20161230INT 1-10 to NWIGU.pdf

WILLIAMS · BRADBURY
ATTO R NEYS AT LAW
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December 30, 2016
Jean D. Jewell
Commission Secretary
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Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
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RE: IGC First Production Request to Northwest Industrial Gas Users -Case No. INT-G-
16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's First Production Request to the Northwest Industrial Gas
Users.
Sincerely,
flwt WAI'-
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 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
___________ )
Case No. INT-G-16-02
FIRST PRODUCTION REQUEST
OF INTERMOUNTAIN GAS
COMPANY TO NORTHWEST
INDUSTRIAL GAS USERS
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 Northwest Industrial Gas Users ("NWIGU") provide the following documents
and information as soon as possible, and no later than Friday, January 20, 2017.
This Production Request is continuing, and NWIGU 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. ID APA 31.01 .01.228.
JGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS 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.
REQUEST NO. 1. Please provide copies of the documents cited in the following
footnotes found in the direct testimony of Michael Gorman, (Di): 14, 16, 17, 18, 21 , 22, 27, 28,
29, 30, 31, 32, 34, 35, 36, 37, 38, 42, 52, and 59.
REQUEST NO. 2. Referencing Michael P. Gorman, Exhibit Nos. 301, 302, 303, 304,
305,306,307,308,309,310,311,312,313,314,315,316,317,and318.
a) Please provide an Excel copy with formulas intact of each of the cited exhibits.
b) Please provide copies of all supporting data and workpapers used in developing each of
the cited exhibits.
REQUEST NO. 3. At page 29, lines 13 through page 30, line 4, Mr. Gorman quotes
an article from Fitch Ratings that was published on September 21 , 2015. Please explain the
relevance of this article for purposes of setting the forward-looking cost of equity for
Intermountain Gas Company in 2017.
REQUEST NO. 4. At page 31, lines 8 through page 32, line 20, Mr. Gorman cites
an EEi report regarding electric utility stock prices in 2015, Federal Reserve policy in 2015,
capital spending for electric utilities, and earnings growth rates for electric utilities. Please
explain the relevance of this article, given that it pertains to electric utilities and that much of the
information is for 2015.
REQUEST NO. 5. At page 51, line 24 through page 52, line 2, Mr. Gorman states
that he has used a long-term growth rate of 4.25 percent in his multi-stage DCF analysis. Please
reconcile this figure with Table 7 on page 50, which shows the Blue Chip nominal GDP growth
rate as 4.30%.
IGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS Page 2
REQUEST NO. 6. Regarding Mr. Gorman's testimony, page 53, line 25, through page
54, line 1, please confirm that the risk premium in Exhibit No. 312 is based on natural gas
distribution companies.
REQUEST NO. 7. Please specify the time period covered by the projected risk-free
rate of 3.40%. Michael P. Gorman, page 60, lines 5-6.
REQUEST NO. 8. Why did Mr. Gorman base his ROE recommendation for
Intermountain Gas Company on a "general assessment of the current investment risk
characteristics of the electric utility industry"? Michael P. Gorman, page 64, lines 14-18.
REQUEST NO. 9. Please provide the analysis used to support the conclusion that
interest rates during the 1980s were more volatile than in today's marketplace. Michael P.
Gorman, page 76, lines 1-2.
REQUEST NO. 10. Please provide the yield on 30-year Treasury bonds as of December 30,
2016. Michael P. Gorman, page 76, lines 21-22.
DATED at Boise, Idaho, this j d day of 0~ , 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
JGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS Page 3
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 30th 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
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 83702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
IGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS Page 4
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 83702
E-Mail: [e-mail]
Peter Richardson
Gregory M . Adams
Richardson Adams, PLLC
515 N. 27'h 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]
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[81 Electronic Transmission
[81 Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
[81 Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[81 Electronic Transmission
[81 Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[81 Electronic Transmission
IGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS Page 5
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. [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
1:8:J Electronic Transmission
Ronald L. Williams
IGC FIRST PRODUCTION REQUEST TO NW INDUSTRIAL GAS USERS Page 6