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HomeMy WebLinkAbout20250530Direct Kivisto.pdf RECEIVED May 30, 2025 Preston N. Carter, ISB No. 8462 IDAHO PUBLIC Megann E. Meier, ISB No. 11948 UTILITIES COMMISSION GIVENS PURSLEY LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Office: (208) 388-1200 Fax: (208) 388-1300 prestoncarter@givenspursley.com mem@givenspursley.com Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION Case No. INT-G-25-02 OF INTERMOUNTAIN GAS COMPANY FOR THE AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR NATURAL GAS SERVICE IN THE STATE OF IDAHO DIRECT TESTIMONY OF NICOLE KIVISTO INTERMOUNTAIN GAS COMPANY MAY 30,2025 INTRODUCTION 1 Q. Please state your name and business address. 2 A. My name is Nicole A. Kivisto and my business address is 1200 W Century Ave, Bismarck, 3 North Dakota 58503. 4 Q. What is your occupation? 5 A. I am the President and Chief Executive Officer("CEO") of MDU Resources Group, Inc. 6 ("MDU Resources"). I also continue to serve as the President and CEO of Intermountain 7 Gas Company("Intermountain" or"Company"), Cascade Natural Gas Corporation 8 ("Cascade"), and Montana-Dakota Utilities Co. ("Montana-Dakota"), all subsidiaries of 9 MDU Resources, as well as Great Plains Natural Gas Co. (a division of Montana-Dakota) 10 collectively the MDU Utilities Group and positions I have held since January 2015. In 11 total, I have worked for MDU Resources/Montana-Dakota for thirty years. STATEMENT OF QUALIFICATIONS 12 Q. Please briefly describe your educational background and professional experience. 13 A. I hold a bachelor's degree in accounting from Minnesota State University Moorhead. In 14 January 2024, I assumed my current role of President and CEO of MDU Resources. Since 15 2015, I had served as MDU Utilities Group CEO. Prior to that I was Vice President 16 Operations of Montana-Dakota and Great Plains Natural Gas Co., for one year and Vice 17 President, Controller, and Chief Accounting Officer for MDU Resources for nearly four 18 years. I held other finance-related positions prior to that. PURPOSE OF TESTIMONY 19 Q. Please summarize your testimony. 20 A. My testimony provides an overview of Intermountain's corporate profile and its new PAGE 1 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I "CORE" strategy, followed by an outline of the strategies the Company is pursuing to 2 provide exceptional customer service while continuing to supply the important energy 3 required to fuel the growth seen throughout the Company's southern Idaho service 4 territory. 5 1 will also summarize Intermountain's rate request which is primarily driven by 6 ongoing capital investments necessary to offer safe and reliable service to both existing 7 customers and those seeking natural gas service. I will next discuss an increase in costs 8 driven primarily by the need to maintain a high-quality, skilled workforce. In addition, l 9 will discuss our focus on cost management and uncovering efficiencies which are helping 10 to mitigate cost increases. Next, I will discuss the importance of fair and timely recovery of 11 prudently incurred expenses and a reasonable rate of return and demonstrate the challenges 12 the Company is facing in earning its allowed rate of return due to regulatory lag. Finally, I 13 will introduce the Company witnesses who will provide testimony and other evidence in 14 support of the Company's proposals. 15 Q. Are you sponsoring any exhibits to your direct testimony? 16 A. Yes, I sponsor the following exhibit: 17 Exhibit 1 System Map COMPANY OVERVIEW 18 Q. Please provide a brief overview of the Company. 19 A. Intermountain has provided safe, reliable, economical natural gas distribution services 20 throughout southern Idaho for the past 75 years. As of December 2024, Intermountain 21 operates in 74 communities and provides natural gas service to 429,142 retail customers 22 and 113 transportation customers. Intermountain was incorporated in Idaho in 1950, and in PAGE 2 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY 1 2008 became a wholly owned subsidiary company of MDU Resources. Intermountain's 2 headquarters are located in Boise, Idaho. A map illustrating Intermountain's distribution 3 system is included as Exhibit No. 1. 4 Idaho has experienced remarkable population growth in recent years, with an 8.8% 5 increase from 2020 to 2024, rising from 1,839,140 to an estimated 2,001,619 residents, 6 according to the U.S. Census Bureau. This rapid expansion has been fueled by in- 7 migration, as families and professionals are drawn to the state's safety, affordability, and 8 abundant career opportunities. For Intermountain, this surge in population presents both 9 challenges and opportunities. The growing demand for natural gas services has 10 necessitated significant investments in infrastructure to maintain a safe and reliable energy 11 supply. Intermountain has aligned its strategies to accommodate this growth, ensuring 12 timely delivery of services while balancing affordability and operational excellence. The 13 Company's commitment to supporting Idaho's economic expansion underscores its role as 14 a pivotal partner in the region's development. 15 Q. Describe Intermountain's business strategy. 16 A. Intermountain's parent company is MDU Resources,which was started as a small electric 17 utility in 1924 and recently reached a significant milestone by celebrating 100 years in 18 business on March 14, 2024. Over the past 100 years, MDU Resources has continued to 19 evolve by expanding into different business lines and growing its utility, including its 2008 20 acquisition of Intermountain. In 2023, MDU Resources spun off Knife River, its former 21 construction materials and contracting business, and in 2024 spun off Everus Construction 22 Group, its former construction services business, into separate publicly traded companies. PAGE 3 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I The completion of these strategic initiatives brings MDU Resources to its desired 2 state of focusing on its core business as a pure play regulated energy delivery company, 3 allowing management and the board of directors to focus on the utility and pipeline 4 businesses. With this new day, the Company has implemented a"CORE" strategy, which 5 prioritizes customers and communities, operational excellence, returns focused initiatives 6 and an employee driven culture. Achieving 100 years in business at MDU Resources, and 7 75 years in business in 2025 at Intermountain, underscores our long-term commitment to 8 doing what's right for our employees, customers, communities and shareholders and aligns 9 with the values that our founder, Rolland M. Heskett, embodied"when communities 10 thrive, we thrive". Both MDU Resources and Intermountain believe community support— 11 beyond providing safe, reliable, and affordable energy—is essential to doing what's right. 12 The Company has a long history of encouraging and supporting its employees as they 13 engage with community-based organizations and non-profits. The Company also provides 14 financial support to the important work of these organizations. 15 Q. What are some of the ways the Company supports the communities it serves? 16 A. Throughout its history, Intermountain has been committed to living its tagline of"In the 17 Community to Serve."The year 2025 marks Intermountain's 75th anniversary. In honor of 18 this important milestone, the MDU Resources Foundation ("Foundation")plans to donate 19 $7,500 to five different charities, one charity in each of Intermountain's districts. 20 Each year, employees spend many hours volunteering and serving in leadership 21 roles with various organizations across the service territory. Intermountain has a long 22 history of supporting the United Way in the communities served across southern Idaho. 23 Many employees choose to allocate a portion of their paychecks directly to United Way. In PAGE 4 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I addition to financial support, many Intermountain employees serve within the United Way 2 organizations in various capacities. The Company fields teams annually for Paint the Town 3 and Rake Up Boise. In addition, the Company has supported the Boise Rescue Mission 4 through canned food drives since 2015. In the Pocatello area, employees participate in 5 Paintfest, Pocatello Spring Clean-up, and Brooklyn's Playground Clean-Up. Many 6 employees serve through The Salvation Army and their events that benefit our 7 communities. For over 40 years, Intermountain has annually sponsored a telephone bank of 8 volunteers to take pledges and contributes as a programming sponsor on PBS through 9 Idaho Public Television. Over the past 28 years, Intermountain has supported the Keep 10 Kids Warm program which has been supplying Treasure Valley children in need with 11 warmth. To date, over$1.5 million has been raised, along with thousands of coats to 12 achieve the mission of keeping children warm through the winter. 13 Further, the Foundation provides support to the communities served by 14 Intermountain. The goal of the Foundation is to help our neighbors make our communities 15 better places to live and work. The Foundation provides an annual $1,000 scholarship to 16 each of the nine Idaho colleges and universities. In addition to the employee support of 17 United Way, the Foundation also provides annual donations to the four United Way 18 organizations located within our service territory, for a total donation in 2024 of$26,500. 