20250530Direct Darrington.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 JACOB DARRINGTON
INTERMOUNTAIN GAS COMPANY
MAY 30,2025

INTRODUCTION
1 Q. Please state your name and business address.
2 A. My name is Jacob Darrington and my business address is 555 South Cole Road, Boise,
3 Idaho 83709.
4 Q. What is your occupation?
5 A. I am Manager of Regulatory Affairs for Intermountain Gas Company ("Intermountain" or
6 "Company") and Cascade Natural Gas Corporation, which are indirect wholly owned
7 subsidiaries of MDU Resources Group, Inc. ("MDU Resources"). In this capacity, I am
8 primarily responsible for the purchased gas adjustment filings and the development of the
9 revenue requirement related to general rate case filings for the Idaho, Washington, and
10 Oregon jurisdictions.
11 Q. Please summarize your education and professional experience.
12 A. I graduated from Boise State University in May 2011 with a Bachelor of Arts Degree in
13 Accounting-Finance. In January 2012, I began work at Deloitte Tax as a Tax
14 Consultant. I obtained my CPA license in the summer of 2013 and continue to keep my
15 CPA license active in the state of Idaho. In April of 2015, I took a position with
16 Intermountain Gas Company as a Regulatory Analyst with primary responsibilities related
17 to the preparation and filing of the annual purchased gas cost adjustment("PGA") filing as
18 well as the development of revenue requirement related to general rate case filings. In July
19 of 2015, I attended the Regulatory Rate School in Chicago sponsored by the American Gas
20 Association. In 2019, I was promoted to Manager in the Intermountain Regulatory Affairs
21 department, and in 2022, 1 took on additional responsibilities for Cascade Natural Gas
22 Corporation's Washington and Oregon jurisdictions.
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Q. Please summarize your testimony.
2 A. My testimony will cover three main areas. First, I will present an overview of the
3 proposed revenue requirement in the current case including a high-level discussion of the
4 main drivers of the increase. Second, I will discuss the Company's proposed test year and
5 the unadjusted results of that test year. Third, I will discuss the Company's proposed
6 adjustments to the test year.
7 Q. Are you sponsoring any exhibits to your direct testimony?
8 A. Yes. I am sponsoring the following Exhibits which are described throughout my
9 testimony.
10 Exhibit 29 Deficiency in Operating Revenue
11 Exhibit 30 Statement of Operating Income and Rate Base with Adjustments
12 Exhibit 31 Summary of Adjustments
13 Exhibit 32 Adjustments to Gas Operating Revenues
14 Exhibit 33 Gross Revenue Conversion Factor
PROPOSED REVENUE REQUIREMENT
15 Q. Please explain Exhibit No. 29.
16 A. Exhibit No. 29 shows the calculation of the proposed deficiency in operating revenue.
17 Lines 1 and 2 show the operating income at present rates and rate base, respectively. Based
18 on that information, the Company is currently earning a rate of return of approximately
19 4.45 percent, as shown on Line 3. The cost of capital of 7.86 percent on Line 4 is discussed
20 in more detail in the direct testimony of Tammy Nygard. The operating income of
21 $45,467,985 at proposed rates on Line 5 is the product of the rate base multiplied by the
22 proposed cost of capital. Finally, the operating income deficiency is grossed up by the
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I gross revenue conversion factor of 1.34348 on Line 7 to determine the deficiency in
2 operating revenue (or revenue requirement) of$26,499,489.
3 Q. Please explain the gross revenue conversion factor.
4 A. The gross revenue conversion factor is based on revenue-sensitive items that change as
5 revenue changes, including uncollectibles expense, the Commission's regulatory fee, Idaho
6 state income taxes, and federal income taxes. The gross revenue conversion factor converts
7 the net operating income deficiency into the additional operating revenues the Company
8 needs to collect from customers in order to earn its authorized rate of return after
9 accounting for the revenue-sensitive items previously mentioned. The components of the
10 gross revenue conversion factor are shown on Exhibit No. 33.
11 Q. What are the main drivers of the proposed revenue requirement?
12 A. There are three main drivers of the revenue requirement in this case. First, the Company's
13 proposed rate base is approximately $193 million larger when compared to its last general
14 rate case. The majority of this growth is related to the Company's investment in net plant
15 with the biggest increases related to main lines, service lines, meters, and compressor
16 stations.
17 Second, the Company's proposed operations and maintenance ("O&M") expense is
18 approximately $6 million more when compared to its last general rate case with the
19 majority of the growth in O&M driven by employee labor and benefits.
20 Third, as would be expected based on the increase in rate base discussed above, the
21 Company's proposed depreciation expense is nearly $9 million more when compared to its
22 last general rate case.
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Q. How do proposed test year base rate revenues compare with the Company's previous
2 general rate case?
3 A. Proposed test year base rate revenues have grown by approximately $11 million when
4 compared to final base rate revenues in the Company's last general rate case. This growth
5 is attributable to customer growth and higher base rates which were implemented as a
6 result of the last general rate case. The growth in base rate revenues partially offsets the
7 growth in rate base, O&M, and depreciation expense discussed above and lowers the
8 revenue requirement that otherwise would result.
PROPOSED TEST YEAR AND UNADJUSTED TEST YEAR RESULTS
9 Q. What is the Company's proposed test year for this rate case proceeding?
10 A. The Company's proposed test year is the calendar year 2024 with several pro forma
11 adjustments for calendar year 2025 that will be known and measurable when rates go into
12 effect on January 1, 2026.
13 Q. What are the Company's unadjusted test year results?
14 A. The Company's unadjusted test year results are shown on Exhibit No. 30, Column (b). As
15 shown on the exhibit, the Company's unadjusted test year Net Operating Income is
16 $11,145,991. The Company's unadjusted test year Average Rate Base is $510,053,911.
REGULATORY ADJUSTMENTS TO THE TEST YEAR
17 Q. Please explain Exhibit No. 31.
18 A. Exhibit No. 31 provides a summary of all the adjustments made to test year operating
19 income and rate base. Each adjustment will be discussed in more detail below.
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Q. Please explain the adjustment to remove non-distribution revenues and expenses on
2 Exhibit No. 31, Column (b).
3 A. This adjustment removes all non-distribution revenues and expenses including franchise
4 taxes, cost of gas revenues and expenses (including non-gas items collected through the
5 Company's PGA), and energy efficiency revenues and expenses included in the
6 Company's test year. Cost of gas and energy efficiency are non-distribution items that are
7 part of the total rate charged to customers. However, these items do not belong in the
8 calculation of revenue requirement because they are evaluated and charged through
9 separate mechanisms. Franchise taxes are a non-distribution item that is charged to
10 customers. The Company is the collector and remitter of these taxes on behalf of
11 municipalities in Idaho and therefore these taxes should not be included in the calculation
12 of revenue requirement. Removing non-distribution revenues and expenses keeps the
13 revenue requirement calculation focused on distribution revenues and expenses.
14 This adjustment also removes unbilled revenues included in the Company's test
15 year. Unbilled revenues represent the difference in time between when gas is provided to
16 customers and when those customers are billed for the gas used. Unbilled revenues are
17 removed because the Company's weather normalization methodology is based on billed
18 consumption data, as discussed in the direct testimony of Min Park.
19 As shown on Exhibit No. 31, Column(b), Lines 3 and 26, this adjustment reduces
20 test year revenues and expense by $212,323,208 and $210,796,109, respectively.
21
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Q. Please explain the billing determinant recalculation adjustment proposed by the
2 Company on Exhibit No. 31, Column (c).
3 A. This adjustment sets distribution revenues equal to tariff rates multiplied by unadjusted
4 billing determinants. The adjustment is calculated on Exhibit No. 32, Columns (e)-(g).
5 This adjustment allows the Company to remove any billing adjustments in the Company's
6 financial records and reflect only the amount of revenues the Company would receive
7 based on its billing determinants and current tariff rates. The majority of the adjustment is
8 primarily due to the residential customer class. This adjustment reduces revenues by
9 $129,624, as shown on Exhibit No. 31, Column(c), Line 3 and Exhibit No. 32, Column
10 (g), Line 132.
