20030618Reply Comments to J Brooks.pdf

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INTERMOUNTAIN GAS COMPANY
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EXECUTIVE OFFICES
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555 SOUTH COLE ROAD. P.O, BOX 7608. BOISE, IDAHO 83707. [phone]. FAX: [phone]
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June 17 2003
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Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, Id 83702-5983
Re:Comments of Jeffrey C. Brooks
Case No. INT-03-
Dear Ms. Jewell:
In response to the Comments of Jeffrey C. Brooks filed as part of the above referenced Case
Intermountain Gas Company submits the following remarks.
Mr. Brooks, throughout his remarks, has supplanted his understanding of issues with conjecture and
assertions that attempt to leave in the readers mind an inaccurate account that Intermountain Gas
Company is engaging in questionable activities. Regrettably, had Mr. Brooks either attended one of
the several workshops sponsored by the IPUC in regards to this Case or submitted Data Requests to
the Company, his misinformation could have been directly addressed and resolved.
Mr. Brooks' assertion that Intermountain Gas Company is somehow profiting by a rise in retail natural
gas prices is in direct contradiction with not only the Company s practices, accounting or otherwise
but also the documented findings of the regular audits performed by the Staff of the Idaho Public
Utilities Commission. By way of example , the Company, again as audited by the Commission Staff
ensures that any benefits derived from the use of stored natural gas at any of Intermountain Gas
Company s storage facilities , the Nampa LNG facility or otherwise, are returned dollar-for-dollar to
Intermountain Gas Company s customers.
Intermountain Gas Company promotes through several avenues the wise and efficient use of natural
gas. These avenues have been addressed fully and exhaustively in the Company Integrated
Resource Plan currently on file with this Commission.Mr. Brooks, using a string of "doesn
necessaril(ies)", "in realit(ies)", "might help(s)", and "may or may not(s)", uses unsubstantiated
conclusions and assertions aimed at bringing into question not only the Company s approved
conservation practices but also choices made by homeowners.
Mr. Brooks purports that Intermountain Gas Company enables and facilitates unethical building
practices that "exacerbate the demand for natural gas" in its service territory and that these alleged
practices "constitute negligence on the part of IGC to properly conduct its business in" a responsible
manner. Such accusations could not be further from the truth. A close reading of Mr. Brooks' remarks
in this area reveal that his assertions about the Company rely on speculation and a weak association
of an unrelated chain of assumed events.
Comments of Jeffrey Brooks
Page 2
June 17, 2003
Using the guise of a purported understanding of the Company s "rate structure vs. profit margin" Mr.
Brooks again professes that increased gas costs translate into increased profit margins for the
Company. Mr. Brooks' attempts to lead the reader through an example whereby a doubling of the
Company s Weighted Average Cost of Gas, or "WACOG", allegedly translates into a doubling of the
Company s profit margin. Again, the documented and audited accounting practices of the Company
ensure our adherence to a mandate whereby the Company profit margin is not impacted by a
change in the Company s WACOG.
Intermountain Gas Company believes that the Comments provided by Mr. Brooks provide little or no
value to our customers and in fact provide misleading, if not slanderous, information to any readers of
its material.
Intermountain Gas Company respectfully requests that this Commission consider the above
comments in its final ruling in the above referenced Case.
Sincerely,
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Market Services and Regulatory Affairs
FILE No,989 06/17 '03 16:14 ID:MOFFATT THOMAS FAX:[phone] PAGE
t Michael McGrath, have served upon Jeffrey C. Brooks a copy of Intennountain Gas
Company s Reply Comments in Case No. INT -O3-0 1.
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