OUCC Objection To 30-Day Filing No. 50134 - American Suburban Utilities, Inc. - 041918
OUCC Objection To 30-Day Filing No. 50134 - American Suburban Utilities, Inc. - 041918
OUCC Objection To 30-Day Filing No. 50134 - American Suburban Utilities, Inc. - 041918
Comes now the Indiana Office of Utility Consumer Counselor ("OUCC"), and hereby files
its timely objection to the thirty-day filing ("Filing") made by American Suburban Utilities
("ASU") on March 26, 2018, designated by the Commission as filing #50134. In support of its
2. While it is appropriate for ASU to select one of the CIAC cost options
updated its revenues to reflect the effect of the cost option it chose. The Commission's
February 16, 2018 Order ("February 16 Order") in this Cause states that Respondents
may only "include in its 30-day filing a request for Commission approval of a cost
option set forth in 170 IAC 6-1.5-3.3 and 170 IAC 8.5-4.-32." The February 16 Order
tax rate on its total revenues rather than revenues subject to increase. Such an en-or
4. The changes proposed in ASU's Filing do not apply the updated revenue
conversion factor to airive at the con-ect reduction in total operating revenues. As a result
of the reduction in federal income tax, ASU's total operating revenues need to be
adjusted for the decrease in bad debt expense, IURC fee, utility receipts tax, state income
tax and federal income tax that will result from the federal income tax change from 35%
to 21 %. Without the application of the updated revenue conversion factor using the new
21 % corporate income tax rate, ASU' s total operating revenues will continue to reflect a
revenue conversion factor at the 35% corporate income tax rate it no longer has to pay.
5. The OUCC proposes that ASU recalculate and resubmit its filing with the cmrect
calculation and treatment of CIAC, revenues subject to increase and gross up the tax
difference.
WHEREFORE, the OUCC respectfully requests the Commission reject or suspend approval of
ASU's thirty-day filing made on March 26, 2018 pertaining to the calculation of its income tax
expense based on the new 21 % corporate income tax rate as a result of the Tax Cuts and Jobs
Act of 2017.
Respectfully submitted,
CERTIFICATE OF SERVICE
SUB URBAN UTILITIES, INC. has been served upon the following counsel of record in the
captioned proceeding by depositing a copy of same in the United States mail, first class postage
The undersigned hereby certifies that a copy of the foregoing has been served upon the