20161025INT to Staff 103-119.pdf

Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
f~ECE!VE D
·e1& ocr 2s PM 3= 41
; ' ' - • I ·=: i \ : ~ ~ ! C
-:::c .t •• r,LSSIO ~
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO FIFTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and in response to the Fifth Production
Request of the Commission Staff to Intermountain Gas Company dated October 4, 2016, herewith
submits the following information:
REQUEST NO. 103: In Response to Production Request No. 23, a detailed spreadsheet of
Advertising Expense was provided. On tab 2 of this spreadsheet, Column "V" provides a
description of customer benefit. Several line items in Column "V" of this spreadsheet are labeled
with a "9" that is not listed in the legend (Column "V" starting on line 191). Please provide
customer benefit description for items marked with a "9" on the spreadsheet.
RESPONSE TO REQUEST NO. 103:
Customer Benefit footnote definition/or "9" is ''franchise reporting requirement".
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page I
REQUEST NO. 104: Please provide a detailed schedule of actual expenditures to date for
all Administration & General Outside Services included within the Company's filing. Please
include within your response the dates, vendors, explanations, amounts posted, supporting
documentation for those amounts (such as invoices, contracts and other detail supporting the
transactions), and associated customer benefit.
RESPONSE TO REQUEST NO. 104:
Please see Confidential attached file labeled "PR# 104-Admin General OS" for details. Per
10/20/2016 teleconference with Staff, supporting documentation (invoices, contracts and other
detail supporting the transactions) will be provided during on-site meeting for selected items.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 105: Please provide supporting documentation for forecasted A&G
Outside Services for the period 7 /1 /16-12/31/16. Please include an explanation of each expenditure
expected, the purpose, the dollar amounts, and supporting documentation for those amounts. If
based on actual expenses for the same period in 2015, please provide a schedule of actual expenses
and include in your response the dates, vendors, explanation, amounts posted, and supporting
documentation for those amounts.
RESPONSE TO REQUEST NO. 105:
Please see file labeled "PR #105 Outside Service Forecast " for details. Theforecasted
A&G Outside Services for the period 7/1/2016 -12/31/2016 is based on the relative relationship of
actual 2015 Outside Services expense to total FY 2015 O&M Expense; applied to total 2016 O&M
Expense forecast.
RESPONSE OF JGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 2
Per 10/20/2016 teleconference with Staff, supporting documentation (invoices, contracts
and other detail supporting the transactions) will be provided during on-site meeting/or selected
items.
Actual FY 2015 Outside Services Expense
Actual FY 2015 Total Expense
Relative percentage of 0/S Services to Total Exp.
Forecasted Expense (7 /16-12/16)
Relative percentage of 0/S Services to Total Exp.
Outside Services portion of total forecasted exp.
Record Holder: Mike McGrath, 208-377-6000
$
$
$
$
Location:
Sponsor/Preparer:
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
1,001,236
43,400,460
2.3070%
23,226,225
2.3070%
535,822
REQUEST NO. 106: Please provide a detailed schedule of actual expenditures to date for
all Miscellaneous or Other Expense accounts included within the Company's filing. Please include
within your response the dates, vendors, explanations, amounts posted, supporting documentation
for those amounts (such as invoices, contracts and other detail supporting the transactions), and
associated customer benefit.
RESPONSE TO REQUEST NO. 106:
Please see confidential file labeled "PR # 106-Other Exp Per Exh 8 line 15 "for details.
Per 10/20/2016 teleconference with Staff, supporting documentation (invoices, contracts and other
detail supporting the transactions) will be provided during on-site meeting/or selected items.
These costs have been removed from our filing therefore no customer benefit has been identified for
each line item.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 3
REQUEST NO. 107: Please provide supporting documentation for forecasted
Miscellaneous or Other Expense accounts for the period 7/1/16-12/31/16. If based on actual
expenses for the same period in 2015 , please provide schedule of actual expenses and include in
your response the dates, vendors, explanation, amounts posted, supporting documentation for those
amounts.
RESPONSE TO REQUEST NO. 107:
Please see confidential CD file labeled "PR#] 07 Other Exp Per Exh 8 Line 15 "for
worksheet details. Per 10/20/2016 teleconference with Staff, supporting documentation (invoices,
contracts and other detail supporting the transactions) will be provided during on-site meeting for
selected items.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 108: Please provide detailed installation records for all encoder receiver
transmitter (ER T) investments.
RESPONSE TO REQUEST NO. 108:
Please see CD file folder titled "PR # 108 "for details. This folder contains invoices billed
by Southern Cross for labor, ERT purchase invoices and ERT freight costs.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
REQUEST NO. 109: Please provide the detailed depreciation schedules with depreciation
rates applied for Depreciation Expenses related to ERT-Units (Account 381-G) and ERT
Installation (Account 382-G) for actual and forecasted periods in the 2016 Test Year. Please
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 4
provide reconciliation/proof between depreciation expense and accumulated depreciation during
2015 and 2016.
RESPONSE TO REQUEST NO. 109:
Please see CD file labeled "PR #109."
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
REQUEST NO. 110: On page 13 of her testimony, Ms. Blattner describes a peak day
allocator used to allocate Transmission and Storage plant costs. The Company has also indicated
that its test year peak day occurred on January 1, 2016. Does the Company believe that January 1,
2016, consumption properly represents the way that customer classes cause the Company to incur
costs? Please explain your answer.
RESPONSE TO REQUEST NO. 110:
January 1, 2016 consumption properly represents the way that customer classes cause the
Company to incur costs. January 1, 2016 represented 57 heating degree days. The next most
recent historical peak was December 8, 2013 which was 63 heating degree days. The more current
peak-day better reflects the customer mix that lntermountain has today. For instance, several large
industrial customers have been added since 2013 and lntermountain 's residential and commercial
customer classes have continued to grow. The table below shows the coldest days from the
calendar year of 2015, the coldest day of the 2015/2016 winter period, and the previous peak day of
December 8, 2013. The table illustrates that as the weather gets colder, the residential and
commercial customer 's share of the total Sendout increases. Because of the customer additions
since 2013, lntermountain believes that the January 1, 2016 peak day best represents the relative
responsibilities of the classes for costs incurred to serve customers on the system peak day.
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 5
PEAK DAY ANALYSIS
Peak Day usage as a percent of total daily Sendout
RS-1, RS-2, GS
Industrial
Record Holder:
Location:
Dec 8, 2013
63 HDD
77%
23%
Nov 30, 2015
52HDD
69%
31%
Dec 27, 2015
56HDD
73%
27%
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
Jan 1, 2016
57 HDD
72%
28%
REQUEST NO. 111: Please explain how the peak day allocator was computed for each
class, and provide all supporting workpapers and calculations with formulas intact. If MDFQ was
used in computation ofthis allocator, please describe how it was used.
RESPONSE TO REQUEST NO. 111:
The calculation of the peak day allocator can be found in the file that was included with
Production Request Response 3 6, "PR 3 6 FINAL Peak Day Study.xlsx ". The coldest day for the
2015/2016 winter heating season was determined to be January 1, 2016. For that day,
lntermountain knew the total gas delivered to customers. The telemetered Industrial usage is
subtracted from the total usage to calculate the usage that went to serve residential and commercial
customers on the peak day.
Because residential and commercial customers do not have telemetry equipment installed on
their meters, it is not possible to determine how the peak sendout less Industrial sendout was split
between the residential and commercial customers. So, lntermountain determined the split for these
two classes based on the ratio of residential and commercial therms used for the entire month of
January (see tab "Core Peak Day Analysis " of the file "PR 36 FINAL Peak Day Study.xlsx ").
MDFQ was not used in the computation of the peak day allocator.
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 6
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
REQUEST NO. 112: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for each and every customer with a meter capable of measuring daily
demand. Include all workpapers with formulas intact.
RESPONSE TO REQUEST NO. 112:
Please see file labeled "PR#112".
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Dave Swenson, 208-377-6000
REQUEST NO. 113: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for all the Company's existing classes.
RESPONSE TO REQUEST NO. 113:
Please see the files "PR 113 & 114 2015 Billing Data " and "PR 113 & 114 2016 Billing
Data ".
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
REQUEST NO. 114: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for each of the Company's proposed classes.
RESPONSE TO REQUEST NO. 114:
The proposed data can be found in the files submitted in response to Production Request No.
113. The new Residential class is the combination of RS-1, RS-2 and IS-R. The new T-4 class is the
combination of the existing T-4 class and the T-5 class.
RESPONSE OF JGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 7
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
REQUEST NO. 115: In 2008, the Company started using a Square Footage/Average
Therm Matrix to determine annual estimated therms, annual estimated bills, level pay and deposit
amounts, and main extension costs. Has the Company updated the matrix to reflect more recent
consumption data for residential and commercial customers? Please explain.
RESPONSE TO REQUEST NO. 115:
No. The technology in residential homes has not changed significantly enough since 2008 to
justify an update. JGC uses like entities for commercial estimates and does not use a therm matrix.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 116: Please provide the Square Footage/Average Therm Matrix currently
used by the Company.
RESPONSE TO REQUEST NO. 116:
Please see CD file labeled "PR#l 16 -JGC Deposit Calculator and JGC Therms Factors."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 117: The 2008 Square Footage/Average Therm Matrix was integrated
with the previous Customer Information System (CIS). Given the Company's recent transition to a
new CIS, was the most recent Square Footage/Average Therm Matrix incorporated into the new
CIS? If not, please explain how the Company is making each of the calculations identified in
Production Request No. 115.
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 8
RESPONSE TO REQUEST NO. 117:
The therm matrix is not integrated into the new CIS (CC&B). The company uses the JGC
Deposit Calculator spreadsheet for CIS related estimates. The therms matrix is only used to
estimate a residential home's usage when there is not enough actual usage history at the premise.
JGC uses the JGC Therms Factors spreadsheet to estimate residential gas usage for the purpose of
main extensions. The factors are loaded into our Project Cost Estimating program to determine
estimated therms and revenue.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 118: Does the Company use the current matrix to determine new service
line costs as well as main extension costs? If not, how are those costs determined?
RESPONSE TO REQUEST NO. 118:
The Service Line matrix determines "Allowable Service Line Footage " and the Mains
Extension matrix determines allowable "Investment ". The Company 's Main and Service extension
policies will be brought before the Commission after the outcome of all the necessary parameters
have been determined by this Case.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 119: The Ketchum/Sun Valley Area Hookup Fee (Rate Schedule H-1)
was originally established to be effective until the Ketchum Uprate Project costs were fully
recovered, or until the capacity provided by the project was fully utilized. Have the costs of the
Ketchum Uprate project been fully recovered, or has the capacity provided by the project been fully
utilized? If not, please provide the current level of costs recovered from the hookup fee and the
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 9
capacity of the project currently being utilized. Furthermore, please explain if the Company plans
to cancel the Ketchum/Sun Valley Area Hookup Fee and incorporate the remaining project costs
into base rates. Please explain how base rates were adjusted to account for the hook-up fee, and
how the Cost-of-Service study was adjusted to account for these customers' above average usage.
RESPONSE TO REQUEST NO. 119:
The cost of the Ketchum Uprate project has not yet been fully recovered and the incremental
capacity afforded by that project has not yet been fully utilized. The original cost of the project was
$339,371 and, @ 6/30/16, a total of $221,612 has been collected through the Fee leaving a net
plant of$11 7, 759. The remaining capacity available from the uprate is estimated at 2,424 therms.
The Company has no plans to cancel the Ketchum/Sun Valley Area Hook-up Fee Tariff. Although
the plant cost, net of the hook-up fee, has been on the Company 's balance sheet for over 7 years
now, the Company 's filing will remove any plant associated with the project from both its Rate Base
and therefore Cost of Service.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
DATED at Boise, Idaho, this 25th day of October, 2016.
Respectfully submitted,
;?vt; l [;v~
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
RESPONSE OF IGC TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 10
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 25th day of October, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to Fifth Production Request of
the Commission Staff upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83 702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: [e-mail]
[e-mail]
Attorneys for NWIGU
Electronic service only:
Michael C. Creamer
Givens Pursley LLP
E-Mail: mcc@ givenspursley.com
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83702
E-Mail: [e-mail]
Peter Richardson
Gregory M . Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
Company LLC
Ken Miller
Snake River Alliance
223 N . 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. J emigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: Andrew. [e-mail]
Lanny .zieman. l @us.af.mil
N [e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Ronald L. Williams