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HomeMy WebLinkAbout20230620Technical Hearing Transcript Volume II.pdfBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF INTERMOUNTAIN ) GAS COMPANY'S APPLICATION FOR )CASE NO.INT-G-22-07 AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR NATURAL GAS )SERVICE IN THE STATE OF IDAHO ) BEFORE COMMISSIONER ERIC ANDERSON (Presiding) COMMISSIONER EDWARD LODGE PLACE:Commission Hearing Room 11331 West Chinden Blvd. Building 8,Suite 201-A Boise,Idaho DATE:June 8,2023 ~ VOLUME II -Pages 23 -80 CSB REPORTINGORIGINALCertgiedShorthandReporters Post Office Box 9774 Boise,Idaho 83707 .Reporter:csbreporting@yahoo.com Constance Bucy,Ph:208-890-5198 CSR 1 A PPE A R A NCES 2 3 For the Staff:Claire Sharp Deputy Attorney General 4 IPUC 11331 W.Chinden Blvd., 5 Bldg.No.8,Suite 201-A PO Box 83720 6 Boise,ID 83720-0074 7 For Intermountain Gas:Preston N.Carter 8 Givens Pursley LL 601 W.Bannock Street 9 Boise,ID 83702 10 For Alliance of Western Chad M.Stokes 11 Energy Consumers:Cable Huston LLP 1455 SW Broadway,Suite 1500 12 Portland,OR 97201 13 For Idaho Conservation Brad Heusinkveld. 14 League:Idaho Conservation League (Of Record)710 N.6th Street 15 Boise,ID 83702 16 For City of Boise:Ed Jewell 17 Deputy City Attorney Boise City Attorney's Office 18 105 N.Capitol Blvd. PO Box 500 19 Boise,ID 83701-0500 20 21 22 23 24 25 CSB REPORTING 24 APPEARANCES 208.890.5198 1 I NDEX 2 3 WITNESS EXAMINATION BY PAGE 4 Lori Blattner Mr.Preston (Direct)29(IGC)Prefiled Direct Testimony 31 5 Bradley G.Mullins Mr.Stokes (Direct)41 6 (AWEC)Prefiled Direct Testimony 42 7 Michael Louis Ms.Sharp (Direct)58(Staff)Prefiled Direct Testimony 60 8 9 10 11 12 13 14 EXH I B I TS 15 16 NUMBER DESCRIPTION PAGE 17 FOR ALLIANCE OF WESTERN ENERGY CONSUMERS: 18 201.Resume of Bradley Mullins Premarked 19 Admitted 78 20 202.First Production Request Premarked of AWEC Admitted 78 21 22 FOR THE STAFF: 23 24 101.Proffesional Qualifications Premarked of Michael Louis Admitted 78 25 CSB REPORTING 25 INDEX/EXHIBITS 208.890.5198 1 BOISE,IDAHO,WEDNESDAY,JUNE 8,2023,9:00 A.M. 2 3 4 COMMISSIONER ANDERSON:Good morning.This is 5 the time and place for a technical hearing in 6 INT-G-22-07,further identified as in the matter of 7 Intermountain Gas Company's application for authority to 8 increase its rates and charges for natural gas service in 9 the State of Idaho. 10 This hearing is taking place to consider a 11 general rate case filed with the Commission on 12 December 2nd,2022,seeking authority to increase 13 Intermountain Gas Company's general rates for gas service 14 in Idaho. 15 My name is Commissioner Eric Anderson.I'm the 16 Chair of today's proceeding and I'm joined by 17 Commissioner Ed Lodge and we comprise the Commission in 18 this case and will collectively make a final 19 determination in this matter. 20 For today's proceedings,we have Connie Bucy 21 serving as our court reporter.Please talk slowly, 22 clearly,and into the microphone for her benefit and she 23 will remind us if we don't do it properly. 24 On March 2nd --excuse me,March 30th and 31st, 25 2023,the Company,intervenors,and Staff participated in CSB REPORTING 26 COLLOQUY 208.890.5198 1 settlement negotiations,which resulted in a proposed 2 settlement.On April 5th,2023,a joint motion was filed 3 notifying the Commission of the proposed settlement and 4 requesting several procedural modifications to the 5 Commission's schedule. 6 On May 4th,2023,the Company filed a proposed 7 stipulation and settlement signed by the Company,Staff, 8 AWEC,and ICL,collectively,called the signing parties. 9 We will begin this morning by taking appearances 10 of the parties,so let's begin with Intermountain Gas 11 Company. 12 MR.CARTER:Sure,this is Preston Carter with 13 Givens Pursley representing Intermountain Gas Company. 14 COMMISSIONER ANDERSON:Welcome.Commission 15 Staff? 16 MS.SHARP:Claire Sharp,Deputy AG. 17 COMMISSIONER ANDERSON:Thank you.Alliance of 18 Western Energy Consumers? 19 MR.STOKES:Good morning,Chad Stokes from 20 Cable Huston for the Alliance of Western Energy 21 Consumers. 22 COMMISSIONER ANDERSON:Welcome,good morning. 23 Idaho Conservation League?The City of Boise? 24 MR.JEWELL:Good morning,my name is Ed Jewell. 25 I'm a Deputy City Attorney for the City of Boise and CSB REPORTING 27 COLLOQUY208.890.5198 1 joining me today is Will Gale. 2 COMMISSIONER ANDERSON:Welcome.Are there any 3 parties that we've missed for purposes of identification 4 for the record?Seeing none. 5 Are there any preliminary matters that need to 6 come before the Commission,motions or requests? 7 Mr.Preston. 8 MR.CARTER:Not from the Company. 9 COMMISSIONER ANDERSON:Thank you.Seeing none 10 other,we scheduled a single day,which will not take a 11 whole day in the effort,so we're not going to schedule 12 breaks or anything.Everybody knows where the rest rooms 13 are.If you need to get up and go,they're just right 14 down the hall. 15 Before calling the first witness,do the parties 16 intend to present direct and rebuttal testimony to be 17 spread across the record simultaneously? 18 MR.CARTER:Mr.Chair,the Company does not 19 have rebuttal testimony,so we'll spread what testimony 20 we have,which is the direct testimony on the settlement 21 on the record. 22 COMMISSIONER ANDERSON:Thank you.I've been 23 reading my script.I probably didn't need to say 24 rebuttal on that,but thank you for that. 25 MR.CARTER:No problem. CSB REPORTING 28 COLLOQUY 208.890.5198 1 COMMISSIONER ANDERSON:So with that,we are 2 ready to call our first witness,so let's begin with 3 Intermountain Gas.You can call your first witness. 4 MR.CARTER:Sure,Intermountain Gas calls Lori 5 Blattner. 6 7 LORI BLATTNER, 8 produced as a witness at the instance of the 9 Intermountain Gas Company,having been first duly sworn 10 to tell the truth,was examined and testified as follows: 11 12 DIRECT EXAMINATION 13 14 BY MR.CARTER: 15 Q.Ms.Blattner,will you please state and spell 16 your name for the record? 17 A.Lori Blattner,L-o-r-i B-1-a-t-t-n-e-r. 18 Q.And are you the same Lori Blattner that filed 19 direct testimony in support of the stipulation and 20 settlement in this case? 21 A.Yes. 22 Q.If I asked you the same questions today,would 23 your answers be the same? 24 A.Yes. 25 MR.CARTER:Mr.Chair,I'd ask that CSB REPORTING 29 BLATTNER (Di) 208.890.5198 Intermountain Gas 1 Ms.Blattner's direct testimony in support of the 2 stipulation and settlement be spread upon the record as 3 if read. 4 COMMISSIONER ANDERSON:Without objection,so 5 done. 6 (The following prefiled direct testimony of 7 Ms.Lori Blattner is spread upon the record.) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 30 BLATTNER (Di) 208.890.5198 Intermountain Gas 1 Q.Please state your name,business address,and 2 present position with Intermountain Gas Company 3 ("Intermountain"or "Company"). 4 A.My name is Lori Blattner,and I am the Director 5 of Regulatory Affairs for Intermountain Gas Company and 6 Cascade Natural Gas Corporation.My business address is 7 555 South Cole Road,Boise,ID 83707. 8 Q.Please describe your involvement in this 9 proceeding. 10 A.I have been involved in all aspects of this 11 proceeding.I filed direct testimony to support 12 Intermountain's General Rate Case Application with the 13 Idaho Public Utilities Commission ("Commission")in this 14 matter.I have reviewed the testimony of all Company's 15 witnesses;was deeply involved in the extensive 16 production requests;attended the settlement conferences; 17 and am otherwise familiar with the issues involved in the 18 case. 19 Q.What is the purpose of your testimony? 20 A.The purpose of my testimony is to describe the 21 Stipulation and Settlement ("Settlement")that was signed 22 by parties in the case,to express the Company's support 23 of the Settlement,and to recommend that the Commission 24 approve the Settlement without change. 25 Q.While maintaining confidentiality,please CSB REPORTING 31 L.BLATTNER DI-1 208.890.5198 Intermountain Gas 1 describe the process that resulted in the Settlement. 2 A.After the Company filed its Application, 3 Commission Staff ("Staff")and Intervenors engaged in 4 extensive discovery,which included well over one-hundred 5 production requests and responses,as well as a series of 6 meetings with Staff during which Staff and the Company 7 discussed questions and issues related to production 8 requests,documents,and other items related to the case. 9 / 10 / 11 / 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 32 L.BLATTNER DI-la 208.890.5198 Intermountain Gas 1 The Commission held three public workshops 2 related to the case:one in Pocatello,one in Twin Falls, 3 and one in Boise.Staff and representatives of the 4 Company attended each of these workshops. 5 Towards the end of the discovery process,and 6 after the public workshops,Staff provided notice of two 7 formal settlement conferences.All Parties to the 8 case-which included Staff,Intermountain,the Alliance of 9 Western Energy Consumers ("AWEC"),Idaho Conservation 10 League ("ICL")and the City of Boise ("City")-attended 11 and participated in the settlement conferences,which 12 took place on March 30 and 31,2023.After extensive 13 discussions-the contents of which are confidential-all 14 but one of the Parties agreed to the terms of the 15 Settlement.The Settling Parties finalized and signed the 16 stipulation and settlement agreement ("Settlement") 17 itself at the end of April and early May 2023. 18 Intermountain appreciates the time and effort of Staff 19 and all Parties to reach a settlement in this rate case 20 proceeding. 21 Q.Did all Parties join the Settlement? 22 A.No.The Company,Staff,AWEC,and ICL signed 23 the Settlement.This testimony refers to the parties that 24 have signed the agreement as the "Settling Parties."The 25 term "Parties"includes all parties to the proceeding. CSB REPORTING 33 L.BLATTNER DI-2 208.890.5198 Intermountain Gas 1 The City did not sign the Settlement,but has agreed not 2 to oppose the Settlement. 3 Q.Please describe the Settlement. 4 A.The Settlement contains several components, 5 each of which is described in the Settlement itself.I 6 would like to touch upon several of the key components of 7 the Settlement. 8 Overall rate increase.The Company sought,in 9 its Application,a margin revenue increase of 10.3%,for 10 an overall revenue increase of 3.2%.The Settlement,if 11 approved 12 / 13 / 14 / 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 34 L.BLATTNER DI-2a 208.890.5198 Intermountain Gas 1 by the Commission,would result in margin revenue 2 increase of approximately 2.75%,as illustrated in 3 Exhibit 1 to the Settlement,for an overall revenue 4 increase of 0.73%. 5 Revenue Requirement.The Settlement includes a 6 revenue requirement of $3.05 million.The components of 7 the Revenue Requirement are set forth in paragraph 2 of 8 the Settlement,and include:a return on equity of 9.5%, 9 which is the same as the return on equity approved in 10 2017 in the Company's most recent general rate case;a 11 total rate base of $385,288,577,with certain values of 12 components of rate base delineated in the text and 13 exhibits of the Settlement;and rate case expenses from 14 this rate case and certain remaining items from the 2017 15 rate case,to be amortized over a period of five years. 16 Cost of Service,Rate Design,and Rate Spread. 17 The Settling Parties agreed to accept the class revenue 18 apportionment proposed by the Company in its Application, 19 which is set forth in Exhibit 2 to the Settlement.In 20 broad terms,if approved by the Commission,the revenue 21 requirement will be recovered by increasing the customer 22 charge for residential customers to $8.00,with a 23 decrease to the distribution rate.Customer and demand 24 charges for other customer classes are described in 25 detail in Exhibit 3 to the Settlement. CSB REPORTING 35 L.BLATTNER DI-3 208.890.5198 Intermountain Gas 1 Billing Determinants and Other Issues.The 2 Settling Parties further agreed that the billing 3 determinants would be as proposed by the Company in its 4 Application and Testimony.Further,the Settling Parties 5 agreed to accept the Company's position,as set forth in 6 the Application and Testimony,related to the Company's 7 proposals on in-person pay station transaction fees and 8 non-utility LNG sales credits. 9 Non-financial components of the Settlement.In 10 addition to the financial aspects of the Settlement,the 11 Company has agreed to meet with Staff before the next 12 rate case to 13 / 14 / 15 / 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 36 L.BLATTNER DI-3a 208.890.5198 Intermountain Gas 1 discuss protocols for providing access to certain 2 information related to the Company's affiliates.This 3 will facilitate an efficient transfer of relevant 4 information during the next rate case. 5 In addition,before filing the Company's next 6 rate case,the Company and Staff have agreed to hold a 7 workshop to discuss the methodology for weather 8 normalization to be used in the next general rate case. 9 Finally,the Company has agreed to provide 10 certain information regarding the allocation factors used 11 in allocating costs and expenses from Intermountain's 12 parent company and affiliates during its next general 13 rate case. 14 Q.Do you believe that the Settlement is in the 15 public interest? 16 A.Yes.Each of the components of the Settlement 17 were thoroughly discussed and negotiated during the 18 settlement conferences,with the participation of the 19 Parties,and reflect a variety of different aspects of 20 the Company's customer base.Before the settlement 21 conferences,the Parties had the opportunity to engage 22 in,and did engage in,an extensive discovery process, 23 confirming that the settlement conferences and resulting 24 Settlement were based on all relevant information. 25 In addition,Staff and the Company had the CSB REPORTING 37 L.BLATTNER DI-4 208.890.5198 Intermountain Gas 1 opportunity to hear from customers during the customer 2 workshops,which were held before the settlement 3 conferences,ensuring that concerns raised by customers 4 were considered during the settlement conferences. 5 All things considered,I believe that the 6 agreement set forth in the Settlement reflects a 7 reasonable compromise of all Parties'positions in the 8 case.Each party had to 9 / 10 / 11 / 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 38 L.BLATTNER DI-4a 208.890.5198 Intermountain Gas 1 compromise,but I believe the overall result reflects a 2 just,fair,and reasonable outcome that appropriately 3 balances the needs of the Company,its customers,and the 4 Parties. 5 For these reasons,the Company respectfully 6 requests that the Commission approve the Settlement 7 without change. 8 Q.Does this conclude your testimony? 9 A.Yes. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 39 L.BLATTNER DI-5 208.890.5198 Intermountain Gas 1 (The following proceedings were had in 2 open hearing.) 3 MR.CARTER:Ms.Blattner is now available for 4 cross-examination or questions from the Commission. 5 COMMISSIONER ANDERSON:Thank you.Commission 6 Staff? 7 MS.SHARP:We don't have any questions. 8 COMMISSIONER ANDERSON:Are there any questions 9 from any of the intervenors?Any questions from us? 10 Hearing none,thank you,Ms.Blattner,for your 11 testimony and it will be spread across the record. 12 THE WITNESS:Thank you. 13 (The witness left the stand.) 14 MR.CARTER:The Company doesn't have any 15 further witnesses. 16 COMMISSIONER ANDERSON:No further.Thank you 17 very much. 18 Mr.Stokes,do you have testimony? 19 MR.STOKES:Yes,Your Honor,I'd like to call 20 Brad Mullins to the stand. 21 22 23 24 25 ICSBREPORTING40BLATTNER 208.890.5198 Intermountain Gas 1 BRADLEY G.MULLINS, 2 produced as a witness at the instance of the Alliance of 3 Western Energy Consumers,having been first duly sworn to 4 tell the truth,was examined and testified as follows: 5 6 DIRECT EXAMINATION 7 8 BY MR.STOKES: 9 Q.Good morning.Please state your name and spell 10 your name as well. 11 A.My name is Brad Mullins,spelled M-u-1-1-i-n-s. 12 Q.Are you the same Brad Mullins that filed 13 settlement testimony in this matter? 14 A.I am. 15 Q.If I asked you the same questions today,would 16 your answers be the same? 17 A.They would. 18 Q.Do you have any corrections to your testimony? 19 A.I do not. 20 MR.STOKES:At this point the witness is 21 available for examination --oh,I'd like to enter the 22 testimony in the record. 23 COMMISSIONER ANDERSON:Very well. 24 (The following prefiled direct testimony of 25 Mr.Bradley Mullins is spread upon the record.) CSB REPORTING 41 MULLINS (Di) 208.890.5198 AWEC 1 I.INTRODUCTION AND SUMMARY 2 Q.PLEASE IDENTIFY THE PARTY ON WHOSE BEHALF 3 YOU ARE TESTIFYING. 4 A.I am testifying on behalf of the Alliance 5 of Western Energy Consumers ("AWEC").AWEC is a 6 non-profit trade association whose members are large 7 energy users in the Western United States,including 8 customers receiving gas sales and transportation services 9 from Intermountain Gas Company ("Intermountain"). 10 Q.WHAT IS THE PURPOSE OF YOUR TESTIMONY? 11 A.I discuss AWEC's support for the May 4, 12 2023 Stipulation and Settlement ("Stipulation")entered 13 into by Intermountain,Staff for the Idaho Public 14 Utilities Commission ("Staff"),AWEC,and the Idaho 15 Conservation League (collectively,"Settling Parties"). 16 The City of Boise,the only intervenor which is not a 17 party to the Stipulation,has indicated that they do not 18 intend to oppose the Stipulation.The Settling Parties 19 and the City of Boise are collectively referred to herein 20 as ("Parties"). 21 Q.PLEASE SUMMARIZE AWEC'S SUPPORT FOR THE 22 STIPULATION. 23 A.The under the terms of the Stipulation, 24 the Settling Parties agreed to increase Intermountain's 25 margin rates by $3,050,000 or 2.75%.The Stipulation CSB REPORTING 42 B.MULLINS,Di 1 208.890.5198 AWEC 1 represents an $8,287,947 reduction from the $11,337,947 2 revenue requirement increase Intermountain requested in 3 its initial filing.In addition,the Stipulation provides 4 a rate spread recognizing that large volume sales 5 / 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 43 B.MULLINS,Di la 208.890.5198 AWEC 1 and transportation customers are paying rates in excess 2 of their class cost of service.While the rate spread 3 does not move the large volume sales and transportation 4 rate classes to parity,AWEC supports the gradual move in 5 this case due to overall size of the rate increase,which 6 is relatively small in comparison to Intermountain's 7 filed case.Finally,the Stipulation contains 8 requirements for Intermountain to provide information 9 about intercorporate cost allocations in its next general 10 rate case filing,a provision that AWEC supported.AWEC 11 finds that the Stipulation represents a reasonable 12 comprise of the issues raised in this docket and 13 recommends that the Commission approve the Stipulation. 14 Q.WHAT STANDARD DOES THE COMMISSION APPLY 15 WHEN CONSIDERING A SETTLEMENT? 16 A.The Commission has jurisdiction over this 17 matter under Idaho Code §§61-502 and 61-503,and has the 18 express statutory authority to investigate rates, 19 charges,rules,regulations,practices,and contracts of 20 public utilities and to determine whether they are just, 21 reasonable,preferential or discriminatory,or in 22 violation of any provision of law,and may fix the same 23 by Order.Idaho Code §§61-502 and 61-503.Proponents of 24 a proposed settlement must show "that the settlement is 25 reasonable,in the public interest,or otherwise in CSB REPORTING 44 B.MULLINS,Di 2 208.890.5198 AWEC 1 accordance with law or regulatory policy."IDAPA 2 31.01.01.275.Notwithstanding,the Commission is not 3 bound by settlement agreements.IDAPA 31.01.01.276. 4 Instead,the Commission "will independently review any 5 settlement proposed to it to determine whether the 6 settlement is just,fair and reasonable,in the public 7 interest,or otherwise in accordance with law or 8 regulatory policy."Id. 9 Q.PLEASE DISCUSS AWEC'S REVIEW OF 10 INTERMOUNTAIN'S FILING. 11 A.AWEC performed a detailed review of 12 Intermountain's revenue requirement and rate spread 13 and rate design.AWEC submitted 95 production requests 14 and reviewed Intermountain's 15 / 16 / 17 / 18 19 20 21 22 23 24 25 CSB REPORTING 45 B.MULLINS,Di 2a 208.890.5198 AWEC 1 responses to Production Requests.AWEC also reviewed 2 Intermountain's responses to the numerous production 3 requests from Staff.AWEC also participated in settlement 4 negotiations.Based on its review of discovery,AWEC 5 prepared a detailed revenue requirement proposal which 6 was provided to settlement participants for consideration 7 in the settlement process. 8 Q.PLEASE DISCUSS THE REVENUE REQUIREMENT 9 CHANGES IN INTERMOUNTAIN'S MARCH 9,2023 UPDATED DIRECT 10 FILINGS. 11 A.In its initial filing,Intermountain 12 requested a $11,337,947 or 10.56%margin rate increase. 13 The initial filing used a historical test period, 14 consistent with the Commission's preferred practice, 15 based on the year ending December 31,2022.The full 16 year of test period results was not available at the time 17 of Intermountain's filing,which occurred on December 1, 18 2022.Accordingly,the revenue requirement in 19 Intermountain's initial filing included forecast data 20 for the fourth quarter of 2022.In AWEC Production 21 Request 02,AWEC requested that Intermountain update its 22 test period results to include actual data for the fourth 23 quarter of 2022.Intermountain responded to AWEC Data 24 Request 02 on February 28,2023,providing updated 25 revenue requirement calculations with the full year of CSB REPORTING 46 B.MULLINS,Di 3 208.890.5198 AWEC 1 historical data,and later filed Updated Direct Testimony 2 on March 9,2023 incorporating the results of that 3 analysis into its filing. 