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<br />ATMOS <br />energy <br /> <br />Charles R. Yarbrough, II <br />Vice President <br />Rates & Reoulatorv Affairs <br /> <br />August 31, 2006 <br /> <br />Mr. Stephen L. Pitner <br />Railroad Commission of Texas <br />Gas Services Division <br />1701 North Congress Avenue <br />P. O. Box 12967 <br />Austin, Texas 78711-2967 <br /> <br />Re: Atmos Energy Corp., Mid-Tex Division Annual Gas Cost Reconciliation Filing <br /> <br />Dear Mr. Pitner: <br /> <br />Attached is Atmos Energy Corp., Mid-Tex Division's (the "Company") Gas Cost <br />Reconciliation filing for the twelve month period ended June 30, 2007. This report has <br />been prepared in accordance with the order of the Railroad Commission of Texas under <br />Gas Utilities Docket ("GUD") No. 9400. In response to the Railroad Commission of <br />Texas Audit No. 06-037, Auditor's Recommendation, the Company has included an <br />additional schedule (Schedule 9) in the filing to reflect the percentage of Lost and <br />Unaccounted For Gas for the reconciliation period. Additionally, the Company has not <br />included the cost of odorant in gas cost as directed by the Commission; however, the <br />Company again reiterates that it does not agree with this position. <br /> <br />The Company is requesting herein an exception to the Final Order issued in GUD 9400, <br />Finding of Fact 121, which directs the Reconciliation Factor to be determined for the <br />"succeeding October through June billing months." In this filing, the Company is <br />requesting the Reconciliation Factor be determined using the months of October <br />through March. Due to the (Over) collection during the current reconciliation period, as <br />shown on Schedule 2 (attached), the Company would prefer to refund the (Over) <br />collection to customers during the typical peak winter usage period to help mitigate the <br />seasonally higher gas cost. The Company has included the standard calculation of the <br />Reconciliation Factor over the nine (9) month period designated in GUD 9400 of <br />($.0781) and an alternative calculation of the Reconciliation Factor over a six (6) month <br />period of ($.0954). Please advise as soon as possible regarding approval to refund the <br />Over collection over a six (6) month period. <br /> <br />Atmos Energy Corporation <br />5420 LBJ Freeway, Suite 1800 <br />Dallas, TX 75240 <br />n "'l-t A "line "'l~f'\n ~ "')-t A "')n.c .,.. 'lC ....h......I,..... ......~.."I ,,.,ht;;'\"=It"""',.,,~on.c.r"n\f r-nm <br />