SEC Comment Letter for UNITIL CORP (UTL) (CIK 0000755001) (UTL) — Jan 10, 2013
UNITIL CORP (UTL) (CIK 0000755001)
Date: Jan. 10, 2013 · CIK: 0000755001 · Accession: 0000000000-13-001537
AI Filing Summary & Sentiment
Referenced dates: December 11, 2012
Letter
January 10 , 2013 Via E -mail Mark H. Collin Chief Financial Officer Unitil Corporation 6 Liberty Lane West Hampton, NH 03842
Re: Unitil Corporation Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 1, 2012 File No. 001 -08858
Dear Mr. Collin :
We have reviewed your response dated December 21, 2012 and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments.
Form 10 -K for the year ended December 31, 2011
Item 8. Financial Statements and Supplementary Data
Note 1: Summary of Significant Accounting Policies, page 54
1. We note your response to comment 1 in our letter dated December 11, 2012. It is our understanding that you are collecting through rates removal and other asset retirement costs that are expected to be incurred in the future. Additionally, y ou state these costs are not associated with an asset retirement obligation within the scope of ASC 410 -20. We believe these removal and other asset retirement costs that you have charged in rates represent regulatory liabilities under ASC 980 . Please amend your filin g by reclassifying these expected future removal and asset retirement costs previously recorded as an element of accumulated depreciation to a regulatory liability.
Mark H. Collin Unitil Corporation January 10 , 2013 Page 2
Note 3: Long -Term Debt, Credit Arrangements, Leases and Guarantees, page 62
Credit Arrang ements, page 65
2. We note your responses to comments 2 and 3 in our letter dated December 11, 2012. In order to better assist us in understanding your accounting for the asset management agreement, p lease provide us with the related asset management agreem ent contract.
You may contact Jarrett Torno, Staff Accountant , at (202) 551 -3703 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3377 with any other questions.
Sincerely,
/s/ Andrew D. Mew
Show Raw Text
January 10 , 2013 Via E -mail Mark H. Collin Chief Financial Officer Unitil Corporation 6 Liberty Lane West Hampton, NH 03842 Re: Unitil Corporation Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 1, 2012 File No. 001 -08858 Dear Mr. Collin : We have reviewed your response dated December 21, 2012 and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we may have additional comments. Form 10 -K for the year ended December 31, 2011 Item 8. Financial Statements and Supplementary Data Note 1: Summary of Significant Accounting Policies, page 54 1. We note your response to comment 1 in our letter dated December 11, 2012. It is our understanding that you are collecting through rates removal and other asset retirement costs that are expected to be incurred in the future. Additionally, y ou state these costs are not associated with an asset retirement obligation within the scope of ASC 410 -20. We believe these removal and other asset retirement costs that you have charged in rates represent regulatory liabilities under ASC 980 . Please amend your filin g by reclassifying these expected future removal and asset retirement costs previously recorded as an element of accumulated depreciation to a regulatory liability. Mark H. Collin Unitil Corporation January 10 , 2013 Page 2 Note 3: Long -Term Debt, Credit Arrangements, Leases and Guarantees, page 62 Credit Arrang ements, page 65 2. We note your responses to comments 2 and 3 in our letter dated December 11, 2012. In order to better assist us in understanding your accounting for the asset management agreement, p lease provide us with the related asset management agreem ent contract. You may contact Jarrett Torno, Staff Accountant , at (202) 551 -3703 or Donna Di Silvio, Staff Accountant, at (202) 551 -3202 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3377 with any other questions. Sincerely, /s/ Andrew D. Mew Andrew D. Mew Accounting Branch Chief