20161216Erdwurm Direct with Exhibits 112-117.pdf

Rt:CE 'ED
BEFORE THE
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IDAHO PUBLIC UTILITIES COMMiSS.IO.~•f 1 '..· :;'J~;s:oN
IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION TO
CHANGE ITS RATES AND CHARGES
FOR NATURAL GAS SERVICE.
)
) CASE NO. INT-G-16-02
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___________ )
DIRECT TESTIMONY OF BENTLEY ERDWURM
IDAHO PUBLIC UTILITIES COMMISSION
DECEMBER 16, 2016
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Q. Please state your name and business address for
the record.
A. My name is Bentley Erdwurm. My business
address is 472 West Washington Street, Boise, Idaho.
Q.
A.
By whom are you employed and in what capacity?
I am employed by the Idaho Public Utilities
Commission as a Utilities Analyst.
Q. What is your educational and professional
background?
A. I received a B.A. in Economics from the
University of Dallas in 1978, and an M.S. in Economics
from Texas A&M University in 1980. I have worked for the
Idaho Public Utilities Commission since November 2015 as
a Utilities Analyst. I have over thirty years of utility
industry experience, focused on cost allocation, rate
design, revenue and load forecasting, the regulatory
treatment of acquisitions, and financial and statistical
analysis. I have testified as an expert witness both for
regulatory agencies (Texas Public Utility Commission and
as a consultant to the Arizona Corporation Commission),
and utilities (California American Water,, Alabama Gas
Corporation, and UNS Energy Corporation subsidiaries
Tucson Electric Power Company, UNS Electric and UNS Gas)
Q.
A.
What is the purpose of your testimony?
My testimony addresses rate design issues
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including: (1) residential and general service customer
charges; (2) combining the two current residential rate
schedules (Schedule RS-1 and Schedule RS-2) into a single
rate schedule; (3) introducing a fourth rate tier into
the general service rate; and (4) rate design for the
large volume and transportation classes.
Q.
A.
Please summarize your testimony.
I am recommending that:
1. the residential customer charge be increased to
$5.50 per month, an average monthly increase of
$1.67 per month (43% increase);
2. the residential usage charges (excluding gas
costs) for current Residential: (a) RS-1
customers be decreased by 47% for April through
November, and decreased by 18% from December
through March; and (b) RS-2 customers be
decreased by 15% from April through November,
and slightly increased by 3% from December
through March;
3. the general service customer charge be
increased to $9.50 per month, an average
monthly increase of $5.00 per month (111%
increase);
4. the general service usage charges be decreased
by 18%, 21% and 24% in usage tiers 1, 2 and 3,
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Q.
respectively;
5. residential rate schedules RS-1 and RS-2 be
combined into a single residential rate
schedule;
6. the Company's proposal to introduce a fourth
rate tier into the general service rate be
approved; and
7. the Company's proposal to introduce a charge
for Maximum Daily Firm Quantity (MDFQ) be
approved, but at a lower charge of $0.20 per
therm rather than the Company's proposed $0.30.
Are there areas where you disagree with the
Company's position?
A. Other than adjustments to conform to Staff's
revenue requirement, and the level of customer charges
and MDFQ charges, my only disagreement involves the
Company's proposal to include a portion of mains in the
customer-related cost calculation. I exclude mains from
that calculation. However, including or excluding mains
has no effect on my customer charge recommendations,
because of customer impact considerations.
RESIDENTIAL AND GENERAL SERVICE CUSTOMER CHARGES
Q. You mentioned you would discuss the Company's
customer charges for residential and general service.
Please explain what a "customer charge" is.
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A. In general, a "customer charge" is a fixed
amount that a customer must pay each month without regard
to how much gas the customer uses.
Q. Please state the Company's current residential
and general service customer charges.
A. The residential customer charge is $2.50 per
month for the billing months of April through November (8
months of the year) and $6.50 per month for the billing
months of December through April (4 months of the year).
The current weighted average residential customer charge
is $3.83.
The general service customer charge is $2.00
per month for the billing months of April through
November (8 months of the year) and $9.50 per month for
the billing months of December through April (4 months of
the year). The current weighted average general service
customer charge is $4.50.
Q. What are the Company's proposed residential and
general service customer charges?
A. The Company's proposed residential customer
charge is $10.00 per month (161% increase) for all months
of the year. The Company's proposed general service
customer charge is $35.00 per month (678% increase) for
all months of the year. The Company has recommended
eliminating the seasonal differential.
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Q. What customer charges are you recommending for
the residential and general service classes?
A. As stated above, I recommend a residential
customer charge of $5 .50 and a general service customer
charge of $9.50. Staff's recommendation eliminates the
seasonal variation in customer charges, as proposed b y
the Company .
Q. Given that you are proposing customer charge
increases, are you proposing offsetting usage charge
decreases?
A. Yes. Given a revenue objective, and two rate
components - a customer charge and a usage charge -to
recover revenue, an increase in customer charge will
necessitate a net decrease in the usage charge . Staff
proposes a $1.67 increase (a 43% increase) in the average
residential customer charge of $3.83. To balance this
increase, Staff proposes Residential usage charges
(excluding gas cost) of $0.16679 per therm that would
apply over the entire year. As explained below, Staff
proposes to eliminate current seasonal differentials and
favors combining the current Residential RS-1 and RS-2
into a single rate schedule. For current RS-1 customers,
Staff's proposed usage charge represents a decrease of
$0.14999 per therm (47% decrease) for November through
April usage, and a decrease of $0.03743 per therm (18%
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decrease) for December through March usage. For current
RS-2 customers, Staff's proposed usage charge represents
a decrease of $0.02921 per therm (15% decrease) for
November through April usage, and a small increase of
$0.00442 per therm (3% increase) for December through
March usage.
The general service Staff-proposed customer
charge increase of $5.00 is offset by usage charge
decreases of $0.03920 (18% decrease), $0.04023 (21%
decrease), and $0.04119 (24% decrease) for usage tiers 1,
2 and 3 respectively.
Q. Why do you support eliminating the seasonal
differentiation in customer charges?
A. Having the same customer charge throughout the
year is consistent with how the Company incurs customer-
related costs over the year. Costs most closely tied to
specific customers are the capital costs and expenses of
metering, meter reading, billing, the service line, and
customer service. Monthly customer-related operation and
maintenance expenses are driven by the number of
customers, but not by variations in usage over the year.
The capital cost of customer-related plant items and the
associated depreciation expense is constant over the
year, much like a fixed-rate mortgage payment. Minor
monthly variations in customer-related capital costs are
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unrelated to monthly usage. A level customer charge
helps match revenue with the incursion of costs.
Q. Please explain how customer charges should be
determined for utilities in general.
A. Several factors should be considered in the
determination of customer charges. The weighting of the
factors depends on the specific circumstances of the
utility, the communities served, and the regulatory
jurisdiction. For Idaho and other jurisdictions where
rates are based on historical test years (as opposed to
forward looking or future test years), factors include:
1. the level of customer-related cost;
2. the bill impact in moving from current to
proposed rates;
3. the total bill for "basic needs";
4. marginal cost pricing and price signals that
promote conservation and the efficient use of
resources; and
5. the customer charges of other utilities.
CUSTOMER-RELATED COSTS
Q. Please explain how average embedded cost is
used to help determine the customer charge.
A. The overall revenue requirement calculation is
based on historical, average embedded costs subject to
known and measurable adjustments; therefore, it generally
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is important to have a cost-of-service study based on
these costs when determining customer charges. Cost
allocation for Intermountain Gas is more fully addressed
in the testimony of Staff witness Mike Morrison. Dr.
Morrison has recommended that the Company's proposed
cost-of-service study be rejected because the Company did
not provide load data necessary to calculate accurate
factors to allocate costs among the classes. Customer-
related unit costs based on historical average embedded
costs (i.e., customer-related costs per customer in a
specific class) cannot be accurately calculated without a
cost-of-service study.
Q. Did you attempt to calculate a residential
customer charge based on average embedded costs with the
data provided by the Company?
A. Yes, I estimated a cost-based residential
customer charge to be $8.57 per month. The calculation
is included as Exhibit 112 to my testimony. However, I
did not recommend a residential customer charge based
exclusively on average embedded cost because, as
mentioned above, Staff has proposed to reject the cost-
of-service study. Furthermore, Staff considered several
other factors when developing its proposed customer
charges.
Q. Did you exclude all portions of mains from your
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customer-related cost calculation?
A. Yes. A given main serves multiple customers,
possibly from different rate classes. My customer
components such as meters and services are associated
with specific customers, at their premises. I have
restricted the customer-related classification to items
that serve specific customers rather than multiple
customers. The classification of costs as "Customer" is
further described in Dr. Morrison's testimony.
BILL IMPACTS
Q. Please discuss how bill impact considerations
affect your customer charge recommendations.
A. Substantial changes in rate design may in some
cases impose unexpected hardships on some customers.
this reason, Staff considers how rate changes affect
customers over a wide range of usage levels. Customer
charge increases have the largest impact in percentage
terms on lower-use customers. Conversely, customer
For
charge increases have the smallest impact in percentage
terms on high-use customers. Staff believes that
implementing the Company-proposed $10.00 residential
customer charge (161% increase) and $35.00 general
service customer charge (678% increase) would excessively
impact some customers.
As discussed below, Staff is recommending
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approval of the Company's proposal to combine the
Residential RS-1 and RS-2 residential rate schedules.
Separate bill comparison tables are presented for RS-1
and RS-2 that quantify the effect of moving from the
current residential rate schedules to Staff's proposed
combined residential rate schedule. The residential bill
comparison tables for RS-1 are presented in Exhibit 113,
and tables for RS-2 are presented as Exhibit 114.
Current rates are differentiated by season; therefore,
the tables show results for April through November and
for December through March. Also, separate bill
comparisons are presented excluding the cost of gas and
including the cost of gas. This proceeding focuses on
distribution and storage costs and not on the cost of
gas. The cost of gas is specified in a separate tariff,
which is an adjustment mechanism that generally recovers
changes in commodity costs on an annual basis.
For an RS-1 customer during April through
November, moving from current rates to Staff-proposed
rates decreases monthly bills by $2.25 (-17% excluding
gas costs and -7% including gas costs) for a typical low
use residential customer using 35 therms per month, and
by $6.00 (-28% excluding gas costs and -11% including gas
costs) for an average residential customer using 60
therms per month.
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For an RS-1 customer during December through
March, moving from current rates to Staff proposed rates
decreases monthly bills by $2.31 (-17% excluding gas
costs, and -7% including gas costs) for a typical low-use
residential customer using 35 therms per month, and by
$3.25 (-17% excluding gas costs and -6% including gas
costs) for an average residential customer using 60
therms per month.
For an RS-2 customer during April through
November, moving from current rates to Staff-proposed
rates increases monthly bills by $1 .98 (21% excluding gas
costs and 7% including gas costs) for a typical low use
residential customer using 35 therms per month, and by
$1.25 (9% excluding gas costs and 3% including gas costs)
for an average residential customer using 60 therms per
month.
For an RS-2 customer during December through
March, moving from current rates to Staff proposed rates
decreases monthly bills by $0.85 (-7% excluding gas
costs, and -3% including gas costs) for a typical low-use
residential customer using 35 therms per month, and by
$0.73 (-5% excluding gas costs and -2% including gas
costs)for an average residential customer using 60 therms
per month.
A general service bill comparison table is
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presented in Exhibit 115. The Staff-proposed general
service rate includes a fourth rate tier, as proposed by
the Company and adjusted for the Staff revenue
requirement.
Q. Please discuss the proposed fourth general
service rate tier.
A. The Company proposes that a fourth rate tier be
added to the general service schedule . Staff recommends
approval of this proposal. The general service schedule
currently has a declining block design, whereby the usage
rate declines as usage increases. Staff has confirmed
that on a v erage the Company's larger general service
customers are less costly to serve on a per therm basis;
therefore, Staff favors retaining the declining block
design for general service. The proposed fourth block
would apply to usage in excess of 10,000 therms per
month. During the test year, monthly usage did not fall
in the over 10,000 therms range. Therefore, introducing
the fourth block will benefit any prospective customer
that uses over 10,000 therms, but does not affect the
rate calculations applicable to customers with lower
usage. Additionally, introducing a fourth general
service rate block allows for a smoother transition for
customers switching from the general service to the large
volume class, or in the opposite direction.
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Q. Do you have concerns about increasing the
general service customer charge beyond $9.50?
A. Yes. The general service class is diverse,
with customers ranging in size from the "mom and pop"
stores to larger retail, office and manufacturing
operations. The Company should study whether the general
service class should be divided into two or more classes.
If such division is appropriate the Company should
propose different customer charges for each of the new
classes. This would avoid having the smallest general
service customers subsidizing the largest general service
customers. In this proceeding, Staff seeks to avoid
recommending a "one-size fits-all" general service
customer charge in excess of $9.50 that may overstate the
customer-related costs of the smallest general service
customers.
Dr. Morrison has proposed that, after this
proceeding ends, a cost-of-service workshop be held where
Staff, the Company and interested parties may also
discuss methodologies and direction of rate design in
future proceedings. General Service rate design issues
should receive special attention.
Q. Given the last Intermountain Gas general rate
case was filed over 30 years ago, did you calculate the
effect of inflation when adjusting the current customer
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charges?
A. Yes. Comparing the increase in the price of
gas service to the increase in the price of a typical
market basket of goods provides some perspective on the
size of customer charge or bill increases. The Bureau of
Labor Statistics Consumer Price Index shows the weighted
average percentage price increase for all items purchased
by American consumers is 124% since 1985. Based on this
percentage increase, the residential customer charge
would increase to $8.58, and the general service customer
charge would increase to $10.08. These results
illustrate that Staff's proposed customer charge
increases (43% and 111% for residential and general
service, respectively) are less than the inflation rate
for the typical market basket of goods (124%). But as
mentioned above, there are several factors to consider
when determining the customer charges.
TOTAL BILL FOR BASIC NEEDS
Q. When you evaluate how rate design affects
customers with basic needs, how do you define "basic
A. Analysts may differ on the number of therms
required to meet monthly "basic needs." However, the
general idea is to determine a usage level that provides
a very basic level of service, but meets health and
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safety objectives. Monthly therms may differ by the
number of end uses served (e.g., space heating, water
heating, and cooking), the month in question, and perhaps
the number of members in the household.
Q. Have you examined the percentage increase in
the annual bill for basic needs?
A. Yes. For simplicity, I assume basic needs are
met with an average usage of 35 therms per month -the
low use-residential level cited above.
Assuming the customer is currently served under
RS-1, the total current annual bill, excluding gas, is
$163.29. The total Staff-proposed annual bill, excluding
gas costs, is $136.05. The bills of basic needs RS-1
customers will decrease under Staff-proposed rates, with
the annual bill decreasing by $27.24, or $2.27 per month.
Assuming the customer is currently served under
RS-2, the total current annual bill, excluding gas, is
$123.61. The total Staff-proposed annual bill, excluding
gas costs, is $136.05. The annual bill increase is
$12.44, or $1.04 per month.
PRICE SIGNAL CONSIDERATIONS
Q. Please explain why the marginal cost of
providing service, and the price signal, should be
considered when designing rates.
A. Marginal cost pricing sends the customer a
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price signal that reflects the cost of additional
consumption. Economic efficiency occurs when the price
the customer pays for the next therm consumed equals the
marginal cost of providing that next therm.
Given that most utility customers use some gas,
the "marginal" decision is whether to use another unit of
gas, as opposed to whether to become an Intermountain Gas
customer and incur a customer charge.
Q. Has Staff considered marginal cost pricing
principles when considering its customer charge proposal?
A. Yes. The Intermountain Gas system is
experiencing customer growth that necessitates system
upgrades to meet future throughput requirements. To the
extent customers conserve, capacity is available to meet
future load growth, potentially deferring the need for
costly investments. The best way to encourage
conservation is to keep usage rates at levels that
recognize the longer-run costs of expanding the system.
This may produce usage rates that are based primarily on
marginal-cost principles. These marginal cost-based
usage rates may exceed rate levels from an average
embedded cost of service study . The marginal cost
approach to rate design is forward-looking, while the
average embedded approach is based on historical costs.
Both approaches should be considered in rate-making.
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COMPARISONS TO OTHER UTILITIES
Q. Are Staff's proposed customer charges lower
than those of some other gas utilities operating in
nearby states?
A. Yes. However, Staff's recommendation is
constrained by customer-impact considerations. The
Company's last general rate case was filed over 30 years
ago. Staff cannot recommend that three decades of rate
design changes be accomplished in a single case . Staff's
proposed customer charges are fair to both the Company
and to customers, and the residential charge almost
matches Avista's recently approved customer charge
(Avista's residential customer charge is $5.25)
COMBINING RS-1 and RS-2 RESIDENTIAL SERVICE
Q. Have you reviewed the Company's proposal to
combine the Company's two current residential rate
schedules (Schedule RS-1 and Schedule RS-2) into a single
rate schedule?
A.
Q.
Yes.
Please explain your review of the proposal, and
whether you have any recommendations regarding it.
A. I reviewed the monthly average consumption
profiles of the two classes, and noted that the
consumption profile of each class over twelve months is
very similar, with peaks and valleys in consumption
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matching. Based on this similarity, I recommend that the
RS-1 and RS-2 classes be combined, as proposed by the
Company.
LARGE VOLUME/ TRANSPORTATION
Q. Have you examined the Company's proposals for
large volume and transportation customers?
A. Yes. The Company has two key proposals.
First, the Company proposes a new charge for MDFQ
(Maximum Daily Firm Quantity) for its LV-1 customers and
for customers in the current T-4 and T-5 rate categories.
Second, the Company proposes combining the T-4 and T-5
rate categories.
Q.
A.
What is the purpose of the MDFQ charge?
MDFQ is a type of demand charge. It is best
characterized as a reservation charge, because it is
based on customers' estimates of their maximum needs, as
opposed to actual usage over some time interval (e.g.,
over one or two days). Introducing a demand charge into
the Company's large volume and transportation rates
recognizes that the Company's costs to serve these
customers are driven in large part by the maximum demands
they place on the system. At this time, the Company has
not supported the amount of its proposed MDFQ charge with
a cost-of-service study.
CASE NO. INT-G-16-02
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Consequently, Staff recommends
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that the amount of the MDFQ charges be addressed at the
aforementioned workshop proposed by Staff.
