Reed Smith LLP
`1301 K Street, N.W.
`Suite 1000 - East Tower
`Washington, D.C. 20005-3373
`+1 202 414 9200
`Fax +1 202 414 9299
`reedsmith.com
`
`
`Debra Ann Palmer
`Direct Phone: +1 202 414 9271
`Email: dpalmer@reedsmith.com
`
`
`March 1, 2023
`
`
`
` Ms. Kimberly D. Bose
`Office of the Secretary
`Federal Energy Regulatory Commission
`888 First Street, NE, Room 1A-21
`Washington, DC 20426
`
`Re: Docket No. RP22-1033-000 – Prepared Direct and Answering Testimony of CenterPoint
`Energy Resources Corporation d/b/a CenterPoint Energy Minnesota Gas
`
`Dear Secretary Bose:
`
`CenterPoint Energy Resources Corporation d/b/a CenterPoint Energy Minnesota Gas
`(“CenterPoint”) hereby submits for electronic filing the Prepared Direct and Answering Testimony of
`Gregg Therrien in the above-referenced docket.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`Debra Ann Palmer
`/s/
`Debra Ann Palmer
`
`for CenterPoint Energy Resources
`Attorney
`Corporation d/b/a CenterPoint Energy Minnesota
`Gas
`
`
`Enclosures
`cc (w/enc.): Parties listed on the official service list
`
`
`Debra Ann Palmer
`
`DAP:cc
`
`ABU DHABI  ASTANA  ATHENS  AUSTIN  BEIJING  BRUSSELS  CENTURY CITY  CHICAGO  DALLAS  DUBAI  FRANKFURT  HONG KONG
`HOUSTON  LONDON  LOS ANGELES  MIAMI  MUNICH  NEW YORK  ORANGE COUNTY  PARIS  PHILADELPHIA  PITTSBURGH
`PRINCETON  RICHMOND  SAN FRANCISCO  SHANGHAI  SILICON VALLEY  SINGAPORE  TYSONS  WASHINGTON, D.C.  WILMINGTON
`
` 03/01/2023 10:48 AM
`
`
`
`

`

`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`)
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 1 of 14
`
`
`
`
`
`Docket Nos. RP22-1033-000
`
` 
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`7 
`8 
`9 
`10 
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`
`
`
`
`
`
`
`
`Northern Natural Gas Company
`
`
`
`
`
`
`
`
`
`
`SUMMARY OF
`PREPARED DIRECT AND ANSWERING TESTIMONY OF
`GREGG THERRIEN ON BEHALF OF
`CENTERPOINT ENERGY RESOURCES CORPORATION D/B/A
`CENTERPOINT ENERGY MINNESOTA GAS
`
`Gregg Therrien, Vice President for Concentric Energy Advisors, Inc. provides Prepared
`
`Direct and Answering Testimony on behalf of CenterPoint Energy Resources Corporation
`
`(“CERC”) d/b/a CenterPoint Energy Minnesota Gas in Northern Natural Gas Company’s
`
`(“NNG”) rate proceeding before the Federal Energy Regulatory Commission in Docket No.
`
`RP22-1033-000. Mr. Therrien’s Prepared Direct Testimony addresses the following:
`
`1) An overview of NNG’s rate filing and relevant procedural history,
`2) NNG’s failure to adequately support certain of its proposed adjustments to elements
`of NNG’s proposed Cost of Service (“COS”),
`3) NNG’s failure to support its proposed postage stamp rate design, and
`4) NNG’s failure to adequately reflect all billing determinants used to develop rates for
`firm transportation and storage services.
`
`
`
`Mr. Therrien concludes that NNG’s proposed cost of service, prospective cost allocation and
`
`rate design, and billing determinants have not been adequately supported by NNG and should
`
`not be approved as filed.
`
`
`
`
` 
`
`

