Understanding the FERC Natural Gas Rate Case Process and Rate Filing

Understanding the FERC Natural Gas Rate Case Process and Rate Filing

August 27, 2020 | Online :: Central time

This one-day course explores the FERC natural gas rate case process from pre-filing through a Commission Final Order.  FERC rules and regulations govern the establishment of maximum and minimum rates jurisdictional interstate pipelines and storage facilities can charge for their services.  This course will provide attendees with insight into the FERC natural gas rate making world by providing them with understanding of time standards, filing requirements, filing components, settlement process, testimony preparation, hearing, rate case participants, and analytical awareness that is sure to assist in their next rate case.

If you are a FERC employee who is interested in attending this course, our speaker will need to be aware of the project(s) you are currently working on so he can include case studies and current examples that are not a conflict of interest.

Learning Outcomes  

  • Discuss and review the rate case timeline
  • Develop analytical tools useful in the development of rate case participant positions
  • Assess FERC jurisdictional cost of service rate filing components to include, rate base, operation and maintenance expenses, taxes other than income, depreciation and net negative salvage expenses, return, and income taxes
  • Review various cost allocation methods and rate designs currently in use by pipelines and storage companies
  • Discuss recent FERC policies and rulemakings to include the impacts of the 2017 Tax Cuts and Jobs Act and Cost Recovery Mechanisms for Modernization of Natural Gas Facilities
  • Discuss and provide guidance on expert testimony and hearing preparation



EUCI has been accredited as an Authorized Provider by the International Association for Continuing Education and Training (IACET).  In obtaining this accreditation, EUCI has demonstrated that it  complies with the ANSI/IACET Standard which is recognized internationally as a standard of good practice. As a result of their Authorized Provider status, EUCI is authorized to offer IACET CEUs for its programs that qualify under the ANSI/IACET Standard.

EUCI is authorized by IACET to offer CEUs for this event.

Requirements for Successful Completion of Program

Participants must log in each day and be in attendance for the entirety of the course to be eligible for continuing education credit.

Instructional Methods

PowerPoint presentations, interactive group exercise, and group discussion will be used during this course.


Thursday, August 27, 2020 :: Central Time

8:45 – 9:00 a.m. :: Log In

9:00 a.m. – 4:30 p.m. :: Course Timing

12:30 – 1:15 p.m. :: Lunch Break


  • Gather and scrub data
    • What data do you need?
      • General ledger
    • Scrub
      • The point of the filing it is come up with a representative year of business, i.e. costs and rates that recover those costs using a projected level of billing determinates.
      • Removal of non-recurring items
      • Removal of non-recoverable items
      • Inclusion of projected changes
        • Increased labor costs
        • Increase expense items (inflation)
  • Understand desired outcome
  • Meet with customers
  • Prepare rate case schedules and testimony


  • Make the filing
  • Protests
  • Answers to Protests
  • Commission Order for hearing and maximum suspension
  • Rehearing/Clarification Requests to FERC


  • Review of testimony and rate filing
    • Test period concept
  • Four key areas of the rate case
    • Cost of service
      • Rate base
        • Plant
          • What is a plant?
          • What to look for
        • ADDA
          • Projecting
          • What to look for
        • Working capital
          • Prepayments
          • Materials and supplies
          • What to look for
        • ADIT
          • Timing difference
          • Credit to rate base
          • What to look for
        • Regulatory assets and liabilities
          • TCJA impacts
          • Other assets and liabilities
          • What to look for
    • Return
      • Cost of capital calculations
        • DCF
        • Cost of debt
        • Capital structure
        • What to look for
    • Income tax allowance
      • TCJA impacts
      • PL19-2 impacts
      • What to look for
    • Operation and maintenance expenses
      • Labor
      • Material and other
      • Administrative and general
      • Gas costs
      • What to look for
    • Depreciation and net negative salvage expense
      • Economic end life
      • Survivor curves
      • What to look for
    • Taxes other than income
      • Property taxes
      • Payroll taxes
      • Miscellaneous taxes
      • What to look for
  • Cost allocation and rate design
    • Billing determinates
      • Firm
      • Interruptible
      • Reservation/commodity
      • What to look for
    • Cost functionalization
      • Common costs allocation
        • General and intangible plant
        • A&G – KN Method
      • Cost allocation to incrementals/zones
        • Allocation factors
    • Cost classification
    • Straight fixed variable
      • Fixed/reservation
      • Variable/commodity
    • Transmission distance sensitive rate designs
      • Mileage based
        • Cost allocation between mileage and non-mileage
        • Access charge
      • Zone gate
        • Cost allocation between zones mileage and non-mileage
        • Access charge
      • Transmission Postage Stamp rate design
      • Storage rate design
        • Equitable method


  • Top sheets
    • What are top sheets?
    • What aren’t top sheets?


