SEC Comment Letter for UNITIL CORP (UTL) (CIK 0000755001) (UTL) — Mar 11, 2020
UNITIL CORP (UTL) (CIK 0000755001)
Date: March 11, 2020 · CIK: 0000755001 · Accession: 0000000000-20-002162
AI Filing Summary & Sentiment
File numbers found in text: 001-08858
Letter
March 10, 2020 Christine Vaughan Senior Vice President, Chief Financial Officer and Treasurer UNITIL CORP 6 Liberty Lane West Hampton, New Hampshire 03842-1720 Re:UNITIL CORP Form 10-K for the Year Ended December 31, 2019 10-K filed January 30, 2020 File No. 001-08858 Dear Ms. Vaughan : We have limited our review of your filing to the financial statements and related disclosures 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 these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for the Year Ended December 31, 2019 Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Gas Sales, Revenues and Margin Gas Operating Revenues and Sales Margin, page 30 1.We note your presentation of the non-GAAP measures Gas Sales Margin and Electric Sales Margin. Please present reconciliations for these non-GAAP measures in accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile these measures to the most directly comparable GAAP measure of gross margin. If you do not believe gross margin that includes depreciation and amortization is the most directly comparable GAAP measure, please tell us why in your response.
FirstName LastNameChristine Vaughan Comapany NameUNITIL CORP March 10, 2020 Page 2 FirstName LastName Christine Vaughan UNITIL CORP March 10, 2020 Page 2 Financial Statements Notes to Consolidated Financial Statements Note 1: Summary of Significant Accounting Policies Utility Revenue Recognition, page 53 2.We note your alternative revenue programs. Please confirm for us and disclose whether you meet all three of the criteria within 980-605-25-4 for recognition of alternative revenues in connection with your rate adjustment mechanisms. Additionally, please tell us and disclose the methodology used to calculate and present revenues from alternative revenue programs. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Yong Kim, Staff Accountant at (202) 551-3323 or Robert Babula, Senior Staff Accountant at (202) 551-3339 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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March 10, 2020
Christine Vaughan
Senior Vice President, Chief Financial Officer and Treasurer
UNITIL CORP
6 Liberty Lane West
Hampton, New Hampshire 03842-1720
Re:UNITIL CORP
Form 10-K for the Year Ended December 31, 2019
10-K filed January 30, 2020
File No. 001-08858
Dear Ms. Vaughan :
We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Year Ended December 31, 2019
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
Gas Sales, Revenues and Margin
Gas Operating Revenues and Sales Margin, page 30
1.We note your presentation of the non-GAAP measures Gas Sales Margin and Electric
Sales Margin. Please present reconciliations for these non-GAAP measures in accordance
with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile these measures to the
most directly comparable GAAP measure of gross margin. If you do not believe gross
margin that includes depreciation and amortization is the most directly comparable GAAP
measure, please tell us why in your response.
FirstName LastNameChristine Vaughan
Comapany NameUNITIL CORP
March 10, 2020 Page 2
FirstName LastName
Christine Vaughan
UNITIL CORP
March 10, 2020
Page 2
Financial Statements
Notes to Consolidated Financial Statements
Note 1: Summary of Significant Accounting Policies
Utility Revenue Recognition, page 53
2.We note your alternative revenue programs. Please confirm for us and disclose whether
you meet all three of the criteria within 980-605-25-4 for recognition of alternative
revenues in connection with your rate adjustment mechanisms. Additionally, please tell
us and disclose the methodology used to calculate and present revenues from alternative
revenue programs.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
You may contact Yong Kim, Staff Accountant at (202) 551-3323 or Robert Babula,
Senior Staff Accountant at (202) 551-3339 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation