20161103INT to NWIGU 1-40.pdf

WILLIAMS · BRADBURY
November 3, 2016
Jean D. Jewell
Commission Secretary
ATTO R NEYS AT LAW
Idaho Public Utilities Commission
4 72 W. Washington Street
Boise, ID 83 702
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RE: IGC Response to First and Second Request ofNWIGU -Case No. INT-G-16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are the following:
1. Original and three conformed copies ofintermountain Gas Company's
Response to Northwest Industrial Gas Users' First Request for Production,
2. Original and three conformed copies of Intermountain Gas Company's
Response to Northwest Industrial Gas Users' Second Request for Production,
and
3. Two CD-ROMs that contain the answers and attachments.
By separate confidential CD, please find the responses to NWIGU's request Nos. 1, 7, 37 and
39.
Please direct any questions related to the transmittal of this filing to Mike McGrath at 208-
377-6168.
Sincerely,
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [phone] -www.williamsbradbury.com
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Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
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BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
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Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO FIRST
PRODUCTION REQUEST OF
NORTHWEST INDUSTRIAL GAS
USERS
COMES NOW, Intermountain Gas Company, and in response to the First
Production Request of Northwest Industrial Gas Users ("NWIGU") dated October 13,
2016, herewith submits the following information:
NWIGU REQUEST NO. 1 TO COMPANY: Please provide copies of all
publications and credit reports referenced in the direct testimony of Dr. Gaske and Mr.
Chiles.
RESPONSE TO REQUEST NO. 1:
Please see the confidential file labeled "NW/GU PR#l ", Attachments 1 through
19, for copies of the publications referenced in Dr. Gaske 's direct testimony.
Attachment 1 _2015 MDU Resources annual report and Form 10-K
Attachment 2_BEA GDP release -May 2016
Attachment 3 _Blue Chip Economic Indicators -June 2016
Attachment 4 _ Bureau of Labor Statistics Unemployment Report -June 2016
Attachment 5 _Federal Open Market Committee Statement -June 2016
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 1
Attachment 6 _ Blue Chip Financial Forecasts -May 2016
Attachment 7 Blue Chip Financial Forecasts -June 2016
Attachment 8_Morningstar SBBI Presentation -2016
Attachment9 _Ibbotson SBBI 2015 Classic Yearbook -pages I 08 and I 09
Attachment JO_FERC Opinion No. 531-B
Attachment I I_ Moody's rating methodology for electric and gas utilities -December
2013
Attachment 12 Regulatory Research Associates Idaho Commission profile
Attachment 13 Sources for Schedule I of Dr. Gaske 's ROE Exhibits
Attachment 14 _ Value Line reports for Dr. Gaske 's proxy group companies
Attachment 15 _ Yahoo! Finance growth rates for Dr. Gaske 's proxy group companies
Attachment 16 Zacks growth rates for Dr. Gaske 's proxy group companies
Attachment 17 _ American Gas Association -Innovative Rates report -May 2016
Attachment 18 _ Sources for Dr. Gaske 's analysis of customer charges for proxy group
companies
Attachment 19 _ Sources for Dr. Gaske 's capital structure analysis of proxy group
companies
Please see the file labeled "NWIGU PR#I-Chiles " for the JD Powers survey
results for 2013-2016.
Record Holder:
Location:
Sponsor/Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Dr. J. Stephen Gaske, 508-263-4471
Mark Chiles, 208-377-6000
NWIGU REQUEST NO. 2 TO COMPANY: Please provide all of Dr. Gaske's
exhibits and work papers in electronic format with all formulas intact.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page2
RESPONSE TO REQUEST NO. 2:
Please see CD file folder labeled "NWIGU P R#2 ", Attachments I and 2 for Dr.
Gaske 's exhibits and workpapers in electronic format.
Attachment I_ Dr. Gaske 's ROE Exhibits for lntermountain Gas Company
Attachment 2_Workpaper for Dr. Gaske 's Risk Premium analysis
Record Holder: Mike McGrath 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Dr. J. Stephen Gaske, 508-263-4471
NWIGU REQUEST NO. 3 TO COMPANY: Please provide Intermountain Gas
Company's ("IGC") capital structure, requested capital cost rates, and revenue conversion,
or tax gross up, factor in electronic format with all formulas intact.
RESPONSE TO REQUEST NO. 3:
Please see the response to the Amalgamated Sugar Co. First Production Request,
question #3, in which the Company provided electronic models of Exhibits 3, 5, and 16.
These Exhibits, in addition to the Testimony of Mark Chiles, Steve Gaske, and Jacob
Darrington, address the capital structure, requested capital cost rates and revenue
conversion.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
NWIGU REQUEST NO. 4 TO COMP ANY: Please provide copies of all credit
reports published by Standard & Poor's ("S&P"), Moody's and Fitch Ratings for IGC, all
of its affiliates issued and parent Company issues over the last two years.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 3
RESPONSE TO REQUEST NO. 4:
JGC is not rated by S&P, Moody 's or Fitch therefore no reports have been issued
during the last two years which could be provided. Please see file folder labeled
"NWJGU PR #4 "for the available reports for the parent company.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles 208-377-6000
NWIGU REQUEST NO. 5 TO COMPANY: Please provide complete copies of
all recent credit reports issued by Standard & Poor's, Moody's and Fitch Ratings that
discuss the natural gas utility industry.
RESPONSE TO REQUEST NO. 5:
JGC does not track all credit rating agency research reports on the industry, nor
would we be able to provide copies of copyrighted industry reports issued by these
agencies without permission.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles 208-377-6000
NWIGU REQUEST NO. 6 TO COMPANY: Please provide the most recent
senior secured, unsecured and corporate credit rating of IGC assigned by S&P, Moody's
and Fitch. Also, please provide IGC's S&P business and financial risk profiles.
RESPONSE TO REQUEST NO. 6:
JGC is not currently rated by S&P, Moody 's or Fitch Ratings, therefore no
assigned ratings or business and financial risk profiles could be provided.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles 208-377-6000
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 4
NWIGU REQUEST NO. 7 TO COMPANY: Please provide copies of all
correspondence, presentations and all other materials that IGC and its parent provided to
credit and equity analysts over the last two years.
RESPONSE TO REQUEST NO. 7:
Please see confidential file labeled "NWIGU PR #7. " JGC is not currently rated
by any of the major credit rating agencies and therefore no JGC specific information or
presentations have been provided. In addition, JGC is not publically traded and
therefore no JGC specific information has been provided to equity analysts. JGC recently
marketed private placement debt securities to a select group of potential purchasers.
Information provided to the potential purchasers is included in the file referenced above.
Information regarding correspondence, presentations, or other materials for the parent
company are attached.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles 208-377-6000
NWIGU REQUEST NO. 8 TO COMPANY: On an electronic spreadsheet with
all formulas intact, please provide the monthly average balances for construction work in
progress and short-term debt for the most recent 13-month period.
RESPONSE TO REQUEST NO. 8:
Please see file labeled "NWIGU PR #8 CWIP _ST Debt."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 9 TO COMPANY: Please provide the amount of
capitalized interest paid during the test year related to construction projects.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 5
RESPONSE TO REQUEST NO. 9:
Jntermountain Gas Co. has paid no capitalized interest during the test year.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST N0.10 TO COMPANY: Please state whether IGC has any
off-balance sheet debt such as purchased power agreements and operating leases. If in the
affirmative, provide the amount of each off-balance sheet debt item and estimate the
related imputed interest and amortization expense associated with these off-balance sheet
debt equivalents.
RESPONSE TO REQUEST NO. 10:
Jntermountain Gas Company hedges future gas purchases through the use of fixed
price contracts. Company also has operating leases, please see CD file labeled
"NWIGU PR#JO ". The Company does not calculate imputed interest estimates.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 11 TO COMP ANY: On an electronic spreadsheet with
all formulas intact, please provide the five-year projected and five-year historical capital
structure, capital expenditures and capital funding.
RESPONSE TO REQUEST NO. 11:
Please see CD file labeled "NW/GU PR#] I Five Year Forecasts."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 6
NWIGU REQUEST NO. 12 TO COMPANY: Please provide a detailed
explanation ofIGC's dividend payment and debt financing plans through the test period.
RESPONSE TO REQUEST NO. 12:
The Company 's dividend payment plan during the test year includes $8.01 M
dividends paid to date with $2. 67 M declaration during Q4.
The Company 's debt financing plan during the test year includes a $1 OM equity
infusion from parent company; $5.3M contractual Long-Term note paydown; and up to
$50M Long-Term note issuance.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
NWIGU REQUEST NO. 13 TO COMPANY: Do any of IGC's outstanding
long-term debt issues have call provisions? If the answer is "yes," please provide a list of
the callable issues with the following: a) outstanding balance, b) issuance date, c) maturity
date, d) coupon payment percent, e) annual interest expense, and f) call price ( as a percent
of par).
RESPONSE TO REQUEST NO. 13:
None of JGC 's outstanding long-term debt issues have call provisions.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 14 TO COMPANY: Has IGC performed any debt
refinancing feasibility studies on its outstanding debt issues? If the answer is "yes," please
provide the following:
a. A detailed description of the results from the study.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 7
b. A detailed description of the conclusion(s) made by IGC based on the results of
the study.
c. All debt refinancing feasibility studies in an electronic spreadsheet with all
formulas intact.
RESPONSE TO REQUEST NO. 14:
Intermountain Gas has not performed any formal debt refinancing feasibility
studies regarding outstanding long-term debt. Early retirement of existing long-term debt
agreements can result in significant make-whole penalties which are required to be paid
at the time of retirement. Therefore, the Company has focused on avenues other than
refinancing of existing notes to manage interest rate exposure, take advantage of lower
rates, and avoid punitive make whole charges.
The Company has been careful not to speculate on interest rate movements, but
rather focus on achieving a competitive rate at the time of issuance and adjusting tenor
of the debt to take advantage of low yields at various parts of the yield curve.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
NWIGU REQUEST NO. 15 TO COMPANY: Please provide all workpapers in
native electronic format with all formulas intact that support the direct testimony of Mr.
David Swenson.
RESPONSE TO REQUEST NO. 15:
There are no formula work.papers used by Mr. Swenson.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
David Swenson 208-377-6000
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 8
NWIGU REQUEST NO. 16 TO COMPANY: Please provide all workpapers in
native electronic format with all formulas intact that support the direct testimony of Mr.
Branko Terzic.
RESPONSE TO REQUEST NO. 16:
There are no formula workpapers used by Mr. Terzic.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Branko Terzic 208-377-6000
NWIGU REQUEST NO. 17 TO COMPANY: Please provide all workpapers in
native electronic format with all formulas intact that support the direct testimony of Ms.
Lori A Blattner.
RESPONSE TO REQUEST NO. 17:
See reference in the Response of Intermountain to First Production Request of the
Amalgamated Sugar Co.filed October 12, 2016.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
NWIGU REQUEST NO. 18 TO COMPANY: With respect to the direct
testimony of Ms. Lori A. Blattner, to the extent not already provided, please provide the
following information with respect to class cost of service and rate design:
a. Exhibit 19 in native electronic format with all formulas intact.
b. Exhibit 20 in native electronic format with all formulas intact.
c. Exhibit 21 in native electronic format with all formulas intact.
d. Exhibit 22 in native electronic format with all formulas intact.
e. Exhibit 23 in native electronic format with all formulas intact.
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 9
f. Exhibit 24 in native electronic format with all formulas intact.
RESPONSE TO REQUEST NO. 18:
See reference in the Response of Intermountain to First Production Request of the
Amalgamated Sugar Co. filed October 12, 2016.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
NWIGU REQUEST NO. 19 TO COMPANY: Please provide a complete copy
ofIGC's most recent management approved integrated resource plan.
RESPONSE TO REQUEST NO. 19:
Please reference the Idaho Public Utilities Commission website for the current
Integrated Resource Plan Case INT-G-15-01.
http://www.puc.idaho.gov/fileroom/cases/summary/INTG 150 I .html
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
NWIGU REQUEST NO. 20 TO COMPANY: Concerning IGC's distribution
main planning process, please answer the following:
a. How were main sizes determined based on customers' load on the system, and
the length of mains needed to connect customers the distribution system.
b. How does the length of distribution main impact distribution related equipment
such as compression, pressure regulation, safety equipment, etc. needed to
reliably and safely provide gas delivery service. Please explain answer.
c. Please provide a copy of any distribution main system modernization plan
currently being considered or approved by IGC's management.
d. Please provide a complete copy of IGC's main extension rules.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page IO
RESPONSE TO REQUEST NO. 20:
a. Main (pipeline) sizes are determined based on a gas network modeling
software program that takes into account the pipeline pressure, customer load
and length of pipeline needed to serve the customer.
The length of main is determined based on the location of the customer in
relation to the nearest main.
b. JGC 's distribution system is typically so interconnected within itself that the
length of distribution main is irrelevant. Compressors are typically installed
on longer lengths of pipelines (i. e high pressure transmission pipelines)
requiring a pressure boost to meet customer demand. Distribution systems
generally have adequate pressure and capacity to meet the customer demand
without needing a compressor.
High pressure is delivered into JGC 's distribution system which requires
regulator stations to reduce the pressure dependent upon the operating
pressure in a given system. Regulator stations have their own capacity of
which is sized to meet the demand within the downstream distribution system.
All of the larger distribution systems have multiple regulator stations feeding
into the system thus increasing the capacity within the system. Therefore, the
length of the main is irrelevant related to regulator stations.
At every regulator station is a pressure relief device that protects the
distribution system from over pressure. The length of the main is irrelevant
related to relief devices.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 11
c. The Distribution Integrity Management Program (DIMP) describes IGC 's
systematic approach/or main replacements based on risk. This data is on file
with the IP UC
d. Procedures 9371 and 9372 describe both the Revenue and General Plant
Additions requirements for the main extensions and are available on file with
the !PUC Please reference the Sixth Commission Staff request number 123.
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Craig Chapin 208-377-6000
Hart Gilchrist 208-377-6000
NWIGU REQUEST NO. 21 TO COMPANY: Please provide all workpapers,
schedules and exhibits discussed in witness testimony in working Excel electronic format
with all formulas intact.
RESPONSE TO REQUEST NO. 21:
See reference in the Response of lntermountain to First Production Request of the
Amalgamated Sugar Co. filed October 12, 2016.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
NWIGU REQUEST NO. 22 TO COMPANY: Please provide all schedules and
exhibits supporting the Company's filing in working Excel electronic format with all
formulas intact.
RESPONSE TO REQUEST NO. 22:
See reference in the Response of lntermountain to First Production Request of the
Amalgamated Sugar Co. filed October 12, 2016.
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 12
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
NWIGU REQUEST NO. 23 TO COMPANY: Please provide all workpapers
and spread sheets supporting the Company's filing in working Excel electronic format with
all formulas intact.
RESPONSE TO REQUEST NO. 23:
See reference in the Response of Intermountain to First Production Request of the
Amalgamated Sugar Co. filed October 12, 2016.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
NWIGU REQUEST NO. 24 TO COMPANY: Please provide the O&M
expenses by FERC account, annually beginning in 2007 through 2015 in working Excel
electronic format with all formulas intact.
RESPONSE TO REQUEST NO. 24:
Please see file folder "NWJGU PR#24. "Intermountain Gas Company converted
from the legacy general ledger system in 2010. Please see the FERC Form 2 PDFSfor
2007-2009.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 25 TO COMPANY: Please provide the O&M
expenses by FERC account, monthly, beginning in 2011 through 2015 in working Excel
electronic format with all formulas intact.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 13
RESPONSE TO REQUEST NO. 25:
Please see file labeled "NWIGU PR #25."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 26 TO COMP ANY: Please provide the actual O&M
expenses by FERC account, monthly for 2016, as the data becomes available, in working
Excel electronic format with all formulas intact.
RESPONSE TO REQUEST NO. 26:
Please see file labeled "NWIGU PR #26."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 27 TO COMPANY: In working Excel electronic
format with all formulas intact, please provide a calculation showing the determination of
the revenue requirement increase requested in the current case.
RESPONSE TO REQUEST NO. 27:
See reference in the Response of lntermountain to First Production Request of the
Amalgamated Sugar Co.filed October 12, 2016.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath 208-377-6000
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 14
The following questions are related to the Direct Testimony of Hart Gilchrist
NWIGU REQUEST NO. 28 TO COMPANY: Please provide the following
regarding pipe replacement.
a. The dollar amount and miles of pipe that have been identified annually in each
of the last five years as being in need ofreplacement.
b. The dollar amount and miles of pipe that were replaced annually in each of the
last five years as a result of being identified as being in need ofreplacement?
c. As specifically as possible, identify the annual sources of funding used for the
pipe replacements identified in subpart b.
RESPONSE TO REQUEST NO. 28:
a. Please see table listed under section b.
b. Table below shows main pipeline mileage and associated costs for
replacement identified through the Company 's Distribution Integrity
Management Program (DIMP). Pipeline replacement activities through
DIMP did not officially start until 2013.
Year (Miles) Estimated Cost . .. -... Replacement Cost (Miles)
2011 0 $0 0
2012 0 $0 0
2013 2.23 $1,513,235 2.23
2014 8.11 $1,580,386 8.11
2015 8.67 $2,901,792 8.26
c. Pipeline replacement projects considered to be needed through the
Company 's DIMP are funded with the Company 's annual capital budget.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
$0
$0
$922,803
$1,620,437
$2,888,306
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 15
The following questions are related to the Direct Testimony of Ted Dedden
NWIGU REQUEST NO. 29 TO COMP ANY: Please provide the following
regarding Customer Deposits.
a. Does the Company collect Customer Deposits?
b. If the response to subpart a. is "no," explain why.
c. If yes to subpart a., explain in detail how these funds are accounted for in the
Company's books and records?
d. The monthly dollar amount balances for Customer Deposits for the period
December 31, 2010 through December 31, 2016 as the data becomes available,
in working Excel electronic format with all formulas intact.
e. Explain in detail the cause of any month to month deviations, of+ or -10% or
more, in the amounts provided in response to subpart d.
f. The rate of interest paid on customer deposits.
g. Explain in detail why Customer Deposits are not included in the Company's
rate base, including cites to Commission orders and/or policies.
RESPONSE TO REQUEST NO. 29:
a. Yes
b. NIA
c. Customer deposits are credited to FERC AIC 235 (Customer Deposits).
d. Please see file labeled "NWIGU PR#29 Customer Deposits."
e. Month to month deviations of total customer deposits are the result of new
customer credit worthiness and annual review of existing deposits. The
Company has not analyzed the month to month deviations.
f Pursuant to !PUC Order 33426, Company pays 1% annual interest on
customer deposits.
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 16
g. The Company does not include Customer Deposits in the determination of
rate base because these deposits do not constitute a source of cost-free
capital. The Company pays interest to its customers for these deposits and
this interest is not included in the Company's cost of service.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise. ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 30 TO COMPANY: Please provide the following
regarding Customer Advances.
a. The monthly balances of the dollar amount of Customer advances for the period
December 31, 2010 through December 31, 2016 as the data becomes available,
in working Excel electronic format with all formulas intact.
b. Explain in detail the cause of any month to month deviations, of+ or -10% or
more, in the amounts provided in response to subpart a.
RESPONSE TO REQUEST NO. 30:
Please see file labeled "NWIGU PR #30. "Month to month deviations of total
customer advances are the result of new customer growth and length of main or service
subject to pre-determined allowance.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 31 TO COMPANY: Please provide following
regarding other revenues.
a. The annual amount of other revenues for the 2011 through 2015, and monthly
for 2016 as actual data becomes available, consistent with the income statement
values used in the Company's case filing (Dedden Exhibit 09), in working Excel
electronic format with all formulas intact.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 17
b. A detailed explanation for year to year variances of+ or -10% or more, by
revenue item.
RESPONSE TO REQUEST NO. 31:
Please see file labeled "NWIGU PR #31." The attached file provides detail by
"Other Revenue " category that will explain significant deviations year over year.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 32 TO COMP ANY: Please provide the actual July
through December 2016 balances as they become available for plant, depreciation and
amortization reserves, materials and supplies, customer advances, accumulated deferred
income taxes and gas storage, consistent with the rate base values used in the Company's
case filing (Dedden Exhibit 07), in working Excel electronic format with all formulas
intact.
RESPONSE TO REQUEST NO. 32:
The Company will provide this data as it becomes available.
Record Holder: Mike McGrath 208-377-6000
Location:
Sponsor/Preparer:
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 33 TO COMPANY: Please provide the following:
a. The Cross Charge Summary annually for 2011 through 2015 and monthly for
2016 as actual data becomes available, consistent with the line item values used
in the Company's case filing (Dedden Exhibit 11).
b. Data for the 2015 summary.
c. Provide subparts a. and b. in working Excel electronic format with all formulas
intact.
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 18
RESPONSE TO REQUEST NO. 33:
Please see file labeled "NW/GU PR #33, "data is provided for all years.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 34 TO COMPANY: Please provide the following
regarding the deferred income tax reserves included in rate base.
a. Supporting calculations demonstrating that the deferred income taxes included
in rate base reflect the timing difference associated with bonus depreciation
available on 2016 plant additions, in working Excel electronic format with all
formulas intact.
b. Supporting calculations demonstrating that the deferred income taxes included
in rate base reflect the timing difference associated with non-bonus tax
depreciation available on 2016 plant additions, in working Excel electronic
format with all formulas intact.
c. Supporting calculations demonstrating that the deferred income taxes included
in rate base reflect the timing difference associated with tax depreciation on pre-
2016 plant additions, in working Excel electronic format with all formulas
intact.
d. Detailed explanations associated with subparts a. through c.
RESPONSE TO REQUEST NO. 34:
a. The Company is electing out of federal bonus depreciation/or 2016 plant
additions. There is no impact on Idaho since the state is non-conforming.
b. See the CD folder "NW/GU PR#34 "for the following files: "IPUC-34.xlsx ",
"Rpt 216 2016 Vintages Jan est.pd/", and "Rpt 216 2016vintages 5+7.pdf "
c. See the CD/older "NW/GU PR#34 "for thefollowingfiles: "IPUC-34.xlsx ",
"Rpt 216 Pre-2016 Vintages Jan est.pdf', and "Rpt 216 Pre-2016 vintages
5+7.pdf "
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 19
d. The file "IPUC-34.xlsx " shows how PowerTax calculates the Company 's
deferred income tax reserves. PowerTax is a module of the Power Plan software
system and is the industry standard for computing the deferred income tax
reserves for utility companies. Using information from the PowerTax 216
Reports, the spreadsheet shows how the 2016 and pre-2016 timing differences are
incorporated into the Company 's deferred income tax reserves. The spreadsheet
incorporates the Company 's original and updated plant additions estimates.
Deferred income taxes arise when income tax amounts expensed for book
purposes --and thus the amounts calculated and recovered in rates --differ from
the amount of taxes that are currently due and payable by the utility to the federal
government. These tax differences are primarily caused by the fact that taxes
included in rates are calculated using straight-line depreciation rates, while the
federal tax authority uses accelerated depreciation--formally referred to as
Modified Accelerated Cost-Recovery System (MACRS) --to calculate tax
obligations. In the early years of the asset life, use of accelerated depreciations
results in higher depreciation expense for tax purposes than for regulatory book
purposes. The higher expense accrued will reflect as a reduction to profit for the
period, causing the income taxes computed for regulatory purposes --and thus
included in revenue requirement --to be higher than the taxes paid to the IRS. In
the later years in the life of the asset the situation reverses itself and the revenue
requirement will include an amount less than is due in taxes.
The APB 11 calculation of deferred income taxes measures the deferred income
tax reserve on the Company 's accounting records at the tax rate at which it was
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 20
first recorded in the Company 's accounting records. The deferred income taxes
are then reversed from the Company 's accounting records using the average rate
assumption method ("ARAM") approach as prescribed by the IRS. For the timing
differences associated with 2016 additions, the deferred income taxes are
measured using the federal tax rate of 35%. For timing differences related to
prior year additions, the deferred taxes were recorded in the Company 's
accounting records at the historical tax rate which was in effect at the time the
deferred income taxes were first measured. As these deferred taxes reverse in the
future, an average rate is used to reverse the deferred income taxes. The
Company has been ordered by the Idaho Public Utilities Commission to flow­
through state deferred income taxes. Therefore, no state deferred income taxes
are included in the APB 11 deferred income tax balances of the Company.
The ASC7 40 (F ASI 09) adjustment is the difference between the deferred income
taxes at the historical rate (i.e. the APB 11 deferred income tax reserve) and the
deferred taxes calculated at the current statutory rate as prescribed by generally
accepted accounting principles ("GAAP "). This adjustment also includes flow­
through items such as AFUDC equity and state deferred income taxes. A gross-up
is then applied to this adjustment as prescribed by GAAP.
In the file "IPUC-34.xlsx ", the ARAM rate for assets added prior to 2016 is
34.9667%. The gross-up rate is .661406. The gross up rate is afunction of the
current federal and Idaho statutory tax rates.
Record Holder: Mike McGrath 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Donna Genora, 701-530-1040
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 21
NWIGU REQUEST NO. 35 TO COMPANY: Please provide the following
regarding costs charged by MDUR.
a. The amount, by function/category, annually for 2010 through 2016, as the data
becomes available, charged to the following entities:
1. Montana Dakota -Electric utility segment;
2. Montana Dakota/Great Plains -Gas utility segment;
3. Cascade Natural Gas ("CNG");
4. Intermountain Gas Company ("IGC");
5. WBI Energy Transmission;
6. WBI Midstream;
7. Knife River Construction ("KRC"); and
8. MDU Construction Services Group, Inc. ("CSG")
b. A description of the business performed by each entity in subpart a.
c. Describe in detail the basis of the cost charged by MDUR (actual, or other) and
how it is determined, including the rate of return and depreciation rates used for
recovery of assets.
d. Describe in detail the process used to determine that the costs charged for
services are necessary, reasonable and equal to or below the cost that would be
charged by an independent third-party.
e. Identify where these costs are charged in the books and records of IGC and the
amount included in the cost of service in this case.
RESPONSE TO REQUEST NO. 35:
a. Please see file labeled "NWIGU PR#35 a". Charges include above the line and
below the line costs. -
b. Please see the attached link for additional information regarding business entity:
http://www. mdu. com/
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 22
----1
I
c. Please refer to the First Production Request, PR# 1, for copy of allocation
manual.
d. MDUR has not studied, or commissioned any studies, regarding whether
MDUR 's charges to Jntermountain or other entities listed in section 3.a., are at or
below costs that would have been charged by independent third parties. In
addition, the Company is of the opinion that a number of charges from MDUR to
lntermountain -such as executive team leadership, experience and expertise -
are not services that can, or should be, acquired from independent third-party
providers.
e. MDUR cross charges are recorded in the 48516 business unit of the Company's
books and records. The amount included in the Company 's cost of service is
$2,795,561 as seen on Exhibit No.11, p . l, Line 3, Column (d). This amount is
then adjusted to account for the Company adjustments listed on Exhibit No. 14,
p.2.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
NWIGU REQUEST NO. 36 TO COMPANY: Please provide the following
regarding costs charged to each operating company by Montana Dakota/Great Plains,
Cascade Natural Gas and IGC.
a. Identify the operating companies receiving costs from each of the above
providers.
b. The amount, by function/category, annually for 2010 through 2016, as the data
becomes available, charged to the companies in subpart a.
c. For the period 2010 to 2016, describe in detail the services provided and the
cost charged by Montana Dakota/Great Plains (actual, or other) for services
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 23
provided and a description of how the cost is determined, including the rate of
return and depreciation rates used for recovery of assets.
d. Describe in detail the process used to determine that the costs charged for
services are necessary, reasonable and equal to or below the cost that would be
charged by an independent third-party.
e. Identify where these costs are charged in the books and records oflGC and the
amount included in the cost of service in this case.
f. Provide complete copies of all regulated filings of the service Company charges
including FERC Form 60.
RESPONSE TO REQUEST NO. 36:
Pending, extension through 11/10/16.
Record Holder: Mike McGrath 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
The following questions are related to the Direct Testimony of Jacob Darrington
NWIGU REQUEST NO. 37 TO COMPANY: Please provide the following
regarding Incentive compensation cost included in the 2016 cost of service.
a. Identify the different incentive plans included in the cost of service.
b. Identify the amount of each plan in subpart a., and how it was determined for
each category (financial, safety, cost control, etc.).
c. Provide the plan documents for each incentive plan that fully describe the terms
of the plan, its intended purpose, the employees covered, how payouts are
determined by category, what adjustments can be made in the determination of
payouts and the level of control management has over the administration of the
plan.
d. The five most recent annual amounts of payout for each plan, by category, in
working Excel electronic format with all formulas intact.
e. Calculations, in working Excel electronic format with all formulas intact, and
other documentation supporting the amounts in subpart b. and d., including
weightings, scorecards, comparisons to benchmarks, etc.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 24
f. Describe how the Idaho Public Utilities Commission has ruled with regard to
the recovery of incentive compensation, including cites to past orders.
RESPONSE TO REQUEST NO. 37:
a. The Company included the Employee Incentive Plan and the Senior
Management Incentive Plan in its cost of service.
b. The amount of expense for the Employee Incentive Plan included in the cost of
service is $506,146 (see the sum of lines 1-3 on Exhibit No. 15, p. 18). The
amount of expense for the Senior Management Incentive Plan included in the
cost of service is $159,257 (see the sum of lines 4-5 on Exhibit No. 15, p. 18).
In the calculation of the above amounts, the Company began first by
determining each eligible employee 's salary, standard labor distribution
("SLD ") (used in determining the amount charged to the operation and
maintenance expenses of the Company), and for those employees without an
SLD, the ratio of each employee 's first quarter work hours allocated to the
Company divided by total first quarter work hours. The Company then used
the plan documents discussed in subpart c. to determine the payout
percentage by paygrade for the successful completion of all plan goals. The
Company then removed the portion of the payout percentage related to the
plan 's Financial Goal. Please see file folder labeled "Request 3 7 b "for
Excel spreadsheets.
c. Plan payouts occur in February of the year follow the plan year for example
2011 Plan is paid in February 2012. Please see Confidential file folder
labeled "Request 37 _c "for Excel spreadsheets. Plans are included for 2011,
2012, 2013, 2014, & 2015 plan years.
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 25
d. Please see file folder labeled "Request 37_d "for Excel spreadsheets. Plan
years listed in "c" are included. For the 2015 plan year the financial
threshold was not met therefore there was no payout for employees for that
plan year.
e. Please see the confidential CD file folders labeled "Request 37 b ", "Request
37 _c ", and ""Request 37 _d" for the Excel files in support of subparts b., c.,
and d.
f The Idaho Public Utilities Commission Orders can be searched at:
http://www.puc. idaho. gov/search/ orders/ order search. html
Record Holder:
Location:
Sponsor/Preparer parts a. & b.:
Sponsor/Preparer parts c.-f.:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Jacob Darrington, 208-377-6000
Linda Murray, 208-377-6000
NWIGU REQUEST NO. 38 TO COMPANY: Please provide the following
regarding the adjustments to the deferred income tax reserve shown on Exhibit 12,
page 2.
a. All calculations supporting the amount of each adjustments, in working Excel
electronic format with all formulas intact.
b. Supporting calculations for the determination of the FAS 109 and APB 11
amounts and detailed explanations of how these amounts were used in the
calculations in subpart a., in working Excel electronic format with all formulas
intact.
c. References to the specific IRS code sections that reqmre the proposed
adjustments.
d. Excerpts from prior Commission orders that support the adjustments and the
method of calculation.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 26
RESPONSE TO REQUEST NO. 38:
a. See the CD file labeled "NW/GU PR #38 Deferred Tax Adjustments.xlsx."
b. The CDfilefolder labeled "NW/GU PR #38" the "52000 Reports " contains
monthly PowerTax Provision reports showing the balance of the FAS 109 and
APB 11 amounts. In these reports the APB 11 amounts are found in the "Accum
Reg Deferreds" section. Please see the response to request #34 subpart d. for
discussion of the APB 11 and FAS I 09 balances.
c. Normalization spreads the tax benefits associated with utility assets over the same
period that the costs of those assets are recovered from customers. This seeks to
treat current and future utility customers equitably by allowing all customers to
enjoy the tax benefits of depreciation.
Section 168(!)(2) of the Internal Revenue Code provides that the depreciation
deduction determined under section 168 shall not apply to any public utility
property. Section 1.167 (l)-1 (h)(I )(i) further provides that the reserve established
for public utility property should reflect the total amount of the deferral of federal
income tax liability resulting from the taxpayer 's use of different depreciation
methods for tax and ratemaking purposes.
For a regulated utility, the normalization method of accounting for accelerated
depreciation requires the recording of deferred income tax liabilities resulting
from the differences between book depreciation-the standard depreciation
recorded by the company based on Commission approved depreciation rates, and
accelerated tax depreciation-the depreciation a company is allowed to take under
the Internal Revenue Code. The normalization method of accounting prohibits
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 27
passing through the benefits of accelerated depreciation to ratepayers faster than
the benefits are realized (i.e. monetized) by the Company.
In order to use a normalization method of accounting, section 168(i)(9)(A)(i) of
the Code requires the taxpayer, in computing its tax expense for ratemaking
purposes and reflecting operating results in its regulated books of account, to use
a method of depreciation with respect to public utility property that is the same
as, and a depreciation period for such property that is not shorter than, the
method and period used to compute its depreciation expense for such purposes.
Under section 168(i)(9)(A)(ii), if the amount allowable as a deduction under
section 168 differs from the amount that would be allowable as a deduction under
section 167 using the method, period, first and last year convention, and salvage
value used to compute regulated tax expense under section 168(i)(9)(A)(i), the
taxpayer must make adjustments to a reserve to reflect the deferral of taxes
resulting from such difference.
The other adjustments to rate base as seen on Exhibit No. 13, p. 6, Columns (c),
(d), (h), and (i), represent rate base adjustments not governed by the IRS
normalization rules. The Idaho Deferred Taxes Adjustment in Column (c)
represents the flow -through of state deferred income taxes as determined by
Commission order. The CWIP Adjustment in Column (d) removes deferred
income taxes related to Construction Work in Process ("CWIP '') from the
deferred income tax balance since CWIP is not allowed in the calculation of rate
base by Idaho Code section 61-502A. The Contributions in Aid of Construction
Adjustment in Column (h) represents the accumulated deferred income taxes
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 28
related to Advances in Aid of Construction which is removed from rate base on
Exhibit No. 13, p. 7. While the Advances in Aid of Construction represent a
source of cost-free capital, the related deferred taxes do not and thus are
includible in the determination of rate base. The Uniform Capitalization
Adjustment in Column (i) represents the accumulated deferred income taxes
related to Gas Storage Inventory which is included in rate base on Exhibit No. 13,
p. 4. The deferred taxes related to this adjustment represent a use of Company
funds and thus are includible in the determination of rate base.
d. The Idaho Public Utilities Commission Orders can be searched at:
http://www. puc. idaho. gov/search/orders/ordersearch. html
Record Holder: Mike McGrath 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer parts a., c. (other adjustments) & d.: Jacob Darrington, 208-377-6000
Sponsor/Preparer parts b., c. (IRS normalization): Donna Genora, 701-530-1040
NWIGU REQUEST NO. 39 TO COMP ANY: Provide the following regarding
the adjustments associated with non-utility LNG adjustments.
a. Rationale for characterizing these transactions as non-utility.
b. Explain whether utility assets and personnel were used to facilitate these
transactions.
c. A detailed explanation of the circumstances that gave rise to these transactions.
d. Excerpts from Commission orders that support the Company's proposed
treatment of these transactions.
e. A calculation showing the total cost associated with these transactions,
including storage cost, in working Excel electronic format with all formulas
intact.
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 29
RESPONSE TO REQUEST NO. 39:
a. All of these LNG sales are to customers that do not receive traditional gas
service from Intermountain and therefore they are referred to as "non­
utility ".
b. Yes, utility assets and personnel are utilized to facilitate non-utility LNG
sales. Please see the Company 's filing and Commission Order in INT-G-13-
02 for further detail
(http ://www. puc.idaho. gov /fileroom/ cases/ summary/INTG 13 02.html ).
c. During calendar year 2012, the Company was aware of growing interest in
LNG usage. The Company decided to gauge local/regional interest and
contacted potential customers to determine if there might be an opportunity
for year-round use of the Nampa facility. Subsequently, the Company was
contracted in January 2013 by one of those entities, West Yellowstone
Montana, who operates a small LNG-based distribution system in south­
western Montana. West Yellowstone had lost its normal LNG supply and
therefore had an emergency need for LNG supply.
Intermountain immediately contacted the !PUC to request temporary
authority to sell LNG to this non-utility customer. The !PUC immediately
opened a Case and granted the Company authority to temporarily serve this
customer and Intermountain begin delivering its first non-utility LNG that
same day. More information is available at
(http://www. puc. idaho. gov /fileroom/ cases/ summary/INTG 13 0 I .html).
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 30
With that experience and positive feedback form other potential customers,
Jntermountain decided to ask the Commission for authority to begin selling
LNG to non-utility customers on an on-going basis (please see
(http ://www. puc.idaho. gov /fileroom/ cases/ summary/INTG 13 02.html) for
further information.
d. The Commission 's Order lists the required treatment of these transactions
(http://www. puc.idaho. gov /fileroom/ cases/ summary/INTG 13 02.html).
Paragraphs 2, 3, 4, 5 and 7 of the Commission 's Order explain the specific
information requested.
e. Please see the Confidential CD file labeled "NWIGU PR#39 Non-Utility LNG
Costs " which was included in the Company 's general rate case filing shows
the monthly cost of gas and storage inventory balances associated with non-
utility LNG sales
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
David Swenson, 208-377-6000
NWIGU REQUEST NO. 40 TO COMP ANY: In working Excel electronic
format with all formulas intact, please provide the actual number of customers by rate
class, by month, for the period January 1, 2011 through December 31, 2016, as the data
becomes available.
RESPONSE TO REQUEST NO. 40:
Please see file labeled "NWIGU PR#40."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
IGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 31
Dated this 3rd day of November, 2016.
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
JGC RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 32
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 3rd day of November, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to First Production Request of
Northwest Industrial Gas Users 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 83 720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83 707
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 AI)
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
[8] Electronic Transmission
D Hand Delivery
[8] US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[8] Electronic Transmission
D Hand Delivery
[8] US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[8] Electronic Transmission
D Hand Delivery
[8] US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
[8] Electronic Transmission
D Hand Delivery
[8] US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[8] 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: [e-mail]
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 702
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
CompanyLLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
2
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZI Electronic Transmission
IZ! Electronic Transmission
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
IZ! Electronic Transmission
D Hand Delivery
IZI US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZI Electronic Transmission
D Hand Delivery IZ! US Mail (postage prepaid)
D Facsimile Transmission
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IZI Electronic Transmission
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny .zieman. l @us.af.mil
[e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
D Hand Delivery
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,_
Ronald L. Williams