  • Customer vs. Pipeline
  • Customer vs. Customer
  • Stability vs. Unknown Outcome in Litigation


  • Building your case
  • Supporting your case
  • Answering
    • Who files
    • What is filed
  • Cross-Answering
    • Who files
    • What is filed


  • Hearing preparation
  • Testifying


  • Initial
  • Reply

Initial Decision

  • Exceptions

FERC Order on Initial Decision


Kenneth A. Sosnick / Managing Director / FTI Consulting

Prior to joining FTI Consulting, Mr. Sosnick spent over five years as a consultant, extensively engaged in the natural gas, crude/product, and electricity markets. His work included analysis of natural gas pipeline and crude/product pipeline cost of service rates, levelized rates, market-based rates, discounted and negotiated rates, incremental vs. rolled-in project costs, initial certificate rates, allocation of corporate overhead costs, and master-limited partnership income taxes. He also specializes in throughput/system rate design quantities, fuel recover mechanisms, NGA Section 5 rate complaints, return on equity calculations under the discounted cash flow/risk premium/capital asset pricing model/expected earnings methods, depreciation rate and negative salvage rate calculations, asset retirement obligations, FERC Form 1 and 2 filing requirements, as well as being proficient in the application of FERC’s uniform system of accounts.

Mr. Sosnick has prepared expert testimony for proceedings at FERC, prepared expert reports assessing and quantifying damages in civil litigation, conducted strategic analysis for a large energy company considering alternatives for its existing pipeline and storage portfolio, written a whitepaper on the impacts of the Tax Cuts and Jobs Act on FERC regulated assets as well as a whitepaper on the impacts of FERC Orders in SFPP, LP Docket No. IS08-390 related to Master Limited Partnerships and other pass-through entities income tax allowance. In addition, he has conducted confidential buy-side valuations and assessments of regulated electric and natural gas utilities in the U.S.

Before working as a consultant, Mr. Sosnick spent 10 years at FERC and spent two years as an auditor in the Office of Enforcement and eight years as an expert witness and a lead technical staff negotiator on major electric utility, interstate natural gas pipeline, and crude/product pipeline proceedings in the Office of Administrative Litigation. Mr. Sosnick’s insights were incorporated into the revision of the FERC Form 2 in Docket No. RM07‐9‐000, which lead to the FERC-initiated Section 5 natural gas pipeline proceedings from 2009 to today.

Mr. Sosnick currently teaches an executive FERC Natural Gas 101 course for EUCI and previously taught Practical and Regulatory Training for the Natural Gas Interstate Pipeline Industry at the New Mexico State University Center for Public Utilities, specifically addressing FERC requirements for determining “just and reasonable” rates. Mr. Sosnick holds a B.S. in Accounting from the Indiana University of Pennsylvania. He is a member of the Energy Bar Association, FERC Liquids Committee, FERC Natural Gas Pipeline Committee, and FERC Practice Committee.

Online Delivery

We will be using Microsoft Teams to facilitate your participation in the upcoming event. You do not need to have an existing Teams account in order to participate in the broadcast – the course will play in your browser and you will have the option of using a microphone to speak with the room and ask questions, or type any questions in via the chat window and our on-site representative will relay your question to the instructor.

  • You will receive a meeting invitation will include a link to join the meeting.
  • Separate meeting invitations will be sent for the morning and afternoon sessions of the course.
    • You will need to join the appropriate meeting at the appropriate time.
  • If you are using a microphone, please ensure that it is muted until such time as you need to ask a question.
  • The remote meeting connection will be open approximately 30 minutes before the start of the course. We encourage you to connect as early as possible in case you experience any unforeseen problems.


Please Note: This event is being conducted entirely online. All attendees will connect and attend from their computer, one connection per purchase. For details please see our FAQ

If you are unable to attend at the scheduled date and time, we make recordings available to all registrants for three business days after the event

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