Q. Although Staff recommends that the proposed
amount of the MDFQ charge not be approved in this case,
does Staff nevertheless support the approval of an MDFQ
charge in this proceeding?
A. Yes. Introducing a demand charge will better
match what customers pay to the Company's costs to serve
them. However, Staff recommends that the Company's
proposed $0.30 per therm per month MDFQ charge be reduced
to $0.20 per therm per month for nominated MDFQ. The
recommendation to reduce the charge is based on the
impact on specific customers.
Introducing a demand charge will shift costs
from higher load factor customers to lower load factor
customers. Staff believes this is appropriate, and that
lower load factor customers should pay more, because they
are more costly to serve (other things being constant).
However, Staff supports a more gradual phase-in of demand
charges than proposed by the Company.
Q. Has the Company provided additional MDFQ
information to Staff since the application was filed?
A. Yes. The Company allowed customers to nominate
new MDFQ after it filed this case. Staff incorporated
the new MDFQ when calculating its proposed rates.
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Q. Why did the Company allow customers to nominate
new MDFQ?
A. Previous MDFQs were nominated before customers
knew that they would be charged for each therm nominated .
Consequently, customers had little disincentive to over­
nominate. On the other hand, customers nominated the new
MDFQs knowing that a charge would apply to each therm.
Q. Were affected customers notified in writing
that they had an opportunity to nominate new MDFQs?
A. Yes. Intermountain Gas sent an October 25,
2016 letter to customers informing them of the "Open
Season" that would allow them to change the amount of
their nominated MDFQ. Customers were informed that the
MDFQ rate proposal would have "both operational and
financial ramifications." Customer responses were due
back to Intermountain Gas on or before November 28, 2016.
As such, customers had approximately thirty days to
consider their decisions and contact the Company.
Q. Describe how and MDFQ charge will affect
customers' bills.
A. The impact on specific customers varies widely.
Based on the Company's proposed rates, large volume
customers would see percentage changes in annual bills
(based on 2016 usage) ranging from a decrease of 8% to an
increase of 20%. T-4 transportation customers would see
CASE NO. INT-G-16-02
12/16/16
ERDWURM, B. (Di) 20
STAFF
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
percentage changes ranging from a decrease of 56% to an
increase of 190% (with the standard deviation in the
percentage increase of 51%). T-5 transportations would
see percentage changes ranging from a decrease of 24% to
an increase of 6 9--0 • Staff's proposal to reduce the MDFQ
charge will reduce the substantial variation in
percentage changes in bills. Staff believes that
introducing the MDFQ charge will better reflect costs,
regardless of these impacts.
Q. Do you support combining T-4 and T-5 as
proposed by the Company?
A. Yes. This simplifies the tariff. Also, there
appears to be no reason for separate tariffs .
REVENUE PROOF
Q. Have you prepared a proof-of-revenue table that
shows that Staff-proposed rates will accurately recover
the Staff-proposed revenue target under normalized
conditions?
A. Yes. This schedule is attached as Exhibit 116.
Absent a cost-of service study, the percentage of revenue
by class is maintained at current levels. Additionally,
a summary of current and Staff-proposed residential and
general service rates is included as Exhibit 117 . Staff­
proposed large volume and transportation (as well as
CASE NO . INT-G-16-02
12/16/16
ERDWURM, B. (Di) 21
STAFF
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
residential and general service) rates are show in
Exhibit 116.
Q. Does this conclude your direct testimony in
this proceeding?
A. Yes, it does.
CASE NO. INT-G-16-02
12/16 /16
ERDWURM, B. (Di) 22
STAFF
Embedded Residential Customer Charge Estimate
Line
2
3
4
5
6
7
8
9
10
11
12
13
14
16
17
19
20
21
22
25
27
28
29
30
31
32
33
34
35
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Description
Customer-Related Operating Expenses (includes depreciation expense)
Operation
4010.2878
4010.28783
4010.2879
Maintenance
4020.2892
4020.2893
Customer Accounting
4010.2901
4010.2902
4010.2903
Customer Service & Information Expenses
4010.2908
Labor-Distribution Operation Expenses
4010.2874
4010.2878
4010.2879
Labor-Distribution Maintenance Expenses
4020.2892
4020.2893
Labor-Customer Account
4010.2902
4010.2903
Depreciation Expense-Distribution Plant
4030.0005
Total O&M
Customer-Related Plant
1010.38 Dist Services
1010.381 Dist Meters
1010.382 Dist Meter Installations
1010.383 Dist House Regulators
1010.384 Dist House Regulator Install
1010.385 Dist Ind Reg Sta
Accumulated Depreciation for Selected Dist Plant
Net Plant
% Debt Financed (Company Assumptions)
Cost of Debt
Interest Expense
Operating Expenses plus Interest
Net Plant
Equity Portion (in Percent) of Net Plant
Equity Portion (in $) of Net Plant
Return as % (Company Assumption)
Equity Return
Gross Revenue Conversion Factor
Grossed-Up Equity Return
$226,375
-$556,097
$7,126,046
$1 ,037,443
$832,745
$98,925
$715,432
$7,599,357
$202,610
$1 ,611,161
$202,693
$5,917,585
$357,288
$353,914
$553,077
$4,401,233
$12,612,078
$43,291,865 Add Lines 3 through 39
$149,255,628
$44,853,911
$13,955,058
$6,410,602
$7,047,749
$11 ,259,697
$232,782,645 Add Lines 43 through 48
-$130,903,051
$101,879,594 Line 49 minus 51
50.000%
4.940%
$2,516,426 Line 52 times 54 times 55
$45,808,291 Add Lines 40 and 56
$101 ,879,594
50.000%!
$50,939,797 Line 61 times 62
9.90%
$5,043,040 Line 62 times 63
1.67055
$8,424,626 Line 64 times 66
i..;I C:;..;u;;.:s;.;.to..;;..m.;;.;..;..er;...-;..;R..;;..el"-a"'te'-'d_R_e'-v-'e.c.cn..:cu.c.e"""R""e""q"'u'-ir..;;..em.;;.;..;..e.;..;.nt'---------"$"'-54"",;;;;.23;;.;:2:.c,9c...1'-'-'7 !Add Lines 58 and 68.
