23-057-18

The docket primarily addresses infrastructure growth in the context of Dominion Energy Utah's (now Enbridge Gas Utah) Replacement Infrastructure 2024 Annual Plan and Budget. The key areas of growth identified are the replacement and reinforcement of high pressure (HP) feeder lines and intermediate high pressure (IHP) belt lines across the utility's service territory.

Areas of Growth:
- Replacement of HP feeder lines in Salt Lake, Weber, Utah, Davis, and Cache counties (such as FL34, FL13, FL21-50, FL26, FL21-13, FL21-19, FL23-2) 1, 1.
- Replacement of IHP belt lines, specifically focusing on Salt Lake County 2, 3.

Key Considerations for Each Area:
- Environmental requirements and permitting (for example, UDOT I-15 project conflict, local city requirements).
- Real property and right-of-way (ROW) acquisitions, including coordination with municipalities and property development.
- Efficiency considerations and integrity management efficacy (especially noted for FL13).
- Scheduling adjustments based on project-specific constraints such as groundwater complications, permitting delays, and construction sequencing.
- The need for reinforcement in areas where the IHP system requires feeder line support (noted for FL23-2 in Cache County) 1, 1.

The docket also references ongoing efforts to group projects geographically to reduce costs and logistical complexity, and highlights that infrastructure replacement will continue at rates adjusted for inflation 2, 1.

The financial and timeline risks and concerns discussed in this docket include:

Financial Risks and Concerns:
- Actual expenditures may exceed budgeted amounts for certain projects. For example, in the first quarter of 2024, the company spent $142,296 more than estimated on feeder line 13, though this overage was expected to be offset by a contractor rebate later in the year. This indicates risk related to timing and receipt of anticipated rebates or cost offsets 1.
- For Salt Lake County IHP belt line replacements, actual spending in 2024 was $14,181,740, exceeding the budgeted amount of $11,000,000 by $3,181,740, highlighting a significant variance risk 2.
- The company is required to provide quarterly variance reports to describe any material variances between actual and budgeted expenditures, indicating ongoing risk of budget deviations 1.

Timeline Risks and Concerns:
- There can be a timing difference between when work is completed and when retirements are recorded, impacting the apparent footage and timing of replacement projects in budget documents. This timing difference can cause annual plans to appear higher or lower than actual activity, leading to confusion and potential planning risks 3.
- Some replacement projects, such as those on feeder line 34 and the Salt Lake County belt line, are expected to continue throughout the year and may not be completed within the calendar year, which poses a risk of project delays beyond scheduled timelines 4.
- The company’s quarterly reports are designed to track progress and address material variances, but these reports also highlight the inherent risk of not completing projects as planned 1, 4.

In summary, the key risks are cost overruns (sometimes mitigated by expected rebates), timing mismatches in reporting versus actual work, and the possibility of not meeting projected completion dates for certain projects.

The main stakeholders in Docket No. 23-057-18 (Dominion Energy Utah/Enbridge Gas Utah’s Replacement Infrastructure 2024 Annual Plan and Budget) are:

- Enbridge Gas Utah (formerly Dominion Energy Utah, formerly Questar Gas Company): The utility company that filed the infrastructure replacement plan and budget proposal. They are advocating for approval and implementation of their proposed plan and budget 1, 2.

- Utah Division of Public Utilities (DPU): The state regulatory division responsible for reviewing the utility’s filings for compliance. The DPU reviewed the 2024 plan and budget and recommended that the Public Service Commission (PSC) acknowledge the filing as compliant with all relevant PSC orders. This means the DPU is supportive of the utility’s proposal from a compliance standpoint, but its recommendation is not an endorsement of the prudency of costs or rate recovery 3, 4, 3.

- Utah Public Service Commission (PSC): The regulatory commission that reviews filings, receives DPU’s recommendations, and issues formal acknowledgments or orders. The PSC has acknowledged the 2024 filing as compliant based on DPU’s recommendation 2.

- Office of Consumer Services: Noted as a recipient of correspondence, but there is no indication in the provided excerpts of their explicit support or opposition to the proposals.

There is no evidence in the excerpts of any stakeholder formally opposing the utility’s proposals. The DPU’s recommendation is for compliance acknowledgment, not opposition, and the PSC has acknowledged the filing. No intervenors or public commenters are noted as opposed in the excerpts provided.

Key events and submissions in the proceeding for Dominion Energy Utah’s Replacement Infrastructure 2024 Annual Plan and Budget (Docket No. 23-057-18) are as follows:

- November 15, 2023: Dominion Energy Utah filed its Replacement Infrastructure 2024 Annual Plan and Budget with the Public Service Commission of Utah, meeting the annual requirement to submit an estimated costs and schedule plan for infrastructure replacement 1.
- November 15, 2023: The Commission issued an action request to the Division of Public Utilities (DPU) to review the filing for compliance and make recommendations, with a due date of December 15, 2023 2.
- November 16, 2023: The Commission issued a notice of filing and comment period, allowing interested persons to submit comments on or before December 18, 2023 2.
- December 18, 2023: The DPU filed its comments and response to the action request, including discussion of the proposed budget and project schedule 2.
- January 4, 2024: The Commission sent a letter acknowledging the budget and directing the company to answer questions raised by the DPU regarding the reduction in feeder line (FL) replacement and a possible discrepancy for FL 13 3.
- January 9, 2024: Dominion Energy Utah submitted reply comments addressing the DPU’s questions and providing clarification on the budget and FL 13 retirement timing 3.
- June 2024: Dominion Energy Utah indicated it would host its annual technical conference in June 2024 to address further questions about infrastructure tracker projects 3.
- July 5, 2024: The Division of Public Utilities filed an Action Request Response recommending the Commission acknowledge Enbridge Gas Utah’s (formerly Dominion Energy Utah) compliance with required reporting 4.

This timeline reflects the statutory filings, Commission directives, DPU reviews, and responses related to the 2024 infrastructure replacement plan.

Docket No. 23-057-18 concerns the 2024 annual plan and budget for the replacement of natural gas infrastructure (high pressure feeder lines and intermediate high pressure belt lines) in Utah, originally filed by Dominion Energy Utah and subsequently managed by Enbridge Gas Utah after a change in ownership in 2024. The plan details anticipated costs, schedules, and project segments to be replaced, with a total 2024 budget of $86.7 million ($74.2 million for feeder lines, $11 million for belt lines, and $1.5 million for engineering studies), consistent with the inflation-adjusted spending cap set by the Public Service Commission (PSC) 1, 1.

The annual plan and budget, required by PSC orders and tariff section 2.07, is subject to quarterly variance reporting and annual updates of master lists and replacement schedules for regulatory review. The Division of Public Utilities reviewed the filings and recommended the PSC acknowledge them as compliant, confirming that the program is proceeding as designed. The required master lists and schedules are filed confidentially but are reviewed annually to ensure compliance and inform regulators of progress and spending 2, 3, 2, 4.