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DOCKET NO. 20170179 -GU to customers who would otherwise be unable to obtain such service. As further addressed herein, and in the testimony and exhibits of FCG's witnesses, the Company is also faced with capacity challenges that it proposes to address through a two-pronged approach involving the purchase of additional interstate pipeline capacity and the construction of an LNG "peaking" unit. FCG has also invested significantly to provide enhanced training opportunities for development and retention of highly skilled and highly specialized personnel in response to the challenges of an aging workforce. In order to continue to provide, in the face of these challenges, "reasonably sufficient, adequate, and efficient service," as required by Section 366.03, Florida Statutes, FCG must be able to not only recover its cost to serve, but also attract capital at reasonable rates and offer a fair return for its investors. Without a rate increase, FCG will be unable to provide the level of service required by statute and will also be unable to meet its obligations to its investors. Thus, FCG is asking that this Commission allow the Company to increase its rates and charges enough to provide a total increase in annual revenues of $19.3 million. FCG's current rates were established by the Commission back in 2004, in Docket No. 20030569 -GU, by Order No. PSC -2004 -0128 -PAA -GU, issued February 9, 2004, using a test year ending September 30, 2004. Since that time, FCG has maintained its focus on the customer as reflected by its service quality, while also effectively managing its costs such that it has been able to avoid seeking a base rate increase for nearly 14 years. As set forth in the testimony and exhibits of FCC's witnesses, cost saving measures, such as becoming a part of the AGL Resources Inc. (AGLR) shared services model and FCG's deployment of various technology solutions, have created significant operational efficiencies that have helped the Company maintain its rates at the same level over this extended period. The Company has seen, however, an increase in its cost to serve customers, which has contributed to its declining rate of return. At present, the Company's current rates and charges no longer allow it to earn a fair and reasonable rate of return nor do they yield reasonable compensation for services provided, which FCG is entitled to under Section 366.06(3), Florida Statutes. As of June 2017, FCG was earning an overall rate of return of 4.86% on a pro forma adjusted basis with an ROE of 7.91%, excluding the AGLR acquisition adjustment and associated regulatory assets, and a mere 6.46% with the acquisition adjustment and regulatory assets included. 41Page �`