FortisAlberta Inc. Compliance Filing to Decision 22741-D01-2018 July 12, 2018 - Decision 23372-D01-2018 - Alberta Utilities Commission
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Decision 23372-D01-2018 FortisAlberta Inc. Compliance Filing to Decision 22741-D01-2018 July 12, 2018
Alberta Utilities Commission
Decision 23372-D01-2018
FortisAlberta Inc.
Compliance Filing to Decision 22741-D01-2018
Proceeding 23372
July 12, 2018
Published by the:
Alberta Utilities Commission
Eau Claire Tower, 1400, 600 Third Avenue S.W.
Calgary, Alberta
T2P 0G5
Telephone: 403-592-8845
Fax: 403-592-4406
Website: www.auc.ab.caContents
1 Decision summary ................................................................................................................. 1
2 Introduction and procedural summary .............................................................................. 1
3 Background ........................................................................................................................... 2
4 Compliance with Commission directions ............................................................................ 3
4.1 Load Settlement Replacement Project ........................................................................... 3
4.1.1 Directions 1, 2 and 3 ......................................................................................... 3
4.2 AESO Contributions Program........................................................................................ 6
4.2.1 Directions 5, 8 and 9 ......................................................................................... 6
4.2.2 Direction 16 ...................................................................................................... 7
4.3 Accounting test requirement of Criterion 1 and Criterion 3 .......................................... 8
4.3.1 Directions 2, 11 and 13 ..................................................................................... 8
4.4 Other directions to be addressed in the 2017 capital tracker true-up application .......... 8
4.4.1 Directions 4, 6, 7, 10, 12 and 14 ....................................................................... 8
5 Order ...................................................................................................................................... 9
Appendix 1 – Proceeding participants ...................................................................................... 11
Appendix 2 – Summary of Commission directions .................................................................. 12
Decision 23372-D01-2018 (July 12, 2018) • iAlberta Utilities Commission
Calgary, Alberta
FortisAlberta Inc. Decision 23372-D01-2018
Compliance Filing to Decision 22741-D01-2018 Proceeding 23372
1 Decision summary
1. In this decision, the Alberta Utilities Commission considers FortisAlberta Inc.’s
compliance filing to Decision 22741-D01-20181 (original decision). In the original decision, the
Commission considered Fortis’ application for approval of its 2016 performance-based
regulation (PBR) capital tracker true-up and directed Fortis to provide additional information and
calculations in a compliance filing.
2. For the reasons outlined in this decision:
The Commission makes no specific determination on Fortis’ compliance with
directions 5, 8 and 9 of the original decision at this time. Fortis is relieved of its
obligation to comply with these directions pending the Commission’s consideration of
the review and variance application in Proceeding 23505.
The Commission finds that Fortis has complied with all other Commission directions as
they pertain to the compliance filing.
Fortis is directed to refund $11.3 million in K factor revenue related to the true-up of the
2016 capital tracker subject to treating $3.3 million2 of this refund as a placeholder until
such time that the Commission makes its determinations in Proceeding 23505 in relation
to the Alberta Electric System Operator (AESO) Contributions Program.3 Fortis is further
directed to include this refund with any associated carrying costs in its 2019 annual
PBR rates filing due on September 10, 2018.
2 Introduction and procedural summary
3. Fortis filed an application with the Commission requesting approval of its compliance
filing on February 28, 2018. Because of adjustments made as a result of directions in the original
decision, Fortis revised its requested refund in K factor revenue from $10.8 million to
$11.3 million.
4. On March 2, 2018, the Commission issued a notice of application and required interested
parties to submit a statement of intent to participate (SIP) by March 14, 2018.4 SIPs were
1
Decision 22741-D01-2018: FortisAlberta Inc., 2016 Performance-Based Regulation Capital Tracker True-Up,
Proceeding 22741, January 11, 2018.
2
Exhibit 23372-X0001, application, paragraph 33, Table 3.
3
Proceeding 23505, AUC-initiated review and variance of Decision 22741-D01-2018.
4
Exhibit 23372-X0005, Notice of application.
Decision 23372-D01-2018 (July 12, 2018) • 1Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
received from the Office of the Utilities Consumer Advocate (UCA) and the Consumers’
Coalition of Alberta (CCA).