Exhibit No. 112
Case No. INT-G-16-02
8 . Erdwurm, Staff
12/16/16 Page I of2
Embedded Residential Customer Charge Estimate
71 Alternate Weighted Customer Calculation
72
73
74
75
76
77
78
RS
GS
LV-1
T-3
T-4
Bills Weights1
3,701,803 1
385,898 6
217 100
72 100
1,158 100
Weighted Customers
3,701,803
2,315,388
21 ,700
7,200
115,800
% ofWtd
Customers
60.08%
37.58%
0.35%
0.12%
1.88%
79 6,161,891 100.00%
80
81 Weights are chosen to reduce allocation to residential (for a conservative estimate).
82 Calculate Customer Related portion allocated to Residential
83
84
85
86
87
88
89
Customer-Related Revenue Requirement
Times Residential % Weighted Factor
Divide by Annual Bills
Unadjusted CosUCustomer
Conformed to Staff Revenue
$54,232,917 Line 70
60.08% Line 74
$32,580,838
3,701 ,803
$8.80
$8.57
Exhibit No. 112
Case No. INT-G-16-02
8. Erdwurm, Staff
12/16/16 Page 2 of2
RS-1 Bill Comparison -Apr through Nov -Current v. Staff Proposed
Staff-
Proposed Staff-
Current1 Bill Bill Current1 Bill Proposed
Excluding Excluding Including Bill including
Therms Gas Cost Gas Cost $ Change % Change Gas Cost Gas Cost $ Change % Change
0 $ 2.50 $ 5.50 $ 3.00 120% $ 2.50 $ 5.50 $ 3.00 120%
10 $ 5.67 $ 7.17 $ 1.50 26% $ 11.23 $ 12.73 $ 1.50 13%
20 $ 8.84 $ 8.84 $ 0.00 0% $ 19.95 $ 19.95 $ 0.00 0%
30 $ 12.00 $ 10.50 $ (1.50) -12% $ 28.68 $ 27.18 $ (1.50) -5%
35 $ 13.59 $ 11.34 $ (2.25) -17% $ 33.04 $ 30.79 $ (2.25) -7%
40 $ 15.17 $ 12.17 $ (3.00) -20% $ 37.41 $ 34.41 $ (3.00) -8%
so $ 18.34 $ 13.84 $ (4.50) -25% $ 46.13 $ 41.63 $ (4.50) -10%
60 $ 21.51 $ 15.51 $ (6.00) -28% $ 54.86 $ 48.86 $ (6.00) -11%
70 $ 24.67 $ 17.18 $ (7.50) -30% $ 63.59 $ 56.09 $ (7.50) -12%
80 $ 27.84 $ 18.84 $ (9.00) -32% $ 72.31 $ 63.31 $ (9.00) -12%
90 $ 31.01 $ 20.51 $ (10.50) -34% $ 81.04 $ 70.54 $ (10.50) -13%
100 $ 34.18 $ 22.18 $ (12.00) -35% $ 89.77 $ 77.77 $ (12.00) -13%
125 $ 42.10 $ 26.35 $ (15.75) -37% $ 111.58 $ 95.84 $ (15.75) -14%
150 $ 50.02 $ 30.52 $ (19.50) -39% $ 133.40 $ 113.90 $ (19.50) -15%
200 $ 65.86 $ 38.86 $ (27.00) -41% $ 177.03 $ 150.04 $ (27.00) -15%
300 $ 97.53 $ 55.54 $ (42.00) -43% $ 264.30 $ 222.30 $ (42.00) -16%
400 $ 129.21 $ 72.22 $ (57.00) -44% $ 351.57 $ 294.57 $ (57.00) -16%
500 $ 160.89 $ 88.90 $ {72.00) -45% $ 438.84 $ 366.84 $ (72.00) -16%
750 $ 240.09 $ 130.59 $ (109.49) -46% $ 657.00 $ 547.51 $ (109.49) -17%
1000 $ 319.28 $ 172.29 $ (146.99) -46% $ 875.17 $ 728.18 $ {146.99) -17%
RS-1 Bill Comparison -Dec through Mar -Current v. Staff Proposed
Staff-
Proposed Staff-
Current Bill Bill Current Bill Proposed
Excluding Excluding Including Bill including
Therms Gas Cost Gas Cost $ Change % Change Gas Cost Gas Cost $ Change % Change
0 $ 6.50 $ 5.50 $ (1.00) -15% $ 6.50 $ 5.50 $ (1.00) -15%
10 $ 8.54 $ 7.17 $ {1.37) -16% $ 14.10 $ 12.73 $ (1.37) -10%
20 $ 10.58 $ 8.84 $ {1.75) -17% $ 21.70 $ 19.95 $ (1.75) -8%
30 $ 12.63 $ 10.50 $ (2.12) -17% $ 29.30 $ 27.18 $ (2.12) -7%
35 $ 13.65 $ 11.34 $ (2.31) -17% $ 33.10 $ 30.79 $ (2.31) -7%
40 $ 14.67 $ 12.17 $ (2.50) -17% $ 36.90 $ 34.41 $ (2.50) -7%
so $ 16.71 $ 13.84 $ (2.87) -17% $ 44.51 $ 41.63 $ (2.87) -6%
60 $ 18.75 $ 15.51 $ (3.25) -17% $ 52.11 $ 48.86 $ (3.25) -6%
70 $ 20.80 $ 17.18 $ (3.62) -17% $ 59.71 $ 56.09 $ (3.62) -6%
80 $ 22.84 $ 18.84 $ (3.99) -17% $ 67.31 $ 63.31 $ (3.99) -6%
90 $ 24.88 $ 20.51 $ (4.37) -18% $ 74.91 $ 70.54 $ (4.37) -6%
100 $ 26.92 $ 22.18 $ (4.74) -18% $ 82.51 $ 77.77 $ (4.74) -6%
125 $ 32.03 $ 26.35 $ (S.68) -18% $ 101.51 $ 95.84 $ (S.68) -6%
150 $ 37.13 $ 30.52 $ (6.61) -18% $ 120.52 $ 113.90 $ (6.61) -5%
200 $ 47.34 $ 38.86 $ (8.49) -18% $ 158.52 $ 150.04 $ (8.49) -5%
300 $ 67.77 $ 55.54 $ (12.23) -18% $ 234.53 $ 222.30 $ (12.23) -5%
400 $ 88.19 $ 72.22 $ {15.97) -18% $ 310.54 $ 294.57 $ {15.97) -5%
500 $ 108.61 $ 88.90 $ {19.72) -18% $ 386.56 $ 366.84 $ (19.72) -5%
750 $ 159.67 $ 130.59 $ {29.07) -18% $ 576.58 $ 547.51 $ {29.07) -5%
1000 $ 210.72 $ 172.29 $ (38.43) -18% $ 766.61 $ 728.18 $ (38.43) -5%
Note 1: Based on Gas Costs in Company's Application
Exhibit No. 113
Case No. INT-G-16-02
B. Erdwurm, Staff
12/16/16
RS-2 Bill Comparison -Apr through Nov -Current v. Staff Proposed
Staff-
Proposed Staff-
Current1 Bill Bill Current1 Bill Proposed
Excluding Excluding Including Bill including
Therms Gas Cost Gas Cost $ Change % Change Gas Cost Gas Cost $ Change % Change
0 $ 2.50 $ 5.50 $ 3.00 120% $ 2.50 $ 5.50 $ 3.00 120%
10 $ 4.46 $ 7.17 $ 2.71 61% $ 9.62 $ 12.33 $ 2.71 28%
20 $ 6.42 $ 8.84 $ 2.42 38% $ 16.74 $ 19.15 $ 2.42 14%
30 $ 8.38 $ 10.50 $ 2.12 25% $ 23.86 $ 25.98 $ 2.12 9%
35 $ 9.36 $ 11.34 $ 1.98 21% $ 27.41 $ 29.39 $ 1.98 7%
40 $ 10.34 $ 12.17 $ 1.83 18% $ 30.97 $ 32.81 $ 1.83 6%
so $ 12.30 $ 13.84 $ 1.54 13% $ 38.09 $ 39.63 $ 1.54 4%
60 $ 14.26 $ 15.51 $ 1.25 9% $ 45.21 $ 46.46 $ l.2S 3%
70 $ 16.22 $ 17.18 $ 0.96 6% $ 52.33 $ 53.28 $ 0.96 2%
80 $ 18.18 $ 18.84 $ 0.66 4% $ 59.45 $ 60.11 $ 0.66 1%
90 $ 20.14 $ 20.51 $ 0.37 2% $ 66.57 $ 66.94 $ 0.37 1%
100 $ 22.10 $ 22.18 $ 0.08 0% $ 73.69 $ 73.76 $ 0.08 0%
125 $ 27.00 $ 26.35 $ (0.65) -2% $ 91.48 $ 90.83 $ (0.65) -1%
150 $ 31.90 $ 30.52 $ (1.38) -4% $ 109.28 $ 107.90 $ (1.38) -1%
200 $ 41.70 $ 38.86 $ (2.84) -7% $ 144.87 $ 142.03 $ (2.84) -2%
300 $ 61.30 $ 55.54 $ (S.76) -9% $ 216.06 $ 210.29 $ (S.76) -3%
400 $ 80.90 $ 72.22 $ (8.68) -11% $ 287.24 $ 278.56 $ (8.68) -3%
500 $ 100.50 $ 88.90 $ (11.61) -12% $ 358.43 $ 346.82 $ (11.61) -3%
750 $ 149.50 $ 130.59 $ (18.91) -13% $ 536.39 $ 517.48 $ (18.91) -4%
1000 $ 198.50 $ 172.29 $ (26.21) -13% $ 714.35 $ 688.14 $ (26.21) -4%
RS-2 Bill Comparison -Dec through Mar -Current v. Staff Proposed
Staff-
Proposed Staff-
Current Bill Bill Current Bill Proposed
Excluding Excluding Including Bill including
Therms Gas Cost Gas Cost $ Change % Change Gas Cost Gas Cost $ Change % Change
0 $ 6.50 $ 5.50 $ (1.00) -15% $ 6.50 $ 5.50 $ (1.00) -15%
10 $ 8.12 $ 7.17 $ (0.96) -12% $ 13.28 $ 12.33 $ (0.96) -7%
20 $ 9.75 $ 8.84 $ (0.91) -9% $ 20.06 $ 19.15 $ (0.91) -5%
30 $ 11.37 $ 10.50 $ (0.87) -8% $ 26.85 $ 25.98 $ (0.87) -3%
35 $ 12.18 $ 11.34 $ (0.85) -7% $ 30.24 $ 29.39 $ (0.85) -3%
40 $ 12.99 $ 12.17 $ (0.82) -6% $ 33.63 $ 32.81 $ (0.82) -2%
so $ 14.62 $ 13.84 $ (0.78) -5% $ 40.41 $ 39.63 $ (0.78) -2%
60 $ 16.24 $ 15.51 $ (0.73) -5% $ 47.19 $ 46.46 $ (0.73) -2%
70 $ 17.87 $ 17.18 $ (0.69) -4% $ 53.98 $ 53.28 $ (0.69) -1%
80 $ 19.49 $ 18.84 $ (0.65) -3% $ 60.76 $ 60.11 $ (0.65) -1%
90 $ 21.11 $ 20.51 $ (0.60) -3% $ 67.54 $ 66.94 $ (0.60) -1%
100 $ 22.74 $ 22.18 $ (0.56) -2% $ 74.32 $ 73.76 $ (0.56) -1%
125 $ 26.80 $ 26.35 $ (0.45) -2% $ 91.28 $ 90.83 $ (0.45) 0%
150 $ 30.86 $ 30.52 $ (0.34) -1% $ 108.23 $ 107.90 $ (0.34) 0%
200 $ 38.97 $ 38.86 $ (0.12) 0% $ 142.14 $ 142.03 $ (0.12) 0%
300 $ 55.21 $ 55.54 $ 0.33 1% $ 209.97 $ 210.29 $ 0.33 0%
400 $ 71.45 $ 72.22 $ 0.77 1% $ 277.79 $ 278.56 $ 0.77 0%
500 $ 87.69 $ 88.90 $ 1.21 1% $ 345.61 $ 346.82 $ 1.21 0%
750 $ 128.28 $ 130.59 $ 2.32 2% $ 515.17 $ 517.48 $ 2.32 0%
1000 $ 168.87 $ 172.29 $ 3.42 2% $ 684.72 $ 688.14 $ 3.42 0%
Note 1: Based on Gas Costs in Company's Application
Exhibit No. I 14
Case No. INT-G-16-02
B. Erdwurm, Staff
12/16/16
General Service Bill Comparison -Apr through Nov -Current v. Staff Proposed
Staff-
Proposed Staff-
Current1 Bill Bill Current1 Bill Proposed Bill
Excluding Excluding Including Gas including Gas
Therms Gas Cost Gas Cost $ Change % Change Cost Cost $ Change % Change
0 $ 2.00 $ 9.50 $ 7.50 375% $ 2.00 $ 9.50 $ 7.50 375%
25 $ 7.44 $ 13.96 $ 6.52 88% $ 20.23 $ 26.75 $ 6.52 32%
50 $ 12.88 $ 18.42 $ 5.54 43% $ 38.46 $ 44.00 $ 5.54 14%
75 $ 18.31 $ 22.87 $ 4.56 25% $ 56.69 $ 61.25 $ 4.56 8%
100 $ 23.75 $ 27.33 $ 3.58 15% $ 74.92 $ 78.50 $ 3.58 5%
150 $ 34.63 $ 36.25 $ 1.62 5% $ 111.38 $ 113.00 $ 1.62 1%
200 $ 45.50 $ 45.16 $ (0.34) -1% $ 147.84 $ 147.50 $ (0.34) 0%
250 $ 55.29 $ 52.94 $ (2.35) -4% $ 183.21 $ 180.86 $ (2.35) -1%
300 $ 65.08 $ 60.72 $ (4.36) -7% $ 218.58 $ 214.22 $ (4.36) -2%
400 $ 84.66 $ 76.27 $ (8.39) -10% $ 289.33 $ 280.94 $ (8.39) -3%
500 $ 104.24 $ 91.83 $ (12.41) -12% $ 360.07 $ 347.66 $ (12.41) -3%
750 $ 153.18 $ 130.71 $ {22.47) -15% $ 536.93 $ 514.47 $ (22.47) -4%
1000 $ 202.13 $ 169.60 $ (32.52) -16% $ 713.80 $ 681.27 $ (32.52) -5%
2500 $ 485.29 $ 391.94 $ (93.35) -19% $ 1,764.46 $ 1,671.11 $ (93.35) -5%
5000 $ 922.19 $ 725.86 $ (196.32) -21% $ 3,480.54 $ 3,284.21 $ (196.32) -6%
7500 $ 1,359.09 $ 1,059.79 $ (299.30) -22% $ 5,196.61 $ 4,897.31 $ (299.30) -6%
10000 $ 1,795.99 $ 1,393.71 $ (402.27) -22% $ 6,912.69 $ 6,510.41 $ (402.27) -6%
20000 $ 3,543.59 $ 2,393.71 $ (1,149.87) -32% $ 13,776.99 $ 12,627.11 $ (1,149.87) -8%
30000 $ 5,291.19 $ 3,393.71 $ (1,897.47) -36% $ 20,641.29 $ 18,743.81 $ {1,897.47) -9%
40000 $ 7,038.79 $ 4,393.71 $ (2,645.07) -38% $ 27,505.59 $ 24,860.51 $ {2,645.07) -10%
General Service Bill Comparison -Dec through Mar -Current v. Staff Proposed
Staff-
Proposed Staff-
Current Bill Bill Current Bill Proposed Bill
Excluding Excluding Including Gas including Gas
Therms Gas Cost Gas Cost $ Change % Change Cost Cost $ Change % Change
0 $ 9.50 $ 9.50 $ 0% $ 9.50 $ 9.50 $ 0%
25 $ 13.67 $ 13.96 $ 0.29 2% $ 26.46 $ 26.75 $ 0.29 1%
50 $ 17.83 $ 18.42 $ 0.58 3% $ 43.42 $ 44.00 $ 0.58 1%
75 $ 22.00 $ 22.87 $ 0.87 4% $ 60.37 $ 61.25 $ 0.87 1%
100 $ 26.17 $ 27.33 $ 1.17 4% $ 77.33 $ 78.50 $ 1.16 2%
150 $ 34.50 $ 36.25 $ 1.75 5% $ 111.25 $ 113.00 $ 1.75 2%
200 $ 42 .83 $ 45.16 $ 2.33 5% $ 145.17 $ 147.50 $ 2.33 2%
250 $ 50.11 $ 52.94 $ 2.83 6% $ 178.02 $ 180.86 $ 2.83 2%
300 $ 57.38 $ 60.72 $ 3.34 6% $ 210.88 $ 214.22 $ 3.34 2%
400 $ 71.92 $ 76.27 $ 4.35 6% $ 276.59 $ 280.94 $ 4.35 2%
500 $ 86.47 $ 91.83 $ 5.36 6% $ 342.31 $ 347.66 $ 5.36 2%
750 $ 122.84 $ 130.71 $ 7.88 6% $ 506.59 $ 514.47 $ 7.88 2%
1000 $ 159.20 $ 169.60 $ 10.40 7% $ 670.87 $ 681.27 $ 10.40 2%
2500 $ 367.16 $ 391.94 $ 24.78 7% $ 1,646.34 $ 1,671.11 $ 24.78 2%
5000 $ 679.66 $ 725.86 $ 46.20 7% $ 3,238.01 $ 3,284.21 $ 46.20 1%
7500 $ 992.16 $ 1,059.79 $ 67.63 7% $ 4,829.69 $ 4,897.31 $ 67.63 1%
10000 $ 1,304.66 $ 1,393.71 $ 89.05 7% $ 6,421.36 $ 6,510.41 $ 89.05 1%
20000 $ 2,554.66 $ 2,393.71 $ (160.95) -6% $ 12,788.06 $ 12,627.11 $ (160.95) -1%
30000 $ 3,804.66 $ 3,393.71 $ (410.95) -11% $ 19,154.76 $ 18,743.81 $ (410.95) -2%
40000 $ 5,054.66 $ 4,393.71 $ (660.95) -13% $ 25,521.46 $ 24,860.51 $ (660.95) -3%
Note 1: Based on Gas Costs in Company's Application
Exhibit No. I 15
Case No. INT-G-16-02
B. Erdwurrn, Staff
12/16/16
Proof of Revenue
Line No. Class
1 RS-1
2 Annual Bills
3 Therms
4 Total
5 RS-2
6 Annual Bills
7 Therms
8 Total
9 15-R
10 Annual Bills
11 Therms
12 Total
GS-1
13 Annual Bills
14
15 Therms -Tier 1
16 Therms -Tier 2
17 Therms -Tier 3
18 Therms -Tier 4
19 Total Therms
20 Total
21 15-C
22 Annual Bills
23
24 Therms -Tier 1
25 Therms -Tier 2
26 Therms -Tier 3
27 Therms -Tier 4
28 Total Therms
29 Total
30 LV-1
31 Annual Bills
32
33 MDFQ
34
35 Therms -Tier 1
36 Therms -Tier 2
37 Therms -Tier 3
38 Total Therms
39 Total
Billing
Determinates Rate
807,488 $5.50
32,972,314 $0.16679
2,893,307 $5.50
184,003,658 $0.16679
1,008 $5.50
137,397 $0.16679
385,791 $9.50
31,992,665 0.17831
52,346,235 0.15555
26,185,787 0.13357
0.10000
110,524,687
102 $9.50
5,911 0.17831
6,823 0.15555
3,276 0.13357
0.10000
16,010
217 No Charge
450,360 $0.20000
6,317,560 $0.03981
0 $0.01584
$0.00373
6,317,560
Revenue
$4,441,184
$5,499,452
$9,940,636
$15,913,189
$30,689,970
$46,603,159
$5,544
$22,916
$28,460
$3,665,015
$5,704,612
$8,142,457
$3,497,636
$0
$17,344,705
$ 21,009,719
$969
$1,054
$1,061
$438
$0
$2,553
$3,522
$90,072
$251,502
$0
$0
$251,502
$341,574
Exhibit No. 116
Case No. INT-G-16-02
B. Erdwurm, Staff
12/16/16 Page 1 of2
Proof of Revenue (cont.)
Line No. Class
40 T-3
41 Annual Bills
42
43 Therms -Tier 1
44 Therms -Tier 2
45 Therms -Tier 3
46 Total Therms
47 Total
48 T-4
49 Annual Bills
so
51 MDFQ1
52
53 Therms -Tier 1
54 Therms -Tier 2
55 Therms -Tier 3
56 Total Therms
57 Overrun
58 Total
59 T-5
60 Annual Bills
61
62 MDFQ1
63
64 Therms -Tier 1
65 Therms -Tier 2
66 Therms -Tier 3
67 Total Therms
68
69 Total
70 Total (excludes Gas Costs)
Billing
Determinates Rate
72 No Charge
8,308,080 $0.01775
3,419,023 $0.00722
33,049,148 $0.00267
44,776,251
1,149 No Charge
14,661,480 $0.20
110,747,535 $0.04846
85,960,760 $0.01712
67,928,377 $0.00526
264,636,672
4,120,808
15,655,352 No Charge
659,820 $0.20
6,575,248 $0.04846
5,009,713 $0.01712
4,070,392 $0.00526
15,655,352
Revenue
$147,468
$24,685
$88,241
$260,395
$260,395
$2,932,296
$5,366,826
$1,471,648
$357,303
$7,195,777
$10,128,073
$131,964
$318,637
$85,766
$21,410
$425,813
$557,777
$88,873,315
Exhibit No. I 16
Case No. INT-G-16-02
B. Erdwurm, Staff
12/16/16 Page 2 of2
Residential & General Service Rates -Current & Staff Proposed
Company
Current Proposed
Residential RS-1
Customer Charge
Apr-Nov (8 months) $2.50 $10.00
Dec-Mar (4 months) $6.50 $10.00
Weighted Avg $3.83 $10.00
Commodity Charge
Apr-Nov (8 months) $0.31678 $0.11265
Dec-Mar (4 months) $0.20422 $0.11265
Residential RS-2
Customer Charge
Apr-Nov (8 months) $2.50 $10.00
Dec-Mar (4 months) $6.50 $10.00
Weighted Avg $3.83 $10.00
Commodity Charge
Apr-Nov (8 months) $0.19600 $0.11265
Dec-Mar (4 months) $0.16237 $0.11265
General Service GS-1
Customer Charge
Apr-Nov (8 months) $2.00 $35.00
Dec-Mar (4 months) $9.50 $35.00
Weighted Avg $4.50 $35.00
Commodity Charge
Apr-Nov (8 months)
1st block $0.21751 $0.11076
2nd block $0.19578 $0.09662
3rd block $0.17476 $0.08297
4th block N/A $0.07500
Dec-Mar (4 months)
1st block $0.16666 $0.11076
2nd block $0.14546 $0.09662
3rd block $0.12500 $0.08297
4th block N/A $0.07500
Current to Staff
Staff Proposed Change
$5.50 $3.00
$5.50 ($1.00)
$5.50 $1.67
$0.16679 ($0.14999)
$0.16679 ($0.03743)
$5.50 $3.00
$5.50 ($1.00)
$5.50 $1.67
$0.16679 ($0.02921)
$0.16679 $0.00442
$9.50 $7.50
$9.50 $0.00
$9.50 $5.00
$0.17831 ($0.03920)
$0.15555 ($0.04023)
$0.13357 ($0.04119)
$0.10000 N/A
$0.17831 $0.01165
$0.15555 $0.01009
$0.13357 $0.00857
$0.10000 N/A
Current to Staff %
Change
120%
-15%
43%
-47%
-18%
120%
-15%
43%
-15%
3%
375%
0%
111%
-18%
-21%
-24%
N/A
7%
7%
7%
N/A
Exhibit No. I 17
Case No. INT-G-16-02
B . Erdwurm, Staff
12/16/16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF DECEMBER 2016,
SERVED THE FOREGOING DIRECT TESTIMONY OF BENTLEY ERDWURM, IN
CASE NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR-REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83 707
E-MAIL : [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre g@ri chardsonadams. com
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83 702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 3TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: km i [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. l @us.af.mil
Nata1ie.cepak.2(@us.af.mil
Thomas.jernigan.3(@us.af.mil
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE