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Docket No. 20170179 -GU <br />Florida City Gas <br />request and asks that, for purposes of administrative efficiency and clarity of the record, the <br />Commission also address the Company's Depreciation Study in this proceeding. <br />III. REQUEST TO INCLUDE LNG FACILITY <br />11) As noted herein, there are three major drivers for this rate request. Ultimately, however, <br />the underlying basis for this request is that the Company has made significant capital investments <br />in its distribution system and its personnel to meet the needs of its customers today, but also has <br />planned significant additional capital expenditures to ensure that it is able to continue to meet the <br />needs of its customers tomorrow. <br />12) The cornerstone of FCC's strategy for meeting the needs of its customers in the <br />foreseeable future is FCC's proposal to construct an LNG facility. As set forth in greater detail <br />in the testimony and exhibits of FCG's witnesses in this case, the Company is faced with <br />capacity issues that present a challenge to its ability to serve all of its sales customers, as well as <br />its critical need, also known as "essential use" customers. FCG has investigated several options <br />to address this need and determined that constructing an LNG facility, to be included in rate <br />base, is the most effective — and cost effective — means to address its capacity needs for the near <br />future. <br />13) As FCC's witnesses describe in testimony, the proposed facility would be constructed at <br />a projected cost of $58 million. <br />IV. STORM RESERVE <br />14) FCG is also requesting that it be allowed to establish a stonn reserve to better allow it to <br />address storm damages expeditiously without incurring significant financial harm. <br />15) FCG's proposal for a storm reserve and the methodology for determining the appropriate <br />annual accrual are similar to proposals made by other Florida natural gas utilities and approved <br />pq-g <br />