20161025Staff 131-162 to INT.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
RECE lVED
2Ql60CT2 5 ~..'1 10:44
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE ITS )
RA TES AND CHARGES FOR NATURAL GAS )
SERVICE. )
)
)
)
) ___________________ )
CASE NO. INT-G-16-02
SEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (Intermountain Gas; Company) provide the following documents and information as soon
as possible, and no later than TUESDAY, NOVEMBER 15, 2016.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference ID APA
31.01.01.228.
SEVENTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 OCTOBER 25, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 131: In the Intermountain Gas Company Depreciation Accrual Rate Study
as of December 31 , 2013 prepared by A US Consultants, it states that the manufacturer of the
encoder receiver transmitters (ERTs) had determined the useful life of the lithium battery (contained
in the compartment of the ERT) to be 12 to 15 years. On page 7 of the study, 381.2 ERT-ERT
Units tab (ERT Replacement Project 2014-2017) it states that the expected useful life of the 40G
ERT unit is 17 years with a Y2 of 1 % failure rate. What is the useful life being used for the 40G
units?
REQUEST NO. 132: In 2014 Intermountain Gas began replacing the 40G ERTs with a
new 1 OOG ERT unit. This unit is stated to have an expected life span of 20 years according to the
manufacturer. What depreciation rate is being used for the 100G ERT units? Also, is the
manufacturer working on production of new ERT units with batteries that have a longer life? If so,
when will those units be available and how long will the estimated battery life of those newer units
be? Please explain.
REQUEST NO. 133: In that same study it states that it would be more cost effective to
replace the ERT unit than to replace the battery. Please explain the evaluation process to make this
determination. How much is the cost of a new/replacement ERT unit versus replacing the lithium
battery?
REQUEST NO. 134: Due to the complexity of the expected life spans of the different ERT
units, IPUC Staff recommended that Intermountain reevaluate the bad battery experience and
establish sub-accounts for new/replacement ERT units in the next rate or depreciation case. Please
explain what sub-accounts have been established for new/replacement ERT units?
REQUEST NO. 135: The study states that the removal and installation of the ERT units
would be contracted out with Itron managing the contract. Please provide a copy of the contract
and the costs for replacing these units and where these costs are booked.
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 2 OCTOBER 25, 2016
REQUEST NO. 136: Does Intermountain Gas Company (IGC) participate in a rebate
program for the Procurement Shared Services Visa Cards? If so, how are the rebates allocated and
shared with customers? If not, please explain why IGC does not earn a rebate on purchases and
what other benefits are received from the Cards.
REQUEST NO. 137: Please list all other consultants and external attorneys who performed
services for the Company or who were paid by the Company for 2015 to present. For all
consultants and attorneys, show services performed, amounts paid, and accounts charged. If
services were performed in support of a docketed federal/state court or regulatory agency action,
please identify the case name, case number, and a brief summary of the issues.
REQUEST NO. 138: Please provide your Uncollectible Expense percentage and show how
it was calculated for each year from 2010 through 2015.
REQUEST NO. 139: Please provide spreadsheets with formulas activated showing all the
allocation factors, calculations of the factors, as well as the calculations for the return on the
invested capital used, as described in Company witness Dedden's Exhibit No. 10 Cost Allocation
Manual.
REQUEST NO. 140: Please provide spreadsheets with formulas activated showing the
calculations and rates for the Corporate Overhead Factor in the Cost Allocation Manual Exhibit I.
Please also provide all supporting documentation.
REQUEST NO. 141: Please provide the dollar amounts allocated to the Company for each
of the services provided for in the Cost Allocation Manual. Please also include the total dollar
amount of costs to be allocated across MDUR Companies.
REQUEST NO. 142: Please provide the rationale and supporting documentation (i.e., time
reports or supported use of general ledger accounts) for using the following allocations as provided
for in Exhibit III in the Cost Allocation Manual:
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 OCTOBER 25 , 2016
• Customer Services, Director:
o 35% CNG, 30% JGC, 35% Montana-Dakota/Great Plains
• Customer Services, Management team Supervisors:
o 30% CNG, 30% JGC, 40% Montana-Dakota/Great Plains
• Customer Services, Management team Manager:
o 30% CNG, 20% JGC, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Manager:
o 20% JGC, 30% CNG, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Team Leads:
o 25% JGC, 25% CNG, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Employees that Schedule both JGC and CNG:
o Split Evenly
• Scheduling, Management Team, Employees that Schedule all brands:
o Split Evenly
• Customer Programs & Support, Manager:
o 30% JGC, 30% CNG, 40% Montana-Dakota/Great Plains
• Customer Programs & Support, Supervisor, Team Lead, And Support Staff:
o Equal portion allocated
REQUEST NO. 143: For all of the categories mentioned in the previous question, please
provide the dollar amounts allocated to the Company annually from 2011 to present. From January
2015 to present, please show the monthly dollar amounts.
REQUEST NO. 144: Please provide a schedule showing when the allocation percentages
are expected to be updated. Please explain the rationale for updating that schedule.
REQUEST NO. 145: The Company's response to Production Request No. 65 indicates that
the Company contributes 5% of eligible compensation as an employer contribution to the retirement
plan, and additional employer match of 50% of employee contribution (up to 3%), and a 1 %
Retirement Profit Sharing if 100% of Target Profitability is met. For each year 2010-2015, please
provide the amount of retirement contributions for each of the sources listed above.
REQUEST NO. 146: Please explain how the Company allocated forecast consumption and
consumption adjustments to rate blocks. Please include all relevant data and workpapers.
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 4 OCTOBER 25, 2016
REQUEST NO. 147: Please explain how the Company determined forecast demand and
demand adjustments by class. Please include all relevant data and workpapers.
REQUEST NO. 148: Please explain how the Company determined normalized Customer
Counts used in Company witness Darrington's Exhibit 15. Please include all relevant data and
workpapers. I
REQUEST NO. 149: Please explain how the Company determined the marginal rates in
Columns T through AE of the worksheet "Exhibits 24, 27, 28.xlsx/Current Therms, Cust, Revs."
REQUEST NO. 150: Please explain how customer migrations were treated in Company
witness Darrington's Exhibit 15 and in the Company's weather and consumption normalization,
adjustment, and forecasts. Please provide all relevant data and workpapers.
REQUEST NO. 151: Please provide unadjusted monthly consumption and customer
counts by rate class, for all rate classes, for the period from October 1989 through September 2016.
REQUEST NO. 152: According to the Company's response to Staff Production Request
No. 25, total RS Margin includes the revenue requirement for distribution, transmission, and
storage. Please provide detailed evidence to support the position that every new customer causes
the Company to add new distribution, transmission and storage resources equivalent to the RS and
GS-1 Margin. Furthermore, because fixed cost recovery mechanisms provide additional revenue
beyond the rate case approved total revenue requirement, please explain how additional fixed costs
recovered through the FCCM will be verified between rate cases.
REQUEST NO. 153: Please provide an analysis in excel format with links enabled
showing the annual deferral balance of the Company's FCCM proposal if it had been in effect since
2013. Please provide the deferral balance using the Company's current and proposed customer
charges.
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 5 OCTOBER 25, 2016
REQUEST NO. 154: Ms. Spector states on page 21 of her testimony that preliminary
estimates ofrebate expenditures are in the range of $200k -$600k. For the rebate portfolio
presented on page 18 of Mrs. Spector's testimony, please provide a table in excel format with links
enabled showing estimates for the rebate expenditures for each DSM measure. Please present this
information for each tier for each measure listed.
REQUEST NO. 155: Ms. Spector states on page 20 of her testimony that the Company has
set a program year target of 65,000 therms, reflecting the Achievable Potential that can be acquired
through Intermountain's proposed portfolio of conservation measures. For the rebate portfolio
presented on page 18 of Ms. Spector's testimony, please provide a table in excel format with links
enabled showing savings estimates for each DSM measure included in the achievable potential.
Please present this information for each tier for each measure listed.
REQUEST NO. 156: Ms. Spector states on page 21 of her testimony that the Company has
developed a levelized cost target of $0.531 (per therm) for the avoided costs used to determine the
measures that would be cost-effective to include in Intermountain's program. Please provide a table
in excel format with links enabled outlining all components of the Pipeline, Fixed Storage and
Commodity Costs used to determine the avoided cost.
REQUEST NO. 157: When the Company considered the design of the Fixed Cost
Collection Mechanism (FCCM), did it consider alternative approaches such as partial decoupling,
recovery of fixed costs based on fixed cost revenue lost through actual Demand Side Management
(DSM) savings; or making recovery of fixed costs through the FCCM contingent on an earnings
test. If the Company considered alternative fixed cost collection approaches, please explain the
alternative approaches it considered. If the Company did not consider alternative approaches,
please explain why not.
REQUEST NO. 158: In the Company's response to Production Request No. 58, the
Company indicates that 631 customer's participated in the Residential Space Heating Equipment
Rebate under current Schedule ER. How many participants were new customers and how many
were existing customers?
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 6 OCTOBER 25, 2016
REQUEST NO. 159: Please provide the number of payment transactions in each of the
following categories for the past three years (2014, 2015 and YTD 2016):
a. Payment by phone via credit/debit cards;
b. Payment by phone via checking/savings account withdrawal;
c. Payment online via credit/debit cards;
d. Payment online via checking/savings account withdrawal;
e. Automatic withdrawal from the customer's financial institution;
f. Payment at authorized Western Union pay stations;
g. Payment at unauthorized pay stations;
h. Payment by mail;
1. Payment at drop boxes; and
J. Other payment methods, if any.
REQUEST NO. 160: Please provide the justification for allowing Western Union to charge
Intermountain Gas customers $1 .00 to collect payment of Intermountain Gas bills. Please provide
the cost Intermountain Gas would incur if it paid for handling its customer's pay station
transactions.
REQUEST NO. 161: Please provide a copy oflntermountain Gas ' contract with Western
Union for handling payment transactions.
REQUEST NO. 162: Please verify if the attached list of authorized pay stations and drop
box locations for Intermountain Gas is correct. Please identify any additions or deletions to this list.
SEVENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 7 OCTOBER 25, 2016
DATED at Boise, Idaho, this 2.f~ay of October 2016.
Technical Staff: Barbara Romano/131-138
Joseph Terry/139-144
Donn English/145
Michael Morrison/ 146-151
Mark Rogers/152-157
Johnathan Farley/158
Daniel Klein/ 15 9-162
i umisc:prodreq/intg 16.2kkscbrjtdemmmrjfdk prod req7
SEVENTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
Sean Costello
Deputy Attorney General
8 OCTOBER 25, 2016
City/ County/ Population by Utility
,Average person per household = 2.68
--. -----------·-
1 ntermounta in Gas
City Populatio n · County
Aberdeen 1,954 Bingham .
American Falls 4,376 ' Power
.,
Blackfoot
Boise
Buhl
Burley
Caldwell
Chubbuck
Eagle
Emmett
Filer
Fort Hall
Fruitland
Garden City
Gooding
Hailey
Homedale
Idaho Falls
Jerome
Kimberly
Kuna
· Meridian
Middleton
Mountain Home
Nampa
~ew Plymouth
Paul
Payette
Pocatello
Rexburg
Rigby
Rupert
Soda Springs
St. Anthony
Twin Falls
Weiser
Total
11,854
214,237
4,214
10,456
48,957
14,125
21,646
6,519
2,602
3,126
4,754
11,260
3,475
8,014
2,610
58,292
11,038
3,432
16,532
83,596
6,003
13,805
86,518
1,513
1,191
7,430
54,350
26,520
4,043
5,617
2,975
3,465
45,981
5,333
811,813
/ 2.68
302,915
INTG Customers= 331,000
Bingham
Ada
Twin falls .
Cass/a
C~nyon
Bannock ·
Ada
Gem
Twin Falls
Bannock
Payette
Ada
Gooding
Blaine
·o·wyhee
Bonneville
Jerom'e
Tl/Yin Falls
Ada
Ada
Canyon
Elmore '.
Canyon
Payette
Minldoka
Payette
Bannock
Madison
Jefferson .
Minidoka .
Caribc:i'u ·
Fremont
Twin Falls
Washington
2 of 4
Population Drop Bo x Pay Station
45,290 1
7,719 · 1
1
416,464 1 16
79,957 1
23,331 1
198,871 5
83,249 1
1
16,686 1
1
1
22,610 2
1
15,080 1
21,329 1 2
11,472 1
107,517 1 4
22,514 1 1
1
2
6
1
26,170 1
1 7
1
20,292 1
1
1 6
37,450 1
26,914 1
1
6,808 1
12,927 1
8
9;944 1
1,212,594 7 83
/ 2.68 ,
452,460 Households
ATTACHMENT TO
STAFF PRODUCTION
REQUEST NO. 162
3/3/2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2016,
SERVED THE FOREGOING SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR -REGULA TORY AFFAIRS
INTERMOUNT AIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: mcc(a),givenspursley.com
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. l @us.af.mil
[e-mail]
[e-mail]
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE