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HomeMy WebLinkAbout20240410Staff Comments.pdf FBaIVID Vvbdnesday,April 10,20244.53.40PM IDAHOPUB IC UIIIITIES C 0tvMS'4ON ADAM TRIPLETT DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 IDAHO BAR NO. 10221 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF QUESTAR GAS ) COMPANY AND ENBRIDGE QUAIL ) CASE NO. QST-G-23-01 HOLDINGS' JOINT APPLICATION FOR ) APPROVAL OF THE PROPOSED SALE OF ) FALL WEST HOLDCO,LLC TO ENBRIDGE ) COMMENTS OF THE QUAIL HOLDINGS, LLC ) COMMISSION STAFF COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission ("IPUC"),by and through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following comments. BACKGROUND On October 20, 2023, Questar Gas Company ("Questar Gas or Questar")1 dba Dominion Energy Utah and Enbridge Quail Holdings, LLC ("EQ Holdings") filed a copy of a Joint Notice and Application("Joint Application") currently pending before the Utah Public Service Commission("UPSC") that seeks approval of EQ Holdings' acquisition of Questar's parent company, Fall West Holdco LLC (the "Transaction"). The Joint Application outlines the multi- ' Questar provides gas service to customers in Franklin County,Idaho,under an unusual regulatory framework. Pursuant to a Contract for Regulatory Services authorized by Idaho Code§61-505,the rates,charges,and service regulations adopted by the Utah Public Service Commission for Questar's customers in Utah also apply to Questar's Idaho customers. STAFF COMMENTS 1 APRIL 10, 2024 step corporate reorganization process by which Questar will become a wholly owned subsidiary of EQ Holdings if the acquisition is approved. In response to the filing of the Joint Application, the Commission opened this case to review the Transaction as it relates to Questar's Idaho customers who are rate regulated by UPSC. Staff intervened and participated in UPSC proceedings of Docket No. 23-057-16. On December 7, 2023, a virtual technical conference was held to discuss and provide information related to the Transaction to the Utah Division of Public Utilities, the Utah Office of Consumer Services ("OCS"), interested parties, and the UPSC and its Staff. IPUC Staff attended the December 7, 2023, virtual Technical Conference where Dominion Energy presented information on their divestiture of gas distribution utilities, including Questar Gas. At the same conference, Enbridge Inc. presented information regarding their corporation, the proposed transaction, an integration plan, financing details, and regulatory commitments. Staff participated in the development of a Settlement Stipulation and Commitment Matrix between the parties. In January 2024 through February 2024, Staff participated in multiple virtual meetings with parties in the UPSC case to review content of the proposed Commitment Matrix and Settlement Stipulation ensuring Idaho's interests were considered and reflected in the documents. While Idaho was not a signing party to the Settlement Stipulation, Staff agrees in principle with the terms in the final document and addresses specifics below. On March 10, 2024, the Settlement Stipulation was finalized and is pending approval. The UPSC is expecting to issue an Order by May 23, 2024. STAFF ANALYSIS If the Transaction is approved by the IPUC and the UPSC, Staff, based on its review, recommends that the Commission modify the current Contract for Regulatory Services ("Agreement") with the UPSC,under which the UPSC regulates rates for Questar's Idaho customers, and revise CPCN No. 315 to indicate the change in ownership of Questar Gas. Due to the unusual regulatory framework governing Questar, a short discussion of the development of that framework is beneficial to an understanding of Staff s recommendations. 2 See Attachment No. 1. STAFF COMMENTS 2 APRIL 10, 2024 Regulatory Considerations IPUC CPCN & Contract for Re _gulatory Services The Certificate of Public Convenience and Necessity("CPCN")under which the Company provides service in Idaho was issued more than thirty years ago and has been amended twice. On June 8, 1990, Mountain Fuel Supply Company, a Utah corporation qualified to do business in the State of Idaho, filed an Application with the Commission requesting a CPCN to operate as a natural gas corporation and public utility in the State of Idaho, and authority to construct facilities required to provide natural gas service in southeastern Idaho. IPUC Regulatory HistgH In Order No. 23282, Case No. MOU-G-90-01, the Contract for Regulatory Services and CPCN were established. Mountain Fuel proposed to provide service to Idaho customers on the same basis and in accordance with the same policies and tariff provisions, rates, charges, and service regulations adopted by the UPSC for its similarly situated Utah customers. To accomplish this end, Mountain Fuel conditioned its initial performance under the requested Idaho Certificate on the execution of a contract for regulatory services between the IPUC and the UPSC in accordance with Idaho Code 61-505. In Case No. QST-G-01-01, Certificate No. 315 was amended for the first time. On January 1, 1998, Mountain Fuel Supply Company changed its name to Questar Gas Company. The amendment was predicated and issued pursuant to the findings contained in Order No. 23282. In Order No. 33367, Case No. QST-G-15-01, the service territory definition was modified to include all of Franklin County, Idaho. In Order No. 33628, Case No. QST-G-16-01, the merger of Dominion Resources, Inc., and Questar Gas ("Dominion Questar")was acknowledged. The IPUC Commission ordered that Dominion Questar notify it by letter when it files notices, applications, petitions, requests, etc., with the UPSC. Contract for Regulatory Services and CPCN No. 315 Updates As a result of the proposed sale and approval of the Settlement Stipulation by UPSC, Staff recommends a number of administrative changes that need to be made to the current Contract for Regulatory Services and CPCN No. 315. A third amendment to CPCN No. 315 STAFF COMMENTS 3 APRIL 10, 2024 should include applicable Company name changes and references to prior Commission Orders. Similarly, Staff recommends the current Contract for Regulatory Services be continued and updated to include applicable name changes, current addresses, and phone numbers for the parties. Consumer Support Idaho Questar Gas customers receive support for consumer issues through the same methods used for Utah customers. When Idaho customers require assistance, their primary point of contact is Questar Gas Customer Service at 800-323-5517 or via the Company's website.3 If the customers' issue cannot be resolved with Questar Gas, they can file a complaint with the Utah Division of Public Utilities at 801-530-7622 or 800-874-0904 or via the Division's website.4 In the event that a Questar Gas customer contacts the IPUC Consumer Assistance group, a Utilities Investigator will obtain limited information from the customer and provide them with contact information for both Questar Gas and the Utah Division of Public Utilities. Pipeline Safety Under the current Contract for Regulatory Services with the UPSC, the IPUC Pipeline Safety Section maintains pipeline safety supervision over Questar Gas's facilities located in Idaho. The IPUC Pipeline Safety Section, through an annual certification with the U.S. Department of Transportation's Pipeline and Hazardous Material Safety Administration ("PHMSA") Office of Pipeline Safety, oversees gas pipeline safety standards for intrastate gas pipelines in Idaho. The Questar Gas infrastructure located in Franklin County, Idaho, falls under the intrastate gas pipeline definition and IPUC jurisdiction. Staff recommends that IPUC Pipeline Safety Section maintain pipeline safety supervision over Questar Gas's facilities located in Idaho subsequent to approval of the Transaction and an updated Contract for Regulatory Services with the UPSC. 3 https://www.questargas.com/forms/feedback/feedback.php 4 https:Hdpu.utah.gov/customer-service/faqs/utility-complaint-procedure/ STAFF COMMENTS 4 APRIL 10, 2024 Questar Gas is required to file an annual report by March 151 of each year with PHMSA under 49 CFR Part 191.5 These reports are available from the U.S. Department of Transportation PHMSA website, and a copy is on file at the IPUC. CUSTOMER BENEFITS and NOTIFICATION Idaho Customer Benefits The rates, charges, and general conditions for natural gas service in Idaho as well as Utah are detailed in the Utah Natural Gas Tariff PSCU 600 Tariff.6 During its review of the Application, Staff determined that an Energy Assistance charge of$0.01176 per Dth(dekatherm = 10 therms) included in the tariff is not applicable for Idaho customers. In development of the Commitment Matrix, Parties agreed to include elimination of the Energy Assistance charge for Idaho customers. If the Transaction is approved, language in the tariff and the Questar Gas billing system will be modified to exclude Idaho customers from this charge. Using data supplied by Questar Gas for the IPUC fiscal years 2017—2023, Staff determined that the average General Service ("GS") customer consumed approximately 74.11 Dth(dekatherms) of natural gas yearly. Elimination of the charge will save the average Idaho GS customer approximately $0.87 annually. Also included in the Utah Natural Gas Tariff PSCU 600 Tariff is a Sustainable Transportation Energy Plan("STEP") surcharge of$0.00346 per Dth that is due to sunset in June of 2024 reducing Utah and Idaho customers charges by this amount. The applicants describe a number of benefits customers would recognize if the Transaction is approved. EQ Holdings will make a charitable contribution of$2000 to a charitable organization in Idaho, in the calendar year when the closing occurs. The charitable organization recipient will be selected by EQ Holdings in consultation with local management of Questar Gas. Enbridge owns and operates the largest natural gas utility by volume in North America, bringing economies of scale to the Transaction. Questar Gas will benefit from a parent company with natural gas as a primary focus as well as the financial resources of Enbridge. 5 https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-D/part-l91?toc=1 6 https://cdn-dominionenergy-prd-OOI.azureedge.net/-/media/pdfs/utah/rates-and-tariffs/utah- tarif£pdf?la=en&rev=4ee919c5 fb8a43 80b8al e670f34eb515&hash=B634406CBBD24B6127F26788812928F2 STAFF COMMENTS 5 APRIL 10, 2024 Questar Gas will continue to have its headquarters in Salt Lake City, Utah, will be locally managed, and will retain many of their current employees. Customers will be doing business with people they have interacted with in the past. The Commitment Matrix also provides for a credit to the revenue requirement in the 2024 Infrastructure Replacement Investment Tracker of$275,000. This will reduce the potential increase in rates for customers. Questar Gas will not seek recovery of any associated transaction and goodwill costs from its customers in rates. Questar Gas will include a summary showing Wexpr07 production by location and natural gas purchases by pipeline interconnect hub within its Integrated Resource Plan. In the next two general rate cases, Questar Gas will not seek recovery on a per customer basis for increases above the amount reflected in the Commitment Matrix for ordinary operating, maintenance, and administrative and general expenses. Specific ring-fencing structures and financial commitments will also be met. Ongoing reports will be filed with the UPSC to show compliance. The Idaho Staff will follow the tariff change process and complete a review to verify completion of the Idaho specific terms. This process review will be coordinated within the Utah process. Staff believes the proposed Settlement Stipulation and Commitment Matrix are reasonable and in the public interest. Customer Notification and Public Outreach On September 5, 2023, Dominion Energy announced that it had completed a sale process and executed agreements to sell its three natural gas distribution companies to Enbridge. The sale includes Questar Gas Company and Wexpro Company which provides service to Idaho, Utah, and Wyoming customers. Dominion Energy Utah will be rebranded to Enbridge Gas Utah with messaging matched to its different customer classes. Staff conducted a Virtual Public Workshop that was held on April 3, 2024 at 1:00 p.m. The workshop was attended by multiple IPUC employees in the Hearing Room; two Dominion Questar and seven Enbridge employees joined online. No Idaho customers or members of the 7 Wexpro is a drilling and production company and is a subsidiary of Fall West and will become a subsidiary of EQ Holdings. 8 Three gas LDCs—The East Ohio Gas Company,Public Service Company of North Carolina,Incorporated,and Questar Gas Company along with Wexpro Company. STAFF COMMENTS 6 APRIL 10, 2024 public participated in-person, online, or over the phone. Staffs presentation was approximately thirty minutes in duration and there were no questions or comments from participants. A Customer Hearing was conducted on April 10, 2024 at 1:00 p.m. in Preston, Idaho. No members of the public participated or signed up to give testimony. Representatives from both companies, Questar Gas Company and Enbridge Gas, attended but did not provide testimony. STAFF RECOMMENDATIONS 1. Staff recommends that the Commission continue the current Contract for Regulatory Services with the UPSC and make any necessary administrative updates resulting from the Transaction; 2. Staff recommends that the Commission make any necessary administrative updates to CPCN No. 315 resulting from the Transaction; and 3. Staff recommends that IPUC Pipeline Safety Section maintain pipeline safety supervision over Questar Gas's facilities located in Idaho, subsequent to approval of the Transaction and an updated Contract for Regulatory Services with the UPSC. Respectfully submitted this 10th day of April 2024. Adain l riplett Deputy Attorney General Technical Staff: Kevin Keyt Curtis Thaden I:\Utility\UMISC\COMMENTS\QST-G-23-01 Comments.docx STAFF COMMENTS 7 APRIL 10, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 10'h DAY OF APRIL 2024, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. QST- G-23-01, BY EMAILING A COPY THEREOF, TO THE FOLLOWING: KELLY B MENDENHALL JENNIFFER NELSON CLARK DOMINION ENERGY UTAH DOMINION ENERGY UTAH 333 SOUTH STATE STREET 333 SOUTH STATE STREET PO BOX 45360 PO BOX 45360 SALT LAKE CITY UT 84145 SALT LAKE CITY UT 84145 E-MAIL: E-MAIL: kellv.mendenhall.c dominionenerQv.com jenniffer.clark(tdoininionenergv.com CAMERON SABIN GEORGE SAMPAS MAYER BROWN LLP TIA BARANCIK 201 S MAIN ST STE 1100 SULLIVAN & CROMWELL LLP SALT LAKE CITY UT 84111 125 BROAD STREET E-MAIL: esabinLamayerbrown.com NEW YORK NY 10004-2498 E-MAIL: sampasg.cusullerom.com barancikt rmsullcrom.com BRIAN BURNETT JENNIFER REINHARDT-TESSMER KIRTON MCCONKIE 50 E SOUTH TEMPLE#400 SALT LAKE CITY UT 84111 E-MAIL: bburnettRkmclaw.com itessmer@kmclaxy.com Jul PATRICIA JORD N, SECRETARY CERTIFICATE OF SERVICE CASE NO. QST-G-23-01 ATTACHMENT NO. 1 SETTLEMENT STIPULATION and COMMITMENT MATRIX Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 Jenniffer Nelson Clark(7947) Cameron Sabin(9437) Dominion Energy Mayer Brown LLP 333 South State Street 201 S. Main Street, Suite 1100 P.O. Box 45433 Salt Lake City, Utah 84111 Salt Lake City,Utah 84145-0433 Phone: (801) 907-2715 Phone: (801) 324-5392 Email: csabingmayerbrown.com Email: jenniffer.clarkgdominionenergy com Attorneys for Questar Gas Company dba Dominion Energy Utah Brian Burnett(3772) Jennifer Reinhardt-Tessmer(19179) Kirton McConkie 50 E. South Temple #400 Salt Lake City, UT 84111 (801) 239-3185 Email: bbumett(a kmclaw.com jtessmer&kmclaw.com Attorneys for Enbridge Quail Holdings, LLC BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH In the Matter of the Joint Application of Questar Gas Company dba Dominion Energy Docket No.23-057-16 Utah and Enbridge Quail Holdings, LLC for Approval of the Proposed Sale of Fall West SETTLEMENT STIPULATION Holdco, LLC to Enbridge Quail Holdings, LLC. Pursuant to Utah Code Ann. § 54-7-1 and rules of the Public Service Commission of Utah ("Commission"), Questar Gas Company ("Questar Gas") dba Dominion Energy Utah and Enbridge Quail Holdings, LLC ("EQ Holdings") (together "Applicants"); the Utah Division of Public Utilities ("Division"); the Utah Office of Consumer Services ("OCS"); and the Utah Association of Energy Users ("UAE"); (collectively "Parties" or singly "Party") submit this Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 Settlement Stipulation. This Settlement Stipulation shall be effective upon the entry of a final order of approval by the Commission. PROCEDURAL HISTORY 1. On September 5, 2023, Dominion Energy, Inc. ("DEI") and EQ Holdings entered into a Purchase and Sale Agreement by which EQ Holdings will acquire from DEI all of the outstanding equity interests of Fall West Holdco LLC ("Fall West"), the parent company of Questar Gas (the "Transaction"). 2. On October 20,2023,the Applicants filed a Joint Notice and Application of Questar Gas and EQ Holdings requesting Commission approval of the Transaction in Docket No. 23-057- 16 ("Joint Notice and Application"). Applicants also filed a Joint Application seeking approval of the Transaction before the Wyoming Public Service Commission ("Wyoming Commission") in Docket No. 30010-218-GA-23 ("Wyoming Joint Application"). Both the Joint Notice and Application and the Wyoming Joint Application were accompanied by pre-filed direct testimonies of Michele Harradence, Christopher Johnston, James Sanders, and Judd Cook, along with substantial supporting exhibits and information. 3. On October 20, 2023, Questar Gas also provided a notice of the Transaction along with copies of the Joint Notice and Application and related documents filed with the Commission to the Idaho Public Utilities Commission(the"Idaho Commission"),which opened Case No. QST- G-23-01 to review the Transaction as it relates to Questar's Idaho customers. 4. On November 7, 2023, the Commission issued a Scheduling Order, Notice of Technical Conference, Notice of Public Witness Hearing, and Notice of Hearing setting dates for filing testimony and hearings. Attachment No. 1 4883-4361-4638 2 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 5. Since that time, the following parties have intervened: UAE and the Idaho Commission. In August 1990, due to the small number of Idaho customers being served by Mountain Fuel Supply Company(predecessor to Questar Gas), the Idaho Commission approved a "Contract for Regulatory Services"with the Commission(pursuant to Idaho Code Section 61-505) agreeing that"the rates, charges and service regulations adopted by the [Utah PSC] will also apply to similarly situated customers served by Mountain Fuel Supply in Idaho." In 2016, when DEI purchased Questar Gas, the Idaho Commission signed on to the Utah approval pursuant to an updated Contract for Regulatory Services entered under Idaho law which permits regulatory agencies of neighboring states to hold hearings and set rates and charges for customers in Idaho located in or nearby border communities served by utilities principally located in states other than Idaho. See Order No. 33628, Case No. QST-G-16-01. 6. On December 7, 2023, a technical conference was held to discuss and provide information related to the Transaction to the Division, the OCS, interested parties, and the Commission and its staff. 7. On February 5, 2024, the Division filed the Direct Testimony of Casey Coleman and Eric Orton, with an accompanying exhibit. On February 5, 2024, the OCS filed the Direct Testimony of Jacob Zachary. On February 5, 2024, UAE filed the Direct Testimony of Kevin Higgins. 8. On February 27,2024, Questar Gas filed a Motion to Amend the Scheduling Order, Notice of Technical Conference,Notice of Public Witness Hearing, and Notice of Hearing to allow the Parties additional time to reach a settlement in this docket. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 3 Attachment to Staff Comments April 10, 2024 9. On February 29, 2024,the Commission issued an Order Granting in Part Motion to Amend Scheduling Order,Notice of Technical Conference,Notice of Public Witness Hearing, and Notice of Hearing establishing an amended schedule in this docket. 10. The Division, OCS, UAE, Idaho Commission, Wyoming Office of Consumer Advocate, and Wyoming Commission Staff have asked, and Applicants have responded to, numerous data requests and inquiries. 11. During January and February of 2024, the Parties met to discuss settlement of the matters raised herein. Through arm's length negotiations, the Parties have reached agreement as set forth below. TERMS AND CONDITIONS The Parties agree for purposes of settlement that the Joint Notice and Application should be granted and approved, subject to the following commitments as set forth in the Joint Notice and Application filed with the Commission on October 20, 2023, in Docket No. 23-057-16, and as modified and supplemented by the Commitment Matrix attached hereto and incorporated by reference herein as Exhibit A with Attachment 1, and should be imposed upon the Applicants as agreed by the Parties and as a condition of the Commission's approval of the Transaction. The Parties agree that the effect of this Settlement Stipulation, if approved by the Commission, should result in an Order that, effective upon the closing of the Transaction, supersedes and replaces the obligations set forth in the Order approving the merger in Docket No. 16-057-01. GENERAL 1. The Parties agree that settlement of those issues identified above is in the public interest and that the results are just and reasonable. The Parties are authorized to represent that the Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 4 Attachment to Staff Comments April 10, 2024 intervenors in this Docket that have not entered into this Settlement Stipulation do not oppose this Settlement Stipulation. 2. The Parties agree that no part of this Settlement Stipulation or the formulae or methods used in developing the same, or a Commission order approving the same, shall in any manner be argued or considered as precedential in any future case. This Settlement Stipulation does not resolve, does not provide any inferences regarding, and the Parties are free to take any position with respect to, any issues not specifically identified and settled herein. All negotiations related to this Settlement Stipulation are confidential and subject to applicable Utah Rules of Evidence,including Rule 408, and no Party shall be bound by any position asserted in negotiations not specifically identified and settled herein. Neither the execution of this Settlement Stipulation nor an order adopting it shall be deemed to constitute an admission or acknowledgment by any Party of the validity or invalidity of any principle or practice of ratemaking; nor shall they be construed to constitute the basis of an estoppel or waiver by any Party;nor shall they be introduced or used as evidence for any other purpose in a future proceeding by any Party except in a proceeding to enforce this Settlement Stipulation. 3. Questar Gas, EQ Holdings, the Division, and the OCS each will make one or more witnesses available to explain and support this Settlement Stipulation to the Commission. Such witnesses will be available for examination. As applied to the Division and the OCS, the explanation and support shall be consistent with their statutory authorities and responsibilities. So that the record in this docket is complete, the Parties agree to recommend that all Parties' filed testimony, exhibits, and the Joint Notice and Application and its exhibits that have been filed in this docket shall be admitted as evidence. Attachment No. 1 4883-4361-4638 5 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 4. The Parties agree that if any person challenges the approval of this Settlement Stipulation or requests rehearing or reconsideration of any order of the Commission approving this Settlement Stipulation, each Parry will use its best efforts to support the terms and conditions of the Settlement Stipulation. As applied to the Division and the OCS,the phrase"use its best efforts" means that they shall do so in a manner consistent with their statutory authorities and responsibilities. In the event any person seeks judicial review of a Commission order approving this Settlement Stipulation, no Party shall take a position in that judicial review opposed to the Settlement Stipulation. 5. Except with regard to the obligations of the Parties under Paragraphs 2, 3 and 4, of this Settlement Stipulation,this Settlement Stipulation shall not be final and binding on the Parties until it has been approved without material change or condition by the Commission. This Settlement Stipulation is an integrated whole, and any Party may withdraw from it if it is not approved without material change or condition by the Commission or if the Commission's approval is rejected or materially conditioned by a reviewing court. If the Commission rejects any part of this Settlement Stipulation or imposes any material change or condition on approval of this Settlement Stipulation, or if the Commission's approval of this Settlement Stipulation is rejected or materially conditioned by a reviewing court, the Parties agree to meet and discuss the applicable Commission or court order within five business days of its issuance and to attempt in good faith to determine if they are willing to modify the Settlement Stipulation consistent with the order. No Party shall withdraw from the Settlement Stipulation prior to complying with the foregoing sentence. If any Party withdraws from the Settlement Stipulation, the remaining Parties retain the right to seek additional procedures before the Commission, including presentation of Attachment No. 1 4883-4361-4638 6 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 testimony and cross-examination of witnesses, and no Party shall be bound or prejudiced by the terms and conditions of the Settlement Stipulation. 6. This Settlement Stipulation may be executed by individual Parties through two or more separate, conformed copies, the aggregate of which will be considered as an integrated instrument. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 7 Attachment to Staff Comments April 10, 2024 RELIEF REQUESTED Based on the foregoing,the Parties request that the Commission issue an order approving this Settlement Stipulation and adopting its terms and conditions. RESPECTFULLY SUBMITTED: March 1 2024. I011foslu(lk"91�al Utah Division of Public Utilities Uti mice of Consumer Services- Q star Gas Company Enbrid e Quall Holdings, LLC dba Dominion Energy Utah Utah Assoc atian >.IiEnergy Users Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments 4883-4361-4638 8 April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 1 OF 11 EQ Holdings and Questar Gas Commitments Matrix No. Commitment Corporate Structure; Local Presence; Local Management I a. At the closing of the Transaction, Fall West will become a direct subsidiary of EQ Holdings, and Questar Gas and Wexpro each will remain direct subsidiaries of Fall West and each will continue to exist as separate legal entities. Questar Gas Inc. will remain its legal name and will be rebranded to "Enbridge Gas Utah". b. Thereafter, Questar Gas d/b/a Enbridge Gas Utah will: (i) seek approval from the Utah Public Service Commission(the "Commission")prior to any transaction which, regardless of the means by which it is accomplished, results in a change of control of Questar Gas;provided,however,that any internal reorganization or any other transaction after which affiliates controlled by Enbridge Inc. (`Enbridge") continue to control Questar Gas shall not be deemed to be a change of control of Questar Gas; (ii)notify the Commission within 30 days after completing any transaction in which 10% or more of the common stock of Questar Gas or 10% or more of the voting interest of any direct or indirect subsidiary of Enbridge Genoa U.S. Holdings, LLC that directly or indirectly owns 10%or more of the common stock or other voting interest of Questar Gas is transferred to an entity that is not controlled by Enbridge; and(iii) comply with all provisions of the Utah Code, rules promulgated by the Commission, and Commission orders. 2 Upon completion of the Transaction, Questar Gas will be operated as a separate legal entity and its headquarters will, for the foreseeable future, remain located in the greater Salt Lake City, Utah area. 3 a. Questar Gas will continue to be locally managed by a seasoned team of executives with expertise in the retail natural gas utility industry who will have responsibility for implementing policies and practices to achieve the objectives of customer satisfaction,reliable service,public and employee safety, environmental stewardship, and collaborative and productive relationships with customers, regulators, governmental entities, and other interested stakeholders. b. In support of the foregoing, EQ Holdings commits that Questar Gas will be provided with access to the resources of the larger Enbridge group of companies and shared services provided by Enbridge and its affiliates. Attachment No. 1 4883-4361-4638 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 2 OF 11 Regulatory;Jurisdiction of the Commission; Compliance with Law 4 a. EQ Holdings and Questar Gas acknowledge that Questar Gas is and will remain subject to full regulation by the Commission' as prescribed by the Utah Code, rules promulgated by the Commission, and Commission orders. b. The Transaction will in no way diminish the authority of the Commission to regulate the service quality and rates charged to Questar Gas customers. Neither EQ Holdings nor Questar Gas will assert in any forum or proceeding that the authority of the Commission to regulate Questar Gas has been or will be diminished by reason of the Transaction. c. EQ Holdings and Questar Gas commit to honor existing laws, rules, regulations, provisions of its Tariff, orders, and directives of the Commission, as applicable, following completion of the Transaction. 5 a. EQ Holdings and Questar Gas commit that senior officers and management responsible for determining policies applicable to the Enbridge group of companies will, with reasonable notice, be available to testify before the Commission and provide relevant information related to matters within the jurisdiction of the Commission, including any such information required to be provided in response to discovery or requests about Enbridge or any of its subsidiaries. b. EQ Holdings and Questar Gas commit to maintain access to books and records requested pursuant to Commitment 5(a) in Salt Lake City, Utah. 6 Upon request,EQ Holdings and its affiliates will provide the Commission,the Utah Division of Public Utilities (the "Division"), the Utah Office of Consumer Services (the"OCS") and intervenors, including their auditors and authorized agents, in Utah rate and other regulatory proceedings, as appropriate, with reasonable access to transactional, accounting and other information, including personnel necessary to explain the requested information,regarding any costs directly or indirectly allocated to Questar Gas. 1 Questar Gas and EQ Holdings have made filings in each of the three states in which Questar Gas provides retail natural gas service: Utah,Wyoming, and Idaho. Attachment No. 1 4883-4361-4638 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 3 OF 11 7 a. All Wexpro agreements, stipulations, and associated guideline letters will be honored, and all such agreements, stipulations and associated guideline letters will be posted on a publicly available website. b. In the 2024 Integrated Resource Plan(IRP), Questar Gas will provide historical information specifying the volumes and the location(s) of its gas supply purchases for the prior three IRP years. In each IRP thereafter, Questar Gas will update such information by including comparable information for the next succeeding year. Questar Gas will, to the extent known to Questar Gas, provide information on the origin of gas purchased at each identified purchase point and the location of Wexpro Production utilized during each year. 8 EQ Holdings will develop and provide to the Division and the OCS a plan identifying how it intends to communicate the change in ownership of Questar Gas from Dominion Energy to EQ Holdings. Upon approval of the Application in this matter and until such communications plan concludes, Questar Gas will periodically meet with the OCS and the Division to share details, and receive feedback, about the communications plan. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 4 OF 11 Ratemaking;Accounting 9 Contingent upon the consummation of the Transaction, Questar Gas commits that: a. No changes will be made to Questar Gas's existing filed rates, rules, regulations, and classifications under its existing Utah Tariff as a result of the Transaction except, promptly following closing of the Transaction, Questar Gas will file a revised Utah Tariff to: i. Change the name of under which the operating entity will do business in the States of Utah and Idaho; and ii. Modify the Energy Assistance Fund language in section 8.03 of its Utah tariff to exclude Idaho customers. b. Except as contemplated by Commitment No. 9(a), to the extent necessary, changes to the Utah Tariff following closing of the Transaction will be made in the ordinary course of business. c. Questar Gas's current Infrastructure Replacement tracker was approved by the Commission in Questar Gas's last general rate case in Docket No.22-057-03 and provides for Questar Gas to recover costs for the replacement of aging infrastructure through a surcharge on Customers' monthly bills between general rate cases. Questar Gas agrees that: i. Questar Gas will not propose an increase to the current Commission approved Infrastructure Replacement Investment level of$84.7 million, adjusted annually based on the GDP deflator index, for Questar Gas's next two general rate cases. ii. In Questar Gas's next Infrastructure Replacement tracker rate adjustment filing with the Commission in 2024, Questar Gas will apply a $275,000 credit to the revenue requirement calculation, effectively reducing the revenue collection from Questar Gas's Customers through the surcharge by such amount for one year, as calculated pursuant to Questar Gas's Tariff PSCU 600, Section 2.07. 10 Questar Gas will not seek recovery on any acquisition premium (goodwill) cost associated with the Transaction from its customers and no goodwill costs will be recorded on Questar Gas's books, and Questar Gas will make the required accounting entries associated with the Transaction on that basis. Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments 4883-4361-4638 April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 5 OF 11 11 Transaction costs associated with the Transaction will not be recovered through the rates of Questar Gas or recovered through charges from affiliated companies of Enbridge or EQ Holdings to Questar Gas. Transaction costs are defined as: (i) legal, consulting, or other professional advisor costs to initiate, prepare, consummate, and implement Transaction, including obtaining regulatory approvals; (ii) rebranding costs, including websites, advertising, vehicles, signage, printing, and stationary;(iii)executive change in control costs(severance payments and accelerated vesting of share-based compensation); and (iv) financing cost related to the Transaction, including bridge and permanent financing costs, executive retention payments, costs associated with shareholder meetings, and proxy statement related to Transaction approval. 12 a. For regulatory purposes, Questar Gas's accounting will continue to reflect assets at historical costs, approved depreciation rates and deferred income taxes based on original cost in accordance with the Uniform System of Accounts. b. EQ Holdings and Questar Gas commit that Questar Gas's customers will be held harmless for any changes in income taxes and/or accumulated deferred income taxes as a result of the Transaction to the extent recovery would otherwise be obtained in Questar Gas's rates in accordance with tax normalization rules. Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments 4883-4361-4638 April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 6 OF 11 Shared Services;Affiliate Transactions 13 a. At closing of the Transaction, Questar Gas will enter into a Master Transition Services Agreement(TSA)with Dominion Energy pursuant to which it will receive certain corporate services that it currently receives from Dominion Energy and affiliates of Dominion Energy on terms and at rates previously approved by the Commission. The purpose of the TSA is to ensure that service quality, safety, and reliability will not be adversely affected by the Transaction. b. Questar Gas will not seek recovery in its retail rates for any "administrative fees" paid to Dominion Energy or any affiliate of Dominion Energy under or pursuant to Section 2 or Section 3 of Schedule 2.1 of the TSA.2 c. Questar Gas will not seek recovery in its next two general rate cases for any increase in the aggregate total inflation adjusted Operating, Maintenance, Administrative, and General Expenses (excluding energy efficiency,bad debt, and pension costs) cost per customer over the cost per customer for such items for the 12 months ended December 2023,unless Questar Gas can demonstrate that such increase was not caused by the Transaction(for example supply chain cost increases or cost increases caused by changes in accounting policy or legal and regulatory requirements). The amount for such items per customer for the 12 months ended December 2023 was $125.89 (2023 Baseline Cost Per Customer), as calculated in Attachment 1 to this Commitment Matrix. Questar Gas will increase the 2023 Baseline Cost Per Customer annually(as increased at the end of each year,the Adjusted Baseline Cost Per Customer) for inflation, if positive over the prior year,by the inflation factor of the U.S. Consumer Price Index—All Urban Consumers and compare the Adjusted Baseline Cost Per Customer to Questar Gas's actual per customer cost for Operating, Maintenance, Administrative, and General Expenses (excluding energy efficiency,bad debt, and pension costs) in the Integration Progress Report referred to in Commitment No. 36. 14 Questar Gas commits to continue to file its affiliate transaction report with the Commission on an annual basis. 2 An"administrative fee"surcharge on top of all charges under the TSA of 10%,beginning no earlier than one year after the closing date and increasing to 20%no earlier than two years after the closing date,will be imposed under the terms of the TSA until termination of the TSA. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 7 OF 11 15 a. Questar Gas will clearly reflect all of its costs and investments in its financial reports, including costs and assets that are directly assigned or allocated to it from another subsidiary of Enbridge. An audit trail will be maintained so that allocable costs can be specifically identified. b. Costs that have been denied recovery by the Commission in prior orders,unless subject to regulation by another governmental agency, will continue to be excluded from rates absent further order from the Commission. 16 Questar Gas will have the burden of proof to show that prices for goods and services provided by Enbridge or its other subsidiaries are just and reasonable and priced consistent with the Affiliate Expense Standard set forth in Section 2.06 of the Tariff. Community 17 a. Questar Gas's charitable contributions were $1,445,602 in 2022. In addition, Questar Gas disbursed $217,500 to various arts and education organizations through a trust. Commencing in the first calendar year in which the closing occurs, EQ Holdings will increase Questar Gas's charitable contributions by $175,000 per year for three years. The continuation of these contributions, with the incremental support, will benefit the local communities by helping to ensure continuity in efforts to support local charitable causes. Also, after the closing,the arts and education trust will be liquidated and the assets in the trust (approximately $3 million) will be given to the various arts and education organizations. b. Commencing in the first calendar year in which the closing occurs, for a period of three (3)years, EQ Holdings agrees to spend $225,000 in aggregate to promote the Energy Assistance Fund. c. In the calendar year in which the closing occurs, EQ Holdings will make a charitable contribution of$2000 to a charitable organization in Idaho, such charitable organization to be selected in consultation with local management of Questar Gas. I Operations 18 EQ Holdings and Questar Gas commit that Questar Gas will continue to install, upgrade, and maintain Questar Gas's infrastructure as necessary for safe and reliable operations and, in the absence of material unforeseen or unanticipated circumstances, as contemplated by Questar Gas's planned capital expenditure program. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 8 OF 11 19 EQ Holdings commits to implement Enbridge's Integrated Management System (which includes safety and risk management programs, processes, and procedures) at Questar Gas and will seek to do so within two years following closing of the Transaction. EQ Holdings and Questar Gas shall include a report on the status of such implementation in each Integration Progress Report referred to in Commitment No. 36 until such implementation is complete. 20 Questar Gas will continue to file an IRP on an annual basis. 21 Questar Gas will maintain the established gas-supply interchangeability Wobbe indices for Questar Gas receipt points and remain in compliance with the Commission's requirements. 22 Questar Gas agrees to retain the thermwise.com website and maintain it under local control so long as there are any energy efficiency programs in its Utah tariff to ensure Utah customer access to comprehensive and up-to-date information about those programs. Customer Satisfaction 23 d. Following closing of the Transaction, Questar Gas will work with the Division and the OCS on a collaborative basis and update the Customer Satisfaction Standards, taking into account recent historical results. e. Questar Gas will report quarterly on its performance relative to the Customer Satisfaction Standards. Quarterly reporting will continue through completion of the second general rate case filing following closing of the Transaction. If service levels fall short of the agreed"goals" identified in the updated Customer Satisfaction Standards, Questar Gas will file a remediation plan with the Commission explaining the undertakings Questar Gas will implement to improve and restore service to meet these goals. Financial and Ring-Fencing is 24 EQ Holdings commits to support the financial strength and integrity of Questar Gas, including by: (i)maintaining Questar Gas as a separate legal entity with clearly understood management and reporting lines; (ii) facilitating operational enhancements; (iii) ensuring that Questar Gas has access to the resources, funding, and credit needed to support its operations and growth; and (iv) establishing and implementing thoughtfully tailored ring-fencing structures adapted to the needs of Questar Gas given the overall policies and practices of the Enbridge group of companies and with due respect for the needs of Questar Gas's customers and the evolving important priorities confronting Questar Gas. Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments 4883-4361-4638 April 10, 2024 SETTLEMENT STIPULATION-EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 9 OF 11 25 None of EQ Holdings, Questar Gas, or Wexpro will incur any new indebtedness or liability for any acquisition debt incurred to finance the Transaction, and Questar Gas will not seek recovery in its rates for transaction costs related to the Transaction. Questar Gas's obligations with respect to its existing indebtedness will continue in connection with the Transaction. 26 a. Questar Gas will be supported with funding consistent with past practice and with the intention of maintaining investment grade credit ratings. b. Questar Gas will be provided with funding to meet its ongoing operational needs consistent with past practice and as necessary to provide safe and reliable service to all its customers. c. Any debt used to capitalize Questar Gas will be kept within the regulated utility. d. Without Commission approval, neither Enbridge nor any of its affiliates will make any loan to Questar Gas that bears interest at rates that are greater than the lower of. (i)rates being paid at the time of such loan by Enbridge or such other affiliate on its own debt; or(ii)rates available, at the time of such loan, on similar loans to Questar Gas from the market. 27 Questar Gas will be provided with the same access to short-term debt, commercial paper, and other liquidity as per past practices. 28 Questar Gas will maintain separate long-term debt with its own debt rating supplied by at least two nationally recognized debt rating agencies. 29 Questar Gas will continue to maintain its own bank accounts that are in its own name and direct access to exclusively committed credit facilities. 