Capital Tracker
In March, 2015, the AUC released the following three decisions related to capital tracker applications:
(a) Decision 3220-D01-2015 regarding FortisAlberta Inc. (“FAI”) 2013-2015 PBR Capital Tracker Application;
(b) Decision 3218-D01-2015 regarding ATCO Electric Ltd. (“ATCO Electric”) 2013 PBR Capital Tracker Refiling and True-up and 2014-2015 PBR Capital Tracker Forecast; and
(c) Decision 3267-D01-2015 regarding ATCO Gas and Pipelines Ltd. (“ATCO Gas”) 2013 PBR Capital Tracker Refiling and True-up and 2014-2015 PBR Capital Tracker Forecast.
Pursuant to directions from the AUC arising from Decision 2013-435, FAI, ATCO Electric, and ATCO Gas applied for their respective 2013 capital tracker refiling and true-ups, as well as their respective 2014 and 2015 capital tracker forecasts. Briefly, the three respective applications were as follows:
(a) FAI applied for nine capital tracker programs in 2013, and an additional three in 2014 and 2015 respectively. FAI stated the total net impact of the applied for programs as: (i) $23.2 million for 2013, or 11% of total revenue requirement; (ii) $48.1 million for 2014, or 19% of total revenue requirement; and (iii) $68.9 million for 2015, or 24% of total revenue requirement;
(b) ATCO Electric applied for nine capital tracker programs in 2013, and an additional two in 2014 and 2015 respectively. The total net impact of the applied for programs was stated by ATCO Electric to be: (i) $ 21.6 million for 2013; (ii) $ 40.6 million for 2014; and (iii) $ 57.1 million for 2015; and
(c) ATCO Gas applied for 18 capital tracker programs. The total net impact of the applied for programs was stated by ATCO Gas to be: (i) For 2013, $9.559 million for the north, and $5.579 million for the south; (ii) For 2014, $15.645 million for the north, and $8.671 million for the south; and (iii) For 2015, $24.537 million for the north, and $14.582 million for the south.
Background
Capital tracker applications are part of the performance based regulation (“PBR”) plans originally approved by the AUC on a five-year term in Decision 2012-237.
The PBR framework essentially provides a formula mechanism to adjust rates annually, using inflation (I Factor) less an offset (X Factor) (the “I-X Index Factor”) to reflect the productivity improvements the utility can expect to achieve during the test period. The I-X Index Factor is further adjusted to account for forecast billing determinant growth (“Q Factor”). However, the PBR framework also requires certain adjustments, including amounts to fund necessary capital expenditures (K Factor), flow-through costs to be recovered directly from the consumer (Y Factor), and material events for which the company has no other reasonable cost recovery mechanism (Z Factor). Capital tracker costs form part of the K Factor adjustments within the PBR mechanism.
Projects or programs are eligible for capital tracker treatment, provided that they meet the following three criteria:
(a) The project must be outside the normal course of on-going operations (“Criteria 1”);
(b) Ordinarily the project must be for replacement of existing capital assets or undertaking the project must be required by an external party (“Criteria 2”); and
(c) The project must have a material effect on the company’s finances (“Criteria 3”).
In order to qualify as Criteria 1, the AUC noted that the increase in associated revenue provided by the PBR formula must be insufficient to recover the entire revenue requirement associated with the prudent capital expenditures for the program or project in question. This test is therefore considered by the AUC as more accounting oriented than engineering oriented, although such applications must generally be supported by an engineering study and business case to assess the reasonableness of the request.
With respect to Criteria 2, generally a growth related project which can demonstrate that customer contributions and incremental revenues are insufficient to offset the revenue requirements associated with a project for a given PBR year will satisfy the requirements.
The materiality threshold in Criteria 3 requires that each project must individually affect the revenue requirement by four basis points. On an aggregate level, all proposed capital trackers must have a total impact on revenue requirement of 40 basis points.
Required Updates to I-X Index Factors and Q Factors
As part of Decision 2013-435, the AUC required that FAI, ATCO Electric and ATCO Gas update their I-X Index Factor and Q Factor.
The AUC held that FAI applied the proper weighted-average cost of capital and that its accounting test model was both reasonable and consistent with the methodology approved in Decision 2013-435. As the AUC recommended that FAI update its I-X Index Factor and billing determinants growth factors in forecasting its costs, due to the fact that updates to the I-X Index Factor and billing determinants would cause FAI’s baseline costs to change, the AUC was not able to specifically approve any quantum of costs for any of the projects. The AUC therefore ordered a compliance filing.
The AUC held that all of the projects and programs met the second criteria insofar as they were externally driven, asset replacements or growth-related, on the basis that the AUC had previously approved such programs, or that there was no evidence to indicate that the projects and programs did not fit into the three categories.
The AUC held that ATCO Electric and ATCO Gas had reasonably applied the accounting test methodology approved in Decision 2013-435. However, for the purposes of applying the I-X mechanism, and the Q Factor, the AUC determined that ATCO Electric and ATCO Gas had applied various placeholders to the 2014 and 2015 values for the I factor and Q Factor. The AUC determined that the 2014 placeholder values were correct, but the 2015 values had to be estimated due to timing constraints associated with ATCO Electric and ATCO Gas’ 2015 annual PBR filing. The AUC noted that Decision 2014-354 approved updated I factors and Q Factors for 2015, and directed ATCO Electric and ATCO Gas to use these updated figures in its accounting test for its compliance filing to this decision.
On matters related to assumptions used by ATCO Electric and ATCO Gas for weighted cost of capital, the AUC directed them to incorporate all changes to 2013, 2014 and 2015 weighted average cost of capital rates directed by the AUC in Decision 3434-D01-2015, and such further changes directed by the AUC in Decision 2191-D01-2015.
Project Groupings
On the issue of project and program groupings, the AUC held that the grouping of projects or programs for the sole purpose of minimizing or maximizing the capital tracker revenue amounts is contrary to the approved PBR mechanism. The AUC also noted that companies naturally have an incentive to group projects in such a way. However, where such groupings are consistent with past practice, there will not normally be a reason to question the reasonableness of such groupings, unless the groupings are not suitable for determining whether particular programs or projects are sufficiently similar to be grouped together for capital tracker purposes.
The AUC accepted that FAI’s groupings were consistent with those approved in its previous distribution tariff application. The AUC also noted that FAI had complied with the directions of the AUC to disaggregate certain projects in order to separate projects that were dissimilar. The AUC directed FAI to reconsider its groupings of projects within its Distribution Capacity Increases program and Metering Unmetered Oilfield project as part of its next capital tracker application, as the AUC held that the projects may not be sufficiently similar.
The AUC found that ATCO Electric’s proposed project groupings were consistent with its prior general tariff applications. Accordingly, the AUC held that the projects were properly grouped, and that there was a need for the projects in order to provide and maintain service quality at adequate levels.
ATCO Gas stated that all of its groupings were approved by the AUC in Decision 2013-435, and that these groupings complied with the AUC directions. ATCO Gas submitted that it performed its grouping and accounting tests by separating its projects between north and south service areas, and performed the materiality test separately under Criteria 3 with respect to each. ATCO Gas stated that the basis for this separation is that it is required to maintain two separate PBR plans for the north and south.
The AUC determined that, until ATCO Gas is directed to implement a single, Alberta-wide rate model with a single rate base, ATCO Gas will maintain its current practice of separating rates for north and south.
The AUC found that ATCO Gas’ proposed project groupings were consistent with its prior general rate applications. Accordingly, the AUC held that the projects were properly grouped, and that there was a need for the projects in order to provide and maintain service quality at adequate levels, with the exception of certain historically grouped costs in the Steel Mains Replacement program.
Project Assessment Under Criteria 1 and 2
The AUC noted that FAI had broadly applied for two categories of programs in its capital tracker application:
(a) Projects or programs which the AUC previously approved in Decision 2013-435; and
(b) Projects or programs implemented in 2013, or to be implemented in 2014-2015, for which the need has not been approved.
The AUC held that the common elements of FAI’s 2014-2015 capital expenditure forecasts, including index escalators, growth rates, and housing starts, were all reasonable. The AUC also found that FAI’s reliance on competitive procurement processes reassures the contention that the scope, level, timing and costs of the forecast capital projects are reasonable.
The CCA took issue with FAI’s request for capitalization of overhead costs, noting that FAI was asking for capitalization of approximately $113 million over the course of three years, with what the CCA characterized as “limited or no details to support the request”. The CCA also submitted that the capital tracker portion of capitalized overhead costs increased to 86% of the total in 2014, and were slated to increase to 87% in 2015.
The AUC agreed with the CCA, noting that FAI had not demonstrated that its capitalized overhead costs were prudent, as detailed information was not provided. Therefore, in the absence of such evidence supporting the overhead costs, the AUC declined to approve an increase in overhead costs in excess of the previous year’s amount adjusted by the I-X mechanism.
The AUC directed FAI, in its compliance filing, to limit the total pool of overheads for each of 2013, 2014 and 2015 to the lower of the amounts in the application or the amounts reflected in the increases in the I-X mechanism, applied to the 2012 rates.
The AUC provided findings only on those projects that it determined were insufficiently addressed or were otherwise raised as an issue by interveners in the proceedings. All programs were approved as filed with respect to Criteria 1, unless otherwise noted.
The AUC also held that each of the proposed project groupings fell into one of the following three categories, as required by Criteria 2:
(a) Asset replacement or refurbishment;
(b) Required by an external party; or
(c) Growth related.
FAI – Worst Performing Feeders Program
FAI submitted that this program focuses on the repair and upgrade of sections of feeders on FAI’s distribution system with the poorest reliability. FAI applied for the following amounts:
(a) $6.1 million in 2014; and
(b) $6.1 million in 2015.
The AUC noted that the Worst Performing Feeders program had previously been approved by the AUC in Decisions, 2008-011, 2010-309, and 2012-108, accordingly, it approved of the continued need for the program. However, the AUC also noted that AUC Rule 002: Service Quality and Reliability Performance Monitoring and Reporting for Owners of Electric Distribution Systems and for Gas Distributors only requires the replacement of the bottom three percent of feeders, and therefore, the AUC limited the scope of the program to the three percent of feeders with the worst performance record, and not any of the additional metrics proposed by FAI. The AUC invited FAI to re-apply for capital tracker treatment on these additional costs in its next true-up application.
Given the reduction in scope, the AUC also directed FAI to reconsider the materiality impacts of the Worst Performing Feeders program, as the additional costs disallowed represented half of the program costs, thereby reducing the increase to $3.0 million for each of 2014 and 2015.
FAI – Pole Management Program
FAI submitted that this was a grouping of capital projects designed to maximize the service life of existing poles, and replacement of poles failing inspections. FAI applied for the following amounts:
(a) $15.6 million in 2013;
(b) $31.4 million in 2014; and
(c) $39.9 million in 2015.
FAI noted that this program is undertaken in order to maintain its system and to provide service in a safe and reliable manner. FAI submitted that this program is necessary, as many of its poles constructed in the 1950s have service lives between 50 and 70 years, and many are at or near the end of those service lives and require replacement.
FAI explained the variances in previous years of forecasts, noting that it is able to accurately forecast the number of poles that will be tested for failure criteria (as one seventh of its poles are tested each year), but that the number that will pass or fail is inherently unknown.
The AUC noted that the program had not previously been approved for capital tracker treatment. The AUC held that the program was required to maintain service reliability and safety at adequate levels. The AUC held that the $11.7 million in actual capital expenditures in 2013 for pole replacements were prudent, remaining $3.9 million in actual capital expenditures related to line-rebuild projects. Therefore, the AUC denied capital tracker treatment for the line-rebuild projects, and invited FAI to re-apply for these costs at a later date with the appropriate information.
Citing similar concerns with forecasts for 2014 and 2015 for line-rebuild projects, the AUC also denied capital tracker treatment for forecast line-rebuild costs in 2014 and 2015, and invited FAI to re-apply for these costs with appropriate information.
The AUC otherwise found that there was no evidence on the record to indicate that the Pole Management Program was not required for 2014 or 2015, and held that the scope level and timing of the program was reasonable.
The CCA submitted that the Pole Management program’s seven year life cycle inspections had no credible support, noting that the reports relied on by FAI actually advocated a 10 year inspection cycle.
The AUC declined to rule on the appropriateness of the seven year inspection cycle. Given the historical use of this inspection cycle, and its current application under FAI’s PBR term, the AUC noted it may address the issue at the end of the current PBR term.
FAI Deferral of 2013 Capital Spending
FAI applied for approval of its 2013 capital spending that was deferred. FAI noted that the deferrals were specific to Distribution Capacity Increases, Metering Unmetered Oilfield services, Worst Performing Feeders, Pole Management and CSAR programs. The total deferred capital spending for 2013 amounted to $34.9 million. FAI submitted that the deferrals did not impact service quality, and were instituted at a time when the accounting tests and materiality thresholds for capital tracker treatment were not yet known.
The AUC held that uncertainty as to the nature and extent of capital tracker treatment was not a valid business decision for deferring work. Nevertheless, the AUC recognized that 2013 was a transition year, and that the deferrals did not appear to have been made in order to affect the recovery of capital under the capital tracker mechanism. Accordingly, the AUC opted not to disqualify the five deferred programs from consideration for capital tracker treatment.
ATCO Electric – Buildings, Structures and Leasehold Improvements Program
This program involves the provision of office and warehouse facilities to meet ATCO Electric’s current staffing needs and near term forecast additions of personnel and equipment. As part of this program, ATCO Electric applied to include the cost of the Drumheller Service Building. The CCA opposed the inclusion of the Drumheller Service Building, noting that ATCO Electric had applied for approval to construct a similar building in three previous general tariff applications, and that the cost had escalated from $10.057 million in 2009 to $30.08 million in its 2013-2014 general tariff application, to $37.6 million in this application. The UCA also noted that even if such costs are approved, that ATCO Electric has neglected to remove the costs of its administration building in Drumheller from rate base since 2009, and that the costs of removal should offset any increase from the Drumheller Service Building.
The AUC held that the Drumheller Service Building had been approved on three separate occasions, and had grown in scope in each successive application. The AUC accepted ATCO Electric’s explanation for the project delays, noting that such factors were primarily outside of ATCO Electric’s control. However, the AUC held that the increase in scope in this application was not substantiated on the record, and therefore denied the $7 million increase in costs as ATCO Electric had failed to demonstrate the project satisfied Criteria 1.
With respect to the omission in rate base, the AUC ordered ATCO Electric to remove the net book value of the administration building from rate base, and that any consequent changes be reflected in ATCO Electric’s next PBR filing.
With respect to the Nisku Pole and Training Facility Development project, the AUC found that there was insufficient evidence with respect to the forecast scope, level, and timing of costs to determine if they were reasonable. However, the AUC stated it was not making a determination of the prudence of the 2013 costs incurred in respect of this specific project. For the remaining 2014 and 2015 forecast costs associated with this project, the AUC found that the project satisfied the requirements of Criteria 1, it did not have supporting evidence necessary to make a determination on the forecast scope, level, and timing of costs. The AUC invited ATCO Electric to re-apply for these costs once it has incurred all the capital expenditures associated with the project.
The AUC also denied capital tracker treatment to the cost of 6.2 acres of land purchased as part of capital expenditures for the Valleyview Service Building, as it held that the surplus land was not required for utility service in the near term. However, the AUC allowed ATCO Electric to apply for capital tracker treatment of such land should it become required to provide service in the future.
The AUC otherwise approved the Buildings, Structures and Leasehold Improvements Program as applied for.
ATCO Electric – Information Technology Program however, there was insufficient evidence on the record to establish the prudence of the remaining $3.9 million in actual capital expenditures related to line-rebuild projects. Therefore, the AUC denied capital tracker treatment for the line-rebuild projects, and invited FAI to re-apply for these costs at a later date with the appropriate information.
Citing similar concerns with forecasts for 2014 and 2015 for line-rebuild projects, the AUC also denied capital tracker treatment for forecast line-rebuild costs in 2014 and 2015, and invited FAI to re-apply for these costs with appropriate information.
The AUC otherwise found that there was no evidence on the record to indicate that the Pole Management Program was not required for 2014 or 2015, and held that the scope level and timing of the program was reasonable.
The CCA submitted that the Pole Management program’s seven year life cycle inspections had no credible support, noting that the reports relied on by FAI actually advocated a 10 year inspection cycle.
The AUC declined to rule on the appropriateness of the seven year inspection cycle. Given the historical use of this inspection cycle, and its current application under FAI’s PBR term, the AUC noted it may address the issue at the end of the current PBR term.
FAI Deferral of 2013 Capital Spending
FAI applied for approval of its 2013 capital spending that was deferred. FAI noted that the deferrals were specific to Distribution Capacity Increases, Metering Unmetered Oilfield services, Worst Performing Feeders, Pole Management and CSAR programs. The total deferred capital spending for 2013 amounted to $34.9 million. FAI submitted that the deferrals did not impact service quality, and were instituted at a time when the accounting tests and materiality thresholds for capital tracker treatment were not yet known.
The AUC held that uncertainty as to the nature and extent of capital tracker treatment was not a valid business decision for deferring work. Nevertheless, the AUC recognized that 2013 was a transition year, and that the deferrals did not appear to have been made in order to affect the recovery of capital under the capital tracker mechanism. Accordingly, the AUC opted not to disqualify the five deferred programs from consideration for capital tracker treatment.
ATCO Electric – Buildings, Structures and Leasehold Improvements Program
This program involves the provision of office and warehouse facilities to meet ATCO Electric’s current staffing needs and near term forecast additions of personnel and equipment. As part of this program, ATCO Electric applied to include the cost of the Drumheller Service Building. The CCA opposed the inclusion of the Drumheller Service Building, noting that ATCO Electric had applied for approval to construct a similar building in three previous general tariff applications, and that the cost had escalated from $10.057 million in 2009 to $30.08 million in its 2013-2014 general tariff application, to $37.6 million in this application. The UCA also noted that even if such costs are approved, that ATCO Electric has neglected to remove the costs of its administration building in Drumheller from rate base since 2009, and that the costs of removal should offset any increase from the Drumheller Service Building.
The AUC held that the Drumheller Service Building had been approved on three separate occasions, and had grown in scope in each successive application. The AUC accepted ATCO Electric’s explanation for the project delays, noting that such factors were primarily outside of ATCO Electric’s control. However, the AUC held that the increase in scope in this application was not substantiated on the record, and therefore denied the $7 million increase in costs as ATCO Electric had failed to demonstrate the project satisfied Criteria 1.
With respect to the omission in rate base, the AUC ordered ATCO Electric to remove the net book value of the administration building from rate base, and that any consequent changes be reflected in ATCO Electric’s next PBR filing.
With respect to the Nisku Pole and Training Facility Development project, the AUC found that there was insufficient evidence with respect to the forecast scope, level, and timing of costs to determine if they were reasonable. However, the AUC stated it was not making a determination of the prudence of the 2013 costs incurred in respect of this specific project. For the remaining 2014 and 2015 forecast costs associated with this project, the AUC found that the project satisfied the requirements of Criteria 1, it did not have supporting evidence necessary to make a determination on the forecast scope, level, and timing of costs. The AUC invited ATCO Electric to re-apply for these costs once it has incurred all the capital expenditures associated with the project.
The AUC also denied capital tracker treatment to the cost of 6.2 acres of land purchased as part of capital expenditures for the Valleyview Service Building, as it held that the surplus land was not required for utility service in the near term. However, the AUC allowed ATCO Electric to apply for capital tracker treatment of such land should it become required to provide service in the future.
The AUC otherwise approved the Buildings, Structures and Leasehold Improvements Program as applied for.
ATCO Electric – Information Technology Program
ATCO Electric applied for the following amounts under the Information Technology program:
(a) $14.4 million for 2013;
(b) $24.2 million for 2014; and
(c) $15.9 million for 2015.
ATCO Electric submitted that the costs for Operations System Extension projects were generally driven by the customer growth and the maintenance of safe and reliable service related to its Outage Management System due to an increase in volumes of work and aging assets.
The AUC held that ATCO Electric had not satisfied the onus of demonstrating that the Operations System Extension projects were required to prevent deterioration in service quality and safety if the expenditures were not undertaken. Accordingly, the AUC denied capital tracker treatment for these costs for 2013, 2014, and 2015.
The AUC otherwise approved the Information Technology costs as filed, noting however that some of the costs applied for could have also been applied for as a Z factor or Y factor. The AUC found that ATCO Electric was not required to apply for recovery of costs under a specific factor, even if on a prima face basis, they should be recovered under a different factor, so long as the evidence before the AUC supports the recovery of costs as a capital tracker. Accordingly, the AUC held that it was within the discretion of the utility to apply for the recovery of costs under the factor it considered appropriate.
ATCO Electric – Overhead Line Rebuilds, Replacements and Life Extension Program
The CCA expressed concerns with ATCO Electric’s Wood Pole Replacement and Life Extension program within this program group. The CCA argued that ATCO Electric uses higher depreciation rates than FAI for average service lives of poles, despite ATCO Electric’s contention that its poles are in a more benign environment, which would suggest a lower depreciation rate.
ATCO Electric replied stating that it did not file evidence on pole life, and that its pole life extension practices have been in place for many years. ATCO Electric indicated that the relevant information was reviewed and approved by the AUC in ATCO Electric’s depreciation study filed with its 2011-2012 general tariff application. ATCO Electric submitted that a capital tracker proceeding is not the appropriate forum to review or change depreciation rates in the absence of a depreciation study. Accordingly, ATCO Electric submitted that the pole depreciation rates approved by the AUC continue to be appropriate for determining the cost impacts of this program.
The AUC agreed with ATCO Electric on this point, finding that in the absence of a new depreciation study, the AUC would not re-open the matter of depreciation rates for consideration in a capital tracker proceeding.
The Overhead Line Rebuilds, Replacement and Life Extension program was otherwise approved as filed with respect to Criteria 1.
ATCO Gas – Overhead Cost Allocation
The CCA took issue with ATCO Gas’ request for capitalization of overhead costs, noting that ATCO Gas had provided “limited or no details to support the request”.
The AUC agreed with the CCA, and found that ATCO Gas had not demonstrated that its capitalized overhead costs were prudent, as detailed information was not provided. Therefore, in the absence of such evidence supporting the overhead costs, the AUC declined to approve an increase in overhead costs, and directed ATCO Gas to include in its compliance filing amounts reflecting increases adjusted by the I-X mechanism applied to the 2012 total pool of overheads approved in Decision 2011-450.
The AUC determined that the scope, level and timing for all of ATCO Gas’ applied for capital tracker projects were reasonable, with one minor exception. With respect to Steel Mains Replacement, the AUC did not expressly deny the cost estimates, but did deny capital tracker treatment to any carrying costs related to the advancement of steel replacements in 2011 that were planned for later years.
Criteria 3: Materiality Thresholds
With respect to the materiality of the proposed project groupings, the AUC noted that Criteria 3 imposes two tiers of materiality:
(a) A four basis point threshold, to be applied to each grouping of projects; and
(b) A forty basis point threshold for the aggregate revenue requirements proposed to be recovered from all proposed capital trackers.
FAI calculated that the materiality thresholds for each year applied for were as follows:
(a) A four basis point threshold of $330,000, and a 40 basis point threshold of $3.356 million for 2013;
(b) A four basis point threshold of $ 341,000, and a 40 basis point threshold of $33.409 million for 2014; and
(c) A four basis point threshold of $347,000, and a 40 basis point threshold of $3.464 million for 2015.
ATCO Electric calculated that the materiality thresholds for each year applied for were as follows:
(a) $224,000 and $2.238 million for 2013;
(b) $228,000 and $2.274 million for 2014; and
(c) $231,000 and $2.310 million for 2015.
ATCO Gas calculated that the materiality thresholds for each year applied for were as follows:
(a) $145,000 (north), $119,000 (south), and $1.448 million (north), $1.187 million (south) for 2013;
(b) $147,000 (north), $121,000 (south), and $1.471 million (north), $1.206 million (south) for 2014; and
(c) $149,000 (north), $123,000 (south), and $1.494 million (north), $1.225 million (south) for 2015.
The AUC made the following findings with respect to the materiality thresholds:
(a) For FAI, the AUC was not able to approve any specific amounts for material thresholds, arising from its directions to update the I-X Index Factor and billing determinants factors. The AUC therefore directed a compliance filing on this basis;
(b) For ATCO Electric and ATCO Gas, the AUC held that:
(i) Their 2013 values were reasonable, as they had been previously approved for 2013 in Decision 2013-435;
(ii) Their 2014 values were calculated correctly according to the approved escalation factors in the I-X mechanism; and
(iii) However, as the AUC determined that ATCO Electric and ATCO Gas had applied a placeholder for 2015, the AUC directed them to apply the 2015 I-X Index Factor of 1.49 percent approved in Decisions 2014-354 and 2014-363 in its compliance filing to this decision, and for all other capital tracker applications in 2015.
Due to the directed changes to the weighted average cost of capital rates, and to the various I factor and Q Factor indexes, the AUC determined that it could not determine whether ATCO Electric and ATCO Gas’ applied for capital trackers met the materiality thresholds, as the underlying figures required a recalculation as part of their compliance filing, and reserved its findings on this matter accordingly.
AUC Dispositions
In summary, the AUC ordered compliance filings in accordance with the directions in their respective decisions by the following dates:
(a) April 14, 2015 for FAI;
(b) April 20, 2015 for ATCO Electric; and
(c) April 27, 2015 for ATCO Gas.