`

` 
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 2 of 14
`
`
`UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`
`Northern Natural Gas Company
`
`
`
`
`
`
`
`
` )
`
`
`
`
`
`
`
`
` Docket Nos. RP22-1033-000
`
`
`
`
`
`
`
`__________________________________________________________
`
`PREPARED DIRECT AND ANSWERING TESTIMONY
`OF GREGG THERRIEN ON BEHALF OF
`CENTERPOINT ENERGY RESOURCES CORPORATION D/B/A
`CENTERPOINT ENERGY MINNESOTA GAS
`
`__________________________________________________________
`
`
`
`
`
`
`
`
` 
`
`

`

` 
`
`
`Table of Contents
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 3 of 14
`
` 
`INTRODUCTION ................................................................................................................................ 5
`I.
`II. OVERVIEW OF NNG’s RATE REQUEST ........................................................................................ 6
`III.
`PROPOSED COS ADJUSTMENTS ................................................................................................ 7
`IV.
`COST ALLOCATION AND RATE DESIGN ................................................................................. 9
`V. BILLING DETERMINANTS ............................................................................................................. 12
`VI.
`CONCLUSION ............................................................................................................................... 14
`
`
`
`1 
`
`2 
`3 
`4 
`5 
`6 
`7 
`8 
`9 
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 
`
`

`

` 
`
`CERC
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 4 of 14
`
`Glossary of Terms
`
`CenterPoint Energy Resources Corporation d/b/a
`CenterPoint Energy Minnesota Gas
`
`Commission or FERC
`
`Federal Energy Regulatory Commission
`
`COS
`
`LDC
`
`MBR
`
`
`
`
`
`
`
`M-SFV
`
`NNG
`
`ROE
`
`SFV
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Cost of Service
`
`Local Distribution Company
`
`Market-Based Rates
`
`Modified Straight-Fixed Variable
`
`Northern Natural Gas Company
`
`Rate of Return on Equity
`
`Straight-Fixed Variable Cost Classification 
`
`
`
`1 
`
`2 
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
` 
`
`

`

`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`21 
`
`22 
`
`23 
`
` 
`
`I.
`
`INTRODUCTION
`
`Q. Please state your name, employer, and business address.
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 5 of 14
`
`A. My name is Gregg H. Therrien, and my business address is 293 Boston Post Road West, Suite
`
`500, Marlborough, MA 01752. I am a Vice President at Concentric Energy Advisors, Inc.
`
`(“Concentric”).
`
`Q. Please describe your educational and professional background.
`
`A. I am a financial and economic consultant with more than 6 years of consulting experience
`
`specializing in public utility rates, finance, and regulation. Prior to consulting I held various
`
`positions at UIL Holdings Corporation, a wholly owned subsidiary of AVANGRID. During
`
`my tenure at UIL, I held the position of Director, Rates & Tariffs for more than 13 years and
`
`Director of Gas Construction for 2 years. Over the span of my 35-year career I have focused
`
`on financial and pricing analysis, with an emphasis on regulated gas and electric utilities. I
`
`hold a B.A. in Finance from Bryant University and a M.B.A. from the University of
`
`Connecticut. A copy of my résumé/CV is included as Exhibit No. CER-0002.
`
`Q. Have you previously provided expert testimony on ratemaking issues?
`
`A. Yes. I have testified on this topic before state regulatory commissions in Connecticut, Georgia,
`
`Illinois, Maine, Massachusetts and New Hampshire. A list of my prior appearances as an expert
`
`witness is provided in Exhibit No. CER-003.
`
`Q. In addition to your testimony in this case, are you sponsoring any supporting exhibits?
`
`A. Yes, I am sponsoring the following statements and schedules:
`
`Exhibit No. CER-00001
`
`
`
`Prepared Direct Testimony
`
`Exhibit No. CER-00002
`
`Résumé / CV
`
`Exhibit No. CER-00003
`
`
`
`List of prior testimony
`
` 
`
`

