20070918Comments.pdf

DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
FLECE 1\/ D
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!DA!e!O PUEUC
UTiliTiES CO!\1i\t1ISSIC;,
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO CHANGE ITS PRICES (2007
PURCHASED GAS COST ADJUSTMENT)
CASE NO. INT -07-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through it Attorney of
Record, Donovan E. Walker, Deputy Attorney General, in response to the Notice of Application
and Notice of Modified Procedure issued on August 22 2007, Order No. 30413, submits the
following comments.
BACKGROUND
On August 16, 2007, Intermountain Gas Company filed its annual Purchased Gas Cost
Adjustment (PGA) Application with the Commission requesting authority to place new rate
schedules in effect as of October 1 , 2007, that will decrease its annualized revenues by $25.4
million (7.7%). Application at 2. The PGA mechanism is used to adjust rates to reflect changes
in costs for the purchase of natural gas from suppliers, including transportation, storage, and
STAFF COMMENTS SEPTEMBER 18 , 2007
otherrelated costs of acquiring natural gas. See Order No. 26019. Intermountain s earnings will
not be decreased as a result of the proposed changes in prices and revenues. Application at 2.
Intermountain Gas seeks to pass through to each of its customer classes a change in gas
related costs resulting from: (1) a decrease in costs billed to Intermountain pursuant to the
settlement of the general rate case filed by Northwest Pipeline Corporation (NPC); (2) the
annualized impact of the general rate case filed by Gas Transmission Northwest Corporation
(GTN); (3) changes in Intermountain s firm transportation and storage costs resulting from its
management of storage and firm capacity rights on pipeline systems including NPC and GTN;
(4) a decrease in Intermountain s Weighted Average Cost of Gas (W ACOG); (5) an updated
customer allocation of gas related costs pursuant to the Company s PGA provisions; (6) the
collection of unaccounted for gas on Intermountain s distribution system; and (7) the inclusion of
temporary surcharges and credits for one year relating to gas and interstate transportation costs
from the Company s deferred gas cost accounts. Application at 3-
According to the Company s customer notice, if its Application is approved as filed
residential customers using natural gas for space heating and water heating could experience a
$6.00 decrease (8.1 %) on an average monthly bill. Those residential customers using natural gas
for space heating only could experience a $4.00 decrease (7.5%) on an average monthly bill.
Commercial business customers could realize an average monthly bill decrease of$29.
(8.7%). Industrial customers who use only Intermountain s delivery service, but do not purchase
their natural gas from the Company, could experience an average increase of9.5% or $0.004 per
therm delivered.
Intermountain Gas proposes to decrease the W ACOG from the currently approved
$0.68500 per therm to $0.63583 per thermo Application at 6. The Company states that the
proposed W ACOG includes the benefits to Intermountain s customers generated by the
Company s management of significant natural gas storage assets whereby gas is procured during
the traditionally lower priced summer season for withdrawal and use during the winter when
prices would otherwise be substantially higher. Application at 7. The Company states that
although current commodity futures prices dictate the use of a $0.63583 W ACOG, it continues to
remain vigilant in monitoring natural gas prices and is committed to come before the
Commission prior to this winter s heating season to amend these proposed prices, if the forward
prices materially deviate from the $0.63583 per thermo Application at 7.
STAFF COMMENTS SEPTEMBER 18, 2007
Intermountain Gas proposes to incorporate the benefits of lower prices resulting from a
settlement filed in the 2006 NPC general rate case. In last year s PGA, Case No. INT-06-
Intermountain s prices were weighted to reflect the inclusion of nine months ofNPC's proposed
increased transportation costs, subject to refund pursuant to FERC's order on the then pending
rate case. The subsequent settlement reached in NPC' s rate case was approved by FERC with an
effective date of April 1 , 2007. Intermountain Gas proposes to incorporate the benefits of these
lower prices to include the annualization, or 12- month application, of the rate reduction when
compared with NPC's initial case. Application at 5. The outcome ofGTN's general rate case
proceeding is still pending before FERC, and Intermountain Gas proposes to incorporate the
annualization, or 12-month application of GTN's filed case. Additionally, Intermountain reports
that its capacity costs have increased on several Canadian pipelines due to rate increases, expired
temporary credits, and the tightening exchange rate between U.S. and Canadian currencies.
Application at 5-
The Company states that it incurred costs to procure additional upstream capacity in
order to more closely align deliveries from those upstream pipelines with Intermountain s take-
away rights on NPC at its Stanfield interconnect with GTN. Application at 6. These costs have
been included at Exhibit 4, Row 5. The Company includes costs to procure additional
incremental liquid storage at NPC's Plymouth LNG facility to enhance its overall storage
portfolio. Application at 6. These costs are included at Exhibit 4, Row 13-18. The Company
also states that it is party to certain agreements whereby it manages its storage related assets in
conjunction with a third-party asset manager. Intermountain Gas proposes to pass back to its
customers the benefits generated from these agreements as shown on Exhibit 4, Line 19.
Application at 6.
The Company proposes to include various surcharges, credits, and adjustments in its
proposed prices. Application at 7-8. Intermountain has included the elimination of temporary
surcharges and credits pursuant to last year s PGA, Case No. INT-06-04. Application at 8
Exhibit 4, L. 29. The Company includes a fixed-cost collection adjustment pursuant to the
provisions of its PGA tariff, which provides that proposed prices will be adjusted for updated
customer class sales volumes and purchased gas cost allocations. Application at 8, Exhibit 5 , L.
24. The Company proposes to pass back to customers the benefits generated from its capacity
release agreements through the inclusion of a $3.4 million credit. Application at 8, Exhibit 7.
Further, the Company proposes to allocate deferred gas costs from its Account No. 186 balance
STAFF COMMENTS SEPTEMBER 18, 2007
to customers through temporary price adjustments effective during the 12-month period ending
September 30, 2008 as follows: (1) fixed gas cost credit of $3.9 million attributable to collection
of interstate pipeline capacity costs, the true-up of expense issues previously ruled on by the
Commission, refunds attributable to the settlement ofNPC's general rate case, and mitigating
capacity release credits from Intermountain s upstream capacity; and (2) deferred gas cost credit
of$1.5 million attributable to variable gas costs since October 1 , 2007. Application at 8-
Intermountain proposes to pass back the balances via the per-therm credit. Application at 9
Exhibit 9, L. 4, Column (b), Exhibit 6, L. 3.
The Company states that a straight cents-per-therm price decrease was not utilized for the
l tariff. Application at 9. Absent Williams' firm transportation TF-l commodity charge
increase and the unaccounted for gas recovery as included on Exhibit 9, the proposed increase in
the T -1 tariff is fixed-cost related, and since there are no fixed costs recovered in the tail block of
the T -1 tariff, a cents-per-therm increase related to fixed costs was made only to the first two
blocks of the T-l tariff. Application at 9-10. Likewise, because the proposed d~crease to the T-
tariff demand charge is fixed-cost related, a cents-per-therm decrease was made to the T-
demand charge for these fixed costs. Application at 10. Additionally, the proposed increase
the T-2 commodity charge incorporates the increase in the Williams' firm transportation TF-
commodity charge pursuant to NPC's current tariffs as well as the collection of unaccounted for
gas as included on Exhibit 9. Id.