11 Q. Please explain the rate class migration adjustment on Exhibit No. 31, Column (d).
12 A. This adjustment captures the revenue impact of customers migrating between general
13 service, large volume, and transport customer classes throughout the test year and through
14 March 2025. The Company removed these customers' volumes from their previous rate
15 class and included them for a full twelve-month period in the new rate class. The
16 adjustment is calculated on Exhibit No. 32, Columns (h)-(j) and increases revenues by
17 $51,227, as shown on Exhibit No. 31, Column (d), Line 3 and Exhibit No. 32, Column 0),
18 Line 132.
19 Q. Please explain the normalization adjustment proposed by the Company on Exhibit
20 No. 31, Column (e).
21 A. The weather normalization adjustment removes the impact of weather on gas usage for the
22 RS and GS-1 customer classes. The process for determining weather normalization is
23 addressed in the direct testimony of Min Park. The revenue impact of the weather
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I normalization adjustment is calculated on Exhibit No. 32, Columns (k)-(m) and increases
2 revenues by $3,370,096, as shown on Exhibit No. 31, Column (e), Line 3 and Exhibit No.
3 32, Column(m), Line 132.
4 Q. Please explain the adjustment to remove revenues and expenses associated with non-
5 utility LNG sales from the Company's Nampa facility proposed on Exhibit No. 31,
6 Column (f).
7 A. This adjustment eliminates revenues and cost of gas expenses included in the Company's
8 test year related to the sale of LNG from the Company's Nampa LNG facility. These
9 revenues and cost of gas expenses are not associated with the provision of regulated gas
10 services to Intermountain's customers. This adjustment reduces operating revenues and
11 cost of gas expenses by $2,839,131 and$2,053,964 as shown on Exhibit No. 31, Column
12 (f), Lines 3 and 5, respectively.
13 Q. Please explain the adjustment to remove other revenues and expenses proposed by
14 the Company on Exhibit No. 31, Column (g).
15 A. This adjustment removes non-utility revenues and expenses included in the Company's test
16 year. A portion of the adjustment is for the removal of revenues and expenses related to
17 providing renewable natural gas ("RNG")producers access to the Company's system in
18 accordance with the Company's RNG facilitation plan approved by the Commission in
19 Order No. 34693 in Case No. INT-G-20-03 and subsequently updated and approved in
20 Order No. 35891 in Case No. INT-G-23-03.
21 This adjustment also removes expenses associated with donations, civic,political,
22 and related activities, and other disallowed or non-utility activities. This adjustment
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I reduces revenues and expenses by $467,010 and $547,945 as shown on Exhibit No. 31,
2 Column(g), Lines 3 and 26, respectively.
3 Q. Please explain the adjustment to remove interest expense proposed by the Company
4 on Exhibit No. 31, Column (h).
5 A. This adjustment removes interest expense included in the Company's test year. Instead, the
6 impact of interest is captured through the application of the weighted average cost of
7 capital to rate base. Intermountain's weighted average cost of debt included in the
8 Company's cost of capital is discussed in more detail in the direct testimony of Tammy
9 Nygard. This adjustment reduces interest expense by$12,980,282 as shown on Exhibit No.
10 31, Column(h), Line 22.
11 Q. Please explain the adjustment to remove supplemental executive compensation
12 proposed by the Company on Exhibit No. 31, Column (i).
13 A. This adjustment removes all supplemental executive compensation expenses related to the
14 Supplemental Executive Retirement Plan, the Supplemental Income Security Plan,
15 Deferred Compensation, and the Long-Term Incentive Plan. Based on prior Commission
16 Orders, the Company has chosen not to charge its customers for these expenses and has
17 therefore removed them from the revenue requirement calculation. This adjustment
18 reduces expenses by $1,461,741 as shown on Exhibit No. 31, Column(i), Line 26.
19 Q. Please explain the rate case expense amortization adjustment proposed by the
20 Company on Exhibit No. 31, Column 0).
21 A. This adjustment increases test year expenses for the estimated costs associated with the
22 preparation, filing, and resolution of this rate case. The Company's estimate of rate case
23 costs is $309,140, which includes the work of consultants and legal counsel to help the
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Company prepare, file, and resolve this rate case. These rate case costs are in addition to
2 the rate case expense amortization included in the test year as agreed to in the settlement of
3 Case No. INT-G-22-07 and approved by the Commission in Order No. 35836
4 ("Settlement"). The Company proposes to amortize the additional $309,140 of rate case
5 costs over 3 years to align with the remaining amortization period of the rate case costs
6 previously approved. This adjustment increases expenses by $103,047 as shown on
7 Exhibit No. 31, Column 0), Line 26.
8 Q. Please explain the salary expense adjustment proposed by the Company on Exhibit
9 No. 31, Column (k).
10 A. The salary expense adjustment includes two components. The first component is a
11 normalization adjustment to normalize the increase in salaries and wages that became
12 effective at various points during calendar year 2024 and January 2025. This adjustment
13 normalizes the increases to reflect an increased expense for the entire test year. The second
14 component of the salary expense adjustment is a pro-forma adjustment to account for
15 salary or wage increases that will occur in 2025.
16 The adjustment for these salary and wage increases ensures the appropriate level of
17 expenses are included in the revenue requirement to allow recovery. Please see the direct
18 testimony of Roxanne Roerick for additional information regarding employee salaries and
19 increases. This adjustment increases expenses by $2,327,308, as shown on Exhibit No. 31,
20 Column(k), Line 26.
21 Q. Please explain the incentive compensation adjustment proposed by the Company on
22 Exhibit No. 31, Column (1).
23 A. The adjustment to incentive compensation expense reflects 100 percent target incentive
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INTERMOUNTAIN GAS COMPANY

I payouts to Company employees according to the Company's newly redesigned incentive
2 compensation plan. Please see the direct testimony of Roxanne Roerick regarding changes
3 to the Company's incentive compensation plan. The Company's payout during the test
4 year was greater than 100 percent, therefore, this adjustment is a reduction to test year
5 expense. This adjustment reduces expenses by $583,107 as shown on Exhibit No. 31,
6 Column(1), Line 26.
7 Q. Please explain the pro forma 401(k) expense adjustment proposed by the Company
8 on Exhibit No. 31, Column (m).
9 A. This adjustment shows the impact of the increase related to the change in the plan design
10 of the Company's 401(k)plan. As explained in the direct testimony of Roxanne Roerick,
11 the Company previously matched 50 percent of an employee's contribution to a 401(k)
12 account with the maximum match being 3 percent of an employee's salary. As of January
13 1, 2025, the Company began matching 100 percent of 4 percent of an employee's
14 contribution to a 401(k) account. This change only applies to non-union employees. This
15 adjustment increases expenses by $236,105 as shown on Exhibit No. 31, Column (m), Line
16 26.
17 Q. Please explain the property tax adjustment proposed by the Company on Exhibit No.
18 31, Column (n).
19 A. This adjustment removes test year property tax expense to comply with the State of
20 Idaho's House Bill 329 requiring utility companies to collect property tax expense as a
21 separate line item on customer's bills. As explained in the direct testimony of Lori
22 Blattner, the Company proposes to add a separate line item to the Company's tariff sheets
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I using the rates established in the House Bill 329. This adjustment reduces expenses by
2 $1,701,418 as shown on Exhibit No. 31, Column(n), Line 26.
3 Q. Please explain the pro forma insurance expense adjustment proposed by the
4 Company on Exhibit No. 31, Column (o).
5 A. This adjustment captures an increase in property and liability insurance expense over the
6 test year amount based on premiums paid through March 2025 plus expected policy
7 renewals to be paid in 2025. Insurance expense is calculated based on the amortization of
8 insurance premiums over the life of the policy. This adjustment increases expenses by
9 $517,310 as shown on Exhibit No. 31, Column(o), Line 26.
10 Q. Please explain the asset retirement obligation ("ARO") adjustment proposed by the
11 Company on Exhibit No. 31, Column (p).
12 A. This adjustment removes ARO from rate base and thereby avoids double charging
13 customers for the cost of removing tangible long-lived assets. The cost of removal is
14 already included in the Company's approved depreciation rates. This adjustment reduces
15 gross gas plant in service and accumulated depreciation and amortization by $36,878,662
16 and$6,195,204 as shown on Exhibit No. 31, Column(p), Lines 29 and 30, respectively,
17 Q. Please explain the retirement work in progress ("RWIP") adjustment proposed by
18 the Company on Exhibit No. 31, Column (q).
19 A. This adjustment removes the balance of RWIP which represents the work performed but
20 not yet completed to retire gas plant in service which is still used and useful at the end of
21 the month. This adjustment decreases the accumulated provision for depreciation and
22 amortization by $109,419 as shown on Exhibit No. 31, Column(q), Line 30.
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY

I Q. Please explain the adjustments to gas inventory proposed by the Company on Exhibit
2 No. 31, Columns (r) and (s).
3 A. The first adjustment removes the gas storage inventory balances associated with non-utility
4 LNG sales as these amounts are recovered through non-utility customers. The second
5 adjustment keeps the utility portion of the gas storage balance at the Nampa LNG facility
6 at 2 million gallons each month. As described in the Company's Integrated Resource Plan
7 (see Case No. INT-G-23-07), the Company seeks to keep 2 million gallons of LNG
8 available at the Nampa LNG facility to provide for boiloff gas, to maintain operational and
9 training requirements at the Nampa and Rexburg LNG facilities, and for permanent storage
10 to ensure that all LNG does not boil off. The first adjustment decreases gas storage
11 inventory by $414,271 and the second adjustment increases gas storage inventory by
12 $159,983 as shown on Exhibit No. 31, Columns (r) and(s), Line 33.
13 Q. Please explain the accumulated deferred income taxes ("ADIT") adjustment
14 proposed by the Company on Exhibit No. 31, Column (t).
15 A. This adjustment recalculates the ADIT related to gas storage inventory to capture the
16 deferred income tax impacts related to the adjustments to storage inventory discussed
17 above. The total amount of the adjustment is a decrease to ADIT of$111,539 as shown on
18 Exhibit No. 31, Column(t), Line 34.
19 Q. Please explain the end of period ("EOP") adjustment proposed by the Company on
20 Exhibit No. 31, Column (u).
21 A. This adjustment changes the Company's rate base from an Average of Monthly Averages
22 ("AMA")basis to an EOP basis. The appropriateness of, and support for, the Company's
23 request to use EOP rate base is discussed in the direct testimony of Lori Blattner. Annual
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INTERMOUNTAIN GAS COMPANY

I depreciation is also adjusted to match the EOP rate base by multiplying the EOP plant in
2 service by the depreciation rates approved in Order No. 35134 in Case No. INT-G-21-01.
3 The final component of this adjustment is to match the revenues with EOP rate base which
4 is accomplished by adjusting the Company's revenues using EOP customer counts and
5 therms. The therms were calculated by multiplying 2024 EOP customer counts by
6 adjusted test year usage per customer. The EOP adjustment was not calculated for the LV-
7 1, T-3, and T-4 rate classes because the same effect is achieved in the rate class migration
8 adjustment explained previously. The revenue impact of the EOP adjustment is calculated
9 on Exhibit No. 32, Columns (n)-(p) and increases revenues by $1,442,697, as shown on
10 Exhibit No. 31, Column(u), Line 3 and Exhibit No. 32, Column(p), Line 132. This
11 adjustment increases depreciation expense by $1,625,613 as shown on Exhibit No. 31,
12 Column(u), Line 16. Additionally, this adjustment increases all items of rate base by a
13 total of$32,061,929 as shown on Exhibit No. 31, Column(u), Line 36.
14 Q. Please explain the pro forma plant additions adjustment proposed by the Company
15 on Exhibit No. 31, Column (v).
16 A. This adjustment captures the impacts to the Company's net operating income and rate
17 related pro forma plant additions expected to be placed in service by December 31, 2025 as
18 well as related increases and offsets. Because 2025 plant additions will be in service
19 before rates go into effect, the Company calculated the impact of this adjustment assuming
20 EOP treatment. Pro forma plant additions are discussed in detail in the direct testimonies
21 of Patrick Darras, Eric Martuscelli, and Tammy Nygard.
22 The increase to gas operating revenues of$2,437,157 on Exhibit No. 31, Column
23 (v), Line 1 and Exhibit No. 32, Column (s), Line 132 was calculated by multiplying pro
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INTERMOUNTAIN GAS COMPANY

I forma customer additions by EOP usage per customer discussed above and using current
2 tariff rates. This ensures that RS and GS-1 pro forma volumes are based on the weather
3 normalized test year volumes adjusted for growth and are not based on a forecast usage per
4 customer.
5 The decrease to distribution O&M of$200,000 on Exhibit No. 31, Column (v),
6 Line 10, is based on estimated savings related to a pro forma plant addition (FP-324562) as
7 discussed in the direct testimony of Patrick Darras.
8 The increase to depreciation expense of$3,601,255 on Exhibit No. 31, Column (v),
9 Line 16 is calculated by multiplying the 2025 pro forma additions to plant in service by the
10 Company's approved depreciation rates. The Company also reduced depreciation expense
11 by multiplying the estimated retirements by the approved average depreciation rate.
12 The increase to plant in service of$92,764,868 on Exhibit No. 31, Column(v),
13 Line 29 is based on pro forma plant additions offset by pro forma plant retirements in 2025
14 which were calculated based on a historical average.
15 The increase to accumulated depreciation of$24,731,667 on Exhibit No. 31,
16 Column(v), Line 30 was calculated by adding 2024 EOP depreciation expense to the
17 estimate of depreciation expense on assets added in 2025 as well as removing estimated
18 retirements and removal costs. The Company calculated the 2025 pro forma depreciation
19 expense by multiplying the 2025 pro forma additions to plant in service by the Company's
20 approved depreciation rates.
21 The decrease to ADIT of$736,081 on Exhibit No. 31, Column(v), Line 34 was
22 calculated in compliance with IRS normalization rules by adding to the 2024 EOP balance
23 of ADIT the projected tax-effect of book-tax differences on assets in service at the end of
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INTERMOUNTAIN GAS COMPANY

1 2024 as well as 2025 net additions to plant in service. Additionally, the amortization of
2 excess deferred income taxes ("EDIT"), as well as ADIT related to customer advances and
3 uniform capitalization were projected and added to the 2024 EOP balance of ADIT.
4 Q. Please explain the income tax adjustment proposed by the Company on Exhibit No.
5 31, Column (w).
6 A. This adjustment calculates the federal and state income tax expense effects of all the
7 adjustments previously explained. Additionally, this adjustment revises income tax
8 expense for the tax effect of the difference between the weighted average debt rate applied
9 to the proposed rate base shown on Exhibit No. 30, Column(d), Line 36 and test year
10 interest expense. This adjustment ensures that rates reflect the tax effect of the interest
11 associated with funding rate base at the weighted average cost of debt. Finally, the tax
12 expense calculation includes an adjustment to reduce the Idaho corporate tax rate to 5.3
13 percent which became effective in March 2025. This adjustment reduces expenses by
14 $1,141,349 as shown on Exhibit No. 31, Column(w), Line 26.
15 Q. What are the Company's adjusted test year results?
16 A. The Company's adjusted test year results are shown on Exhibit No. 30, Column(d). As
17 shown on the exhibit, the Company's adjusted test year Net Operating Income is
18 $25,743,472. The Company's adjusted test year Total Rate Base is $578,473,094. As a
19 result of the adjustments discussed above, the Company's revenue requirement request is
20 $26,499,489 as shown on Exhibit No. 30, Column(e), Line 1, and Exhibit No. 29, Column
21 (b), Line 8.
22 Q. Does this conclude your testimony?
23 A. Yes, it does.
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J.DARRINGTON,DI
INTERMOUNTAIN GAS COMPANY