`

`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`21 
`
` 
`Q. What is the purpose of your testimony in this proceeding?
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 6 of 14
`
`A. The purpose of my direct testimony is to demonstrate that NNG’s has not adequately supported
`
`all items in its proposed COS. If not appropriately adjusted, NNG’s proposed transportation
`
`and storage rates will recover more than a reasonably calculated COS.
`
`While I will support NNG’s rate design methodology for transmission, commodity and storage
`
`rates, I reject NNG’s arguments for a prospective postage stamp rate methodology. I also
`
`discuss why NNG’s proposed billing determinants are not reasonable and will result in an
`
`overcollection by NNG.
`
`
`
`II. OVERVIEW OF NNG’S RATE REQUEST
`
`Q. What is the basis for NNG’s current rates?
`
`A. NNG’s current rates were established pursuant to a settlement agreement filed in the
`
`Company’s last Natural Gas Act Section 4 rate proceeding in Docket Nos. RP19-1353 and
`
`RP19-59 on July 1, 2019 (the “2020 Settlement”). The 2020 Settlement was approved by the
`
`Commission on September 28, 2020.1
`
`Q. What are the time periods you utilized to review NNG’s costs and revenues in this
`
`proceeding?
`
`A. The base period consists of the 12-months ended March 31, 2022 (“Base Period”), and the
`
`nine-month test period, reflects the period from April 1, 2022, through December 31, 2022
`
`(“Test Period”). I utilize both the Base Period and Test Period data, as NNG recently filed its
`
`45-day Update Filing on February 13, 2023.2
`
`                                                            
`1 Northern Natural Gas Co., 172 FERC ¶ 61,287 (2020) (letter order approving settlement).
`2 Pursuant to Section 154.311 of the Commission's regulations.
`
` 
`
`

`

` 
`
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 7 of 14
`
`III. PROPOSED COS ADJUSTMENTS
`
`Q. What is NNG’s overall COS during the test period in this proceeding?
`
`A. NNG’s filing shows a COS of $1.328 billion, per Statement A of its filing. This, when
`
`combined with NNG’s proposed billing determinants, results in an average increase in NNG’s
`
`Market Zone rates of about 121%, in NNG’s Field Zone rates of 44%, and in NNG’s storage-
`
`related rates of 53%. The rates settled upon in the aforementioned proceeding were the result
`
`of a “black-box” settlement and became effective January 1, 2020. Article VI of the Settlement
`
`contains a moratorium that limited NNG's ability to file a Section 4 general rate case until
`
`certain events transpired. The moratorium prevented NNG from filing a case prior to June 30,
`
`2022, or the date on which NNG had cumulative maintenance capital expenditures of at least
`
`$525.0 million, whichever date was later. According to NNG’s July 1, 2022 transmittal letter
`
`in the instant proceeding, NNG exceeded the cumulative maintenance capital expenditures in
`
`2021, which then established June 30, 2022 as the expiration date of the moratorium.3 NNG
`
`provided evidence that it added $1.1 billion in rate base primarily due to the $1.6 billion capital
`
`investment made to modernize and maintain its pipeline system.4
`
`Q. In your view, what are the primary drivers of the requested rate increase?
`
`A. My review of NNG’s application indicates that its proposed COS increase is largely
`
`attributable to its increase in rate base, which increases the required return of and return on
`
`invested capital (depreciation and rate of return, including a return on equity (“ROE”)
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`                                                            
`3 July 1, 2022 Section 4 transmittal letter, page 3.
`4 Ibid. 
`
` 
`
`

`

` 
`
`component). Other items such as operations and maintenance (“O&M”) expenses and taxes
`
`also contribute to the increase, albeit to a lesser degree.
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 8 of 14
`
`Q. Of these COS contributors, which adjustments does CenterPoint Energy Resources
`
`Corporation (“CERC”) consider unreasonable and why?
`
`A. CERC is supportive of NNG’s continued capital investment and maintenance expenditures to
`
`ensure a safe and reliable transmission system. The 2020 Settlement clearly anticipated a
`
`significant increase in capital expenditures (and ultimately rate base). NNG has not established
`
`that its proposed rate of return is reasonable. For example, NNG has not established that its
`
`risk is any greater than the average pipeline, or that it warrants an allowed return greater than
`
`that which the Commission recently awarded to Panhandle Eastern.5 I am aware of no recent
`
`Commission decision that granted an allowed return that is comparable to NNG’s requested
`
`return.
`
`Q. Are NNG’s 45-day updates to its COS reasonable?
`
`A. Yes. NNG’s 45-day update filing sets forth final COS numbers for various items, including
`
`plant in service. These numbers appear to be reasonable.
`
`Q. Do you have concerns about specific items in NNG’s proposed COS?
`
`A. Yes. I have concerns regarding two COS adjustments made by NNG, including: 1) prior rate
`
`case expenses, and 2) Operations and Maintenance Base Period Project Expense.
`
`Q. Please describe your concern over prior rate case expenses.
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`                                                            
`5 Panhandle Eastern Pipe Line Co., LP, Opinion No. 885, 181 FERC ¶ 61,211 (2022) (setting the
`ROE at 11.25%).
`
` 
`
`

`

` 
`A, Rate case expenses from NNG’s last rate case, Docket No. RP19-1353-000, were to be
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 9 of 14
`
`amortized over a three-year period commencing January 1, 2020.6 Any amortization expense
`
`related to this docket should be adjusted out from NNG’s proposed COS.
`
`Q. Please describe your concern over the proposed level of Operations and Maintenance Base
`
`Period Project Expense.
`
`A. NNG proposes to recover $117.7 million of O&M expenses for eleven project categories.7 This
`
`compares to identically categorized O&M project expenses of $90.2 million from NNG’s prior
`
`rate application8 in Docket No. RP19-1353-000, a 30% increase. Comparing each line item
`
`indicates that three of these project components, Inline Inspection and Hydrotesting, Pipeline
`
`Safety and Integrity, and Corrosion Control, comprise the bulk of the increase ($24.5 million
`
`of the $27.5 million variance). NNG has not demonstrated that a 30% increase in project O&M
`
`expense over a three-year period is reasonable.
`
`
`
`IV. COST ALLOCATION AND RATE DESIGN
`
`Q. Please describe NNG’s proposed rates in this proceeding.
`
`A. NNG’s Base Case in this proceeding proposed to be effective August 1, 2022, utilizes the
`
`Company’s existing rate design. NNG proposes to implement a system-wide postage stamp
`
`rate design in the future, as described in the Prospective Case.9 NNG’s Base Case reflects
`
`continuation of the modified-straight fixed variable ("M-SFV") rate design methodology for
`
`transmission rates.
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`                                                            
`6 Northern Natural Gas Company, 2021 FERC Form No. 2, Page 232, Line 1.
`7 Exhibit No. NNG-00027.
`8 Docket No. RP19-1353-0000 Exhibit No. NNG-00027.
`9 July 1, 2022 Transmittal Letter, page 4.
`
` 
`
`

`

`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`21 
`
` 
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 10 of 14
`
`Under NNG’s M-SFV methodology, the majority of the transmission fixed COS has been
`
`assigned to the transportation reservation charge, and the transmission variable COS has been
`
`assigned to the transportation commodity charge.
`
`NNG calculated revised minimum Market Area and minimum Field Area commodity rates
`
`based on the Straight Fixed Variable (“SFV”) rate design, which recovers only variable costs
`
`in the minimum commodity rate. The underground storage COS has been allocated between
`
`firm contract storage and operational storage based on the total cycle volumes and daily
`
`deliverability volumes that are assigned to each. The underground storage rates continue to be
`
`designed using the Equitable method, wherein the fixed cost of service component is allocated
`
`50 percent each to the daily deliverability component and the cycle capacity component of the
`
`contract storage charges, and the variable cost component is allocated to the injection and
`
`withdrawal charges.10
`
`Q. Are you supportive the M-SFV transmission, SFV commodity, and underground storage
`
`COS methodologies utilized in the NNG Base Case?
`
`A. Yes. The Base Case COS methodologies remain the appropriate cost classification
`
`methodology for NNG.
`
`Q. Has NNG proposed any changes to its rate design?
`
`A. In its Prospective Case, NNG proposes to eliminate its two-zone rate design (Market and Field
`
`Zones) and to switch to a system-wide postage stamp rate design.
`
`Q. Does CERC support the Prospective Case system-wide rate, or postage stamp, proposal
`
`by NNG?
`
`                                                            
`10 Equitable Gas Co., 36 FERC ¶ 61,147 (1986) (“Equitable”). See also Exhibit No. NNG-00023
`direct testimony of witness Luis Valdivia, page 11.
`
` 
`
`

