20161229INT 1-71 to Staff.pdf

WILLIAMS BRADBURY
AT TOR NE Y S AT L A W
20i&DEC 29 PM 3:49
December 29, 2016
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE : IGC First Production Request to Staff -Case No. INT-G-16-02
Dear Ms. Jewell:
• -I '_i..3LiC
···-~ C'dM IS.:ION
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's First Production Request to the Commission Staff.
Sincerely,
~~'vi/AA--
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [phone] -www.williamsbradbury.com
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
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
FIRST PRODUCTION REQUEST
OF INTERMOUNTAIN GAS
COMPANY TO COMMISSION
STAFF
Intermountain Gas Company ("Intermountain" or "Company"), a subsidiary of MDU
Resources Group, Inc., by and through its attorney of record Ronald L. Williams and pursuant to
the Rules of Procedure of the Idaho Public Utilities Commission ("Commission"), hereby
requests that the Staff of the Idaho Public Utilities Commission ("Staff') provide the following
documents and information as soon as possible, and no later than Thursday, January 19, 2017.
This Production Request is continuing, and Staff is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, and supporting work papers that provide detail
or are the source of information used in calculations. Responses pursuant to Commission Rules
of Procedure must include the name and phone number of the person preparing the document,
and the name, location and phone number of the record holder and if different the witness who
can sponsor the answer at hearing if need be. IDAPA 31.01.01.228.
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page I
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS TERRI CARLOCK.
REQUEST NO. 1. Referring to page 4 of Ms. Carlock's direct testimony, has Ms.
Carlock or any member of the Commission Staff within the last 10 years supported the position
that cash working capital is or should be included in ratebase. If "yes", please provide case
references or copies of such testimony.
REQUEST NO. 2. Referring to lines 9 -11 on page 5 of Ms. Carlock's direct
testimony, if a cash working capital analysis does not adequately show that shareholders are
supplying cash, how does Staff propose that the determination of who is supplying cash funds for
operations be shown?
REQUEST NO. 3. If cash funds are used to provide service prior to the receipt of
customers' payments for such service, would this reflect a scenario in which shareholders are
supplying the cash for cash working capital? If not, please explain how such a scenario does not
represent shareholder provided funds for cash working capital.
REQUEST NO. 4. Referring to lines 13 -17 on page 5 of Ms. Carlock's direct
testimony, does Staff consider the inclusion of Inventories, Materials and Supplies and Gas
Storage Inventory in rate base a source of cash working capital? If yes, please explain the basis
for such a position.
REQUEST NO. 5. Does Staff believe that Intermountain Gas Company's billing
operations and collection practices are inappropriate? If yes, please provide a detailed
explanation of each aspect of the Company's billing operations and collection practices that Staff
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 2
believes are inappropriate, the changes that Staff believes need to be made, and the basis for that
op1mon.
REQUEST NO. 6. Referring to page 6, lines 6 through 9 of Ms. Carlock's direct
testimony, please provide a detailed explanation of what information Staff believes the Company
needs to provide to adequately show "that the source of the funds is truly supplied by the
Company shareholders".
REQUEST NO. 7. Referencing Request No. 6, please identify each rate proceeding
before the Commission within the last 10 years in which the utility was required to provide the
level of information suggested by Staff to demonstrate that the source of funds was supplied by
the Company's shareholders.
REQUEST NO. 8. For the period 2005 through 2015, please provide a list or table
showing the Returns on Equity (ROE) for each utility regulated by the Idaho PUC that includes
the following information: (i) ROE authorized by the Commission for the utility, and the year
and Case No. in which the authorization order was issued, (ii) the ROE percentage requested by
each utility in the case referenced, and (iii) Staffs recommended ROE percentage in the case
referenced.
REQUEST NO. 9. In each utility case Staff reference in response to Request No. 8
above, did any of the utilities have in place, or were authorized to put in place, rate decoupling
mechanisms? If "Yes", please list the utility, the proceeding, the decoupling mechanism and the
utility involved.