5. The main process steps, as amended throughout the course of the proceeding, are set out
in the table below:
Process step Due date
Information requests (IRs) to Fortis April 11, 2018
IR responses from Fortis April 25, 2018
Fortis response to Direction 5 April 27, 2018
IRs to Fortis on Direction 5 May 4, 2018
IR responses from Fortis on Direction 5 May 11, 2018
Submissions on the need for further process May 18, 2018
6. The Commission considers the record of this proceeding to have closed on May 18, 2018,
when the parties filed their submissions on the need for further process.
7. In reaching the determinations set out within this decision, the Commission has
considered all relevant materials comprising the record of this proceeding. References in this
decision to specific parts of the record are intended to assist the reader in understanding the
Commission’s reasoning relating to a particular matter and should not be taken as an indication
that the Commission did not consider all relevant portions of the record with respect to this
matter.
3 Background
8. On September 12, 2012, the Commission issued Decision 2012-237,5 which set out the
PBR framework and approved PBR plans for the distribution utility services of certain Alberta
electric and gas utilities, including Fortis (collectively, the distribution utilities). The approved
PBR plans included a rate adjustment mechanism to fund certain capital-related costs. This
supplemental funding mechanism was referred to in Decision 2012-237 as a “capital tracker” and
the revenue requirement associated with approved amounts was to be collected from customers
by way of a “K factor” adjustment to the annual PBR rate-setting formula.
9. At paragraph 592 of Decision 2012-237, the Commission set out the criteria for capital
tracker treatment approval. The implementation and application of these criteria and the K factor
calculation methodology were considered in a 2013 capital tracker proceeding, leading to
Decision 2013-435.6 The implementation methodology established in Decision 2013-435 has
been used to evaluate the capital tracker programs or projects proposed by the parties throughout
the five-year PBR term, from 2013 to 2017.
5
Decision 2012-237: Rate Regulation Initiative, Distribution Performance-Based Regulation, Proceeding 566,
Application 1606029-1, September 12, 2012.
6
Decision 2013-435: Distribution Performance-Based Regulation 2013 Capital Tracker Applications,
Proceeding 2131, Application 1608827-1, December 6, 2013.
2 • Decision 23372-D01-2018 (July 12, 2018)Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
10. Since the release of Decision 2013-435, each distribution utility has filed separate capital
tracker applications on an annual basis. The three criteria that must be satisfied to receive capital
tracker treatment are:
Criterion 1 – The project must be outside the normal course of the company’s ongoing
operations. This includes assessing whether the actual scope, level, timing and costs of
the project are prudent.
Criterion 2 – Ordinarily, the project must be for the replacement of existing capital assets
or undertaking the project must be required by an external party.
Criterion 3 – The project must have a material effect on the company’s finances.
11. The Commission indicated that it would generally undertake assessments with respect to
all three criteria for capital tracker treatment for all capital programs or projects that the
Commission has not considered in prior capital tracker decisions. In the original decision, the
Commission did not have to assess all aspects of the three criteria for all projects, but only for
the Load Settlement Replacement Project, not previously approved for capital tracker treatment.
12. In the original decision, the Commission did not undertake a reassessment of need under
Criterion 1 in the absence of evidence that the project or program was no longer required.
However, in the original decision, the Commission did assess the scope, level and timing of each
project or program for prudence, and whether the actual costs of the project or program were
prudently incurred, as required by the second part of the project assessment under Criterion 1.
An assessment of the 2016 capital tracker projects and programs was conducted, with respect to
the accounting test under Criterion 1 and materiality test under Criterion 3.
13. In Decision 2013-435, the Commission determined that the accounting test and the first
tier of the materiality test would be applied to approved groupings (i.e., either at a project or a
program level). When necessary, however, the Commission would consider the individual
component projects comprising the approved groupings in order to assess the need for capital
expenditures and the reasonableness of the forecast costs. The second tier of the materiality test
is applied to the aggregate revenue requirement requested for all capital tracker projects. 7 The
Commission also determined that the reasonableness of the grouping of capital projects would be
assessed on a case-by-case basis for each individual company.8
4 Compliance with Commission directions
4.1 Load Settlement Replacement Project
4.1.1 Directions 1, 2 and 3
14. Directions 1, 2 and 3 in the original decision related to Fortis’ application for approval of
the Load Settlement Replacement Project, which was not included in its previous capital tracker
requests. In paragraph 25 of the original decision, the Commission found that it could not make a
7
Decision 2013-435, paragraph 407.
8
Decision 2013-435, paragraph 406.
Decision 23372-D01-2018 (July 12, 2018) • 3Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
determination on the reasonableness of treating the Load Settlement Replacement Project as a
separate capital tracker project without further information. As a result, it directed Fortis to:
explain the activities that justify the historical capital additions (from 2005 to 2012)
included in the accounting test for the Load Settlement Replacement Project;
identify all projects in its accounting test that included historical capital additions
associated with the old Energy Vision Enterprise (EVE) and/or Post Final Adjustment
Mechanism (PFAM) applications; and
explain why it did not group all of its expenditures related to load settlement together
under the Load Settlement Replacement Project.
15. Fortis confirmed that the 2012 going-in rate base for the Load Settlement Replacement
Project included all actual and forecast costs associated with the old EVE and PFAM
applications, and that the 2016 closing actual rate base correctly reflected retirement of those
costs. As such, there are no old EVE and/or PFAM costs included in other project groupings.9
16. Fortis explained that in re-examining all Information Technology – Software groupings,
it determined that there were other additions that had not been originally included in the Load
Settlement Replacement Project grouping. As a result, Fortis adjusted the accounting test,
resulting in a decrease of $47,000 of K factor revenue for the Load Settlement Replacement
Project.10
17. In describing why its expenditures related to load settlement were not grouped together
under the Load Settlement Replacement Project, Fortis explained that the accounting test
includes two groupings related to load settlement: Software – Load Settlement, and the Load
Settlement Replacement Project. EVE and PFAM applications perform the main settlement and
PFAM calculations, and process many market transactions defined in the Settlement System
Code. These are the applications that were replaced as part of the Load Settlement Replacement
Project. Other applications, which were not replaced as part of the Load Settlement Replacement
Project, collect and prepare metering data for input into the settlement calculation and
distribution to the market, and process site-specific changes that are required as inputs into the
settlement calculation. These applications include Lodestar, MV90 and certain functionalities of
SAP and Biztalk middleware.11
18. In response to a Commission IR, Fortis explained that to determine whether existing and
new applications fall under the Software – Load Settlement grouping or the Load Settlement
Replacement Project grouping, it assessed each application as to whether it was replaced or
modified as a direct result of the Load Settlement Replacement Project. Any historical capital
additions and retirements that were incurred as a result of the replacement of the EVE and PFAM
applications were grouped in the Load Settlement Replacement Project. Any historical or new
9
Exhibit 23372-X0001, application, paragraph 7.
10
Exhibit 23372-X0001, application, paragraph 8.
11
Exhibit 23372-X0001, application, paragraph 9.
4 • Decision 23372-D01-2018 (July 12, 2018)Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
additions to ancillary applications fell under the Software – Load Settlement grouping as they
were not replaced or modified as a result of this project.12
19. Fortis also confirmed that minor labour costs were incurred for configuration of the
Biztalk middleware application in order for it to achieve compatibility with the new load
settlement application. These costs were included in the Load Settlement Replacement Project
grouping because they were incurred as a direct result of the replacement of the EVE and PFAM
applications.13
20. In another IR, the Commission asked Fortis to submit the accounting test and related
capital tracker schedules for 2016, showing both the Software – Load Settlement and the Load
Settlement Replacement Project combined into one project grouping and to confirm if it would
still meet the accounting test requirement of Criterion 1 and the two-tiered materiality test
requirement of Criterion 3. Fortis confirmed that these requirements would be met and would
result in an applied-for K factor revenue of $59.4 million,14 compared to the revised applied-for
revenue of $59.6 million.15
21. Fortis was also asked to explain why it is necessary to have two separate project groups,
given the identical service lives and the relationship of the inputs and processes used for the new
load settlement application. Fortis responded that the indicative service life for the Load
Settlement Replacement Project is determined using a weighted calculation of the asset classes
involved because it consists of both hardware and software asset classes. Fortis indicated that
while the weighted calculation resulted in the same indicative service life for 2016, as the
weightings change so will the indicative service life, which will not always be equal to the
Software – Load Settlement group.16
22. The UCA and the CCA did not ask Fortis any questions on the Load Settlement
Replacement Project.
Commission findings
23. The Commission finds that Fortis’ explanations on why the Load Settlement Project is
included as a separate project grouping are reasonable. In reaching this determination, the
Commission has also reviewed the revised calculations requested in a Commission IR.17
24. The Commission accepts Fortis’ explanation that the Software – Load Settlement
contained software ancillary to the EVE and PFAM applications, all of which were not replaced
or modified as part of the project. Accordingly, the Commission finds it reasonable that the Load
Settlement Replacement Project contains only the replacement of the EVE and PFAM
applications. The Commission is also satisfied that no old EVE/PFAM application costs are
included in any other project groupings.
12
Exhibit 23372-X0015, FAI-AUC-2018APR11-001(a).
13
Exhibit 23372-X0015, FAI-AUC-2018APR11-001(b) and (c).
14
Exhibit 23372-X0016, Attachment FAI-AUC-2018APR11-001.01.
15
Exhibit 23372-X0001, application, paragraph 33, Table 3.
16
Exhibit 23372-X0015, FAI-AUC-2018APR11-002.
17
Exhibit 23372-X0016, Attachment FAI-AUC-2018APR11-001.01.
Decision 23372-D01-2018 (July 12, 2018) • 5Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
25. As a result, the Commission is satisfied that the Load Settlement Replacement Project
and the Software – Load Settlement groupings are sufficiently different that they both can exist
on their own, and approves the K factor revenue of $1.6 million for the Load Settlement
Replacement Project.
4.2 AESO Contributions Program
4.2.1 Directions 5, 8 and 9
26. In the original decision, the Commission rejected Fortis’ proposal that AESO
contributions be deemed to be final each year and further rejected Fortis’ related proposal that
the 2016 AESO contribution capital tracker be considered final upon the issuance of the
Commission’s original decision. As a result, in Direction 5, at paragraph 80 of the original
decision, the Commission directed Fortis to recalculate AESO contributions for all projects to
reflect the AESO contribution refund that Fortis would be eligible for under subsection 2 of
Section 9 of the ISO tariff if it immediately increased demand transmission service (DTS) to the
amount of the maximum capacity of the project. Fortis was also directed to calculate the effect of
such DTS contract capacity changes to determine a revised prior-year true-up for the year 2016.
27. In the compliance filing, Fortis declined to comply with Direction 5, stating it believed
that the Commission had signalled “an intention to embark on an overarching reassessment of
the fundamentals of the AESO Tariff’s contribution policy as applied to DFOs [distribution
facility owners] and customers, and the ways in which DFOs are permitted a reasonable
opportunity to recover capital that they invest in accordance with that policy.”18
28. On April 20, 2018, the Commission initiated a review and variance of Direction 5 with
respect to the Commission’s determination of how to finalize the AESO Contributions Program
amounts to enable Fortis’ transition to the next generation PBR. The Commission assigned
Proceeding 23505 to its initiated review. That proceeding is ongoing.
29. In a letter dated April 20, 2018,19 the Commission directed Fortis to submit recalculated
AESO contributions in compliance with Direction 5 of the original decision. The Commission
clarified that the resulting AESO Contributions Program amounts for 2016 would be treated as a
placeholder. The Commission advised that in light of this placeholder treatment, it would not use
the recalculated amount to determine any refund from the 2016 true-up for this program, pending
its determination in Proceeding 23505. Fortis complied with this direction, and filed recalculated
amounts.20
30. Direction 8 set out at paragraph 129 of the original decision required Fortis to file a report
for each project that shows whether Fortis intends to seek a refund, the date by which the refund
is expected to be provided and the amount of the contribution refund in each case.
31. In its response, Fortis stated that it had submitted DTS adjustment requests via system
access service requests (SASRs) for five point-of-delivery substations. Fortis explained that the
contribution adjustment amount and date of adjustment for each of the SASRs are pending the
18
Exhibit 23372-X0001, page 2.
19
Exhibit 23372-X0013, AUC letter – Directions applicable to AESO Contributions, April 20, 2018.
20
Exhibit 23372-X0018, Attachment FAI-AUC-2018APR20-001-.01 – Updated 2016 AESO Contributions.
6 • Decision 23372-D01-2018 (July 12, 2018)Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
outcome of AESO assessments and, therefore, the timing and estimated contribution adjustment,
if any, are not determinable at this time.21
32. In Direction 9, set out at paragraph 138 of the original decision, Fortis was directed to
provide its view and potential recommendations on the finalization of 2017 AESO contribution
amounts. In its response, Fortis referenced its proposal from Proceeding 22394, that final
(i.e., post capital tracker true-ups) AESO contributions in each year from 2013 to 2017 be
recognized as the actual contributions paid in those years.22 Fortis further noted that the
Commission’s rejection of this proposal in Decision 22741-D01-2018 signalled an intention to
consider notional adjustments to Fortis’ historical AESO contribution amounts for purposes of
establishing K-bar capital additions using review of DTS contract levels as a basis for such
notional adjustments.23 However, consistent with its position on Direction 5, Fortis submitted
that the requirements of second generation rebasing cannot be fairly addressed by using notional
DTS contract levels to adjust actual AESO contribution amounts. Instead, Fortis submitted that
any consideration of AESO contribution amounts should be guided by the following principles:
The Commission’s past consideration of the Company’s AESO Contribution
program in capital tracker proceedings created legitimate expectations on the part
of FortisAlberta regarding the criteria for the program’s assessment and the ways in
which approved amounts may reasonably be subject to revision. Such reasonable
revision cannot fairly include adjustments to accommodate the particulars of a
rebasing approach adopted in 2017-18 in respect of Second Generation PBR.
The AESO’s customer contribution policy is a feature of the ISO Tariff.
Consequently, general concerns relating to policies implemented under that tariff
are most properly considered within the context of the pending AESO 2018 ISO
Tariff proceeding, where impacts on all stakeholders may be assessed.
To the extent that the Commission determines that FortisAlberta’s historical AESO
customer contributions should be examined for the purpose of rebasing for the
second term of PBR, such assessment should take place in the appropriate PBR
rebasing proceeding, where all potential impacts of adjustments can be
understood.24
Commission findings
33. Pending the Commission’s decision in Proceeding 23505, the AESO Contributions
Program has been given placeholder treatment and no specific determination on Fortis’
compliance with directions 5, 8 and 9 of the original decision will be made in this decision.
Fortis is consequently relieved of its obligation to comply with these directions at this time.
4.2.2 Direction 16
34. In paragraph 119 of the original decision, the Commission directed Fortis to remove all
costs transferred from the Big Rock, Black Diamond and Waiparous area projects from
21
Exhibit 23372-X0001, application, paragraph 16.
22
Exhibit 23372-X0001, paragraph 25.
23
Exhibit 23372-X0001, paragraph 26.
24
Exhibit 23372-X0001, pages 15-16.
Decision 23372-D01-2018 (July 12, 2018) • 7Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
the AESO contribution amounts claimed, because Fortis is contractually required to pay
cancellation costs to AltaLink Management Ltd. for these projects.
35. In response, Fortis removed $6.5 million of costs, which consisted of $4.1 million for the
Okotoks 678S Transformer Add Project (AESO Project 1670), and $2.4 million for the
Cochrane 291S Transformer Upgrade and 25 kilovolt Breaker Add Project (AESO Project 1450).
Fortis stated that there is no AESO contribution amount included in the AESO Contributions
Program for the High River 65S portion of AESO Project 1670.25
Commission findings
36. The Commission is satisfied that Fortis has complied with the Commission’s direction at
paragraph 119 of Decision 22741-D01-2018.
4.3 Accounting test requirement of Criterion 1 and Criterion 3
4.3.1 Directions 2, 11 and 13
37. At paragraph 258 of the original decision, the Commission directed Fortis to revise its
accounting test to reassess whether the capital tracker programs or projects included in its
2016 true-up satisfy the accounting test requirement of Criterion 1. At paragraph 272, the
Commission directed Fortis to reassess whether the programs or projects included in its
2016 true-up satisfy the two-tiered materiality test requirement of Criterion 3.
38. Fortis filed a revised accounting test as part of its revised 2016 capital tracker schedules,
in which it reassessed the accounting test requirement of Criterion 1 and applied the Criterion 3
two-tiered materiality test, based on the projects and required revisions.26
Commission findings
39. The Commission is satisfied that all of the programs or projects included in Fortis’
2016 true-up satisfy the accounting test requirement of Criterion 1. It is also satisfied that Fortis
has interpreted and applied the Criterion 3 two-tiered materiality test properly for the purposes of
its 2016 capital tracker true-up, based on the projects and assumptions included in the
application. As a result, the Commission finds that all of the programs or projects included in
Fortis’ 2016 true-up qualify for capital tracker treatment.
4.4 Other directions to be addressed in the 2017 capital tracker true-up application
4.4.1 Directions 4, 6, 7, 10, 12 and 14
40. Fortis confirmed that directions 4, 6, 7, 10, 12 and 14 from the original decision will be
addressed in its 2017 capital tracker true-up application. As a result, the Commission will review
and provide comment on these directions in Proceeding 23649 under which Fortis’ 2017 capital
tracker true-up application is considered.
25
Exhibit 23372-X0001, application, paragraphs 28-32.
26
Exhibit 23372-X0002, Appendix B – 2016 Capital Tracker Schedules.
8 • Decision 23372-D01-2018 (July 12, 2018)Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
5 Order
41. It is hereby ordered that:
(1) FortisAlberta Inc. has complied with all Commission directions as they pertain to
the compliance filing, with the exception of directions 5, 8 and 9, for which the
Commission makes no specific determination pending the Commission’s
consideration of its review and variance application in Proceeding 23505.
(2) FortisAlberta Inc. is directed to refund $11.3 million in K factor revenue related
to the true-up of the 2016 capital tracker, subject to treating $3.3 million27 of this
refund as a placeholder until such time that the Commission makes its
determinations in Proceeding 23505 in relation to the AESO Contributions
Program.28 FortisAlberta Inc. is further directed to include this refund with any
associated carrying costs in its 2019 annual PBR rates filing due on
September 10, 2018.
Dated on July 12, 2018.
Alberta Utilities Commission
(original signed by)
Neil Jamieson
Panel Chair
(original signed by)
Anne Michaud
Commission Member
(original signed by)
Carolyn Hutniak
Commission Member
27
Exhibit 23372-X0001, application, paragraph 33, Table 3.
28
Proceeding 23505, AUC-initiated review and variance of Decision 22741-D01-2018.
Decision 23372-D01-2018 (July 12, 2018) • 9Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
Appendix 1 – Proceeding participants
Name of organization (abbreviation)
Company name of counsel or representative
FortisAlberta Inc. (Fortis or FAI)
Consumers’ Coalition of Alberta (CCA)
Office of the Utilities Consumer Advocate (UCA)
Brownlee LLP
Alberta Utilities Commission
Commission panel
N. Jamieson, Panel Chair
A. Michaud, Commission Member
C. Hutniak, Commission Member
Commission staff
S. Albert (Commission counsel)
S. Sharma
J. Halls
Decision 23372-D01-2018 (July 12, 2018) • 11Compliance Filing to Decision 22741-D01-2018 FortisAlberta Inc.
Appendix 2 – Summary of Commission directions
This section is provided for the convenience of readers. In the event of any difference between
the directions in this section and those in the main body of the decision, the wording in the main
body of the decision shall prevail.
1. For the reasons outlined in this decision:
The Commission makes no specific determination on Fortis’ compliance with
directions 5, 8 and 9 of the original decision at this time. Fortis is relieved of its
obligation to comply with these directions pending the Commission’s consideration of
the review and variance application in Proceeding 23505.
The Commission finds that Fortis has complied with all other Commission directions as
they pertain to the compliance filing.
Fortis is directed to refund $11.3 million in K factor revenue related to the true-up of the
2016 capital tracker subject to treating $3.3 million of this refund as a placeholder until
such time that the Commission makes its determinations in Proceeding 23505 in relation
to the Alberta Electric System Operator (AESO) Contributions Program. Fortis is further
directed to include this refund with any associated carrying costs in its 2019 annual
PBR rates filing due on September 10, 2018. .................................................... Paragraph 2
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