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DOCKET NO. 20170179 -GU the Commission's prior decision on the Company's SAFE program. When the additional revenue requirement of $3.5 million associated with SAFE installments is included, as contemplated by Commission order and as further discussed herein, this results in a total revenue increase request of $19.3 million. It should, however, be noted that moving the SAFE investments into rate base is ultimately bill neutral for FCG's customers, as well as revenue neutral to the Company, because FCG is also proposing to make a corresponding adjustment to reduce the current SAFE surcharge. III. Interim Request FCG is also asking for an interim increase in its retail rates and charges in an amount necessary to generate additional revenues in the amount of $4,893,061. This proposed interim increase would be effective during the interim period while the case is processed and before permanent rates and charges go into effect in accordance with the Commission's final determinations in this proceeding. The requested amount is based upon actual data derived from the preceding or "historic" test year with an ending date of December 31, 2016. For that period, the Company's annual revenue deficiency is $4,893,061 based upon a historic test year rate base of $209,312,678. The Commission will consider the Company's request for interim rate relief at its December 12, 2017, Agenda Conference. If the request is granted, any interim increase will be placed into effect subject to refund, with interest, if at the conclusion of this proceeding, the Commission determines that some or all of the increase was not justified. IV. Reasons for Request - Key Factors As further set forth in the testimony and exhibits of FCG's witnesses, there are three key drivers for FCG's request in this proceeding: (1) capital investments to enhance the safety and reliability of FCG's distribution system; (2) capacity challenges, which have prompted FCG to develop a liquefied natural gas ("LNG") strategy; and (3) the challenges associated with an aging workforce and the costs associated with proactively addressing the pending skills and knowledge gap. Significant investments have been made by FCG to its system in response to federal regulatory changes regarding safety of natural gas facilities. FCG has also made investments to improve the reliability of its system and to enhance the ability of its employees to access facilities for maintenance and repairs, as well as to extend facilities to provide natural gas service 31Page �� `"f-