30 a. To the extent that any future dividends are offered, EQ Holdings intends to continue Questar Gas' practice of setting its dividend rates at levels that maintain Questar Gas's capital structure between 48% and 55%. b. Questar Gas will provide notification to the Commission of any such dividends paid and include in such notice an associated projection of cash flows. Attachment No. 1 Case No. QST-G-23-01 Attachment to Staff Comments 4883-4361-4638 April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 10 OF 11 31 The Joint Applicants commit to provide for and effect the appointment of a "Special Bankruptcy Director" to serve as a member of the Board of Directors of Questar Gas. Said Director shall be nominated by and retained from an independent entity, such as CT Corporation, (at shareholder expense) and shall not be employed by or otherwise affiliated with EQ Holdings or any affiliate of EQ Holdings. Said Director shall not participate in ordinary and routine activities of the Questar Gas Board and shall have no voting rights except in the event of a vote by the Questar Gas Board to approve a voluntary bankruptcy petition to be filed under Title 11 of the U.S. Code on behalf of Questar Gas. Notice of such vote shall be provided to the Special Bankruptcy Director prior to the meeting at which the Questar Gas Board holds a vote to consider said voluntary bankruptcy petition, and no voluntary bankruptcy petition on behalf of Questar Gas may be filed without the affirmative vote of the Special Bankruptcy Director. It is the intent of the Parties that the Special Bankruptcy Director will consider the interests of all relevant economic stakeholders, including without limitation the utility's customers, and the financial health and public service obligations of Questar Gas, in exercising his or her responsibilities, subject to applicable law. Concurrent with the notice to the Special Bankruptcy Director, Questar Gas will provide confidential notice to the Commission, Division, and the OCS. 32 EQ Holdings or Questar Gas will provide prompt notice to the Commission, the Division, and the OCS of any bankruptcy petition or other filing that petitions for Enbridge or any of its material subsidiaries to be declared bankrupt. Employees 33 For 24 months after closing, Questar Gas employees will have: (i) base pay and target annual cash bonuses that are no less than the employee's base pay and target annual cash bonus in effect prior to closing; and (ii) benefit plans that, in the aggregate, are equivalent to the employee's various benefits prior to closing. 34 a. Questar Gas employees will be offered opportunities to learn from and share experiences, including with respect to enhanced safety practices and protocols, with other Enbridge company employees and thereby share best practices for improving their experiences and customer experiences. b. Questar Gas will offer employee training and opportunities for career development, including due and fair consideration for other employment and promotion opportunities within the larger Enbridge organization,both inside and outside of Utah. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 SETTLEMENT STIPULATION—EXHIBIT A EQ HOLDINGS AND QUESTAR GAS DOCKET No.23-057-16 COMMITMENTS MATRIX PAGE 11 OF 11 JrClean Energy 35 EQ Holdings,as a member of the Enbridge family,is committed to conducting its business operations in an environmentally friendly and responsible manner. Consequently, EQ Holdings has embraced carbon reduction as a component of its sustainability goals and will, in its capacity as the owner of Questar Gas, seek to have Questar Gas operate and conduct the business of Questar Gas in accordance with this corporate philosophy. Consistent with this effort, EQ Holdings will explore the possibilities for implementing clean energy projects and undertake and explore possibilities for implementing clean energy projects within Questar Gas's service area with respect to renewable natural gas, hydrogen, and compressed natural gas. Such exploration will include assessment of Federal funding eligibility of any such projects under the U.S. Inflation Reduction Act. These efforts are intended to benefit consumers by helping to reduce combustion-related and methane emissions and helping to reduce the carbon intensity of the energy delivered to customers. Integration Progress Report 36 Questar Gas will work with the Division and the OCS on a collaborative basis to develop reporting requirements for an Integration Progress Report on planned and accomplished activities related to the Transaction. The report will also identify and include Transaction costs. Questar Gas will file the first Integration Progress Report with the Commission on or before April 15, 2025, for the period ending December 2024 and will provide updates quarterly thereafter until the conclusion of the second general rate case. Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 ATTACHMENT EXHIBIT A SETTLEMENT STIPULATION Docket No.23-057-16 Commitment Matrix Questar Gas Company 12 Months Ended Dec 2023 O&M and A&G per customer (A) (B) 1 Production -$685,362 2 Distribution 87,097,588 3 Customer Accounts(Excl.Bad Debt) 12,188,678 4 Customer Service/Information(Excl.EE) 3,559,291 5 Administrative&General(Excl. Pension Credit) 46,701,164 6 Bad Debt 6,219,365 7 Energy Efficiency 24,648,570 8 Pension Credit -12,588,204 9 Total O&M and A&G $167,141,090 10 LESS Bad Debt -$6,219,365 11 LESS Energy Efficiency -$24,648,570 12 LESS Pension Credit $12,588,204 13 Adjusted O&M and A&G S148,861,359 14 12-Month Avg Customer Count Dec 2023 1,182,438 15 O&M and A&G/Customer(Line 13 divided by 14) $125.89 Attachment No. 1 4883-4361-4638 Case No.QST-G-23-01 Attachment to Staff Comments April 10,2024 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Settlement Stipulation in Docket No. 23- 057-16 was served upon the following persons by email on March 21 SL2024: OUESTAR GAS COMPANY Jenniffer Nelson Clark jenniffer.clarknas.auestar.com Cameron Sabin csabinnu.maverbrown.com Kelly B.Mendenhall kelly.mendenhall&dominionenergyy.com Austin Summers austin.summers(adominionenergv.com ENBRIDGE QUAIL HOLDINGS. LLC Brian Burnett bbumettnkmclaw.com Jennifer Reinhardt-Tessmer jtessmer&kmclaw.com Tia Barancik baranciktnsullcrom.com George Sampas sampasg(a),sullcrom.com DIVISION OF PUBLIC UTILITIES Chris Parker chrisparker(cutah.gov Madison Galt mgalt&utah.gov Patricia Schmid pschmidaaautah.gov Patrick Grecu pgrecu c&agutah.gov dnudatarequest&utah.gov OFFICE OF CONSUMER SERVICES Michele Beck mbeck c&utah.gov Bela Vastag bvastag&utah.gov Alyson Anderson akanderson cnisutah.gov Alex Ware aware(a),utah.gov Robert Moore rmoorenaQutah.gov ocs(cutah.gov UTAH ASSOCIATION OF ENERGY USERS Phillip J.Russell prussell(&,idrslaw.com Kevin Higgins khigginsaenergvstrat.com Neal Townsend ntownsendaenergystrat.com Kelly Francone kfrancone&energvstrat.com Justin Farr jfarr&energvstrat.com Shantell Garrett sgarrettng.energvstrat.com Attachment No. 1 Case No. QST-G-23-01 4883-4361-4638 Attachment to Staff Comments April 10, 2024 IDAHO PUBLIC UTILITIES COMMISSION Michael Duval michael.duval&puc.idaho.g Adam Triplett adam.trinlett&12uc.idaho.gov Kevin Keyt kevin.kevtgpuc.idaho. oovv Ty Johnson ty.iohnsonna puc.idaho.gov Chris McEwan chris.mcewannapuc.idaho.gov Terri Carlock terricarlockna puc.idaho. oovv Attachment No. 1 4883-4361-4638 Case No. QST-G-23-01 Attachment to Staff Comments April 10, 2024