20170120INT 95-100 to Staff.pdf

WILLIAMS · BRADBURY
A T T O R EYS AT LAW
HEC F.IVED
20!7 J,~J~ 20 PM 3: 51
January 20, 2017
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Fourth Production Request to Staff-Case No. INT-G-16-02
Dear Ms. Hanian:
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Fourth Production Request to the Commission Staff.
Sincerely, • fi {fa\ (;J~
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [phone] -www.williamsbradbury.com
. ·.J;.,u c
·~~: rn.~ISSION
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
hECE IVED
21 /L/N 20 p 3: 5 I
. ' .. _r .:.11:uc '.: ~; r .. MISS IO~·
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
FOURTH 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 Friday, February 10, 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. IDAP A 31.01 .01 .228.
JGC FOURTH 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.
REQUEST NO. 95. Is it correct that in the INT-G-06-3 case, Staff in Production
Request No. 2 ("Linear Regression Modeling") was critical of the Company for not addressing
the autocorrelation issues identified by the Durbin-Watson statistic ("The Durbin-Watson
statistic suggests that better specification of the model is possible. Has the Company followed up
on that indication?")? Does Staff agree or disagree that autoregression is an accepted practice
for addressing autocorrelation?
REQUEST NO. 96. Referring to page 11 , lines 16-18 of Morrison Direct, please explain
your understanding of what information is available in the "system that the Company uses to
estimate line extension costs" and how this information could be used to allocate distribution
services, regulators, and ERTs.
REQUEST NO. 97. Referring to lines 7 -9, on page 15 of Dr. Morrison's direct
testimony, Provide a list of all gas utilities that Mr. Morrison is aware of that maintain records at
this level of detail.
REQUEST NO. 98. With the most current BLS data available from 2015, what years
were used in the Mercer and Towers Watson surveys? What year's employee salary information
was used?
REQUEST NO. 99. With Avista Corp. providing both natural gas and electric service,
would the labor cost as a percentage of total revenue comparison expected to be a like
comparison?
REQUEST NO. 100. What is Dr. Morrison's opinion of the appropriate Normal Degree
Days to be used for ratemaking purposes to include the specifics of the calculation and design of
IGC FOURTH PRODUCTION REQUEST TO THE COMMISSION STAFF Page 2
that Normal? Are you aware of other cases brought before this Commission where that same
definition was used?
DATED at Boise, Idaho, this 20th day of January, 2017.
Respectfully submitted,
J{vW/L Wr
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
IGC FOURTH PRODUCTION REQUEST TO THE COMMISSION STAFF Page 3
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 20th day of January, 2017, I caused to be served a
true and correct copy of the Fourth 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)
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 720
Michael P. McGrath
lntermountain Gas Company
555 S. Cole Road
Boise, ID 83 707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAPAI)
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
1:8:J Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
1:8:J Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
1:8:] Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
1:8:J Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
1:8:J Electronic Transmission
IGC FOURTH PRODUCTION REQUEST TO THE COMMISSION STAFF 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 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
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-Mai 1: kmiller@snakeri veralliance. org
D Hand Delivery
0 US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZ! Electronic Transmission
IZ! Electronic Transmission
D Hand Delivery
D 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
IZ! Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express IZ! Electronic Transmission
JGC FOURTH PRODUCTION REQUEST TO THE COMMISSION STAFF 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]
N [e-mail]
Thomas .j ernigan. [e-mail]
Ebony. payton. [e-mail]
Attorneys for Federal Executive Agencies
(FEA)
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[8] Electronic Transmission
Ronald L. Williams
IGC FOURTH PRODUCTION REQUEST TO THE COMMISSION STAFF Page 6