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HomeMy WebLinkAbout20230109INT to Staff Attachment - Response to No. 3_Cost Allocation Manual 2022.pdf2022 Cost Allocation Manual Table of Contents Overview ....................................................................................................................................... 1 MDU Resources Group, Inc. (MDUR) Allocations .......................................................................... 2 Shared Services ........................................................................................................... 2 Payroll Shared Services ......................................................................................................................... 2 Human Resources ................................................................................................................................. 3 Business Services .................................................................................................................................. 3 Enterprise Information Technology ...................................................................................................... 3 Administrative and General Services ........................................................................... 4 FutureSource ............................................................................................................... 5 Intermountain Gas Allocation of Cost to/from Others .................................................................. 6 Allocations to other MDUR Companies ........................................................................ 6 Allocations from other Utility Companies ...................................................................... 6 Intermountain Gas Allocations to Departments ........................................................................... 7 Exhibit I- MDUR Corporate Overhead factor ................................................................................. 9 Exhibit II- MDUR Usage of Boise GO ............................................................................................ 10 Exhibit III- Customer Allocation Factors ...................................................................................... 12 Exhibit IV- MDUR Shared Services Pricing Methodology ............................................................. 12 Exhibit V- Utility Operations Support Allocation Methodology ................................................... 18 Exhibit VI – MDU Executive Usage of Boise GO ……………………………………………………………………………………. 27 2022 Cost Allocation Manual Page 1 Overview Intermountain Gas Company (IGC), a subsidiary of MDU Resources Group, Inc. (MDUR), conducts business in five geographical districts throughout Southern Idaho. Intermountain Gas Company is a singular legal entity with its own set of financial records. However, utility related rate base and income statement items, whether directly assigned or allocated, are captured in a unique financial ledger to provide for regulatory reporting. The operations of IGC are under the direction of one Utility Group (UG) executive leadership team. FutureSource Capital Corporation (FutureSource) is a separate legal entity that owns the corporate campus facilities that house the MDUR corporate staff and other property utilized in providing services to the operating companies within MDUR. Below is an overview of the operational structure for the purpose of assigning costs. The diagram presented is intended to provide an overview for cost allocation only and is not intended to represent the legal structure of the Corporation. Note that costs from MDUR and FutureSource are directly assigned or allocated and charged to the operating companies (i.e., Utilities Group, WBI Energy, etc.) 2022 Cost Allocation Manual Page 2 This document is intended to provide an overview of the different types of allocations and the processes employed to direct costs to the proper business unit for Intermountain Gas. This document will discuss the allocations to/from: • MDUR and FutureSource to Intermountain Gas • Intermountain Gas to other companies within MDUR • Intermountain Gas to Cascade Natural Gas Company (CNGC) and Montana-Dakota Utilities (MDU) Overall, the approach to allocating costs at each level is to directly assign costs when applicable and to allocate costs based on the function or driver of the cost. MDU Resources Group, Inc. (MDUR) Allocations The MDUR corporate staff consists of shared services departments (payroll, human resources, business services and enterprise information technology), and administrative and general departments. Shared Services MDU Resources Group, Inc. has several departments that provide specific services to the operating companies. These departments have developed a pricing methodology which is updated annually for the allocation of costs to the MDUR operating companies that utilize their services. (See Exhibit IV) These departments include: Payroll Shared Services Payroll Shared Services department provides comprehensive payroll services for MDUR companies and employees. It processes payroll in compliance with appropriate federal, state and local tax laws and regulations. Payroll Shared Services is also responsible for preparation, filing and payment of all payroll related federal, state and local tax returns. It also maintains and facilitates payments and accurate reporting to payroll vendors for employee benefits and other payroll deductions. For Intermountain Gas, the payroll shared services department is also responsible for the accumulation of time entry records 2022 Cost Allocation Manual Page 3 and maintenance of employee records. IGC does not have any departments that provide these payroll related services. Human Resources Human Resources operates as “One HR” across the regulated business units of MDU Resources Group including Montana-Dakota, Great Plains, Cascade Natural Gas, Intermountain Gas, and WBI Energy. There are employees in the HR departments at each of the business units that focus on the operational function of human resources: employee relations, labor relations, staffing, and leave management. At MDU Resources, shared HR functions are performed for all the regulated businesses: compensation management, benefits administration, policy development, human resource information systems, organizational development, as well as providing support and backup for the business unit functions. Business Services Business Services provides support services for facilities and administrative services (including bill printing), supply chain (purchasing and inventory), fleet, travel, and accounts payable (including unclaimed property). Business Services also creates and maintains the Corporation’s national accounts for the purchase of products, goods and services. National accounts take advantage of the combined purchasing power of all the Corporation’s operating companies. Business Services is committed to serving its customers by providing timely, standardized, cost-effective goods and services that support business strategies and goals. Enterprise Information Technology Enterprise Information Technology (EIT) provides policy guidance, infrastructure related IT functions and security-focused governance. EIT seeks to increase the return on investment in technology through consolidation of common IT systems and services, while eliminating waste and duplication. EIT works to increase the quality and consistency of technology, increase functionality and service to the enterprise, provide governance for managing and controlling risk and reduce costs through economies of scale. 2022 Cost Allocation Manual Page 4 The EIT services get allocated to Intermountain Gas using agreed upon formulas based on utilization of the services. Administrative and General Services Administrative and general functions performed by MDUR for the benefit of the operating companies include the following departments: • Corporate governance, accounting & planning • Communications & public affairs • Human resources • Internal audit • Investor relations • Legal • Risk management • Tax and compliance • Treasury services Intermountain Gas receives an allocation of these corporate costs. Corporate Policy No. 50.10 states “It is the policy of the Company to allocate MDU Resources Group, Inc.’s (MDUR) administrative costs and general expenses to the MDUR’s business units”. Business units described in the policy have been referred to as operating companies in this document. The policy states that costs that directly relate to a business unit will be directly assigned to the applicable business unit and only the remaining unassigned expenses will be allocated to the operating companies using the corporate allocation methodology. The allocation factor developed to apportion MDUR’s unassigned administrative costs is a capitalization factor which is based on 12-month average capitalization on March 31, effective July 1 and on September 30, effective January 1 each year. MDUR has a mix of regulated and non-regulated companies. The non-regulated companies are cyclical in nature and could be impacted significantly with a downturn in the economy. It is unlikely during that same downturn their share of corporate costs would be materially different. Due to the volatility of non-regulated companies, and inconsistency between periods of other potential allocation factors, capitalization is the most appropriate allocation factor for MDUR. Capitalization includes total equity and current and non-current long-term debt (including capital lease obligations). The Corporate Overhead Allocation Factors are shown in Exhibit I. 2022 Cost Allocation Manual Page 5 Operating companies that receive allocated costs on a monthly basis from MDUR include: • Montana Dakota – Electric utility segment • Montana Dakota/Great Plains – Gas utility segment • Cascade Natural Gas Corporation (CNGC) • Intermountain Gas Company (IGC) • WBI Energy Transmission • WBI Midstream • Knife River (KR) • MDU Construction Services Group, Inc. (CSG) FutureSource FutureSource, a separate legal entity, owns the facilities at the corporate campus that house the MDUR corporate staff and other property utilized in providing services to all the operating companies within MDUR. These include the corporate office, computers, telephones, furniture, fixtures and aircraft. Montana-Dakota/Great Plains acquired an interest in a portion of the land, building, hangar and aircraft with a cash contribution to FutureSource and placed these assets into rate base. The purchase of a portion of the assets (based on the net book value) was determined to be beneficial to the rate payer rather than paying a higher rate of return for the investment in the cost-of-service calculation billed by FutureSource. The investment in these assets is fluid in nature and does change over time depending on the total investment held by FutureSource. This investment is monitored annually and compared to its proximity to the Corporate Overhead Allocation Factor. The level of investment is targeted to remain relatively close to the Utility Group’s Corporate Overhead Allocation Factor. Intermountain Gas and Cascade Natural Gas Company pay a cost-of-service return to Montana-Dakota for their proportionate share of the contribution made by MDU. Annually FutureSource calculates a cost of service for any unfunded portion of these corporate assets and bills the operating companies monthly. Components included in the cost of service for these facilities and other property include operation and maintenance expense, depreciation, property taxes, income taxes and a pretax return on the investment. The annual calculation is maintained by FutureSource and the most recent copy may be requested from the MDU Resources Corporate Planning Department. 2022 Cost Allocation Manual Page 6 FutureSource also owns and operates a corporate aircraft and a hangar. Fixed costs for the aircraft are allocated to the MDUR operating companies on the MDUR corporate overhead factor referenced above (Exhibit I). The variable costs are charged to the appropriate business unit as a direct charge on an hourly flight rate. These charges will at times exceed or be below the actual variable cost. A year-end true-up includes an adjustment to the excess or shortfall in such hourly billing. Flights for employees of Intermountain Gas Company are directly assigned to the appropriate Business Unit based on the purpose of the trip. For trips that are not directly applicable to a Business Unit, costs are allocated on the employee’s standard payroll allocation and subsequently allocated to the jurisdictions. Standard labor distribution allocations are discussed on page 9. Intermountain Gas Allocation of Cost to/from Others Allocations to other MDUR Companies Certain Intermountain Gas owned assets, such as the General Office, located in Boise, are also used for the benefit of other MDUR operating companies. To cover the cost of ownership and operating costs associated with these owned assets, a revenue requirement (asset return plus annual operating expenses) is computed for the shared assets. The expense component included in the return is composed of operating and maintenance costs, depreciation, income tax and property tax expenses. The resulting revenue requirement is billed to the other MDUR operating companies, including CNGC and MDU, as a monthly fee. Intermountain Gas also owns the Customer Service Center located in Meridian, ID. To cover the cost of ownership associated with that owned asset, a revenue requirement (asset return) is computed. The expense component included in the return is composed of depreciation, income tax and property tax expenses. The resulting revenue requirement is billed to Montana-Dakota and Cascade as a monthly fee. The costs are allocated based on the number of customers served by each utility. Allocations from other Utility Companies Montana-Dakota/Great Plains has several departments that provide services to all four utility operating companies (Montana-Dakota, Great Plains, Cascade Natural Gas Co. and Intermountain Gas Company). These departments include: 2022 Cost Allocation Manual Page 7 • Leadership Group - composed of the Executive Group and Directors that oversee shared utility specific functions • Customer Services - (Call Center, Scheduling and Online Services) • Operations & Engineering Services Group – composed of shared utility group operations department functions • Process Improvement and Operations Technology departments – composed of shared utility group department functions • Information Technology and Communications- (Enterprise Network & Telecommunications, Enterprise Management, Enterprise Development and Integration, Field Automation, Enterprise GIS) • Environmental • Safety & Technical Training • Business Development • Gas Supply & Control • Utility Group Controller • Utility Group Human Resources These operational groups have calculated the proper allocation to use to allocate the costs to the utility companies based on services performed for each utility company. The allocation methodology is included in Exhibit V. Intermountain Gas Allocations to Departments The account structure within JDE consists of the following components: Business Unit - The Business Unit is one of the primary components used for identifying the regulatory allocation of costs. It usually defines a location such as an operating region, operating district, or department (i.e., human resources, engineering). Object – The object for operations and maintenance (O&M) expense accounts represents the resource consumed (i.e., payroll or materials). For balance sheet accounts, the object represents the FERC account. Subsidiary – The subsidiary portion of the account for O&M accounts identifies the utility segment and the FERC account. For balance sheet accounts the subsidiary represents a further breakdown of the account such as which bank for a cash account. Revenue Accounts – Revenues are directly assigned to the jurisdiction when possible. The applicable FERC account is part of the account structure. It is the combination of the business unit, utility segment and FERC that drive the 2022 Cost Allocation Manual Page 8 allocation factor used. An example of revenue that is allocated to the jurisdictions is revenue from the cost-of-service calculation which is assigned an allocable location (Business Unit). Operation and Maintenance (O&M) accounts – As costs are incurred, the approver of the expense assigns the general ledger account structure. It is the combination of the location (Business Unit), utility segment and FERC that drive the allocation factor utilized. Locations are assigned a factor based on the geographic area for which they serve, and the FERC function assigned. For example, location (Business Unit) 48535 represents the geographic location of the Boise, ID District. The allocation of costs is based on the FERC range of accounts. The location may also be a responsibility or department. Taxes Other Than Income Taxes other than income taxes are directly assigned when possible. Ad valorem taxes are allocated based on the subsidiary, which indicates the region and function. Payroll related taxes follow the allocation of labor, revenue taxes are directly assigned, and generation and other taxes are allocated on the applicable factor. Income Taxes Income taxes are allocated or directly assigned based on accordance with federal and state law. Plant in Service/Work in Progress/Reserve/Depreciation Accounts Plant in service, work in progress, reserve and depreciation expense accounts are allocated in through a similar process in the PowerPlan software based on attributes associated with the work order and asset. It is the combination of the utility segment, location of the asset and the FERC account that is used to allocate the project, asset, reserve and depreciation. The tables that are maintained in JDE for jurisdictional allocations are interfaced into PowerPlan and are used to allocate these accounts. Allocation Factors The allocation factors are computed annually by the Regulatory Affairs and General Accounting departments and assigned to the proper Business Unit (location) effective in January each year. 2022 Cost Allocation Manual Page 9 Exhibit I- MDUR Corporate Overhead factor 2022 Cost Allocation Manual Page 10 Exhibit II- MDUR Usage of Boise GO 2022 Cost Allocation Manual Page 11 2022 Cost Allocation Manual Page 12 Exhibit III- Customer Allocation Factors Costs associated with the Customer Service Center in Meridian, Idaho are split via the customer count breakdown amongst the three main utility groups. Exhibit IV- MDUR Shared Services Pricing Methodology 2022 Cost Allocation Manual Page 13 2022 Cost Allocation Manual Page 14 2022 Cost Allocation Manual Page 15 2022 Cost Allocation Manual Page 16 2022 Cost Allocation Manual Page 17 2022 Cost Allocation Manual Page 18 Exhibit V- Utility Operations Support Allocation Methodology Leadership Group: President & CEO (985) – The payroll allocations will be based on average Utility Group customer and employee counts for the President & CEO and Executive Assistant. 2022 Cost Allocation Manual Page 19 Executive Vice President of Business Development & Gas Supply (701) – The payroll allocations will be based on Utility Group customer counts. Utility Group Customer Counts Vice President of Safety, Process Improvement & Operations Systems (707) – The payroll allocations will be based on Utility Group meter counts. Utility Group Meter Counts Executive Vice President of Regulatory Affairs, Customer Service & Administration (919) – The EVP payroll allocation will be based on Utility Group meter counts. Utility Group Meter Counts Vice President of Regulatory Affairs and CustomerService (708) – The payroll allocation will be 50% for IGC & CNG Regulatory Affairs and then based on Utility Group meter counts. Utility Group Meter Counts Vice President of Operations & Engineering Service (960) – The payroll allocations will be based on Utility Group customer counts. Utility Group Customer Counts Vice President of Field Operations (725) – The payroll allocations will be based on Utility Group customer counts. Utility Group Customer Counts 2022 Cost Allocation Manual Page 20 Customer Experience Team (129, 711, 712, 713, 714): The Customer Experience Team is made up of four distinct areas and provides service to all four brands within the MDU Utility Group. Those areas are Credit and Collections, Scheduling, Customer Service, and Customer Programs and Support. In addition to these departments, the Customer Service group has a management team, Consumer Specialists, and other administrative positions. Customer Service payroll costs are allocated using five (5) different methodologies: Customer Count, Customer Call Time, Cleared Order Count, Credit To-Dos, and Emails and Web Requests. Costs other than payroll will be allocated based on customer count if they provide benefit for all brands. Costs specific to a brand will be charged directly to that brand and will not go through an allocation process. Customer Count • Based on the average customer count of each utility brand from December to November. • Uses a customer weighting of 1 for each natural gas or electric only customer and 1.25 for each electric/natural gas combination customer. • The following positions will be allocated based on customer count with nonutility:  Customer Service Director  Manager, Customer Service  Supervisor, Customer Service  Customer Service Trainer  Customer Service Team Lead (Support)  Customer Project Analyst • The following positions will be allocated based on customer count without nonutility:  Administrative Assistant  Manager, Credit, Support, Program Dev  Supervisor, Customer Support Service  Customer Service Team Lead (Credit)  Customer Communications Coordinator  Customer Project Analyst I and II  Business Analysts I and II  Supervisor, Credit & Collections  Customer Service Team Lead  Manager, Scheduling  Scheduling Analyst  Scheduling Lead Customer Call Time • Based on the total time that Customer Service Agents are handling a call.  Includes total talk time and after call work  Does not include idle time or auxiliary time • Uses data for the preceding December to November of each year. • The following positions will be allocated based on customer call time:  Customer Service Rep I, II, III, IV, and IV PT Cleared Order Count • Based on the number or work orders cleared through the work assignment management system for each brand. • Uses data for the preceding December to November of each year. • The following positions will be allocated based on cleared order count:  Scheduler 2022 Cost Allocation Manual Page 21 Credit To-Do’s • Based on three types of completed To-Do’s;  accounts up for severance  closed accounts pending write-off  broken payment plans • Uses data for the preceding December to November of each year. • The following positions will be allocated based on credit to-do’s:  Credit & Collections Rep I, II, and III  Credit Support Rep E-mails and web requests Based on e-mails that include direct inquiries from customers, follow up requests from a CSR phone call, or e-mails generated by the web applications requiring account maintenance. • Uses data for the preceding December to November of each year. • The following positions will be allocated based on e-mails  Customer Support Rep I, II, and III MDU Elect MDU/GP Gas MDU Nonutility CNG IGC Total 11.26% 23.86% .72% 28.07% 36.09% 100% 11.49% 24.35% - 28.07% 36.09% 100% 13.59% 28.80% - 25.61% 32.01% 100% 15.57% 27.19% - 21.68% 35.55% 100% 18.38% 38.94% - 11.98% 30.70% 100% 10.55% 22.36% - 28.41% 38.68% 100% Operations & Engineering Services Group: Process Improvement & Operations Tech (Dept 703) The payroll allocations will be based on the Utility Group employee counts. Utility Group Employee Counts Quality Control (Dept 730) The Quality Control department provides oversight and post work review of both maintenance and construction work that is performed by both utility group employees and our contractors. The payroll allocations will be based on time studies. Engineering Services (Dept 769) The Engineering Services department duties include gas modeling, working with district personnel, engineering design of capital projects, creation of cost estimates, creation of design and work plans, budget planning, etc. The payroll allocations will be based on time studies. 2022 Cost Allocation Manual Page 22 Construction Services (Dept 863) The Construction Services (CS) department provides construction management and inspection for large and high-pressure projects, as well as for projects generated by TIMP, DIMP, and MAOP Validation Plans. CS creates and manages programs and procedures for welding and fusion programs. Fabrication standards and a majority of fabrication are done by CS. The payroll allocations will be based on time studies. Operation Systems (Dept 864) This department supports Operations compliance systems as well as supporting other systems that Operations and Engineering utilize. The group not only supports these efforts but also works as a liaison group between the business and enterprise information technology (EIT). The payroll allocations are based on the Utility Group meter counts. Utility Group Meter Counts Operations GIS (Dept 867) This department supports the Operations and Engineering GIS system. The group not only supports these efforts but also works as a liaison group between the business and enterprise information technology (EIT). The payroll allocations will be based on time studies. Costs specific to a brand will be charged directly to that brand and will not go through an allocation process. System Integrity (Dept 865) The System Integrity department is responsible for the Utilities Distribution and Transmission Integrity Management Programs, Integrity Projects, Cascade’s MAOP Validation Project, and Corrosion Control. The payroll allocations will be based on time studies. Safety Management System & Quality Assurance (Dept 866) The Safety Management System and Quality Assurance (SMS/QA) department is responsible for the implementation of the utility group’s safety management system. The team is responsible for reviewing, documenting, and developing processes to ensure compliance with the industry recommend practice 1173. Key objectives of our current plan include the development of an operational risk management program, SMS/QA program oversight and metrics, and completion of risk-based process audits. The payroll allocations will be based on Utility Group gas customer count. Utility Group Gas Customer Counts Operations Policies & Procedures (Dept 923) This department is responsible for aligning new Utility Group procedures as well as maintaining all previous company specific procedures. Each company was and is required to have and maintain these procedures per federal code 192. The payroll allocations will be based on time studies. 2022 Cost Allocation Manual Page 23 Operation Services (Dept 958) The Operation Services department provides compliance, damage prevention, and public awareness across the Utility Group. The payroll allocations will be based on time studies. Information Technology and Communications Group: Enterprise Management, Enterprise Development and Integration, Field Automation (Dept 723, 926, 964) These teams support business and technical functions that are common to all brands. Provides support to the business through data requests and augments the system by developing programs and technical solutions to accommodate business and field needs as well as regulatory requirements. The payroll allocations will be based on Utility Group meter counts. Utility Group Meter Counts Enterprise GIS (Dept 951) This department provides gas, electric and fiber pipeline and facilities mapping services for the Utility Group The payroll allocations will be based on Utility Group meter counts. Utility Group Meter Counts Environmental (Dept 889) The Environmental Department provides environmental regulatory compliance guidance and assistance to MDU Utilities Group facilities and operations in accordance with the company environmental policy: The Company will operate efficiently to meet the needs of the present without compromising the ability of future generations to meet their own needs. Our environmental goals are: • To minimize waste and maximize resources. • To support environmental laws and regulations that are based on sound science and cost-effective technology; and • To comply with or exceed all applicable environmental laws, regulations and permit requirements. The payroll allocations will be based on time studies. Safety & Technical Training (Dept 720, 901) The Safety and Technical Training department provides oversight for all things safety and technical training for the entire utility group. The payroll allocations will be based on Utility Group or Montana-Dakota employee counts or time studies, depending on the employee’s job functions. Utility Group Employee Counts Montana-Dakota Utilities Employee Counts Human Resources (Dept 963) The Human Resources payroll allocations will be based on average Utility Group customer and employee counts. 2022 Cost Allocation Manual Page 24 Gas Supply (Dept 931, 933, 928) The payroll allocations will be based on two methodologies: Utility Group meter count and time studies. There are employees focused on Montana-Dakota Utilities functions, which will be allocated 100% to Montana-Dakota Utilities gas segment. Utility Group Meter Counts Utility Group Controller (Dept 941) The Controller Department provides various accounting services to the Utility Group: Fixed Assets Accounting, Revenue Accounting, Internal Controls Coordination, and Management. The payroll allocations are based on these methodologies: Utility Group customer count, Utility Group meter count, number of employees, Montana-Dakota customer factor, Utility Group corporate factor, Montana-Dakota corporate factor, and specific shared services methodologies. • Utility Group customer count • The following positions will be allocated based on Utility Group customer count based on job duties/functions:  Business Analyst I and II (Revenue Accounting) • Utility Group meter count • The following positions will be allocated based on Utility Group meter count based on job duties/functions:  Business Analyst II and Sr. (Customer Accounting) • Number of employees • The following positions will be allocated based on number of employees under their supervision:  Controller – Utility Group  Director, Finance  Manager, Revenue Administration • Montana-Dakota customer factor • The following positions will be allocated based on MDU customer factor  Financial Analyst I, II (Revenue Accounting)  Financial Specialist (Revenue Accounting)  Financial Technician (Revenue Accounting)  Manager, Revenue Accounting 2022 Cost Allocation Manual Page 25 • Utility Group corporate factor • The following position will be allocated based on Utility Group corporate factor  Internal Controls Coordinator • Montana-Dakota corporate factor • The following positions will be allocated based on MDU corporate factor  Financial Analyst I, II, III, IV (Gen Acctg, Reporting & Planning)  Financial Systems Analyst (Gen Acctg)  Financial Technician (Gen Acctg)  Manager, Accounting & Finance  Manager, Financial Reporting & Planning Manager, General Accounting Utility Group Customer Counts Utility Group Meter Counts Number of Employees: Controller* Number of Employees: Director, Finance* Number of Employees: Manager, Revenue Administration** Montana-Dakota Customer Factor Utility Group Corporate Factor Montana-Dakota Corporate Factor * MDU electric/gas split is based on the MDU Corporate Factor. ** MDU electric/gas split is based on the MDU Customer Factor. • Utility Group Fixed Assets Accounting methodology - • The following positions will be allocated based on 3-Year Averages reviewed annually:  Financial Analyst I, II, III, IV (Fixed Assets Accounting)  Supervisor, Fixed Assets Accounting  Manager, Fixed Assets Accounting Costs for the Financial Analysts in the MDU Utility Group Fixed Asset Accounting group are based upon three separate methodologies based on the three major types of work performed in the department. The three major work types of work are: 1. Capital Expenditure Support (16.7% of workload)-Allocated to capital overhead (ES/GA) accounts based on 3-year average of capital expenditures. 2. Fixed Asset Life Cycle Support (68.3% of workload)-Allocated to capital overhead (ES/GA) accounts based on 3-year average of capital work orders weighted by a difficulty factor. 3. All Other Fixed Asset Accounting (15.0% of workload)-Allocated to expense (O&M) accounts based on estimate of time spent on non-project related tasks (Depreciation, ARO, Data Requests, etc.). 2022 Cost Allocation Manual Page 26 MDUR* MDU WBIE** KRC** CSG** CNG IGC Total Total Allocated to ES/GA 55.84% 19.16% 10.0% 85.00% Total Allocated to O&M 10.83% 2.08% 2.08% 15.00% * Time devoted to CHCC companies deemed immaterial and is included in MDU amounts. ** No service provided to WBIE, CSG or CSG Costs for the Manager of the Utility Group Fixed Asset Accounting group are based upon the company workload split of the “Other Fixed Asset Accounting” time spent by the Lead Financial Analyst in charge of depreciation, ARO’s, data requests, etc. No portion of these costs is allocated to capital overhead (ES/GA) as they are deemed to be non-direct construction support costs. MDUR* MDU WBIE** KRC** CSG** CNG IGC Total Manager Costs 75.00% 12.5% 12.5% 100.00% * Time devoted to CHCC companies deemed immaterial and is included in MDU amounts. ** No service provided to WBIE, CSG or CSG • Utility Group Payment Processing methodology  Payment Processer (Revenue Accounting)  Payment Processer, Lead (Revenue Accounting) Payment Processing has been allocated by utility brand based on the number of customer payments posted to utility accounts in the 12-month period ending June 30, 2021. MDU/GPNG CNG IGC Total # of Payments Processed 1,523,264 868,118 769,163 3,160,545 % of Payments Processed by Brand 48.20% 27.50% 24.30% 100.00% 2022 Cost Allocation Manual Page 27 Exhibit VI – MDU Executive Usage of Boise GO