20161115INT to Staff 131-162.pdf

WILLIAMS · BRADBURY
November 15, 2016
Jean D. Jewell
Commission Secretary
ATTO R NEYS AT LAW
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702
RE: IGC Response to Staffs Seventh Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
RECE IVED
ZOIS~•:•\1 15 PMl2:39
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Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Response to Staffs Seventh Request for Production, and one
CD-ROM that contains the answers and attachments.
By separate confidential CD, please find the responses to Staffs Request No. 135, Request
No. 137 and Request No. 161.
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] -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
r.' r: ,.., i::· i\;r: D l \,--~-1 LI '-
1015 W. Hays St.
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Boise, ID 83702 . '"'!I"
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Telephone: [phone] · , · C'l11 ll l, ,._ . .,.· ·.· ..•• , ,v....,.1vl .
Email: [e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MA TIER OF INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SEVENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and in response to the Seventh Production
Request of the Commission Staff to Intermountain Gas Company dated October 25, 2016,
herewith submits the following information:
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 (ER Ts) 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 Yi of 1 % failure rate. What is the useful life being
used for the 40G units?
RESPONSE TO REQUEST NO. 131:
Page 7 of the December 31, 2013 Depreciation Accrual Rate Study states "At that time
(2002-2003), Itron, the ERT manufacturer indicated an expected useful life of 17 years with a
Yi of 1 % annual failure rate ". A US Consultant has always recommended a service life of 12 to
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page I
15 years. The useful life of the ERT units for depreciation accrual basis had been 15 years over
the period 2002 through 2013. Based on the Company 's replacement program commencing in
2014 and ending by December 31, 201 7 A US Consultants determined the overall service life
characteristics of the company 's ERT investment to be 11.8 years with a remaining life
expectancy of 2. 6 years and an average age of the surviving investment of 9. 4 years ( average
9.4 years + remaining life 2.6 years = useful life 11 .8 years). In negotiations with !PUC Staff
the ERT service life for depreciation was established at 15 years despite the Company's plans
and the fact that those plans produced the proposed 11.8 year service life.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 132: In 2014 Intermountain Gas began replacing the 40G ERTs with a
new 1 OOG ER T 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 1 OOG ER T 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.
RESPONSE TO REQUEST NO. 132:
Based on the settlement reached with IP UC Staff the service life for the development of
the depreciation rate of the 1 OOG ER Ts is 15 years. Based on historical experience concerning
Itron 's life expectancy estimates:
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 2
Table #132
Circa ltron's ERT Useful Life ERT's Actual Life Ratio of ltron's ERT
Expectancy Expectancy Life Expectancy to
Actual Life
Expectancy
2002-2003 17 years 11.9 years 0.70
2013 20 years Anticipated Life Using 0.70
Expectancy 14 years {20
years* 0.70)
The JOOG ERTunit's depreciation rate is 14.22%. Itron is working on a 500G ERT
module, which also has a 20 year battery life. The 500G is the next generation ERT and is just
starting production with availability in 201 7.
Record Holder:
Location:
Sponsor/Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
Hart Gilchrist, 208-377-6000
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?
RESPONSE TO REQUEST NO. 133:
Although cost was a factor in the 40G ERT replacement project, it was not the sole
consideration. JGC did not consider battery replacement as an option for many reasons, the
most compelling being that the 40G ERT has a design life of 20 years. This would mean that
replacing the battery would only add approximately 5-6 years to the life of the ERT.
Compounding this is the fact that battery replacement is costly.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 3
When reviewing the cost comparison of a battery replacement program vs. replacing the
ERT with a new 1 OOG ERT Intermountain found that the cost is comparable or even less to
install a new ERT The average cost to replace the 40G ERT with a 1 OOG ERT is approximately
$64/unit-(based on Itron contract values).
The cost to replace a battery is comparable or more because the labor cost estimated to
replace a battery is at least three times what it takes to swap out an ERT The process to replace
a battery is extensive involving digging a battery out of a silicon encased compartment and
cleaning a circuit board and rewiring a new battery and then adding back silicon (See diagram
below). Labor alone would push the cost of replacing the batteries to close to $60/unit. When
the cost of the battery replacement kit of around $10 was added in, replacement did not make
good business sense.
Battery Replacement Images
The original 40G Legacy ERT project was implemented in 2002-2003. This original AMR
project increased JGC meter reading efficiency and had a 5-year payback and AMR continues to
provide efficiency gains.
The primary drivers for replacement of the legacy 40G ERTs is that they are nearing the
end of battery life (12-15 years), and were no longer being manufactured. Waiting for 40G ERTs
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page4
to fail before replacement would cause an increase in billing adjustments, billing errors,
estimated usage and all the administrative work to ensure customers understood how their bill
was affected. Proactively replacing the 40G ERT before failure, increased replacement
efficiency and overall customer satisfaction.
Battery replacement of the 40G was not a viable option; as the design life on the 40G
was 20 years, the new battery would outlive the life of the unit. Additionally, a portion of the
40G ERT population contains a small amount of mercury, so the retiring and proper disposal of
the entire unit reduces the chance mercury could spill into the environment. Finally, as
mentioned previously, the battery replacement process was difficult and time consuming. In
summary, the time and money invested in battery replacement was significant and provided no
long term benefit.
Proactively replacing the 40G ERT with a 1 OOG ERT provides several advantages. The
bubble up mode with the 1 OOG model allows for a longer battery life, and the higher power
allows for greater distances to read ERTs. The 20-year battery life matches the design life and is
mercury free. The updated housing optimizes antenna performance and maximizes RF signal.
Installation is easier than the legacy 40G ERT because of an improved wriggler design. The
1 OOG ERT's biggest benefit is the ability to work on a fixed network meter reading system.
Intermountain is planning to phase in a fixed network for meter reading over the next 2-5
years. This fixed network allows for meters to be read at any time from fixed locations
throughout the service territory. This allows for improved efficiency in reading meters in two
primary ways. The first is the reduction of 90-95% of our current mobile meter reading drive
routes. The second is the elimination of service trips for reading meters when customers move in
and out of homes. Additionally, real-time meter read data analytics allow for improved
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 5
business decision making regarding customer usage. Finally, the estimated overall increased
efficiency of fixed network results in a 10-12 year payback on the fixed network investment.
It was because of all of these advantages that Intermountain made the decision to replace
the 40G ERTs.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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?
RESPONSE TO REQUEST NO. 134:
The Company utilizes the following sub-accounts for ERTs: 381.2 -ERT Units and 382.2 -
ERT Installations.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 135:
Please see confidential file labeled "PR 135 Itron Equipment Sales and Professional
Services Agreement." Costs are booked as referenced in PR#134, sub-accounts for ERTs: 381.2 -
ERT Units and 382.2 -ERT Installations.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 6
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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.
RESPONSE TO REQUEST NO. 136:
Intermountain Gas Company does participate in a rebate program. Corporate receives
the rebate annually and distributes it to the subsidiaries based on dollars of expenditure. The
amount is eventually posted as a reduction of supplies expense.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 137:
Please see Confidential attached file labeled "PR#13 7-Consultants and Legal
Expenses " for details. Per 11/14/2016 teleconference with Staff, supporting documentation
(invoices, contracts and other detail supporting the transactions) will be provided during an on­
site audit for selected items.
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 7
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 138: Please provide your Uncollectible Expense percentage and show
how it was calculated for each year from 2010 through 2015.
RESPONSE TO REQUEST NO. 138:
Please see file folder labeled "PR #138 Bad Debt."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
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.
RESPONSE TO REQUEST NO. 139:
The allocation manual in Dedden Exhibit 10, describes the different types of corporate
allocations. The occupancy reimbursement files are the ones where each utility charges a return
on invested capital. Please see file folder labeled "PR 139 "for all three companies' occupancy
reimbursement calculations. Jntermountain Gas Co. (JGC) charges Cascade Natural Gas Corp.
(CNG) and Montana-Dakota Utilities (MDU) for the Customer Service Center as well as space
used in the General Office for shared departments. CNG charges MDU and JGC for space used
in the General Office for shared departments. All three companies allocate the shared space
based on customer counts.
The MDU occupancy reimbursement file includes a section for MDU and a different
section for MDU Resources (MDUR). The MDU section charges for space for shared employees
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 8
including executives, information technology, GIS, gas supply, accounts payable, etc. It also
charges for utility shared assets, which are the servers on MDU 's books for the benefit of the
Utility Group. The last item charged in the file by MDU are FutureSource costs, which is the
corporate company that holds the land, building and aircraft for the corporation on its books.
The MDUR section includes charges at MDU that serves MDUR and needs to charge all
companies, including a portion to JGC The building charges includes building and grounds, the
print shop and the mail room, which are all housed at MDU but serve the entire MDU Resources
Corporation. The Office Services charges are the printing costs and are allocated based on the
number of impressions; JGC receives 1% of those charges. Power Plan is primarily a Utility
software, but it is used by MD UR for budgeting and tax and therefore a portion is charged to all
affiliated companies.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 140:
MDU Resources allocates corporate overhead based on each of its business unit's
corporate allocation factor. The corporate allocation factor is determined by the relative
capitalization of each business unit as a percentage of overall capitalization of MDU Resources.
Intermountain 's corporate allocation factor -which reflects the Company 's capitalization
relative to MDU Resources ' other business units -is 8. 9 percent. This percentage is based on
capitalization as o/9/30/15. MDU Utilities Group accounts for 51.3 percent of overall
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 9
capitalization. Please see file labeled "PR #140 Corporate Overheads " to find the calculation
(27. 7% + 23.6% = 51.3%). When costs are allocated to the MDU Utilities Group,
Jntermountain 's share of the 51. 3% of allocated costs is 17. 4% percent based on its
capitalization relative to MDU Resources ' other utility brands, or a total of 8. 9% of MDU
Resources (51. 3% X 17. 4%). Please see file labeled "PR # 140-UG Capitalization. "
Because MDU Resources does not maintain its own books separate from MDU, MDU's
books includes MDU Resources' investments in its subsidiaries, Centennial Energy Holdings
(WBI Holdings, FutureSource, Knife River, and Construction Services Group) and MDU Energy
Capital (Cascade and lntermountain). In calculating the corporate overhead allocation factors,
the MDU Resources investment in subsidiaries is removed to determine the stand-alone utility
capital investment amount. The capital investments in lntermountain -along with the other
subsidiaries' capital investment amounts -were used to calculate the corporate overhead
allocation factors.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 141:
Please see file folder labeled "PR # 141 Allocated Costs. "
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page IO
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:
• Customer Services, Director:
o 35% CNG, 30% IGC, 35% Montana-Dakota/Great Plains
• Customer Services, Management team Supervisors:
o 30% CNG, 30% IGC, 40% Montana-Dakota/Great Plains
• Customer Services, Management team Manager:
o 30% CNG, 20% IGC, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Manager:
o 20% IGC, 30% CNG, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Team Leads:
o 25% IGC, 25% CNG, 50% Montana-Dakota/Great Plains
• Scheduling, Management Team, Employees that Schedule both IGC and CNG:
o Split Evenly
• Scheduling, Management Team, Employees that Schedule all brands:
o Split Evenly
• Customer Programs & Support, Manager:
o 30% IGC, 30% CNG, 40% Montana-Dakota/Great Plains
• Customer Programs & Support, Supervisor, Team Lead, And Support Staff:
o Equal portion allocated
RESPONSE TO REQUEST NO. 142:
Please see file labeled PR #142 CSC Allocation.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 143:
Please see file labeled PR #143 CSC Costs.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 11
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 144:
All job classifications referenced in Request #142 are salaried employees where no time
cards are used to track time and therefore based on management's best evaluation of the team
category. Allocations are re-evaluated at the beginning of every year and changes made if any
allocation has changed.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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 ofretirement contributions for each of the sources listed above.
RESPONSE TO REQUEST NO. 145:
Please see the Company 's employer match, retirement contribution and 1 % profit
sharing payout for years 2010-2015 below.
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 12
Eme_/o'f_ee
Match
2010 $191,318
2011 $205,847
2012 $197,111
2013 $212,225
2014 $235,015
2015 $254,837
Record Holder:
Location:
Sponsor/Preparer:
Retirement Profit
Contribution Share
$515,841 $0
$370,752 $73,099
$350,703 $0
$370,251 $73,441
$405,994 $0
$443,591 $0
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 146: Please explain how the Company allocated forecast consumption
and consumption adj ustments to rate blocks. Please include all relevant data and workpapers.
RESPONSE TO REQUEST NO. 146:
Forecast consumption for GS-10, GS-I I, GS-60, and IS-Con Exhibit No. 15, page 8 was
spread to the relevant rate blocks using historical rate block percentages. The historical
percentages were derived from the Company's billing system. Please see the folder labeled "PR
# 146 -GS Block %s, "for the Excel and PDF files supporting the calculation of the historical
percentages.
Actual consumption and weather migration adjustments were spread to the relevant rate
blocks based on percentages derived from the Company 's billing system. Please see the response
to Request No. 150 for a discussion of how customer migration adjustments were determined.
Please see the folder labeled "PR #146 -GS Blocks Actual Months " for the Excel and PDF files
supporting the calculation of the consumption adjustments by rate block.
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 13
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Jacob Darrington, 208-3 77-6000
REQUEST NO. 147: Please explain how the Company determined forecast demand and
demand adjustments by class. Please include all relevant data and workpapers.
RESPONSE TO REQUEST NO. 147:
To forecast demand that was used in developing the demand charge component of the
proposed LV-1 and T-4 prices, lntermountain used the most current Contract Demand included
in these customers ' current contracts or contracts in process with the Company. T-4 and T-5
Contract Demands were combined to create the contract demand for the new T-4 class. The
demandforecast is included as "PR #147 Contract Demand".
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
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.
RESPONSE TO REQUEST NO. 148:
In determining normalized customer counts on Exhibit No. 15, page 10, the Company
began with customer counts from the Company's billing system. Please see the file labeled "PR
113& 114 2016 Billing Data," as provided in response to Request Nos. 113 & 114.
The Company then used the June ending customer count balances as the beginning
balance for July and added in the Company 's monthly customer growth forecast. The
Company's customer growth forecast for the RS-1, RS-2, and GS-JO & 11 customers is prepared
by the Manager of Energy Utilization with inputs from an economic forecast prepared by John
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 14
Church as well as historical penetration rates. Forecasted customer counts for the GS-12 CNG
Compressor customers were based on the prior year counts. Forecasted customer counts for the
GS-60 Irrigation customers were based on a historical average. Forecasted customer counts for
the IS-R Residential Snowmelt and IS-C Commercial Snowmelt customers were based on the
June 2016 balances. Please see the file labeled "PR # 148 Customer Forecast" for the customer
count forecast.
After actual and forecast customer counts have been determined, the Company then
adjusts these count balances for customer migrations between rate classes. Please see the
response to Request No. 150 as it relates to Customer Migration Adjustments.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Jacob Darrington, 208-377-6000
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."
RESPONSE TO REQUEST NO. 149:
The marginal rates are the "Distribution Cost" for April through November and
December through March taken directly from Intermountain 's applicable tariffs. An adjustment
for lost gas, as illustrated on Exhibit No. 15, p. 9, Column (i), was applied to the Distribution
Cost to arrive at the marginal rates noted in "Exhibit 24, 27, 28/Current Therms, Cust, Revs".
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
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.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 15
RESPONSE TO REQUEST NO. 150:
Customer rate class migrations relate to the Company 's general service, large volume, or
transport customers who have changed rate classes at some point during the test year. The
Company removed these customers' actual and forecasted volumes, revenues, and cost of gas
from the customer 's previous rate class and included them for a full twelve month period in the
customer's new rate class. Please see the file labeled "PR#150 Industrial Migrations Summary"
for a summary of the migrations that occurred during the test year.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Jacob Darrington, 208-377-6000
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.
RESPONSE TO REQUEST NO. 151:
Please see CD file labeled "PR 151 Billing Register Oct 2002-2014." Thisfile includes
the monthly customer count and consumption data for the period of October 2002 through
December 2014. Prior to October 2002, the requested data is not available electronically.
However, the large binders containing billing datafrom 1989 through September 2002 are
stored on-site in Intermountain 's vault. Intermountain stands ready to set up an on-site visit for
Staff where this data could be reviewed. The data for 2015 -2016 was submitted in response to
PR 113 and 114 (see "PR 113 & 114 2015 Billing Data" and "PR 113 & 114 2016 Billing
Data.'').
Some changes in Intermountain's rate classes will be noted over time in reviewing the
electronic data. In 2008, Intermountain cancelled its T-1 and T-2 Industrial tariffs. The
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 16
customers that were previously on the T-1 tariff were rolled into the T-4 class, and the customers
that were previously on the T-2 tariff were moved to the new T-5 tariff In 20 I 0, the Company
added residential and commercial snowmelt tariffs. Existing customers with snowmelt
equipment were grandfathered onto their existing rate schedules.
Over the time period of 1989 through 2016, lntermountain has made several changes in
Customer Information Systems (CIS). Each CIS conversion has brought with it a new definition
of customers and different ways that the data could be reported and analyzed.
The Legacy CIS system, which was in place prior to July 2004, counted customers as
each account that received a customer charge. Adjustments were done in the customer's billing
cycle, so there were no out of cycle adjustments sent.
With the migration to the Customer Watch system in July of 2004, the customer count
was based on account package. This meant that each customer that received a customer charge
or gas charge at a premise during the month counted as a customer. In addition to regular
monthly billing, if the customer at a premise was billed again with a different rate or Inside City
Limits/Outside City Limits this would add one to the customer count. In the Customer Watch
system adjustments were called cancel/rebills. Cancel/rebills were processed and billed as they
were discovered, and not necessarily with the normal monthly billing.
In July of 2015, lntermountain migrated to the CCB billing system. In this system,
customer counts are based on metered services with an active utility service agreement on a
given date, normally at accounting month end. Cancel/re bills can also be processed out of cycle
in this system, so there can be adjustment therms included in a different cycle from the cycle in
which the customer is normally billed, however, these would not affect the customer count.
In 2002, lntermountain established a database ("Weather System'') to house data used in
forecasting and weather normalizing usage. This separate database allowed lntermountain to
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 17
establish parameters for usage per customer data that were different from those reported in the
billing data. It also replaced an old main-frame system that was used to weight the weather data.
As the Company has made decisions about the data included in the Weather System, the guiding
principal has been that since we are using the equations that result from this data to measure a
customer's response to temperature, an accurate matching of customers, usage and weather is
important.
The Weather System only includes data for customer classes that are considered
temperature sensitive. The classes included are:
• RS-I
• RS-2
• GS (excluding CNG (GS-12) and water pumper (GS-60) customers)
It does not include any industrial customers or snowmelt customers.
Intermountain's Weather System counts customers based on account in CC&B, premise
in Customer Watch, and premise in Legacy. The common element between these 3 definitions is
that there was a bill associated. The Company felt these customer definitions provided the most
continuity between the CIS systems. Adjustments (or cancel/rebills) have also been removed
from the Weather System data. The idea here is that adjustments hit in a single month, but may
have been caused by several prior months. Removing the adjustment altogether ensures that the
Company is measuring the true customer response to temperature, and that an extraneous event
does not unduly influence that match.
Finally, with the implementation of Customer Watch, the Company had the ability to
restrict the customer count to only count those customers that had therm usage each month on
their bill. This gives a true measure of a customer 's response to temperature and allowed the
Company to more accurately forecast usage in the summer months.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 18
Although lntermountain has data available back as far as 1989, because of structural
changes in the way customers use natural gas over time and the way data is collected,
lntermountain decided to restrict the time series used to generate regression equations that are
used for weather normalization and usage forecasting to October 2003 -December 2014.
Several notable structural shifts have occurred in the data over time. First, new building
codes and efficiency factors have been implemented throughout Idaho. The Idaho Residential
Energy Code was adopted by many cities beginning in 1991. This new building standard was
designed to improve the energy efficiency of new homes. In addition, efficiency standards for
furnaces and water heaters began to improve during the late 1980 's. Although these standards
only applied to new homes and new purchases, lntermountain has seen tremendous growth in its
customer base since that time. Over 60% of its customers are new since 1990. These customers
would be using the new standards and equipment, and as they become a larger percentage of the
customer base, they have had a gradual impact on therm usage per customer.
Further, price stability has changed dramatically over time. Until 1999 there was a
period of relatively stable prices. Beginning with the prices effective in August 1999, however,
the country entered a period of extreme price volatility with a generally increasing price trend.
It appeared that prices reached a new equilibrium around 2003, following the transition to this
new price environment. Because all of these factors would cause a shift in the data,
lntermountain chose to shorten the time series upon which the regression equations are built to
11 years of data.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 19
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.
RESPONSE TO REQUEST NO. 152:
To clarify, it is not the Company 's position that every new customer causes the
Company to add new distribution, transmission and storage resources equivalent to the
RS and GS-I Margin. Rather, as explained in the testimony of Michael McGrath, the
margin that the Company relies on to pay for the Company 's fixed costs to (1) operate
and maintain its system and (2) expand its distribution system has been declining over
time, as our customer 's homes and businesses continue to use progressively less natural
gas as a result of revisions to building code standards, more efficient appliances as well
as other customer behaviors that conserve energy. While the Company 's proposal to
implement a Demand Side Management (DSM) program adds measurable value to our
customers and the environment, these same DSM programs will, nonetheless, exacerbate
an already decreasing usage, and therefore margin, per customer. The FCCM that the
Company is proposing will allow the Company to effectively promote and advocate for its
proposed DSM program without the financial disincentives that currently exist, with
margins directly connected to sales volumes.
That is, to have a reasonable opportunity to earn a fair return, the Company relies on
modest growth in margins to offset increased costs associated with inflation, replacing aging
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 20
portions of its distribution system, and additions to new distribution, transmission and storage
resources to provide natural gas service to new customers. Jntermountain recognizes that in
addition to modest growth in margins, in order to have a reasonable opportunity to earn a fair
return, utilities must also manage costs that are under its control. The Company 's proposed
FCCM will provide for growth in margins at the growth rate in the number of customers -no
more and no less.
As the analysis prepared in response to Production Request No. I 53 illustrates (see file
labeled "PR 152 & 153 FCCM Analysis", tab "PR 152 Summary"), customer growth is a very
small factor in the amount of the margin surplus or deficiency to be trued up via the FCCM
mechanism. By way of example, the margin variance due to customer growth for RS-2 would
have only averaged 4. 7% of the total variance for the 2013 -2015 historical time period.
Furthermore, the Idaho Public Utilities Commission determines the "approved total
revenue requirement" for the rate case test year. There is no expectation or requirement in
standard ratemaking process as practiced by the !PUC and other state regulatory agencies that
distribution revenue will not exceed, or be less than, the approved total revenue requirement in
the years following a rate case. Under the Company 's FCCM proposal, when the approved
margin per customer exceeds that allowed for in the Case, customer refunds will be provided
and, conversely, when the approved margin per customer is less than that allowed by the Case,
temporary price increases would be implemented. The proposed FCCM is necessary and
appropriate to counter the decline in the Company 's distribution margins that has been caused
by customers' conservation activities, and which will be exacerbated by the Company's
proposed DSM program.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 21
As specified in the Company 's proposed Rate Schedule FCCM, Exhibit No. 31, pages 13
-16, annually, the Company will make a FCCMfiling. Included in the filing will be actual
(verified) distribution revenues recovered in the prior year.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
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.
RESPONSE TO REQUEST NO. 153:
Please see file folder labeled "PR #152 &153 FCCM Analysis." This file shows the
FCCM calculation for 2013 -2015 based on current rates (blue tabs) and proposed rates (green
tabs). The analysis illustrates that the FCCM adjustment will be much lower under our
proposed rate structure where more of the customer related costs are collected via the customer
charge than the per therm charge.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
REQUEST NO. 154: Ms. Spector states on page 21 of her testimony that preliminary
estimates of rebate 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.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 22
------!
I
RESPONSE TO REQUEST NO. 154:
The volume of rebate expenditures per measure will ultimately depend on the individual
measure-mix selected by Jntermountain customers. While the Company anticipates strong
participation from both local builders, and HVAC customers seeking high efficiency natural gas
upgrades, we have not assigned specific achievement estimates on a measure-by-measure basis.
Instead, the Company has assumed that about 450 measures will be installed in total as a result
of this program in the first year, and this mix will comprise a range of portfolio measures.
Following on-the-ground findings from the first full program year, Jntermountain will refine its
estimates on a measure-by-measure basis based on actual program results.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Alison Spector, 206-310-1120
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.
RESPONSE TO REQUEST NO. 155:
For clarification, the word "achievable" was a typo on page 20 of Ms. Spector 's
testimony. The Company intended to characterize this refined level of therm savings as
"programmatic. "
Therm savings for all measures associated with the Company 's residential DSM rebate
portfolio can be found in Exhibit 26 under the testimony of Ms. Spector under lines E-20 through
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 23
E-26. The estimated 65,000 target anticipates that a varied mix of portfolio measures will be
installed (with HVA C and Energy STAR homes anticipated to be of greatest interest). The first
year target takes a conservative approach, assuming an average per-measure savings of
approximately 140 therms with about 450 measures installed in the program year. The target
was then rounded up to an even 65,000. This is a preliminary estimate that will be refined based
on actual on-the-ground program findings at the end of the first program year.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Alison Spector, 206-310-1120
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.
RESPONSE TO REQUEST NO. 156:
The cost-effectiveness threshold set for this program reflects the following inputs:
Commodity Cost of Gas (WACOG) = $0.32764
Fixed Cost of Gas (pipeline + storage, fixed + commodity) = $0. 20418
Total= $0.53182
Documentation of the process used to determine the avoided cost can be found in CD file
labeled "PR# 156-AvoidedCosts."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Alison Spector, 206-310-1120
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 24
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.
RESPONSE TO REQUEST NO. 157:
When lntermountain was designing the FCCM, a variety of alternative approaches were
considered and subsequently ruled out because they did not meet the Company's objective of" ...
break(ing) the link between Jntermountain's (a) margin from its residential and commercial
customers and, (b) the natural gas deliveries to these same core market customers."
Specifically, lntermountain reviewed a recent survey of decoupling-type mechanisms that
have been implemented by gas distribution companies in the US. That survey indicates that (1)
"per customer " mechanisms, such as the Company's proposed FCCM, have been implemented
by many gas distribution companies and (2) few, if any gas distribution companies have
implemented alternative approaches, such as partial decoupling. At the time of the survey, 51
gas distributors in 22 states had decoupling mechanisms similar to the Company's proposed
FCCM Of the 51 decoupling mechanisms, 3 7 were very similar to lntermountain 's proposed
FCCM in that they are per customer mechanisms. The remaining 14 gas distributors had total
revenue decoupling mechanisms that provide for actual revenues to be trued up to allowed
revenues on an annual basis.
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 25
The Company did not propose a "Lost Revenue " mechanism1 because, as indicated in the
survey of decoupling mechanisms that we reviewed, Lost Revenue mechanisms are not in
common use by gas distributors. Also, Lost Revenue mechanisms do not address the issues that
are most important to the Company as described in the testimony of Michael McGrath.
Specifically, that the margins Intermountain relies on to pay for the fixed costs to operate,
maintain, and expand its distribution system have been declining over time, as customer 's homes
and businesses continue to use progressively less natural gas as a result of revisions to building
code standards, more efficient appliances, and other customer behaviors that conserve energy.
While the Company 's proposal to implement a Demand Side Management (DSM) program adds
measurable value to our customers and the environment, these same DSM programs will,
nonetheless, exacerbate an already decreasing usage, and therefore margin, per customer.
Lastly, the industry 's prior experience with Lost Revenue mechanisms demonstrated that
estimates of lost revenues due to DSM program savings require significant detailed data and rely
on assumptions and estimates that can be subjective and difficult to validate.
The Company did not propose a partial decoupling mechanism because such a
mechanism (1) is not in common use and (2) would not provide the Company with the revenues
that it requires to operate, maintain and grow its system.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Mike McGrath, 208-377-6000
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
Lost Revenue mechanisms allow for the recovery of fixed cost revenues that have been "lost" through
actual energy savings from Demand Side Management programs.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 26
Rebate under current Schedule ER. How many participants were new customers and how many
were existing customers?
RESPONSE TO REQUEST NO. 158:
All participants in the Residential Space Heating Equipment Rebate under current rate
schedule ER were new heating customers.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 159:
Bil!Matrix was our third-party vendor for handling credit and debit card payments until
the end of 2015. Bil!Matrix offered payments via Credit, Debit/ATM or Electronic Check (ACH).
Payments could be submitted on the web, through an automated IVR (phone) or directly with an
agent.
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 27
Since we no longer have a business relationship with BillMatrix we do not have access to
history data that gives detail of the method and channel the customer used to make a payment.
Through analysis we conducted in October 2015 we determined 67. 5% of payments
through BillMatrix were made via credit card, 25.5% Debit/ATM and 7% were ACH Most of
those payments were made through the IVR (63%), with 29% made through the web and 8%
made directly with a customer service agent.
T IP ota ayments Md h a et roug h B' IIM . (' I d Credit, Debit/ A TM and ACH) I atnx me u es
2014 2015 YTD 2016
163,597 144,625 n/a
With the change to SpeedPay as our Credit/Debit vendor in March of 2016, we now have
metrics that allow us to identify the method and the channel the customer uses to pay via
SpeedPay. Additionally, due to Payment Card Industry standards we ceased taking agent
assisted payments over the phone in January 2016. The customers still have the option of the IVR
and the web.
T IP ota h h S dP ayments t rougi ,pee C d' /Debit/ATM via the IVR av usmg re 1t
2014 2015 YTD2016
n/a n/a 72,433
b. Payment by phone via checking/savings account withdrawal;
usin ACH via the IVR
YTD 2016
n/a n/a 9,003
c. Payment online via credit/debit cards;
Total a ments throu h S eedPa usin Credit/Debit/ A TM via the web
2014 2015 YTD 2016
n/a n/a 7,586
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 28
d. Payment online via checking/savings account withdrawal;
Total a ments throu h S eedPay usin ACH via the web
2014 2015 YTD 2016
n/a n/a 600
Customers may also elect to schedule a payment directly through our website by creating
a username/password and entering the checking account information.
Pa ments made direct! throu hour customer website via ACH:
2014 2015 VTD 2016
582,286 667,166 627,596
Banks and other financial institutions offer bill-pay on their websites and transact those
payments through an electronic vendor. These are payments made online directly to those
vendors or through one of their contracted partners.
2014 2015 YTD 2016
CheckFree 552,618 532,265 253,762
Metavante 161,284 107,002 99,297
Online Resources 87,737 90,955 235,867
iPay 130,927 177,058 139,034
e. Automatic withdrawal from the customer's financial institution;
2014 2015 YTD2016
582,286 667,166 627,596
f. Payment at authorized Western Union pay stations;
2014 2015 YTD2016
94,891 94,686 72,483
g. Payment at unauthorized pay stations;
Payments at an unauthorized pay station are not able to be tracked. These payments
come to us through several different payment sources. Some locations use an existing electronic
payment relationship and payments come through mixed in with others in that file. For example,
RESPONSE OF JGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 29
payments made at Wal mart are remitted through Checlifree and are part of the payment file that
includes payments where customers pay at their bank that has also partnered with Checkfree.
Other unauthorized locations do not have an electronic payment partner and in turn, they
mail a check that is handled through our daily remittance process.
h. Payment by mail;
2014 2015 YTD2016
1,241,078 1,188,529 956,083
i. Payment at drop boxes; and
Drop boxes are located at company offices throughout the state
2014 2015 YTD 2016
26,724 20,447 14,992
j. Other payment methods, if any.
Payments received via electronic file from LIHEAP/Energy Assistance
2014 2015 YTD2016
9,935 10,629 1,159
*LIHEAP benefits are distributed during the heating season October through March. The bulk of
customer benefits are granted early in the heating season. The YTD figures for 2016 include
payments received from January to March during the 2015-2016 heating season.
Payments made directly to third-party collection agencies
2014
2,784
Record Holder:
Location:
Sponsor/Preparer:
2015 YTD2016
1,741 1,212
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
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
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 30
provide the cost Intermountain Gas would incur if it paid for handling its customer's pay station
transactions.
RESPONSE TO REQUEST NO. 160:
The $1 convenience fee for payments at an authorized Western Union Convenience Pay
location is a direct pass-through of the costs associated with transacting a walk-in payment. The
fee is paid direct to Western Union and Intermountain only receives the amount of the payment
directed toward the gas bill.
If Intermountain were to incur the cost, Western Union would pass on charge of the $1
fee per transaction.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 161: Please provide a copy oflntermountain Gas' contract with
Western Union for handling payment transactions.
RESPONSE TO REQUEST NO. 161:
Please see Corifidential CD file labeled "PR 161 MDU Resources Group Amdl."
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
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.
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 31
RESPONSE TO REQUEST NO. 162:
The CD file titled "PR 162 Active Agents" shows the active Convenience Pay locations that
are authorized to accept Intermountain Gas payments. Our website is also updated monthly to reflect
locations that are available. https://www.intgas.com/customer-service/pay-locations
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
DATED at Boise, Idaho, this 15th day of November, 2016.
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 32
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 15th day of November, 2016, I caused to be served a
true and correct copy of the Response of Intermountain Gas Company to Seventh 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 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
[gJ Electronic Transmission
D Hand Delivery
[gJ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[gJ Electronic Transmission
D Hand Delivery
[gJ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[gJ Electronic Transmission
D Hand Delivery
[gJ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[gJ Electronic Transmission
D Hand Delivery
[gJ US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
[gJ 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: kmiller@ snakeriveralliance.org
2
D Hand Delivery
t8J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
t8J Electronic Transmission
t8J Electronic Transmission
D Hand Delivery
t8J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
t8J Electronic Transmission
D Hand Delivery
t8J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
t8J Electronic Transmission
D Hand Delivery
t8J US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
t8J 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: Andrew. [e-mail]
Lanny .zieman. l @us.af.mil
N [e-mail]
Thomas.j ernigan. [e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
D Hand Delivery
1:8] US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
1:8] Electronic Transmission
Ronald L. Williams