`

` 
`A. No. The current two zone system (Market Zone and Field Zone) should not be changed. The
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 11 of 14
`
`prospective rate design change to a system-wide or postage stamp rate was first introduced in
`
`the settlement of NNG’s rate case in Docket Nos. RP03-398 and RP04-155 (the “2004
`
`Settlement”). In the 2004 Settlement, NNG was then required in its next general section 4 rate
`
`case proceeding to propose a prospective implementation of a cost allocation methodology
`
`different from the Market Area/Field Area cost allocation methodology. NNG subsequently
`
`met that requirement from the 2004 settlement when it proposed moving to a postage stamp
`
`rate in its 2019 rate case in Docket No. RP19-1353-009. In the ensuing 2020 Settlement in
`
`RP19-1353-009 the existing two-zone system remained in place. NNG should not be allowed
`
`to consolidate zones in this proceeding or in its Prospective Case proposed future proceeding.
`
`NNG has the burden of proving that gas flows on their system have materially changed.
`
`Q. Has the NNG system design materially changed over the past 20 years such that
`
`elimination of the two zone system is warranted?
`
`A. No, based on my review of previous NNG FERC rate proceedings and discussions with CERC
`
`management, there has been no material changes to the fundamentals of the NNG system that
`
`necessitate a system-wide or postage stamp rate design. Gas flows have remained largely one-
`
`directional, from the southern Field Area to the NNG Market Area, with a clearly defined and
`
`relevant point of demarcation. Additionally, NNG indicates that implementing such a change
`
`would “require significant business system changes to implement, which could take more than
`
`12 months to complete”.11 NNG estimates that system-wide rates would not likely be effective
`
`until mid-2025 at the earliest.12 Given the uncertainty of the costs and time to implement, NNG
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`21 
`
`                                                            
`11 Exhibit No. NNG-00023 page 41.
`12 Ibid.
`
` 
`
`

`

`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
` 
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 12 of 14
`
`can proactively develop such necessary system changes and propose rates concurrent with its
`
`next full section 4 rate application, and should not rely on a limited section 4 Prospective Case
`
`where COS and other important ratemaking information may presumably not be updated.13
`
`Based on the record in this proceeding, NNG has not justified either the appropriateness of
`
`moving to a postage stamp rate design nor adequately developed the costs and rate impacts
`
`that would be associated with such a change. Therefore, this proposal should be rejected.
`
`
`
`
`
`V.
`
` BILLING DETERMINANTS
`
`Q. Have you reviewed NNG’s proposed billing determinants for reservation quantities,
`
`commodity, and storage reservation and commodity?
`
`A. Yes. I have carefully reviewed NNG’s responses to data requests on this topic. Those data
`
`responses indicate that the majority of NNG’s contract demand quantities are either discounted
`
`or negotiated. Further, the level of discount to maximum rates is substantial – meaning that
`
`the significant discounts cause full rate equivalent billing determinants to be reduced
`
`substantially, which then results in comparatively higher unit rates. These discounts call into
`
`question whether NNG can fully justify the quantity and level of discounts provided, and
`
`whether such discounts will reasonably continue in the future.
`
`
`
`Q. Are there any other considerations regarding the accuracy of NNG’s billing determinants
`
`used in the instant case?
`
`                                                            
`13 NNG witness Valdivia states that in the Prospective Case “Northern proposes to recalculate
`System-Wide reservation rates based on the billing determinants in effect at that time, following
`the procedures outlined in the Pro Forma Tariff Sheets related to the System-Wide rate design
`proposal through a limited section 4 rate change filing.” Exhibit No. NNG-00023 page 41.
`
` 
`
`

`

` 
`A. Yes. NNG has failed to reflect billing determinants associated with short-term TFX and
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 13 of 14
`
`interruptible T1 services in its proposed rates. In addition, NNG has not included billing
`
`determinants associated with recent contracts for fairly large volumes. NNG’s failure to reflect
`
`these billing determinants indicates that its proposed rates are too high. A review of NNG’s
`
`index of shippers indicates a substantially sized contract became effective in late 2022 and two
`
`new shipper contracts are expected in 2023.
`
`Q. Please describe NNG’s proposed adjustments to Base Year billing determinants?
`
`A. NNG proposes to remove short term contracts associated with rate schedule TFX. Based on
`
`my review of NNG’s responses to data requests, it appears that this adjustment is not
`
`warranted. The historical level of TFX billing determinants has not been shown to be
`
`unrepresentative for setting future rates, and NNG has not adequately supported its use of a
`
`materially lower level of billing determinants for this service. One cannot simply assume that
`
`expiring contracts will not be renewed or replaced by new TFX contracts; the question must
`
`be addressed from the perspective of what is a representative level of TFX service based on
`
`past levels and market trends. NNG’s proposed removal of the proposed billing determinants
`
`results in the projected reduction in revenues from this service, which results in a
`
`corresponding higher revenue requirement from NNG’s other services. This proposed
`
`reduction in the cost contribution from TFX service is not reasonable nor is it adequately
`
`supported by NNG in its filing.
`
`Q. Please describe recent contracts NNG has executed that are not included in its proposed
`
`billing determinants?
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
`8 
`
`9 
`
`10 
`
`11 
`
`12 
`
`13 
`
`14 
`
`15 
`
`16 
`
`17 
`
`18 
`
`19 
`
`20 
`
`21 
`
` 
`
`

`

` 
`A. For example, a new contract for 30,000 Dth of Field Area contract demand was executed
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00001
`Page 14 of 14
`
`March 31, 2022. Although this appears to be short-term, it calls into question whether such
`
`substantially sized contracts may be entered into in the future.
`
`
`
`VI. CONCLUSION
`
`Q. Does this conclude your testimony?
`
`A. Yes, it does.
`
`1 
`
`2 
`
`3 
`
`4 
`
`5 
`
`6 
`
`7 
`
` 
`
`

`

`GREGG H. THERRIEN
`Vice President
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00002
`Page 1 of 4
`
`Mr. Therrien provides regulatory strategy and financial rate case expertise to regulated and
`unregulated entities in the natural gas, electric, and water industries. Since joining Concentric
`in 2016, Mr. Therrien has performed a multitude of consulting engagements including expert
`testimony on the subjects of allocated cost of service, rate design, rate consolidation,
`alternative rate plans, decoupling, revenue requirements, and natural gas infrastructure
`replacement programs. Other engagements include merger and acquisition due diligence,
`electric power plant retirement analysis (including securitization), billing system and rate
`mechanism audits, natural gas storage rate analysis, solar/renewable project evaluation, line
`extension policies, power procurement advisory services, interstate pipeline rate settlement
`assistance and tariff writing and administration.
`Prior to entering consulting Mr. Therrien held previous leadership level positions at Connecticut
`Natural Gas Corporation and its affiliated companies for over 19 years. He formerly served as
`Director, Gas Construction at Connecticut Natural Gas and The Southern Connecticut Gas
`Company and Director, Regulatory & Tariffs at UIL Holdings, Inc.
`Mr. Therrien holds an M.B.A. from the University of Connecticut, a B.S. in Finance from Bryant
`University, and is certified Project Management Professional (PMP).
`
`REPRESENTATIVE PROJECT EXPERIENCE
`Consultancy
`
` Regulatory risk assessments
` Gas infrastructure replacement program benchmarking, technical and financial analysis,
`and expert testimony
` Market analysis for international clients
` M&A due diligence (regulatory and financial)
` Gas and Electric distribution alternative rate plan analysis
` Economic Development and large customer tariff development
` Decoupling testimony assistance for a Western Gas LDC
` Decoupling and Rate Design expert witness testimony for a New England Gas LDC
` Revenue Requirements witness for an electric distribution company
` Regulatory rate strategies for a vertically integrated electric utility
` Testified on behalf of a New England gas LDC on the subjects of decoupling, capital
`trackers and rate design
` Developed an Alternative Rate Plan for a New England gas LDC
` Rate comparison study for the Government of Alberta, Canada
` Established a cost of service‐based pricing model for a 10MW fuel cell developer
` Power procurement consultancy for a New England investor‐owned water utility
` Rates comparisons for U.S. electric and gas distribution utilities
` Revenue requirements and tariff review of a gas storage facility
` Rate consolidation analysis for gas and water distribution companies
` Renewable project financial evaluation
`
`
`
` 1
`
`
`
`

`

`Docket No. RP22-1033-000
`Exhibit No. CER-00002
`Page 2 of 4
`
` Review of natural gas company regulatory and operational performance in response to a
`commission Show Cause Order
` Led an investigation of billing errors related to a municipal electric, gas, water, and refuse
`utility in support of a class action lawsuit investigation
` Assessed the impact of and strategy to comply with the Tax Cuts and Jobs Act (“TCJA”)
` Reviewed and recommended changes to electric line extension policies
` Evaluated Renewable Natural Gas (“RNG”) investments as part of buy‐side due diligence
` Modeled alternative time of use (“TOU”) tariff structures in support of a utility customer’s
`evaluation of a large customer potential electric system bypass
` Provided regulatory assistance and strategy to a market broker in a state utility
`investigation of Consumer Choice Aggregation
` Assisted in the development of a lead/lag study for a Southwestern electric utility
` Part of a team that developed a multi‐year rate plan regulatory strategy for a Mid‐Atlantic
`natural gas utility
` Co‐authored a RNG white paper for a Southern U.S. natural gas company
` Authored a report on behalf of a major U.S. interstate pipeline in support of an ongoing
`FERC settlement proceeding
` Prepared extensive rate analyses in support of electric transmission and generation
`project development and acquisition
` Developed a rate design model, performed rate analysis, drafted position papers and
`data responses for an international electric utility
` Led the preparation, filing, discovery and implementation of several rate cases
` Designed rates and prepared testimony, and served as the primary rate design witness
` Prepared, testified, and implemented revenue requirement rate mechanisms for new
`customer growth and pipeline replacement programs
` Prepared gas Integrated Resource Plans
` Prepared assessment of forecast methodology and forecast accuracy of gas demands
` Prepared validation of sales forecast and analysis of declining use per customer
` Proposed, testified, and implemented Connecticut’s first gas decoupling mechanism
` Key contributor in settlement negotiations for rate cases and other litigated regulatory
`matters, including the LDC gas expansion plan
` Prepared testimony and exhibits for bi‐annual Purchased Gas Adjustment proceedings
` Prepared biennial Gas LDC Demand and Supply filings
` Prepared testimony and new program tariffs in support of gas unbundling
` Led a gas construction organization, leveraging project management practices to plan and
`execute a $100M annual capital budget
` Responsible for RFP development and bid selection of five‐year contracts of local, regional
`and national gas construction and restoration contractors representing approximately
`seventy work crews
` Developed and implemented a tablet‐based QA/QC inspection program
` Developed annual sales and revenue operating budgets
` Developed rate of return new customer acquisition model
`
`Regulatory Affairs
`
`Business Strategy and Operations
`
`
`
` 2
`
`
`
`

