20251105Direct Mullins.pdf

RECEIVED
NOVEMBER 5, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
cstokes(a,cablehuston.com
Attorneys for Alliance of Western Energy Consumers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. INT-G-25-02
OF INTERMOUNTAIN GAS COMPANY FOR)
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR NATURAL GAS )
SERVICE IN THE STATE OF IDAHO )
SETTLEMENT TESTIMONY OF BRADLEY G. MULLINS
ON BEHALF OF THE
ALLIANCE OF WESTERN ENERGY CONSUMERS
November 5, 2025

1 I. INTRODUCTION AND SUMMARY
2 Q. PLEASE STATE YOUR NAME AND OCCUPATION.
3 A. My name is Bradley G. Mullins. I am a consultant representing utility customers
4 before state public utility commissions in the Northwest and Intermountain West.
5 My witness qualification statement can be found at Mullins Exhibit 1.
6 Q. PLEASE IDENTIFY THE PARTY ON WHOSE BEHALF YOU ARE
7 TESTIFYING.
8 A. I am testifying on behalf of the Alliance of Western Energy Consumers
9 ("AWEC"). AWEC is a non-profit trade association whose members are large
10 energy users in the Western United States, including customers receiving gas
11 sales and transportation services from Intermountain Gas Company
12 ("Intermountain"). AWEC's principal interest in this, and other dockets, is to
13 keep Idaho's economy healthy by ensuring affordable access to energy and
14 energy choices for large volume energy customers.
15 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
16 A. In my testimony I discuss AWEC's support for the October 20, 2025 Stipulation
17 and Settlement("Stipulation") entered into by Intermountain, Staff for the Idaho
18 Public Utilities Commission("Staff"), AWEC, and Micron Technologies, Inc.
19 ("Micron") (collectively, "Settling Parties").
20 Q. PLEASE SUMMARIZE AWEC'S SUPPORT FOR THE STIPULATION.
21 A. Under the terms of the Stipulation, the Settling Parties agreed to increase
22 Intermountain's margin rates by $13,000,000, or approximately 10.4%. The
23 Stipulation represents almost a $13,500,000 reduction from the $26,500,000
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B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I revenue requirement increase Intermountain requested in its initial filing. In
2 addition, while the parties did not necessarily agree on the cost of service study
3 results, the Stipulation provides a rate spread recognizing that large volume sales
4 and transportation customers are paying rates in excess of their class cost of
5 service based on the cost of service study submitted in Intermountain's initial
6 filing. AWEC finds that the Stipulation represents a reasonable comprise of the
7 issues raised in this docket and recommends that the Commission approve the
8 Stipulation.
9 Q. WHAT STANDARD DOES THE COMMISSION APPLY WHEN
10 CONSIDERING A SETTLEMENT?
11 A. The Commission has jurisdiction over this matter under Idaho Code §§ 61-502
12 and 61-503, and has the express statutory authority to investigate rates, charges,
13 rules, regulations,practices, and contracts of public utilities, and to determine
14 whether they are just, reasonable, preferential or discriminatory, or in violation of
15 any provision of law, and may fix the same by Order.Idaho Code §§ 61-502 and
16 61-503. Proponents of a proposed settlement must show"that the settlement is
17 reasonable, in the public interest, or otherwise in accordance with law or
18 regulatory policy."IDAPA 31.01.01.275. Notwithstanding, the Commission is
19 not bound by settlement agreements.IDAPA 31.01.01.276. Instead, the
20 Commission"will independently review any settlement proposed to it to
21 determine whether the settlement is just, fair and reasonable, in the public interest,
22 or otherwise in accordance with law or regulatory policy."Id.
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B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I Q. PLEASE DISCUSS AWEC'S REVIEW OF INTERMOUNTAIN'S FILING.
2 A. AWEC performed a detailed review of Intermountain's revenue requirement and
3 rate spread and rate design proposals. AWEC submitted several production
4 requests and reviewed Intermountain's responses to those production requests.
5 AWEC also reviewed Intermountain's responses to the numerous production
6 requests from Staff. AWEC also participated in settlement negotiations. Based
7 on its review of discovery, AWEC prepared a detailed revenue requirement
8 proposal which was provided to settlement participants for consideration in the
9 settlement process.
10 Q. PLEASE GIVE AN OVERVIEW OF THE SETTLEMENT PROCESS.
11 A. The Parties met for settlement conferences on September 30 and 31, 2025. In the
12 settlement conferences, the Parties presented their respective positions and
13 proposed adjustments to Intermountain's revenue requirement and Parties
14 discussed the merits of each adjustment. Ultimately, the Settling Parties were
15 unable to reach consensus on all of the individual revenue requirement
16 adjustments that had been proposed. Notwithstanding, the Settling Parties were
17 able to reach a compromise where Intermountain would be provided with a
18 $13,000,000 revenue requirement increase, reflecting an overall margin rate
19 increase of approximately 10.4%. Each Settling Party came to this result
20 independently. Other than the items specified in Paragraph 2 of the Stipulation,
21 there was no consensus on the specific adjustments that were made to arrive at
22 this result. Based on AWEC's proposed adjustments and analysis prepared in
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B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I advance of the settlement conference, however, AWEC found the stipulated level
2 of revenue requirement to be a reasonable result.
3 Q. WHY DID AWEC AGREE TO A 9.5% ROE?
4 A. Paragraph 2 (a) of the Stipulation provides Intermountain with a 9.5%return on
5 equity("ROE"). From AWEC's perspective, in the context of the overall
6 Stipulation, and taking into consideration the unique factors facing Intermountain,
7 AWEC was willing to accept a 9.5% ROE, which is the same ROE that the
8 Commission approved in Intermountain's prior general rate case INT-G-22-07.
9 While AWEC's cost of capital analysis supported a lower ROE, AWEC was
10 willing to accept a 9.5% ROE because the Stipulation, taken as a whole, resulted
11 in rates that AWEC found to be reasonable.
12 Q. PLEASE DISCUSS THE RATE SPREAD INCLUDED IN THE
13 STIPULATION.
14 A. Parties did not reach an agreement on the cost of service study results
15 Intermountain presented in its initial filing. The cost of service study included in
16 Intermountain's filed case showed that transportation customers had materially
17 higher parity ratios than sales customers, and thus, warranting a lower rate
18 increase for the large volume classes. Ultimately, parties reached a compromise
19 settlement position that provided transportation customers in the T-3
20 (Interruptible) and T-4 (Firm) a lower than average rate increase, while customers
21 in the RS and LV rate classes were allocated a higher than average rate increase.
22 In the Stipulation, there was no consensus on the cost-of-service study
23 assumptions and results. Based on the Company's filed cost of service study,
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B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I however, a lower rate increase would have been justified for the transportation
2 customers. AWEC recognizes, however, that high energy costs present a
3 challenge for all customers, and in the context of gradualism and the spirit of
4 compromise, AWEC was willing to accept Intermountain's proposed rate spread
5 as part of a global settlement.
6 Q. DID INTERMOUNTAIN COMMIT TO CONDUCT WORKSHOPS TO
7 EVALUATE ITS COST OF SERVICE STUDY METHODS PRIOR TO ITS
8 NEXT GENERAL RATE CASE?
9 A. Yes. Paragraph 6 (c) of the Stipulation requires Intermountain to hold workshops
10 evaluating several components related to its cost of service study. AWEC finds
11 that informal collaboration between the parties, outside of the rate case process, is
12 valuable for developing a mutual understanding of Parties' perspectives and
13 streamlining subsequent rate case negotiations. Accordingly, AWEC is
14 supportive of continuing dialog regarding the methods that are used in the cost of
15 service study, as well as efforts to evaluate cost of service study issues in informal
16 settings prior to Intermountain's next general rate case.
17 Q. PLEASE EXPLAIN WHY THE STIPULATION SATISFIES THE
18 INTERESTS AND CONCERNS OF AWEC.
19 A. Based on its review of Intermountain's filing and through the discovery process,
20 AWEC had issues with the requested ROE, several revenue requirements
21 adjustments, and rate spread and rate design. Although the Stipulation does not
22 incorporate all of AWEC's proposed adjustments, it does incorporate many of
PAGE 5 OF 7
B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I AWEC adjustments and positions. Accordingly, the overall result is fair and
2 provides a significant benefit to customers.
3 Q. PLEASE EXPLAIN WHY AWEC BELIEVES THE STIPULATION IS IN
4 THE PUBLIC INTEREST.
5 A. AWEC believes the Stipulation is in the public interest and recommends the
6 Commission approve the Stipulation because the best interests of Intermountain's
7 natural gas customers are served by the underlying fair compromise on certain
8 revenue requirement and rate spread and design issues. While the Stipulating
9 Parties may each hold different positions on the individual components of
10 Intermountain's natural gas revenue requirement addressed in the Stipulation,
11 AWEC supports the Stipulation because it decreased the proposed revenue
12 requirement increase by approximately $13,500,000 from Intermountain's initial
13 filing, which results in a revenue requirement increase of$13,000,000. AWEC
14 supports the Stipulation as an overall result that is a fair compromise between
15 Intermountain and its customers. AWEC also finds the Stipulation to be in the
16 public interest as the spread of the gas rate increase considers Intermountain's
17 cost of service study. For the reasons set forth above, AWEC believes the
18 Stipulation is in the public interest and should be approved by the Commission.
19 Q. DO YOU HAVE ANY CLOSING REMARKS?
20 A. Yes. AWEC appreciates the opportunity to participate in this proceeding. AWEC
21 appreciates Staffs thorough review of, and attention to, the matters at issue in this
22 proceeding. AWEC also appreciates Intermountain's willingness to engage in
23 settlement negotiations in good faith in order to reach a compromise position that
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B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

I all parties could support. Finally, AWEC appreciated working with Micron in
2 this case. While this Stipulation did not necessarily resolve all issues that AWEC
3 identified in its review, AWEC found that it represented a reasonable
4 compromise, resulting in just a 10.4%rate increase relative to the 22.2%rate
5 increase included in Intermountain's initial filing. AWEC supports the stipulation
6 as just, fair and reasonable, and in the public interest.
7 Q. DOES THIS CONCLUDE YOUR SETTLEMENT TESTIMONY?
8 A. Yes.
PAGE 7 OF 7
B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
cstokes(a,cablehuston.com
Attorneys for Alliance of Western Energy Consumers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. INT-G-25-02
OF INTERMOUNTAIN GAS COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR NATURAL GAS )
SERVICE IN THE STATE OF IDAHO )
EXHIBIT 1 TO ACCOMPANY THE
DIRECT TESTIMONY OF BRADLEY G. MULLINS

Mw Analytics Bradley Mullins
ENERGY ST UTILITIES Principal Consultant
[e-mail]
MW Analytics is the professional practice of Bradley Mullins, a consultant and expert witness that
represents utility customers in regulatory proceedings before state utility commissions throughout the
western United States. Mr. Mullins started MW Analytics in 2013 and, since then, has sponsored
expert witness testimony in over 100 regulatory proceedings on a variety of subject matters,including
revenue requirements,regulatory accounting,pricing, cost allocation, depreciation and new resource
additions. MW Analytics also assists utility customers with informal regulatory, legislative energy
policy matters, as well as providing advisory and other energy consulting services.
Education
• Master of Accounting, Tax Emphasis, University of Utah, 2007
• Bachelor of Finance, University of Utah, 2006
• Bachelor of Accounting, University of Utah, 2006
Relevant Prior Experience
PacifiCorp, Portland, Oregon: Net Power Cost Consultant 2010—2013
• Analyst responsible for power cost modeling and forecasting
• Supported regulatory filings,including drafting prewritten testimony,preparing annual power
cost deferral filings, and developing qualifying facility avoided cost calculations
Deloitte, San Jose, California: Tax Senior 2007—2009
• Staff accountant responsible for preparing corporate tax returns for multinational corporate
clients and partnership tax returns for hedge fund clients
• Joined national tax practice specialized in research and development tax credits
Recent Expert Witness Testimony
Docket Party Topics
Alliance of Revenue
In re Avista Corporation, d/b/a Avista Utilities,Request for a General rate Western Energy Requirement,
Revision, Or.PUC Docket No.UG 519,2024 Consumers Rate Spread,
&Rate Design
In Re the Application of Rocky Mountain Power for Authority to Increase Its
Retail Electric Service Rates by Approximately$123.5 Million per Year or Wyoming
14.7 Percent, to Establish an Insurance Cost Adjustment Rider, to Revise the Net Power
Energy Cost Adjustment Mechanism, to Approve the Wildfire Mitigation Industrial Energy Costs
Plan, and to Approve a Voluntary Renewable Energy Credit Program, Consumers
Wy.PSC Docket No 20000-67 1-ER-24(Record No 17659)
In re Cascade Natural Gas Corporation, 2024 General Rate Case, Wa.UTC Alliance of Revenue
Docket No.UE-240008 Western Energy Requirement
Consumers
In re the Application of Rocky Mountain Power to Increase Current Rates by
$84.3 Million to Recover Deferred Net Power Costs Under Tariff Schedule 95 Wyoming Power Cost
Energy Cost Adjustment Mechanism and to Increase Current Rates By$2.1 Industrial Energy Deferral
Million Under Tariff Schedule 93, REC and S02 Revenue Adjustment Consumers
Mechanism,Wy.PSC Docket No 20000-664-EM-24(Record No 17547)
In re Puget Sound Energy, 2024 General Rate Case, Wa.UTC Docket No. Alliance of Revenue
UE-240004(Cons.) Western Energy Requirement
Consumers
Mullins Exhibit 1
Case No.INT-G-25-02
B.Mullins,AWEC
Page 1 of 2

Docket Party Topics
In re Portland General Electric Company,Requests for a General Rate Alliance of Revenue
Revision,Or.PUC Docket No UE 343 Western Energy Requirement
Consumers
In re Avista 2024 General Rate Case, Wa.UTC Docket No.UE-240006 Alliance of Revenue
(Cons.) Western Energy Requirement
Consumers
In re Portland General Electric Company, 2025 Annual Update Tariff, Alliance of Power Cost
Or.PUC Docket No UE 346 Western Energy Forecasting
Consumers
In re PacifiCorp 2025 Transition Adjustment Mechanism, Or.PUC Docket Alliance of Power Cost
No.UE 434 Western Energy Forecasting
Consumers
In re the Application of Sierra Pacific Power Company d/b/a NV Energy for
authority to adjust its annual revenue requirement for general rates charged Smart Energy Revenue
to all classes of electric customers and for relief properly related thereto, Alliance Requirement
PUC Nv.Docket No. 24-02026
In re Joint Application of Nevada Power Company d/b/a NV Energy and Smart Energy
Sierra Pacific Power Company d/b/a NV Energy for Approval of the Alliance and Wynn Wildfire
Cost Recovery for the 2023 Natural Disaster Protection Plan Regulatory Las Vegas,LLC Mitigation
Asset Account, PUC Nv.Docket No.24-03006
In re the Petition ofPacifiCorp d/b/a Pacific Power&Light Company, 2022 Alliance of Power Cost
Power Cost Adjustment Mechanism Annual Report., Wa.UTC Docket UE- Western Energy Deferral
230482. Consumers
In re Northwest Natural Gas Company, dba NW Natural, Alliance of Revenue
Request for a General Rate Revision, Or.PUC Docket no.UG 490 Western Energy Requirement
Consumers
Application of Nevada Power Company d/b/a NV Energy for authority to Circus Circus Las
adjust its annual revenue requirement for general rates charged to all classes Vegas,LLC, Revenue
of electric customers and for relief properly related thereto, PUC Nv.Docket HR Nevada,LLC, Requirement,
No.23-06007;Application of Nevada Power Company d/b/a NV Energy for and Depreciation
approval of new and revised depreciation and amortization rates for its Smart Energy
electric and common accounts, PUC Nv.23-06008. Alliance
In re the Application of Rocky Mountain Power To Increase Current Rates By
$50.3 Million To Recover Deferred Net Power Costs Pursuant to Tariff Wyoming Power Cost
Schedule 95 Energy Cost Adjustment Mechanism And To Decrease Current Industrial Energy Deferral
Rates By$1.5 Million Pursuant to Tariff Schedule 93,REC and SO2 Revenue Consumers
Adjustment Mechanism, Wy.PSC Docket No.20000-642-EM23
In re the Application of Rocky Mountain Power for Authority to Increase Its Wyoming
Retail Electric Service Rates by Approximately$140.2 Million Per Year or Industrial Energy Power Costs
21.6 Percent and to Revise the Energy Cost Adjustment Mechanism, Wy.PSC Consumers
Docket No.20000-633-ER-23
In re of Avista Corporation, d.b.a.Avista Utilities,Requestfor a General Alliance of Revenue
Rate Revision, Or.PUC Docket No.UG 461 Western Energy Requirement
Consumers
In re Joint Application of Nevada Power Company d/b/a NV Energy and
Sierra Pacific Power Company d/b/a NV Energy for Approval of the Cost Smart Energy Wildfire
Recovery of the Regulatory Assets Relating to the Development and Alliance and Wynn Mitigation
Implementation of their Joint Natural Disaster Protection Plan., PUC Nv. Las Vegas,LLC
Docket No.23-03004
In re of PacifiCorp, dba Pacific Power, 2024 Transition Adjustment Alliance of
Mechanism, Or.PUC Docket No.UE 420 Western Energy Power Costs
Consumers
In re the Application of Avista Corporation dba Avista Utilities Requesting Alliance of
Authority to Revise Its Natural Gas Book Depreciation Rates and Deferred Western Energy Depreciation
Accounting, Or.PUC Docket No UM 2277 Consumers
Mullins Exhibit 1
Case No.INT-G-25-02
B.Mullins,AWEC
Page 2 of 2

I DECLARATION OF BRADLEY G. MULLINS
2 I, Bradley G. Mullins, declare under penalty of perjury under the laws of the state
3 of Idaho:
4 1. My name is Bradley G. Mullins. I am employed by MW Analytics as
5 Principal Consultant in the field of energy and utilities.
6 2. On behalf of Alliance of Western Energy Consumers, I present this direct
7 testimony in support of the settlement stipulation in this matter.
8 3. To the best of my knowledge, my direct testimony in support of the
9 settlement stipulation is true and accurate.
10 I hereby declare that the above statement is true to the best of my knowledge and
I I belief, and that I understand it is made for use as evidence before the Idaho Public
12 Utilities Commission and is subject to penalty for perjury.
13 SIGNED this 5th day of November 2025, at Paltamo, Finland.
14 Signed:
15
16
Declaration
B. Mullins, Di—Settlement
Alliance of Western Energy Consumers

CERTIFICATE OF SERVICE
I certify that on November 5, 2025, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:
Commission Staff Via Electronic Mail
Laura Calderon Robles, Interim Commission Secretary [e-mail]
Idaho Public Utilities Commission [e-mail]
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, Idaho 83714
Jeffrey R. Loll jef£[e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd. Building 8, Suite 201-A
Boise, Idaho 83714
Intermountain Gas Company
Preston N. Carter [e-mail]
Megann E. Meier [e-mail]
Givens Pursley, LLP [e-mail]
601 W. Bannock Street
Boise, Idaho 83702
Micron Technology, Inc.
Austin Rueschhoff [e-mail]
Thorvald A. Nelson [e-mail]
Austin W. Jensen [e-mail]
Kristine A.K. Roach [e-mail]
Holland& Hart LLP [e-mail]
555 17th Street, Suite 3200 [e-mail]
Denver, Colorado 80202
Chad M. Stokes
CERTIFICATE OF SERVICE