20170210Staff to INT 95-100.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone] t334-03 t2
IDAHO BAR NOS . 515618743
N';CI iVED
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Street Address for Express Mail
472W, WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
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 FOURTH
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
Third Production Request to Commission Staff.
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOLINTAIN GAS
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I FEBRUARY TO,2OI7
STAFF WITNESS MICHAEL MORRISON WILL BE ABLE TO ANSWER
QUESTIONS ABOUT OR SPONSOR THE ANSWER TO REQUEST NOS. 95-97
BELOW.
REQUEST NO. 95: Is it correct that in the NT-G-06-03 case, Staff in Production
Request No. 2 ("Linear Regression Modeling") was critical of the Company for not addressing
the autocorrelation issues identified by the Durbin-Watson statistic ("The Durbin-Watson
statistic suggests that better specification of the model is possible. Has the Componyfollowed
up on that indication?")? [sic] Does Staff agree or disagree that autoregression is an accepted
practice for addressing autocorrelation?
STAFF RESPONSE NO. 95: This was a request for information, and not a criticism of
the model used by the Company in INT-G-06-03. As explained in Staffs response to Company
Request No. 24, the use of autoregressive terms is appropriate for some applications.
REQUEST NO. 96: Refening to page 11, lines 16-18 of Morrison Direct, please
explain your understanding of what information is available in the "system that the Company
uses to estimate line extension costs" and how this information could be used to allocate
distribution services regulators, and ERTs.
STAFF RESPONSE NO. 96: At a December 2,2016, meeting between Staff and Ted
Dedden et a1., the Company explained that it uses Power Plan software to develop work orders
and determine line extension costs. The Company further explained that it keeps detailed records
of the material, labor, and other costs associated with service line extensions. In its response to
Production Request No. 76, the Company explained that it has used Power Plan since 2013.
Based on this information, Staff believes that the Company possesses the information required to
allocate its distribution services, regulators, and ERTs in a manner that is analogous to the
methodology used to develop its Meters Study.
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 2 FEBRUARY IO,2OI7
REQUEST NO. 97: Referring to lines 7-9, onpage l5 of Dr. Morrison's direct
testimony, provide a list of all gas utilities that Mr. Morrison is aware of that maintain records at
this level of detail.
STAFF RESPONSE NO. 97: Avista Utilities.
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOI.INTAIN GAS J FEBRUARY IO,2OI7
STAFF WITNESS JOSEPH TERRY WILL BE ABLE TO ANSWER QUESTIONS
ABOUT OR SPONSOR THE ANSWER TO REQUEST NOS. 98-99, BELOW.
REQUEST NO. 98: With the most current BLS data available from 2015, what years
were used in the Mercer and Towers Watson surveys? What year's employee salary information
was used?
STAFF RESPONSE NO. 98: The Mercer and Towers Watson surveys were the 2016
surveys provided by the Company as Response to Staff s Production Request No. 166.
The Company employee salary information was the 2016 information provided in
response to Staff s Production Request No. 230.
REQUEST NO. 99: With Avista Corp. providing both natural gas and electric service,
would the labor cost as a percentage of total revenue comparison expected to be a like
comparison?
STAFF RESPONSE NO. 99: Staff witness Terry did not make any conclusions on the
comparability of the two companies for calculating the salaries adjustment. That comparison
was only used as an indicator that this is an area that should be analyzed.
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 4 FEBRUARY IO,2O17
STAFF WITNESS MICHAEL MORRISON WILL BE ABLE TO ANSWER
QUESTTONS ABOUT OR SPONSOR THE ANSWER TO REQUEST NO. 100 BELOW.
REQUEST NO. 100: What is Dr. Morrison's opinion of the appropriate Normal Degree
Days to be used for ratemaking purposes to include the specifics of the calculation and design of
that Normal? Are you aware of other cases brought before this Commission where that same
definition was used?
STAFF RESPONSE NO. 100: Staff objects that this question is ambiguous, confusing,
and requires a speculative response. Subject to these objections, Staff refers the Company to
page22,lines 8 and 9 of Dr. Morrison's testimony, and to Staffs responses to Production
Request Nos. 13, 15, and 18. Dr. Morrison's analysis used the HDD65 values provided by the
Company in its supplemental response to Staff Production Request No. 27.
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 5 FEBRUARY IO,2OI7
lrLDATED at Boise, Idaho, this / t day of February 2017
Sean Costello
Deputy Attomey General
Technical Staff: Michael Morrisor/95-97, 100
Joseph Terryl98-99
i:umisc/intgl6.2 Staff46 Responso to trntermountain Gas
STAFF'S RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
INTERMOUNTAIN GAS 6 FEBRUARY IO,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF FEBRUARY 2017,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE
FOURTH PRODUCTION REQUEST OF INTERMOUNTAIN GAS COMPANY, N
CASE NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
MICHAEL P MoGRATH
DIR - REGULATORY AFFAIRS
INTERMOLTNTAIN GAS CO
PO BOX 7608
BOISE TD 83707
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1OO1 SW 5TH AVE STE 2OOO
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
tbrooks@ cablehuston. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE TD 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 RIVAS
NW ENERGY COALITION
l IOI 8TH AVENUE
HELENA MT 5960I
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
PETER RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL : peter@richardsonadams. com
sre [e-mail]
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. 1 @us.af.mil
[e-mail]
Thomas j erni gan. 3 @us. af.mil
Ebony.payton. [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
I95I S SATURN WAY
STE lOO
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 : Andrew. [e-mail]
Jo /,A',,t
SECRETARY'/-
CERTIFICATE OF SERVICE