20170525Answer.pdf

.1 i.i I,,/f. DSEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
rJ !" ,. t,nr ll L'"iU
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.ir'll;-,tl
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY
FOR AUTHORITY TO CHANGE ITS RATES
AND CHARGES FOR NATURAL GAS
SERVICE IN THE STATE OF IDAHO
CASE NO. INT.G.16.O2
COMMISSION STAFF'S
ANSWER TO INTERMOUNTAIN
GAS COMPANY'S PETITION
FOR RECONSIDERATION
The Commission Staff, pursuant to Rule of Procedure 331.05, files this Answer to
Intermountain Gas Company's Petition for Reconsideration. IDAPA 31.01.01.331.05.
Intermountain Gas (lntermountain or Company) filed its Petition for Reconsideration (the
Petition) on May 18, 2017, asking the Commission to reconsider parts of its Final Order No.
33757, issued April 28, 2017. The Commission Staff files this Answer to address Intermountain
Gas Company's Petition as it relates to weather normalization only.
The Commission Should Grant Reconsideration andAllow a Limited Re-Opening of the
Record os to Intermountain's Issues Concerning Staffs lYeather Normalization Analysis
Intermountain's Petition asks the Commission to reconsider its decision to use Staff s
weather normalization analysis to adjust for weather in the Company's rates. Specifically, the
Company asks for reconsideration of Stafls definition and use of the term "normal" weather,
and, more generally, the Petition asks the Commission to reconsider the underlying
reasonableness of Staff s weather normalization methodology.
The Petition states that Staff used "only 13 years and 8 months of weather data to
define Normal weather for the Company, and did not use the industry best practice of 30 years of
COMMISSION STAFF'S ANSWER
TO INTERMOUNTAIN GAS COMPANY'S
PETITION FOR RECONSIDERATION
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weather data." Petition at 2. However, Staff maintains that after an extensive and arduous
process of informal communication(s), meetings, a series of formal discovery requests and
responses, and the technical hearing, the Company failed to provide the full 30-year range of
weighted weather data it claims it has used and which would have allowed Staff to undertake the
analysis that the Company asserts Staff should have done. The information is simply not in the
record before the Commission.
The Company defines its'oNormal weather" in Exhibit 40, stating, "Intermountain['s]
Rolling 30-year Normal is the 30 years ended [sic] December 2015. The HDD data for 7
weather stations is weighted by 2015 customers resulting in a weighted Normal for each
customer class." See Exhibit 40 at 3 (emphasis added). While the Company provided some
relevant workpapers and documentation related to weighted weather data through informal
communication and in obligatory ongoing discovery, it failed to provide all of the relevant data
that would have allowed Staff to reasonably and responsibly reproduce the "weighted Normal for
each customer class." Id. Critically, even a reasonable narrative explanation of how the
Company uses its weather nornalization data was not provided until post-discovery in rebuttal
testimony filed approximately two weeks before the technical hearing in this matter. However,
even at that late stage, the Company did not provide the underlying documentation or o'facts upon
which [its analysis was] based," for Staff to analyze its reasonableness. See IDAPA
31.01.01.052.01 and ldaho Code $ 61-4011.
The Company had 31 years to "refine its weather normalization methodology"2 and
roughly 9 months from its Application to the technical hearing in this case, to provide all
relevant documentation, that is, any and all documentation to demonstrate the link between the
Company's methodology and its proposed adjustment. Such documentation would have enabled
Staff to evaluate the Company's weather normalization methodology, and, therefore, aid the
Commission in determining the methodology's reasonableness and appropriateness. The
Company has failed to show that it provided such necessary documentation to Staff. The
1 "Every public utility shall fumish to the commission, in such form and such detail as the commission shall
prescribe, all tabulations, computations and all other information required by it to carry into effect any of the
provisions of this act . . . ."
2 See Order Nos. 21048 and33757
COMMISSION STAFF'S ANSWER
TO INTERMOI.JNTAIN GAS COMPANY'S
PETITION FOR RECON SIDERATION 2
Company's insistence that it did so is belied by the record and is thus an unreasonable burden on
the Commission's time.
As to the general reasonableness of the Commission-approved weather normalization
adjustment in this case, Staff again asserts that the full spectrum of relevant "[w]orkpapers or
documentation showing how test year [weatherJ data was adjusted," (see IDAPA
31.01.01 .I2l.}l.f (emphasis added)), was never provided to Staff in a cohesive or fully
comprehensible format. This lack of clarity is reflected in the record before the Commission. As
a result, in order to make a showing of reasonableness, Staff used what data, documentation and
information the Company did provide to model Staffs own weather normalization adjustment.
Absent any other data, Staff believed that the provided data was what the Company had used.
Staff maintains that its methodology is reasonable and appropriate under the facts, and given the
circumstances, of this case.
Staff Recommendation
As an initial observation, Staff believes that a potential best outcome for resolution of
the issues raised in the Company's Petition would be for the Company to retract its Petition and
file a separate docket addressing weather normalization. This would allow greater finality to the
many other issues addressed in Order No. 33757. It would also enable the Company to establish
a clearer, cleaner record, now that weather notwtalization concerns have been distilled through
the Company's rate case. Staff believes a separate and focused proceeding to address the
weather normalization issues raised in this case may also facilitate communication, and
potentially encourage stipulation, between the parties. Staff further believes such a process
would best assist the Commission in determining a reasonable and appropriate weather
normalization methodology.
Specifically, as it relates to the Company's Petition, Staff would agree to assist in
clarifying the Commission's understanding of the weather normalization issues and StafPs
efforts to analyze those issues during the pendency of this case. In order to do so, Staff
recommends that the Commission re-open the record for the limited purpose of accepting such
records already provided through discovery requests and responses to date, related to weather
normalization, which would illustrate Staffs efforts to analyze and present a reasonable and
appropriate weather normalization adj ustment.
COMMISSION STAFF'S ANSWER
TO INTERMOUNTAIN GAS COMPANY'S
PETITION FOR RECON SIDERATION 3
For this, Staff recommends that each party identiff the records (already provided by a
party in discovery) they believe are necessary for the Commission to make a fully informed
decision on reconsideration related to the provision of certain weighted data from the Company
to Staff, and more generally, regarding the appropriateness of Staffs weather normalization
analysis and modeling. Staff further recommends that interested parties should provide written
briefs or comments outlining their arguments on the issue.
Finally, Staff disagrees with the Company that additional testimony or evidentiary
hearings are needed for the Commission to render a decision on the Company's Petition. The
Company did not timely submit the required documentation in this proceeding. Although Staff
believes such documentation would be appropriate in a separate case, as suggested above, Staff
objects to the Company's effort to submit such evidence in the record on reconsideration, where
such records should have been provided at or before hearing.
Respectfully submitted this 25n day of May 2017.
Sean Costello
Deputy Attorney General
N:INT-G-16-02 sc Staff Answer to Reconsideration
COMMISSION STAFF'S ANSWER
TO INTERMOUNTAIN GAS COMPANY'S
PETITION FOR RECONSIDERATION 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF MAY 20T7,
SERVED THE FOREGOING COMMISSION STAFF'S ANSWER TO
INTERMOUNTAIN GAS COMPANY'S PETITION F'OR RECONSIDERATION, 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 83707
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE TD 83702
E-MAIL .com
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
IOOI SW 5TH AVE STE 2OOO
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
tbrooks@cablehuston. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1OI5 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 : mcc@siv enspursley. com
F DIEGO RIVAS
NW ENERGY COALITION
I IOI 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
PETER RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL : [e-mail]
sre sfari chard sonadams. com
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 173 I
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 I
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. I @us.af.mil
Natalie. cepak.2 @,us.af.mil
Thomas.iernisan.3(Dus.af.mil
Ebony. pa).ton. ctr@us. af. mi I
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
195I S SATURN WAY
STE 1OO
BOISE ID 83709
E-MAIL: [e-mail]
ANDREW J I.JNSICKER MAJ USAF
AFLOA/JACE-ULFSC
I39 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL : [e-mail]
SECRETARY
CERTIFICATE OF SERVICE