19 Beyond United Way, the Foundation provides one-time grants to non-profit organizations 20 throughout Intermountain's service territory. Organizations receiving a $3,000 to $5,000 21 donation in 2024 included Boise Habitat for Humanity, Giraffe Laugh, The Giving 22 Cupboard, The Jesse Tree of Idaho, Life's Kitchen,NeighborWorks Boise, Pocatello 23 Neighborhood Housing Services and Wyakin Warrior Foundation, Inc. Finally, the PAGE 5 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I Foundation supports selected multi-year projects. As an example, it is currently providing 2 $5,000 annually for five years to support construction of a new club facility for the Boys & 3 Girls Club of Ada County. Intermountain's culture of employee volunteerism and the 4 financial support of the Foundation demonstrate the Company's commitment to be "In the 5 Community to Serve."The Foundation, which has a philanthropic goal to be "a neighbor 6 of choice", is funded entirely by shareholder contributions. 7 Q. How is Intermountain focused on providing exceptional customer service? 8 A. Intermountain's CORE strategy is centered on delivering exceptional customer service and 9 achieving best-in-class customer satisfaction. Intermountain has a consistent track record 10 of high rankings within the J.D. Power Gas Utility Residential Customer Satisfaction 11 Study. As discussed in the testimony of Eric Martuscelli, Intermountain has been ranked 12 first or second in overall customer satisfaction for West Midsize utilities twelve out of the 13 previous fourteen years. The CORE strategy builds trust by focusing on safety, timely and 14 clear communication, and efficient service. Intermountain takes a community-focused 15 approach, supporting economic development and strengthening relationships across the 16 communities it serves. By putting customers first and supporting community growth, 17 Intermountain aims to create a positive cycle of shared success throughout Idaho. INTERMOUNTAIN'S REQUEST 18 Q. Please summarize Intermountain's requested increase in this filing. 19 A. With this application, Intermountain is seeking to increase revenues by approximately 20 $26.5 million. This request represents a margin revenue increase of 22.2 percent, or an 21 overall revenue increase of 8.6 percent. The rate increase requested in this filing is 22 necessary to continue supporting Idaho's economic development through investments in PAGE 6 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I the infrastructure required to safely and reliably meet growth in customer demand, as well 2 as addressing inflationary pressures. 3 As described more fully in the testimony of Tammy Nygard, Intermountain is 4 requesting a 10.8 percent return on common equity and a proposed capital structure 5 comprised of 50 percent debt and 50 percent equity. On May 9, 2025, the Company filed 6 an application for authorization to issue $50 million in long-term debt between July and 7 October of 2025 (see Case No. INT-G-25-03). Intermountain has included the projected 8 debt issuance in the development of the proposed capital structure. This results in an 9 overall rate of return request of 7.86 percent. 10 Q. What is the test year in this case? 11 A. Intermountain is proposing a 2024 historical test year in this proceeding. The Company is 12 also proposing pro forma adjustments for the 2025 calendar year for items that will be 13 known and measurable when rates go into effect on January 1, 2026. 14 Q. What are the primary drivers behind the Company's need for a base rate increase? 15 A. The primary factors driving the increase in the Company's revenue requirement are 16 increases in net plant investments, and the resulting increase in depreciation expense, as 17 well as increases in operations and maintenance expenses ("O&M"). In addition, an 18 increase in rates is necessary to attract sufficient capital dollars from investors, which will 19 be used to maintain service to customers, provide adequate operating and maintenance 20 coverage, and maintain a sound financial position. Intermountain's realized rate of return 21 ("ROR") of 4.45 percent at December 31, 2024 is well below the Company's current 22 authorized ROR of 6.97 percent. It is also below the 7.86 percent ROR recommended in 23 this case that would enable the Company to maintain its financial integrity and therefore its PAGE 7 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I ability to attract capital at reasonable rates under a variety of economic and financial 2 market conditions. 3 Q. Why are the Company's investments in plant increasing? 4 A. As seen in the chart below, the years since 2017 have been a time of significant growth 5 across the Company's service territory. Intermountain has seen sustained average customer 6 growth of 3 percent over the eight-year period, which resulted in the addition of just over 7 75,000 new customers. Intermountain Gas Company Customer Growth 2017-2024 440,000 420,000 400,000 380,000 360,000 340,000 320,000 300,000 2017 2018 2019 2020 2021 2022 2023 2024 g 9 Although the Company's line extension policy ensures that growth is paying for itself, the 10 growth also requires investments in backbone infrastructure to ensure Intermountain can continue 11 to provide reliable service to all customers. In today's world, a safe and reliable natural gas 12 distribution system also requires important investments in cybersecurity and other software 13 systems. All this activity has grown the Company's rate base from $385.3 million as filed in its PAGE 8 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I last rate proceeding filed in 2022 to $578.5 million in this proceeding. Most of the rate base 2 growth is related to net plant in service which has grown by approximately $193.7 million, with 3 the majority of the increase related to natural gas transmission and distribution mains, service 4 lines, meters, and compressor stations. 5 Q. How has this growth in plant in service impacted depreciation? 6 A. The substantial increase in plant investments, over$190 million in total, results in a nearly 7 $9 million increase in depreciation expense. As the value of plant grows, the calculated 8 depreciation expense also increases, reflecting the cost allocation of these assets over their 9 useful life. In the Company's last general rate case, an important mitigating factor in the 10 rate increase was a decrease in depreciation rates effective January 1, 2021. In the 11 Settlement approved in Case No. INT-G-21-01, the parties agreed to a decrease in 12 depreciation and amortization rates of approximately $3.8 million from the previously 13 approved rates. Order No. 35134, which approved the Settlement, allowed Intermountain 14 to begin using the lower rates effective January 1, 2021. This decrease in expense allowed 15 Intermountain to continue to earn a return near its allowed rate of return in 2021. However, 16 Order No. 35134 also required Intermountain to begin deferring the depreciation and 17 amortization reduction beginning July 1, 2023. As a result, the Company filed Case No. 18 INT-G-22-07 to embed the decrease in depreciation rates in its base rates. The continued 19 pace of substantial increase in plant investments, however, means that the increases in 20 depreciation expense are again putting downward pressure on the Company's returns. PAGE 9 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I Q. Is the Company experiencing upward cost pressures on its Operations and 2 Maintenance expenses? 3 A. Unfortunately, the economy-wide inflation is impacting customers and the Company alike. 4 O&M costs have increased by approximately $6.1 million, from $57.7 million in the last 5 rate filing to $63.8 million in this filing. The $6.1 million in increased O&M costs reflects 6 an annual average increase of 5.3%per year since the last case was filed. The increase in 7 O&M expense is due primarily to increases in labor and benefit costs. 8 Q. Please provide an overview of the Company's efforts to maintain a safe and reliable 9 system through a high-quality, skilled workforce. 10 A. The "E" in the Company's new CORE strategy prioritizes an employee-driven culture, 11 with a goal to maintain an employer of choice work culture and competitive total 12 compensation package. Despite the challenges posed by the current labor market, 13 Intermountain remains committed to providing high-quality, safe, and reliable service to its 14 customers. A skilled workforce is critical to achieving this commitment. Like many other 15 organizations across the country, Intermountain has struggled to recruit, train, and retain 16 personnel in this competitive job market. The Company has successfully implemented 17 various programs to attract and retain highly skilled employees, investing significantly in 18 their training and development. The costs associated with these efforts are considered the 19 minimum necessary to maintain a highly qualified workforce capable of providing a safe 20 and reliable natural gas system. 21 Intermountain employs a Total Rewards Philosophy designed to minimize costs 22 while attracting and retaining qualified employees. This approach includes competitive 23 wages, a retirement plan, and an employee incentive compensation plan. The Company has PAGE 10 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I also increased its use of sign-on bonuses and up-front vacation banks to recruit new 2 employees and enhanced the Company 401(k)plan match from a maximum contribution 3 of three percent of salary to four percent of salary. Ultimately, the CORE strategy aims to 4 attract and retain a superior workforce, foster collaboration and respect, and utilize 5 improved employee engagement to motivate higher levels of performance, leading to 6 exceptional service for customers. 7 Q. Please discuss Intermountain's focus on managing costs. 8 A. Intermountain's CORE strategy includes a focus on Operational Excellence. A responsible 9 approach to operating costs and a proactive approach to safety are critical elements in this 10 focus on keeping costs low. Intermountain has a long history of mitigating increasing cost 11 pressures to keep customer base rates low. Prior to the 2016 general rate case, 12 Intermountain had not filed for an increase in base rates since 1985. Since the acquisition 13 of Intermountain by MDU Resources, the Company has been part of a One Vision, One 14 Utility process that has resulted in synergistic savings in the form of joint senior 15 management, a unified customer service center,joint billing and payment processing, 16 uniform accounting systems, combined engineering support, and shared information 17 technology resources. 18 In the two years since the Company's last general rate case, Intermountain has 19 implemented a cost review initiative to help mitigate the impact of economy-wide 20 inflationary pressures. The Utilities Group Officer Team drives the initiative. All 21 departments in the Company were tasked with reviewing existing processes to uncover 22 opportunities for increased efficiencies, to find opportunities to minimize O&M increases 23 and to potentially discover opportunities for cost savings. PAGE 11 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I Company-wide, a manager must make a business case for any job opening before 2 the position is allowed to be filled. This has resulted in reorganizing work in some cases, 3 restructuring teams, and utilizing technology solutions where they make sense. Other 4 process reviews that have resulted in cost savings include an analysis of telephone and cell 5 phone costs, a review of vehicles for underutilization, a review to determine whether the 6 Company has excess equipment, a review and assessment of materials and outside services 7 for potential efficiencies and savings, and a review of facilities to determine the efficiency 8 of building use. The building review resulted in consolidating the Customer Experience 9 Team into an existing facility that was underutilized, which allowed for the sale of the 10 Meridian, Idaho building that had been used by the Customer Experience Team. The sale 11 of the building provided a rate base benefit to customers as well as a reduction in ongoing 12 operations and maintenance expense that is embedded in the test year of this case. 13 Q. Why do you believe the increase requested in this case is necessary? 14 A. It is essential to ensure fair and timely recovery of prudently incurred expenses and a 15 reasonable return on investment,which current rates do not sufficiently provide. The 16 increase will allow the company to operate efficiently and meet its financial obligations. 17 The rapid growth and system upgrades necessary for safety and reliability necessitate 18 substantial capital investments. These investments are fundamental to enhancing 19 Intermountain's capacity to offer safe and reliable service to both existing customers and 20 those seeking natural gas services. Significant capital investments require access to debt 21 and equity markets to secure funding,which is vital for the financing needed for 22 infrastructure and operational improvements. Timely and equitable recovery of the 23 Company's prudently incurred expenses and investments is crucial for attracting these PAGE 12 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I capital investments and managing financing costs. This ultimately benefits customers by 2 ensuring the continued provision of safe and reliable natural gas services while effectively 3 managing financial expenditures. 4 Q. Has the Company historically earned its authorized rate of return? 5 A. In recent years, Intermountain has struggled to earn its authorized rate of return. As the 6 following chart illustrates, the Company's return on equity("ROE")was on a downward 7 trajectory and well below its authorized ROE of 9.5 percent prior to the implementation of 8 a significant reduction in depreciation rates in January 2021. Although that reduction 9 stabilized rates for a short time, the growth in rate base described earlier continues to 10 drastically erode the Company's return. As the chart below illustrates, because of 11 regulatory lag, even the rates from the Company's last general rate case that went into 12 effect in July 2023 did not provide much help in slowing the erosion in ROE. Intermountain Gas Company Actual Return on Equity 12.00% • 600.0 1 10.00% ' 500.0 LA + 8.00% 400.0 '0 c — v a 6.00% 300.0 W ■ Ln 4.00% 200.0 v a 2.00% 100.0 0.00% 0.0 Jan 19 Jan 20 Jan 21 Jan 22 Jan 23 Jan 24 Jan 25 Ratebase ROE 13 PAGE 13 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I Q. Does chronic underearning impact Intermountain's customers? 2 A. Utilities require ready access to capital markets. The capital-intensive nature of 3 Intermountain's business necessitates the ability to obtain funding from the financial 4 markets under reasonable terms at regular intervals. To have this ability, investors need to 5 understand the risks related to any of their investments. To help investors assess the 6 creditworthiness of a company, ratings are assigned to companies based on their financial 7 performance and certain metrics. Although Intermountain is not rated by credit rating 8 agencies like S&P or Fitch, they are assigned an NAIC-2 rating by the National 9 Association of Insurance Commissioners ("NAIC.") These ratings indicate the 10 creditworthiness of a company which assists investors in determining if they want to invest 11 in a company and also shows the comparative level of risk compared to other investment 12 choices. The ratings can also affect the type of investor who will be interested in 13 purchasing the debt. Investment risks include, but are not limited to, liquidity risk, market 14 risk, operational risk, regulatory risk, and credit risk. Maintaining a strong rating is 15 important for the Company in order to access debt at reasonable rates. If Intermountain's 16 ratings were to fall, it would cause additional harm to the risk perception of the Company 17 in debt markets. The Company's borrowing costs would increase substantially. A 18 downgrade would immediately raise the cost of short-term borrowing and would also 19 increase the cost for future long-term borrowings. Intermountain often requires significant 20 amounts of short-term debt to fund its yearly operations including, importantly, gas costs. 21 The interest costs related to carrying the gas cost deferral balances are passed on directly to 22 customers. As illustrated in this case, Intermountain also requires significant amounts of 23 both debt and equity to fund its rapidly growing infrastructure requirements. The costs of PAGE 14 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I this long-term debt are also passed on to customers through general rate cases. It is 2 therefore critical that Intermountain maintain a rating that allows the Company to access 3 debt at reasonable rates on behalf of its customers. 4 A downgrade would also negatively impact MDU Resources' stock price, 5 decreasing the value the Company would receive for issuances in the equity markets. 6 Financial performance is the driver for credit rating upgrades/downgrades, so strong 7 financial performance of the company is imperative in ensuring access to capital markets at 8 acceptable rates. 9 Q. Is the Company proposing steps to mitigate regulatory lag in this case? 10 A. Yes. First, the Company is requesting approval of 2024 rate base on an end of period 11 ("EOP")basis. To account for the proposed EOP rate base treatment, the Company is also 12 proposing to adjust annual depreciation to match EOP rate base and to include EOP 13 customers and associated revenues. Second, the Company is requesting pro forma 2025 14 plant additions (including related adjustments to expenses and rate base) that will be in 15 service and used and useful by the time the Company's rates go into effect on January 1, 16 2026. Further, Intermountain proposes to include a pro forma wage adjustment that 17 recognizes the salary increases that will be effective during 2025, an adjustment for the 18 increased Company match in 401(k) that became effective on January 1, 2025, as well as 19 an adjustment for insurance premium increases based on premiums paid through March 20 2025 plus expected policy renewals. To offset the pro forma increases, the Company has 21 also included an adjustment that accounts for projected customer growth that is anticipated 22 to occur through the end of 2025. Taken together, the Company believes these steps will PAGE 15 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I help to reduce the regulatory lag it is experiencing and ease some of the financial market 2 risk that could impact the Company's debt rates going forward. 