20250530Direct Roerick.pdf

RECEIVED
May 30, 2025
IDAHO PUBLIC
Preston N. Carter, ISB No. 8462 UTILITIES COMMISSION
Megann E. Meier, ISB No. 11948
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
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 ROXANNE ROERICK
INTERMOUNTAIN GAS COMPANY
MAY 30,2025

INTRODUCTION
1 Q. Please state your name and business address.
2 A. Roxanne Roerick, 1200 West Century Avenue, Bismarck, North Dakota.
3 Q. What is your occupation?
4 A. I am employed by MDU Resources Group, Inc. ("MDU Resources"), as the Director of
5 Human Resources.
6 Q. What are the responsibilities of your position?
7 A. My primary responsibilities include leading and administering the company's
8 compensation philosophy, the active and retiree health and welfare benefit plans, 401(k)
9 Retirement Plan and company pension plans.
STATEMENT OF QUALIFICATIONS
10 Q. Please describe your educational background and other qualifications.
1 1 A. I graduated from Minnesota State University Moorhead in 1999 with a Bachelor's degree
12 in Business Administration. I have been a certified Human Resources Professional by the
13 Society of Human Resources Management since 2014, as well as a Professional in Human
14 Resources by Human Resources Certification Institute.
15 Q. Please describe your work experience.
16 A. I have worked in the Human Resources field for 25 years and have held a variety of
17 positions of increasing responsibility since joining MDU Resources in 2009. I began my
18 career at MDU Resources as a benefits analyst leading the administration and operation of
19 the corporate benefit programs and legal compliance. In 2013 I was promoted to HR
20 Generalist with Montana-Dakota Utilities Co. My primary responsibilities focused on the
21 compensation philosophy, recruitment and retention and the benefits programs. In 2017, I
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I was promoted to Sr. Compensation Analyst for MDU Resources. During this time, I
2 implemented and administered the total rewards strategies and programs for the company,
3 including designing and administering the components of the compensation program. In
4 2019, I rejoined Montana Dakota Utilities Co. as Manager of Human Resources. My focus
5 was on compensation and benefits, talent acquisition and development, employee relations,
6 as well as compliance with employment and employee relations laws. In 2022 I was
7 promoted to my current position as Human Resources Director at MDU Resources.
PURPOSE OF TESTIMONY
8 Q. Please summarize your testimony.
9 A. My testimony will cover many aspects of how the Human Resources Department ensures
10 that Intermountain Gas Company ("Intermountain" or"Company") maintains an excellent
11 workforce. I will describe the current labor market in Idaho and how MDU Resources
12 addresses recruitment, retention and engagement challenges. I will also address how MDU
13 Resources, the MDU Utilities Group and Intermountain are controlling costs and managing
14 open positions while maintaining safe and reliable service for customers. Next, I will
15 share MDU Resources' compensation philosophy and how it effectively utilizes a
16 combination of base pay and at-risk pay to attract, retain, and engage employees, thus
17 providing safe and reliable service that is also affordable for customers. Finally, I will
18 describe the benefit plans provided to employees and how they effectively attract, retain
19 and engage employees.
20 Q. Are you sponsoring any exhibits to your direct testimony?
21 A. No.
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I Q. Has the current labor market impacted the Company's goal to hire qualified
2 employees?
3 A. Yes, the current labor market has made it more challenging for the Company to hire
4 qualified employees. Intermountain provides an essential service to its customers and must
5 maintain high-quality, safe, and reliable service regardless of the economics existing in the
6 industry or labor market. Intermountain has reinforced its goal to attract and retain highly
7 skilled employees despite current and recent economic conditions and continues to
8 significantly invest in employees' training and development. The costs associated with
9 recruiting and retention submitted in this proceeding are the minimum amount necessary to
10 maintain a highly qualified workforce that can provide a safe and reliable gas system.
I I Q. How does the Company manage open positions caused by employee turnover in an
12 effort to keep costs low?
13 A. When an employee's resignation or retirement results in an open position, the first step is
14 for local leadership to assess whether the work done by that position could be permanently
15 transferred to other positions within the organization, whether because of technological
16 advancements or other factors. If the answer is "yes", then the position will not be
17 backfilled. If the answer is "no", then local leadership will work with senior leadership
18 and human resources to backfill the role. If the answer is "maybe" or"temporarily", then
19 the position will be held for up to six months to determine if long-term needs require the
20 position to be backfilled.
21 Q. How is the Company ensuring that it attracts and retains qualified employees and
22 encourages employee engagement?
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I A. As discussed in the testimony of Nicole Kivisto, in 2025 the Company introduced the
2 CORE strategy, which is central to guiding business priorities and culture. As part of this
3 strategy, a new short-term incentive plan was implemented with metrics directly aligned to
4 CORE goals. The "E" in CORE stands for"Employee Driven,"reflecting the Company's
5 commitment to be an employer of choice. This includes fostering a workplace culture
6 defined by collaboration, creativity, respect and strong employee engagement.
7 To meet this goal, the Company has enhanced its total compensation offerings,
8 including expanded use of sign-on bonuses, up-front vacation banks to recruit new
9 employees, and increased Company 401(k)plan match from a maximum contribution of
10 three percent of salary to four percent of salary. Ongoing research into employee
11 preferences ensures that compensation and benefits programs continue to evolve with
12 workplace needs. These initiatives are not only competitive but also strategic, as they are
13 designed to attract and retain top talent while promoting engagement and performance—all
14 in alignment with the CORE strategy.
15 Q. Please explain the Company's CORE strategy.
16 A. The CORE Strategy is designed to deliver sustained value to customers through four focus
17 areas—Customers and Communities, Operational Excellence, Returns Focused, and
18 Employee Driven. Each element works together to ensure the Company provides safe,
19 reliable and affordable service.
20 For customers, this means a continued emphasis on delivering best-in-class
21 customer satisfaction, maintaining rates below the national average, and supporting the
22 vitality of local communities. The CORE Strategy also prioritizes safety—for both
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I employees and systems—and reinforces operational efficiency by keeping operations and
2 maintenance costs below peer utility averages.
3 A key driver of CORE's success is the "Employee Driven" component, which
4 underscores the importance of attracting, retaining, and developing a high-performing
5 workforce. By investing in employees through compensation, benefits, and development
6 opportunities, the Company increases engagement and performance—directly contributing
7 to service quality and reliability.
8 Ultimately, the CORE Strategy supports a cycle of continuous improvement that
9 benefits customers, employees, and the communities the Company serves.
10 Q. Please describe the Total Rewards philosophy and general approach to managing
11 total compensation for employees.
12 A. The Company's approach to employee compensation is designed to minimize costs while
13 allowing it to attract and retain the qualified employees necessary to deliver safe and
14 reliable service to its customers. To do this, the Company applies three basic principles:
15 First, the Company has adopted a Total Rewards philosophy, which provides
16 employees with a Total Rewards package. The Total Rewards package includes both total
17 cash compensation and benefits. The two key components of total cash compensation are
18 base pay and incentive compensation.
19 Second, the Company compares its base pay and at-risk incentive compensation
20 with the relevant labor market and seeks to set total cash compensation at the market
21 average for comparable jobs. As previously mentioned, the market for employees with the
22 skills and experience required is very competitive in the industry, and therefore
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I Intermountain must provide the same general total cash compensation and benefits as are
2 included in the packages provided by the Company's competitors for labor.
3 Third, the Company believes that a certain percentage of each employee's market
4 compensation should be "at-risk"to encourage employee engagement and reward
5 employees for their role in effectively operating the business. Accordingly, employees
6 have the opportunity to receive total cash compensation at the market average under the
7 MDU Utilities Group incentive plan. However, that program is structured such that total
8 compensation for all employees is aligned with the market average in a typical year.
9 Q. Please explain how the market average for the base pay and pay-at-risk components
10 of total cash compensation is determined.
11 A. The Company researches and obtains industry salary data when market pricing individual
12 positions. This data comes from many sources, including the American Gas Association,
13 Mercer, World at Work, Willis Towers Watson, and Kenexa Compensation Analyst,
14 among others. Specifically, the Company analyzes the median base pay and target
15 incentive compensation from these sources to determine an appropriate market wage.
16 Q. How are non-bargained employee annual base pay increases determined?
17 A. The Company allocates a share of its annual salary budget for merit-based compensation
18 increases. Managers and supervisors are provided guidelines by Human Resources for
19 how to allocate individual employee salary increases, taking into consideration
20 performance appraisals, pay equity, retention concerns and other factors. In the second
21 quarter each year, the Company reviews available external salary budget surveys and
22 resources to project the salary budget for the following year. The Company also reviews
23 internal needs and historical data when information is limited early in the year. In the third
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I quarter each year, the Company finalizes the salary increase budget by reviewing the
2 external survey data for any updates or changes from the second quarter. The Company's
3 Chief Human Resources, Administration & Safety Officer publishes guidelines for the
4 Utility Group to follow in allocating the following year's pay increases for non-bargained
5 employees. Managers and supervisors are responsible for allocating this budget in
6 accordance with the guidelines.
7 Q. How does the Company ensure it is not paying or incentivizing more than necessary
8 to attract and retain a qualified workforce?
9 A. In addition to the internal market review described above, approximately once every five
10 years the Company retains an outside, independent consultant to review its compensation
11 practices and programs. In 2022 the Company engaged Mercer to conduct a robust
12 competitive market study on multiple aspects of the Company's compensation program.
13 This outside review assures that reasonable and appropriate compensation packages are
14 being implemented to attract and retain quality employees, who in turn allow the Company
15 to continue providing safe and reliable service to its customers.
16 The Company's pay philosophy is to pay employees at the 50th percentile of the
17 identified salary grade for base salary and total cash compensation,but Mercer's study
18 found the Company was positioned between the 25th and 50th percentiles. Thus, a new pay
19 structure was identified where warranted.
20 Mercer also found that the Company's pay levels under this new structure were
21 within a competitive market range of+/- 10% for base salary and+/- 15% for total cash
22 compensation.
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I The Company analyzed options to position a more favorable compensation package
2 for current and potential employees, as the talent market continues to be very competitive,
3 and extremely competitive for certain positions. Options now being utilized to
4 successfully recruit new employees include frontloading vacation time for new hires as
5 well as utilizing sign-on bonuses and relocation assistance. Incentives that help attract new
6 employees as well as retain current employees include changes to the Company's 401(k)
7 plan match that increase the amount of funds contributed to employees' retirement
8 accounts, the addition of a new paid holiday (MLK Day) in 2024, and the restructuring of
9 the Company incentive plan program to align more closely with employee contributions to
10 the Company's success.
11 Q. How was Intermountain's 2025 and 2026 non-bargained employee compensation
12 determined?
13 A. In the second quarter of each year, the Company creates a budget for non-bargained
14 employee pay increases. MDUR's Chief Human Resources, Administration& Safety
15 Officer provides a recommendation for the subsequent calendar year, subject to approval
16 by the MDUR President and CEO. This salary budget recommendation considers
17 competitive pay, economics, and industry-specific salary budget projections. The
18 recommendation is presented as an all-inclusive percentage that includes merit increases
19 for performance, equity and competitive pay adjustments, and promotions.
20 In October of 2024, the Chief Human Resources, Administration& Safety Officer
21 published guidelines for the Company's officers to follow in allocating 2025 pay increases
22 for non-bargained employees. The guidelines provided managers a 4.5 percent merit-
23 based wage increase budget plus an additional 0.5 percent to be used during 2025 to
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I address pay equity, wage compression, and promotions through a mid-year salary increase
2 process. The Chief Utilities Officer approved 2025 salary recommendations submitted by
3 officers for non-bargained employees effective on December 16, 2024, which resulted in a
4 total increase of approximately 4.3 percent.
5 At this point, limited information is available about the energy industry's labor
6 market for 2026, however based on an internal review and historical data, the Company
7 estimates an increase to base wages for its non-bargained workforce of approximately 5
8 percent. This increase will be effective in December of 2025, which is before the rate
9 effective date of this case.
10 Q. Please explain the rationale for bargained employee compensation.
11 A. There are currently three separate groups of bargained employees at Intermountain, and
12 although each group is represented by the Plumbers and Pipefitters Union ("Union"), each
13 group entered into a separate collective bargaining agreement between Intermountain and
14 the Union. Hourly pay rates and total compensation make up one portion of each
15 collective bargaining agreement ("CBA"). The current CBAs for each group have been
16 effective since April 18, 2023,November 18, 2024, and February 24, 2025. The annual
17 wage increases for each group is as follows:
Bargained
Group 2024 Wage Increase 2025 Wage Increase 2026 Wage Increase
District 0% 6.23% 4%
Assistants
District
Operations 0% 8% 4%
Coordinators
Field
Operations 3.5% 3% 3%
Employees
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I While annual wage increases are normally within the range of 3%to 4%, the cost
2 of labor has increased slightly in recent years for individuals with the skills utilized in
3 bargained roles.
4 Q. Does Intermountain propose inclusion of allocated wage increases from affiliate
5 companies to Intermountain's overall wage expense?
6 A. Yes. Since 2018, the Company has been consolidating functions within its utility
7 companies to become more efficient at providing safe, reliable and cost-effective service to
8 customers. This consolidation resulted in many positions transferring from
9 Intermountain's headcount to an affiliate's headcount. A percentage of these positions
10 continue to service Intermountain's business either directly or indirectly through activities
11 that simultaneously benefit Intermountain and the other utilities.
12 Q. Has the consolidation of operation functions with affiliate companies resulted in a
13 decrease in headcount at Intermountain?
14 A. No. The headcount at Intermountain has remained relatively consistent over the last five to
15 ten years even though some roles were transferred from Intermountain's headcount to an
16 affiliate's headcount. The reason for this consistency is that a number of roles have been
17 added to Intermountain's headcount that didn't exist ten years ago. Examples of these new
18 roles include field positions to service areas with significant customer growth,
19 environmental positions, and positions to ensure regulatory compliance and pipeline
20 safety.
21 Q. Why is allocation of affiliate wage increases to Intermountain appropriate?
22 A. Wage increases at Intermountain's affiliates follow the same total rewards philosophy as
23 Intermountain, and wages for Intermountain and its affiliates are determined in the same
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1 manner. Wage increases for employees at affiliates of Intermountain who have a portion
2 of their time allocated to Intermountain increase the total cost of said time that is allocated
3 to Intermountain. As such it is appropriate to allocate a percentage of those increased costs
4 to Intermountain.
5 Q. Did Intermountain's affiliates experience labor market price increases?
6 A. Yes. MDU Resources and the MDU Utilities Group companies have experienced labor
7 market increases across the service territory since 2022 due to the same competitive market
8 conditions previously discussed.
9 Q. Please describe Intermountain's medical plan benefits provided to its employees.
10 A. All MDU Utilities Group companies and MDU Resources utilize the same medical plan
11 package. This package includes a health savings account ("HSA") coupled with a choice
12 of two high-deductible medical plans, a Company contribution to employees' HSA
13 accounts, dental insurance, vision insurance, supplemental life and AD&D insurance,
14 flexible spending plans, and more.
15 All MDU Utilities Group companies and MDU Resources pay the same percentage
16 of the premium for their employees' medical, dental, and vision insurance premiums, and
17 provide their employees with the same contributions to the employees' HSA accounts.
18 Q. Have the medical plan benefits changed since 2022?
19 A. The benefits offered and their structure has not changed. However, medical plan
20 premiums have increased for both employees and the Company since 2022. The reasons
21 for the cost increases include increased cost of medical services, the introduction of new
22 specialty prescription drugs, and variations in utilization of the plans.
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I The Company has successfully implemented various programs to slow these cost
2 increases, including enacting options for video doctor and therapist visits, on-demand on-
3 line therapy options, a program to help employees prevent diabetes and heart disease, and a
4 program for employees with sudden and severe medical conditions to assist them with
5 finding specialists, second opinions and alternative treatment options. The Company has
6 also slowly begun to shift a larger percentage of the increases in the cost of the medical
7 program to employees; for example, in 2023 employees paid approximately 8 percent of
8 the total premium for medical coverage and in 2024 and 2025 they pay approximately 9
9 percent of the total premium.
10 Q. Please describe Intermountain's retirement plan benefits for its employees.
11 A. All Utility Group companies utilize the same retirement plan package for their non-
12 bargained employees. This package includes a 401(k)plan with employer match equal to
13 100% of an employee's salary deferrals with the maximum match being 4 percent of an
14 employee's salary. Additionally, non-bargained employees receive an annual contribution
15 to their 401(k) accounts equal to 5 percent of their salary.
16 Some bargained employees at Intermountain do not receive an employer match to
17 their 401(k) accounts. However, those specific employees do receive monthly
18 contributions to a multi-employer pension plan associated with their local union. These
19 monthly contributions have been increasing based on the total number of employee hours
20 worked per month and the contribution rate negotiated between Intermountain and the
21 union. The current contribution rate is $4.97 per labor hour for those employees.
22 Q. Has the retirement plan benefits changed since 2022?
23 A. Yes. The current 401(k) matching employer contribution was implemented in 2025.
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I Previously, the employer match equaled 50 percent of an employee's salary deferrals with
2 the maximum match being 3 percent of an employee's salary.
3 Q. Please summarize the Company's pro forma adjustment to the test year 401(k)
4 expense included in the revenue requirement of this case.
5 A. The Company included a pro forma adjustment to capture the impact to 2025 expense of
6 the change in the 401(k) explained above. To calculate this adjustment the Company took
7 the difference between the previous 401(k)matching percentage applied to previous
8 employee salaries and the new matching 401(k)percentage applied to current employee
9 salaries for both direct and allocated employees. The pro forma increase in Intermountain's
10 401(k) cost totaled $236,105. The result of this adjustment is discussed in the direct
11 testimony of Jacob Darrington.
12 Q. Please describe the Company's short-term incentive pay plan for employees and
13 executives.
14 A. MDU Resources and the MDU Utilities Group companies utilize the same Short-Term
15 Employee Incentive Compensation Plan("Plan"). The Plan is available to all employees
16 who are classified as full-time or part-time employees and is structured to provide
17 incentive compensation to those employees with satisfactory performance. While the
18 metrics for all MDU Resources Group companies are combined for purposes of the
19 incentive, Intermountain's metrics are integral to the calculations.
20 The 2025 Plan is based on the CORE strategy discussed earlier in my testimony,
21 with each independent element of the Plan representing a section of the MDU Resources'
22 CORE Strategy. The "Customers and Community" element is based on the results
23 received by the Utility Group in the JD Power Gas Utility Customer Service Satisfaction
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I Study and is ten percent of the total available Plan payout. The "Operational Excellence"
2 element is also ten percent of the total available Plan payout and is measured by the
3 combined incident frequency rate of unplanned service outage events. The "Returns
4 Focused" element is the largest, consisting of seventy percent of the total available payout,
5 and is determined on MDU Resources reaching its target earnings from continuing
6 operations for 2025. Finally, the "Employee Driven" element constitutes ten percent of the
7 total available payout and is measured by the amount of reduction in preventable motor
8 vehicle/equipment incidents and how timely incidents are reported. If minimum Company
9 performance is achieved in each area, employees may earn between one and a half and
10 sixty percent of their annual salary under the Plan, depending on their pay grade and the
11 strength of Company performance of the various elements; executives may earn between
12 17.5 and 200 percent of their annual salary depending upon their pay grade and the
13 strength of Company performance.
14 Q. How do these incentive pay plans benefit Intermountain's customers?
15 A. The incentive pay plans, particularly as revised for 2025,provide benefits to Intermountain
16 customers in multiple ways. Most importantly, as described above, seventy percent of the
17 eligible incentive payout is based on MDU Resources' progress towards reaching its target
18 earnings from continuing operations. This element includes many sub-items such as
19 reduction of operations and maintenance costs and enhancement of employee engagement
20 and performance which are essential to maintaining a stable business operation that can
21 effectively provide safe, reliable and affordable service to its customers.
22 The remaining thirty percent of the eligible incentive payout is also connected to
23 goals that directly benefit customers. Ten percent of the eligible incentive payout is based
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I upon the Company's employees providing superior customer service, measured by the JD
2 Power annual company rankings. Another ten percent of the eligible incentive payout is
3 based wholly on the incident frequency rate of unplanned service outage events with a goal
4 to directly reduce the amount and duration of service interruptions to customers. The final
5 ten percent of eligible incentive payout is based on employees reducing the number of
6 preventable motor vehicle accidents, which benefits customers by improving the safety of
7 operations for customers and the public, as well as reducing the costs associated with
8 property damage and personal injuries.
9 Q. Please summarize the Company's adjustment to the test year incentive compensation
10 expense included in the revenue requirement of this case.
11 A. The Company calculated the incentive compensation expense amount associated with the
12 new plan based on 100 percent target payout percentages and current employee salaries.
13 The Company's incentive payout during the test year was greater than 100 percent,
14 therefore, the adjustment is a$583,107 reduction to test year expense. The result of this
15 adjustment is discussed in the direct testimony of Jacob Darrington.
16 Q. Does the Company account for potential offsetting costs as part of its budgeting
17 process for wage increases?
18 A. Intermountain's budgeting process for wage increases is a comprehensive process that
19 accounts for factors that both increase and decrease wage-related costs. For example,
20 managers are instructed to account for employees who are ineligible for pay increases
21 because they were recently hired, recently promoted, or received another type of wage
22 adjustment. Moreover, employees who receive a marginal or unacceptable performance
23 score on their annual reviews are ineligible for wage increases the following year. Finally,
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I salary recovery through attrition offsets the costs for wage adjustments.
2 Q. How does the Company's total cash compensation package benefit customers?
3 A. The Company's base compensation benefits customers by effectively meeting the need to
4 compensate employees fairly and competitively to assure the retention of a qualified
5 workforce to provide safe and reliable service to all its customers.
6 Additionally, the Company's incentive compensation plan benefits customers by
7 creating incentives for employees to focus on key objectives, including high-quality
8 customer service, the reduction of unplanned service outages, operational efficiency, and
9 reduction of preventable safety incidents. Using incentive compensation as a component
10 of total cash compensation also allows the Company to be competitive in the labor market
11 with lower fixed costs in the form of base pay. Finally, utilizing both base pay and
12 incentive compensation encourages employees to focus on the key metrics that benefit the
13 Company's customers.
14 Q. Please summarize the Company's proposed adjustments to the test year wages
15 included in the revenue requirement in this case.
16 A. The Company's proposed adjustments to test year wages include the following
17 components: (1) a normalizing adjustment for non-bargained employee wage increases
18 implemented in December 2024; (2) a normalizing adjustment for January 2025 executive
19 wage increases; (3) a normalizing adjustment for wage increases that occurred in 2024 for
20 bargained employees as provided in their collective bargaining agreements; (4) a pro forma
21 adjustment for estimated wage increases to be implemented for non-union employees in
22 December 2025; and(5) a pro forma adjustment for 2025 wage increases to take effect in
23 February 2025, March 2025, and November 2025 for various bargained employees as
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I outlined in their respective collective bargaining agreements. The resulting increase to
2 wages is $2,327,308 and is discussed in the direct testimony of Jacob Darrington.
CONCLUDING REMARKS
3 Q. Does this conclude your testimony?
4 A. Yes.
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