REQUEST NO. 10. In developing the 9.25% ROE recommendations (Carlock, T.(Di)
p. 3), what evidence did Ms. Carlock considered with regard to economic and capital market
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 3
conditions? Please provide the documentation relied on by Ms. Carlock in making this
recommendation.
REQUEST NO. 11 . Please provide the basis and all supporting documentation for Ms.
Carlock's recommendation (Carlock, T.(Di) p. 9) to reduce the authorized ROE for
Intermountain Gas Company by 25 basis points if the Commission adopts the proposed Fixed
Cost Collection Mechanism.
REQUEST NO. 12. Has Ms. Carlock performed an analysis of the proxy group
companies to determine if they have cost recovery mechanisms that are similar to the FCCM? If
so, please provide that analysis. If not, why not?
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS MICHAEL MORRISON.
REQUEST NO. 13. Please define "average weather year" as found in Dr. Morrison's
Direct Testimony Page 18, Line 23.
REQUEST NO. 14. Please provide copies of the data, workpapers, models and
calculations used to replicate the Company's test year calculations (Morrison Direct, Page 20,
Lines 11 through 16). Also provide all results of the calculations and support for the statistics
cited ("The Company's GS-I model predicted test year consumption that was 79% higher than
its GS-I customers actually consumed"). The information should be provided in Excel format
with all formulas intact.
REQUEST NO. 15. Please provide the consumption and HDD data used to generate
Figure I on Page 21 of Dr. Morrison's direct testimony. The information should be provided in
Excel format with all formulas intact.
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 4
REQUEST NO. 16. Please provide all copies of workpapers and analysis that support
Dr. Morrison's conclusion on Page 22, lines 2 -7, that "The consumption of these subclasses
differ sufficiently to warrant separate treatment." Also provide a description of your
understanding of what makes up the subclasses listed.
REQUEST NO. 17. Please provide copies of the data, workpapers, models and
calculations used to create Dr. Morrison's normalized consumption estimate, noting the time
period used to develop the estimate (Morrison Direct, Page 23 , Lines 18 through 24). Also,
provide all results of the calculations and support for the statistics cited. The information should
be provided in Excel format with all formulas intact.
REQUEST NO. 18. Please provide the starting list of variables for backward
regressions (see Morrison Direct, Page 22, Line 20).
REQUEST NO. 19. Please provide any and all evidence showing the forecasting
accuracy of Staffs models for each customer class. Specifically, please provide a comparison of
Staffs monthly consumption forecasts for 2016 compared with actual consumption. Provide
documentation showing how Staffs forecasts were computed for each customer class. The
information should be provided in Excel format with all formulas intact.
REQUEST NO. 20. Please provide Exhibit Nos. 110 and 111 as well as any supporting
workpapers necessary to derive the Exhibits in electronic format with all links activated.
REQUEST NO. 21. Please provide copies of testimonies from each Commission
proceeding in which Dr. Morrison provided testimony on weather normalization.
REQUEST NO. 22. Please provide copies of testimonies filed by Commission Staff,
other than Dr. Morrison, in each rate proceeding within the last 10 years in which Staff has filed
testimony on Weather Normalization.
IGC FIRST PRODUCTION REQUEST TO THE COMMISSlON STAFF, Page 5
REQUEST NO. 23. Please provide a list of computer software used by the Commission
Staff over the past 30 years. Please also include dates of implementation and retirement, as well
as any analysis of or reports on compatibility issues experienced when upgrading to new
software.
REQUEST NO. 24. Referring to lines 6-7 on page 20 of Dr. Morrison's direct
testimony, please provide the basis and the support for the statement, "The use of autoregressive
terms in a predictive weather normalization model is inappropriate."
REQUEST NO. 25. For what statistics courses taken by Dr. Morrison and at which
universities he attended was Ramsey and Schafer's 1997 textbook, The Statistical Sleuth used as
the primary course textbook, (See Morrison Direct, Page 21, Line 24)?
REQUEST NO. 26. Please provide the documentation for how the GS-1 growth was
allocated to "subclasses" (see line 17-19, page 22 Morrison direct).
REQUEST NO. 27. Please define the term "robust" as used on line 4, page 23 of Dr.
Morrison's direct testimony.
REQUEST NO. 28. Please provide copies of testimonies from each proceeding in
which Dr. Morrison provided testimony on class cost of service studies for gas or electric
utilities.
REQUEST NO. 29. In any of these cases, has Dr. Morrison developed a comprehensive
cost of service model and presented that model before the commission for the purpose of
allocating rates among customer classes? If so, please provide that model in Excel format with
all formulas intact. If not, why not?
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 6
REQUEST NO. 30. Referring to lines 14 -21 , on page 4 of Mr. Morrison's direct
testimony do any of the natural gas utilities in Idaho conduct load studies for use in class cost of
service studies? Please list those utilities and provide copies of such studies?
REQUEST NO. 31. Is Dr. Morrison aware of any natural gas disturbing utilities in the
Northwest that have conducted load studies upon which class cost of service studies have been
based? If so, please list.
REQUEST NO. 32. Referring to lines 2 -5, on page 6 of Dr. Morrison's direct
testimony, provide a list of Idaho case references where non-coincident peak allocators were
used in the allocation of gas distribution plant.
REQUEST NO. 33. Referring to lines 16 -18, on page 12 of Dr. Morrison's direct
testimony. "By definition, mains serve multiple users, and so it is not appropriate to classify any
portion of the mains as customer-related costs." Please provide the source and the full
"definition" referred to in this statement. Can customers receive service without being attached
to the main? If not, why should costs associated with new main installations to serve new
customers be excluded from customer costs?
REQUEST NO. 34. On page 28, lines 8 -12 of Dr. Morrison's testimony, please
specifically identify data the Staff was not provided that would have allowed Staff to "fully
evaluate the Company's weather normalization methodology and its mains study."
REQUEST NO. 35. Does Dr. Morrison agree or disagree with the following section
from NARUC's 1989 Gas Distribution Rate Design Manual, pages 24 -24, where it states:
Demand or capacity costs vary with the size of plant and equipment. They are related to
maximum system requirements which the system is designed to serve during short intervals and
do not directly vary with the number of customers or their annual usage. Included in these costs
are: the capital costs associated with production, transmission and storage plant and their related
expenses; the demand cost of gas; and most of the capital costs and expenses associated with
that part of the distribution plant not allocated to customer costs, such as the costs associated
with distribution mains in excess of the minimum size?
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 7
Does Dr. Morrison believe he has applied the same guidelines in his testimony? If so,
please explain, and if not, why not?
REQUEST NO. 36. On pages 17 (lines 13 -25) and page 18 (lines 1 -12) ofNWIGU
witness Gorman's testimony, Mr. Gorman states that it is appropriate -and recognized by
NARUC -to allocate a portion of the costs of a distribution mains on a customer basis. Does
Dr. Morrison believe he has also followed the same NARUC guidelines in making his
recommendations, and if so, how? Does Dr. Morrison or Staff disagree with zero intercept
methodology? If so, on what basis?
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF WITNESS
RANDY LOBB
REQUEST NO. 37. In reference to the direct testimony of Randy Lobb, page 6 line 3, -
--"[A] long stay out without detailed, consistent record keeping" --what IPUC required records
were not kept by IGC? During the 30 year period did the Company fail to file any required
reports or prepare any IPUC required studies?
REQUEST NO. 38. Does Staff agree or disagree that the primary purpose of a cost of a
service (COS) study is to identify and to then eliminate or at least minimize cross subsidies
among customer rate classes? If Staff agrees with this COS purpose, is it Staffs position that the
Company's current cost allocations among rate classes that have been in place for 30 years better
eliminates or minimizes current cross subsidies between rate classes than the Company's
proposed cost of service study? Does Staff agree or disagree that a uniform percentage rate
increase keeps in place cost allocations that were established in the Company's last major rate
case, 30 years ago?
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 8
REQUEST NO. 39. If Staff believes that the Company's COS study was so flawed as
to render it unusable, why did not Staff present its own COS Study?
REQUEST NO. 40. In reference to Mr. Lobb's testimony at page 15, line 8 -that the
Company's ROE should be adjusted downward to reflect reduced risk if the Company 's FCCM
were implemented -please provide the basis for such a statement and any documentation and/or
studies supporting the statement.
REQUEST NO. 41. Please provide the list of"adjustments in customer and
consumption data" that made comparing and analyzing that data difficult as mentioned in Mr.
Lobb's testimony (page 5, lines 1 -4).
REQUEST NO. 42. Please provide a list of the underlying capital costs the Staff was
unable to evaluate, as discussed in Mr. Lobb's testimony (page 5, lines 8-11).
REQUEST NO. 43. On page 6 of his testimony, Mr. Lobb claims that the Company's
records were not detailed or consistent. Please provide specific examples where the Company's
records were not detailed or consistent. To which time periods does Mr. Lobb's testimony
apply?
REQUEST NO. 44. Testimony of Mr. Lobb, page 12 line 25 through page 13 line 4
states "Rather than reimbursing the Company for total fixed costs as approved by the
Commission in a general rate case, the Company collects through the FCCM, an additional level
of fixed cost per customer for each new customer added in between rate cases." How would
revenues generated from new customers be treated in a FCCM that trues up to a fixed revenue
amount established in a base rate case?
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS BARBARA ROMANO.
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 9
REQUEST NO. 45. Please provide the criteria Staff used for removing additional
expenditures, as stated in Ms. Romano's testimony on page 5 lines 2-5.
REQUEST NO. 46. When applying the percentage of Staff-identified disallowed actual
expenses (Q 1-3) to the future expenses (Q4), was seasonality of those disallowed expenses
taken in to consideration? If not, why not and if so, in what manner was it applied?
REQUEST NO. 47. Please provide Exhibit Nos. 101 and 102 in electronic format with
all links activated. Additionally, please provide the primary source data on which these Exhibits
were based.
REQUEST NO. 48. Please indicate which expenses on Exhibit No. 101, Schedule 3
were related to the enhancement of the Company's image. What criteria were used to
differentiate between advertising expenses that are includible in customer rates and advertising
expenses that enhance the Company's image?
REQUEST NO. 49. On page 8 of her testimony, Ms. Romano suggests that
Intermountain does not face any competition since it is a monopolistic utility. Please explain why
natural gas does not face competition as a heating fuel source.
REQUEST NO. 50. On page 8 of her testimony, lines 10-12, Ms. Romano states
"Chamber of Commerce expenses have been routinely removed from revenue requirement
calculations for Idaho's other utilities." Please provide copies of Commission Orders supporting
this claim.
REQUEST NO. 51. During her review of Company expenses, did Ms. Romano
differentiate between contributions made for charitable purposes and contributions made to
encourage economic development? Please explain.
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page IO
REQUEST NO. 52. What therm savings quantification methodology does Staff
recommend for natural gas market transformation efforts such as NEEA's and the existing
market transformation efforts the Company has engaged in with the Gas Technology Institute?
THE FOLLOWING REQUESTS RELATES TO THE TESTIMONY OF STAFF
WITNESS MARK ROGERS
REQUEST NO. 53. Please explain why Mr. Rogers believes that if the comparable
earnings standard is met, the financial integrity and capital attraction standard will also be met.
(Mark Rogers, Page 4, lines 21-25).
REQUEST NO. 54. Please provide a copy of the cited exhibit in Excel format with
formulas intact and copies of all workpapers and supporting data used in developing Exhibit No.
107.
REQUEST NO. 55. Please identify the one company in the proxy group referred to on
Page 8, line 25 thru Page 9, line 1 of the testimony of Mr. Rogers that does not pay quarterly
dividends.
REQUEST NO. 56. Is it Mr. Rogers' understanding that the earnings per share
estimates published by Zacks Investment Research and Thomson First Call are those of a single
analyst, or are they consensus estimates? (Mark Rogers, Page 10, lines 15-18)
THE FOLLOWING REQUESTS RELATES TO THE TESTIMONY OF STAFF
WITNESS JOSEPH TERRY
REQUEST NO. 57. Why does Mr. Terry recommend that BLS data for the state as a
whole be used, rather than BLS data from the markets that the Company has operations?
REQUEST NO. 58. Why is equal weighting ofBLS survey data to the Towers Watson
and Mercer surveys used?
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 11
REQUEST NO. 59. Was BLS survey data used for salaries in determining Idaho Power
Company 's, Avista's and or United Water's revenue requirement in their most recent ratecases?
REQUEST NO. 60. Please provide workpapers or other documentation relied on by
Mr. Terry in support of his testimony, page 10, lines 7 -9 referencing that bank fees are assigned
by Intermountain's parent company, MDU.
REQUEST NO. 61. Please provide workpapers or other documentation relied on by
Mr. Terry in support of his testimony, page 10, line 17 -18 that the "Company has not produced
any evidence on whether the bank fees were a reasonably incurred expense".
THE FOLLOWING REQUESTS RELATES TO THE TESTIMONY OF STAFF
WITNESS BENTLEY ERDWURM
REQUEST NO. 62. Please provide working copies of the electronic spreadsheet files,
with all formulas intact that were used to prepare Exhibits 112 through 117.
REQUEST NO. 63. Exhibit 112 page 1 of 2. Please provide documentation that labor
O&M is not inadvertently counted twice in this Exhibit. Specifically, are lines 21-35 already
included in lines 3-14?
REQUEST NO. 64. Exhibit 112 page 2 of 2, line 81 , "Weights are chosen to reduce
allocation to residential (for a conservative estimate)". Please explain the source for the
weighting factors. What cost allocation theory/methodology was used to support the weighting?
REQUEST NO. 65. Page 15, lines 7 -9. Please explain how Mr. Erdwurm
determined that basic needs are met with average monthly usage of 35 therms per month ( 420
therms per year). What gas equipment is included in basic needs usage? For each of the
following types of gas equipment, please provide the annual or monthly basic needs usage
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 12
associated with the following types of gas equipment: (a) Space heating, (b) Water heating, and
( c) Cooking.
REQUEST NO. 66. Page 17, lines 9 -11. Please describe how Mr. Erdwurm
evaluated the fairness of his proposed customer charges to (a) low use customers in each class
and (b) high use customers in the same class. Please provide copies of all workpapers, research
or analysis relied on in assessing the fairness of Staffs proposed customer charges on low use
and high use customers.
REQUEST NO. 67. Staff Testimony of B. Erdwurm, page 17, lines 1-13. Please
provide the customer charges for all classes and all peer utilities researched.
REQUEST NO. 68. Please provide all workpapers and documentation relied on in
support a demand charge of $0.20 per them, rather than that proposed by the Company.
(Erdwurm, p. 6, lines 3 -9) What effect will this lower demand charge have on high, medium
and low load factor customers?
REQUEST NO. 69. On page 19, line 19 -20, Mr. Erdwurm states that Staff supports a
more gradual phase-in of a nominated MDFQ demand charge. Please specify the phase in
period[ s] that Staff would support.
THE FOLLOWING REQUESTS RELATES TO THE TESTIMONY OF STAFF
WITNESS STACEY DONOHUE
REQUEST NO. 70. Is it Staffs position that the Company must first begin its
investment in DSM measures before it can propose a cost recovery measure related to DSM
investment? Does Staff believe it would be appropriate for the Company to establish a
Commission approved DSM deferral account related to DSM investments, for later rate recovery
of prudently incurred DSM costs?
IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 13
REQUEST NO. 71. What frequency ofEM7V is recommended by Staff in association
with the implementation of a DSM portfolio? At what phase in development of their programs
(preliminary residential and subsequent ramp-up of commercial program portfolio) should this
analysis be applied?
DATED at Boise, Idaho, this ~ q <?~ day of f)~ , 201 i.
Respectfully submitted,
/?AL VJlv-
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 14
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 29th day of December, 2016, I caused to be served
a true and correct copy of the First Production Request of Intermountain Gas Company to 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 83 720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 1 ih 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. 61h Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h 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)
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IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 15
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. 2ih Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
CompanyLLC
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 61h St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
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IGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 16
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLONJA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny .zieman. l @us.af.mil
Natalie. [e-mail]
Thomas.j ernigan. [e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
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Ronald L. Williams
JGC FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF, Page 17