We follow the accounting and reporting requirements of ASC Topic 980, which provides that regulated entities account for and report assets and liabilities consistent with the economic effect of regulatory rate-making procedures when the rates established are designed to recover the costs of providing the regulated service and it is probable that such rates will be charged and collected from customers. Certain expenses and credits subject to utility regulation or rate determination normally reflected in income or expense are deferred on the balance sheet and are recognized in the income statement as the related amounts are included in customer rates and recovered from or refunded to customers. We assess the probability of collection for all of our regulatory assets each period.


At December 31, (in millions)	2021		2020
Regulatory Assets
Unrecognized pension and other postretirement benefit costs (see Note 12)	$	512.1	$	583.3
Deferred pension and other postretirement benefit costs (see Note 12)	74.8		72.4
Environmental costs (see Note 19-E)	45.8		56.6
Regulatory effects of accounting for income taxes (see Note 1-N and Note 11)	194.8		194.5
Under-recovered gas and fuel costs (see Note 1-J)	73.6		8.0
Depreciation	177.5		192.6

Post-in-service carrying charges	237.9		228.6



Safety activity costs	171.9		146.0
DSM programs	39.2		37.8
Retired coal generating stations	803.9		204.7
Losses on commodity price risk programs (See Note 10)	9.6		54.7
Deferred property taxes	65.1		62.9
Renewable energy investments (See Note 1-S and Note 4)	18.5		—
Other	67.5		88.4
Total Regulatory Assets	$	2,492.2	$	1,930.5
Less: Current Portion	206.2		135.7
Total Noncurrent Regulatory Assets	$	2,286.0	$	1,794.8


At December 31, (in millions)	2021		2020
Regulatory Liabilities
Over-recovered gas and fuel costs (see Note 1-J)	$	5.4	$	47.8
Cost of removal (see Note 8)	749.5		775.2
Regulatory effects of accounting for income taxes (see Note 1-N and Note 11)	1,040.8		1,105.1
Deferred pension and other postretirement benefit costs (see Note 12)	75.9		69.5
Gains on commodity price risk programs (See Note 10)	34.2		14.0
Other	74.2		53.9
Total Regulatory Liabilities	$	1,980.0	$	2,065.5
Less: Current Portion	137.4		161.3
Total Noncurrent Regulatory Liabilities	$	1,842.6	$	1,904.2

Regulatory assets, including under-recovered gas and fuel costs and depreciation, of approximately $1,207.0 million and $1,260.6 million as of December 31, 2021 and 2020, respectively, are not earning a return on investment. These costs are recovered over a remaining life, the longest of which is 48 years.

Unrecognized pension and other postretirement benefit costs. Represents the deferred other comprehensive income or loss of the actuarial gains or losses and the prior service costs or credits that arise during the period but that are not immediately recognized as components of net periodic benefit costs by certain subsidiaries that will ultimately be recovered through base rates.

Deferred pension and other postretirement benefit costs. Primarily relates to the difference between defined benefit plan expense recorded by certain subsidiaries due to regulatory orders and the corresponding expense that would otherwise be recorded in accordance with GAAP. The majority of these amounts are driven by Columbia of Ohio. The timeframe for the

Environmental costs. Includes certain recoverable costs related to gas plant sites, disposal sites or other sites onto which material may have migrated, the recovery of which is to be addressed in future base rates, billing riders or tracking mechanisms of certain of our subsidiaries.

Under-recovered gas and fuel costs. Represents the difference between the costs of gas and fuel and the recovery of such costs in revenue and is used to adjust future billings for such deferrals on a basis consistent with applicable state-approved tariff provisions. Recovery of these costs is achieved through tracking mechanisms.

Depreciation. Represents differences between depreciation expense incurred on a GAAP basis and that prescribed through regulatory order. The majority of this balance is driven by Columbia of Ohio's IRP and CEP deferrals. Recovery of these amounts is approved annually through the related riders.

Post-in-service carrying charges. Represents deferred debt-based carrying charges incurred on certain assets placed into service but not yet included in customer rates. The majority of this balance is driven by Columbia of Ohio's IRP and CEP deferrals.

Safety activity costs. Represents the difference between costs incurred by certain of our subsidiaries in eligible safety programs in compliance with PHMSA regulations in excess of those being recovered in rates.

DSM programs. Represents costs associated with Gas Distribution Operations and Electric Operations segments' energy efficiency and conservation programs. Costs are recovered through tracking mechanisms.

Retired coal generating stations. Represents the net book value of Units 7 and 8 of Bailly Generating Station that was retired during 2018 and the net book value of Units 14 and 15 of R.M. Schahfer Generating Station retired in 2021. These amounts are currently being amortized at a rate consistent with their inclusion in customer rates. The December 2019 NIPSCO electric rate case order allows for the recovery of, and on, the net book value of the stations by the end of 2032 and implements a revenue credit for the retired units. The credit is based on the difference between the net book value of Units 14 and 15 upon retirement and the last base rate case proceeding. The credit will be reset when new base rates are determined. See Note 6, "Property, Plant and Equipment," for further details.

Losses on commodity price risk programs. Represents the unrealized losses related to certain of our subsidiary's commodity price risk programs. These programs help to protect against the volatility of commodity prices and these amounts are collected from customers through their inclusion in customer rates.

Renewable energy investments. Represents the regulatory deferral of certain amounts representing the timing difference between the profit earned from the joint ventures and the amount included in regulated rates to recover our approved investments in consolidated joint ventures. These amounts will be collected through base rates over the life of the renewable generating assets to which they relate. Refer to Note 1-S, "VIEs and Allocation of Earnings," for additional information. Renewable energy formation and developer costs are also included in this regulatory asset.

Over-recovered gas and fuel costs. Represents the difference between the cost of gas and fuel and the recovery of such costs in revenues and is the basis to adjust future billings for such refunds on a basis consistent with applicable state-approved tariff provisions. Refunding of these revenues is achieved through tracking mechanisms.

Regulatory effects of accounting for income taxes. Represents amounts owed to customers for deferred taxes collected at a higher rate than the current statutory rates and liabilities associated with accelerated tax deductions owed to customers. Balance includes excess deferred taxes recorded upon implementation of the TCJA in December 2017, net of amounts amortized through 2021.

Gains on commodity price risk programs. Represents the unrealized gains related to certain of our subsidiary's commodity price risk programs. These programs help to protect against the volatility of commodity prices, and these amounts are passed back to customers through their inclusion in customer rates.

In response to COVID-19, we received approvals or directives from the regulatory commissions in the states in which we operate. The ongoing impacts of these approvals or directives are described in the table below:


Jurisdiction	Moratorium in Place?	Regulatory Asset balance as of December 31, 2021 (in millions)		Regulatory Asset balance as of December 31, 2020 (in millions)		Deferred COVID-19 Costs
Columbia of Ohio	No	$	2.1	$	2.0	Incremental operation and maintenance expenses
NIPSCO	No	$	2.2	$	9.2	Incremental bad debt expense and the costs to implement the requirements of the COVID-19 related order
Columbia of Pennsylvania	No	$	5.2	$	5.4	Incremental bad debt expense incurred from March 13, 2020 through December 29, 2021, above levels currently in rates
Columbia of Virginia	No	$	1.5	$	—	Incremental incurred costs (including incremental bad debt expense), subject to an earnings test review
Columbia of Maryland	No	$	0.9	$	0.7	Incremental costs (including incremental bad debt expense) incurred to ensure that customers have essential utility service during the state of emergency in Maryland. Such incremental costs must be offset by any benefit received in connection with the pandemic

The Pennsylvania PUC adopted an order on March 11, 2021, and subsequently reaffirmed their stance in a June 23, 2021 order, which lifted its prior pandemic-related moratorium on service terminations for non-payments of utility bills beginning April 1, 2021. Pursuant to that order, Pennsylvania utilities are required to offer payment plans on billing arrearages, with the length of such payment plans depending on a customer's income level. Pursuant to a subsequent order, Pennsylvania utilities were no longer required to offer these extended pandemic-related payment arrangements to customers in arrears as of October 1, 2021.On December 16, 2021, CPA received a final order approving its 2021 base rate case, which includes a provision to discontinue the deferral of COVID-19 uncollectible accounts as of December 29, 2021 and begin recovery of amounts deferred as of 12/31/2020 over a five year period beginning on January 1, 2022.

For Columbia of Virginia, the moratorium on non-residential disconnections ended on October 6, 2020, and the moratorium on residential disconnections and late payment fees ended on August 30, 2021. Legislative and regulatory requirements extending COVID-19 payment plans between 6 and 24 months remain in place.

In connection with the Maryland Relief Act and the order issued by the PSC of Maryland on June 15, 2021, Columbia of Maryland received approximately $0.8 million of assistance that was applied to customer accounts in August 2021. As such, all termination moratoriums were lifted and normal collections procedures resumed on November 1, 2021.