20170106INT 72-91 to Staff.pdf

WILLIAMS BRADBURY
ATTO R NEYS AT LA W
January 6, 201 7
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Second Production Request to Staff -Case No. INT-G-16-02
Dear Ms. Jewell:
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Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Second Production Request to the Commission Staff.
Sincerely, R~ ~lfv-
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 INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
___________ )
Case No. INT-G-16-02
SECOND PRODUCTION REQUEST
OF INTERMOUNT AIN GAS
COMPANY TO COMMISSION
STAFF
Intermountain Gas Company ("Intermountain" or "Company"), a subsidiary of MDU
Resources Group, Inc., by and through its attorney ofrecord 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 Friday, January 27, 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. ID APA 31.01.01.228.
IGC SECOND 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 RANDY LOBB
REQUEST NO. 72. Please clarify and describe, and provide any workpapers or analysis,
showing how Staff struggled to duplicate the Company customer totals over time and total
annual consumption (Lobb Direct, page 5, lines 15-18).
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS MIKE MORRISON
REQUEST NO. 73. 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 class cost of service studies.
REQUEST NO. 74. Referring to lines 22 -23, on page 5 of Dr. Morrison's direct
testimony, provide a list of utilities and case references where CP allocators were determined
using data for multiple days.
REQUEST NO. 75. Referring to lines 8-10 on page 28 of Dr. Morrison's direct
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".
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS BARBARA ROMANO
REQUEST NO. 76. In Witness B. Romano 's testimony, Pg. 2 line 21-25, she states "Staff
reviewed the Company's proposed Sales and General Advertising Expense to ensure that they
only include expenses that directly benefit the Company customers and are used and useful in
JGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 2
providing safe a reliable utility service " How does Staff determine if an expense directly
benefits the Company's customers? As part of your response please provide any criteria,
framework, or bright line test that the Staff may use in this regard.
REQUEST NO. 77. Referencing the question above, are indirect customer benefits
considered in the determination of allowable expenses? If not, why not? Please provide any
Commission orders that Staff may have relied on in responding to this question.
REQUEST NO. 78. Ms. Romano, on page 3, lines 4-12, of her testimony, provided two
examples of allowable advertising expenses incurred by the Company. These two examples
reference the competition that natural gas faces as a heating fuel source. If it is Staffs answer to
Request No. 49 that the Company faces competition, what are the metrics for determining which
advertising expenses are allowable?
REQUEST NO. 79. Please differentiate, from a product marketing perspective, the
difference between promoting the company's image and promoting the use of natural gas as an
energy source and how they are mutually exclusive?
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS JOE TERRY
REQUEST NO. 80. Please provide documentation in Mr. Terry's testimony, page 10,
lines 19 -24 referencing lack of evidence that bank fees are not a recurring expense and that there
were no entries before "this time frame." Is it Mr. Terry's testimony that bank fees are not
ongoing?
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS DANIEL KLEIN
JGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 3
REQUEST NO. 81. In Daniel Klein's testimony he makes the recommendation to
eliminate convenience fees and pay station fees for residential customers. Was analysis done to
show the impact to current customer's bills in order to cover the additional cost? If so, please
provide that analysis.
REQUEST NO. 82. How many complaints has the Idaho PUC received regarding the
convenience fee charged for credit/debit card payments in each of the last three years? How
many were from low-income customers? Unbanked Customers? Underbanked Customers?
REQUEST NO. 83. Did Mr. Klein or Staff perform analysis comparing the cost of
convenience fees to other acceptable methods of customer payments? If so, please provide that
analysis.
REQUEST NO. 84. Mr. Klein at page 4 of his testimony uses Avista as an example for the
elimination of convenience fees at a cost per transaction of $1.50. Did IPUC staff find any other
comparable transaction costs from outside Idaho? If so, please provide that information.
REQUEST NO. 85. On line 13 of page 3 of Mr. Klein's testimony he uses a payment
transaction number for Intermountain of 144,625 which is 2015 data. What has been the change
in volume for Avista since implementing the free credit/debit card option?
REQUEST NO. 86. At page 7 of Mr. Klein's testimony, beginning on line 10, he
correlates the elimination of the convenience fee to a reduction of costs associated with
collection activity. Please provide all documentation that supports this correlation.
REQUEST NO. 87. What has been the trend ofreduced arrearage and collection activity
realized by A vista as a result of offering free credit and debit card payment to residential
customer? Are there similar trends for small commercial customers that do not have the free
option available?
JGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 4
REQUEST NO . 88. Referencing page 7, Line 21 of Mr. Klein's testimony: Was analysis
performed by Staff comparing the cost to process credit/debit card payments versus the other
means of paying the utility bill? (i.e. mailed payments, autopay, third party banks -CheckFree
or Metavante, etc.) If so, please provide that analysis.
REQUEST NO. 89. On page 8, line 6, Mr. Klein recommends that "transaction costs
associated with receiving payment for services should be included in base rates." Did Staff
make an adjustment to the Company's base rates to implement this recommendation? If not,
why not?
REQUEST NO. 90. Mr. Klein at page 8, line 8 states that "In summary, removing the
$1.99 convenience fee will bring the Company's payment practices in line with other Idaho
utilities ... " What other Idaho utilities have removed the convenience fee for credit/debit card
transactions and what impact have they seen on their number of transactions and bad debt
activity? What are their costs per transaction?
REQUEST NO. 91. What trends or insights have been identified by Staff in review of the
credit and collection reports submitted by A vista, Idaho Power, and Rocky Mountain Power?
DATED at Boise, Idaho, this 6th day of January, 2017.
Respectfully submitted, fl~ l lJ»:--
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
JGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 5
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 6th day of January, 2017, I caused to be served a true
and correct copy of the Second 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. 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
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IGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 6
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. 27th Street
Boise, ID 83702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
Company LLC
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 6th 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
~ Electronic Transmission
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D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
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JGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 7
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.jernigan.3 @us.af.mil
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
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Ronald L. Williams
IGC SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF Page 8