20251105Direct Travis Culbertson.pdf

RECEIVED
November 05, 2025
BEFORE THE IDAHO PUBLIC
"T" 'TIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ) CASE NO. INT-G-25-02
INTERMOUNTAIN GAS COMPANY )
FOR AUTHORITY TO INCREASE )
ITS RATES AND CHARGES FOR )
GAS SERVICE IN THE STATE OF )
IDAHO )
DIRECT TESTIMONY OF TRAVIS CULBERTSON
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 5, 2025

I Q. Please state your name and business address for
2 the record.
3 A. My name is Travis Culbertson. My business address
4 is 11331 W. Chinden Blvd. , Building 8, Suite 201-A, Boise,
5 Idaho 83714 .
6 Q. By whom are you employed and in what capacity?
7 A. I am employed by the Idaho Public Utilities
8 Commission ("Commission") as the Program Manager overseeing
9 the Accounting and Finance team in the Utilities Division.
10 Q. Please describe your educational background and
11 professional experience .
12 A. I was hired by the Commission in 2018 . My
13 educational background and professional experience are
14 provided in more detail in Exhibit No . 101 .
15 Q. What is the purpose of your testimony in this
16 proceeding?
17 A. The purpose of my testimony is to describe the
18 Application filed by Intermountain Gas Company ("Company")
19 to increase its rates and charges for natural gas service
20 in Idaho, describe the proposed comprehensive Stipulation
21 and Settlement ("Settlement") and explain Commission
22 Staffs ("Staff") support for the Settlement .
23 Q. How is your testimony organized?
24 A. My testimony is structured under the following
25 headings :
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 1
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1 1 . Background Page 2
2 2 . Staff Investigation Page 4
3 3 . Settlement Evaluation Page 5
4 4 . Settlement Overview Page 7
5 Background
6 Q. Please provide an overview of the Company' s
7 Application.
8 A. The Company filed its Application to increase
9 rates and charges for natural gas services in Idaho on June
10 1, 2025 . The Company requested authority to increase its
11 base revenue by $26 . 5 million, or 22 .2%, effective on or
12 after June 30, 2025 .
13 The Company' s requested increase was based on a
14 historical test period ending December 31, 2024, with pro
15 forma adjustments through December 31, 2025 . Capital
16 additions through December 31, 2025, were included in the
17 Company' s proposed test year rate base and calculated on an
18 end-of-period basis .
19 The Company proposed a hypothetical capital
20 structure consisting of 50% equity and 50% debt, with a
21 Return on Equity ("ROE") of 10 . 8% for an overall weighted
22 average cost of capital of 7 . 86% .
23 The Company proposed movement towards cost of
24 service based on its class cost-of-service study ("COSS") .
25 As proposed, Residential customers and Large Volume
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 2
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1 customers were capped at 120% of the total relative system
2 increase, while Interruptible Transport Service customers
3 were limited to 25% of the overall system increase . All
4 other customers were proposed to receive the remainder of
5 the increase at 59% of the system average increase .
6 Finally, the Company proposed to increase its
7 monthly fixed customer charges for all customer classes and
8 proposed a Residential customer charge increase in a two-
9 step process, increasing its current Residential Service
10 and Interruptible Residential Service customer charge from
11 $8 . 00 to $14 . 00 effective January 1, 2026, and increasing
12 it to $20 . 00 effective January 1, 2027 . In year two, the
13 Company also proposed a reduction to the residential
14 volumetric charge to offset the revenue generated from the
15 increased monthly customer charges . The Company also
16 proposed increases to remaining classes' customer charges
17 and to all blocks of the volumetric rates in the respective
18 tariff schedules based on the margin revenue in each block.
19 Q. How was the case processed after it was filed?
20 A. The Commission issued a Notice of Application,
21 Notice of Suspension of Proposed Effective Date, and Notice
22 of Intervention Deadline on June 13, 2025, establishing an
23 Intervention deadline of July 4, 2025 . Intervenor status
24 was subsequently granted to the Alliance of Western Energy
25 Consumers ("AWEC") and Micron Technology ("Micron")
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 3
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1 (collectively, "Intervenors") . The Company, Staff, and the
2 Intervenors (collectively, "Parties") participated in
3 settlement conferences on September 4th and 5th, resulting
4 in a settlement by the Parties . The comprehensive
5 Settlement was signed by representatives for each of the
6 Parties .
7 Staff Investigation
8 Q. What type of investigation did Staff conduct to
9 evaluate the Company' s base rate increase request?
10 A. Staff' s approach in any general rate case is to
11 extensively review the Company' s Application and associated
12 testimony and workpapers, identify adjustments to the
13 proposed revenue requirement, evaluate the Company' s class
14 COSS and rate spread, and prepare to file testimony for a
15 fully litigated proceeding. There were ten Staff members
16 analyzing this case consisting of four auditors, three
17 utility analysts, one engineer, and two consumer compliance
18 investigators . Additionally, five supervisors reviewed the
19 results of all analysis and provided policy directions to
20 the assigned Staff.
21 Staff reviewed the Company' s test year results
22 of operations, capital budgets, capital spending trends,
23 operations and maintenance ("O&M") expenses and trends, and
24 verified all the Company' s calculations and assumptions
25 regarding the overall revenue requirement, COSS, and rate
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 4
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1 design. The auditors reviewed thousands of transactions,
2 selected samples, and performed transactional testing in
3 accordance with standard audit procedures . The auditors
4 also reviewed the Company' s labor expenses, incentive
5 plans, employee benefits, pension expenses, and 0&M
6 expenses, along with depreciation expenses and taxes .
7 Auditors assured the appropriate level of expenditures were
8 included in rates .
9 Staff reviewed both completed and proposed
10 capital investments to determine prudence of capital
11 additions . Staff investigated the Company' s cost of
12 capital, actual and proposed capital structure, class COSS,
13 and revenue normalization. In total, Staff submitted 171
14 production requests, many of which contained multiple sub-
15 parts, performed an onsite audit, and held several virtual
16 meetings with Company personnel as a part of its
17 comprehensive investigation.
18 Based on the success of its investigation, Staff
19 proposed approximately 21 separate revenue requirement
20 adjustments during settlement discussions .
21 Settlement Evaluation
22 Q. How did Staff determine that the overall
23 settlement was reasonable?
24 A. In every settlement evaluation, Staff and other
25 parties must examine the risks of losing positions at
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 5
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1 hearing and determine if the settlement is a better overall
2 outcome . Staff must evaluate each individual adjustment and
3 determine the likelihood of the Commission accepting or
4 rejecting Staff' s rationale for the adjustment . All parties
5 must weigh the risks of the Commission' s decision
6 establishing perceived adverse precedent which creates a
7 willingness to negotiate a positive outcome in good faith.
8 Ultimately, Staff' s intent in every settlement conference
9 is to negotiate the best possible outcome for customers .
10 Q. Can you describe the process used during these
11 settlement negotiations?
12 A. The settlement conference was conducted over two
13 days with the Parties . Each party described and provided
14 justification for its proposed revenue requirement
15 adjustments, and positions for consumption normalization,
16 class COSS, rate design, or other issues . The settlement
17 conference continued until the Parties reached a compromise
18 on a tentative revenue increase of $13 million.
19 After an agreement on the revenue requirement was
20 reached, the only two open issues identified were the
21 allocation of the revenue requirement to the classes, and
22 Company' s proposed changes to customer charges . Without
23 agreement on any specific COSS or methodology, the Parties
24 agreed that the Company' s proposals on movement towards
25 class COSS were reasonable .
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 6
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I Regarding changes to customer charges, the
2 Parties agreed to the monthly customer and demand charges
3 stated in the Settlement .
4 Q. Were there other issues discussed during the
5 settlement conferences?
6 A. Yes . Several issues were identified during the
7 discussions that would improve future rate cases . Action
8 items were identified for inclusion in the Settlement .
9 Q. Does Staff support the Settlement as fair, just,
10 and reasonable?
11 A. Yes, after a comprehensive review of the
12 Company' s Application, a thorough audit of the Company' s
13 books and records, an analysis of the Company' s class COSS,
14 and extensive negotiations with the Parties, Staff supports
15 the proposed Settlement . Staff believes the Settlement
16 offers a reasonable balance between the Company' s
17 opportunity to earn a reasonable return on its investment
18 and affordable rates for customers . Staff believes the
19 Settlement is in the public interest, is fair, just, and
20 reasonable, and should be approved by the Commission.
21 Settlement Overview
22 Q. Please describe the terms of the proposed
23 Settlement .
24 A. The proposed Settlement provides a reduction in
25 the Company' s requested revenue requirement . Instead of the
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 7
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I Company' s proposed base rate increase of $22 . 6 million, or
2 22 .20, the base rates under the proposed Settlement will
3 increase by $13 million, or 10 . 40, effective January 1,
4 2026 .
5 Q. How was the stipulated revenue requirement
6 derived?
7 A. The revenue requirement was calculated by
8 starting with the Company' s proposed revenue requirement .
9 While Staff and other parties presented adjustments to the
10 Company' s filing, the Parties were unable to reach
11 agreement on individual adjustments . Instead, following
12 discussions and negotiation, the Parties agreed to a
13 general revenue requirement increase that all deemed
14 reasonable and in the public interest .
15 Q. How were operating expense adjustments addressed
16 in the Settlement?
17 A. The Settlement increase represents a negotiated
18 outcome among the Parties and does not represent an
19 acceptance or rejection of any specific operating expense
20 adjustment . Although certain adjustments were discussed
21 during negotiations, such as salaries, incentives, and
22 other general operating expenses, the $13 million
23 stipulated increase to revenue requirement was based on an
24 overall compromise among the Parties rather than an
25 agreement on any individual adjustment .
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 8
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1 Q. Please explain the cost of capital and return on
2 equity of the Settlement .
3 A. In its Application, the Company proposed a 50%
4 common equity ratio and a 10 . 8% ROE . The Parties agreed to
5 maintain the hypothetical common equity ratio and keep the
6 ROE at the currently authorized 9 . 5% . Staff believes an ROE
7 of 9 . 5% is reasonable because it is within the range of
8 reasonableness established by Staff as part of its ROE
9 evaluation. A 9 . 5% ROE should allow the Company to maintain
10 its ability to attract new capital from equity markets to
11 finance capital investments and to grow and maintain its
12 operations .
13 Q. How does the Settlement account for the Company' s
14 capital investments included in net rate base?
15 A. In its Application, the Company proposed to
16 include capital investments through December 31, 2025, in
17 its calculation of net rate base . Additionally, the Company
18 requested a net rate base on an end-of-period basis . The
19 Parties agreed to use an average rate base as outlined on
20 page 3 of the Settlement . Additional adjustments were made
21 to capital projects that were either removed from the
22 Company' s proposed projects or delayed beyond the December
23 31, 2025, test year.
24 Additionally, the Parties agreed that all capital
25 projects that have been transferred to plant as of July 31,
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 9
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1 2025, are deemed prudent . Any capital additions transferred
2 to plant after July 31, 2025, may still be reviewed for
3 prudence in the Company' s next general rate case .
4 Q. How does the Settlement allocate the revenue
5 requirement amount to the different customer classes?
6 A. The Parties agreed to a class revenue
7 apportionment as illustrated in Exhibit 2 of the Settlement
8 Agreement . More specifically, there was general recognition
9 that certain customer classes were paying more than their
10 relative cost of service .
11 Q. What changes to the customer charge were included
12 in the Settlement?
13 A. The Parties agreed to increases in the monthly
14 customer charge for Residential customers from $8 . 00 to
15 $11 . 00 and General Service from $15 . 00 to $23 . 00 . For firm
16 distribution only transportation customers taking service
17 under Schedule T-4, the monthly service charge will be
18 $275 . 00 . The proposed customer charges for all remaining
19 classes were agreed to be the same as filed in the
20 Company' s Application.
21 Q. Why does Staff support the increase in the
22 customer charges in the Settlement?
23 A. The increased customer charge provides a better
24 alignment of recovery of the Company' s customer-classified
25 costs included in the COSS . The increase also provides the
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 10
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I Company with more stable recovery of its fixed costs, which
2 vary little throughout the year.
3 Q. Are there other terms and conditions not already
4 discussed that Staff supports?
5 A. Yes . Additional terms include numerous workshops
6 and meetings to be held in preparation for the next general
7 rate case between Company, Staff, and interested Parties .
8 The workshops are intended to discuss topics raised during
9 the case such as : (1) identification of capital cost
10 associated with renewable natural gas, (2) assurance that
11 contribution in aid of construction is charged
12 appropriately for mains and service line extensions (Tariff
13 Section C, installations and extensions of mains and
14 services) , (3) the COSS methodology properly identifies
15 each classes' cost to be served, and (4) how notices should
16 be issued to paperless billing customers .
17 Q. Do you have any other comments on the Settlement?
18 A. Yes . Staff believes the proposed Settlement
19 provides rate stability and certainty to customers . Staff
20 believes that during a time of increased capital spending
21 and inflationary pressures, it is a reasonable method to
22 provide certainty to customers while maintaining the
23 financial viability of utilities . The rate stability and
24 certainty included in this Settlement, along with the
25 reduced revenue increase agreed upon by the Parties,
CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 11
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1 represent a fair, just, and reasonable compromise of the
2 positions put forth by the Parties and is in the public
3 interest . Therefore, Staff recommends that the Commission
4 approve the Settlement, inclusive of all attachments,
5 without material changes or modifications .
6 Q. Does this conclude your testimony in this
7 proceeding?
8 A. Yes, it does .
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CASE NO. INT-G-25-02 CULBERTSON, T . (Di) 12
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Professional Qualifications
of
Travis Culbertson
Program Manager—Accounting and Finance
Idaho Public Utilities Commission
EDUCATION
Mr. Culbertson graduated from Boise State University in 2012 with a Bachelor of Business
Administration degree in Accounting with an emphasis on Internal Audit.
BUSINESS EXPERIENCE
Prior to joining the Idaho Public Utilities Commission ("Commission"), Mr. Culbertson was
employed by a custom home builder in Meridian, Idaho, where he began as an Accountant. His
responsibilities included accounts payable, payroll, client construction accounting,
implementation of a new payroll service system, employee benefits administration, and
onboarding of new employees. He also performed month-end reconciliations of expenses,
accruals, prepaids, monthly construction bank draws, payroll processing, check processing,
inventory controls, internal audits, and other assigned financial and administrative duties.
Mr. Culbertson joined the Commission Staff in October 2018 as an Auditor. In May 2021 he joined
the Technical Analysis team, where he focused on rate design. During his tenure with the
Commission, Mr. Culbertson has participated in a variety of audits and regulatory cases involving
electric,natural gas, and water utilities. These cases include PacifiCorp's Energy Cost Adjustment
Mechanism and depreciation study; Avista Utilities' Power Cost Adjustment, general rate cases;
SUEZ Water Idaho, now Veolia Water Idaho, Inc. general rate case; Idaho Power's Value of
Distributed Energy Resources, general rate case, Power Cost Adjustment; and numerous other
utility filings and compliance reviews.
In October 2022,he expanded his responsibilities on the Audit team, to include oversight of small
water utilities transitioning to regulation and ensuring compliance with State Code and
Commission requirements. In September 2025, he was promoted to Program Manager for the
Accounting and Finance section, where he supervises a team of professional auditors.
Mr.Culbertson participates in professional development and industry training through the National
Association of Regulatory Utility Commissioners ("NARUC"). He has completed NARUC Rate
School, the University of Missouri Financial Research Institute programs, and attends NARUC
Staff Subcommittee of Accounting and Finance meetings. In July 2025, Mr. Culbertson was
appointed to the NARUC Staff Subcommittee of Water, where he will contribute to discussions
regarding policy development on water utility regulation and best practices.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF NOVEMBER 2025,
SERVED THE FOREGOING DIRECT TESTIMONY OF TRAVIS CULBERTSON IN
SUPPORT OF THE STIPULATION AND SETTLEMENT , IN CASE NO.
1NT-G-25-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR—REGULATORY AFFAIRS MEGANN E. MEIER
INTERMOUNTAIN GAS CO GIVENS PURSLEY LLP
PO BOX 7608 601 W BANNOCK ST
BOISE ID 83707 BOISE ID 83702
E-MAIL: lori.blattnergint.as�com E-MAIL: prestoncarterk ig venspurslgy.com
igcre ug latorykint ag s.com memk i�pursle,
stephaniew(crsgivenspursley.com
Alliance of Western Energy Consumers
CHAD M. STOKES BRAD MULLINS
CABLE HUSTON LLP E-MAIL: brmullins&rnwanalytics.com
1455 SW BROADWAY, SUITE 1500 -
PORTLAND, OR 97201
E-MAIL: cstokeskcablehuston.com
Micron Technology,Inc. (Micron)
Austin Rueschhoff
Thorvald A.Nelson
Austin W.Jensen
Kristine A.K. Roach
Holland&Hart,LLP
555 171' Street, Suite 3200
Denver,CO 80202
E-MAIL:
darueschhoffkhollandhart.com
tnelsonkhollandhart.com
awj ensen(kho llandhart.com
(cr�,�karoachhollandhart.com
[e-mail]
tlfrielkhollandhart.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE