULES ATMOS ENERGY CORP.,MID-TEX DIVISION ATM COALITION REVENUE REQUI REM ENT SUMMARY TESTYEAR ENDING DECEMBER 31,2017 Atmos Proposed(Note a) ATM Adjustments ATM Proposed Line No. Description Ref. Rate Base/ROR Operating Income (See Schedule B) Operating Income COS (a) (b) (c) (d) (e) (fl 1 Test Year Revenue Requirement: 2 Revenue at Present Rates Schedule $ 1,494,918,603 $ - $ 1,494,918,603 1,494,918,603 3 4 GCR $ 816,965,570 $ 816,965,570 - 816,965,570 5 6 Operation and Maintenance Expenses Schedule F-1 $ 188,642,689 $ (1,299,845) $ 187,342,844 - 187,342,844 7 8 Taxes Other than lncomeTax-Non-Revenue Related Schedule F-5 43,711,991 $ 43,711,991 - 43,711,991 9 10 Revenue Related Taxes 96,255,692 (2,054,831) $ 94,200,861 - 94,200,861 11 12 Depreciation and Amortization Expense Schedule F-3 144,321,772 $ 144,321,772 - 144,321,772 13 14 Interest on Customer Deposits Schedule F-7 117,764 $ 117,764 - 117,764 14a 15 Rate Base Schedule $ 2,573,504,828 (830,856) 2,572,673,972 - 2,572,673,972 16 Atmos Rate of Return Schedule 8.388% 17 ATM Rate of Return 7.5189% 0.00% 7.52% 18 Return Requirement $ 215,855,775 $ (22,418,528) $ 193,437,246 - 193,437,246 19 20 IncomeandOtherTaxes Schedule F-6 47,913,915 (7,396,426) 40,517,489 - 40,517,489 21 22 Revenue Requirements L.3...L.20 $ 1,553,785,168 $ (33,169,630) $ 1,520,615,538 - 1,520,615,537 25 26 Base Revenue Deficiency(excluding revenuetaxes) L.22-L.2 $ 58,866,565 $ (33,169,630) $ 25,696,934 $ - $ 25,696,934 27 28 Amortization of Excess ADIT-with Revenue Taxes 12,873,035 16,041 12,889,076 12,889,076 29 30 Proposed Cost of Service-SystemwideAdjustedforExcessADIT $ 45,993,529 (33,185,671) $ 12,807,858 $ $ 12,807,858 5 Exhibit MG-2 Summary ATMOS ENERGYCORP.,MID-TEX DIVISION ATM RECOMMENDATION SUMMARY TESTYEAR ENDING DECEMBER 31,2017 Line Equity/ Pre-Tax Rate No. Description ROE Reference Rate Base ROR Change Requested Amounts $ 2,573,504,828 10.0674% $ 45,993,529 Pension and OPEB Regulatory Asset MG-2.4 $ (20,861) 10.0674% (2,100) Cash Working Capital MG-2.1 $ (66,472) 10.0674% (6,692) Adjustment to ADIT-SEEP Adjustment MG-2.4 (464,794) 10.0674% (46,792) SEBP EDIT Liability Net Adjustment MG-2.4 (278,730) 10.0674% (28,061) Excess ADIT Liability,Net ofADIT 10.0674% - NOL ADIT Regulatory Adjustment 10.0674% - NOL EDIT Liability Net Adjustment 10.0674% - Total Rate Base Adjustments $ (830,856) $ (83,645) Capital Structure and ROE 53.81% MG-2.10 $ 2,572,673,972 -1.1467% (29,499,831) 9.80% - Total Cost of Capital Adjustments (29,499,831) Incentives-Restricted Stock Units MG-2.2 (306,458) Incentives-Annual Incentive Plan MG-2.3 (488,558) Non-Qualified Retirement Plans MG-2.4 (37,089) Injuries and Damages MG-2.5 (216,667) Bad Debt Expense MG-2.1 (251,073) Taxes Other Than Income Tax MG-2.1 (2,054,831) Gross Margin Tax MG-2.1 (231,477) EDIT Amortization SEBP MG-2.4 (15,047) EDIT Amortization @ 12-31-17 EDIT Amortization NOL - EDIT Amortization Flow Through MG-2.1 (994) Total Revenueand Expense Adjustments $ (3,602,194) Toral Revenue Requirement Adjustments $ (33,185,671) Rate lncease(Decrease) $ 12,807,858 6 Exhibit MG-2.10 ATMOS ENERGYCORP., MID-TEX DIVISION COST OF CAPITAL TESTYEAR ENDING DECEMBER 31,2017 Atmos Cost of Capital(Schedule G) P re-Tax Line Capital Cost of Weighted Tax Weighted No. Structure Capital Cost Gross Up Cost 1 Debt 39.82% 5.20% 2.0686% 1 2.0686% 2 Equity 60.18% 10.50% 6.3190% 1.2658228 7.9988% 3 100.00% 8.3876% 10.0674% ATM Recommended Capital Structure Pre-Tax Capital Cost of Weighted Tax Weighted Structure Capital Cost Gross Up Cost 4 LT Debt 38.98% 5.45% 2.1244% 1 2.1244% 5 ST Debt 7.21% 1.68% 0.1211% 1 0.1211% 6 Equity 53.81% 9.80% 5.2734% 1.2658228 6.6752% 7 100.00% 7.5189% 8.9207% 8 Difference -1.1467% ATM Recommended ROE and Capital Structure P re-Tax Capital Cost of Weighted Tax Weighted Structure Capital Cost Gross Up Cost 4 LT Debt 38.98% 5.45% 2.1244% 1 2.1244% 5 ST Debt 7.21% 1.68% 0.1211% 1 0.1211% 6 Equity 53.81% 9.80% 5.2734% 1.2658228 6.6752% 7 100.00% 7.5189% 8.9207% 8 Difference 0.0000% 7 COST ALLOCATION AND RATE DESIGN SCHEDULES ATMOS ENERGY CORP-MID-TEX DIVISION COMPARISON OF BASE RATE CHARGES Atmos Proposed(See Note 1) ATM Proposed(See Note 1) Line Incr./(Deer.) Incr./(Decr.) Incr./(Deer.) Incr./(Decr.) No. Rate Description Current Rate Rate from Current-$ from Current-% Rate from Current-$ from Current-% (a) (b) (C) (d) (e) (f) (g) (h) 1 RateR-Residential 2 Customer Charge(per Bill) $ 18.35 $ 20.21 $ 1.86 10.14% $ 17.89 $ (0.46) -2.52% 3 Consumption Charge(per Ccf) 0.13734 0.15701 0.01967 14.32% 0.16052 0.02318 16.88% 4 RateC-Commercial 5 Customer Charge(per Bill) $ 41.95 $ 41.85 $ (0.10) -0.24% $ 37.85 $ (4.10) -9.78% 6 Consumption Charge(per Ccf) 0.08746 0.07729 (0.01017) -11.63% 0.10081 0.01335 15.26% 7 Rates I and T-Industrial&Transportation 8 Meter Charge $ 752.00 $ 750.07 $ (1.93) -0.26% $ 619.85 $ (132.15) -17.57% 9 Consumption Charge-0 to 1,500 MMBtu 0.3172 0.2390 (0.0782) -24.65% 0.3655 0.0483 15.21% 10 Consumption Charge-Next 3,500 MMBtu 0.2322 0.1901 (0.0421) -18.13% 0.2908 0.0586 25.23% 11 Consumption Charge-All Additional MMBtu 0.0498 0.0498 0.00% 0.0761 0.0263 52.90% Note 1:All proposed charges exclude gas costs,riders