Extract to table

The FL&U tracker is one of several critical tariff design elements that must be resolved before the redesigned tariff is ready for filing

The Deficiency Letter described the absence of an FL&U tracker as a material deficiency that must be cured before the tariff could be accepted for filing

The consistent themes emerging from this body of precedent are: (i) FL&U trackers are strongly encouraged for interstate natural gas pipelines; (ii) in-kind percentage retention is the preferred structure; (iii) separate tracking and reporting of fuel-use and L&U components is required; (iv) periodic true-up filings — typically annual — are necessary to ensure accuracy; and (v) shippers must have access to FL&U data and audit rights to verify the pipeline's calculations

Interaction with Other Tariff Provisions The FL&U tracker mechanism does not operate in isolation; it interacts with numerous other provisions of the Ridgeline tariff, and its design must be coordinated with those provisions to ensure internal consistency and avoid unintended consequences

15 million must be adjusted to exclude fuel costs to the extent they are recovered through the FL&U tracker, to avoid double recovery

The FL&U reporting and nomination processes must comply with the applicable standards of the North American Energy Standards Board Wholesale Gas Quadrant ("NAESB WGQ") Version 3