3 Q. What are the average residential and commercial customer bill impacts and percent 4 increases resulting from the proposed rate changes? 5 A. Table 1 shows the bill impact of the proposed rate increase for the Company's residential 6 and commercial customers. 7 Table 1 -Bill Impacts Current Bill Proposed Bill Difference ($) Difference (%) Residential $40.88 $45.57 $4.69 11.46% Commercial $179.35 $188.61 $9.26 5.16% 8 9 The information in Table I is also available in Exhibit 38,provided with the direct 10 testimony of Ronald J. Amen. 11 Q. Please provide a high-level summary of the Company's rate design proposals. 12 A. Intermountain's proposed rate design is a meaningful step toward cost-based rates, moving 13 towards parity among the classes of service by utilizing the Company's Cost of Service 14 Study ("COSS"). Based on the results of the COSS, Intermountain is also proposing to 15 increase customer charges for all customer classes. Specifically for the residential customer 16 class, the Company proposes to increase the customer charge over a two-year period, 17 achieving a cost-based charge and also aligning more closely with the customer charge 18 currently approved for other Idaho utilities. PAGE 16 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY OTHER COMPANY WITNESSES 1 Q. Please introduce and provide a brief description of each of the witnesses filing 2 testimony on behalf of Intermountain in this proceeding? 3 A. The following additional witnesses are presenting direct testimony on behalf of 4 Intermountain: 5 TammyNy_gard, Controller, reviews the Company's capital structure and addresses 6 the Company's cost of debt and the overall rate of return as well as providing support for 7 certain pro forma capital expenditures. 8 Ann Bulkley, Principal at The Brattle Group, presents evidence and provides a 9 recommendation regarding the appropriate return on equity for the Company and assesses 10 the reasonableness of its proposed capital structure for ratemaking purposes. 11 Niki Ogami, Manager of Accounting and Finance, presents information regarding 12 the Company's cost allocation methodology. 13 Lori Blattner, Director of Regulatory Affairs, discusses items the Company agreed 14 to address as part of the previous general rate case, explains the Company's capital 15 budgeting process, summarizes the requested additions to plant in service in this case, 16 outlines the Company's proposals to mitigate the impacts of regulatory lag, and discusses 17 the Company's proposal related to the treatment of property taxes. 18 Patrick Darras, Vice President—Engineering, Operations Services & Compliance, 19 supports the Company's major capital system investments since the last rate case,pro 20 forma investments for 2025, and he discusses the Company's public awareness and 21 damage prevention efforts. PAGE 17 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY I Eric Martuscelli, Vice President—Field Operations & Customer Service, discusses 2 Intermountain's commitment to exceptional customer service, and supports capital 3 investments related to growth installation and replacement projects since the last rate case 4 as well as pro forma investments in 2025. 5 Roxanne Roerick, Director of Human Resources, discusses the Company's Total 6 Rewards Philosophy for retaining a high quality, well-trained workforce, increases in 7 wages and benefits, and the Company's proposed wage adjustments. 8 Min Park, Regulatory Analyst,presents and discusses the results of the weather 9 normalization study Intermountain performed for this rate case. 10 Jacob Darrington, Manager of Regulatory Affairs, discusses the Company's 11 proposed revenue requirement and supporting calculations. 12 Ronald Amen, Atrium, presents the Company's load study, cost of service study, 13 proposed changes to Intermountain's rate design, and resulting customer bill impacts. 14 Zachary Harris, Manager of Regulatory Affairs, presents an update on the 15 Company's fixed network deployment, provides support of Intermountain's rate design 16 proposals, and presents proposed changes to Intermountain's tariff structure. CONCLUDING REMARKS 17 Q. Does this conclude your testimony? 18 A. Yes. PAGE 18 OF 18 N.KIVISTO,DI INTERMOUNTAIN GAS COMPANY