and Atmos'proposed Rate Case Expense Surcharge 9 ATMOS ENERGY CORP.,MID-TEX DIVISION ATM RECOMMENDED RATE CASE EXPENSE SURCHARGE Costs Incurred to Date ATM Consulting Garrett Group $ 43,050 GDSAssociates,Inc. 33,753 J.Randell Woodridge 2,600 Total ATM Consulting 79,403 ATM Legal Herrera Law&Associates,PLLC 36,654 Total ATM Legal 36,654 Total Rate Case Expenses to be Recovered $ 116,057 Recovery Period(Years) 5 Annual Recovery $ 23,211 ATM Base Rate Revenue Volumetric Billing Average Monthly Average Monthly Rate Class Req. ATMRCEAIIocation Determinants(1) RCE Surcharge Usage Bill Impact Residential $ 497,923,762 $ 18,825 63,441,015 $ 0.00030 34.60 $ 0.01 Commercial 103,088,213 3,897 35,426,746 0.00011 273.30 $ 0.03 Industrial and Transportation 12,932,750 489 3,554,341 0.0001 4,114.00 $ 0.57 Total $ 613,944,726 $ 23,211 (1)Residential and Commercial volumetric billing determiants are Ccf,1&Tdeterminants are MMBtu. 10 ATMOS ENERGY CORP-MID-TEX DIVISION COMPARISON OF REVENUE DISTRIBUTION TO CUSTOMERS Atmos Proposed ATM Proposed Line Incr./(Decr.) Incr./(Derr.) Incr./(Decr.) Incr./(Derr.) No. Rate Description Current Revenue Revenue from Current $ from Current % Revenue from Current-$ from Current-% (a) (b) (C) (d) (e) (f) (B) (h) 1 RateR-Residential $ 447,851,269 $ 497,926,227 $ 50,074,958 11.18% $ 458,255,829 $ 10,404,560 2.32% 2 RateC-Commercial 108,705,970 103,089,082 (5,616,888) -5.17% 109,855,273 1,149,303 1.06% 3 Rates I and T-Industrial&Transportation 14,243,218 12,932,618 (1,310,600) -9.20% 14,703,776 460,559 3.23% 4 Total $ 570,800,457 $ 613,947,927 $ 43,147,470 7.56% $ 582,814,879 $ 12,014,422 2.10% 11 ATMOS ENERGY CORP-MID-TEX DIVISION COMPARISON OF MONTHLY BASE RATE BILL IMPACTS Atmos Proposed(See Note 1) ATM Proposed(See Note 1) Line Current Base Base Rate Incr./(Derr.) Incr./(Decr.) Base Rate Incr./(Decr.) Incr./(Decr.) No. Rate Description&Usage Level Rate Bill Total Bill Total from Current-$ from Current-% Bill Total from Current-$ from Current-% (a) (b) (C) (d) (e) (f) (g) (h) 1 Rate R-Residential 2 0 Ccf $ 18.35 $ 20.21 $ 1.86 10.14% $ 17.89 $ (0.46) -2.52% 3 20 Ccf 21.10 23.35 2.25 10.68% 21.10 0.00 0.01% 4 50 Ccf 25.22 28.06 2.84 11.28% 25.91 0.70 2.76% 5 70 Ccf 27.96 31.20 3.24 11.58% 29.12 1.16 4.15% 6 100 Ccf 32.08 35.91 3.83 11.93% 33.94 1.86 5.78% 7 120 Ccf 34.83 39.05 4.22 12.12% 37.15 2.32 6.66% 8 160 Ccf 40.32 45.33 5.01 12.42% 43.57 3.25 8.05% 9 180 Ccf 43.07 48.47 5.40 12.54% 46.78 3.71 8.61% 10 200 Ccf 45.82 51.61 5.79 12.65% 49.99 4.17 9.11% 11 RateC-Commercial 12 0 Ccf $ 41.95 $ 41.85 $ (0.10) -0.24% $ 37.85 $ (4.10) -9.78% 13 50 Ccf 46.32 45.71 (0.61) -1.31% 42.89 (3.43) -7.41% 14 100 Ccf 50.70 49.58 (1.12) -2.20% 47.93 (2.77) -5.46% 15 200 Ccf 59.44 57.31 (2.13) -3.59% 58.01 (1.43) -2.41% 16 300 Ccf 68.19 65.04 (3.15) -4.62% 68.09 (0.10) -0.14% 17 400 Ccf 76.93 72.77 (4.17) -5.42% 78.17 1.24 1.61% 18 500 Ccf 85.68 80.50 (5.19) -6.05% 88.25 2.57 3.00% 19 1,000 Ccf 129.41 119.14 (10.27) -7.94% 138.65 9.24 7.14% 20 1,500 Ccf 173.14 157.79 (15.36) -8.87% 189.06 15.92 9.19% 21 2,000 Ccf 216.87 196.43 (20.44) -9.43% 239.46 22.59 10.42% 22 2,500 Ccf 260.60 235.08 (25.53) -9.79% 289.86 29.26 11.23% Note 1:All proposed charges exclude gas costs,riders and Atmos'proposed Rate Case Expense Surcharge 12 ATMOS ENERGY CORP-MID-TEX DIVISION REVENUE REQUIREMENT ALLOCATION TO CUSTOMER CLASSES-ATCLASS COST OF SERVICE Line No. Revenue Requirement Component Total Residential Commercial I&T (a) (b) (c) (d) (e) 1 Operating and Maintenance Expenses $ 187,342,844 $ 148,585,126 $ 33,873,802 $ 4,883,916 2 Depreciation Expense 144,321,772 113,626,539 27,120,191 3,575,042 3 Taxes Otherthan Income 43,711,991 34,337,668 8,259,964 1,114,360 4 Interest on Customer Deposits 117,764 83,481 34,283 - 5 Return on Investment 193,437,246 151,754,188 36,747,735 4,935,323 6 IncomeTaxes 40,517,490 31,786,530 7,697,204 1,033,756 7 Total Cost of Service $ 609,449,107 $ 480,173,532 $ 113,733,178 $ 15,542,396 8 Revenue Credits 14,543,619 11,458,645 2,714,077 370,897 9 Amortization ofADFIT (12,090,609) (9,481,039) (2,302,608) (306,962) 10 Total Revenue Requirement $ 582,814,879 $ 459,233,848 $ 108,716,493 $ 14,864,538 13 ATMOS ENERGY CORP-MID-TEX DIVISION RATE BASE ALLOCATION TO CUSTOMER CLASSES Line No. Revenue Requirement Component Total Residential Commercial I&T (a) (b) (C) (d) (e) 1 Gross Plant $ 4,532,029,129 $ 3,559,151,661 $ 858,973,880 $ 113,903,588 2 Accumulated Depreciation 1,323,023,298 1,042,759,772 247,831,547 32,431,979 3 Net Plant 3,209,005,831 2,516,391,889 611,142,333 81,471,609 4 Cash Working Capital (26,580,445) (21,081,449) (4,806,059) (692,936) 5 Materials and Supplies 1,053,524 835,570 190,490 27,465 6 Prepayments 17,841,836 14,150,695 3,226,015 465,126 7 Pension Expense Regulatory Asset 941,167 746,457 170,174 24,536 8 Customer Deposits (12,941,103) (9,173,792) (3,767,311) - 9 Injuries and Damages Reserve (2,002,505) (1,588,225) (362,077) (52,204) 10 ADFIT&Regulatory Liabilities (603,948,499) (473,595,620) (115,019,577) (15,333,302) 11 Rate Base Adjustments (10,695,834) (8,387,305) (2,036,979) (271,550) 12 Total Rate Base $ 2,572,673,971 $ 2,018,298,220 $ 488,737,009 $ 65,638,742 14