20170120Staff to INT 1-71.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
RECEl\/ED
20 l1 J,:. ' 19 PM 3: 0 I
., .. ·.·. !JbLIC . ·. :; :;.,.i.1WSSION
BEFORE THE IDAHO PUBLIC UTILITIES 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
)
)
)
)
)
___________ )
COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Sean Costello, Deputy Attorney General, responds as follows to Intermountain Gas Company's
First Production Request to Commission Staff.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS JANUARY 19, 2017
STAFF WITNESS TERRI CARLOCK WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 1-12,
BELOW.
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 rate base? If "yes", please provide case
references or copies of such testimony.
STAFF RESPONSE NO. 1: Yes. Usually the support is in the form of not removing or
adjusting the cash working capital (CWC) request. There are many settled cases where the initial
Staff analysis normally limits working capital to Fuel Inventory and Materials and Supplies
without a cash working capital component. Since the settlement negotiations are confidential,
these details are usually not in the stipulation, testimony or order. Rocky Mountain Power
includes a cash working capital component but most of those cases were settled. PAC-E-10-07
did not settle and Order No. 32196 states "Usually we will utilize the balance sheet approach
where there is a showing of who provides the funds."
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?
STAFF RESPONSE NO. 2: The question implies a statement not made by Ms.
Carlock. The referenced testimony states "A lead-lag study does not adequately show that
shareholders are supplying the cash for CWC." Sources of CWC may be determined with a
Balance Sheet Analysis.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 2 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 3: The scenario described shows a cash working capital
component but not necessarily that shareholders have supplied that cash. There are other sources
of capital that are not shareholder supplied. For example, other sources include Investment Tax
Credits, Accumulated Deferred Taxes, and deposits.
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.
STAFF RESPONSE NO. 4: Cash is needed to fund Inventories, Materials and Supplies,
and Gas Storage Inventory. They are not a source of cash working capital but are a component of
CWC. Including these items in rate base recognizes and provides the return on these
investments. No further return through CWC is needed.
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
believes are inappropriate, the changes that Staff believes need to be made, and the basis for that
opm10n.
STAFF RESPONSE NO. 5: No.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 3 JANUARY 19, 2017
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."
STAFF RESPONSE NO. 6: A Balance Sheet Analysis demonstrating shareholder
capital exceeds other sources of capital when the use of funds exceeds rate base components
earning a return.
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.
STAFF RESPONSE NO. 7: PAC-E-10-07, Order No. 32196. Most other cases reflect
Fuel Inventory and Materials and Supplies in rate base but not a separate cash working capital
component. UWI-W-06-02, UWI-W-09-01, UWI-W-11-02, UWI-W-15-01 all supplied a
balance sheet approach to cash working capital but the cases settled so a Staff response is not
documented.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 4 JANUARY 19, 2017
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) Staff's recommended ROE percentage in the case
referenced.
STAFF RESPONSE NO. 8: See file provided on the CO produced with this response.
REQUEST NO. 9: In each utility case Staff reference to 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.
STAFF RESPONSE NO. 9: Yes. The cases where a decoupling mechanism was in
place or implemented are: AVU-E-15-05, AVU-G-15-01 , IPC-E-07-08, IPC-E-08-10, and
IPC-E-11-08. Avista's Fixed Cost Adjustment was authorized in AVU-E-15-05, AVU-G-15-01 ,
Order No. 33437 dated 12/18/2015. Idaho Power's Fixed Cost Adjustment was authorized in
IPC-E-04-15 , Order No. 30267, dated 3/13/2007.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 5 JANUARY 19, 2017
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
conditions? Please provide the documentation relied on by Ms. Carlock in making this
recommendation.
STAFF RESPONSE NO. 10: Economic conditions were evaluated by monitoring local
area and Idaho activity including building activity, unemployment and job growth articles, state
economic reports. Capital market conditions were evaluated by monitoring local stock prices,
security issuance applications and general observations detailing borrowing availability and
interest rates, national capital markets observing the Dow Jones Industrial Average, Utility
Average, Standard & Poor's, New York Stock Exchange and Wall Street Journal articles.
Documentation is public information but copies were not made at the time. References include:
Wall Street Journal, Markets Digest Section, Key Interest Rates and Money Rates,
federalreserve.gov, labor.idaho.gov, dpw.idaho.gov, and employment.idaho.gov.
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.
STAFF RESPONSE NO. 11: Collection mechanisms reduce risk by providing more
elaborate and routine recovery of costs. The 25 basis point differential is based on professional
judgement. Discussions with rating agency representatives (including Moody's, Standard &
Poor's, Fitch and independent analysts) over the years provides the primary source of this
reasoned conclusion.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 6 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 12: Yes.
STAFF WITNESS MICHAEL MORRISON WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 13-36,
BELOW.
REQUEST NO. 13: Please define "average weather year" as found in Dr. Morrison's
Direct Testimony, page 18, line 23.
STAFF RESPONSE NO. 13: As used on page 18, line 23 of Dr. Morrison's testimony,
an average weather year is a year consisting of average weather months. For each month, Dr.
Morrison used the average of all monthly Heating Degree Day (HDD65) values provided by the
Company in its response to Staffs Production Request No. 27.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 7 JANUARY 19, 2017
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-1 model predicted test year consumption that was 79% higher than its
GS-1 customers actually consumed"). The information should be provided in Excel format with
all formulas intact.
STAFF RESPONSE NO. 14: Dr. Morrison used the Usage Proof (Usage
Calculation.xlsx) spreadsheet provided by the Company as part of its supplemental response to
Staffs Production Request No. 27 as a basis for his calculations. Dr. Morrison then added rows
for the Company's autoregressive terms. Dr. Morrison's updated model can be found in
"Workpapers_Morrison_IGCPR14.xlsx," which is included in File Name PR #13 -36 on the CD
produced with this response.
Also, please note that the 79% figure used on page 20, lines 11 through 16 of Dr.
Morrison's testimony was obtained using the AR(l) coefficient from the GS M03.4 model
presented in witness Blattner's supplement to Staffs Production Request No. 27. Later, when the
Company provided its Usage Calculation.xlsx as part of an amendment to its supplemental
response to Production Request No. 27, Dr. Morrison learned that the Company actually used
model M03.4b in its calculations. Using the Company's M03.4b AR (1) coefficient, the figure
becomes 76% rather than 79%. Dr. Morrison will update his testimony to reflect the new
number.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 8 JANUARY 19, 2017
REQUEST NO. 15: Please provide the consumption and HDD data used to generate
Figure 1 on page 21 of Dr. Morrison's direct testimony. The information should be provided in
Excel format with all formulas intact.
STAFF RESPONSE NO. 15: This is an x-y graph of per-customer consumption versus
HDD65. Dr. Morrison calculated per-customer consumption using data provided by the
Company in its response to Staff's Production Request No. 151. HDD65 values were provided
by the Company in its response to Staff's Production Request No. 27. This chart and the data
used to create it can be found in the RS2 tab of the spreadsheet
"Workpapers_Morrison_Normalization.xlsx," which is included in File Name PR #13 -36 on the
CD produced with this response.
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.
STAFF RESPONSE NO. 16: Dr. Morrison relied on the Company's division of its
subclasses; however, his conclusion that these subclasses differ sufficiently to warrant separate
treatment is based entirely on his analysis of monthly and annual consumption patterns. Charts
of monthly consumption patterns are included in the GS-10, GS-11 , GS-12, GS-20, and GS-60
tabs of "Workpapers_Morrison_Normalization.xlsx," which are included in File Name PR #13 -
36 on the CD produced with this response.
For example, the Company's irrigators (GS-60) are summer peaking, and use virtually no
natural gas during the winter months, whereas the remaining GS-1 subclasses are all winter
peaking. Absent a load study, it is not possible to estimate actual load factors for each of the
subclasses; however, using monthly consumption as a rough guide, we can see that the
Company's GS-11 subclass has a much more variable consumption pattern than the GS-10, GS-
12, and GS-20 subclasses.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 9 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 17: This information is provided in
"Workpapers_Morrison_Normalization.xlsx," which is included in File Name PR #13 -36 on the
CD produced with this response.
REQUEST NO. 18: Please provide the starting list of variables for backward
regressions (see Morrison Direct, page 22, line 20).
STAFF RESPONSE NO. 18: Dr. Morrison tested all variables provided by the
Company in its response to Staff Production Request No. 27. Dr. Morrison also included "Year"
in order to capture possible long term trends. In most cases, Year, HDD65 , and polynomial
terms using HDD65 were important. In the case of GS-10, Dr. Morrison was able to combine
some months to create seasonal Shoulder, Spring, and Summer variables.
STAFF 'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 10 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 19: Calculations are found in
"Workpapers_Morrison_Normalization.xlsx," which is included in File Name PR #13 -36 on the
CD produced with this response.
The Company did not provide consumption information by class for all months of 2016,
so it is impossible to provide the comparison requested by the Company. Instead, refer to R2
values for each class. These can be found in the regression summary table on each worksheet.
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.
STAFF RESPONSE NO. 20: See "Workpapers_Morrison_Normalization.xlsx" tabs
Proposed Allocation_ Ex 110 and Billing Determinants_ Ex 111, which is included in File Name PR
#13 -36 on the CD produced with this response.
REQUEST NO. 21: Please provide copies of testimonies from each Commission
proceeding in which Dr. Morrison provided testimony on weather normalization.
STAFF RESPONSE NO. 21: None.
STAFF 'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 11 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 22: See Matt Elam's direct testimony in IPUC Case No.
AVU-G-09-01, a copy of which is included in File Name PR #22 on the CD produced with this
response.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 12 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 23: Staff objects that this request is vague, overbroad, unduly
burdensome, and not reasonably calculated to lead to the discovery of relevant, admissible
evidence.
The request fails to describe the types of software sought with reasonable particularity;
for example, it could be construed to seek information about Windows Media Player, Google
Earth, Paint, Firefox, Internet Explorer, etc., that is irrelevant to any issue in this proceeding. The
Commission's Information Technology (IT) personnel maintain software programs according to
State of Idaho IT policies and procedures, records retention schedules and the Idaho Public
Records Act, but the IT personnel do not maintain "analysis of or reports on compatibility issues
when upgrading to new software."
Further, the response would be speculative beyond the timeframe that current personnel
have been employed by the Commission, and to the extent the request seeks information about
statewide fiscal and accounting software systems not actually maintained by Staff.
Lastly, the request seeks irrelevant information and is harassing because a government
regulator's implementation and retirement of software used to perform a regulatory function has
no bearing on a regulated utility's implementation and retirement of software needed to
reproduce data with which to support a requested rate increase.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 13 JANUARY 19, 2017
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."
STAFF RESPONSE NO. 24: There are two primary objections to the use of
autoregressive terms in weather normalization models: The use of autoregressive terms
constitutes a strong violation of regression's fundamental independence assumption, and
autoregressive terms do not represent any causal consumption mechanism.
Regression makes four assumptions about the distribution of error in the data:
Independence, randomness, normality, and uniform variance. The first two of these are very
strong assumptions, and if violated can invalidate the results ofregression modeling. Inclusion
of autoregressive terms in a regression model results in a clear violation of regression's
independence assumption.
An obvious result of this violation is that statistics such as F, t, R2, p-value, and their
derivatives are no longer valid measures of model quality. Autoregressive models were
developed within the framework of control theory as a discretization of general feedback models,
and they are best evaluated within the context of that framework. Deconvolution, and not
regression, is the appropriate methodology for developing autoregressive models.
With a sufficient number of predictor variables, it will always be possible to produce an
R2 value of 1. Such a model is a perfect predictor of the data used to create it, but this perfection
is obtained at the cost of generalizability to situations not already incorporated in the data. For
the purposes of weather normalization, such a model is useless because normalization requires us
to apply the model to hypothetical situations wherein test year weather is average.
The ability to draw statistically valid inference beyond the modeling data requires us to
restrict our use of predictors to those that are closely related to mechanisms that cause
consumption. Lagged consumption terms, as represented by the Company's autoregressive
terms, are predictors, but they are not drivers. Drivers should be weather variables that are
closely related to mechanisms that cause consumption. Without this restriction, we could create
models with very high R2 values and no predictive utility beyond their ability to describe the data
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 14 JANUARY 19, 2017
sets used to create them.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 15 JANUARY 19, 2017
REQUEST NO. 25: For what statistic 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 )?
STAFF RESPONSE NO. 25: This particular textbook was not used in a statistic course
taken by Dr. Morrison; however, Dr. Morrison attended the University ofldaho, and this
textbook was the primary textbook used for the University of Idaho's Statistical Analysis (ST AT
401) course during the late 1990s.
REQUEST NO. 26: Please provide the documentation for how the GS-1 growth was
allocated to "subclasses" (See lines 17-19, page 22, Morrison direct).
STAFF RESPONSE NO. 26: The adjustments were relatively small, and where
possible, Dr. Morrison followed the ratios used by Company witness Darrington. These can be
found in the "Billing Determinants" tab of "Workpapers_Morrison_Normalization.xlsx," which
is included in File Name PR# 13 -36 on the CD produced with this response.
REQUEST NO. 27: Please define the term "robust" as used on line 4, page 23 of Dr.
Morrison's direct testimony.
STAFF RESPONSE NO. 27: As used on line 4, page 23 of Dr. Morrison's direct
testimony, a "robust" estimation technique is one that is insensitive to small departures from the
idealized assumptions which have been used to optimize the algorithm. Robust techniques
include M-estimates, L-Estimates, and R-estimates. Least squares regression provides an M­
estimate, or Maximum Likelihood Estimate. In this particular instance, Dr. Morrison also is
comparing performance of his model to that of the Company's, which tends to give increasingly
divergent results when applied beyond the data range used to create it.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 16 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 28: None.
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?
STAFF RESPONSE NO. 29: No such cases exist.
REQUEST NO. 30: Referring to lines 14-21, on page 4 of Mr. [sic] 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 each studies?
STAFF RESPONSE NO. 30: No. Idaho's other natural gas utilities do not conduct
load studies, because they obtain required load data directly from their meters. According to
NARUC's 1989 Gas Distribution Rate Design Manual, pages 28 -29, "load data are necessary for
a cost of service study." But when appropriate metering technology is available, such as that
used by Idaho's other gas utilities, this data can be obtained from monthly metering/billing data.
So a load study is only required by companies without metering technology capable of
determining peak consumption by customer class. Intermountain Gas is the only regulated gas
utility in the State of Idaho without this technology, and thus is the only regulated Idaho gas
company that would require a load study.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 17 JANUARY 19, 2017
REQUEST NO. 31: Is Dr. Morrison aware of any natural gas distributing utilities in the
Northwest that have conducted load studies upon which class cost of service studies have been
based? If so, please list.
STAFF RESPONSE NO. 31: No. See response to Request No. 30.
REQUEST NO. 32: Referring to lines 2-5, on page 6 of Dr. Morrison's direct
testimony, provide a list ofldaho case references where non-coincident peak allocators were used
in the allocation of gas distribution plant.
STAFF RESPONSE NO. 32: The use of coincident Peak, Non-Coincident Peak, and
Average and Peak Demand allocators is described on pages 26 and 27 ofNARUC's 1989 Gas
Distribution Rate Design Manual.
As explained in Dr. Morrison's testimony, non-coincident peak and peak-average
allocators may be appropriate. Intermountain Gas Co. is the only regulated gas utility in the state
ofldaho proposing that such an allocator not be used. For reference, see AVU-G-15-01 (Miller
Exhibit 14), and AVU-G-12-07 (Knox, di).
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 18 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 33: In general, Dr. Morrison defines a "main" as a larger
pipeline that conveys gas to smaller pipes for ultimate delivery to multiple customers. Customers
cannot receive service without being attached to the main. Nevertheless, costs associated with
the Company's mains should not be classified as customer related costs. As page 23 of
NARUC's 1989 Gas Distribution Rate Design manual states: " ... mains and services are installed
to serve demands of the customers and should be allocated to that function. Under this basic
system theory, only those facilities, such as meters, regulators, and service taps, are considered to
be customer related, as they vary directly with the number of customers on the system." The
Company's contrary position is predicated on a categorical error. By the Company's reasoning,
given that all of its plant is somehow needed to provide natural gas to individual customers, the
entire plant should be allocated using a Customer allocator. The Company's reasoning and
position are simply wrong.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 19 JANUARY 19, 2017
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."
STAFF RESPONSE NO. 34: The Company did not provide the following types of data
that would have enabled Staff to fully evaluate the Company's weatherization methodology and
mains study:
1. Weather Normalization Data and Methodology: Blattner's direct testimony provided
very little information about the Company's weather normalization methodology. Instead, the
Company provided a third party letter that opined the appropriateness of the Company's
methodology. See Blattner Exhibit 18. In Staff Production Request No. 27, Staff asked the
Company to provide the data and workpapers used by Company witness Blattner to perform this
regress10n.
a. The workpapers provided by the Company in its response to Staff Production Request
No. 27 included no consumption data, so it was impossible to evaluate the Company's
model.
b. The workpapers provided by the Company in its response to Staff Production Request
No . 27 were incomplete, and many crucial calculations were not included.
c. Dr. Morrison contacted the Company, and was eventually provided amended
workpapers that included per-customer consumption from 1989 through 2014. See
Company's Supplemental Response to Staff Production Request No. 27.
d. Dr. Morrison was unable to duplicate the per-customer consumption and total
consumption provided by the Company in its amended workpapers. He again requested
clarification from the Company.
e. In a face-to-face meeting with the Company on October 14, 2016, Dr. Morrison
learned that the Company had used neither billing data, nor billed customer counts to
develop its per-customer consumption values. Instead, the Company used summary, per­
customer, information obtained from its weather system. The weather system does not
use the actual billed customer counts to determine its per-customer consumption values.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 20 JANUARY 19, 2017
Instead, it uses only those customers who consumed gas in a given month. The Company
was only able to provide the customer counts used in the computation for selected months
(June through October) and for selected years (2011 through 2014). See Company's
Customer Usage Per Customer.xlsx spreadsheet.
f. In the same meeting, Dr. Morrison also learned that the Company had not provided
several critical work papers in either its original, supplemental, or amended responses to
Staff Production Request No. 27. The missing workpapers included the Company's
Usage spreadsheet, Usage Per Customer spreadsheet, and its Weather Normalization
spreadsheet. The Company provided these spreadsheets to the Commission Staff, but
despite requests by Staff, did not amend its responses to Staff Production Request No . 27
to include these calculations.
g. Dr. Morrison was unable to full y reconcile the data provided by the Company via
Production Request No. 27 with the Company's numbers, so he eventually requested that
the Company provide its billed consumption and customer counts. See Staff Production
Request No. 151 . The Company explained that it was unable to provide values for the
entire date range (1989 through 2014), because of changes to its billing system. The
Company has explained this further in its responses to Production Request Nos. 151 and
201.
2. Mains Study: The Company used average annual cost information for various pipe
diameters obtained by the Company for the years 1959 through 2015 , but was only able to
provide project-level information such as purpose, customer class, and specific installation costs
for pipes installed after the year 2013. The Company was unable to identify costs that
represented actual installation costs, and those that represented valuations of plant that were
purchased at the time the Company was formed. The Company was unable to associate
particular classes, depreciation, or customer contributions with any plant installed prior to 2013 .
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 21 JANUARY 19, 2017
REQUEST NO. 35: Does Dr. Morrison agree or disagree with the following section
from NARUC's 1989 Gas Distribution Rate Design Manual, pages 23-24, 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? [sic]
Does Dr. Morrison believe he has applied the same guidelines in his testimony? If so,
please explain, and if not, why not?
STAFF RESPONSE NO. 35: The quote is part of the Rate Design manual's discussion
of different approaches to classification of Demand and Capacity costs. At the beginning of this
section, the manual states, "A portion of the costs associated with the distribution system may be
included as customer costs. However, the inclusion of such costs can be controversial." Much of
the section from which this section is abstracted discusses the pros and cons of using the
minimum size and zero size methods to classify a portion of distribution mains as customer
related costs. Within that context, Dr. Morrison concurs with the quote, noting that when
applying the basic system theory described on page 23 of the Rate Design manual, there would
be no costs associated with distribution mains in excess of the minimum size. Dr. Morrison's
testimony is consistent with the Rate Design Manual. A more thorough explanation is set forth
in response to Request No. 36, which is incorporated here.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 22 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 36: According to the NARUC manual, "A portion of the costs
associated with the distribution system may be included as customer costs. However, the
inclusion of such costs can be controversial." See NARUC Natural Gas Distribution Rate Design
Manual, page 22. Indeed, much of this section of the NARUC Natural Gas Distribution Rate
Design Manual describes the argument against such a classification scheme.
In general, Dr. Morrison agrees with the contra argument presented on page 22 of
NARUC's 1989 Gas Distribution Rate Design Manual:
The contra argument to the inclusion of certain distribution costs as customer costs is
that mains and services are installed to serve demands of the customers and should be
allocated to that function. Under this basic system theory, only those facilities, such
as meters, regulators, and service taps are considered to be customer related, as they
vary directly with the number of customers on the system.
Dr. Morrison's specific criticism of the Company's classification methodology can be
found in his direct testimony beginning on page 11 .
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 23 JANUARY 19, 2017
STAFF WITNESS RANDY LOBB WILL BE ABLE TO ANSWER QUESTIONS
ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 37-44, BELOW.
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?
STAFF RESPONSE NO. 37: The referenced testimony addresses the lack ofproject­
specific details identifying investment, customer contributions and the project justification. This
information is necessary to evaluate the prudency of the investment and to assign class cost
responsibility. To the best of Mr. Lobb's knowledge, the Company has not failed to file any
required reports or prepare any IPUC required studies over the 30-year period.
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 lease 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, 3 0 years ago?
STAFF RESPONSE NO. 38: Staff agrees that the primary purpose of a cost of service
(COS) study is to identify and then eliminate or at least minimize cross subsidies among
customer rate classes. Given the available information regarding the purpose of investments, the
contributions in aid of construction collected by class and the lack of customer load data, it is
unclear whether the Company's proposed class cost of service allocates class revenue
requirement more accurately than a uniform increase in the existing allocation.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 24 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 39: Staff did not prepare and present its own class COS
because the underlying cost and load information necessary to perform an accurate study was not
available.
REQUEST NO. 40: In reference to Mr. Lobb's testimony on 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.
STAFF RESPONSE NO. 40: The basis for the statement is the general premise that if
the risk of revenue loss in between rate cases is eliminated, the return on equity should be
adjusted to recognize that reduced risk.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 25 JANUARY 19, 2017
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).
STAFF RESPONSE NO. 41: The information needed to replicate the Company's
customer and consumption data was requested in a series of Staff production requests and
meetings with Company representatives. Staff was unable to identify and readily obtain
Company adjustments in annual customer totals by rate class or annual consumption for the
period used in the Company's rate proof and weather normalization analysis.
Please see attached Staff Production Request Nos. 28, 29, 151 and 201, with Company
responses, that attempted to identify where customer counts and consumptions values came from
and how they were adjusted in the Company's analysis. Also find attached emails between
Commission Staff member Mike Morrison and Company representative Lori Blattner regarding
customer counts and per customer consumption.
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).
STAFF RESPONSE NO. 42: As stated in Mr. Lobb's testimony, Staff was unable to
review many capital investments on an individual project basis. Please see attached Staff
Production Request No. 76 and the Company's response stating that detailed project data is
unavailable prior to 2013 with additional work order reporting issues occurring in 2013 as well.
Staff Production Request No. 202 with the Company's response and an email from Mike
McGrath dated November 23 are also attached confirming that the Company does not now nor
has it ever recorded project cost information on a customer class specific basis. Id.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 26 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 43: See Staffs response to Company Production Request No.
42.
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?
STAFF RESPONSE NO. 44: A fixed revenue per customer amount established in a
rate case is designed to collect the revenue requirement associated with fixed costs reviewed and
approved for recovery by the Commission in that case. Collection of a fixed revenue amount
from each new customer in a FCCM after that time and prior to the next rate case guarantees
recovery of assumed additional fixed cost incurred but not actually reviewed and approved for
recovery by the Commission.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 27 JANUARY 19, 2017
STAFF WITNESS DONN ENGLISH WILL BE ABLE TO ANSWER QUESTIONS
ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 45-52, BELOW.
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.
STAFF RESPONSE NO. 45: Expenses directly related to the safe delivery of natural
gas to customers were allowed for inclusion in the Company's revenue requirement. If an
expense was not related to the safe delivery of natural gas services to customers, it was excluded.
The expenses Staff recommended for removal included golf sponsorships, barbecue grills, and
donations to selected charity organizations as listed in Exhibit No. 101, Schedule 2.
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?
STAFF RESPONSE NO. 46: By using actual expenses for QI through Q3 some
seasonality was reflected. This percentage was then applied to Q4 Sales and General Expenses.
With regard to Management Expense Reports amounts, there was a consideration of seasonality
based on the actual expenses incurred during Q4 of2015 (i.e., Christmas parties) as the Company
did not provide a forecast for Management Expenses.
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.
STAFF RESPONSE NO. 47: Exhibit Nos. 101 and 102 and source documents attached
as requested with links activated. Please see detailed response attached on the CD -File Name PR
#4 7. Source data for Exhibit 101 derived from Company responses to Production Requests 72
and 73. Source data for Exhibit 102 derived from Company response to Production Request 70.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 28 JANUARY 19, 2017
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 were includible in customer rates and advertising
expenses that enhance the Company's image?
STAFF RESPONSE NO. 48: All of the expenses listed on Exhibit 101, Schedule 3
were considered to enhance the Company's image in the community (via contribution to selected
charities) without directly benefiting the ratepayer in the safe delivery of natural gas to
customers.
REQUEST NO. 49: On page 8 of her testimony, Ms. Romano suggests that
Intermountain does no face any competition since it is a monopolistic utility. Please explain why
natural gas does not face competition as a heating fuel source.
STAFF RESPONSE NO. 49: Ms. Romano was referring to the monopolistic operation
of services Intermountain provides to ratepayers. As capital-intensive enterprises, utilities
operate efficiently as the sole provider of utility services within the certificated area. Some
element of competition does exist -electricity and gas companies compete for industrial
customers and wholesale sales -but competition at the retail level is relatively limited.
Intermountain may compete with electric utilities as a heating fuel source when systems are
installed or replaced. As such Staff included advertising expenses informing customers of the
low cost of gas versus electricity.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 29 JANUARY 19, 2017
REQUEST NO. SO: 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.
STAFF RESPONSE NO. SO: The Commission approved Staff adjustments in
Commission Order Nos. 29505, 29602, and 28097, which have been attached.
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.
STAFF RESPONSE NO. 51: No. Whether expenses were related to charitable
purposes or encouraging economic development did not impact Ms. Romano's
recommendations. While Commission Staff commends the Company for participating in
community events, these contributions have no impact on the safe delivery of natural gas service
to customers and these expenses should not be passed on to ratepayers through rates.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 30 JANUARY 19, 2017
STAFF WITNESS ST ACEY DONOHUE WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWER TO REQUEST NO. 52, BELOW.
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?
STAFF RESPONSE NO. 52: Staff does not generally specify the savings quantification
methodologies used to evaluate market transformation programs or any other DSM program.
NEEA contracts with independent, third-party evaluators to measure the savings from its market
transformation efforts. These evaluations use a variety of measurement techniques depending on
the measure specifics and other factors. Staff recommends that the Company consult
independent, third party evaluators and its energy efficiency advisory committee regarding best
practices for evaluating its existing market transformation efforts funded through the Gas
Technology Institute .
STAFF WITNESS TERRI CARLOCK WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 53-56,
BELOW.
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).
STAFF RESPONSE NO. 53: The Comparable Earning Standard utilizes the return of
comparable companies. Staff utilized the same list of proxy group companies as Company
witness Gaske and these companies have financial integrity and are able to attract capital. When
a company has financial integrity and is able to attract capital, both of these standards will be met
when the comparable earnings for that company is part of the proxy company analysis.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 31 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 54: The Excel spreadsheets with formulas intact is provided
on the enclosed disk. See Exhibit 5 _ Staff.xlsx. The workpapers and supporting data are the
Staff version of those used by Company witness Gaske and reflected in the attached spreadsheets
and Mr. Gaske's workpapers.
REQUEST NO. 55: Please identify the one company in the proxy group referred to on
page 8, line 25 through page 9, line 1 of the testimony of Mr. Rogers that does not pay quarterly
dividends.
STAFF RESPONSE NO. 55: Mr. Gaske's Exhibit No. 5, Schedule 4 showed each of
the proxy company's annualized dividend yield by multiplying each quarterly dividend by 4, for
all companies except WGL Holdings Inc. Mr. Rogers was under the impression that the single
input for annualized dividend reflected only a single payment. However, it has come to Staffs
attention that this Company also pays 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)
STAFF RESPONSE NO. 56: It is Staffs understanding that they are consensus
estimates from individual analysts.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 32 JANUARY 19, 2017
STAFF WITNESS JOSEPH TERRY WILL BE ABLE TO ANSWER QUESTIONS
ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 57-61, BELOW.
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?
STAFF RESPONSE NO. 57: The BLS data has only nine areas more specific than its
statewide survey data. The Company has services in all of southern Idaho. The markets where
the Company operates are included in six of those nine areas. These include, in total, 517,905 of
642,698 of total statewide employment. In addition, due to the fact the underling detail of those
surveys is not available, it would be difficult, if not impossible, to accurately aggregate the
different survey results into one result.
REQUEST NO. 58: Why is equal weighting for BLS survey data to the Towers Watson
and Mercer surveys used?
STAFF RESPONSE NO. 58: Equal weighting was used so that Idaho specific data was
on equal footing with the two surveys that did not take Idaho specific data into account. As
mentioned in Staff witness Terry's testimony, the largest concern was that all of the surveys used
by the Company did not take Idaho specific salary levels into account.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 33 JANUARY 19, 2017
REQUEST NO. 59: Was BLS survey data used for salaries in determining Idaho Power
Company's, A vista's and or United Water's revenue requirement in their most recent rate cases?
STAFF RESPONSE NO. 59: The most recent rate cases for the above-mentioned
companies resulted in settlement. Greater detail for the salary adjustment in each case was not
disclosed, but adjustments were made as follows:
Avista's most recent electric rate case, AVU-E-16-03: "This adjustment reduces the
overall revenue requirement by $310,000, by removing 2017 incremental non-union labor
expenses." See A VU-E-16-03, Stipulation and Settlement, pg. 4.
A vista's most recent gas rate case, A VU-G-15-01: "2016 incremental non-executive
labor increases related to increases approved by the Board of Directors for 2016 for its non­
union, non-executive employees, as well as the 2016 union contract increases for union
employees was removed. This adjustment reduced the electric revenue requirement by $385,000
and reduced the natural gas revenue requirement by $185,000." See AVU-G-15-01, Andrews
Direct in Support of Stipulation, pg. 16.
Idaho Power Company's most recent rate case, IPC-E-11-08 : "Similarly, Staff
maintained that the salary increases awarded to employees in 2011 and 2012 were excessive and
should not be allowed for cost recovery." See IPC-E-11-08, Lobb Direct, pg. 8.
United Water's most recent rate case, UWI-W-15-01: "Staff proposed adjustments to reduce
the total allowable level of employee compensation." See UWI-W-15-01, Carlock Direct, pg. 7.
In addition BLS data has been accepted in other water company rate cases in the past.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 34 JANUARY 19, 2017
REQUEST NO. 60: Please provide workpapers or other documentation relied on by Mr.
Terry in support of this testimony, page 10, lines 7-9, referencing that bank fees are assigned by
Intermountain's parent company, MDU.
STAFF RESPONSE NO. 60: Here are the details provided for the bank charges
associated with this adjustment:
7/31/2016 48514.5914.29210 7 16 16,201.66 JE 09 Cash Upload July Analysis Fee Wells Fargo
8/31/2016 48514.5914.29210 8 16 15,079.25 JE 09 Cash Upload August Analysis Fee Wells Fargo
JE 09 Cash Upload
9/30/2016 48514.5914 .29210 9 16 16,549.40 September Analysis Fee Wells Fargo
The remainder of the information was obtained through discussions during the onsite audit.
REQUEST NO. 61: Please provide workpapers or other documentation relied on by Mr.
Terry in support of his testimony, page 10, lines 17-18, that the "Company has not produced any
evidence on whether the bank fees were a reasonably incurred expense."
STAFF RESPONSE NO. 61: None. Commission Staff asked for this information
during an onsite audit at the Company, but the Company was not able to provide it. Specifically,
Staff asked Company employee Nicole Gyllenskog to explain why the bank had analyzed the
Company's accounts, and to support that the Company had reasonably incurred expenses arising
from the bank's analysis. Nicole Gyllenskog responded, in summary, that the Company did not
know why the bank had analyzed the accounts, and that the fees for the analysis had been
assigned to the Company by MDU without explanation.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 35 JANUARY 19, 2017
STAFF WITNESS BENTLEY ERDWURM WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 62-69,
BELOW.
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.
STAFF RESPONSE NO. 62: See electronic workpapers attached as Excel file: PR #62-
69.xls on the CD produced with this response. Sheet (tab) names identify the exhibit supported
in Mr. Erdwurm's pre-filed direct testimony. Sheets "GS ANOVA" and "GS DATA" are related
to the General Service rate's declining block structure. Sheet "Memo" includes updated MDFQ
data by class from the Company.
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?
STAFF RESPONSE NO. 63: The calculation in Exhibit No. 112 uses data from the
Company's Cost of Service Model. The "Acct Detail" tab in the model included separate line
items for labor expense starting on Excel row 490. Staff assumed that these labor expense
entries were not included in O&M expenses starting on Row 284. If the labor expenses in the
Company's "Acct Detail" tab are included in the O&M expenses, then labor expenses in Exhibit
No. 112 are double-counted, and lines 21-35 should be removed. Removing lines 21-35 of
Exhibit No. 112 will reduce the calculated residential customer-related cost per customer in this
analysis. Please refer to sheet (tab) "BE-112 Res Cust Chg" in Mr. Erdwurm 's electronic
workpapers (Excel file: PR#62-69.xls), which is included on the CD produced with this response.
The result ofremoving labor expense is shown in sheet "Alt BE-112 REMOVE LABOR EXP".
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 36 JANUARY 19, 2017
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?
STAFF RESPONSE NO. 64: Staffs general service and large volume/transportation
weighting factors were chosen based on the weighting factors associated with the Company's
allocators as shown in the "FACTORS EXTERNAL" sheet in Mr. Erdwurm's electronic
workpapers (Excel file: PR #62-69.xls), which is included on the CD produced with this response.
Data used in the workpapers was drawn directly from the Company's "EXTERNAL" tab
in its cost-of-service study. The Company's "EXTERNAL" tab data is included in its entirety
beginning with Column "S" of Staffs "FACTORS EXTERNAL" sheet.
Staffs chosen weighting factors are intentionally overstated relative to the weighting
factors associated with the Company's "Weighted" and "Weighted I " allocators from the
"External" sheet in its filed cost-of-service study. Staff weighting factors are shown on rows
73-78, column "Weights" in Mr. Erdwurm's Exhibit 112.
The purpose for overstating the general service and large volume/transportation weighting
factors was to increase the allocation of costs to general service and large volume/transportation
classes, and to reduce the allocation to the residential class. The degree to which the general
service and large volume/transportation weighting factors were overstated (relative to the
Company's weighting factors) was meant to insure that the percentage of specified costs
allocated to the residential class would be less than the percentage supported by any average
embedded costing methodology generally used in the industry. The result is a conservative,
lower-bound estimate of residential customer-related cost per customer based on historical
average embedded costs.
To the extent that the labor expenses are double counted (see Response to Company
Request No. 63), the residential customer-related cost per customer is reduced. Removing the
double count reduces the lower bound estimate for residential customer-related cost per customer
from $8.57 to $6.45 monthly. Please refer to sheet (tab) "BE-112 Res Cust Chg" in Mr.
Erdwurm's electronic workpapers (Excel file: PR#62-69.xls), which is included on the CD
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 37 JANUARY 19, 2017
produced with this response.
The result of removing labor expense is included in sheet "Alt BE-112 REMOVE
LABOR EXP".
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 38 JANUARY 19, 2017
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 associated with the
following types of gas equipment: (a) Space heating, (b) Water heating, and (c) Cooking.
STAFF RESPONSE NO. 65: For simplicity, 100% of non-winter (April-November)
average residential use per customer was considered to be for "basic needs," plus half of
Intermountain Gas's winter ( 4 months; December-March) average use per residential customer.
Staff did not attempt to make assumptions about the gas equipment included in basic needs
usage. The consumption level that represents "basic needs" is subjective, and will depend on
several factors, including: household size, location and whether the customer uses gas for space
heating, water heating, cooking and clothes drying. Please refer to sheet (tab) "BasicNeeds" in
Mr. Erdwurm's electronic workpapers (Excel file: PR #62-69.xls), which is included on the CD
produced with this response, for average residential use calculations
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 39 JANUARY 19, 2017
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.
STAFF RESPONSE NO. 66: Staff believes its proposed customer charges achieve a
reasonable balance for customers with varied usages. Even though the Company's COS study
was unusable, Staff believes its proposed increase to the customer charge is a reasonable
movement toward more cost-based rates. Movement toward cost-based promotes fairness to all
customers. Staff also considered bill impacts when it determined whether rates were fair. Mr.
Erdwurm explained on lines 5-13, page 17, of his pre-filed testimony that the proposed
residential customer charge was constrained by customer impact considerations. See Erdwurm
Exhibit Nos. 113-115.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 40 JANUARY 19, 2017
REQUEST NO. 67: Staff Testimony ofB. Erdwurm, page 17, lines 1-13. Please
provide the customer charges for all classes and all peer utilities researched.
STAFF RESPONSE NO. 67: Staff reviewed residential customer charges for the
following utilities. Results are included in the table:
R 'd . 1 C Ch es1 entia ustomer arges:
Utility State
Avista WA
Avista ID
NW Natural OR
NW Natural WA
Questar UT
Questar WY
SW Gas NV
MDU MT
MDU WY
Cascade OR
Cascade WA
s ff ta rev1ewe d h £ 11 t e o owmg G enera 1 S erv1ce C
Utility
Avista
Avista
NW Natural
NW Natural
Questar
Questar
SW Gas
MDU
MDU
Cascade
Cascade
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS
State
WA
ID
OR
WA
UT
WY
NV
MT
WY
OR
WA
Monthly Charge
$9.00
$5.25
$8.00
$7.00
$6.75
$12.00
$10.80
$7 .91
$15.81
$3 .00
$4.00
ustomer Ch arges (£ mallest GS customers): ors
Monthly Charge
$9.00
$5.25
$15.00
$15.00
$18.25
$32.50
$18.25
$13 .99
$20.38
$3 .00
$10.00
41 JANUARY 19, 2017
REQUEST NO. 68: Please provide all workpapers and documentation relied on in
support of demand charge of $0.20 per therm, 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?
STAFF RESPONSE NO. 68: Mr. Erdwurm considered the percentage of large volume
and transportation revenue recovered through MDFQ charges. The implementation of a $0.20
MDFQ charge results in 28% ofrevenue being collected through demand charges under Staff's
rate design. If the MDFQ charge is $0.30, 42% ofrevenue would be collected through demand
charges given Staff's proposed revenue requirement. Currently, revenue is collected
volumetrically through usage charges. Mr. Erdwurm states on lines 14-18, page 19 that
introducing demand charges shifts costs from high load factor customers to low load factor
customers, and that this is appropriate given that low load factor customers are more costly to
serve, other things constant. Staff does not have newly nominated MDFQ by customer;
therefore, Staff cannot calculate specific customer impacts.
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.
STAFF RESPONSE NO. 69: The phase-in period would depend on the Company's
future proposals. Staff assigned to this proceeding cannot commit to future positions.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS 42 JANUARY 19, 2017
STAFF WITNESS ST ACEY DONOHUE WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 70-71,
BELOW.
REQUEST NO. 70: Is it Staff's 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?
STAFF RESPONSE NO. 70: Staff is open to discussing the establishment of a cost
recovery measure slightly before or concurrent with its DSM investments. Staff believes it could
be appropriate for the Company to establish a Commission approved DSM deferral account for
later recovery of prudently incurred expenses.
REQUEST NO. 71: What frequency of EM7V 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?
STAFF RESPONSE NO. 71: Staff generally expects that DSM programs are evaluated
every 2 to 3 years. However, this schedule can be adapted to align with program maturity and
acquisition. Staff recommends that the Company consult with independent, third party
evaluators and its energy efficiency advisory committee regarding best practices for evaluating
new programs.
STAFF 'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 43 JANUARY 19, 2017
DATED at Boise, Idaho, this
Technical Staff: Terri Carlock/1-12
Michael Morrison/13-36
Randy Lobb/37-44
Donn English/45-51
Terri Carlock/53-56
Joseph Terry/57-61
Bentley Erdwurrn/62-69
Stacey Donohue/52, 70-71
i:umisc/intg 16.2 Staff I" Response to lntermountain Gas
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
INTERMOUNT AIN GAS
day of January 2017.
Deputy Attorney General
44 JANUARY 19, 2017
Response No. 8. Return on Equity provided for large utility companies providing service in Idaho
COMPANY Case No. Order &
Date
AVISTA AVU-E-08-01 ON 30647
AVU-G-08-01 9/30/2008
AVISTA AVU-E-09-01 ON 30856
AVU-G-09-01 7/17/2009
AVISTA AVU-E-10-01 ON 32070
AVU-G-10-01 9/21/2010
AVISTA AVU-E-11-01 ON 32371
AVU-G-11-01 9/30/2011
AVISTA AVU-E-12-08 ON 32769
AVU-G-12-07 3/27/2013
AVISTA AVU-E-15-05 ON 33437
AVU-G-15-01 12/18/2015
AVISTA AVU-E-16-03 ON 33682
12/28/2016
Idaho Power IPC-E-05-28 ON 30035
5/12/2006
Idaho Power IPC-E-07-08 ON 30508
2/28/2008
Idaho Power IPC-E-08-10 ON 30722
1/30/2009
Idaho Power IPC-E-11-08 ON 32426
12/30/2011
Rocky Mountain PAC-E-05-01 ON 29878
Power 9/30/2005
Rocky Mountain PAC-E-07-05 ON 30482
Power 12/28/2007
Rocky Mountain PAC-E-08-07 ON 30783
Power 4/16/2009
Rocky Mountain PAC-E-10-07 ON 32196
Power 2/28/2011
Rocky Mountain PAC-E-11-12 ON 32432
Power 1/10/2012
Rocky Mountain PAC-E-13-04 ON 32910
Power 10/24/2013
United Water Idaho UWI-W-04-04 ON 29838
8/3/2005
United Water Idaho UWI-W-06-02 ON 30104
7/24/2006
United Water Idaho UWI-W-09-01 ON 31016
3/5/2010
United Water Idaho UWI-W-11-02 ON 32443
1/24/2012
United Water Idaho UWI-W-15-01 ON 33436
Authorized
ROE
10.2%
10.5%
ROE Not
specified
ROE Not
specified
9.8%
9.5%
9.5%
ROE Not
specified
ROE Not
Specified
Settled RR
10.5%
ROE Not
specified
ROE Not
specified
10.25%
10.25%
9.9%
ROE Not
specified
ROE Not
specified
10.3%
ROE Not
specified
ROE Not
specified
ROE Not
specified
ROE Not
specified
Company
Requested
10.8%
11.0%
10.9%
10.9%
10.9%
9.9%
9.9%
11.25%
11.5%
11.25%
10.5%
11.0125
10.75%
10.75%
10.6%
10.5%
9.9%
11.1%
10.3%
10.4%
10.5%
10.4%
Staff
Proposed
Settled
Settled
Settled
Settled
Settled
Settled
Settled
Settled
10.25%
10.25%
Settled
Settled
10.25%
10.25%
10%
Settled
Rate Plan
10%
10.3% prior ROE
authorized
Settled
Settled
9.2% -9.5% depend
Capital structure
Attachment to Response No. 8
Case No. INT-G-16-02
T. Carlock, Staff
01/19/17
Record Holder: Mike McGrath; 208-377-6000
Location: 555 S Cole Rd. Boise. ID 83 707
Sponsor/Preparer: Lori Blattner: 208-377-6000
REQUEST NO. 28: Please describe the method and provide the workpapers used to weigh
customer weather data described on page 4 of Ms. Blattner' s testimony.
RESPONSE TO REQUEST NO. 28:
The data used to weight the weather data by customers (which is referred to in this response
as "Rate Study'') is stored in a clustered Sq/Server database. Data is imported and processed by
Sq/Server jobs running on the production server. All code used by Rate Study is stored on the
secured product ion server. The code consists of stored procedures, functions and views.
Sq/Server Jobs to collect external data:
Rate Study -Import Actual Temps
Rate Study -Import Billing Data
The section highlighted by dashed lines in Chart I on the following page represents the
stored procedure that calculates the normalized temperatures. The weighting is calculated through
a series of database views (SQL code) using billing data and normalized temperature data. The
final weighted iveather is weighted by the proportion of customers in each weather region and
billing cycle.
The following flowchart shows the weighting process:
Attachment to Response No. 41
Case No. lNT-G-16-02
R. Lobb, Staff
01/19/17 Page I ofl6
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 5
PR#28 Chart 1
Calculate Normal Weather ~ fc~k:u~tt_nonn~l_ttmps_evt~_ ------------
I I DI.L I l>IT!S L£N' YEAAS
I
I
I • ~-:_J I I BIU. DATE 'fEAAS V I I
""""""'".,... )--1 "''"l'ram,I ) OR.L ----.j }--BR.L
l>ITA WW CATA Sl.MMAAY _ V -hORMA1.. TE~.PS -=pot,ch wth oates
I
I I •
il!.t:"1)ral'NI \ Tl'.P NOR>\,11. TfMl'S \/IEW -wt1li OATfS ,,.,. ..... I l '---------------------------------
H.L TMPNORMAI. TEMPS
OITA WUCHT!O_V cYaf OAT!
I '11£\V
1
TMP~T!fol'S
Y,OCT[DCYO.£ f----..j •JEW }--t l;OONAl m'f'S
l>ITf_V wtJCTro_v
Record Holder: Mike McGrath; 208-377-6000 --~~~-~-~--~-~~---
Location: 555 S Cole Rd, Boise, ID 83707 -----~~~---~-~-~~~--
Sponsor/Preparer: __ L~o~n_· _B_la_ttn_er~,_2_0_8_-3_7_7_-_60_0_0 __ _
REQUEST NO. 29: The Company provides different customer counts in its Application
and throughout the testimony of several witnesses. Please explain the following discrepancies,
particularly how any corrections might impact the proposed rates:
• Application at pg. 2 334,650
• Kivisto Direct at 2, ln. 14 339,000
• Madison Direct at 2, In. 9 334,650
• Gilchrist Direct at 5, lns. 2, 3 334,650
• Gaske Direct at 4, In. 13 320,000
• Blattner Workpaper No. 8 338,798
RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page 2 of 16
Page 6
RESPONSE TO REQUEST NO. 150:
Customer rate class migrations relate lo the Company's general service, large volume, or
transport customers who have changed rate classes at some point during the test year. The
Company removed these customers' actual and.forecasted volumes. revenues, and cost of gas
.from the customer's previous rate class and included them for a fi1ll twelve month period in the
wstomer 's new rate class. Please see the file labeled "PR#l 50 Industrial Migrations Summary "
for a summary of the migrations that occurred during the test year.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer: Jacob Darrington, 208-3 77-6000
REQUEST NO. 151: Please provide unadjusted monthly consumption and customer
counts by rate class, for all rate classes, for the period from October 1989 through September
2016.
RESPONSE TO REQUEST N0.151:
Please see CD file labeled "PR 151 Billing Register Oct 2002-2014. " This.file includes
the monthly customer count and consumption data for the period o_f October 2002 through
December 2014. Prior to October 2002, the requested data is not available electronically.
However. the large binders containing billing data from 1989 through September 2002 are
stored on-site in Jntermountain's vault. lntermountain stands ready to set up an on-site visit.for
Stajfwhere this data could be reviewed. The data.for 2015 -2016 was submitted in response to
PR 113 and 114 (see "PR 113 & 114 2015 Billing Data" and "PR 113 & 114 2016 Billing
Data. "j.
Some changes in Jntermountain's rate classes will be noted over time in reviewing the
electronic data. In 2008, lntermountain cancelled its T-1 and T-2 Industrial tar[ffs. The
RESPONSE OF !GC TO SEVENTH PRODUCTION REQUEST OF COMMISS ION STAFF Page 16
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page3ofl6
customers that 1-vere previously on the T-1 tar(ff were rolled into the T-./ class, and the customers
that were previously on the T-2 tariff were moved to the new T-5 tariff In 2010. the Company
added residential and commercial snowmelt tariffs. Existing customers with snoH1melt
equipment were grandfathered onto their existing rate schedules.
Over the time period of 1989 through 2016, Intermountain has made several changes in
Customer Information Systems (CJS). Each CIS conversion has brought with it a new definition
of customers and d(fferent ways that the data could be reported and analyzed.
The Legacy CIS system, ·which was in place prior to July 2004. counted customers as
each account that received a customer charge. Adjustments were done in the customer's billing
cycle, so there were no out of cycle adjustments sent.
With the migration to the Customer Watch system in July of 2004, the customer count
was based on account package. This meant that each customer that received a customer charge
or gas charge at a premise during the month counted as a customer. In addition tu regular
monthly billing. if the customer at a premise was billed again with a d(fferent rate or Inside City
Limits/Outside City Limits this would add one to the customer count. In the Customer Watch
system adjustments were called cancellrebills. Cancel/rebills were processed and billed as they
were discovered, and not necessarily with the normal monthly billing.
In July of 2015, Intermountain migrated to the CCB billing system. In this system,
customer counts are based on metered services ·with an active utility service agreement on a
given date, normally al accounting month end. Cancel/rebills can also be processed out of cycle
in this system, so there can be adjustment therms included in a different cycle from the cycle in
which the customer is normally billed, however, these would not affect the customer count.
In 2002, Intermountain established a database ("Weather System "j to house data used in
forecasting and weather normalizing usage. This separate database allowed Intermountain to
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMM ISSION STAFF Page 17
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page4ofl6
establish parameters for usage per customer data that were different.from those reported in the
billing data. It also replaced an old main:frame system that was used to weight the weather data.
As the Company has made decisions about the data included in the Weather System, the guiding
principal has been that since we are using the equations that result.from this data to measure a
customer's response to temperature, an accurate matching of customers, usage and weather is
important.
The Weather System only includes data for customer classes that are considered
temperature sensitive. The classes included are:
• RS-1
• RS-2
• GS (excluding CNG (GS-12) and water pumper (GS-60) customers)
It does not include any industrial customers or snowmelt customers.
Intermountain's Weather System counts customers based on account in CC&B, premise
in Customer Watch, and premise in Legacy. The common element between these 3 definitions is
that there was a bill associated. The Company felt these customer definitions provided the most
continuity between the CJS systems. Adjustments (or cancel/rebills) have also been removed
from the Weather System data. The idea here is that adjustments hit in a single month. but may
have been caused by several prior months. Removing the ac{justment altogether ensures that the
Company is measuring the true customer response to temperature, and that an extraneous event
does not unduly influence that match.
Finally, with the implementation of Customer Watch, the Company had the ability to
restrict the customer count to only count those customers that had therm usage each month on
their bill. This gives a true measure of a customer 's response to temperature and allmved the
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff Company to more accurately forecast usage in the summer months.
01/19/17 Page5ofl6
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 18
Although Intermountain has data available back as far as 1989, because ofstructural
changes in the ·way customers use natural gas over time and the way data is collected,
lntermountain decided to restrict the time series used to generate regression equations that are
used for weather normalization and usage forecasting to October 2003 -December 2014.
Several notable structural sh(fis have occurred in the data over time. First, new building
codes and ejjiciencyfactors have been implemented throughout Idaho. The Idaho Residential
Energy Code was adopted by many cities beginning in 1991. This new building standard was
designed to improve the energy efficiency of new homes. In addition, efficiency standards.for
furnaces and water heaters began to improve during the late 1980 's. Although these standards
only applied to new homes and new purchases, lntermountain has seen tremendous growth in its
customer base since that time. Over 60% of its customers are new since 1990. These customers
would be using the new standards and equipment. and as they become a larger percentage of the
customer base, they have had a gradual impact on therm usage per custom er.
Further, price stability has changed dramatically over time. Until 1999 there was a
period of relatively stable prices. Beginning with the prices effective in August 1999, however,
the country entered a period of extreme price volatility with a generally increasing price trend
ft appeared that prices reached a new equilibrium around 2003, following the transition to this
new price environment. Because all of these factors would cause a sh(fi in the data,
lntermountain chose to shorten the time series upon which the regression equations are built to
I I years of data.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd. Boise. ID 83707
Mike McGrath. 208-377-6000
RESPONSE OF IGC TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page6of16
Page 19
------------------------------------------------------
Group 1 meters are generally used in residential and small commercial applications.
Group 2 turbine meters and Group 3 rotary meters are most commonly used in large commercial
and industrial applications. Intermountain used Group I meters to create a weighted customer
allocator (WEIGHTED!) that was used to allocate costs included in Ratebase accounts,
1010.3810. 3820, 3830, and 3840. It was also used to allocate the O&M accounts 4010.28780
and 28783 as well as 4020.28930.
lntermountain combined Group 2 and Group 3 meters to create a weighted customer
allocator (WE!GHTED2) that was used to allocate costs included in Ratebase account
f 010.3850.
Record Holder: Mike McGrath. 208-377-6000
Location: 555 S Cole Rd. Boise, ID 83707
Sponsor/Preparer: Lori Blattner. 208-377-6000
REQUEST NO. 201: In its supplemental response to Staffs Production Request No. 27,
the Company provided per-customer consumption for the period October 1989 through March
2015. Please: (I) explain the source for the consumption data and numbers of customers used to
determine per-customer consumption; (2) identify and explain all adjustment and data processing
that was performed on these numbers; and (3) provide workpapers, with in-tact links, showing
how per-customer consumption was obtained from the original source data.
RESPONSE TO REQUEST NO. 201:
(1) The source for the usage per customer data provided in response to Production
Request No. 2 7 is the Company ·s Weather System that is explained in detail as part of
Production Request No. 15 I. The data housed in that system originated from the Company's
billing database.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page7ofl6
Page 2
-----------------------------
(2) As Production Request No. I 51 outlines, the data housed in the Weather System is
downloaded from the Company's billing database based upon a certain set of parameters.
Therefore, no data processing was pe1formed on these numbers. The Company does not include
therm adjustmentslcancel-rebills in the usage per customer data loaded into the Weather System.
Beginning in July of 200-1, the Company also limited the customer count to those customers with
therm usage. Although the Company provided all the data that resides in its Weather System
database, only datafrom October 2003 -December 2014 11·as used in the development of the ·
regression equations.
(3) The calculations for usage per customer are performed internally in the Company's
Weather System software. The customer information system database was queried to select
customers and therms based on the parameters outlined in Jntermountain 's reply to Production
Request No. I 5 I. The que1y data that was extractedfrom Jntermountain 's CIS .systems and thCll
iras used in the calculation of usage per customer is included with this response as "PR 201
WTH RO I 20 I 989-20 I 6csv.xlsx ".
The definitions of the.file heading are as follows:
bill_rate_class is the rate class (RS-I = I; RS-2 = 2: GS = I I)
bill nbr services is the number of services (customers)
bill_ nbr_therms is the number of therms
Record Holder: Mike McGrath. 208-377-6000
Location: 555 S Cole Rd. Boise. JD 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
REQUEST NO. 202: Please provide a breakdown of Capital Expenditures in FERC
accounts 380,381,382,383 ,384, and 385 and by existing rate class .
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page8ofl6
Page 3
Randy Lobb
From:
Sent:
To:
Subject:
Gents:
Mike Morrison
Friday, October 07, 2016 11:10 AM
Sean Costello; Randy Lobb
FW: Billing and Rate Determinants
Here's the e-mail that I sent to Lori. I also left a voice mail message. When we chat, I plan to:
a. Convey the importance of providing us ALL of this information .
b. My frustration with the Company's piecemeal dissemination of this information.
c. How close we are to getting attorneys involved:-)
d. The desire to have a meeting with myself, Bentley, Randy, Lori, and other Company employees who can
provide this information in a timely matter. ·
e. Explain, in detail, what I'm lacking.
f. Listen to whatever Lori tells me.
M"2
From: Mike Morrison
Sent: Friday, October 07, 2016 11:03 AM
To: 'Blattner, Lori' <[e-mail]>
Subject: Billing and Rate Determinants
Hi Lori:
I left a voice mail message. I'm having difficulty understanding how you got from your weather normalization model to
the billing determinants used by Mr. Darrington (Exhibit 15). In particular, I would like to know how the Company
determined:
a. Test Year Customer counts, by class and by month.
b. Test Year Therm adjustments by class and by month.
c. How Adjusted Therms were allocated to rate blocks by class and by month.
d. How Test Year Demands were determined by class and by month.
e. How were customer migrations determined?
Also, in Exhibits 24, 27, and 28, Mr. McGrath uses customer counts, Therm adjustments, and Test Year demands that I
have been unable to duplicate.
It is very important that I be able to duplicate these numbers independently, and at the moment I am unable to do
that. Please call me as soon as possible.
Mike Morrison
[phone] {IPUC)
[phone] (Cell)
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page9ofl6
Randy Lobb
From:
Sent:
To:
Cc:
Subject:
Lori:
Mike Morrison
Wednesday, October 12, 2016 4:42 PM
Blattner, Lori
Bentley Erdwurm; Randy Lobb
Friday's Meeting
I chatted with Bentley and Randy today. We would like the Company to walk us through all of the spreadsheets, data,
assumptions, and calculations that were ultimately used to determine the Company's revenue proof. In particular, we
would like you to show us:
1. How the Company determined customer counts by month and by rate class for the test year (Darrington
Exhibit 15 p. 10)
a. Migration adjustments.
b. Forecast increases for each class.
2. How the Company determined the weather normalization adjustments by rate class and by month
(Darrington Exhibit 15 p. 8)
3. How the Company determined forecast Therms (July through December, Darrington Exhibit 15 p. 8).
4. Which subclasses were included in the weather normalization regression?
a. How were the various GS subclasses, e.g. GS-11, 12, 60, CNC treated?
b. How were snow melt classes handled in regression? Were they included in modeling?
4. How the Company determined Migration/Weather normalization adjustments to GS blocks shown in lines
25, 26, and 27 of Darrington Exhibit 15 p. 8.
a. How were adjusted therms allocated to different rate blocks?
5. The Company proposes a two-block rate schedule for CNG vehicular fuel. How were these charges
incorporated into Darrington's exhibits?
6. Please explain the use of the numbers in Columns T through AE of Exhibit 24, 27, 28 tab "Current Therms,
Cust, Revs".
a. How were they calculated?
Thanks,
Mike Morrison
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Pagel0ofl6
Randy Lobb
From:
Sent:
To:
Cc:
Subject:
Mike Morrison
Thursday, October 13, 2016 8:17 AM
Blattner, Lori
Bentley Erdwurm; Randy Lobb
RE: Friday's Meeting
In the version of the model you provided for me, these numbers are in the order of $0.20--Much lower than the
Company's current volumetric rate.
It is obtained using the following formula: =1ND1RECT("CUR_"&$B4&"_"&$B6&T$1), which refers to a hard coded value
in EXCEL's name manager.
In this context, we would like the Company to explain how these numbers are being used.
Mike
From: Blattner, Lori [mailto:[e-mail]]
Sent: Wednesday, October 12, 2016 5:31 PM
To: Mike Morrison <[e-mail]>
Cc: Bentley Erdwurm <[e-mail]>; Randy Lobb <[e-mail]>; McGrath, Mike
<[e-mail]>
Subject: RE : Friday's Meeting
Hi Mike,
Thank you for sending over this list. It will be very helpful in making sure we are able to get all of your questions
answered.
If it is helpful in keeping your review moving along, I think I can provide a quick answer to 6.a. below. If this doesn't
answer it, we can definitely address it more completely on Friday.
6. Please explain the use of the numbers in Columns T through AE of Exhibit 24, 27, 28 tab "Current Therms,
Cust, Revs".
a. How were they calculated?
The numbers in Columns T through AE are our current customer charge and margins for each class. The model is
pulling the information from the "Rates" tab.
We're looking forward to seeing you Friday.
Lori
From: Mike Morrison [mailto:[e-mail]]
Sent: Wednesday, October 12, 2016 4:42 PM
To: Blattner, Lori <[e-mail]>
Cc: Bentley Erdwurm <B [e-mail]>; Randy Lobb <[e-mail]>
Subject: Friday's Meeting
*** This is an EXTERNAL email. Exercise caution. *** Attachment to Response No. 41
----------------------------------case No. INT-G-16-02
1 R. Lobb, Staff
01/19/17 Page 11 of 16
Lori:
I chatted with Bentley and Randy today. We would like the Company to walk us through all of the spreadsheets, data,
assumptions, and calculations that were ultimately used to determine the Company's revenue proof. In particular, we
would like you to show us:
1. How the Company determined customer counts by month and by rate class for the test year (Darrington
Exhibit 15 p. 10)
a. Migration adjustments.
b. Forecast increases for each class.
2. How the Company determined the weather normalization adjustments by rate class and by month
(Darrington Exhibit 15 p. 8)
3. How the Company determined forecast Therms (July through December, Darrington Exhibit 15 p. 8).
4. Which subclasses were included in the weather normalization regression?
a. How were the various GS subclasses, e.g. GS-11, 12, 60, CNC treated?
b. How were snow melt classes handled in regression? Were they included in modeling?
4. How the Company determined Migration/Weather normalization adjustments to GS blocks shown in lines
25, 26, and 27 of Darrington Exhibit 15 p. 8.
a. How were adjusted therms allocated to different rate blocks?
5. The Company proposes a two-block rate schedule for CNG vehicular fuel. How were these charges
incorporated into Darrington's exhibits?
6. Please explain the use of the numbers in Columns T through AE of Exhibit 24, 27, 28 tab "Current Therms,
Cust, Revs".
a. How were they calculated?
Thanks,
Mike Morrison
2
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page 12 of 16
Randy Lobb
From:
Sent:
To:
Cc:
Subject:
Lori & Mike:
Mike Morrison
Friday, October 21, 2016 9:36 AM
Blattner, Lori; McGrath, Mike
Mike Louis; Randy Lobb
Weather Normalization Customer Adjustments
I need the monthly customer counts, by class (RS-1, RS-2, and GS), used to determine the per-customer consumption
numbers provided in the Company's first supplement to its response to Production Request Number 27. This would
cover the period from October 1989 through April, 2015. I have only received the customer counts for June through July
of calendar years 2011 through 2015.
Thanks,
Mike Morrison
[phone]
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page13of16
Randy Lobb
From:
Sent:
To:
Cc:
Subject:
Attachments:
Mike,
Blattner, Lori <[e-mail]>
Tuesday, October 25, 2016 2:13 PM
Mike Morrison; McGrath, Mike
Mike Louis; Randy Lobb
RE: Weather Normalization Customer Adjustments
Customer Counts.xlsx
I'm sorry it has taken a couple of days to get this information to you. I was out last week, so I am still working on getting
caught up. Attached you will find a file that includes customer data from July 2004 forward. July 2004 was when we
implemented our previous billing system (Customer Watch). I was not able to go back and extract customer counts from
the data that was stored from the legacy system that preceded Customer Watch. The attached file includes a tab for RS-
1, RS-2 and GS. Each tab is set up the same way with the Weather Normalization Customers at the top and the Billed
Customers at the bottom. As you recall from our meeting, Weather Normalization customers are the ones upon which
the regression usage per customer data is calculated. These customer counts do not include customers that had zero
usage for the month. The Billed Customer numbers include zero usage customers. As I discussed in the meeting, we
have adjusted the usage forecast to account for these zero usage customers.
Regards,
Lori
From: Mike Morrison [mailto:[e-mail]]
Sent: Friday, October 21, 2016 9:53 AM
To: Blattner, Lori <[e-mail]>; McGrath, Mike <[e-mail]>
Subject: RE: Weather Normalization Customer Adjustments
*** This is an EXTERNAL email. Exercise caution. ***
I should probably clarify:
I will need both the unadjusted and the adjusted customer counts used for each month of the period from October 1989
through April 2015.
Mike
From: Mike Morrison
Sent: Friday, October 21, 2016 9:36 AM
To: 'Blattner, Lori' <LO [e-mail]>; 'McGrath, Mike' <[e-mail]>
Cc: Mike Louis <[e-mail]>; Randy Lobb <[e-mail]>
Subject: Weather Normalization Customer Adjustments
Lori & Mike:
I need the monthly customer counts, by class (RS-1, RS-2, and GS), used to determine the per-customer consumption
numbers provided in the Company's first supplement to its response to Production Request Number 27. This would
cover the period from October 1989 through April, 2015. I have only received the customer counts for June through July
of calendar years 2011 through 2015. Attachment to Response No. 41
1 Case No. INT-G-16-02
R. Lobb, Staff
01 /19/17 Page 14 of 16
Thanks,
Mike Morrison
[phone]
2
Attachment to Response No. 41
Case No. lNT-G-16-02
R. Lobb, Staff
01/19/17 Page 15 of 16
Randy Lobb
From: Mike Morrison
Sent:
To:
Tuesday, November 01, 2016 9:42 AM
Randy Lobb
Subject: Intermountain Gas Revenue Proof
I thought you would be interested.
Here's the revenue proof submitted by the Company. In the original spreadsheet, all numbers are hard coded, so you're
not missing any information.
M"2
Revenue Requirement Proof
Total Operating Revenue (Exel Other Rev) $ 251,900,147
Cost of Gas
Margin
Revenue Shortfall
Rate Design Revenue Requirement $
168,822,659
83,077,488
10,165,700
93,243,188
1
Notes
Ex 14, pl, Line 1, Col (d)
Ex 14, pl, Line 4, Col (d)
Ex 14, pl, Line 3, Col (e)
Ex 24 p2, Line 65, Col (F) {current rates}
Ex 24, p4, Line 132, Col (F) {proposed rates}
Attachment to Response No. 41
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page 16 of 16
$
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
PEC EIVED
20:6 CCT 26 PH 3: 55
: . ···; J '.: LIC
--:OW,1 IS SION
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATIER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
)
Case No. INT-G-16-02
SUPPLEMENT AL RESPONSE OF
INTERMOUNTAIN GAS
COMPANY TO FOURTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, supplements its response to the Fourth
Production Request of the Commission Staffto Intermountain Gas Company as follows:
REQUEST NO. 76: Please provide an Excel file showing all capital projects completed or
due to be complete by year from January 1, 2010 through December 31, 2016. For each project,
please include the following: project name, project number or identifier, cost of service
classification, description of the project, rationale for the project, target start date, actual start date,
target completion date, actual completion date, estimated cost, and actual cost associated with each
project.
RESPONSE TO REQUEST NO. 76:
The file "PR #76 CapEx Detail" provides data that is available from 2013 through 2015.
For 2010 -2012, detailed project data is unavailable for those work orders converted from JD
Edwards when the Company began using Power Plan. The requested data is not available by
project in the Company's records until the conversion from JD Edwards to Power Plan in May of
2013. There are currently issues with projects that were converted in 2013 for active work orders
SUPPLEMENT AL RESPONSE OF JGC TO FOURTH PRODUCTION REQUEST OF COMMISSION STAFF Page I
Attachment to Response No. 42
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Pagelof6
------------------·
ar that time creating reporting issues.for the affected work orders. Due to this issue 2013 is not
included with this submission, and 1rill be provided q(ter the issue has heen resolved
Record Holder: Mike McGrath. 208-377-6000
Location: 555 S Cole Rd, Boise. JD 83 707
Sponsor/Preparer: Ted Dedden, 208-377-6000
REQUEST NO. 95: Please provide documentation including accounting entries and
underlying reasoning for the $1 million negative amount in additions in Mains (account 367) during
2015 according to the 2015 plant schedule.
RESPONSE TO REQUEST NO. 95
Please see CD file labeled "P R#95 ". Transmission mains (Account 367) had a
misclassification o.f 5967.468. 77/or Contributions in Aid of Construction (CJAC) that should have
been recorded in distrib11tion 111ai11s (Account 376). A review of the Power Plan co11fig11ratio11 is
being underraken and the CJAC 1ri// be reclassified ro the proper accozmr when rhe co,?figurari on
issue is resolved.
Record Holder: Mike McGrath. 208-377-6000
Location: 555 S Cole Rd. Boise. JD 83707
Sponsor/Preparer: Ted Dedden. 208-377-6000
DA TED at Boise, Idaho, this 261h day of October, 2016.
Respectfully submitted,
J?.i!LW~
Ronal d L. Williams
Williams Bradbury, P.C.
Attorneys for lntermountain Gas Company
Slll'PLEMI-Xl",\l. RESPONSE OF IGC TO FOURTI I PRODUCTION REQUEST OF C0i'vl:v11SSl0N ST,\FF Pag, 2
Attachment to Response No. 42
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page2of6
1. Since large pipe sizes (10, 12 and I 6 inch diameter) are generally transmission mains and
transmission mains are allocated based on a peak day allocator, those large pipe sizes were
removed from the equation data.
2. Data for a particular pipe diameter was removed for years that showed very low footage
installed with an accompanying high cost. This outlier data was deemed to not be
representative of normal operations.
3. Early in the Company's history, some 3. 5 inch diameter steel pipe was installed. It has not
been installed since, so that data was also removed.from the model.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath. 208-377-6000
555 S Cole Rd, Boise. ID 83707
Lori Blattner, 208-377-6000
REQUEST NO. 100: Please provide the following data for work orders that were used in
the Mains Study:
a. Work Order Number;
b. Year;
c. Pipe type (plastic/steel);
d. Pipe Length;
e. Total Cost.
RESPONSE TO REQUEST NO. 100:
The requested data is not available by project in the Company ·s records until the conversion
to Power Plan in May of 2013. The CD.file labeled "PR JOO JGC 367 and 376.xlsx "provides the
data that is available for 2013 through 2015. The projects listed in 2013 that do not have footage
included are for those work orders converted.from JD Edwards when the Company began using
Power Plan.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise. ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
REQUEST NO. 101 : Currently, the Company's line and mains extension charges (Tariff
Section C) are computed using a 12.5% Rate of Return. Please provide updated tariff sheets that
reflect the Company's proposed Rate of Return. Please provide work papers supporting these
changes.
RESPONSE TO REQUEST NO. 101:
Attachment to Response No. 42
Case No. INT-G-16-02
R. Lobb, Staff
01 /19/17 Page3of6
RESPONSE OF JGC TO FOURTH PRODUCTION REQUEST OF COMMISSION STAFF, Page 18
(2) As Produclion Request No. l 5 l outlines, the data housed in the Wea/her System is
downloaded from the Company's billing database based upon a certain set ofparameters.
Therefore, no data processing was performed on these numbers. The Company does not include
therm adjustmenlslcancel-rebills in the usage per customer data loaded into the Weather System.
Beginning in July of 200,J, the Company also limited the customer count lo !hose customers ·with
lherm usage. Al/hough the Company provided all !he dala that resides in its Wea/her System
dalabase, only dataji-mn October 2003 -December 2014 was used in the development of the
regression equations.
(3) The calculations for usage per customer are performed internally in the Company 's
Weather System software. The customer information system database was queried to select
customers and therms based on the paramelers outlined in Intermountain 's reply to Production
Request No. J 5 !. The que,y data that was extracted from Jntermountain 's CJS systems and that
was used in the calculation of usage per customer is included with this response as "PR 201
WTHROJ 20 1989-2016csv.xlsx".
The definitions of the.file heading are asfollrrws:
bill_rale_c!ass is the rate class (RS-! = l ; RS-2 = 2: GS = 11)
bill_ nbr_ services is !he number o_fservices (cuslomers)
bill_ nbr_lherms is the number of therms
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer: Lori Blattner. 208-377-6000
REQUEST NO. 202: Please provide a breakdown of Capital Expenditures in FERC
accounts 380, 381, 382, 383 , 384, and 385 and by existing rate class.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF
Attachment to Response No. 42
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page4of6
Page 3
RESPONSE TO REQUEST NO. 202:
Please see the CD.file labeled "PR #202 Plant Act Bals YTD Sep 2016.xlsx "for the
breakdmvn of actual account balances.for January through September 2016. For the forecasted
months of October -December 2016, please re.fer to file "Gas Plant in Service.xlsx ,. submitted
in response to Production Request No. 178.
lntermountain ·s accounting records have never provided the fimctionality to track plant
and accumulated depreciation by rate class for FERC accounts 380. 381. 382, 383, 384, and
385. Since this type of direct assignment was not possible, lntermountain chose to use an
industry accepted practice to all.ocate these accounts to the various customer classes.
Because lntermountain can associate its meters in service with a customer class, the
Company was able to determine the number of each type of meter currently installed for each
rate class. lntermountain then valued those meters at the current replacement cost for each
meter. The total current cost of the meters for each class was calculated and then averaged by
the number a/meters in each class. That average meter cost was indexed and then multiplied by
annual customers to create a weighted customer allocator. The weighted customer allocator
was split into Group 1 and Group 2 categories as outlined in the response to Production Request
No. 200. The calculation of the weighted customer allocator was included in response to
Production Request No. 33. "PR 33 2015 Meter Study -CONFIDENT!AL.xlsx ··. These
allocators were used to assign the FERC accounts 380-385 to lntermountain 's customer classes.
Record Holder: Mike McGrath. 208-377-6000
Location: 555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer: Ted Dedden. 208-377-6000
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF
Attachment to Response No. 42
Case No. INT-G-16-02
R. Lobb, Staff
01/19/17 Page5of6
Page 4
Randy Lobb
From:
Sent:
To:
Cc:
Subject:
Randy,
McGrath, Mike <[e-mail] >
Wednesday, November 23, 2016 10:10 AM
Randy Lobb
Ron Williams ([e-mail]); Karl Klein
IGC Accounting Records
During our discussion earlier this week, you had mentioned what I recall to be a belief that lntermountain's accounting
records may have historically provided for certain customer class breakouts but, with the implementation of the
Company's newer accounting software, that functionality was lost.
I turned to Ron for help to elaborate on the correctness of this accounting record keeping assumption but, of course,
Ron simply shrugged his shoulders leaving me to check on this after my return to the office. Turns out our legacy
accounting system, as well as our current accounting system, never did record a customer class breakout for the FERC
accounts in question.
I believe there are one or two outstanding Production Request questions that will allow the Company to provide this
clarification so I'll make sure this clarification becomes part of the record.
Thank you again for our earlier meeting and Happy Thanksgiving to you and yours.
Mike
Michael P. McGrath
Director-Regulatory Affairs
lntermountain Gas Company
Office : [phone]
[e-mail]
~
i.. INTERMOUNTAIN ' (1 GAS COMPANY
·~J;,/lll\f~..aflru:t.t-c
Attachment to Response No. 42
Case No. INT-G-I 6-02
R. Lobb, Staff
01/19/17 Page6of6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JANUARY 2017,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF INTERMOUNTAIN GAS COMPANY, IN CASE NO.
INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH
DIR -REGULA TORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
tbrooks@cab I ehuston. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
. BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre g@ri chardsonadams. com
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. [e-mail]
[e-mail]
[e-mail]
[e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83709
E-MAIL: [e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
SECRETARY ""'
CERTIFICATE OF SERVICE