20230119INT to Staff 48-57.pdf

RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 4
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Intermountain Gas Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR NATURAL GAS SERVICE IN
THE STATE OF IDAHO

Case No. INT-G-22-07

INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Second Production Request of the Commission Staff to Intermountain Gas
Company dated December 29, 2022, submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email. Confidential
responses and documents are subject to the protective agreement in this case, and are available
for download using a password-protected link that will be provided separately by email to those
parties that have signed the protective agreement. The password will be provided in a third
email.

RECEIVED
Thursday, January 19, 2023 3:47:08 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 4
DATED: January 19, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF PAGE 3 OF 4
CERTIFICATE OF SERVICE
I certify that on January 19, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Chad M. Stokes
Cable Huston LLP
1455 SW Broadway, Ste. 1500
Portland, OR 97201
Attorneys for Alliance of Western Energy
Consumers
[e-mail]

Marie Callaway Kellner
710 N. 6th Street
Boise, ID 83702
Attorneys for Idaho Conservation League
[e-mail]

Brad Heusinkveld
Idaho Conservation League, Energy Assoc.
710 N. 6th Street
Boise, ID 83702
[e-mail]

Non-confidential responses only:
Darrell Early
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF PAGE 4 OF 4

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Lori
Blattner
REQUEST NO. 48:
On page 17 of Company Witness Blattner’s testimony, she explains how the Nampa
Liquefied Natural Gas (“LNG”) facility was out of service for repair due to a leak in the outer
shell LNG tank for most of 2021.
a)Please explain the accounting treatment the Company will use for the repair costs for the
Nampa LNG plant. Please provide Excel worksheets with formulas intact.
b)Please provide a worksheet that details all costs associated with the repair that are
included in this case. If not all costs are being included within this case, please explain
exclusions and accounting treatment that will be applied to them.
c)Please explain how repair costs will be allocated to utility customer classes and off
system sales customers. Please provide the percentage of costs that will be allocated to
each customer class.
RESPONSE NO. 48:
a.The costs for the repair of the originally identified leak in the Nampa LNG facility
will be charged to operation and maintenance expense - subcontract payments.
The costs associated with the replacement and retirement of components of the
facility were capitalized. The majority of the costs were recorded to plant in
service, FERC subplant accounts 361 – Structures and Improvements, 362 – Gas
Holders, and 363 – Measuring and Regulating, while cost of removal was booked
to accumulated reserve. While preparing this response, the Company determined
that $14,888 associated with the leak repair was capitalized and is currently
INT-G-22-07
IPUC DR 48
Page 1 of 2
reflected in plant in service. In January 2023, the $14,888 related to the repair of
the leak will be reclassified from plant in service to operation and maintenance
expense in FERC 843.3 - maintenance of gas holders.
b.Please see RFP 48 – Nampa LNG Tank Repair Costs for details of the costs
associated with the repair.
c.Please refer to Company Witness Ron Amen’s Exhibit 2, Schedule 1, lines 12-14
for the allocation factor for the accounts identified in response to subpart “a”
above. The allocation percentages can be found in Ron Amen’s Exhibit 2,
Schedule 2 under the PDAY_F Demand Factor. The reclassification will not
impact the allocation factor selection; however, it will impact the overall impact
on cost to serve.
Non-utility LNG sales customers are not allocated any portion of these repair
costs because all costs associated with the Nampa LNG plant are included in base
rates for the purpose of being a supply source in the event of a very cold weather
or extraordinary system issues.
INT-G-22-07
IPUC DR 48
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Lori
Blattner
REQUEST NO. 49:
Please describe both the expected service and depreciation life of the repaired Nampa
LNG plant. Please provide workpapers detailing the expected depreciation expense.
RESPONSE NO. 49:
The expected service and depreciation life of the Nampa LNG plant is determined
through depreciation studies prepared by an outside consultant. The current expected service life
for the Nampa LNG plant is presented in “RFP 49 – Nampa LNG Life and Depr Exp.xlxs”. The
impact of the repairs to the Nampa LNG plant will be considered in the company’s next
depreciation study.
The expected 2023 monthly and annualized depreciation expense presented in “RFP 49 –
Nampa LNG Life and Depr Exp.xlsx” is based on plant balances at December 31, 2022.
INT-G-22-07
IPUC DR 49
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dyke Boese/ Dyke
Boese
REQUEST NO. 50:
Please describe the selection process/methods used for information technology upgrades,
enhancements, and projects for the period of 2016 through 2022.
a.Please describe how the Company addressed least risk and least cost considerations in
selection of projects.
b.Please provide any cost benefit analyses conducted for each project.
RESPONSE NO. 50
A. When addressing projects, the Company looks at a number of factors including least
risk and cost, and starting in 2021, the vendor’s security posture along with security
questionnaires and other security type reports from the vendor are reviewed as applicable.
Several of the projects discussed were related to keeping current with maintenance and security
patches and were required to be completed to avoid potential issues such as downtime and
software vulnerabilities. In general, when evaluating projects, Intermountain looks at company
benefit, compliance requirements, and cost comparisons.
B. Below is information regarding the major information technology projects and
applicable cost-benefit analyses and attachments:
Maximo (asset management system) had a team of individuals that reviewed
vendors and compared features and costs associated with the project. Attached is
the “RFP 50 Maximo Savings Estimate 6-1-18” document that was used during
the review and supports costs that were discussed. As shown in the attachment,
Maximo will provide savings regarding six primary benefits:
INT-G-22-07
IPUC DR 50
Page 1 of 3
o Align operations business processes across the enterprise – facilitate the
one utility objective.
o Replace fragmented and unintegrated operations technology
systems/processes with one unified work and asset management system –
improving efficiency of implementation and support.
o Reduce touch points and redundancy.
o Gain enterprise-wide insight into asset tracking, construction,
maintenance, compliance, and costs.
o Drive consistent workflows across the enterprise, improving work product
results.
o Improve the user experience with consistent field data entry technology –
lowers training needs, and limits confusion and errors.
o These benefits translate into an estimated annual savings of $4.5M. The
greatest savings come from the elimination of touchpoints caused by paper
processes and fragmented systems.
Interactive Voice Response (“IVR”) project involved a team that looked at the
current vendor along with options from Cisco as the current product at the time
was outdated and out-of-support and would not support new technologies and
equipment. The attachment, RFP 50 Avaya-Cisco-Option-Compare.xls, is a cost
comparison document that was created prior to moving forward with the Cisco
solution.
o Power Plan – Power Plan is the Company’s budgeting software. The costs
associated with Power Plan are for a lease module that was implemented for an
INT-G-22-07
IPUC DR 50
Page 2 of 3
accounting mandate to accommodate GAAP accounting rules. The other upgrades
were upgrade costs to stay current with the latest released software. These
upgrades were required to stay within a supported version of software to get
support, bug fixes, and security updates to protect the Company from malware
and downtime. The upgrades were needed to mitigate risks, including downtime
and software vulnerabilities.
o PCAD – PragmaFIELD is used for field order completions across CC&B as well
as Maximo to install meters, inspections, or repairs. These upgrades not only
provided additional functionality the field requires but are also required to stay
within a supported version of software to get support, bug fixes, and security
updates to protect the Company from malware and downtime. The upgrades were
needed to mitigate risks, including downtime and software vulnerabilities.
INT-G-22-07
IPUC DR 50
Page 3 of 3
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden, Kim
Ukestad/ Dyke Boese
REQUEST NO. 51:
Please provide Capital and Operations & Maintenance ("O&M") informational
technology expenses for MDU Resources Group Inc. ("MDU") from 2016-2022 allocated to
Intermountain Gas. Please explain how MDU allocates Capital and O&M informational
technology expenses to their subsidiaries and please provide supporting worksheets.
RESPONSE NO. 51:
Please see the attached document “RFP 51 IT Expenses.xlsx” for Information
Technology expenses allocated to Intermountain Gas Company (“Intermountain”) from 2016-
2022.
MDU does not allocate capital to Intermountain. The use of MDU’s capital software
programs is allocated to its subsidiaries via O&M. The O&M for Information Technology is
allocated in accordance with the Cost Allocation Manual (see page 23). The Cost Allocation
Manual was provided as part of Intermountain’s response to Commission Staff Production
Request, RFP 03.
INT-G-22-07
IPUC DR 51
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden, Kim Ukestad/Boese
REQUEST NO. 52:
Please provide Capital and O&M informational technology expenses for the Company
from 2016-2022 and please provide supporting worksheets.
RESPONSE NO. 52:
See the attached documents “RFP 52 IT Expenses.xlsx” and “RFP 52 – IT Capital
Expenditures.xlsx” for the requested information.
INT-G-22-07
IPUC DR 52
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ryan Privratsky/Patrick Darras
REQUEST NO. 53:
Please describe the Company's current progress of its Aldyl-A replacement program.
a.Based on the Company's assessments, how many miles of Aldyl-A pipe require
replacement in 2023 and beyond?
b.Please provide the expected timeline and annual costs for Aldyl-A replacement.
c.Please provide a workpaper that details the number of miles and costs of Aldyl-A
replacement for each year since the last general rate case.
d.Please provide the accounting treatment for all Aldyl-A cost included in this rate case.
RESPONSE NO. 53:
2017 – 2019
Aldyl-A (Pre-1985) replacement projects were prioritized utilizing Intermountain Gas
Company’s (IGC) Distribution Integrity Management Program (DIMP) risk model. Each
segment of Aldyl-A (a segment being identified by project number and installed during the same
time period) was given a normalized risk score based on the DIMP risk model. The pipeline
segments were then risk ranked based on the normalized risk score. The risk ranking was then
used to identify and budget pipeline segments that would be replaced annually. Replacement
only included replacement of main and did not include replacement of the connected service
lines.
2020 – Present
Beginning in 2020, MDU Utilities Group (MDUG) expanded its System Safety and
Integrity Program (SSIP) to IGC which established a structured replacement program to identify
INT-G-22-07
IPUC DR 53
Page 1 of 6
and replace specific pipeline segments utilizing IGC’s DIMP. IGC’s SSIP utilizes IGC’s DIMP
risk model and relative risk score to establish a weighted average risk score for each town within
Idaho. The weighted average risk score is then used to identify towns with increased risk related
to the type of pipeline segments being targeted through the SSIP. Pipeline segments that are
primarily being targeted for replacement include:
Early Vintage Plastic Pipe (EVPP) – Plastic mains, service lines, and associated fittings
installed earlier than 1/1/1995.
o Pre-1983: These pipelines include pipe installed prior to 1/1/1983 that may be
susceptible to possible Low Ductile Inner Wall (LDIW) characteristics that can result
in slow crack growth and slit failures, as documented by PHMSA–2004–19856.
o Post-1982: These pipelines were installed between 1/1/1983 and 12/31/1994 and are
classified as EVPP to account for different inventory levels and rates of new material
adoption among MDUG.
Early Vintage Steel Pipe (EVSP) – Steel mains, service lines, and associated fittings
installed earlier than 1/1/1970. EVSP includes aging and/or obsolete pipeline segments,
bare steel or poorly coated pipe, pipe with unknown attributes or missing data, gas meters
located indoors, and/or pipeline segments with mechanical couplings and fittings.
Ongoing analysis of EVPP and EVSP continue to show increased risk factors. EVPP and
EVSP are typically pipelines prone to bare or poor coating, industry documented Aldyl-a plastic
defects, unknown attributes, missing data, mechanical fittings, inside gas meters, and non-
reported third-party damages. Universal integrity related project selection has evolved from
utilizing independent high score categories to an integrated, system-based approach which ranks
EVPP and EVSP jointly. These segments of main and their associated service lines have an
elevated risk of failure as validated by DIMP risk analysis.
The replacement of these facilities ultimately increases overall system safety for the
public and increases system reliability for IGC customers.
INT-G-22-07
IPUC DR 53
Page 2 of 6
a.Based on the Company's assessments, how many miles of Aldyl-A pipe require
replacement in 2023 and beyond?
As of IGC’s last DIMP model run (5/1/2022) there are a total of 5,004.63 miles of
EVSP and EVPP main and service in Idaho.
EVSP = 2,449.36 Miles
EVPP = 2,555.27 Miles
o Pre-1983 = 820.88 Miles
o Post-1982 = 1,734.39 Miles
2022 Idaho SSIP Plan - System Integrity – “RFP 53 SSIP 2022 Appendix ID.pdf”
b.Please provide the expected timeline and annual costs for Aldyl-A replacement.
o Timeline - IGC will continue to replace EVPP & EVSP at a consistent rate over the
next five years. Replacement will continue past 2027 and continue well into the
future. Rate of replacement will remain consistent unless IGC’s DIMP risk analysis
indicates further accelerated action is warranted.
o Costs:
Main: FP-318180 - Sys Safety & Integrity Mains Rpl-ID (see table below)
Service: FP-318181 - Sys Safety & Integrity Srvcs Rpl-ID (see table below)
Budgeted increase of 3% annually.
2023 Approved Capital Budget
2023 2024 2025 2026 2027
FP-318180 $1,750,482 $1,802,996 $1,857,092 $1,912,801 $1,970,181
FP-318181 $1,750,482 $1,802,996 $1,857,092 $1,912,801 $1,970,181
TOTAL $3,500,964 $3,605,992 $3,714,184 $3,825,602 $3,940,362
c.Please provide a workpaper that details the number of miles and costs of Aldyl-A
replacement for each year since the last general rate case.
Year District Miles of Main # Services Funding
Project
Work
Order
2017 Twin Falls
0.10 0
FP-200840
229476
0.10 0 240352
0.04 0 240324
0.02 0 241328
0.39 0 229458
INT-G-22-07
IPUC DR 53
Page 3 of 6
Boise 0.54 0 FP-200854 241259
0.10 0 243002
Idaho Falls
0.05 0
FP-200883
240134
0.06 0 240136
0.19 0 240188
0.17 0 240189
0.09 0 244659
0.08 0 247432
Nampa 0.16 0 FP-302252 240563
0.04 0 243066
Pocatello
0.67 0
FP-302332
240429
0.04 0 240431
0.03 0 240434
0.07 0 240435
0.24 0 240438
0.05 0 246153
2018
Twin Falls
0.32 0
FP-200840
241341
0.20 0 251362
0.05 0 251389
0.09 0 257941
Boise
2.19 0
FP-200854
245334
0.19 0 248297
0.01 0 251365
2.80 0 251489
0.10 0 253595
0.01 0 253712
0.03 0 254339
0.05 0 254798
0.14 0 255223
0.13 0 257974
Idaho Falls
0.15 0
FP-200883
240190
0.03 0 251854
0.15 0 251855
0.13 0 251860
0.17 0 251861
0.88 0 251871
0.09 0 251872
Nampa 0.10 0 FP-302252 251902
Pocatello 0.04 0 FP-302332 252838
INT-G-22-07
IPUC DR 53
Page 4 of 6
0.67 0 253094
2019
Twin Falls 0.73 0 FP-200840 263725
0.71 0 FP-317522 266086
Boise
0.17 0
FP-200854
258253
0.36 0 263803
0.03 0 264878
0.08 0 267005
0.31 0 270184
0.65 0 FP-317202 263786
0.80 0 FP-317476 264337
Idaho Falls
0.06 0
FP-200883
265516
0.13 0 265647
0.12 0 265748
0.30 0 265816
0.20 0 265817
0.13 0 271940
Nampa
0.10 0 FP-302252 270883
0.36 0 FP-316895 270902
0.52 0 FP-316896 264941
Pocatello
0.08 0
FP-302332
266136
0.11 0 266189
0.86 0 266191
2020
Pocatello 0.42 0 FP-302332 266190
Boise 1.31 0 FP-319032 274748
Idaho Falls 5.65 305 FP-318180 278442
FP-318181 278516
2021 Idaho Falls 6.40 350 FP-318180 278442
FP-318181 278516
2022 Idaho Falls
3.60 191 FP-318180 278442
FP-318181 278516
2.84 240 FP-318180 291454
FP-318181 291455
Cost data is still being gathered. IGC will update the response when cost data is complete.
d.Per our Capitalization Policy, replacements of Aldyl-A Mains under 15 feet would be
charged to Maintenance Expense, while replacements of Aldyl-A Mains of 15 feet or
INT-G-22-07
IPUC DR 53
Page 5 of 6
more would be capitalized to Plant In Service with the original cost of the replaced pipe
retired from Plant In Service.
INT-G-22-07
IPUC DR 53
Page 6 of 6
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Lance Elroy/ Hart
Gilchrist
REQUEST NO. 54:
Please provide the supporting worksheets for the $35 million Work and Asset
Management project referenced in Company Witness Gilchrist Direct Testimony at 7.
RESPONSE NO. 54:
The rounded reference to $35 Million should have been more accurately stated as “the
original estimated cost of the Work and Asset Management system for gas and electric was
approximately $33.07 Million.” The supporting worksheet (“RFP 54 - Maximo Budget and Costs
Through 2022.xlsx”) is included in this response. The worksheet includes a summary tab that
shows the original total budget and the amount budgeted for Intermountain. To be clear, the
$33.07 Million budget was for implementing Maximo for electric and gas across 8 states over 5
years. Intermountain’s portion of this original budget was $5.68M.
The worksheet includes the costs for the project broke into two additional tabs – one for
in service costs and one for open work order costs. The in-service cost is for the first phase of
Maximo and includes all of the compliance/maintenance work. This was under budget and is a
successful deployment.
The open work order costs are associated with Phase II to deploy a fully electronic and
integrated construction solution. Phase II is underway, and the target is to stage the go-lives over
the next 24 months.
INT-G-22-07
IPUC DR 54
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ryan Privratsky/Patrick Darras
REQUEST NO. 55:
Please provide the Company’s latest Distribution Integrity Management Program
(“DIMP”) plan and annual report.
RESPONSE NO. 55:
For the Company’s latest Distribution Integrity Management Program (“DIMP”) plan,
please see the attachment “RFP 55 OPS 1000.pdf”. The latest annual report is included as “RFP
55 2021 - IGC - 7100.1-1.pdf” and “RFP 55 2021 - IGC - 7100.2-1.pdf”.
INT-G-22-07
IPUC DR 55
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ann E. Bulkley,
Principal, The Brattle Group
REQUEST NO. 56:
Please provide Company Witness Bulkley’s workpapers and exhibits in Excel format
with all formulas intact.
RESPONSE NO. 56:
Please see Response to IPUC Staff Request 56, Attachment 1 through Response to IPUC Staff
Request 56, Attachment 19. Please note that the exhibits from Ms. Bulkley’s direct testimony were
also provided to Staff in Excel format on December 8, 2022.
Please note that certain Attachments may apply to more than one Exhibit/Figure in Ms. Bulkley’s
direct testimony. An index is provided below:
Testimony Exhibit No. / Figure No. Attachment(s)
Exhibit No. 2 Summary Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Exhibit No. 3 CGDCF RFP 56, Attachment 1
RFP 56, Attachment 2
RFP 56, Attachment 3
Exhibit No. 4 CAPM & ECAPM RFP 56, Attachment 4
RFP 56, Attachment 5
RFP 56, Attachment 1
Exhibit No. 5 LT Beta RFP 56, Attachment 6
Exhibit No. 6 Market Return Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Exhibit No. 7 Risk Premium CONFIDENTIAL RFP 56, Attachment 7
INT-G-22-07
IPUC DR 56
Page 1 of 3
Exhibit No. 8 Size Premium CONFIDENTIAL RFP 56, Attachment 8
Exhibit No. 9 CapEx RFP 56, Attachment 1
Exhibit No. 10 Regulatory Risk CONFIDENTIAL RFP 56, Attachment 9
Exhibit No. 11 Flotation Cost RFP 56, Attachment 10
RFP 56, Attachment 11
Exhibit No. 12 Capital Structure CONFIDENTIAL RFP 56, Attachment 12
Figure 1: Summary of Cost of Equity
Analytical Results
Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Figure 2: Consumer Price Index—YOY
Percent Change January 2008–October
2022
RFP 56, Attachment 13
Figure 3: 10-Year Treasury Bond
Yield—January 2021– October 31, 2022
RFP 56, Attachment 14
Figure 4: Yield Spread between the
Dividend Yield on the S&P Utilities
Index and the Yield on the 10-year
Treasury Bond – January 2012 – October
2022
RFP 56, Attachment 15
Figure 5: The Effect of a Decline in
Stock Prices on the Constant Growth
DCF Model
N/A
Figure 6: Natural Gas Utility Proxy
Group
N/A
Figure 7: Constant Growth Discounted
Cash Flow Results
Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Figure 8: Realized U.S. equity market
returns (1926-2021)
RFP 56, Attachment 16
Figure 9: CAPM and ECAPM Results Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Figure 10: Risk Premium Results CONFIDENTIAL RFP 56, Attachment 7
INT-G-22-07
IPUC DR 56
Page 2 of 3
Figure 11: Comparison of Capital
Expenditures
Provided in the electronic copy of Ms. Bulkley’s
exhibits.
Figure 12: Comparison of Idaho and
U.S. Authorized Electric Returns
CONFIDENTIAL RFP 56, Attachment 17
Figure 13: Pinnacle West Capital Stock
Price VS. S&P 500
RFP 56, Attachment 18
Figure 14: Customer Concentration RFP 56, Attachment 19
Figure 15: Summary of Results Provided in the electronic copy of Ms. Bulkley’s
exhibits.
INT-G-22-07
IPUC DR 56
Page 3 of 3
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Lori Blattner/Lori
Blattner
REQUEST NO. 57:
Please provide any studies the Company has in its possession, or any studies the
Company has reviewed on the gas consumption of low-income customers.
RESPONSE NO. 57:
The Company does not have any studies on the gas consumption of its low income
customers.
INT-G-22-07
IPUC DR 57
Page 1 of 1