20170209Corrected Terry Direct.pdf

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MEMORANDUM
PARTIES OF RECORD
COMMISSION SECRETARY
FROM: SEAN COSTELLO
DATE: FEBRUARY 8,2017
SUBJECT: DIRECT TESTIMONY OF JOSEPH TERRY, EXHIBIT 103
CASE NO.INT.G-I6.02
Please find enclosed the Revised Direct Testimony of Joseph Terry in INT-G-16-02,
including revisions to Exhibit No. 103. The following are summaries of the revisions:
l. Staff made an effor related to income tax. The tax effect on net income was not
calculated. Thus, a formula error on StaffExhibit No. 103 has been amended to properly
reflect income ta< changes related to Staff s proposed adjustments (see Revised Exhibit
103);
2. The Company made an error related to depreciation. The Company provided corrections
in its Amended Response to Staff Production Request No. 178. Staff has audited the
depreciation correction and believes it to be reasonable (see Revised Terry Direct at 8-9);
3. The Company made an error in the treatment of Investment Tax Credits (ITCs). The
Company did not amortize ITC in its Application. The Company subsequently provided
a correction in its Amended Response to Staff Production Request No. 178. Staffhas
audited the ITC amortization and believes it to be reasonable (see Revised Terry Direct at
9); and
4. Staff believes a change to its testimony related to bank fees is warranted. Additional
information was obtained and analyzed by Staffduring discovery related to annualized
bank fees. As a result of this review, Staff has removed its initial bank fee adjustment.
Specific details are provided in the enclosed Revised Direct Testimony of Joseph Terry and
Exhibit 103.
As a result of these changes in revenue requirement certain calculations undertaken by Staff
in prefiled testimony have also changed. However, Staff s underlying proposals and
conclusions-specifically customer charges proposed by Staff witness Bentley Erdwurm and
cost of service allocation proposed by Staff witness Michael Morrison-have not changed.
472 West Washington Stseet Boise lD 811702
Ielephone: (208) 334-{13fl1 Facsimile (208} 334-376'2
Staff would also like to notiff the Parties that two Staff members who previously provided
direct testimony in Case No. NT-G-16-02 are no longer employees of the State of Idaho, and,
therefore, are not available to provide or sponsor further testimony in this case. As a result,
going forward, the Direct Testimony of Mark Rogers will be sponsored by Terri Carlock, who is
already a witness in this case, and the Direct Testimony of Barb Romano will be sponsored by
Staff member Donn English.
Please do not hesitate to contact me if you have any questions regarding these changes.
Sean Costello
Deputy Attorney General
Intgl 6.2 partics letter
472 West Washington Stseet Boise lD 8117(12
Telephone: [phone] Facsimile: (2m) 334-3762
BEFORE THE
TDAHO PUBLIC UTILITTES COMMISSION :'- r i
IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION TO
CHANGE ITS RATES AND CHARGES
FOR NATURAL GAS SERVICE.
cAsE NO. !NT-G-16-02
REVISED DIRECT TESTIMONY OF JOSEPH TERRY
IDAHO PUBLIC UTILITIES COMMISSION
FEBRUARY 8, 2017
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0. Please state your name and business address for
the record.
A. My name is .Toseph Terry. My busj-ness address
is 472 West Washington Street, Boise, Idaho.
A. By whom are you employed and in what capacity?
A. I am employed by the fdaho Public Utilities
Commission as a Seni-or Auditor.
O. What j-s your educational and professional
background?
A. I graduated from Boise State University with a
bachelor's degree j-n accounting in 2OO7 . I have worked
with the Commission si-nce 2}]-l and in that time have
worked on several rate cases, includlng United Water,
Rocky Mountain Power, and several small waEer company
cases.
O. What. is the purpose of your testimony?
A. The purpose of my testimony is to present
Staff's recommended revenue requirement for Intermountain
Gas Company (tne Company, Intermountain Gas). In it, I
will provide an overview of each of Staff's adjustments
to the Company's proposed expenses, rate base, and rate
of return. I also will detail adjustments to: (1)
reflect an update to the Company's forecasted test year,
which the Company provj-ded through a response to a
production reguest; (2) adjust salary expenses for
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nonunion employees; (3) remove the profit sharing portion
of the Company's retirement plan; and (4) reclassify part
of the Customer Service Center to plant held for future
use.
O. Are you sponsoring any exhibits with your
testimony?
A. Yes, I am sponsoring Staff Exhibit Nos. l-03
(Summary of Staff's Recommendation), L04 (Comparison of
Wages Nationwide to Idaho), 105 (Schedule Supporting
Salary Adjustment), and l-05 (Schedule of Customer Service
Center Plant Held for Future Use).
STAFF'S RECOMMENDED REVENUE REQUIREMENT
O. What is Staff's recommended revenue requJ-rement
increase for the Company?
A. Staff recommends a revenue requirement increase
of $4,884,066, or approximately 1,.92. Thls amount is
$5,281-,634 less than the Company's proposed increase of
$1-0, 165, 700 . See Exhibit No. L03, Column 10 .
OVERVTEW OF STAFF'S RECOMMENDED AD,IUSTME}iIIIS
O. Please outline Staff's recommended adjustments
to the Company's proposed revenue requirement components,
and identify who will testify about each adjustment.
A. Proceeding from left to right, Exhibit No. 103
sets forth the Company's proposed revenue requiremenL as
modified to reflect an updated forecast that the Company
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provided through discovery. The exhibit then specifies
Staff's recommended adjustments to each of the Company's
proposed revenue requj-rement components. The exhibit
then concludes with Staff's ultimate recommendations as
to each component, and the overall revenue requirement
increase.
Tracking through the exhibit,
"Column/Adjustment A," adjusts the Company's proposal to
reflect actual expenses and rate base t.hrough September
30, 201-6 and an updated three-month forecast that the
Company provided through dJ-scovery. The next Column
provides an adjustment for an error the Company
discovered with its asset reEirements, as well as an
adjustment for Investment Tax Credits.
Adjustment 2 decreases the Return on Equity
from 9.9* to 9.252. Staff wj-tnesses Rogers and Carlock
will testify in support of this adjustment.
Adjustment 3 removes working capital from the
rate base calculation. Staff witness Carlock will
testify in support of this adjustment.
Adjustment 4 adjusts nonunj-on salary expense.
I will testify in support of this adjustment.
Adjustment 5 removes the 1? profit sharj-ng
contribution to the Company's retirement plan that j-s
based on target profitability. I will testify in support
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of this adjustment.
Adjustment 5 removes plant-in-service
associated with the Customer Service Center. I will
test,ify in support of this adjustment.
Adjustment 7 is a series of adjustments
supported in Staff witness Romano's testimony.
Adjustment I removes some expenses arising from
injuries and damages. Staff witness Romano will testify
j-n support of this adjustment.
Adjustment 9 is the normalization adjustment.
Staff witness Morrison will testify in support of this
adjustment.
STAFF POSITION ON THE TEST YEAR
O. What test year did the Company propose in this
case?
A. In its Applj-cation, which the Company filed on
August J-2, 201-5, the Company proposed a 2Ol5 test year
consisting of six month of actual results (.Tanuary 1,
201,6 to ,fune 30, 2075) and six months of forecasts (.futy
t, 2016 to December 3L, 201,5) .
O. Do you have concerns with the use of forecasts
in this case?
A. Yes. Other than the need to set rates on
actual, verifiable numbers, the flaw with the use of
forecasts is that it is impossj-bIe to know j-f a forecast
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is accurate until after the forecast period has passed
The Commission recognized this concern in Order No
29838, p. 7 (UWI-W-04-04), where the Commission stated
To facilitate an adequate review, Companydata should be provided in time toincorporate the information in the prefiledtestimony of Staff and other parties. Thiswill facilitate the hearing and decisionprocesses by having simil-ar time period andinformation for Staff and intervenor prefiledtestimony, the Company's rebuttal, and at thehearing. Using recent, actual data for thehearing will reduce if not eliminate the need
t.o argue over forecasts.
O.
Staff take
forecasts?
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A. Yes. On November 2, 20L5, Staff served the
Company with Production Request No. :-.78, which asked the
Company to provide actual data by FERC account as of
September 30, 2015, along with updated forecasts for
October, November, and December. The Company responded
to this request on November 23, 201-6, producing an
updated test year data with actual expenses and rate base
through September 30, 20L5, and providing new forecasts
for the remaining three months of the year. Staff has
used t.his update as the basis for its test year revenue
requirement.
We have several Production Requests that were
specj-fically considered to be continuing requests for
In light of the Commission's prior remarks, did
any action with regard to the test year
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updates to be received as the information was completed,
but the only information we received prior to November 23
that, included data past September 30, 201"6, is Company
Response to Production Request No. 155 referencing salary
information.
O. What impact did the September 30, 20t5 update
have on the Company's case?
A. This update reduces the Company's overall
request by $574,21"4 as shown on Exhibit No. 103,
Adjustment L, line 43.
O. Does this adjustment raise any concerns with
respect to expenses and rate base items that the Company
forecast through September 30, 201-6?
A. Yes. In certain areas, one would expect the
Company's update - which provided the Company's actual
expenses and rate base through September 30, 201-5 - to be
extremely close to Company's forecast for this period as
expressed in the Application. But the updated actuals
revealed that the Company's forecast was somewhat. less
accurate in these areas than would be expected.
O. Please provide some examples where the
Company's forecast should have been close to the updated
actuals, but was not.
A. The Company's forecasted amounts for plant-in-
service should have been close to t,he updated actual
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numbers. But the update revealed that the largest
forecast inaccuracy, ln either expenses or rate base, was
in the Company's forecast for plant-in-service.
fntermountain Gas is a Loca1 Distribution
Company (LDC) and, therefore, most of its plant-in-
service is gas distribution plant and these projects
should be easier to forecast. Additionally, accumulated
depreciation is a calculation based on current plant-in-
service. Plant-in-service and accumulated depreciation
are both based on the L3-month average. That means that
any adjustment later in the test year will have a
proportionally lesser effect on the rate base. Both the
plant-in-service and accumulated depreciation forecasts
were reduced by similar amounts, which respectively
lowered the amounts in those accounts by $f ,2L6,587 and
$1,308,528. Depreciation expense is reduced by $258,492,
which was the third largest operatj-ng expense adjust,ment.
a. Were there any other Company forecasts that
departed from the actual updated numbers?
A. Yes. Administrative and General Expense is
another category that should be a relatively constant
number, a,s these expenses are normally ongoing costs for
a company. But fntermountain's Administrative and
General Expense was the largest of all the expense
categories be updated. This creaLes some doubt about the
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accuracy of the Company's forecasting methodology.
a. Does Staff propose an adjustment to the
Company's forecasted expenses for October - December
20]-6?
A. Yes. Adjustment 4 adjusts salaries and
incorporates a reduction to the Company's forecasted
annual salary expense. In addition, Adjustment 7 (which
j-s supported by Staff witness Romano) incorporates a
reduction to the Company's forecasts for specific
expenses related to Sales and General Advertising, along
with mj-scellaneous expenses discovered during Staff
witness Romano's review of the Company's Management
Expense Reports. fn light of the Company's updated
adjustment to actuals, and the new forecast, Staff has
not proposed any further adjustments for the October to
December, 2015 period because such adjustments would only
minimally impact the Company's proposed revenue
requirement.
O. Were there any other adjustments made to
expenses and rate base after the init,ial update?
A. Yes. In 2015, the Company implemented new
depreciation rates as a resul-t of Order No. 33260 in Case
No. Int-G-L4-02. At the conclusion of the case, the new
depreciation rates were entered into the Company's
financial accounting software, but the auto-retirement
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dates for the amortizable assets were not updated. This
caused an over-depreciation of amortizable assets that
were set to retire in 2015 and 2015. The Company
notified Staff of the error and corrected it in its
Amended Response to Production Request No. l-78.
a. Were there any other parts to this adjustment?
A. Yes. Additionally, in its filing, the Company
included the fu11 value of Investment Tax Credits rat.her
than amortizing them over the life of the assets as
required by IRS Section 46(f) (2). Failure to normalize
the t.ax credits could result in the loss of the credits
to the Company.
O. Was there any part of this adjustment that is
not included in your exhibit?
A. Yes. The Company included $6,245 in cash
working capital. I did not. include this, because witness
Carlock is proposing to remove all cash working capital
from rate base. The effect on revenue requj-rement was
minor, lowering it by an additional $773 than the Company
supplied adjustment.
O. What j-s the overall effect of the September 30
updates?
A. These updates increased net j-ncome by $712,976,
and increased rate base by $S85,660, for a total decrease
in revenue requirement of $1,143,113.
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O. Does Staff recommend an adjustment to the
Company's forecasted rate base?
A. No. In fj-ve of the previous six years before
20:..6, the Company fail-ed to spend its entire capital
budget. On average, the Company has over-budgeted by
9.88? duri-ng that time frame. Because of this over-
budgeting, including the Company's budgeted amounts in
rate base may artificially increase the return on capital
that customers pay through rates without any guarantees
that rate base is accurate or that plant is actually used
and useful.
That said, Staff does not recommend that the
Commission adjust the Company's forecasted rate base.
Staff reviewed the Company's forecasted capital expenses
for October through December. While Staff cannot accept
the Company's forecasts as accurate, doy adjustment made
to additional plant placed j-n service late in the year
has a very minimal impact on the Company's revenue
requJ-rement. Because the Company used a 13 -month averagie
rate base, dny adjustment to plant in service in December
only reduces rate base by t/13Eh of that amount because it
would only be j-n service for one month out of the test
year. Staff calculated the impact of a five percent
reduction to the Company's capJ-ta1 expense for the fourth
quarter of 201,6, and it reduced the Company's revenue
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requirement by less than 1/1008h of a percent. While
Staff does not support the use of forecasts, the impact
in this case is minimal. Therefore Staff does not
propose an adjustment to the remaining three months of
forecasted rate base.
STAFF'S POSTIION ON SALARIES
O. What are the initial concerns dealing with the
salary 1eve1s in this case?
A. Salary expense is the Company's third largest
expense category. This is not a concern per se, but due
diligence is required to review this category. I note
that, when compared to the only other LDC in the sLate,
Avista Corp, the Company's labor cost as a percentage of
total revenue was higher; 7.05? vs 4.75+.
O. Does the Company's salary expenses apply to
different classes of employees?
A. Yes. About half of the base salary expenses
are related to nonunlon employees and half to unj-on
employees.
a. Did you evaluate the union salary separately
from the nonunion salary?
A. Yes. Union employees have a set contract
the salary amountssetsnegotiated with the Company that
over a period of time. This is
negotiation, and the transaction
arm's length
separate from the
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Company operat,ions.
O. Has the Company provided any analysis of
salari-es?
A. Yes. In its Confidential Response to
Production Request No. 66, the Company provided a wage
study performed by Aon Hewitt.
0. Did you have any concerns with the study's
conclusions?
A. Yes. The Aon Hewitt study minimizes the
effects of regional markets on salaries. For example,
the study states that Idaho is approximately 90t of the
national average. On the other hand, I performed an
analysis based on data from the Bureau of Labor
Statistics (BLS) that shows, ofl average, for all
occupations, Idaho is 84.462 of the national average.
And my sampling of 1ikeIy professions (See Exhibit No.
104) shows that Idaho is 86.68? of the natj-ona1 average.
Both of these Idaho-based averages are lower than the 90*
of average stated in the Company's study from AON Hewitt.
Yet on page 3, the study suggests the Company not apply
geographic dif ferentials .
O. Do you have your own proposal for analyzing the
Company's salary Ieve1s?
A. Yes. The Aon Hewitt study recommends utilizing
surveys by Towers Watson and Mercer, two human resources
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consulting groups. I propose adding the BLS data from
the most recent year as a third data point. Using all
three surveys provides information on industry averages
while accounting for regional pricing.
Towers Wat.son and Mercer annually surveys
employment characteristics, including salary costs, on a
nationwide scale. In addition, these two surveys
separate industries to create industry-specific
information. For the Towers Watson and Mercer surveys, I
used the 50? percentile (which was the stated goal in the
Aon Hewitt study). Both surveys provide differing
information based on the Ieve1 of expertise provided by
some employee classj-fj-cations. For example, there is a
different wage for an entry leve1 financi-aI analyst and
an analyst with more experience or expertise.
On the other hand, BLS survey data generally
does not differentiate between classes j-n one employee
classification, except by using different percentiles in
a classifj-cation. Therefore, in the BLS data, I used the
75Eh percentile. This also helps reflect the long tenure
that InLermountain Gas tends to have with its employees.
O. How did you determine t.he classificat.ions?
A. In some cases, the Company provj-ded the
classificatj-on it has used in the past. Tn others, I
used the job description provided in the Response to
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Production Request No. 8, and compared that with the job
descriptions in the surveys.
Some classifications were not readily
comparable to one of the categories provided in these
individual surveys. In those instances, as opposed to
making assumptions that could be incorrect, f did not
include them in this analysis.
O. How many classifications were included for your
analysis?
A. For the Towers Watson survey, I used 21
classificat,ions. For the Mercer survey, I used 19
classif icat j-ons. And for the BLS survey, 24
classifications.
O. What were Lhe results of your analysis?
A. For the Towers Watson data, f found that the
Company's base salary was above the j-ndustry average in
some employee classifications and below average in
others. Overa11, compared to the Towers Watson Survey
the Company was above industry average by $aa7,270. See
Exhibit No. 105, Column 5, line 25.
fn nearly every employee classifj-cation in the
Mercer survey, I found the Company was below the industry
average. This totaled to $354,326. See Exhibit No. 105,
Column 7, lj-ne 26 .
For the BLS data, f found that the Company's
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base salary was similar to the Towers Watson data in that
some employee classifications were above the industry
average and below in others. Overa11, compared to the
BLS survey the Company was above industry average by
$384 ,'774 . See Exhibit No. 105, Column 8, line 26 .
O. How did you calculate your recommended
adjustment for salary expenses?
A. My analysis produced three different results
depending on the survey. My purpose in usJ-ng all three
surveys was to have all of them weighted agai-nst each
other to achieve a more accurate result. Because the
Mercer and Towers Watson surveys omit regional pricing
data, I recommend weighting the BLS data double. Doing
so would reduce salary expense by $21-3,123. See Exhibit
No. 105, Column 8, line 28. After gross up, this would
reduce the Company's proposed revenue requirement by
$214 , 296. See Exhibit No . 103 , Column 4 , lj-ne 43 .
STAFF POSITION ON RETIREMENT BENEFITS
O. Please describe the retirement benefits the
Company offers to its employees.
A. For nonunion employees, the Company offers a
tradj-tional 401(k) plan in which the Company matches 50?
of an employee's contribution up to the first 52, for a
maximum employer match of 3?. Additionally, the Company
contrj-butes 5? of income for all eligible employees,
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regardless of whether or not the employee voluntarily
contributes to the 401 (k) . The Company also contributes
an additional 1Z in profit sharing if the Company reaches
its profitability target.
Union employees participate in a multi-employer
pension plan through the United Association of ,Journeyman
and Apprentj-ces of the Plumbing and Pipe Fitting Industry
of the United States and Canada (Locals 295 and 548).
InLermountain Gas pays a negotiated amount per each hour
paid to a union employee based on the funding status of
the p1an. The hourly amount is open for renegotiation
during the month of August within any contract year.
O. Do you accept the 1eve1 of retirement benefits
offered by the Company as reasonable?
A. With the exception of the 1? profit sharing
contribution mentioned above, I accept the Company's
retirement benefits package as reasonable and comparable
to other utilities serving ldaho and the region.
O. Do you propose an adjustment to remove the LZ
profit sharing contribution?
A. Yes. Employee payments or benefits that are
based on crj-teria that are not properly aligned with the
interests of customers should be removed from rates. The
Commission, and other Idaho utilities, have a long
standing precedent of removing from customer rates
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employee benefits that are based on shareholder value.
Intermountain Gas has already removed from its revenue
requirement the portion of the employee incentive plan
that is awarded if net income targets are met. The
Company should have also removed the portion of it,s
retirement. benefits package t,hat is provided to employees
for creating additional shareholder value. tty adjustment
removes $90,105, the amount the Company has accrued for
this benefit, from the Company's case. This adjustment
reduces the Company's overall revenue requirement request
by #90,602 as shown on Exhibit No. 103, Column 5.
STAFF POSITION ON CUSTOMER SERVICE CENTER ADiIUSTMENT
a. Please describe the analysis that went into
reviewing the Customer Service Center.
A. By way of background, as stated by Company
Witness Chiles the customer service center was buil-t in
201-0 in Meridian, ID to consolidate customer service,
credit and collect.ions, customer development and
programs, and scheduling for all the brands. Initially,
I reviewed the allocation manual- and also reviewed
entries for the total costs and the cost allocated to
Intermountain Gas. From there f went on site and viewed
how the new Oracle Customer Care and Billing (CC&B)
system worked and revj-ewed a sample of calls made. I
also reviewed the training methodology as well as the
CASE NO
REVISED
rNT-G- 1,6-0202/--/tt TERRY, ,f
STAFF
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Company's method for forecasting the number of calls to
establish proper staffing 1eve1s.
a. Where there any concerns from this analysis?
A. There was one primary concern. When on the
tour of the building in whj-ch the Customer Service Center
is housed, I observed that there was a large section of
the building that was empty. Discussions with Company
witness Chiles indicate approximately one third of the
building is currently not in use at this point in time,
and is not wired for expansion. This portion of the
building is only heated above t.he leve1 needed to keep
the pipes from freezing in the winter. In addition, the
Customer Service Center has been lowering employee head
count over the 1ast. several years as stated in Company
witness Chiles' testimony on page 5.
O. Did Intermountain Gas give a reason for the
unused space in the Customer Service Center building?
A. Yes. Mr. Chiles stat.ed that when the Company
designed the building in which the Customer Service
Center is housed, one of the Company's goals was to have
the building be Leadership in Energy and Environmental
Design (LEED) certified. The Company found j-t would be
less expensive to build the ent.ire facility to be LEED-
certified than to build only the Customer Service Center
part of the building as LEED certified, and then expand
CASE NO. INT-G-L6.02
REVTSED 02/--/tt
TERRY, .J
STAFF
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into the new area if needed. I verified that the
building in which the Customer Service Center is housed
was LEED certified in 201-0.
O. What is your recommendation?
A. I recommend that t.he portion of the plant-in-
servj-ce associated the unused building space be removed
from plant-in-servj-ce and placed into plant-held-for-
future-use and not included in rates. This would also
remove that portion of the depreciation from the revenue
requirement.
a How do you propose calculating this adjustment?
A. Using the Company's Response to Production
Request No. 139, I found that the amount of net book
value of the building and the land used for the Customer
Service Center is $5,5L5,255, and the depreciation
associated with t,he building is *83,407. See Exhj-bit No.
106, lines 4 and 8. These costs are allocated based on
number of customers and Intermount.ain Gas' percentage is
34.62. See Exhibit No. 105, line ]-6. The amounts
allocat,ed to Intermountain Gas is $L,942,8'7 8 in book
value and $28,859 in depreciation. See Exhibit No. 105,
lines 5 and 8. Because one third of the building is
currently not being used, I recommend that one third of
Intermountain's share of t,he building and land's net book
va1ue, or i647,625, be removed from rate base. Further,
CASE NO
REVISED
rNT-G-L6-02
02/--/tt
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STAFF
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one third of Intermountaj-n's proposed depreciation for
the building, or #9,520, should be removed from
depreciation expense. See Exhibit No. 105, lines 10 and
l-1. My recommended adjustments would reduce the
Company's proposed revenue requirement by $86,487. See
Exhibit No. 103, Adjustment 6, Ilne 43.
O. Does this conclude your direct testimony in
this proceeding?
A. Yes, it does.
CASE NO. INT-G-l.6-02
REVTSED 02/ --/tt
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STAFF
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Case No. INT-G-16-02
J. Terry, Staff
02/08117
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Case No. INT-G-16-02
J. Terry, Staff
l2/16/r6
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CASE NO. INT.G.I6.O2
EXHIBIT NO. 105 PREPARBD AND SPONSORBD
BY JOSEPH TERRY
IS
CONFIDBNTIAL AND ONLY AVAILABLE TO THOSE
PERSONS WHO HAVE SIGNED PROTECTIVE AGREEMBNTS
Confidential Exhibit No. 105
CaseNo. INT-G-16-02
J. Terry, Staff
t2lt6lt6
No
Line
5 Plant Allocation
6 rGC
7 Depreciation
8 rGC
Book Value
5,615,255
(647,6261
(9,620)
Allocation Factor
354,324
332,506
273,0L2
959,842
83,407 34.60%
Assets that are Partly Held for Future Use
Description Net Book Value Dep Rate
Building - Project (390) 3,610,700 2.37Yo
Land (389) 2,004,555 0.00%
5,515,255
1
2
3
4
Allocation %
34.60%
Annual Dep
83,407
83,407
Amount Allocated to IGC
L,942,878
9
10
11
Adiustment
Rate Base
Depreciation
Gustomer Counts
MDU Electric, Gas, Combo
rGc
CNG
Total
28,859
t/3 of book value allocated to IGC
Yo
36.90Yo
34.60%
28.40%
72
13
74
15
16
ExhibitNo. 106
Case No. INT-G-16-02
J. Terry, Staff
t2/16/t6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY oF FEBRUARY 2017,
SERVED THE FOREGOING REVISED DIRECT TESTIMONY OF JOSEPH
TERRY, 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 TD 83707
E-MAIL: [e-mail]
Confi dential Information
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N 17TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
Non-Confi dential Information
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1OO1 SW 5TH AVE STE 2OOO
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
tbrooks@cablehuston. com
Confidential Information
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
C onfidential Information
RONALD L WILLIAMS
WILLIAMS BRADBURY
IOI5 W HAYS ST
BOISE ID 83702
E-MAIL: ron@williamsbradbur)r.com
Confi dential Information
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
Confidential Information
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: mcc@ sivenspursley. com
Non-Confi dential Information
F DIEGO RIVAS
NW ENERGY COALITION
I IOI 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
Non-Confi dential Information
CERTIFICATE OF SERVICE
PETER zuCHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL : [e-mail]
gre [e-mail]
Confi dential Information
KEN MILLER
SNAKE zuVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
Non-Confi dential Information
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
I39 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL : lanny.zieman. I @us.af.mil
[e-mail]
Thomas j emi gan. 3 @us. af.mil
Ebony. payton. [e-mail]
Non-Confi dential Information
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
I95I S SATURN WAY
STE lOO
BOISE ID 83709
E-MAIL : [e-mail]
Confi dential Information
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
I39 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL : [e-mail]
Non-Confi dential Information
Y
CERTIFICATE OF SERVICE