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2020. This should save ratepayers approximately $9 million such that the case is functionally <br />equivalent to ACSC's consultants' recommendation of $80.8 million. <br />The Executive Committee recommends a settlement at $90 million. The Effective Date for <br />new rates is December 1, 2020. ACSC members should take action approving the Resolution <br />before November 1, 2020. <br />PROOF OF REVENUES <br />Atmos generated proof that the rate tariffs attached to the Resolution will generate $90 <br />million in additional revenues from ACSC Cities. That proof is attached as Attachment 1 to this <br />Staff Report. ACSC consultants have agreed that Atmos' Proof of Revenues is accurate. <br />BILL IMPACT <br />The impact of the settlement on average residential rates is an increase of $5.15 on a <br />monthly basis, or 9.9 percent. The increase for average commercial usage will be $15.48 or 6.56 <br />percent. A bill impact comparison is attached as Attachment 2. <br />SUMMARY OF ACSC'S OBJECTION TO THE UTILITIES CODE SECTION 104.301 <br />GRIP PROCESS <br />ACSC strongly opposed the GRIP process because it constitutes piecemeal ratemaking by <br />ignoring declining expenses and increasing revenues while rewarding the Company for increasing <br />capital investment on an annual basis. The GRIP process does not allow any review of the <br />reasonableness of capital investment and does not allow cities to participate in the Railroad <br />Commission's review of annual GRIP filings or allow recovery of Cities' rate case expenses. The <br />Railroad Commission undertakes a mere administrative review of GRIP filings (instead of a full <br />hearing) and rate increases go into effect without any material adjustments. In ACSC's view, the <br />GRIP process unfairly raises customers' rates without any regulatory oversight. In contrast, the <br />RRM process has allowed for a more comprehensive rate review and annual evaluation of expenses <br />and revenues, as well as capital investment. <br />2 <br />