May 29, Dear Secretary Asbury:

Transcription

1 520 Green Lane Union, NJ phone Via FedEx & Electronic Mail May 29, 2015 Irene Kim Asbury, Secretary State of New Jersey Board of Public Utilities 44 South Clinton Avenue, 9 th Floor P.O. Box 350 Trenton, New Jersey Re: In The Matter Of The Petition Of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas To Review Its Periodic Basic Gas Supply Service Rate BPU Docket No. Dear Secretary Asbury: Enclosed for filing are an original and ten copies of the Petition of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas ( Elizabethtown or Company ) to revise its Periodic Basic Gas Supply Service ( BGSS-P ) rate, as discussed below. Attached to and made part of the Petition are the testimony and supporting schedules of Company witnesses Thomas Kaufmann and Leonard J. Willey. The Petition concerns the period October 1, 2015 through September 30, 2016 ( the BGSS Year ). Elizabethtown proposes to decrease its currently effective BGSS-P rate from $ per therm to $ per therm, inclusive of all taxes. The Company s currently effective BGSS-P rate is in effect in accordance with a Board Order dated May 19, 2015 issued in BPU Docket No. GR As discussed in the testimony attached to Elizabethtown s Petition, the proposed decrease in the BGSS-P rate is due primarily to (i) lower gas costs and (ii) credits provided to the Company s firm customers as a result of the Company s outsourcing of its gas supply and upstream capacity management to Sequent Energy Management L.P. Elizabethtown projects that it will begin the BGSS Year with a gas cost overrecovery balance of approximately $3.0 million.

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3 IN THE MATTER OF THE PETITION OF PIVOTAL UTILITY HOLDINGS, INC. d/b/a ELIZABETHTOWN GAS TO REVIEW ITS PERIODIC BASIC GAS SUPPLY SERVICE RATE BPU DOCKET NO. GR SERVICE LIST Mary Patricia Keefe, Esq. Elizabethtown Gas 520 Green Lane Union, NJ Susan Potanovich Elizabethtown Gas 520 Green Lane Union, NJ Timothy Sherwood AGL Resources Ten Peachtree Place Atlanta, GA Megan Lupo, Esq. Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Robert Schultheis Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Beverly Tyndell Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Kurt S. Lewandowski, Esq. Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ Thomas Kaufmann Elizabethtown Gas 520 Green Lane Union, NJ Diane Rojek Elizabethtown Gas 520 Green Lane Union, NJ Erica McGill, Esq. AGL Resources Ten Peachtree Place Atlanta, GA Jerome May Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Irene Kim Asbury, Secretary Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Stefanie A. Brand, Director Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ Brian Lipman, Litigation Manager Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ Leonard J. Willey Elizabethtown Gas 520 Green Lane Union, NJ David Weaver AGL Resources Ten Peachtree Place Atlanta, GA Kenneth Yagelski AGL Resources 544 S. Independence Blvd Virginia Beach, VA Henry Rich Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ Scott Sumliner Board of Public Utilities 44 South Clinton Avenue, 9th Floor P.O. Box 350 Trenton, NJ James W. Glassen, Esq. Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ Felicia Thomas-Friel, Esq. Division of Rate Counsel 140 East Front Street, 4th Floor P.O. Box 003 Trenton, NJ Page 1 of 2

4 IN THE MATTER OF THE PETITION OF PIVOTAL UTILITY HOLDINGS, INC. d/b/a ELIZABETHTOWN GAS TO REVIEW ITS PERIODIC BASIC GAS SUPPLY SERVICE RATE BPU DOCKET NO. GR SERVICE LIST Alex Moreau, DAG Department of Law & Public Safety Division of Law 124 Halsey Street P.O. Box Newark, NJ Deborah Franco, Esq. Cullen and Dykman Garden City Center 100 Quentin Roosevelt Blvd. Garden City, NY Babette Tenzer, DAG Department of Law & Public Safety Division of Law 124 Halsey Street P.O. Box Newark, NJ Kenneth T. Maloney, Esq. Cullen and Dykman th Street, NW, Suite 550 Washington, DC Page 2 of 2

5 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas 2015 / 2016 BGSS Filing MINIMUM FILING REQUIREMENT (MFR) INDEX Minimum Filing Requirement Schedule(s) 1. Motion, Supporting Testimony & Tariff Modifications Petition, Testimony, TK Computation of Proposed BGSS Rates LJW-1, LJW-3 3. Public Notice with Proposed Impact on Bills Petition 4. Actual and Forecasted Refund Amounts TK-3, LJW-9 5. Cost of Gas Sendout by Component TK-2, TK-5, TK-7, LJW-2, LJW-4, LJW-6, LJW-7, LJW-10, LJW BGSS Contribution and Credit Offsets TK-3, TK-4, LJW-9, LJW Over/Under Recovery Comparisons TK-1, TK-6, LJW-3 8. Wholesale Gas Pricing Assumptions LJW-7, LJW GCUA Recoveries and Balances not applicable 10. Historical Service Interruptions TK Gas Price Hedging Activities TK-11, LJW Storage Gas Volumes, Prices and Utilitization TK-7, LJW Affiliate Gas Supply Transactions TK Supply and Demand Data LJW Actual Peak Day Supply and Demand TK Capacity Contract Changes Testimony - L J Willey pgs FERC Pipeline Activities LJW-15

6 STATE OF NEW JERSEY BOARD OF PUBLIC UTILITIES x In The Matter Of The Petition Of Pivotal Utility : Holdings, Inc. d/b/a Elizabethtown Gas To : Docket No. GR Review Its Periodic Basic Gas Supply Service : Rate : SUMMARY SHEET x This Petition presents the request of Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas ( Petitioner ) that the Board of Public Utilities approve Petitioner's Periodic Basic Gas Supply Service ( BGSS-P ) charge, and grant such other and further relief as described in the Petition. The Petition proposes to decrease the BGSS-P rate from $ per therm to $ per therm. The proposed BGSS-P rate will decrease the bill of a residential heating customer using 100 therms by $8.42 from $99.94 to $91.52, a decrease of 8.4% based on rates in effect June 1, 2015.

7 STATE OF NEW JERSEY BOARD OF PUBLIC UTILITIES x In The Matter Of The Petition Of Pivotal Utility : Holdings, Inc. d/b/a Elizabethtown Gas To : Docket No. GR Review Its Periodic Basic Gas Supply Service : Rate : PETITION x To The Honorable Board of Public Utilities: Petitioner, Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas ( Petitioner or Company ), a public utility corporation duly organized under the laws of the State of New Jersey subject to the jurisdiction of the Board of Public Utilities ( Board ), respectfully states: Petitioner's principal business office is located at 520 Green Lane, Union, New Jersey, 2. Communications and correspondence concerning these proceedings should be sent as follows: Mary Patricia Keefe Erica McGill Vice President, Regulatory Affairs Regulatory Counsel and Business Support AGL Resources Inc. Pivotal Utility Holdings, Inc. 10 Peachtree Place d/b/a Elizabethtown Gas Atlanta, Georgia Green Lane (404) Union, New Jersey emcgill@aglresources.com (908) mkeefe@aglresources.com Kenneth T. Maloney Deborah Franco Cullen and Dykman, LLP Cullen and Dykman, LLP 1101 Fourteenth Street, N.W., Suite Quentin Roosevelt Boulevard Washington, D.C Garden City, New York (202) (516) kmaloney@culldyk.com dfranco@culldyk.com 3. Petitioner is engaged in the business of transmission and distribution of natural and mixed gas to approximately 280,000 customers in its service territory located principally in Hunterdon, Mercer, Middlesex, Morris, Sussex, Union and Warren Counties.

8 4. Pursuant to the terms of the Basic Gas Supply Service ( BGSS ) clause contained in Petitioner s tariff as approved by the Board by Order dated March 30, 2001 in BPU Docket No. GX and GO , and as modified by the Board by Orders dated December 7, 2001 in Docket No. GR , et al., November 22, 2002 in Docket No. GR , January 6, 2003 in Docket No. GX and December 17, 2009 in Docket No. GR , Petitioner proposes to reduce the current Periodic BGSS charge ( BGSS-P Charge ) and submits this filing to account for the actual and forecasted gas costs and BGSS rates for the twelve month period October 1, 2014 through September 30, 2015 ( Base BGSS Year ). All information presented in this filing regarding the period October 1, 2015 through September 30, 2016 ( the BGSS Year ) reflects forecast data. Petitioner s accounting for its gas costs and recoveries for the Base BGSS Year is based upon actual data for the seven months ended April 30, 2015 and projected data for the period May 1, 2015 through September 30, In addition, the information and data contained in this Petition and in the supporting Exhibits and Schedules are intended to comply with the "Annual BGSS Minimum Filing Requirements" adopted by the Board by Order dated June 20, 2003 in Docket No. GR , et al. 5. In accordance with the Board s January 6, 2003 Order in Docket No. GX as amended with the Board s December 17, 2009 Order in Docket No. GR , Petitioner recovers gas costs from its residential, small commercial and gas light sales service classes through the BGSS-P rate. Petitioner recovers gas costs from its firm large commercial, industrial and electric generation customers through the assessment of the Monthly BGSS ( BGSS-M ) rate. Under Petitioner s tariff, the BGSS-P rate consists of a gas cost component ( GCC-P ) and a capacity cost component ( CCC-P ) and is adjusted to reflect the projected beginning over or underrecovery balance from the prior period. The CCC-P established in this proceeding is also used to determine the monthly BGSS-M rate. However, BGSS-M rates are not established in this proceeding; they are established on a monthly basis. 6. Petitioner proposes to decrease its current BGSS-P rate of $ per therm inclusive of all applicable taxes to $ per therm inclusive of all applicable taxes. The current BGSS-P rate of 2

9 $ per therm was approved in accordance with a Board Order dated May 19, 2015 in BPU Docket No. GR Petitioner projects that its recoverable gas costs will be approximately $18 million lower than the level recoverable through its current BGSS-P rate in the BGSS Year. This projection is based on Petitioner s best estimate of gas costs to be incurred in the BGSS Year. Petitioner s proposed BGSS-P rate is based on a CCC-P of $ per therm, which also will be used to establish BGSS-M rates. Petitioner projects that it will begin the BGSS Year with a gas cost overrecovery balance of approximately $3.0 million. 8. Petitioner has taken reasonable steps to reduce its gas costs and manage the volatility that has become characteristic of the natural gas commodity marketplace. As discussed by Company witness Leonard J. Willey, Petitioner s efforts to reduce costs and manage volatility have included, (a) continuing to implement its Gas Procurement Strategy and Plan on file with the Board, (b) maximizing benefits for firm customers through a capacity management and gas supply agreement with Sequent Energy Management, L.P. that was modified and extended by the Board Order dated March 19, 2014 in Docket No. GO , and (c) employing its gas storage resources to eliminate Petitioner s exposure to some of the volatility associated with winter price swings. Petitioner s purchases of gas supply have been effectuated at prices consistent with market conditions as required by N.J.S.A. 48:3-58(t). 9. Annexed hereto and made a part of this Petition is the testimony of Thomas Kaufmann, Manager of Rates and Tariffs for Petitioner, which Petitioner suggests be marked as Exhibit P-1. The schedules listed below are attached and referred to in Exhibit P-1, which Petitioner suggests be marked as indicated. Where noted, the following schedules contain information responsive to the BGSS Minimum Filing Requirements ( MFR ) set forth in the MFR Settlement: (a) Schedules TK-1 to TK-11 present data for the BGSS year ending September 30, 2015 (these schedules provide data responsive to MFRs 4, 5, 6, 7, 10, 11, 12, 13, and 15) and; (b) Schedule TK-12 sets forth the revised tariff sheet to implement the proposed rate (this schedule provides data responsive to MFR 1). 3

10 10. Also annexed hereto and made a part of this Petition is the testimony of Leonard J. Willey, Manager of Gas Supply, which Petitioner suggests be marked as Exhibit P-2. The schedules listed below are attached and referred to in Exhibit P-2, which Petitioner suggests be marked as indicated. (a) Schedules LJW-1 through LJW-15 support the calculated BGSS-P rate and reflect projected data for the period October 1, 2015 through September 30, 2016 (these schedules provide data responsive to MFRs 2, 4, 5, 6, 7, 8, 11, 12 and 17); and (b) Schedule LJW-16 presents historical and estimated supply and demand requirements for Petitioner for the period November 2012 through October 2017 (this schedule provides data responsive to MFR 14). 11. Petitioner is serving notice and a copy of this Petition, together with a copy of the exhibits and schedules annexed hereto upon Stefanie A. Brand, Esq., Division of Rate Counsel, 140 East Front Street, 4th Floor, Trenton, New Jersey, upon the attached service list and as outlined in N.J.A.C. 14: Petitioner is also serving this petition electronically on Board Staff and employees of the Division of Rate Counsel. In accordance with MFR Number 3 and to expedite consideration of this matter, Petitioner is attaching as Appendix A, a form of public notice, setting forth the proposed impact on typical gas bills at various winter therm utilization levels. As discussed in the notice, and in accordance with the Board s January 6, 2003 Order in BPU Docket No. GX , Petitioner s form of notice provides notice to the public that Petitioner may seek to implement provisional increases to the BGSS-P rate of up to 5% of a 100 therm residential total bill to be effective December 1, 2015 and February 1, Petitioner may submit such provisional increases if they are necessary to permit Petitioner to avoid a BGSS underrecovery balance at September 30,

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12 PIVOTAL UTILITY HOLDINGS, INC. D/B/A ELIZABETHTOWN GAS NOTICE OF PUBLIC HEARINGS Appendix A TO OUR CUSTOMERS: On May 29, 2015, Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas ("the Company" or Elizabethtown ), filed a Petition with the New Jersey Board of Public Utilities ("BPU" or Board ) in Docket No. GR to review its Periodic Basic Gas Supply Service ( BGSS-P ) rate. The Company has petitioned the BPU to decrease its current BGSS-P rate from $ per therm to $ per therm, inclusive of applicable taxes, a decrease of 8.4% to the typical residential customer using 100 therms based on rates in effect June 1, The proposed rates are subject to BPU approval and may be higher or lower depending on the Board s final determination and the date on which such rates are made effective. The overall percentage change in the affected rate schedule is as follows: Rate Schedule Percentage Change Residential Service (8.4%) The effect of the Company's filing on typical residential gas bills is illustrated below: Consumption in Therms Present Bill Proposed Bill Proposed Change Percent Change 10 $17.19 $16.35 ($0.84) (4.9%) 50 $53.97 $49.76 ($4.21) (7.8%) 100 $99.94 $91.52 ($8.42) (8.4%) 250 $ $ ($21.05) (8.9%) These proposed rates may be subject to a self-implementing rate increase of up to 5% on December 1, 2015 and another 5% increase on February 1, 2016, upon 30 days written notice by Elizabethtown to the BPU and the Division of Rate Counsel. Should it become necessary to apply the self-implementing increase, the impact of this increase on December 1st on a typical residential customer using 100 therms per month would be an incremental increase of $4.58, increasing the proposed bill from $91.52 to $ Should it become necessary to apply the self-implementing increase on February 1st, the incremental increase to a typical residential customer using 100 therms per month would be $4.81, increasing the proposed bill from $96.10 to $ Any assistance required by Customers in ascertaining the impact of the proposed rate increase will be provided by the Company on request. The Board has the statutory authority to establish Elizabethtown's rates at levels it finds just and reasonable as well as to establish the effective date of such rates. Therefore, the BPU may establish the rates at levels and/or an effective date other than those proposed by Elizabethtown. Copies of the Petition are available for inspection at the Company offices located at 520 Green Lane, Union, New Jersey, online at Elizabethtown s website: and at the Board of Public Utilities, 44 South Clinton Avenue, 9th Floor, Trenton, New Jersey. PLEASE TAKE NOTICE that Public Hearings have been scheduled on the above mentioned Petition at the following times and places:, 2015 Hunterdon County Complex, Route 12, Building #1, Flemington, New Jersey 08822, 2015 Rahway Municipal Council, Court Chambers, City Hall Plaza, Rahway, New Jersey The public is invited to attend and interested persons will be permitted to testify and/or make a statement of their views on the proposed rates. Information provided at the public hearings will become part of the record of this case and will be considered by the Board in making its decision. In order to encourage full participation in this opportunity for public comment, please submit requests for needed accommodations, including interpreter, listening devices and/or mobility assistance, 48 hours prior to this Hearing. In addition, members of the public may submit written comments concerning the Petition to the BPU regardless of whether they attend the hearing by addressing them to: Irene Asbury, Secretary, Board of Public Utilities, 44 South Clinton Avenue, 9th Floor, P.O. Box 350, Trenton, New Jersey Hearings will continue, if necessary, on such additional dates and at such locations as the Office of Administrative Law may designate in order to ensure that all interested persons may be heard. Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Brian MacLean President

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15 Exhibit P-1 PIVOTAL UTILITY HOLDINGS, INC. d/b/a ELIZABETHTOWN GAS DIRECT TESTIMONY OF THOMAS KAUFMANN Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Thomas Kaufmann. My business address is 520 Green Lane, Union, New Jersey Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? A. I am employed by Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas ( Elizabethtown or Company ) as Manager of Rates and Tariffs. Q. WHAT IS THE SCOPE OF YOUR DUTIES AT ELIZABETHTOWN? A. I am responsible for designing and developing rates and rate schedules for regulatory filings with the New Jersey Board of Public Utilities ( Board ) and internal management purposes. I also oversee daily rate department functions, including tariff administration, monthly parity pricing, competitive analyses and preparation of management reports. Q. PLEASE DESCRIBE YOUR PROFESSIONAL QUALIFICATIONS AND BUSINESS EXPERIENCE. A. In June 1977, I graduated from Rutgers University, Newark, N.J. with a Bachelor of Arts degree in Business Administration, majoring in accounting and economics. In July 1979, I graduated from Fairleigh Dickinson 1

16 Exhibit P University, Madison, N.J. with a Masters of Business Administration, majoring in finance. My professional responsibilities have encompassed financial analysis, accounting, planning, and pricing in manufacturing and energy services companies in both 6 regulated and unregulated industries. In 1977, I was employed by Allied Chemical Corp. as a staff accountant. In 1980, I was employed by Celanese Corp. as a financial analyst. In 1981, I was employed by Suburban Propane as a Strategic Planning Analyst, promoted to Manager of Rates and Pricing in 1986 and to Director of Acquisitions and Business Analysis in In 1993, I was employed by Concurrent Computer as a Manager, Pricing Administration. In 1996, I joined NUI Corporation ( NUI ) as a Rate Analyst, was promoted to Manager of Regulatory Support in August 1997 and Manager of Regulatory Affairs in February 1998, and named Manager of Rates and Tariffs in July NUI Corporation was acquired by AGL Resources Inc. ( AGL ) on November 30, 2004, and AGL is now the parent company of Elizabethtown. 2

17 Exhibit P Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? A. In connection with the Company's petition to review its Periodic Basic Gas Supply Service ( BGSS-P ) charge, the purpose of my testimony is to support the annual reconciliation of gas costs and recoveries for the period October 1, 2014 through September 30, 2015 ("Base BGSS Year"). Q. DO YOU SPONSOR ANY SCHEDULES AS PART OF YOUR TESTIMONY? A. Yes. My testimony includes the following schedules which were prepared under my supervision and direction: Schedules TK-1 to TK-11 present data for the Base BGSS Year. These schedules contain information responsive to a number of the Minimum Filing Requirements ( MFRs ) that were required by the Board by Order dated June 20, 2003 in Docket Nos. GR et al. Specifically, they provide information responsive to MFRs 4, 5, 6, 7, 10, 11, 12, 13, and 15. Schedule TK-12 is the tariff sheet necessary to implement the proposed BGSS-P rate. Q. WHAT ARE THE RESULTS FOR THE BGSS YEAR ENDING SEPTEMBER 30, 2015? A. Schedules TK-1 through TK-7 present the actual and projected data that support the results for the Base BGSS Year ending September 30, Based on actual data through April 2015 and projections for the period 3

18 Exhibit P May 2015 through September 2015, the Company projects that the BGSS clause will be over-recovered by $2,303,906 as of September 30, Q. HOW WERE THE PROJECTIONS FOR THE PERIOD MAY THROUGH SEPTEMBER 2015 DEVELOPED? A. The prices for gas were developed employing the same methodology as described by Company Witness Leonard J. Willey for the projected BGSS period - October 1, 2015 through September 30, The purchase quantities reflect the projected sales requirements based upon normal 10-year weather and planned storage injections in preparation for the winter. Gas cost recoveries were projected by applying the current BGSS rate, excluding taxes and assessments, to the projected level of firm sales that will be subject to the BGSS-P rate. For firm commercial sales subject to the Monthly Basic Gas Supply Service ( BGSS-M ) rate, gas cost recoveries were developed using a projection of the BGSS-M rates based on the forecast of gas prices. Other gas cost recoveries and credits to gas costs were projected in the same manner as set forth in the projected BGSS period. Mr. Willey discusses the Company s sales forecast in his testimony. 4

19 Exhibit P Q. PLEASE EXPLAIN SCHEDULE TK-1. A. Schedule TK-1 is a reconciliation of gas costs and recoveries for the period October 1, 2014 through September 30, Schedule TK-1 is presented in three sections: 1) recoverable costs, 2) gas cost recoveries, and 3) the difference between these amounts, which represents the over or under recovery of gas costs. Recoverable costs are the costs of the gas delivered less supplier refunds, credits and other adjustments. Gas cost recoveries represent the cost of gas that the Company has recovered through firm and non-firm sales. Firm recoveries are broken down among recoveries 14 from monthly and periodic firm sales. If the gas cost recoveries are greater than the recoverable costs the Company has incurred, the Company is over-recovered. Conversely, if the gas cost recoveries are less than the recoverable costs, the Company is under-recovered. The elements of Schedule TK-1 are explained in more detail below. Recoverable Costs This section represents the components of net recoverable costs that the Company has incurred. Column 1 presents the gas sendout, in dollars, for each month. 5

20 Exhibit P These amounts, as detailed in Schedule TK-2, represent the dollar value of gas that flowed into the Company's distribution system during the months indicated. Column 2 of TK-1 presents refunds received from suppliers, capacity release credits, and other credits and charges. Refunds from suppliers are generally made as a result of actions taken by the Federal Energy Regulatory Commission ("FERC"). The detail of these amounts, including related FERC docket numbers, are listed on Schedule TK-3. Capacity release credits to the BGSS-P are detailed on Schedule TK-4. Also included in Column 2 of TK-1 are amounts associated with credits received by the Company under the terms of the Asset Management and Agency Agreement with Sequent Energy Management, L.P. ( Sequent ) for the BGSS year October 1, 2014 through September 30, The agreement with Sequent is described more fully by Mr. Willey. Under the agreement, the Company has designated Sequent as its agent to manage its capacity. In addition to certain credits being realized by the Company under long-term capacity release agreements, Elizabethtown receives a negotiated fee from Sequent as 6

21 Exhibit P compensation for permitting the supplier to act as its asset manager and gas supplier. The amounts in Column 2 of Schedule TK-1 reflect asset management fee credits received and/or projected to be received from Sequent during the period October 1, 2014 through September 30, Column 3 of Schedule TK-1 presents the monthly totals of net recoverable costs which are equal to gas sendout (Column 1) less supplier refunds, credits and other adjustments of recoverable costs (Column 2). Gas Cost Recoveries Columns 4 through 8 on Schedule TK-1 present the recoveries from customers of the Company's recoverable gas costs during the Base BGSS Year, as shown in more detail on Schedule TK-5. Column 4 presents recoveries of gas costs from sales to residential and small commercial customers that are subject to the BGSS-P rate. Column 5 presents recoveries of gas costs from sales to the Company s larger commercial customers who are subject to the BGSS-M rate. Column 6 presents the monthly totals of the gas cost recoveries from firm sales. Column 7 presents recoveries of gas costs from sales to non-firm customers. Column 8 7

22 Exhibit P presents the monthly totals of the gas cost recoveries from firm and non-firm sales. (Over) Under Recovery Schedule TK-1, Column 9, presents the monthly (over) or under-recovery of gas costs, which is the difference between net recoverable costs (Column 3) and total gas cost recoveries (Column 8). Column 10 is the accumulation of the monthly amounts from Column 9 added to the preceding month's cumulative balance. The October 1, 2014 beginning balance of $17,659,518 is the carryforward balance of the actual over-recovery of gas costs during the BGSS period October 1, 2013 through September 30, The carry forward balance also includes interest due customers for the period, if any, from overrecovered balances. Interest in the amount of $333,478 was due customers for the BGSS period ending September 30, During the BGSS Base Year, the Company is projecting that interest will be due to customers as shown on Schedule TK-6, which is more fully discussed below. Q. WERE ANY CUSTOMER REFUNDS ISSUED DURING THE BASE BGSS YEAR? A. Yes. Due to gas prices that were lower than those projected in the Company s filing last year, the Company 8

23 Exhibit P-1 1 determined that two customer refunds were needed. On December 23, 2014, the Company notified the BPU that it would refund approximately $10 million to its BGSS-P customers with billing cycles beginning in January The Company implemented the refund as a lump sum per a bill credit based on ($0.0429) per therm (inclusive of taxes and assessments) that was applied to BGSS-P customers consumption during the twelve months ended October 31, The refund reduced the annual bill of a typical residential heating customer using 1,000 therms annually by approximately $40 and the bill of a typical residential non-heating customer using 250 therms by 13 approximately $10. On February 23, 2015, the Company notified the BPU that it would again refund approximately $10 million to its BGSS-P customers with billing cycles 16 beginning in March The Company implemented the second lump sum refund through a bill credit based on ($0.0444) per therm (inclusive of taxes and assessments) that was applied to eligible BGSS-P customers consumption during the twelve months ended January 31, The refunds reduced the bill of a typical residential heating and non-heating customer by approximately $40 and $10, respectively. These refunds 9

24 Exhibit P are included in the Periodic Gas Cost Recoveries on Schedule TK-1, Column 4. Q. PLEASE EXPLAIN SCHEDULE TK-2. A. Schedule TK-2 is a statement of combined gas sendout for the period October 1, 2014 projected through September 30, This schedule supports the amounts shown in Column 1 of Schedule TK-1. Columns 1 and 2 of Schedule TK-2 page 1 reflect the monthly total quantity and cost, respectively, of gas and fuel purchased (natural gas and liquefied natural gas) in the periods indicated. Column 1 shows the quantities purchased in dekatherms. rate. Column 3 shows the average Columns 4, 5 and 6 of Schedule TK-2 page 1 show the adjustment to the prior month s ending inventory balance, the total inventory at the beginning of each month, and the total at the end of each month, respectively, all in dekatherms. Column 9 reflects the quantities of gas sendout in dekatherms and is calculated by adding the purchases for the month (Column 1) to the adjusted beginning inventory balance (Column 5) and subtracting the ending inventory balance (Column 6). The adjustment to the beginning inventory (Column 4) is then added or subtracted from this calculated amount, as it is also 10

25 Exhibit P included in the ending inventory balance. The result represents the gas sendout quantity for the month. Q. HOW IS THE DOLLAR AMOUNT OF SENDOUT CALCULATED? A. For each type of inventory, (natural gas, propane and LNG), an average monthly relief rate is applied to the total of the withdrawal volumes to arrive at the sendout dollars. The balances and activity in each of these types 8 of storage are detailed in Schedule TK-7. The dollar amount presented in Column 10 of Schedule TK-2 page 1 includes the cost of sendout for all inventory withdrawals, demand costs and the cost of gas and fuel delivered directly to the city gate. Schedule TK-2 page 1, Column 11, presents the composite average monthly rate. It is computed by dividing the total dollars of sendout in Column 10 by the total volumes of gas sendout (Column 9). Q. PLEASE EXPLAIN SCHEDULE TK-6. A. Schedule TK-6 is a computation of interest on the cumulative over or under-recovery for the period October 1, 2014 through September 30, Interest on the cumulative over or under-recovery was computed on the average of the beginning and ending balances for each month, using a rate equivalent to one-twelfth of Elizabethtown's authorized annual rate of return of 11

26 Exhibit P %. The cumulative over or under-recovery amounts used in these calculations are from Schedule TK-1, 3 Column 10. The schedule shows a projected interest amount of $665,020 due the Customer. Q. HAS THE COMPANY INCLUDED THE AMOUNT OF INTEREST SET FORTH ON SCHEDULE TK-6 IN THE DERIVATION OF THE PROPOSED BGSS-P RATE? A. Yes. The Company has included the interest set forth on Schedule TK-6 in the derivation of the BGSS-P rate as shown on Schedule LJW-1. Q. HAS THE COMPANY CONDUCTED ANY GAS SUPPLY OR CAPACITY TRANSACTIONS WITH AFFLIATES DURING THE BASE BGSS YEAR? A. Yes. As I noted previously, the Company entered into a gas supply and asset management agreement with Sequent for the period April 1, 2014 through March 31, The Company received authorization from the Board to enter into this agreement by Order dated March 19, in Docket No. GO As discussed more fully by Mr. Willey, the agreement with Sequent permits Elizabethtown to purchase firm gas supply requirements at prices consistent with market conditions. The Company s net purchases from Sequent are set forth on Schedule TK-8. 12

27 Exhibit P Q. WHAT HEDGING OR PRICE PROTECTION HAS THE COMPANY DONE IN THE BASE BGSS YEAR? A. For the Base BGSS Year, the Company, under its Gas Procurement Strategy & Plan ( GPS&P ), has priceprotected 12,590,000 Dth. Mr. Willey discusses the GPS&P in greater detail. Schedule TK-11 presents the breakout of this price-protected quantity. The schedule also presents the projected normal firm requirements that underlie the targets set out in the GPS&P. Q. DOES THE COMPANY INCLUDE ANY COSTS ASSOCIATED WITH THE USE OF FINANCIAL INSTRUMENTS TO REDUCE PRICE VOLATILITY IN RECOVERABLE COSTS IN THE BGSS? A. Yes. In accordance with its tariff, the Company includes any transaction costs associated with its hedging activities in its gas purchase costs in the BGSS. Q. HAS THE COMPANY IMPLEMENTED ANY SERVICE INTERRUPTIONS OVER THE LAST 12 MONTHS? A. Yes. This past year, the Company implemented interruptions of service to interruptible gas sales customers. The interruptions in service were in accordance with tariff provisions and contractual terms. The interruptions were necessary to meet operational parameters for providing safe and adequate service to 13

28 Exhibit P our firm gas sales customers. Schedule TK-9 sets forth the customer classes interrupted, number of customers interrupted, dates of interruption and reason for interruption. During the past year, interruptible gas sales customers were interrupted during January through March 2015 ranging from 25 to 29 days depending on the customer type. Customers subject to peaking recall contracts are interrupted as necessary, within the parameters set forth in the respective contracts, to meet high demand for gas by the Company s distribution customers. Q. PLEASE DESCRIBE SCHEDULE TK-10. A. Schedule TK-10 sets forth the supply/demand balance on the five days in which the largest throughput was experienced in Elizabethtown s system during each of the last three winters. TARIFF SHEETS Q. WHAT CHANGES TO THE COMPANY S TARIFF ARE REQUIRED BY THE COMPANY S FILING? A. Schedule TK-12 is the revised tariff sheet that sets forth the proposed BGSS-P charge of $ per therm (inclusive of assessments and taxes), the calculation of which is shown on Mr. Willey s Schedule LJW-1. 14

29 Exhibit P Q. WHAT IS THE OVERALL IMPACT OF THE PROPOSED BGSS-P RATE ON A RESIDENTIAL CUSTOMER CONSUMING 100 THERMS PER MONTH? A. The proposed decrease in the BGSS-P charge is $ per therm. This would decrease the monthly bill for a residential customer consuming 100 therms by $8.42 or 8.4% based on rates in effect June 1, Q. IS THE COMPANY RESERVING THE RIGHT TO INCREASE RATES LATER IN THIS BGSS YEAR? A. Yes. Although the Company does not project that it will need to increase its BGSS-P rate during the BGSS period, the Company reserves the right, in accordance with its tariff, to seek to implement increases to the BGSS-P rate of up to 5% of a 100 therm residential total bill in December 2015 and February 2016, respectively. Q. WHAT IS THE OVERALL IMPACT ON A RESIDENTIAL CUSTOMER CONSUMING 100 THERMS PER MONTH IF THE TWO PERIODIC ADJUSTMENTS FOR DECEMBER AND FEBRUARY WERE IMPLEMENTED AT THEIR MAXIMUM LEVELS? A. The proposed incremental increase to the BGSS-P charge from two such periodic adjustments implemented at the maximum 5% allowed levels in December and February would be $ per therm. These changes would increase the 15

30 Exhibit P monthly bill for a residential customer consuming 100 therms by $9.39 from that proposed for October 1 st. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes, it does. 16

31 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Statement of Annual Reconciliation of Gas Costs and Recoveries For the Period October 1, 2014 through September 30, 2015 Schedule TK-1 (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) Recoverable Costs Gas Cost Recoveries (Over) Under Recovery Less Supplier Net Monthly Refunds, Recoverable Total (Over)Under Cumulative Credits & Costs From Firm Sales From Non Recoveries Recovery (Over) Under Period Gas Sendout Other (a) (C.1-2) Periodic (c) Monthly Total Firm Sales (C. 6+7) (C. 3-8) Recovery Over-recovery at October 1, 2014 ($17,659,518) (b) Oct-14 $7,801,856 $37,068 $7,764,788 $3,109,813 $1,128,911 $4,238,724 $405,745 $4,644,469 $3,120,319 ($14,539,199) Nov-14 $16,433,345 $59,812 $16,373,533 $6,956,638 $2,302,346 $9,258,984 $438,366 $9,697,350 $6,676,183 ($7,863,016) Dec-14 $20,968,537 $1,164,498 $19,804,039 $14,863,429 $4,716,004 $19,579,433 $356,102 $19,935,535 ($131,496) ($7,994,512) Jan-15 $27,385,986 $31,361 $27,354,625 $9,263,192 $6,456,290 $15,719,482 $817,469 $16,536,951 $10,817,674 $2,823,162 Feb-15 $32,811,212 $32,806 $32,778,406 $24,071,059 $7,025,107 $31,096,166 $594,611 $31,690,777 $1,087,629 $3,910,791 Mar-15 $26,148,207 $19,147,788 $7,000,419 $13,683,911 $6,281,442 $19,965,353 $516,566 $20,481,919 ($13,481,500) ($9,570,709) Apr-15 $10,752,051 $32,688 $10,719,363 $13,753,658 $3,599,345 $17,353,003 $481,139 $17,834,142 ($7,114,779) ($16,685,488) May-15 * $7,555,418 $33,314 $7,522,104 $5,938,545 $700,173 $6,638,718 $172,892 $6,811,610 $710,494 ($15,974,994) Jun-15 * $7,070,797 $1,094,740 $5,976,057 $2,935,094 $547,716 $3,482,810 $198,787 $3,681,597 $2,294,460 ($13,680,534) Jul-15 * $7,021,231 $33,314 $6,987,917 $2,077,099 $653,486 $2,730,585 $290,842 $3,021,427 $3,966,490 ($9,714,044) Aug-15 * $7,412,038 $33,314 $7,378,724 $1,953,360 $654,941 $2,608,301 $234,106 $2,842,407 $4,536,317 ($5,177,727) Sep-15 * $6,872,185 $1,094,740 $5,777,445 $2,066,098 $632,819 $2,698,917 $204,707 $2,903,624 $2,873,821 ($2,303,906) $178,232,863 $22,795,443 $155,437,420 $100,671,896 $34,698,580 $135,370,476 $4,711,332 $140,081,808 $15,355,612 * Forecast (a) Includes energy management fees, as well as actual shared margins, if any, received in October but reflected in September, received in May but reflected in March and a September estimate. (b) Represents opening balance as of September 30th including $333,478 credit from interest due to customers as well as any shared margins received in October but reflected in September. (c) Includes customer refunds of approximately $10 million in January and March 2015.

32 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Statement of Combined Gas Sendout For the Period October 1, 2014 through September 30, 2015 Schedule TK-2 Page 1 of 2 (1) (2) (3=2/1) (4) (5) (6) (7) (8=7/6) (9) (10) (11=10/9) Purchases Inventory (Dth's) Sendout Average Adjusted Ending Average Average Period Dth's Amount Rate Adjustment Beginning Ending Amount Rate Dth's Amount Rate Beginning Inventory 7,868,547 $26,866,861 $ Oct-14 2,312,615 $10,566,086 $ (11,148) 7,857,399 8,861,401 $29,631,091 $ ,319,761 $7,801,856 $ Nov-14 2,802,477 $14,199,562 $ ,221 8,890,622 7,996,625 $27,397,308 $ ,667,253 $16,433,345 $ Dec-14 3,252,563 $16,954,401 $ (10,851) 7,985,774 6,596,510 $23,383,172 $ ,652,678 $20,968,537 $ Jan-15 4,824,298 $19,864,535 $ (19,247) 6,577,263 4,386,900 $15,861,721 $ ,033,908 $27,385,986 $ Feb-15 5,495,549 $26,586,409 $ (21,468) 4,365,432 2,512,598 $9,636,918 $ ,369,851 $32,811,212 $ Mar-15 4,176,962 $21,460,713 $ (13,509) 2,499,089 1,082,012 $4,949,424 $ ,607,548 $26,148,207 $ Apr-15 2,747,254 $12,360,600 $ (29,991) 1,052,021 1,924,563 $6,557,973 $ ,904,703 $10,752,051 $ May-15 * 2,225,612 $8,867,089 $ ,924,563 3,086,747 $7,869,644 $ ,063,428 $7,555,418 $ Jun-15 * 2,051,081 $8,766,974 $ ,086,747 4,249,180 $9,565,821 $ ,648 $7,070,797 $ Jul-15 * 1,942,802 $8,804,470 $ ,249,180 5,411,355 $11,349,060 $ ,627 $7,021,231 $ Aug-15 * 1,967,585 $10,109,058 $ ,411,355 6,653,935 $14,046,080 $ ,005 $7,412,038 $ Sep-15 * 1,904,039 $8,743,371 $ ,653,935 7,819,956 $15,917,266 $ ,018 $6,872,185 $ ,702,837 $167,283,268 (76,993) 35,751,428 $178,232,863 * Forecast

33 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Statement of Combined Gas Sendout For the Period October 1, 2014 through September 30, 2015 Schedule TK-2 Page 2 of 2 (1) (2) (3) (4=3/1) (5) (6) (7) (8=7/5) Purchases Sendout Average Average Commodity Rate Commodity Rate Period Dth's Demand Commodity $/dth Dth's Demand Commodity $/dth Oct-14 2,312,615 $4,081,673 $6,484,413 $ ,319,761 $4,081,673 $3,720,183 $ Nov-14 2,802,477 $4,022,749 $10,176,813 $ ,667,253 $4,022,749 $12,410,596 $ Dec-14 3,252,563 $4,528,468 $12,425,933 $ ,652,678 $4,528,468 $16,440,069 $ Jan-15 4,824,298 $4,246,307 $15,618,228 $ ,033,908 $4,246,307 $23,139,679 $ Feb-15 5,495,549 $4,053,392 $22,533,017 $ ,369,851 $4,053,392 $28,757,820 $ Mar-15 4,176,962 $4,490,479 $16,970,234 $ ,607,548 $4,490,479 $21,657,728 $ Apr-15 2,747,254 $4,154,759 $8,205,841 $ ,904,703 $4,154,759 $6,597,292 $ May-15 * 2,225,612 $4,132,496 $4,734,593 $ ,063,428 $4,132,496 $3,422,922 $ Jun-15 * 2,051,081 $4,057,051 $4,709,923 $ ,648 $4,057,051 $3,013,746 $ Jul-15 * 1,942,802 $4,133,771 $4,670,699 $ ,626 $4,133,771 $2,887,460 $ Aug-15 * 1,967,585 $4,132,496 $5,976,562 $ ,004 $4,132,496 $3,279,542 $ Sep-15 * 1,904,039 $4,057,051 $4,686,320 $ ,018 $4,057,051 $2,815,134 $ ,702,837 $50,090,692 $117,192,576 $ ,751,426 $50,090,692 $128,142,171 $ * Forecast

34 Schedule TK-3 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Supplier Refunds For the Period October 1, 2014 through September 30, 2015 Docket Refund Period Suppliers Number Amounts Total Oct-14 Transco Dominion RP RP $4,600 $4,600 Nov-14 Transco N/A $27,344 $27,344 Dec-14 Columbia Gas RP $70,637 $70,637 Jan-15 $0 $0 Feb-15 $0 $0 Mar-15 $0 $0 Apr-15 $0 $0 May-15 * $0 $0 Jun-15 * $0 $0 Jul-15 * $0 $0 Aug-15 * $0 $0 Sep-15 * $0 $0 Total $102,581 * Forecast

35 Schedule TK-4 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Capacity Release Credits For the Period October 1, 2014 through September 30, 2015 Capacity Release Volumes Average Total Credit Period Dths Rate Amount To BGSS Oct ,145 $ $38,198 $32,468 Nov ,850 $ $38,198 $32,468 Dec ,145 $ $36,895 $31,361 Jan ,145 $ $36,895 $31,361 Feb ,260 $ $38,595 $32,806 Mar ,145 $ $38,595 $32,806 Apr ,850 $ $38,456 $32,688 May-15 * 195,145 $ $39,193 $33,314 Jun-15 * 188,850 $ $37,929 $32,240 Jul-15 * 195,145 $ $39,193 $33,314 Aug-15 * 195,145 $ $39,193 $33,314 Sep-15 * 188,850 $ $37,929 $32,240 2,297,675 $ $459,269 $390,380 * Forecast

36 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Gas Costs Recovered Through Sales For the Period October 1, 2014 through September 30, 2015 Schedule TK-5 page 1 of 2 Firm Period Periodic Monthly Total Dth $ Dth $ Dth $ Oct ,878 $3,109, ,592 $1,128, ,470 $4,238,724 Nov-14 1,481,172 $6,956, ,326 $2,302,346 1,868,498 $9,258,984 Dec-14 3,161,470 $14,863, ,078 $4,716,004 3,945,548 $19,579,433 Jan-15 4,036,099 $9,263,192 1,122,104 $6,456,290 5,158,203 $15,719,482 Feb-15 5,104,082 $24,071,059 1,380,230 $7,025,107 6,484,312 $31,096,166 Mar-15 4,958,003 $13,683,911 1,287,630 $6,281,442 6,245,633 $19,965,353 Apr-15 2,951,825 $13,753, ,766 $3,599,345 3,702,591 $17,353,003 May-15 * 1,263,160 $5,938, ,146 $700,173 1,418,306 $6,638,718 Jun-15 * 624,310 $2,935, ,772 $547, ,082 $3,482,810 Jul-15 * 441,810 $2,077, ,417 $653, ,227 $2,730,585 Aug-15 * 415,490 $1,953, ,060 $654, ,550 $2,608,301 Sep-15 * 439,470 $2,066, ,119 $632, ,589 $2,698,917 TOTAL 25,454,769 $100,671,896 6,590,240 $34,698,580 32,045,009 $135,370,476 * Forecast

37 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Gas Costs Recovered Through Sales For the Period October 1, 2014 through September 30, 2015 Schedule TK-5 Page 2 of 2 Period Non-Firm IS CS Special Contract (a) CSI Total Dth $ Dth $ Dth $ Dth $ Dth $ Total Amount Credited To BGSS Oct-14 14,526 $88,067 - $0 20,648 $317,672 1 $6 35, ,745 $4,644,469 Nov-14 13,775 $81,679 - $0 40,317 $356,687 - $0 54,092 $438,366 $9,697,350 Dec-14 19,457 $115,709 - $0 537 $240,393 - $0 19,994 $356,102 $19,935,535 Jan-15 20,572 $122,223 - $0 125,519 $695,241 1 $5 146,092 $817,469 $16,536,951 Feb-15 19,456 $99,247 - $0 90,662 $495,364 - $0 110,118 $594,611 $31,690,777 Mar-15 7,901 $38,581 - $0 101,992 $477,949 7 $36 109,900 $516,566 $20,481,919 Apr-15 19,046 $91,114 - $0 22,709 $390,015 2 $10 41,757 $481,139 $17,834,142 May-15 * 15,730 $73,349 - $0 7,000 $76,978 5,000 $22,565 27,730 $172,892 $6,811,610 Jun-15 * 16,530 $78,071 - $0 17,000 $97,851 5,000 $22,865 38,530 $198,787 $3,681,597 Jul-15 * 23,630 $112,739 - $0 43,000 $154,998 5,000 $23,105 71,630 $290,842 $3,021,427 Aug-15 * 21,750 $104,248 - $0 19,000 $106,643 5,000 $23,215 45,750 $234,106 $2,842,407 Sep-15 * 16,440 $78,896 - $0 18,000 $102,561 5,001 $23,250 39,441 $204,707 $2,903,624 TOTAL 208,813 $1,083,923 - $0 506,384 $3,512,352 25,012 $115, ,209 $4,711,332 $140,081,808 * Forecast (a) The recovery dollars include sales under special contract.

38 Schedule TK-6 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Computation of Interest on Cumulative (Over) Under Recovery For the Period October 1, 2014 through September 30, 2015 Cumulative Monthly Computed Computed Average Interest Interest Interest Period Beginning Ending Balance Rate (a) (Expense) (Expense) Oct-14 ($17,659,518) ($14,539,199) ($16,099,359) % ($102,505) ($102,505) Nov-14 ($14,539,199) ($7,863,016) ($11,201,108) % ($71,317) ($173,822) Dec-14 ($7,863,016) ($7,994,512) ($7,928,764) % ($50,482) ($224,304) Jan-15 ($7,994,512) $2,823,162 ($2,585,675) % ($16,463) ($240,767) Feb-15 $2,823,162 $3,910,791 $3,366, % $21,438 ($219,329) Mar-15 $3,910,791 ($9,570,709) ($2,829,959) % ($18,018) ($237,347) Apr-15 ($9,570,709) ($16,685,488) ($13,128,099) % ($83,587) ($320,934) May-15 * ($16,685,488) ($15,974,994) ($16,330,241) % ($103,975) ($424,909) Jun-15 * ($15,974,994) ($13,680,534) ($14,827,764) % ($94,408) ($519,317) Jul-15 * ($13,680,534) ($9,714,044) ($11,697,289) % ($74,477) ($593,794) Aug-15 * ($9,714,044) ($5,177,727) ($7,445,886) % ($47,408) ($641,202) Sep-15 * ($5,177,727) ($2,303,906) ($3,740,817) % ($23,818) ($665,020) * Forecast (a) Based on a 7.64% authorized rate of return.

39 Schedule TK-7 Page 1 of 4 Pivotal Utility Holdings, Inc. d/b/a Elizabethtown Gas Statement of Injections and Withdrawals - Natural Gas Inventory For the Period October 1, 2014 through September 30, 2015 Injections Inventory (Dth's) Withdrawals Ending Inventory Cost of Ending Ending Adjusted Average Sendout Inventory Inventory Period Dth's Amount Adjustment Beginning Ending Sendout Rate from Storage (Dth's) ($) Beginning Inventory 7,829,325 $26,680,403 Oct-14 1,083,216 $2,743,096 (11,148) 7,818,177 8,799, ,347 $ $374,199 8,799,194 $29,049,300 Nov ,868 $367,492 29,221 8,828,415 7,882,118 1,094,944 $ $3,588,005 7,882,118 $25,828,787 Dec ,599 $723,235 (10,851) 7,871,267 6,519,610 1,491,107 $ $4,942,367 6,519,610 $21,609,655 Jan ,206 $259,015 (19,247) 6,500,363 4,395,711 2,241,105 $ $7,384,563 4,395,711 $14,484,107 Feb ,180 $322,980 (21,468) 4,374,243 2,761,203 1,743,688 $ $5,731,313 2,761,203 $9,075,774 Mar-15 8,068 $151,279 (13,509) 2,747,694 1,334,418 1,434,853 $ $4,780,848 1,334,418 $4,446,205 Apr-15 1,043,823 $2,182,785 (29,991) 1,304,427 2,128, ,190 $ $697,367 2,128,051 $5,931,623 May-15 * 1,165,842 $1,367,416-2,128,051 3,293,893 - $ $0 3,293,893 $7,299,039 Jun-15 * 1,165,973 $1,750,126-3,293,893 4,459,866 - $ $0 4,459,866 $9,049,165 Jul-15 * 1,165,833 $1,838,985-4,459,866 5,625,699 - $ $0 5,625,699 $10,888,150 Aug-15 * 1,165,915 $2,574,574-5,625,699 6,791,614 - $ $0 6,791,614 $13,462,724 Sep-15 * 1,166,021 $1,896,534-6,791,614 7,957,635 - $ $0 7,957,635 $15,359,258 * Forecast