HomeMy WebLinkAbout20170117INT to Staff Redacted Amended 178.pdfWILLIAMS · BRADBURY
ATTO R NEYS A T LAW
January 17, 2017
Ms. Diane Hanian
Idaho Public Utilities Commission
4 72 West Washington
Post Office Box 83720
Boise, Idaho 83720-0074
Re: Intermountain Gas Company,
IPUC Case No. INT-G-16-02
Amended Response to Staff Request No. 178
Dear Ms. Hanian:
REC EIV ED
.. ' ' .,
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Amended Response to Staffs Eighth Production, Request No.
178.
By separate and confidential CD, please find additional information regarding Request No. 178
that is confidential and proprietary.
If you should have comments or questions regarding this filing, please contact Michael P.
McGrath (377-6168) or me (344-6633).
Sincerely, A Wt 1,v W"-
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
cc: Michael P. McGrath
Enclosure
1015 W. Hays Street -Boise, ID 83702
Phone: 208-344-6633 -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: (208) 344-6633
Email: ron@williamsbradbury.com
Attorneys for Intermountain Gas Company
REC EIV ED
7r , l 1 :; i ! I 7 r •. ID= '-4 -V,. "", ,l I J 4
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
AMENDED RESPONSE OF
INTERMOUNTAIN GAS
COMPANY TO REQUEST NO. 178
OF THE COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and amends its response to Request No.
178 of the Commission Staff to Intermountain Gas Company dated January 17, 2017, herewith
submits the following information:
AMENDED RESPONSE TO REQUEST NO. 178:
The attached amended Exhibits includes Exhibit No. 12, Page 1; Exhibit No. 13, Pages 1,
2, 5 and 6; Exhibit No. 14, Page 1; Exhibit No. 15, Pages 24 and 25; and Exhibit No. 16, Page 1.
These amended Exhibits correct for errors discovered after the filing of the Company's original
response to Staff's Production Request No. 178.
The Company made adjustments to the Exhibits referenced above to correct for an
accounting error pertaining to the Commission approved depreciable lives for the following
asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and
397 -Communication Equipment. The error originated in January 2015, was discovered in late
October 2016 and was corrected for in December 2016. The resulting adjustments to plant-in-
service, accumulated depreciation, cash working capital, accumulated deferred income taxes,
depreciation expense, and income tax expense can be seen on the above mentioned Exhibits.
Please note that the adjustment to the Company 's rate base corrects test year-end rate
base for the cumulative impact of the error, however, the adjustment to depreciation expense
reflects only that amount of overstated depreciation that occurred during the test year of 2016.
In addition to the above corrections, the Company has also made adjustments to correct
for an inconsistency between Exhibit No. 15, Pages 24 and 25 and the Company's books and
records. When Exhibit No. 15, Pages 24 and 25 were originally produced, the Company
inadvertently included the effect of Idaho Investment Tax Credits ("ITCs'') in the calculation of
its state current income tax expense. The corrected Exhibit 1) removes the effect of Idaho ITCs
to match the Company's accounting treatment on its books and records and, 2) updates the
estimated ITC amortization to reflect actual ITC amortization, net of recapture amortization and
federal tax effect.
The net effect of the above adjustments is a lowering of the Company 's Revenue
Requirement.
Please see confidential Disk "Amended Exhibits 12-16 Selected pages.xlsx "
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
Sponsor/Preparer: Jacob Darrington, 208-377-6000
DATED at Boise, Idaho, this 17th day of January, 2017.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
Line
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lntermountain Gas Company
Rate Base -13-Month Average
For the Test Year Ending December 31 , 2016
September Company
Update Retirement Adjusted
Descrietion Rate Base[1J Adjustment[2l Rate Base
(a) (b) (c) (d)
Gas Plant in Service:
Original Cost13l $ 594,848,972 $ (143,029) $ 594,705,943
Less Accumulated Depreciation14l {307,142,320) 189,090 {306,953,230)
Net Gas Plant in Service 287,706,652 46,061 287,752,713
Materials & Supplies Inventory 3,195,291 3,195,291
Liquid Natural Gas Storage Inventory 3,225,344 3,225,344
Cash Working Capital15l 1,137,743 6,245 1,143,988
Accumulated Deferred Income Taxes16l (49,961,992) (14,431) (49,976,423)
Advances in Aid of Construction {8,022,512) {8,022,512)
Rate Base $ 237,280,526 $ 37,875 $ 237,318,401
NOTES
[1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to
IPUC Staff Production Request No. 178.
[2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the
following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 -
Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was
corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the error.
[3] See Amended Exhibit No. 13, Page 1.
[4] See Amended Exhibit No. 13, Page 2.
[5] See Amended Exhibit No. 13, Page 5.
[6] See Amended Exhibit No. 13, Page 6.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 12
Case No. INT-G-16-02
J. Darrington, IGC
Page 1 of 2
Line
No.
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3
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6
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21
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24
25
26
27
28
lntermountain Gas Company
Gas Plant in Service -Original Cost
For the Test Year Ending December 31 , 2016
September Update
Gas Plant in Service Retirement Month End Average
Month a/c 1010 and 106d11 Adjustment121 Total Balance
(a) (b) (c) (d) (e)
December 2015 $ 581 ,612,364 $ -$ 581,612,364
$ 582,450,330
January 2016 583,288,295 583,288,295
584,396,744
February 585,505,193 585,505,193
586,421 ,185
March 587,337,177 587,337,177
588,017,818
April 588,698,458 588,698,458
589,680,774
May 590,663,089 590,663,089
592,015,774
June 593,368,458 593,368,458
593,922,583
July 594,476,707 594,476,707
595,622,740
August 596,768,773 596,768,773
599,501,069
September 602,233,364 602,233,364
604,679,980
October 607,126,595 607,126,595
608,487,967
November 609,849,338 609,849,338
611 ,274,342
December 616,132,049 (3,432,704) 612,699,345
Total $ 7,136,471,306
Divided by 12
Average Balance $ 594,705,942
NOTES
(1] These amounts match the Company's updated rate base and revenue requirement which was filed in response
to IPUC Staff Production Request No. 178.
[2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for
the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397
Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was
corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the
error.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 13
Case No. INT-G-16-02
J. Darrington, JGC
Page 1 of 7
Line
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3
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12
13
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18
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24
25
26
27
28
lntermountain Gas Company
Accumulated Depreciation -Gas Plant in Service
For the Test Year Ending December 31 , 2016
September Update
Accumulated Provision
for Depreciation Retirement Month End Average
Month ale 1080 and 1110111 Adjustment121 Total Balance
(a) (b) (f) (g) (h)
December 2015 $ (299,741,040) $ -$ (299,741,040)
$ (300,208,766)
January 2016 (300,676,492) (300,676,492)
(301,742,662)
February (302,808,832) (302,808,832)
(303,439,469)
March (304,070,105) (304,070,105)
(304,685,687)
April (305,301,268) (305,301 ,268)
(305,868,253)
May (306,435,237) (306,435,237)
(306,864,044)
June (307,292,850) (307,292,850)
(307,539,625)
July (307,786,400) (307,786,400)
(307,963,527)
August (308,140,654) (308,140,654)
(309,149,761)
September (310,158,868) (310,158,868)
(311,062,619)
October (311,966,370) (311 ,966,370)
(312,883,641)
November (313,800,912) (313,800,912)
(312,030,698)
December (314,798,647) 4,538,163 (310,260,484)
Total $ (3,683,438,752)
Divided by 12
Average Balance $ (306,953,229)
NOTES
[1] These amounts match the Company's updated rate base and revenue requirement which was filed in response
to IPUC Staff Production Request No. 178.
(2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for
the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 -
Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was
corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the
error.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 13
Case No. INT-G-16-02
J. Darrington, IGC
Page 2 of 7
Line
No. Description
(a)
REVENUES
Revenues at Proposed Rates
2 Plus Franchise Tax
3 Plus Interest Expense
4 (Less) Uncollectibles
5 (Less) Depreciation and Amortization
6 (Less) Return on Equity
7 TOTAL -REVENUES
EXPENSES
8 Employee Benefits
9 Payroll and Wrthholdings
10 PGA Expense
lntermountain Gas Company
Cash Working Capital
For the Test Year Ending December 31 , 2015111
$
$
$
Test Year Revenues
and Expenses
at Proposed Rates
(b)
264,745,726
6,773,679
5,861 ,765
(1 ,117,843)
(20,868,936)
(17,609,108)
237,785,283
299,655
27,673,347
169,187,048
Revenue Lag/
Expense (Leads)
(c)
44.96
44.96
44.96
44.96
44.96
44.96
(9.24)
(13.82)
(41 .29)
ewe Factor
(d)
12.32% $
12.32%
12.32%
12.32%
12.32%
12.32%
$
-2.53% $
-3.79%
-11.31%
Cash
Working Capital
Requirement
(e)
32,609,050
834,322
722,001
(137,686)
(2,570,452)
(2,168,935)
29,288,300
(7,584)
(1,047,769)
(19,137,475)
11 Other Operations and Maintenance (less uncollectibles) 15,990,168 (31.74) -8.69% (1,390,314)
12
13
14
15
16
17
18
Payroll Taxes 1,649,612 (24.70) -6.77% (111 ,648)
Property Taxes 3,191,226 (131.88) -36.13% (1,152,994)
Franchise Tax 6,773,679 (169.50) -46.44% (3,145,574)
Interest Expense 5,861 ,765 (87.68) -24.02% (1,408,107)
Income Tax 7,158,783 (37.88) -10.38% (742,846)
TOTAL EXPENSES $ 237,785,283 $ (28,144,311)
CASH WORKING CAPITAL REQUIREMENT $ 1,143,988
NOTES
(1] The Cash Working Capital amount reflects the adjustment explained on the Amended Exhibit 12, footnote [2].
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 13
Case No. INT-G-16-02
J. Darrington, IGC
Page 5 of 7
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25
26
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28
Month
(a)
December 2015
January 2016
February
March
April
May
June
July
August
September
October
November
December
NOTES
lntermountain Gas Company
Deferred Income Taxes
For the Test Year Ending December 31, 2016
September Update
Accumulated Deferred
Income Taxes Retirement
ale 2820[11 Adjustment[2l Total
(b) U) (k)
$ (50,189,245) $ -$ (50,189,245)
(50,161,278) (50,161,278)
(50,099,181) (50,099,181)
(50,078,857) (50,078,857)
(49,995,634) (49,995,634)
(49,919,808) (49,919,808)
(50,021,034) (50,021 ,034)
(49,994,205) (49,994,205)
(49,934,289) (49,934,289)
(49,852,271) (49,852,271)
(49,780,400) (49,780,400)
(49,758,479) (49,758,479)
(49,707,686) (346,332) (50,054,018)
Total
Divided by
Average Balance
Average
Balance
(I)
$ (50,175,262)
(50,130,230)
(50,089,019)
(50,037,246)
(49,957,721)
(49,970,421)
(50,007,620)
(49,964,247)
(49,893,280)
(49,816,336)
(49,769,440)
(49,906,249)
$ (599,717,071)
12
$ (49,976,423)
[1] These amounts match the Company's updated rate base and revenue requirement which was filed in response
to IPUC Staff Production Request No. 178.
[2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for
the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 -
Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was
corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the
error.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 13
Case No. INT-G-16-02
J. Darrington, IGC
Page 6 of7
Line
..!:!2'.... Description
(a)
Gas Operating Revenues
2 Other Revenues
3 Total Operating Revenue
4 Operating Expenses
5 Cost of Gas
6 Operation & Maintenance
Production 7
8
9
10
11
12
13
14
Natural Gas Storage, Terminaling, and Processing
Transmission
Distribution
Customer Accounts
Customer Service and Informational
Sales
Administrative and General
15 Other
16 Depreciation
17 Payroll Taxes
18 Property Taxes
19 Franchise Taxes
20 Interest Expense
21 Total Operating Expense
22 Before Income Taxes
23 Income Taxes
24 Total Operating Expenses
25 Net Operating Income
NOTES
lntermountain Gas Company
Statement of Operating Income with Adjustments
For the Test Year Ending December 31, 2016
$
September Update
Company
Unadjusted
Direcil'1
(b)
252,430,742 $
2 963,369
255,394,111
169,187,048
82,819
1,205,914
454,928
18,916,816
9,542,629
195,479
1,217,728
13,413,537
21,438,620
1,649,612
3,191,226
240,496,356
3,032 985
Company
Adjustments
(c)
(569,684) ,,1
(569,684)
423 288 1'1
243,529,341 (146,396)
11864770 ~$ ___ ___;1~46~·~396;:.:.
$
Company
Direct
Present
(d)
252,430,742 $
2 963,369
255,394,111
169,187,048
82,819
1,205,914
454,928
18,916,816
9,542,629
195,479
1,217,728
13,413,537
20,868,936
1,649,612
3,191,226
239,926,672
3,456,273
243,382,945
12 011166 $
Proposed
Revenue
Deficiency
(Over Collection)
(e)
9,351 ,615 $
9,351 ,615
33,610
17,553
51,163
3,702 510
Company
Direct
Proposed
(f)
261,782,357
2 963,369
264,745,726
169,187,048
82,819
1,205,914
454,928
18,916,816
9,576,239
195,479
1,217,728
13,431,090
20,868,936
1,649,612
3,191,226
239,977,835
7 158,783
3,753 673 247,136 618
5,597,942 _$ ___ 1~7_60_9~,1_0_8
(1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178.
(2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -
Tools, Shop, Garage Equipment, and 397 -Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016
The adjustment to depreciation expense reflects only that amount of overstated depreciation that occurred during the test year of 2016.
(3] See Amended Exhibit No. 15, Page 25, Line 78.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 14
Case No. INT-G-16-02
J. Darrington, IGC
Page 1 of 2
lntermountain Gas Company
Income Tax Calculation
For the Test Year Ending December 31, 20Hf'l
Line
~----------~D~•~sc_r~i _tio~n __________ _ September Updatel1l
(b)
Company
Adjustments Proforma Amount
(a)
Total Operating Revenue
2 Total Operating Expenses Before Interest Expense and Income Taxes 121
Interest Charges131
Pre-Tax Income
Permanent Tax Adjustments:
6 401 K Dividend Deduction
50% Meals and Entertainment
Club Dues
Lobbying Expenses
10 Total Permanent
11 Temporary Tax Adjustments:
12 Accrued 401 K Pension
13 Bad Debt Expenses
14 Charitable Contributions
15 Customer Advances
16 Deferred Compensation -Officers
17 Incentive Compensation
18 LNG Sales Deferred Revenue
19 Payroll Taxes -Incentive Compensation
20 Postretirement Benefit Costs
21 SISP/SERP Expense -Current
22 SISP/SERP Expense Officers
23 SISP/SERP Expense Officers -PBO
24 Unamortized Loss on Reacquired Debt
25 Uniform Capitalization
26 Vacation Pay
27 AFUOC Debt -CWIP
28 AFUOC Equity -CWIP
29 Capitalized Interest -CW1P
30 Contribution in aid of construction -CWIP
31 Plant Temporary Differences Federa1121
32 Total Temporary
33 Total Tax Adjustments
34 T axabte income before state income taxes
35 state Current Income Tax Calculation:
36 Taxable income before state income taxes
37 Bonus Modification
38 state taxable income
39 state tax rate
40 State income tax (expense)/benefit before adjustments
41 state Net Operating Loss
42 State Tax Credits
42 Permanent Building Fund
42 Investment tax credit recapture 141
43 Investment tax creditl4l
44 Return and other adjustments
45 Total State Current Income Taxes (expense)/benefrt
255.394, 111
240,496,356
5,860,829
9,036,926
(123,189)
74,546
(48,643)
(5,508)
(39,018)
(428,577)
652.655
37.236
(235,697)
72.216
595,027
38,692
1,358.182
2,045.208
1,996,565
11,033,491
11,033,491
(5,580,075)
5,453,416
7.40%
(403,553)
(10)
(18,856)
201,777
(220,642)
(C)
(569,684)
936
568,748
(569,684)
(569,684)
(569,684)
(936)
(936)
(936)
7.40%
69
18,856
(201,777)
(182,852)
(d)
255,394.111
239,926,672
5,861,765
9.605.674
(123,189)
74,546
(48,643)
(5,508)
(39,018)
(428,577)
652,655
37,236
(235,697)
72.216
595,027
38.692
788,498
1,475.524
1,426,881
11,032,555
11,032,555
(5,580,075)
5,452,480
7.40%
(403,484)
(10)
(403,494)
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 15
Case No. INT-G-16-02
J. Darrington, IGC
Page 24 of 27
lntermountain Gas Company
Income Tax Calculation
For the Test Year Ending December 31, 201 &11
Line
~ ----------~D~•-=-•c~r~i "'tio~"~------------~F~o~r•-=-c•~•~te"d~---'-'Ad"'j~us~tm-"e"'n"'ts'----~P-'--,o"'fo"'r""m"'a-'--A"'m'-'o-=-un"'t
(a)
46 State Deferred Income Tax Calculation
47 Deferred Gas Cost and SERP timing differences
48 State deferred tax rate
49 State NOL
50 State Deferred Income Taxes (expense)/benefrt
51 Total State Income Taxes (expense)/benefrt
52 Federal Current Income Tax Calculation:
53 Taxable income before state income taxes
54 State income tax -Current year
55 Federal taxable income
56 Federal tax rate
57 Federal income tax (expense)benefrt before adjustments
58 Federal Net Operating Loss
59 State Net Operating Loss
60 Federal Tax Credits
61 State Tax Credits
62 FIN 48 Adjustments
63 Return and other adjustments
64 Total Federal Current Income Taxes (expense)/benefit
65 Federal Deferred Income Tax Calculation
66 Non fixed asset & CWIP timing differences
67 Federal deferred tax rate
68 Deferred taxes
69 Deferred Gas Cost & SERP timing differences
70 Federal deferred tax rate
71 Deferred taxes
72 Utility fixed asset timing differences
73 Federal deferred tax rate
7 4 Deferred taxes
75 Federal Deferred Income Taxes (expense)/benefit
76 Total Federal Income Taxes (expense)/benefit
77 ITC Amortization151
78 Total tax (expense)/benefrt
llilill
(b)
7.40%
(220,642)
11,033,491
(220,642)
10,812,849
35.00%
(3,784,497)
(3,784,497)
687,026
35.00%
240,459
32.41%
1,358,182
31.33%
425,508
665,967
(3,118,530)
306,187
(3,032,985)
(c) (d)
7.40% 7.40%
(182,852) (403,494)
(936) 11,032,555
(182,852) (403,494)
(183,788) 10,629.061
35.00% 35.00%
64,326 (3,720,171)
64,326 (3,720,171)
687,026
35.00% 35.00%
240,459
32.41% 32.41 %
(569,684) 788,498
31.33% 31.33%
(178,478) 247,030
(178,478) 487,489
(114,152) (3,232,682)
(126,284) 179,903
$ (423,288) (3,456,273)
[1) These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178.
[2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 • Office
Furniture and Equipment. 394 -Tools, Shop, Garage Equipment, and 397 · Communication Equipment. The error originated in January 2015, was discovered in
late October 2016 and was corrected in December 2016. The adjustment to depreciation expense reflects only that amount of overstated depreciation that
occurred during the test year of 2016.
[3] Interest expense is calculated by multiplying total rate base by the weighted average cost of debt. This adjustment is the result of the Retirement Adjustment
explained in footnote [2] above.
[4] In the creation of this tax schedule, the Company inadvertently included the effect of Idaho Investment Tax Credits ("ITCs") in the calculation of its state
current income tax expense. This adjustment removes the effect of Idaho ITCs to match the Company's correct accounting treatment on its books and records.
[5) This adjustment is updates the estimated ITC amortization to reflect actual ITC amortization. net of recapture amortization and federal tax effect.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 15
Case No. INT-G-16-02
J. Darrington, IGC
Page 25 of 27
Line
No.
1
2
3
4
5
6
7
8
lntermountain Gas Company
Deficiency in Operating Revenue
For the Test Year Ending December 31 , 2016
September Company
Descrietion Update[1l Adjustments Total
(a) (b) (c) (d)
Rate Base $ 237,280,526 $ 37 ,875 $ 237,318,401
Operating Income at Present Rates 11 ,864,770 146,396 12,011 ,166
Earned Rate of Return 5.000% 0.061% 5.061%
Cost of Capital 7.420% 0.000% 7.420%
Operating Income at Proposed Rates 17,606,215 2,810 17,609,025
Operating Income Deficiency 5,741 ,445 (143,586) 5,597,859
Gross Revenue Conversion Factor 1.67057 1.67057
Deficiency in Operating Revenue $ 9,591,486 $ (239,871) $ 9,351,615
NOTES
[1] These amounts match the Company's updated rate base and revenue requirement which was filed in
response to IPUC Staff Production Request No. 178.
Amended Response to IPUC Staff Production Request No. 178
Amended Exhibit No. 16
Case No. INT-G-16-02
J. Darrington, IGC
Page 1 of 2
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 17th day of January, 2017, I caused to be served a true
and correct copy of the Amended Response of Intermountain Gas Company to Request No. 178
of the Commission Staff upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 copies)
Diane Hanian
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: Mike.McGrath@intgas.com
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-Mail: bmpurdy@hotmail.com
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 61h Street
Boise, ID 83 702
E-Mail: botto@idahoconservation.org
F. Diego Rivas
NW Energy Coalition
1101 81h Avenue
Helena, MT 59601
E-Mail: diego@nwenergy.org
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: efinklea@nwigu.org
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
~ 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
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: cstokes@cablehuston.com
tbrooks@cablehuston.com
Attorneys for NWIGU
Electronic service only:
Michael C. Creamer
Givens Pursley LLP
E-Mail: mcc@givenspursley.com
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 702
E-Mail: sblickenstaff@amalsugar.com
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83 702
E-Mail: peter@richardsonadams.com
greg@richardsonadams.com
Attorneys for 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: kmiller@snakeriveralliance.org
2
D Hand Delivery IZ! US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZ! Electronic Transmission
IZ! Electronic Transmission
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
IZ! Electronic Transmission
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZ! Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZ! 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.unsicker@us.af.mil
Lanny .zieman. l @us.af.mil
N atalie.cepak.2@us.af.mil
Thomas.jernigan.3@us.af.mil
Ebony. payton. ctr@us.af.mil
Attorneys for Federal Executive Agencies
(FEA)
3
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Ronald L. Williams