20161216Rogers Direct with Exhibit 107.pdf

BEFORE THE n::c r:J''ED f ,. t ... ..r I, ... 'y
IDAHO PUBLIC UTILITIES COMMIS;Sld_N Cl/f'\1.Q ,_ 10 11 . 1 •.. ··-" , .. ,1 11-.;0 . I
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
)
)
)
___________ )
DIRECT TESTIMONY OF MARK ROGERS
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 Mark Rogers. 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 in the Utilities
Division where my primary role has been developing and
reviewing utility rate design, cost of service studies,
tariff modifications, integrated resource planning,
multi-state allocation and emerging utility issues.
Q. What is your educational and professional
background?
A. I graduated from the University of Idaho with a
Bachelor of Science degree in biological systems
engineering. I hold a Master's of Environmental Science
with an emphasis in ecosystems and biodiversity from the
Swedish University of Agricultural Sciences in Uppsala,
Sweden. I also hold a Master's of Environmental Science
with an emphasis in water resource engineering from the
University of Natural Resources and Applied Life Sciences
Vienna, Austria. Furthermore, I have graduated with a
Master's in Business Administration from Boise State
University. I have worked previously as an analyst for
the International Water Association in the Specialist
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Group for Statistics and Economics, where I have
published statistical data on international water
services. I have been employed as a utilities analyst
with the Commission since July 2015, have attended the
New Mexico State University Center for Public Utilities'
course in Practical Regulatory Training, and serve on
Avista's Technical Advisory Committee.
Q.
A.
What is the purpose of your testimony?
I will provide Commission Staff's position on
Intermountain Gas Company's ("Intermountain Gas";
"Company") DCF return on equity.
Q.
A.
Can you please summarize your testimony?
Of course. In my testimony, I will address the
Company's proposed return on equity. I will outline the
Company's methodology of using a Basic Discounted Cash
Flow ("DCF") to determine the return on equity. With
regards to this, I will address the need to include a
Blended DCF methodology with a Basic DCF to derive a more
reasonable, and long-term oriented return on equity.
Furthermore, I will outline a controversy in the
Company's flotation calculation used in both DCF
methodologies. I will provide recalculated results of
the DCF analyses and conclude with a summary.
Q. Please describe the standards for determining a
fair and reasonable rate of return.
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A. Absolutely. The legal test of a fair rate of
return for a utility company was established in the
Bluefield Water Works decision of the United States
Supreme Court and is repeated specifically in Hope
Natural Gas.
In Bluefield Water Works and Improvement Co. v.
West Virginia Public Service Commission, 262 U.S. 679,
692, 43 S.Ct. 675, 67 L.Ed 1176 (1923), the Supreme
Court stated:
A public utility is entitled to such rates as
will permit it to earn a return on the value
of the property which it employs for the
convenience of the public equal to that
generally being made at the same time and in
the same general part of the country on
investments in other business undertakings
which are attended by corresponding risks and
uncertainties; but it has no constitutional
right to profits such as are realized or
anticipated in highly profitable enterprises
or speculative ventures. The return should
be reasonably sufficient to assure confidence
in the financial soundness of the utility and
should be adequate, under efficient and
economical management, to maintain and
support its credit and enable it to raise the
money necessary for the proper discharge of
its public duties. A rate of return may be
reasonable at one time and become too high or
too low by changes affecting opportunities
for investment, the money market and business
conditions generally.
The Court refined these guidelines in Federal Power
Commission v. Hope Natural Gas Company, 320 U.S. 591,
603, 64 S.Ct. 281, 88 L.Ed. 333, 345 (1944):
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From the investor or company point of view it
is important that there be enough revenue not
only for operating expenses but also for the
capital costs for the business. These include
service on the debt and dividends on the
stock. (Citation omitted) By that standard
the return to the equity owner should be
commensurate with returns on investments in
other enterprises having corresponding risks.
That return, moreover, should be sufficient to
assure confidence in the financial integrity
of the enterprise, so as to maintain its
credit and to attract capital.
The Idaho Supreme Court has adopted these rate of return
guidelines. See Application of Citizens Utilities Co.,
112 Idaho 1061, 1067, 739 P.2d 360, 366 (1987 (Bluefield
and Hope clarify "that the primary objective in
ratemaking is t o allow the utilit y to meet its legitimate
operating expenses, as well as to pay creditors, prov ide
dividends to shareholders, and maintain its financial
integrity so that it might attract new capital").
As a result of these United States and Idaho
Supreme Court decisions, three standards have evolved for
determining a fair and reasonable rate of return: ( 1)
The Financial Integrity or Credit Maintenance Standard;
(2) The Capital Attraction Standard; and, (3) The
Comparable Earning Standard. If the Comparable Earnings
Standard is met, the Financial Integrity or Credit
Maintenance Standard, and the Capital Attraction Standard
will also be met, as they are an integral part of the
Comparable Earnings Standard.
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Q. Please describe the Comparable Earnings
Standard and how the cost of equity is determined using
this approach?
A. The Comparable Earnings Standard for
determining the cost of equity is based upon the premise
that a given investment should earn its opportunity
costs. In competitive markets, if the return earned by a
firm is not equal to the return being earned on other
investments of similar risk, the flow of funds will be
toward those investments earning the higher returns.
Therefore, for a utility to be competitive in financial
markets, it should be allowed to earn a return on equity
equal to the average return earned by other firms of
similar risk. The Comparable Earnings approach is
supported by the Bluefield Water Works and Hope Natural
Gas decisions as a basis for determining those average
returns.
Q. Has the Comparable Earnings Standard been
considered in the testimony and analyses conducted by Mr.
Gaske and yourself?
A. Yes, it has. As Intermountain Gas is a
subsidiary of the Montana-Dakota Utilities Resource Group
("MDU"), it trades no common stock. Due to this
parent/subsidiary relationship, there is no direct equity
market data available for utility operations at
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Intermountain Gas. Consequently, Mr . Gaske and I have
both used a discounted cash flow methodology that meets
the Comparable Earnings Standard by using a proxy group
of similar companies to determine Intermountain Gas's
return on equity. In fact, both the recommendations from
Mr . Gaske and myself include return on equity rates
greater than 8.42%, which is the average return on equity
for the companies in the proxy group. Thus, not only has
the Comparable Earnings Standard been met, but our
recommendations both exceed the standard of the test. As
a result, the legal standard for setting the rate of
return on common equity has also been satisfied.
Q. Let's turn our attention to the discounted cash
flow methodology.
method.
Please explain the basis for the DCF
A. The DCF method is based upon the theory that
(1) stocks are bought for the income they provide (i.e.,
both dividends and gains from the sale of the stock), and
(2) the market price of stocks equals the discounted
value of all future incomes. The discount rate, or cost
of equity, equates the present value of the stream of
income to the current market price of the stock. The
formula to accomplish this goal is:
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Equation No. 1-1
Po = PV = - - - - - -+ - - - - - - + ... + - - - - - - + -- - - - -
( l+Ks) 1 ( l+Ks ) 2 ( l+Ks ) N { l+Ks) N
Where:
Po = Current Price
D = Dividend
Ks= Capitalization Rate, Discount Rate, or Required Rate
of Return
N = Latest Year Considered
The pattern of the future income stream is the
key factor that must be estimated in this approach. Some
simplifying assumptions for ratemaking purposes can be
made without sacrificing the validity of the results.
Two such assumptions are: (1) the dividends per share
grow at a constant rate in perpetuity and (2) prices
track earnings. These assumptions lead to the simplified
traditional DCF formula, where the required return is the
dividend yield plus the growth rate (g)
D
Ks = - - - - -+ g
Po
Equation No. 1-2
Q. Is this traditional DCF formula the same
formula presented by Mr. Gaske in his testimony?
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A. No. But it is the basis for the formula used
by Mr. Gaske in his testimony. The traditional DCF
formula assumes that dividends are paid annually, and
that they increase once a year starting one year from the
present. In both practice and theory, however, this
assumption is incorrect. Rather, most companies,
including utilities, tend to pay dividends on a quarterly
basis instead of an annual basis. To reflect this
concept, Mr. Gaske modified the traditional DCF formula
to approximate the timing of dividend payments on a
quarterly basis. Thus the DCF model presented in his
testimony is:
Q.
Equation No. 1-3
Do (l+.0625g)
K = -------------+ g
p
Is it acceptable to apply this adjusted formula
for the DCF model when calculating Intermountain Gas's
return on equity in this proceeding?
A. Yes. While there are many forms of the DCF
model, modifying it to account for quarterly dividend
payments is acceptable in this case. Specifically, the
Comparable Earnings Standard described a fair and
reasonable rate of return equal to the return being
earned on other investments of similar risk. Since all
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but one company in the proxy group issues quarterly
dividends, it is acceptable in this proceeding to modify
the formula to account for the timing of these payments.
Q. Please describe the growth rate in terms of the
traditional DCF?
A. Of course. The growth rate utilized by Mr.
Gaske in the Basic DCF is simply the growth estimates for
each of the companies in the proxy group from analysts at
both Zacks Investment Research and Thomson First Call.
The values from both analysts are averaged together to
determine the growth rate for each of the proxy
companies. Intermountain Gas's return on equity will be
compared to this growth rate.
Q. Are there any negative consequences associated
with using such an approach?
A. Yes, specifically when relying solely on this
approach. While Zacks Investment Research and Thomson
First Call are two respected firms, the bottom line is
that the growth rates used in the analysis rely on
estimates that are subjective to the skill of the
analysts developing them. As Mr. Gaske states in his
testimony, the Basic DCF analysis assumes that the
analysts' earnings growth forecasts incorporate all
information required to estimate a long-term expected
growth rate for a company.
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See Gaske Direct at 20. This
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argument in itself would lead one to ask, "what is all
information required to estimate a long-term growth
rate?" The answer to this is subjective based on what
the analyst deems to be important enough to include. In
this regard, each analyst would separately estimate the
future growth rate based on their own opinion of what
information should be included in the estimate.
This produces a model that has three outcomes:
(1) both analysts predict the correct growth rate; (2)
one analyst predicts the correct growth rate; or (3)
neither analyst predicts the correct growth rate.
Unless, by chance, both analysts have correctly predicted
the actual growth rate, then the model will inevitably be
based on incorrect estimates and incomplete information.
In terms of the proxy group of companies, the estimates
from both analysts vary by up to 20%. In this capacity,
that model is inherently flawed and will be based to some
degree on incorrect estimates. Such implications are
concerning when this method is used as the sole basis for
calculating a return on equity within a DCF model.
Q. Are there other forms of the DCF model that are
acceptable to use as well?
A. Yes, there are. One such model, as described
by Mr. Gaske, is a Blended DCF model that incorporates
growth as presented in the traditional DCF, while
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incorporating a long-term retention rate .
Q. Does the Blended methodology remove the
subjectivity inherent in the Basic DCF model?
A. The Blended methodology does not completely
remove the subjectivity because half of the Blended DCF
model is based on the Basic DCF. However, by
incorporating the retention rate to the model, the
subjectivity is greatly reduced.
Q. Please explain how the retention rate works
within the DCF model.
A. The retention rate is described as the
percentage of earnings retained by the Company, used for
future investments. The remaining portion of earnings is
paid out as dividends to shareholders. If a company is
expected to retain a portion of its earnings (b), and
expects to earn a return on common equity (r), then its
earnings, dividends, book value and market price would be
expected to grow at the rate of (b*r). From this, we can
derive a new DCF model by replacing the growth rate with
the Company's expected return on equity times its
retention rate:
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Equation No. 1-4
D
Ks = - - - - -+ ( b * r)
Po
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Q. Is this the formula used by the Company in the
Blended DCF model?
A. To an extent, yes. This formula represents a
variation of the traditional DCF using the Company's
return on equity and retention rate. However, as the
Blended methodology uses both the retention rate and the
growth estimates from the analysts at Zacks Investment
Research and Thomson First Call, this formula is combined
with the Basic DCF formula, before being modified to
incorporate the quarterly dividend payment. Thus the
final formula for the Blended DCF methodology that the
Company uses is:
Equation No. 1-5
Do (l+.0625g) (g +(r*b))
K = + -------------
p 2
Where the growth rate and retention rate are averaged
together to form the blend of the two methodologies.
Q. What advantages does the Blended DCF model have
over the Basic DCF model?
A. As previously described, the subjectivity of
the estimates used for the growth rate is reduced to half
of the level of the Basic DCF. Moreover, the blended
methodology is not based on the subjectivity of analysts,
but rather on the earnings and dividends associated with
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each company. While Mr. Gaske used forward looking
values for these variables in his model, the subjectivity
of such numbers are substantially less than an analysts
forecasts, and much more predictable. Take for example
the annual dividend payment from MDU Resources from 2000
to 2015, as shown in the following graph:
.$0 80
.$0 7S
~ $0.70
"" .s:::. V, ,_
<1) 0.. -C: <1)
E > "' 0..
-0 C: <IJ -0 ·;:;
S0.6S
$0.GO
$0.45
0 $0.40
$0.3!)
$0.30
1998
MDU Resources -Annual Dividend Payment 2000 -2015
2000 2002 2004 2006 2008
Vear
~­,, .. ~··
y ::: 0.0249x --19..374
H": 0.9906
2010 2012 2014
.. ···
2016
It is evident that dividend payments have been
steadily rising for MDU Resources over the past ten
years. The regression model, and R2 value of 0.99 shows a
near perfect linear trend in dividend growth, making
future predictions on dividend payments for MDU resources
quite accurate. Rather than relying on the opinions of
analysts, using this type of data from the proxy group of
companies more accurately measures the proxy group's
future growth and the comparable return for Intermountain
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-------------------------------------------------
Gas.
Q. Are there any other advantages to utilizing the
Blended DCF model?
A. Yes. Beyond having more verifiable and
accurate estimates for growth, the Blended DCF model is
also better for estimating long-term growth. That is,
the Value Line forecasts used by both Mr. Gaske and
myself estimate the proxy group's retention rate from
2019 -2021. This approach calculates a more sustainable
growth rate that better reflects the workings of
Intermountain Gas. Mr. Gaske himself describes the
benefits of this approach:
Since these retention rates are projected to
occur several years in the future, they should
be indicative of a normal expectation for a
primary underlying determinant of growth that
would be sustainable indefinitely beyond the
period covered by analysts' forecasts.
Gaske Direct at 23.
Given that Intermountain Gas has not filed a
general rate case in decades, using a sustainable long­
term growth rate more accurately reflects the reality of
Intermountain Gas in that the new rate of return may also
be in effect for many years. Thus, the Blended DCF model
is of primary importance if Intermountain Gas does not
file another general rate case in the near future, as the
Company's return on equity will not be solely based off
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of growth estimates from 3 rd party analysts, but rather as
Mr. Gaske describes, a "cruising speed" that companies
can be expected to maintain indefinitely.
Furthermore, Mr. Gaske states that:
The primary determinants of growth for the proxy
companies will be (i) their ability to find and
develop profitable opportunities; (ii) their
ability to generate profits that can be
reinvested in order to sustain growth; and,
(iii) their willingness and inclination to
reinvest available profits. Expected future
retention rates provide a general measure of
these determinants of expected growth,
particularly items (ii) and (iii).
Gaske Direct at 22.
He continues by pointing out that the level of
earnings and proportion of earnings retained by the
Company is the primary driver in the rate of growth in a
firm's book value per share. As previously stated in my
testimony, stocks are bought for the income they
provide, both gains from dividends and from the eventual
sale of the stock. Therefore, if retention rates are
the primary driver of dividends and the firm's book
value per share, and stocks are bought for both their
dividends and future value, then it is only logical that
the primary driver of both be used to develop the return
on equity.
Q. So you recommend an approach that incorporates
retention rates through the blended methodology?
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A. Absolutely. Incorporating a Blended DCF in
the analysis more adequately reflects the long-term
nature of Intermountain Gas's rate filings, reduces the
impact of the subjectivity and dependence of the 3rd
party analysts in the Basic DCF model, and reflects the
fact that retention rates are the primary driver of
dividend growth and the book value per share, which are
the two primary variables for attracting common equity
investors.
Q. Alright then let us move on. You stated in
the summary of your testimony that you would discuss the
flotation adjustment used by the Company. Can you
please explain what a flotation cost adjustment is?
A. Of course. When a publicly traded company
issues securities in the form of stocks or bonds, the
Company incurs expenses in many forms including, but not
limited to, legal fees, underwriting fees, banking
and/or registration fees. The difference between the
cost of equity before issuance, and the cost of the new
equity is termed the flotation cost. In essence, when
new securities are issued, the existing shareholders'
investments will become diluted . To mitigate this,
flotation cost allowances are applied to the dividend
yield component of the DCF model in order to compute a
fair return on common equity.
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Q. Is the flotation adjustment necessary in this
case even though Intermountain Gas does not issue common
equity?
A. While Intermountain Gas does not issue common
equity directly, it is issued by MDU. So using a
flotation cost is still acceptable. It also serves to
meet the legal obligation to satisfy the Comparable
Earnings Standard of the proxy group of companies.
However, the method the Company has used to incorporate
the flotation cost into both DCF models is
controversial, and does not follow the conventional
methodology.
Q. Can you please explain the flotation
calculation?
A. Absolutely. As previously described in
Equation No. 1-3, the traditional approach to the DCF
model describes the investor's required rate of return
on equity capital as:
Equation No. 1-6
D
Ks =------+ g
P o
If Po is the proceeds per share actually received by the
Company from which dividends and earnings will be
generated, that is, if P o equals Bo or the book value per
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share, then the companies required return is:
Equation No. 1-7
D
r = -----+ g
Bo
The flotation cost percentage (f), and proceeds per
share Bo are related to market price Po as follows:
Equation No. 1-8
P ( 1-f) = Bo
By substituting Equation No. 1-8 into 1-7, we obtain the
following formula, which is the required return adjusted
for flotation:
Equation No. 1-9
D
r = -------+ g
P (1-f)
This equation is the standard equation for flotation
cost adjustments and is referred to as the
"conventional" approach. Its use in regulatory
proceedings is widespread, and the formula is outlined
in several corporate finance textbooks.
Q. Can you please provide an example of how this
computation is used?
A. Yes. Assume a hypothetical widget company
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needs to raise $100 million in common stock at $20 a
share to finance future capital expenditures. If the
underwriting and legal expenses are 4%, and the company
expects to pay out $1 in dividends per share, with a
future growth of 4.25%, then the above equation can be
used to calculate the new cost of equity as follows:
$1
r = -------------+ .0425
$20(1-.04)
= .0945 or 9.45%
Had the company not issued new stock, the flotation
component would not be taken into account, and the
company's cost of equity would have simply been
($1/($20*(1-0%)) + 4.25% = 9.25%.
Q. How has Intermountain Gas applied the
flotation adjustment formula in this case?
A. Flotation costs compensate for the decrease in
proceeds due to expenses associated with issuing stock.
Therefore, it is an adjustment to the stock price. When
looking at Equation No. 1-9 above, it can be seen that
the flotation adjustment needs to be applied only to the
dividend yield component of the formula, and not the
growth component.
In his testimony, Mr. Gaske has applied the
flotation adjustment not just to the dividend yield
component of the formula, but to the entire DCF model.
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By doing so, the general theory underlying the flotation
adjustment is ignored, and the return on equity is
artificially inflated.
Q. Can you provide an example of how this
inflates the return on equity?
A. Yes. Take our previous example of the widget
company where we calculated the cost of new equity at
9.45%. If we apply the flotation adjustment to the
entire DCF, we would obtain the following cost of new
equity:
r =
$1
-----+ .0425) * 1.04
$20
= .0962 or 9.62%
Applying the flotation adjustment to the growth
component of the formula has increased the return on
equity from the previous calculation of 9.45%, to a rate
of 9.62%. Similarly, Mr. Gaske's use of the flotation
adjustment formula artificially inflates the return on
equity by applying the flotation adjustment to the entire
DCF model.
Q. So what do you recommend in terms of the
overall methodology used to calculate the return on
equity?
A. I recommend incorporating a Blended DCF with
the Basic DCF to more adequately reflect the long-term
CASE NO. INT-G-16-02
12/16/16
ROGERS, M. (Di)
STAFF
20
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nature of Intermountain Gas' rate filings, to reduce the
impact of the subjectivity and dependence of the 3rd party
analysts in the Basic DCF model, and to reflect the fact
that retention rates are the primary driver of dividend
growth and the book value per share, which are the two
primary variables for attracting common equity investors.
Furthermore, I recommend applying the flotation
adjustment only to the dividend yield portion of the DCF,
which is the widely accepted conventional approach to
incorporating a flotation adjustment to a DCF.
Q. Do you have any exhibits attached to your
testimony regarding the recalculated DCF's using the
appropriate calculation of the flotation adjustment?
A. Yes, Exhibit No. 107 shows the recalculated DCF
results for both the Basic DCF and Blended DCF, with the
conventional flotation adjustment applied only to the
dividend yield portion of the DCF.
Q.
A.
Does this conclude your testimony?
Yes, it does.
CASE NO. INT-G-16-02
12/16/16
ROGERS, M. (Di) 21
STAFF
Company
Atmos Energy Corporation
Spire, Inc.
New Jersey Resources Corporation
Northwest Natural Gas Company
South Jersey Industries, Inc.
Southwest Gas Corporation
WGL Holdings, Inc.
High
3rd Quartile
2°d Quartile (Median)
151 Quartile
Low
i::33:'.lltTl --. ~ >< ~ ;:,o ~ :!. Revised Company Proposal ::::o'5 z g:
0\ ~ 9 z ·"' z 9 '"OCl'.l-,-~s.o
~~0--.J I --0 0\ ...., b N N
Intermountain Gas Company
Selected Natural Gas Distribution Companies
Staff Revised Basic DCF Calculation
Ticker
ATO
SR
NJR
NWN
SJI
swx
WGL
Dividend
Yield
2.44%
3.11 %
2.80%
3.62%
4.12%
2.72%
2.85%
4.12%
3.36%
2.85%
2.76%
2.44%
Flotation
Cost
Adjustment
1.0400
1.0400
1.0400
1.0400
1.0400
1.0400
1.0400
Dividend Yield x
(1 + 0.625g)
2.64%
3.32%
3.03%
3.86%
4.44%
2.91%
3.10%
4.44%
3.59%
3.10%
2.97%
2.64%
Primary Market:
Expected Growth I Cost of Capital
Rate (g)
6.50% 9.14%
4.56% 7.88%
6.50% 9.53%
4.00% 7.86%
6.00% 10.44%
4.50% 7.41%
7.65% 10.75%
7.65% 10.75%
6.50% 9.99%
6.00% 9.14%
4.53% 7.87%
4.00% 7.41%
9.56%
-3:ntr1 ~. ~ &
;;: ;;<:HI> CT :::::~ z ;::.·
0\ ~ !=) z
rJ} -0 -z.
'1:,Cll -l -
i::i;i s I 0
(JQ ....., C) -.J
(1> -+i '
N -
0 9' ....., 0
N N
Company
Atmos Energy Corporation
Spire, Inc.
New Jersey Resources Corporation
Northwest Natural Gas Company
South Jersey Industries, Inc.
Southwest Gas Corporation
WGL Holdings, Inc.
High
3rd Quartile
2°d Quartile (Median)*
1st Quartile
Low
Intermountain Gas Company
Selected Natural Gas Distribution Companies
Staff Revised Blended Growth Rate DCF Calculation
Dividend Yield Expected Dividend Flotation Cost
X Growth Rate Ticker Yield Adjustment (I + 0.625g) (g)
ATO 2.44% 1.040 2.63% 5.79%
SR 3.11% 1.040 3.32% 4.54%
NJR 2.80% 1.040 3.02% 5.99%
NWN 3.62% 1.040 3.85% 3.66%
SJI 4.12% 1.040 4.39% 4.06%
swx 2.72% 1.040 2.92% 5.17%
WGL 2.85% 1.040 3.07% 6.18%
4.12% 4.39% 6.18%
3.36% 3.59% 5.89%
2.85% 3.07% 5.17%
2.76% 2.97% 4.30%
2.44% 2.63% 3.66%
* Average Return for Proxy Group that must be met for the Comparable Standards Test
Secondary
Market:
Cost of Capital
8.42%
7.87%
9.01%
7.51%
8.45%
8.09%
9.25%
9.25%
8.73%
8.42%
7.98%
7.51%
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF DECEMBER 2016,
SERVED THE FOREGOING DIRECT TESTIMONY OF MARK ROGERS, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR-REGULATORY AFFAIRS
INTERMOUNT AIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: mike.mcgrath(ci),intgas.com
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ci),hotmail.com
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 M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
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 8TH AVENUE
HELENA MT 59601
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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: [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
Natalie.cepak.2(a),us.af.mil
[e-mail]
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE