program, and in light of the Company’s stated future likelihood of filing a base rate case every three years, the Commission should grant UGI’s request for an accelerated period in which to amortize the expense. UGI M.B. at 57-58. I&E opposed the Company’s rate case expense contending that it should be normalized over a period of five years for a normalized expense claim of $135,000 per year. I&E asserted that consistent with the Commission determination Emporium, should rely upon some historic evidence of the Company’s filing frequency. I&E rejected the Company’s proposed three-year normalization period both because it does not relate to UGI’s historic filing frequency, and because the Company’s assertion that it will likely file a rate case every three years is purely speculative. I&E proposed that the Commission rely on the historic frequency model and exercise discretion to arrive at a reasonable amortization period, given the fact that UGI’s historic filing frequency would otherwise impose a long period in which to normalize the expense. I&E M.B. at 44-45; I&E St. 1 at 11; I&E St. 1-SR at 8-9. Based on I&E’s calculation of all cases filed by the company since 1992, resulting in an average historic frequency of every 103 months, or an amortization period of more than eight years, I&E proposed that the Commission make a reasonable downward adjustment of the period to a five-year amortization period. I&E St. 1 at 11 (citing I&E Exh. No. 1, Sch. 2); and I&E St. 1-SR at 7-8. Recommended Decision The ALJs agreed with I&E on this issue, recommending adoption of UGI’s rate case expense claim in the amount of $676,000, to be normalized over I&E’s recommended normalization period of five years. R.D. at 40-41
program, and in light of the Company’s stated future likelihood of filing a base rate case every three years, the Commission should grant UGI’s request for an accelerated period in which to amortize the expense. UGI M.B. at 57-58. I&E opposed the Company’s rate case expense contending that it should be normalized over a period of five years for a normalized expense claim of $135,000 per year. I&E asserted that consistent with Emporium, the Commission determination should rely upon some historic evidence of the Company’s filing frequency. I&E rejected the Company’s proposed three-year normalization period both because it does not relate to UGI’s historic filing frequency, and because the Company’s assertion that it will likely file a rate case every three years is purely speculative. I&E proposed that the Commission rely on the historic frequency model and exercise discretion to arrive at a reasonable amortization period, given the fact that UGI’s historic filing frequency would otherwise impose a long period in which to normalize the expense. I&E M.B. at 44-45; I&E St. 1 at 11; I&E St. 1-SR at 8-9. Based on I&E’s calculation of all cases filed by the company since 1992, resulting in an average historic frequency of every 103 months, or an amortization period of more than eight years, I&E proposed that the Commission make a reasonable downward adjustment of the period to a five-year amortization period. I&E St. 1 at 11 (citing I&E Exh. No. 1, Sch. 2); and I&E St. 1-SR at 7-8. Recommended Decision The ALJs agreed with I&E on this issue, recommending adoption of UGI’s rate case expense claim in the amount of $676,000, to be normalized over I&E’s recommended normalization period of five years. R.D. at 40-41