Relating to the recovery of certain costs associated with a gas utility's plant, facilities, or equipment placed in service.

Contracts

• Statement of Intent Filings: Legal teams must update templates for future rate case filings to explicitly include a schedule for the regulatory asset established under Section 104.302.
• Lending Covenants: Review credit agreements. Ensure that this new "regulatory asset" is recognized as a valid asset class for the purpose of EBITDA/Interest coverage ratios, as this improves balance sheet health prior to cash recovery.

Hiring/Training

• Regulatory Accounting: Finance teams require immediate training on the specific formula for "Post In-Service Carrying Costs": *(Unrecovered Gross Plant) × (Pre-tax WACC from most recent final rate order)*.
• Asset Management: Operational staff must be retrained on the critical importance of documenting the exact "placed in service" date, as this date triggers the accrual eligibility.

Reporting & Record-Keeping

• Audit Trails: You must maintain a rigorous audit trail linking specific physical assets (Unrecovered Gross Plant) to the regulatory asset account.
• Tax Allocation: Ad valorem tax invoices must be specifically allocated to the unrecovered assets to justify the deferral entry.
• Accounting Adjustments: You are legally required to book adjustments moving these costs from "regulatory asset" to "recovered rates" immediately upon RRC approval to prevent double recovery.

Fees & Costs

• Refund Liability: There are no new state fees; however, the law creates a contingent liability. If the RRC disallows costs included in the regulatory asset during a rate review, you must refund those collected rates plus interest.