`

`Docket No. RP22-1033-000
`Exhibit No. CER-00002
`Page 3 of 4
`
`PROFESSIONAL HISTORY
`Concentric Energy Advisors, Inc. (2016 – Present)
`
`AVANGRID and affiliated companies (2016)
`Connecticut Natural Gas and The Southern Connecticut Gas Company (2014 – 2016)
`
`UIL Holdings, Inc. (2010 – 2014)
`
`Iberdrola S.A. / Energy East Corporation / Connecticut Natural Gas and The Southern
`Connecticut Gas Company (2001 – 2010)
`
` Guided several process improvement teams
` Successfully negotiated contracts with large cogeneration users avoiding system bypass
`and obtaining regulatory approval
`Vice President (2022‐Present)
`Assistant Vice President (2016‐2021)
`Director, Gas Construction
`Director, Regulatory & Tariffs
`Director, Regulatory & Pricing / Director, Pricing & Analysis
`Manager, Pricing
`Manager, Financial Planning & Analysis
`Business Unit Cell Leader, Overhaul & Repair / Manufacturing – turbine airfoils (1994 – 1996)
`Financial Analyst, Commercial Engine Business (1987 – 1994)
`M.B.A., Concentration in Finance, 1993
`B.S., Finance, 1987
`American Gas Association
`Guild of Gas Managers
`Northeast Gas Association
`Project Management Institute
`Certified Project Management Professional (PMP)
`
`Connecticut Natural Gas Corporation (1997 – 2001)
`
`United Technologies, Inc. – Pratt & Whitney
`Turbo Power & Marine Systems (1996 – 1997)
`
`Pratt & Whitney Aircraft
`
`EDUCATION
`University of Connecticut
`
`Bryant University (College)
`
`PROFESSIONAL AFFILIATIONS
`
`CERTIFICATIONS
`
`
`
` 3
`
`
`
`

`

`Docket No. RP22-1033-000
`Exhibit No. CER-00002
`Page 4 of 4
`
`LEADERSHIP
`Connecticut Economic Resource Center (CERC)
`
`Member, Board of Directors 2008 – 2011
`Treasurer, 2011 – 2016
`Treasurer and Director 2022 ‐ present
`Secretary and Director 2018 – 2022
`Member, Board of Directors 2017 – 2018
`
`Connecticut Power and Energy Society (CPES)
`
`AGA Executive Leadership Development Program – 2012
`
`
`
`
`
` 4
`
`
`
`

`

`Connecticut Public Utilities Regulatory Authority
`
`CASE/APPLICANT
`
`United Illuminating
`Company Application for
`a rate increase
`PURA – review of combined
`heat and power projection
`solicitation.
`The Connecticut Water
`Company
`PURA – review of combined
`heat and power projection
`solicitation.
`Yankee Gas Services DBA
`Eversource Energy – amend
`rate schedules.
`Connecticut Natural Gas
`Corporation & Southern
`Connecticut Gas Company ‐
`OCC successfully advocated
`that the
`gas utilities should not be
`allowed to recover certain
`expenses
`Connecticut Natural Gas
`Corporation & Southern
`Connecticut Gas Company
`Connecticut Natural Gas
`Corporation & Southern
`Connecticut Gas Company
`Connecticut Natural Gas
`Corporation
`
`The Southern Connecticut
`Gas Company
`
`DOCKET
`/CASE NO.
`
`Docket No.
`22‐08‐08
`Docket No.
`18‐08‐
`14RE01
`20‐12‐30
`Docket No.
`18‐08‐14
`Docket No.
`18‐05‐10
`Docket No.
`16‐04‐10
`Docket No.
`13‐06‐
`02RE01
`Docket No.
`13‐06‐02
`Docket No.
`13‐06‐08
`
`Docket No.
`99‐10‐
`25RE01
`
`Docket No. RP22-1033-000
`Exhibit No. CER-00003
`Page 1 of 2
`
`SUBJECT
`
`Rate design, Economic
`Development rate
`Cost of Service analysis for a
`regulated fuel cell project, as
`amended
`Allocated Cost of Service, Rate
`Design and Rate
`Consolidation
`Cost of Service analysis for a
`regulated fuel cell project
`Distribution Rate Case
`Rate design, decoupling, and
`capital trackers
`State of Connecticut LDC Gas
`Expansion Plan: System
`Expansion Reconciliation
`Capital Expenditures, System
`Improvement/Reinforcement
`Projects
`State of Connecticut LDC Gas
`Expansion Plan
`Settlement