STAFF ANALYSIS
Staff has calculated the impact of the Company s proposal on its customer classes as
follows:
STAFF COMMENTS SEPTEMBER 18 , 2007
Proposed
Proposed Average Proposed Proposed
Change in Change in Average %Average Price
Customer Class Class Revenue $/Therm Change $/Therm
RS-1 Residential 028 343 09084 7.45%12846
RS-2 Residential 137 918 08913 10%01072
GS-1 General Service 8,794 625 09057 66%95480
L V-1 Large Volume 216 892 08685 10.22%76284
T -1 Transportation 453 590 01811 18.16%11786
T -2 Transportation (Demand)183 01087 10%97694
2 Transportation (Commodity)070 00357 73.46%00841
T -3 Transportation 121 346 00191 10.74%01969
T -4 Transportation 190 157 00191 4.44%04498
354 798 05092 74%60660
The overall effect of the proposed changes in the Company s Application would decrease the
revenue received by Intermountain Gas Company by $25 354 798. The net decrease is
comprised of the following items:
Deferrals:
Removal of INT -06-04 Temporaries
INT -07 -03 Temporaries
Total Deferrals
Lost and Unaccounted for Gas
Re-allocation of Fixed Costs
Changes in Weighted Average Cost of Gas
Fixed Cost Changes:
Northwest Pipeline
Upstream Price Changes
New Upstream Capacity Costs
New LS Storage Costs
AECO & Clay Basin Cost Changes
Total Fixed Cost Changes
$ (7 523 989)
(8,798,839)
$ (16 322 828)
599 779
071 141)
(14 137 174)
(961 347)
1,425 811
694 948
723 097
(305,943)
4.576.566
Total Annual Price Change $ (25.354.798)
STAFF COMMENTS SEPTEMBER 18 2007
Staff has reviewed the Company s Application and gas purchases to verify that the
Company s earnings will not change as a result of the filing, that the deferred costs are prudent
and to determine the reasonableness of the W ACOG request. Intermountain Gas has included
the elimination of the temporary credits in the amount of$7 523 989, pursuant to last year
PGA, Case No. INT -06-04. The temporary credits proposed for the current PGA case equal
798 839 which consist of market segmentation and capacity release revenues, interest, and the
per therm amortization of deferrals and over collections from last year s PGA, including $1.4
million credit in variable costs from truing up last year s W ACOG to actual commodity costs
throughout the year. The Company includes a fixed-cost collection adjustment that credits
071 141 back to customers pursuant to the provisions of its PGA tariff, which provides that
proposed prices will be adjusted for updated customer class sales volumes and purchased gas
cost allocations. During the course of the review, Staffmade additional findings that are
discussed in more detail below.
Weighted Average Cost of Gas (W ACOG)
In the current Application, Intermountain Gas is proposing a W ACOG of $0.63583 per
therm, which is a decrease of approximately 7.18% from the $0.68500 W ACOG currently
included in the Company s rates. The current W ACOG was approved last year by Order No.
30137 and has been in effect since October 1 , 2006. Though the request would be the second
decrease in as many years, the chart below illustrates the increases in the natural gas market over
the past ten years and the volatility experienced over the same time:
Percentage
Year W ACOG Increase/(Decrease)
From Prior Year
1998 $0.15684 n/a
1999 $0.18252 16.37%
2000 $0.42296 131.73%
2001 $0.35295 16.55%
2002 $0.32000 34%
2003 $0.47500 48.44%
2004 $0.55492 16.83%
2005 $0.73219 31.95%
2006 $0.68500 6.45%
2007 $0.63583 18%
STAFF COMMENTS SEPTEMBER 18, 2007
Last year s W ACOG of $0.68500 per therm was based on forward gas prices for the
Company s supply sources as of the date of the Company s 2006 amended PGA filing. While
actual gas prices varied greatly throughout the year, the W ACOG estimates were fairly reflective
of prices that Intermountain Gas paid for gas throughout the year. The result was a nominal
over-collection of the Company s variable costs, which will be returned to customers through
credits over the next twelve months.
The Company s proposed W ACOG of $0.63583 per therm is slightly less than that which
could be justified when applying the forward prices available as of June 30, 2006 to the
purchases that are yet to be made. The Company has taken the aggressive stance that they can
deliver the natural gas yet to be purchased for a lower price than the forward prices indicate.
Given that all natural gas needed for Intermountain s storage has already been purchased at
favorable prices, that the resulting affect of the Company s aggressive forward purchasing plan
on the W ACOG is small and that any difference will be deferred and collected in customer rates
next year, Staff believes that the deviation from use of the NYMEX pricing is acceptable in this
case.
Staffhas also reviewed the established W ACOG of other northwest gas utilities, and the
proposed W ACOG for Intermountain Gas is considerably less than other utilities in the region.
Much of the disparity can be attributed to Intermountain s reliance on a significant portion of its
gas supplies coming from the Rockies. Production in the Rockies has increased significantly in
recent years, far outpacing the ability to transport the additional gas to markets in the east. As
additional pipelines are built to transport Rockies ' gas to the eastern metropolitan markets , the
price of gas coming out of the Rockies will likely increase to the price levels in effect at other
sources.
Intermountain is also able to support a lower W ACOG because of the significant amount
of storage rights it possesses. Intermountain has over 120 million therms injected into storage
not including an additional 17 million therms ofliquefied natural gas, 11 million of which were
added during the year at an additional cost of$1.7 million. The gas is injected into storage
during the summer months when prices are lower, and withdrawn during the winter months
providing customers with substantial savings. Intermountain s storage capacity is approximately
55% of its November through March winter load, making it less dependent on spot market
purchases during the volatile winter months and thus decreasing its W ACOG in the process.
STAFF COMMENTS SEPTEMBER 18, 2007
Pipeline Transportation Rate Cases
On June 30, 2006, Northwest Pipeline Corporation (NPC) filed a general rate case with
the Federal Energy Regulatory Commission (FERC). The FERC suspended the effective date of
NPC's proposed rates until January 1 2007, subject to refund and the outcome of the final FERC
Order in the case. The transportation costs approved in last year s PGA filing, Case No. INT-
06-, were weighted to reflect the increase effective on January 1 , 2007. Subsequent to
Commission Order No. 30137 establishing rates for Intermountain Gas customers, NPC and
other interested parties filed a settlement to resolve all outstanding issues in the NPC general rate
case, resulting in a rate reduction as compared to NPC's original filing. On March 30 2007, the
FERC issued an Order approving the settlement effective April 1 , 2007. In the current filing,
Intermountain proposes to pass the benefits from the NPC transportation rate reduction and
refunds back to customers and incorporate the benefits of these lower rates by including the
annualized level of transportation costs from Northwest Pipeline Corporation. The benefits
received by customers from the settlement are approximately $970 000.
On the same day that Northwest Pipeline Corporation filed its general rate case with the
FERC, Gas Transmission Northwest (GTN) also applied for a transportation rate increase. The
FERC also suspended the effective date ofthe GTN increase, subject to refund and the outcome
of a hearing. Consistent with its treatment of NPC rates, Intermountain used a weighting
methodology that would reflect the GTN rate increase as being in effect for only nine months of
the PGA year. The outcome of the GTN General Rate Case proceeding is still pending before
the FERC. Intermountain is proposing with this Application to incorporate the annualization, or
12-month application, ofGTN's filed case, which increases Intermountain s annual revenue by
425 811. Staff believes the Company s treatment of the pending GTN transportation rate
increase is consistent and reasonable given the uncertainty of the timing and amount of increase
to be granted by FERC Order. However, in the likely event that the FERC approves an increase
less than that proposed by GTN, Staff believes any and all refunds should be credited back to
Intermountain s customers.
TransCanada s British Columbia, also known as Foothills Pipeline System (Foothills)
and its Alberta system, also known as Nova Gas Transmission (Nova) both implemented price
increases during 2007. The Foothills increase relates to the assignment of its former Alberta
Natural Gas assets to its parallel Foothills system while the Nova increase largely relates to the
expiration of temporary credits passed back to customers during 2006. Intermountain acquired
STAFF COMMENTS SEPTEMBER 18 2007
additional capacity on these Canadian pipelines after an annual adequacy review of its interstate
transportation and storage services dictated a need to procure additional upstream capacity in
order to more closely align deliveries from those upstream pipelines with Intermountain s take-
away rights on Northwest Pipeline at its Stanfield interconnect with GTN. The additional
upstream capacity costs add $2 694 948 to the Company s revenue during the PGA year.
Staff recommends that, in the event that the FERC approve a rate increase for GTN that
is significantly lower than that proposed in the Intermountain tariffs, the Commission reserve the
right to reopen this case and reevaluate the approved tariffs that result from this proceeding.
Recovery of Lost and Unaccounted For Gas
Intermountain Gas requests the recovery of its estimated lost and unaccounted for gas for
the 2007-2008 PGA year through a per therm surcharge, netting the Company an additional $1.6
million. Lost and unaccounted for gas is simply the difference between the physical inputs and
the physical outputs of the system. The Company s base rates established in 1985 allowed the
Company to recover a normalized level for lost and unaccounted for gas. However, the
commodity costs have increased significantly since that time, and Intermountain believes that the
level of recovery is no longer sufficient to cover the actual levels of lost and unaccounted for gas
on today s system.
The causes for unaccounted for gas can be grouped into two main categories; leaks and
measurement. Leaks are defined as gas escaping from the system at a given rate at an unknown
location. The rate of gas loss is dependent on the pressure and the size of the hole. Normally,
gas leakage will occur at a fairly constant rate and then gradually increase with time if not
located and repaired. Gas measurement is defined as the accounting of all gas bought and sold
and is often times a significant source of unaccounted for gas.
Gas measurement can be effected by several factors, such as ambient temperature
pressure, theft, inaccurate or faulty meters and human error while reading or maintaining meters
among many other things. As a general rule, for every 5 degrees above or below the temperature
at which the gas was purchased, the volume will change by approximately 1 percent. Gas is
generally purchased at 4-oz. pressure, and with every 2-oz. change in pressure, there is also an
expected loss of 1 percent. Untimely detection and repair of faulty meters and the element of
human error will also cause upward pressure on the amount of unaccounted for gas. Though
Staff believes that the Company is entitled to recovery of some level of unaccounted for gas
ST AFF COMMENTS SEPTEMBER 18 , 2007
Staff is hesitant to recommend the recovery in the PGA, when many factors affecting the level of
unaccounted for gas are within the Company s control. It should be noted that Intermountain
rate oflost and unaccounted for gas is 0.7 percent of throughput. The industry average is
approximately 2 percent, which would indicate that Intermountain is adequately monitoring and
maintaining its system to minimize the amount of lost and unaccounted for gas.
The normalized level of revenue collected by Intermountain in its current base rates for
unaccounted for gas is $445 905. As stated, this amount was established in 1985. Adjusted for
growth, the normalized level is $934 721 , as illustrated on Workpaper No.8 included with the
Company s Application. Intermountain is requesting to recover the estimated amount oflost and
unaccounted for gas over today s normalized level adjusted for growth, an additional $1.6
million. If the Company decreases its level of unaccounted for gas during the coming PGA year
the Company will credit the difference back to customers in next year s PGA filing.
Staff recommends that the Commission allow the Company to recover the additional
amounts for lost and unaccounted for gas in the PGA, as is common with other gas utilities in the
northwest and across the nation. However, approval of the proposal should not guarantee the
Company recovery of all lost and unaccounted for gas regardless of circumstances. If the system
were to experience a catastrophic failure, Staff would expect the Company to file for an
accounting order authorizing it to defer the costs of the repair and lost gas, with recovery to be
determined at a later date. Staff also does not believe it to be appropriate for unaccounted for gas
or losses due to faulty meters and meter reading errors to be included in PGA rates. Staff will
again review the actual levels of unaccounted for gas during next year s PGA audit to determine
the appropriateness of the recovery. .
Risk Management and Gas Purchasing
The objectives ofIntermountain Gas Company s Gas Supply Risk Management Program
are to (a) help ensure adequate gas supplies, transportation and storage are available for its
customers; (b) mitigate the adverse impact that significant price movements in the natural gas
commodity can have on the Company s supplies, customers and other operations; and (c)
minimize the credit risk inherent in the implementation of certain price risk reducing strategies.
The Company and Staff continue to evaluate the risk management guidelines within the "Gas
Supply Risk Management Program" to manage the risk and price volatility to customers. The
Company s documentation of its market evaluations and market fundamentals continues to
STAFF COMMENTS SEPTEMBER 18, 2007
Improve. The market expertise and experience of the Company and its purchasing agent are
extensive and they will provide the background to evaluate the current guidelines and expand the
Gas Supply Risk Management Program as the Company and Staff continue to evaluate this topic.
The Company s contracts for physical gas supplies are typically based on the first-of-
month index price. As part of the short-term hedging strategy, the Company has the opportunity
to convert the first-of-month price to daily pricing. This decision is based on the market
fundamentals reviewed by the Gas Management Committee when the daily pricing is expected to
decrease during the month. Additional financial hedge opportunities are also evaluated with the
same process.
As indicated by the Company s Risk Management Program, Intermountain Gas does not
acquire financial hedges to obtain the lowest possible price, but rather to mitigate the volatility in
the natural gas markets by hedging in comparison to the W ACOG. During the 2006-2007 PGA
year, the Company executed numerous financial hedges by locking in specific prices for gas.
Though spot prices actually dropped below the hedge prices, the Company s hedging practices
were successful as they were able to beat the W ACOG and return nearly $1.5 million to
customers in the coming year.
Intermountain Gas also physically hedges the price of gas with its abundance of storage
capacity, as previously mentioned. Currently the storage is at maximum capacity with injections
already completed this summer to serve the coming winter load. Intermountain locked in the
price of the gas injected into storage, and had to make cash settlements in the amount of$5.
million on those hedges, but that number is misleading as the benefit from those hedges .will not
be seen until the gas is actually withdrawn. The average price of the gas in storage is $0.4965
per therm as compared to the requested W ACOG of $0.63583 per thermo As gas is withdrawn
from storage, customers will recognize the benefits of the hedge in next years PGA filing.
In addition to the storage hedge to provide supply and price stability for the 2007-2008
PGA year, the Company also hedges winter flowing gas requirements based on normal winter
weather projections. This strategy will lock the price of90% of the expected winter needs with
multiple financial gas contracts from the three supply basins of Sumas, Rockies and AECO.
STAFF COMMENTS SEPTEMBER 18, 2007
CONSUMER ISSUES
Customer Notice and Press Release
The Customer Notice and Press Release were included in Intermountain s Application.
The Application was received on August 16 2007. Staff reviewed the customer notice and press
release and determined they were in compliance with the requirements of IDAP A 31.21.02.102.
The customer notice was mailed with cyclical billings beginning August 17, 2007 and ending
September 14 2007.
Customer Comments
Customers were given until September 18 , 2007 to file comments. As of September 17
no comments had been received.
Financial Assistance for Paying Heating Bills
If approved, residential customers will see an approximate 8% decrease in their natural
gas rates. However, energy costs continue to challenge some customers. Because some
customers still struggle to pay their gas bills, Staff would like to remind qualified customers to
take advantage of the energy assistance available through the federally-funded Low Income
Home Energy Assistance Program (LIHEAP) and non-profit fuel funds such as Project Share in
southwestern Idaho and Project Warmth and Helping Hand in southeastern Idaho. For more
information on these programs, customers may call the nearest Community Action Agency,
Intermountain Gas Company, the Idaho Public Utilities Commission, or the 2-1 Idaho Care
Line.
RECOMMENDATION
After a complete examination of the Company s Application and gas procurements for
the year, Staff recommends the following:
That the Commission accepts the Company s Application and filed tariffs
reducing the Company s annual revenue by $25 354 798.
That the Commission reserve the right to reopen this case and reevaluate any
approved tariffs as a result of pipeline transportation increases being significantly
less than what the Company included in the Application.
STAFF COMMENTS SEPTEMBER 18, 2007
That the Commission reserve the right to reopen this case and reevaluate any
approved tariffs if the W ACOG materially changes below that included in the
Application.
Respectfully submitted this 1$ it. day of September 2007.
onovan E. Walker
Deputy Attorney General
Technical Staff: Donn English
Marilyn Parker
i :umisc:comments/intgO7 .3dwdemp
STAFF COMMENTS SEPTEMBER 18, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF SEPTEMBER 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. INT-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
PAULRPOWELL
EXECUTIVE VICE PRESIDENT & CHIEF
FINANCIAL OFFICER
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE ID 83707
MAIL: customerinput~intgas.com
STEPHEN R THOMAS
MOFFATT, THOMAS, BARRETT
ROCK & FIELDS, CHARTERED
PO BOX 829
BOISE ID 83701
SECRETAR
CERTIFICATE OF SERVICE