4 In addition to updating the test period results 5 described above,Intermountain also corrected several 6 errors that AWEC had identified in discovery.In AWEC 7 Production Requests 21 and 23,AWEC identified errors 8 related to Intermountain's calculation of income tax 9 expenses.In its response to AWEC's requests, 10 Intermountain acknowledged its mistake and committed to 11 correcting the error in its Updated Direct Filings. 12 In Intermountain's March 9,2023 Updated Direct 13 Filings,Intermountain included an update of its revenue 14 requirement with actual data for the entire test period. 15 Intermountain also 16 / 17 / 18 / 19 20 21 22 23 24 25 CSB REPORTING 47 B.MULLINS,Di 3a208.890.5198 AWEC 1 corrected the above referenced tax expense errors.The 2 result of the March 9,2023 Updated Direct Filings was a 3 proposed revenue requirement of $6,752,224,representing 4 a $4,585,723 reduction from Intermountain's initial 5 filing.Of this reduction,approximately $4,138,315 of 6 the difference in revenue requirement from 7 Intermountain's initial filing was attributable to 8 reduced tax expenses.In response to AWEC Production 9 Request 63,Intermountain confirmed that the reduction to 10 income tax expenses was attributable to the tax expense 11 items identified in AWEC Production Requests 21 and 23. 12 Copies of these requests have been attached as Mullins 13 Exhibit 202. 14 Q.PLEASE GIVE AN OVERVIEW OF THE SETTLEMENT 15 PROCESS. 16 A.The Parties met for settlement conferences 17 on March 30 and 31,2023.In the settlement conferences, 18 the Parties presented their respective positions and 19 proposed adjustments to Intermountain's revenue 20 requirement and Parties discussed the merits of each 21 adjustment.Ultimately,the Settling Parties were unable 22 to reach consensus on all of the individual revenue 23 requirement adjustments that had been proposed. 24 Notwithstanding,the Settling Parties were able to reach 25 a compromise position in which Intermountain would be CSB REPORTING 48 B.MULLINS,Di 4 208.890.5198 AWEC 1 provided with a $3,050,000 revenue requirement increase, 2 reflecting an overall margin rate increase of 3 approximately 2.75%.Each Settling Party came to this 4 result independently.Other than the items specified in 5 Paragraph 2 of the Stipulation,there was no consensus on 6 the specific adjustments that were made to arrive at this 7 result.Based on AWEC's proposed adjustments and 8 analysis prepared in advance of the settlement 9 conference,however,AWEC found the stipulated level of 10 revenue requirement to be a reasonable result. 11 / 12 / 13 / 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 49 B.MULLINS,Di 4a 208.890.5198 AWEC 1 Q.WHY DID AWEC AGREE TO A 9.5%ROE? 2 A.Paragraph 2(a.)of the Stipulation 3 provides Intermountain with a 9.5%return on equity 4 ("ROE").From AWEC's perspective,in the context of the 5 overall Stipulation and taking into consideration the 6 unique factors facing Intermountain,AWEC was willing to 7 accept a 9.5%ROE.AWEC finds that the Stipulation,taken 8 as a whole,results in fair,just and reasonable rates. 9 Q.PLEASE DISCUSS THE RATE SPREAD INCLUDED IN 10 THE STIPULATION. 11 A.The rate spread included in the 12 Stipulation was based on Intermountain's filed case, 13 which provided schedule LV sales and T-4 transportation 14 customers with a rate increase that is 53%of the system 15 average rate increase,or approximately 1.5%.Similarly, 16 the rate spread included in the Stipulation provides T-3 17 interruptible transportation customers with a rate 18 increase that is 25%of the system average rate increase, 19 or approximately 0.7%.Based on the cost of service 20 study contained in Intermountain's March 9,2023 Updated 21 Direct Testimony,Schedules LV and T-4 had parity ratios 22 of 1.38 and 1.37,respectively.By definition,the rates 23 for those schedules would need to be reduced 24 significantly to bring those customer rates in line with 25 their actual cost of service.Schedule T-3 CSB REPORTING 50 B.MULLINS,Di 5 208.890.5198 AWEC 1 transportation customers had an even larger parity ratio 2 of 6.55,meaning that the rates for those customers would 3 need to be reduced by several multiples to reach cost of 4 service rates.In the Stipulation,there was no 5 consensus on the cost-of-service study assumptions and 6 results.Notwithstanding,AWEC was willing to agree to a 7 more gradual shift towards parity,particularly 8 considering the magnitude of the revenue requirement 9 increase in the Stipulation.AWEC recognizes that high 10 energy costs present a challenge for all customers,and 11 in the context of gradualism and the spirit of 12 compromise, 13 / 14 / 15 / 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 51 B.MULLINS,Di 5a 208.890.5198 AWEC 1 AWEC was willing to accept Intermountain's proposed rate 2 spread as part of a global settlement. 3 Q.PLEASE EXPLAIN THE SETTLEMENT PROVISIONS 4 SURROUNDING CROSS COMPANY COST ALLOCATIONS. 5 A.One of AWEC's concerns with Intermountain's 6 filed case had to do with cross company cost allocations. 7 Since Intermountain was acquired by MDU Resources ("MDU") 8 in 2008,the amount of costs that have been allocated 9 from Intermountain's corporate parent and between other 10 affiliate utilities have been increasing.MDU and its 11 family of utilities are also becoming increasingly 12 integrated,making it more difficult to segregate costs 13 from one utility to another.While AWEC recognizes that 14 there can be some benefits to integrated operation of 15 certain utility functions,AWEC was concerned with the 16 level of detail supporting the cost allocations that were 17 proposed in revenue requirement.Accordingly,as a 18 provision of the Stipulation,AWEC requested that 19 Intermountain provide further information regarding 20 intercorporate cost allocations in its next general rate 21 case filings.Specifically,AWEC requested that 22 Intermountain file testimony describing the allocation 23 methods,and that Intermountain provide workpapers 24 supporting the allocation factors and the allocated costs 25 in its filing.Accordingly,in Paragraph 5 of the CSB REPORTING 52 B.MULLINS,Di 6 208.890.5198 AWEC 1 Stipulation,Intermountain agreed to provide more cost 2 allocation information in its next general rate case. 3 This provision of the Stipulation is designed to improve 4 staff and intervenors'ability to review the cost 5 allocation and provide a better understanding of how the 6 intercorporate cost allocations are being performed. 7 Q.PLEASE EXPLAIN WHY THE STIPULATION SATISFIES 8 THE INTERESTS AND CONCERNS OF AWEC. 9 A.Based on its review of Intermountain's filing 10 and through the discovery process,AWEC had issues with 11 the requested ROE,income tax expense,several revenue 12 requirements adjustments, 13 / 14 / 15 / 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 53 B.MULLINS,Di 6a 208.890.5198 AWEC 1 intercompany allocations,and rate spread and rate 2 design.Although the Stipulation does not incorporate 3 all of AWEC's proposed adjustments,it does incorporate 4 many of AWEC adjustments and positions.Accordingly,the 5 overall result is fair and provides a significant benefit 6 to customers. 7 Q.PLEASE EXPLAIN WHY AWEC BELIEVES THE 8 STIPULATION IS IN THE PUBLIC INTEREST. 9 A.AWEC believes the Stipulation is in the public 10 interest and recommends the Commission approve the 11 Stipulation because the best interests of Intermountain's 12 natural gas customers are served by the underlying fair 13 compromise on certain revenue requirement and rate spread 14 and design issues.While the Stipulating Parties may 15 each hold different positions on the individual 16 components of Intermountain's natural gas revenue 17 requirement addressed in the Stipulation,AWEC supports 18 the Stipulation because it decreased the proposed revenue 19 requirement increase by $8,287,947 from Intermountain's 20 initial filing,which results in a revenue requirement 21 increase of $3,050,000.AWEC supports the Stipulation as 22 an overall result that is a fair compromise between 23 Intermountain and its customers.AWEC also finds the 24 Stipulation to be in the public interest as the spread of 25 the gas rate increase is done in a manner to better CSB REPORTING 54 B.MULLINS,Di 7 208.890.5198 AWEC 1 align rates based on Intermountain's cost of service 2 study.For the reasons set forth above,AWEC believes 3 the Stipulation is in the public interest and should be 4 approved by the Commission. 5 Q.DO YOU HAVE ANY CLOSING REMARKS? 6 A.AWEC appreciates the opportunity to participate 7 in this proceeding.AWEC also appreciates 8 Staff's thorough review of,and attention to,the matters 9 at issue in this proceeding,and Intermountain's 10 willingness to engage in settlement negotiations in good 11 faith in order to reach 12 / 13 / 14 / 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 55 B.MULLINS,Di 7a 208.890.5198 AWEC 1 a compromise position that all parties could support. 2 While this Stipulation did not necessarily resolve all 3 the issues that AWEC identified in its review,AWEC found 4 that it represented a reasonable compromise,resulting in 5 just a 2.75%rate increase relative to the 10.56%rate 6 increase included in Intermountain's initial filing. 7 AWEC supports the stipulation as just,fair and 8 reasonable and in the public interest. 9 Q.DOES THIS CONCLUDE YOUR SETTLEMENT TESTIMONY? 10 A.Yes. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 56 B.MULLINS,Di 8 208.890.5198 AWEC 1 (The following proceedings were had in 2 open hearing.) 3 COMMISSIONER ANDERSON:Are there any questions 4 from Staff? 5 MS.SHARP:None. 6 COMMISSIONER ANDERSON:The Company? 7 MR.CARTER:None from the Company. 8 COMMISSIONER ANDERSON:Any of the other 9 intervenors? 10 COMMISSIONER ANDERSON:Without objection,we 11 will spread Mr.Mullins'testimony across the record as 12 if read and I don't believe the Commission has any other 13 questions,so thank you very much for your testimony. 14 THE WITNESS:Thank you. 15 (The witness left the stand.) 16 COMMISSIONER ANDERSON:Mr.Stokes,are there 17 any other witnesses you wish to call? 18 MR.STOKES:No. 19 COMMISSIONER ANDERSON:The Idaho Conservation 20 League,a witness?No. 21 City of Boise?None,and Staff. 22 MS.SHARP:Staff calls Michael Louis. 23 COMMISSIONER ANDERSON:Thank you. 24 25 CSB REPORTING 57 MULLINS 208.890.5198 AWEC 1 MICHAEL LOUIS, 2 produced as a witness at the instance of the Staff, 3 having been first duly sworn to tell the truth,was 4 examined and testified as follows: 5 6 DIRECT EXAMINATION 7 8 BY MS.SHARP: 9 Q.Would you please state and spell your last name 10 for the record? 11 A.My name is Michael Louis.Last name is spelled 12 L-o-u-i-s. 13 Q.And are you the same Michael Louis that filed 14 testimony in support of the proposed settlement? 15 A.I am. 16 Q.Do you have any corrections or modifications to 17 your testimony? 18 A.I have none. 19 Q.And if I were to ask you the same questions 20 today,would your answers be the same? 21 A.They would. 22 MS.SHARP:Mr.Chair,I now move to spread the 23 filed testimony of Michael Louis on the record. 24 COMMISSIONER ANDERSON:Thank you.Without 25 objection,we will spread Mr.Louis'testimony across the CSB REPORTING 58 LOUIS (Di) 208.890.5198 Staff 1 record as if read. 2 (The following prefiled direct testimony of 3 Mr.Michael Louis is spread upon the record.) 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CSB REPORTING 59 LOUIS (Di) 208.890.5198 Staff 1 Q.Please state your name and business address for 2 the record. 3 A.My name is Michael Louis.My business address 4 is 11331 W.Chinden Blvd.,Ste.201-A,Boise,ID 83714. 5 Q.By whom are you employed and in what capacity? 6 A.I am employed by the Idaho Public Utilities 7 Commission ("Commission")as the Engineering Section 8 Program Manager. 9 Q.What is your educational and professional 10 background? 11 A.Please see a summary of my educational and 12 professional background in Exhibit No.101. 13 Q.What is the purpose of your testimony in this 14 proceeding? 15 A.The purpose of my testimony is to describe the 16 proposed comprehensive Stipulation and Settlement 17 ("Settlement")and explain Staff's support. 18 Q.Please summarize your testimony. 19 A.The proposed Settlement would provide a base 20 rate revenue increase of 2.75%or $3.05 million on June 21 01,2023.1 Based on Staff's comprehensive review of 22 1 On page 9 of the Settlement,it states that the increase in 23 revenue requirement reflects a 2.75%"overall"increase as illustrated in Exhibit 1 of the Settlement.This percentage and what 24 is reflected in Exhibit 1 is the base rate revenue increase not an overall increase since an overall increase would include the cost of 25 gas which is in the Company's Purchased Gas Adjustment Rate. CASE NO.INT-G-22-07 60 LOUIS,M.(Stip)1 05/17/23 STAFF 1 Intermountain Gas Company's ("Company"or 2 "Intermountain")Application,a thorough audit of the 3 Company's books and records resulting in a detailed 4 identification of adjustments to the revenue requirement, 5 an extensive negotiation with the intervening parties in 6 the case,and thoughtful consideration of the alternative 7 to settlement,Staff believes that the proposed 8 Settlement is in the public interest,is fair,just,and 9 reasonable;and should be approved by the Commission. 10 Q.How is your testimony organized? 11 A.My testimony is structured under the following 12 sections: 13 I.Background 14 II.Staff Investigation 15 III.The Settlement Process 16 IV.Staff Support for the Settlement 17 A.Revenue Requirement 18 B.Allocation of the Revenue Requirement 19 C.Rate Design 20 D.Other Terms and Conditions 21 Background 22 Q.Please provide an overview of the Company's 23 Application? 24 A.The Company filed its Application on December 25 1,2022,requesting a $11.3 million increase in base rate CASE NO.INT-G-22-07 61 LOUIS,M.(Stip)205/17/23 STAFF 1 recovery or an increase of 10.3%.On March 9,2023,the 2 Company filed an amended Application adjusting the 3 increase to $6.8 million or a base rate revenue increase 4 of 6.9%.The Company proposed an overall rate of return 5 ("ROR")of 7.37%and a Return on Equity ("ROE")of 10.3%. 6 The Company's proposed changes were based on a 7 2022 test year,with actuals from January through 8 September 2022 and estimates from October through 9 December 2022,which the Company updated with actuals in 10 early March 2023. 11 The Company proposed movement towards cost of 12 service based on their cost-of-service study ("COSS"). 13 As proposed,under-allocated Residential Customers were 14 limited to 125%of the total relative system increase, 15 while the highest over-allocated customers,interruptible 16 Transport Customers,were limited to 25%of the overall 17 system increase.All other customers were proposed to 18 receive the remainder of the increase at 53%. 19 Finally,the Company proposed changes in 20 customer charges,increasing Residential Customer charges 21 from $5.50 to $9.00 and $8.00 for Residential and 22 interruptible Residential Customers,respectively; 23 increasing General Service Customer charges from $9.50 to 24 $15.00 for both General Service and interruptible General 25 Service Customers;and establishing customer charges CASE NO.INT-G-22-07 62 LOUIS,M.(Stip)305/17/23 STAFF 1 where none currently exist of $150.00 for Large Volume 2 and firm Transport Service Customers and $300.00 for 3 interruptible Transport Customers.The Company also 4 proposed changes in the rate block thresholds for Large 5 Volume Customers reducing them so that they are relevant 6 to historic usage patterns. 7 Q.How was the case processed after the case was 8 filed? 9 A.The Commission issued Notices of Application 10 and Intervention and granted intervenor status to the 11 Alliance of Western Energy Consumers ("AWEC"),the City 12 of Boise,and the Idaho Conservation League ("ICL").The 13 Commission approved a procedural schedule and a 14 settlement conference was held on March 30th and 31st.A 15 comprehensive Settlement was reached by all parties and a 16 motion to approve it was filed with the Commission on 17 April 5,2023. 18 Staff's Investigation 19 Q.Could you please describe Staff's investigation 20 leading up to the settlement conference? 21 A.Yes.Staff's approach prior to the settlement 22 conference was to comprehensively review the Company's 23 filing to identify adjustments to the revenue requirement 24 request and make recommendations for allocation of the 25 revenue requirement and rate design in preparation to CASE NO.INT-G-22-07 63 LOUIS,M.(Stip)405/17/23 STAFF 1 file testimony for a fully-litigated proceeding.Four 2 auditors,five utility analysts,and one engineer were 3 assigned to the case and submitted over 120 discovery 4 requests to investigate all aspects of the case.Staff 5 performed an on-site audit on January 26 and 27 and on 6 March 1 through the 3rd,and held several electronic 7 meetings with the Company to conduct its investigation. 8 For the revenue requirement,the four auditors 9 reviewed the test year results of operations,O&M 10 expenses,capital budgets and spending,and verified 11 thousands of calculations and assumptions related to 12 labor expenses,incentive plans,employee benefits and 13 pension expenses to ensure an appropriate level of 14 expenditure.In addition,an auditor performed an 15 extensive analysis of the cost of capital and capital 16 structure. 17 In addition to the auditors,four of the 18 utility analysts and the engineer assigned to the case 19 performed an extensive review of capital projects to 20 determine if the projects included for recovery were 21 prudently incurred.They also reviewed several of the 22 miscellaneous proposals included in the filing such as 23 updating the credits for non-utility LNG sales and 24 resolution of in-person pay station transaction fees. 25 One utility analyst was assigned to review the |CASE NO.INT-G-22-07 64 LOUIS,M.(Stip)505/17/23 STAFF 1 normalization of consumption,cost of service,and rate 2 design.Because of the number of issues related to 3 normalization of consumption and cost of service,the 4 Company and Staff met on several occasions prior to the 5 case being filed to improve what was filed in this case. 6 Staff also worked with the Company to completely redesign 7 the Company's line extension policy that was at issue in 8 the last general rate case so it was no longer an issue 9 in this case. 10 The Settlement Process 11 Q.Can you describe the process used during these 12 settlement negotiations? 13 A.Yes,I can.The Settlement conference was 14 conducted on March 30th and 31st of 2023 with all 15 intervening parties in attendance.Each party described 16 and provided justification for its proposed revenue 17 requirement adjustments,and positions for consumption 18 normalization,cost of service,rate design,or other 19 issues.Questions and discussions occurred prior to 20 adjourning for the day. 21 At the start of the second day meeting,the 22 Company presented their counter proposal for the revenue 23 requirement.Time was given for intervening parties and 24 Staff to evaluate and discuss the proposal.Negotiations 25 continued until the parties reached a compromise on a CASE NO.INT-G-22-07 65 LOUIS,M.(Stip)605/17/23 STAFF 1 tentative revenue increase of $3.05 million. 2 After an agreement on the revenue requirement 3 was reached,the only two open issues identified from the 4 previous day was the allocation of the revenue 5 requirement and Company proposed changes to customer 6 charges.With consideration of the COSS results,it was 7 agreed that the Company's proposals on movement towards 8 cost of service was reasonable. 9 Regarding changes to customer charges,each 10 party was able to restate their preferences and reasons 11 for their position.After negotiation,small changes 12 were made to the Company's proposal and agreed upon by 13 all parties. 14 Q.Were there other issues discussed during the 15 settlement? 16 A.Yes.Several issues were identified during the 17 discussions that would improve future rate cases.Action 18 items were identified for inclusion in the agreement. 19 Staff's Support for the Settlement 20 Q.How did Staff determine that the overall 21 Settlement was reasonable? 22 A.In every settlement evaluation,Staff and other 23 parties must determine if the agreement provides a better 24 overall outcome than could be expected at hearing.Staff 25 looked at each revenue requirement adjustment and other CASE NO.INT-G-22-07 66 LOUIS,M.(Stip)7 05/17/23 STAFF 1 issues under consideration and determined that the 2 overall agreement was as good or better than what could 3 be expected by fully litigating the case.All 4 intervening parties to the case,including other customer 5 groups and those representing customers with 6 environmental interests,agreed to support or not oppose 7 the Settlement. 8 In addition,Staff evaluated the issues from 9 the last general rate case (INT-G-16-02)including: 10 inadequately justified rate case expenses from the 2016 11 general rate case,the lack of a load study for 12 determining cost of service,issues related to 13 normalization of consumption,updating the Company's line 14 extension policy,and treatment of in-person payment 15 transaction fees.These issues were addressed through 16 the Company's Application,efforts prior to filing the 17 Application,or as part of the Settlement. 18 Revenue Requirement 19 Q.Please describe the terms of the Settlement 20 agreement regarding the revenue requirement. 21 A.Under the terms of the Settlement,the Company 22 would receive a $3.05 million or 2.75%base rate revenue 23 increase effective on June 01,2023.This represents 24 $8.25 million in total adjustments to the revenue 25 requirement compared to the Company's $11.3 million CASE NO.INT-G-22-07 67 LOUIS,M.(Stip)805/17/23 STAFF 1 initially proposed increase.The parties agreed to a 2 9.50%return on equity ("ROE"),which is a reduction of 3 80 basis points from the Company's proposed 10.3%ROE. 4 Q.Can you explain why Staff believes the 9.5%ROE 5 is reasonable? 6 A.Yes.Staff believes a ROE of 9.5%is 7 reasonable because it is within the range of 8 reasonableness established by Staff as part of its ROE 9 evaluation.It is consistent with authorized ROEs for 10 other electric and gas utilities operating nationally and 11 in the Northwest.It is also consistent with the 12 Commission's most recent authorization of a 9.5%ROE in 13 Order No.35692,issued March 1,2023,for Gem State 14 Water Company.A 9.5%ROE should allow the Company to 15 maintain its ability to attract new capital from equity 16 markets to finance capital investments to grow and 17 maintain its operations. 18 Q.Other than ROE,can you describe Staff's 19 adjustments to the Company's proposed Revenue Requirement 20 Staff identified through its investigation prior to 21 Settlement? 22 A.Yes.Besides the adjustment for ROE,Staff 23 identified 16 additional Revenue Requirement adjustments. 24 Three of the items were adjustments to rate base while 25 the remaining 13 adjustments were expense related. CASE NO.INT-G-22-07 68 LOUIS,M.(Stip)9 05/17/23 STAFF 1 The rate base items included assets Staff 2 believed were not used and useful by the end of the test 3 year and infrastructure that should be offset by 4 contributions-in-aid-of-construction payments from 5 customers. 6 The largest expense items included:removal of 7 pay increases beyond the test year;removal of incentive 8 payments for non-executive employees Staff believed were 9 being paid to increase shareholder value rather than for 10 the benefit of customers;removal of several credit card 11 transactions and other miscellaneous expenses;an 12 adjustment for costs of the multi-year corporate Maximo 13 information technology project due to realization of 14 benefits not likely to occur until more of the project is 15 implemented;adjustments for parent company (MDU 16 Resources)expenses and affiliate transactions Staff 17 could not tie to benefits realized by Intermountain's 18 customers;and adjustments to rate case expenses 19 inadequately justified or improperly amortizing over a 20 reasonable period. 21 Q.Why does Staff believe the revenue requirement 22 is reasonable? 23 A.Staff has a good understanding of the 24 adjustments that the Commission typically supports based 25 on experience in past cases and a good understanding of CASE NO.INT-G-22-07 69 LOUIS,M.(Stip)10 05/17/23 STAFF 1 regulatory cost-of-service principles.Staff assessed 2 the likelihood that each adjustment would be accepted by 3 the Commission and determined a target range it believed 4 would be acceptable for settlement.Only if the proposed 5 revenue requirement in settlement was within that range, 6 Staff would proceed with the settlement and filing with 7 the Commission.Otherwise,Staff would be inclined to 8 walk away from the negotiations and allow the case to go 9 to hearing. 10 Consumption Normalization 11 Q.Does Staff support the Company's normalization 12 of the test year consumption used for billing 13 determinants in rates and normalization of the test year 14 revenue in the revenue requirement included in the 15 Settlement? 16 A.Yes.Staff believes the Company's proposed 17 normalized consumption used in the Settlement is 18 reasonable based on the methods used to weather normalize 19 test year consumption. 20 Q.Was consumption normalization an issue in the 21 last general rate case? 22 A.Yes,it was.There were significant issues 23 Staff identified including issues with the data used in 24 the linear regression model to weather normalize the test 25 year consumption and several issues with the model CASE NO.INT-G-22-07 70 LOUIS,M.(Stip)1105/17/23 STAFF 1 itself. 2 Q.Were these issues resolved? 3 A.Yes.Staff and the Company met several times 4 between the last rate case and when this case was filed. 5 Almost all of the issues Staff identified were resolved 6 and those improvements were included in the Company's 7 Application.There were a couple of issues in this case 8 that Staff identified in the proposed model to improve 9 its accuracy,but the Company's resulting weather 10 normalized consumption was well within an acceptable 11 level of error. 12 Q.Please characterize these issues in the model. 13 A.Staff identified modifications to the model 14 that would improve its accuracy.Without these 15 modifications,it could push the results to an 16 unacceptable level of error in a future rate case under 17 different circumstances.Staff proposed these items be 18 addressed in a workshop after this case has concluded in 19 preparation for the next general rate case. 20 Allocation of the Revenue Requirement 21 Q.Does Staff support the class allocation of the 22 revenue requirement that is used in the Settlement? 23 A.Yes.Staff believes the Company's proposed 24 movements towards cost of service for the various classes 25 and adopted in the Settlement is reasonable for three CASE NO.INT-G-22-07 71 LOUIS,M.(Stip)12 05/17/23 STAFF 1 reasons. 2 First the COSS submitted with the Application 3 was based on a recent load study.Lack of a recent load 4 study was the most important reason why the Company's 5 COSS was not used in the previous general rate case. 6 Second,the COSS utilized accepted methods for 7 separating the costs each class of customers cause in the 8 Company's system so that the parties could determine how 9 far each class is from paying their equitable share of 10 the Company's costs based on present rates. 11 Finally,Staff believes that the method,as 12 described earlier in my testimony,struck a good balance 13 of making movements towards each class's cost of service 14 while maintaining the Commission's past values of 15 gradualism when changing rates. 16 Rate Design 17 Q.Does Staff support changes in the rate design 18 included in the Settlement? 19 A.Yes.Staff believes that the increases in the 20 monthly customer charge in customer's bills negotiated 21 and accepted by the parties to the Settlement and the 22 reductions in Large Volume Customer rate block thresholds 23 proposed in the Company's Application also included in 24 the Settlement are reasonable. 25 Q.What changes to the customer charge were CASE NO.INT-G-22-07 72 LOUIS,M.(Stip)1305/17/23 STAFF 1 included in the Settlement? 2 A.The parties agreed to the increases in the 3 customer charge and establishment of new customer charges 4 included in Company's Application,with the exception of 5 the customer charge for firm Residential Customers.The 6 parties agreed to increase the charge to $8.00 per bill 7 rather than $9.00 as proposed by the Company. 8 Q.Why does Staff support the increase in the 9 customer charges in the Settlement? 10 A.Staff believes the increases in customer 11 charges to be reasonable for several reasons.Customer 12 charges should be based on fixed costs.Concerns 13 regarding reducing the incentive of energy efficiency by 14 decreasing the amount of cost recovered through the 15 volumetric rate are not as relevant in the Company's rate 16 structure as they are in other utility rate structures. 17 The Company's rate structure is bifurcated with all of 18 the short-term variable costs associated with the cost 19 and transportation of gas being recovered through the 20 Purchased Gas Adjustment ("PGA")filing,which are 100% 21 recovered through a volumetric rate.Most of the cost 22 included in the Company's base rates and subject to 23 examination in this case are fixed costs over the short 24 term and do not vary based on the amount of the gas 25 commodity sold.However,customers may not differentiate CASE NO.INT-G-22-07 73 LOUIS,M.(Stip)1405/17/23 STAFF 1 the price signals of different rates within their utility 2 bills,so there could be some reduction in the incentive 3 to conserve. 4 On the other hand,increasing the customer 5 charge provides the Company with more stable recovery of 6 its fixed costs,which vary little throughout the year. 7 This is especially important for gas utilities which see 8 significant swings in their seasonal revenue streams from 9 winter space heating.Staff believes the modest 10 increases in the customer charge for all customer classes 11 strike a balance. 12 Q.Does Staff support the changes in the Large 13 Volume Customer rate block thresholds? 14 A.Yes.The usage patterns of existing Large 15 Volume Customers make the current rate block thresholds 16 irrelevant since none of the Large Volume Customers 17 approach the threshold amounts in the current rate blocks 18 with the peak amount of gas they consume.Staff believes 19 the new rate block thresholds are reasonable given the 20 class's current usage patterns. 21 Other Terms and Conditions 22 Q.Are there other terms and conditions not 23 already discussed that Staff supports? 24 A.Yes.Additional terms include:1.Company 25 action items to provide access to information on costs CASE NO.INT-G-22-07 74 LOUIS,M.(Stip)15 05/17/23 STAFF 1 and the allocation of those costs from its parent Company 2 and affiliates prior to the next rate case;2.resolution 3 of issues related to in-person pay station transaction 4 fees;and 3.changes to non-utility LNG Sales credits. 5 Q.Does Staff support the action items related to 6 access to and allocation of corporate affiliate costs 7 included in the Settlement? 8 A.Yes.Through Staff's initial investigation, 9 Staff questioned the allocation of costs from MDU 10 resources and affiliates because of a lack of access to 11 the information.Staff believes these action items 12 should resolve these issues in the next general rate 13 case. 14 Q.Does Staff support the resolution of issues 15 related to in-person pay station transaction fees 16 accepted in the Settlement? 17 A.Yes.The Company proposed to embed in-person 18 payment transaction fees in base rates in this filing and 19 collect deferred fees from October 1,2022,through 20 February 1,2023,through the PGA filing.Staff believes 21 this to be reasonable. 22 Q.Does Staff support the Company's proposal to 23 update the amount of the credit for Liquid Natural Gas 24 ("LNG")off-system sales as reflected in the Settlement? 25 A.Yes.The Company proposed in its Application, CASE NO.INT-G-22-07 75 LOUIS,M.(Stip)1605/17/23 STAFF 1 and the parties accepted,updating non-utility LNG sales 2 credits.Staff reviewed the workpapers included in the 3 Application and believes the update to the capital credit 4 of $0.03 and O&M credit of $0.04 for every gallon of LNG 5 sold will adequately recover those costs caused by 6 non-utility LNG customers,thus protecting the Company's 7 core customers. 8 Q.Does this conclude your testimony in this 9 proceeding? 10 A.Yes,it does. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CASE NO.INT-G-22-07 76 LOUIS,M.(Stip)1705/17/23 STAFF 1 (The following proceedings were had in 2 open hearing.) 3 MS.SHARP:I don't have any further questions. 4 The witness is available for cross-examination or further 5 questioning. 6 COMMISSIONER ANDERSON:Are there any questions 7 from any intervenors? 8 MR.CARTER:Not from the Company. 9 COMMISSIONER ANDERSON:Hearing none,thank you, 10 Mr.Louis,very much for your testimony. 11 (The witness left the stand.) 12 COMMISSIONER ANDERSON:Okay,we're moving right 13 along here.Do we have exhibits? 14 Ms.Sharp,do you want me to just go ahead and 15 read them into the record or has that been done already? 16 MS.SHARP:I think the exhibits have been 17 spread on the record as attached to the testimony of the 18 witnesses providing that in support of the record,but we 19 could review what you have -- 20 COMMISSIONER ANDERSON:Well -- 21 MS.SHARP:--just to make sure. 22 COMMISSIONER ANDERSON:Without objection, 23 Exhibits 1 through 6 are admitted into the record and 24 without objection,Exhibits 201,202 are admitted into 25 the record from Chad Stokes and I believe that exhausts CSB REPORTING 77 LOUIS208.890.5198 Staff 1 all of them that have to be done. 2 (AWEC Exhibit Nos.201 &202 were admitted into 3 evidence.) 4 COMMISSIONER ANDERSON:And that has exhausted 5 the witness list.Are there any further issues or items 6 that we need to discuss here today? 7 MS.SHARP:None for Staff. 8 MR.CARTER:None from the Company. 9 COMMISSIONER ANDERSON:Okay,very good.Any 10 posthearing briefs or closing statements from any of the 11 parties? 12 MR.CARTER:Not from the Company. 13 COMMISSIONER ANDERSON:Thank you.Have I 14 overlooked anybody here that has any questions at all, 15 because this is going so quickly,I don't know what to 16 do. 17 One thing I would like to say,if I've 18 overlooked the admission of any additional exhibits 19 previously identified in this matter,they are hereby now 20 admitted,and pursuant to Rule 267,any exhibits 21 presented during the hearing without objection are deemed 22 admitted at this time. 23 (All exhibits previously marked for 24 identification were admitted into evidence.) 25 COMMISSIONER ANDERSON:One side note, CSB REPORTING 78 COLLOQUY 208.890.5198 1 intervenor funding requests Rule 164 allows 14 days to 2 apply for intervenor funding,so if you anticipate 3 needing the full 14 days,are there any parties that need 4 that full 14 days or less than 14 days,I guess?I guess 5 we're fine with 14 days. 6 I appreciate everyone's attendance today. 7 Pursuant to Rule 247,representatives and parties 8 appearing in this proceeding must conduct themselves 9 properly and you've done that today and I always 10 appreciate that and like to make acknowledgments to that. 11 The Commission will consider this record to be 12 fully developed at this time and we will deliberate 13 privately and render a decision as quickly as we possibly 14 can,and with that,then,we are adjourned. 15 (The hearing adjourned at 9:09 a.m.) 16 17 18 19 20 21 22 23 24 25 ICSBREPORTING79COLLOQUY 208.890.5198 1 A UTHENT I C A T I ON 2 3 4 This is to certify that the foregoing 5 proceedings held in the matter of Intermountain Gas 6 Company's application for authority to increase its rates 7 and charges for natural gas service in the State of 8 Idaho,commencing at 9:00 a.m.,on Thursday,June 8, 9 2023,at the Commission Hearing Room,11331 West Chinden 10 Blvd.,Building 8,Suite 201-A,Boise,Idaho,is a true 11 and correct transcript of said proceedings and the 12 original thereof for the file of the Commission. 13 Accuracy of all prefiled testimony as 14 originally submitted to the Reporter and incorporated 15 herein at the direction of the Commission is the sole 16 responsibility of the submitting parties. 17 18 CONSTANCE S.BUCY 21 Certified Shorthand Reporter 187 22 23 CONSTANCE S BUCY 2 4 NOTARY PUBUC-STATE OF IDAHO COMMISSION NUMBER 12995 2 5 MY COMMISSION EXPIRES 9-5-2024 CSB REPORTING 80 AUTHENTICATION208.890.5198