20210701Reply Comments.pdf

Ms. JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,lD 83720-0074
RE: Case No. INT-G-21-01
Dear Ms. Noriyuki:
Attached for filing in regard to Case No. INT-G-20-01 is an electronic submission of lntermountain
Gas Company's Reply Comments in support of the Stipulation and Sefflement filed on June 3,2021
in this matter.
If you should have any questions regarding the attached, please don't hesitate to contact me at (208)
377-6015.
Sincerely,
A INTERMOUNIAIN'
GAs COMPANY
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June 30,2021
Lori A. Blattner
Director, Regulatory Affairs
lntermountain Gas Company
Enclosure
Mark Chiles
Preston Carter
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Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
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Attorneys for Intermountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOT]NTAIN GAS
COMPAI\"Y'S APPLICATION FOR
APPROVAL TO CHA}IGE
DEPRECIATION AI\D
AMORTIZATION RATES
CASE NO. INT.G-2I.OI
IxrnruvrouNTAlN G.ls CoupANY's
Rrplv Corrurxrs
Intermountain Gas Company ("Intermountain" or "Company") respectfully submits the
following Reply Comments in support of Settlement Comments filed by the Idaho Public
Utilities Commission Staff ("Staff ').
B,c,cxcnouxn
Intermountain filed an application on January 12,2021requesting authority to decrease
its depreciation and amortization rates from a combined 2.97%to 2.S1Yo.Intermountain
contracted with Concentric Energy Advisors ("Concentric") to perform an update of the
depreciation and amortization study filed in Case No. INT-G-17-06. In the Application,
Intermountain stated that the results of Concentric's study indicated that Intermountain's
currently approved depreciation and amortization rates were over-depreciating Intermountain's
assets. Accordingly, in the Application Intermountain requested a decrease in its depreciation
and amortizationrates to 2.55%.
On February 8,2021, the Commission issued a Notice of Application and Notice of
INTERMoI,]NTAIN GAS CoMPANy,S IIEPLY ColnmvTs. I
lntervention Deadline that, among other things, provided notice and a description of the
Application and provided notice of the deadline to petition for intervention in the proceeding.
Order No. 34914.
On February l8,202l,the Commission issued aNotice of Modified Procedure, which,
among other things, provided notice that the case would be processed by modified procedure and
set a comment deadline of June 8,2021. Order No. 34960.
Staff and the Company (individually, "Part5/" or collectively, "Parties") held settlement
conferences on May 20,2021and May 25,2021. As a result of discussions in these settlement
conferences the Parties reached an agreement in principle. On June 3, 202l,Intermountain filed
a Settlement and Stipulation ("Settlement") and a Motion for Approval of Stipulation and
Settlement requesting Commission approval of the Settlement.
On June 14,2021, the Commission issued the Notice of Proposed Settlement and Notice
of Amended Comment Deadlines.
SrrrlrurNT STTPULATToN
The Parties agreed to update the Company's depreciation and amortization rates as
follows:
1. The Parties agree to the depreciation and amortization rates set forth on Settlement
Exhibit No. 1, Col. (o).
2. Settlement Exhibit Nos. 2 and 3 provide the supporting calculations, including the
retirement rate analysis and detailed depreciation calculations, for the plant accoturts that changed
from the original Application as a result of this Settlement, including: Account 363 (including all
the subaccounts listed in Settlement Exhibit No. 3, Pages 2-6), Account 367, Account 376, Account
378, Account 380, and Account 390. The Parties agree that the depreciation and amortization rates
for all other plant accounts should be approved as set forth in the Application.
INTERMOUNTATN GAS COMPANY'S REPLY COIT,NAENTS. 2
3. If approved by the Commission, the rates would reflect an effective combined
depreciation and amortization rate of 2.4lYo ils seen on Settlement Exhibit No. 1, Line 41, Col. (o).
4. The Parties agree that the rates reflected on Settlement Exhibit No. 1, Col. (o), if
approved by the Commission, will be effective as of January 1,2021.
5. The Parties agree that the reduction in accruals, as reflected on Sefflement Exhibit
No. 1, Col. (q) shall be deferred starting on July 1,2023 unless the reduction in depreciation rates
have previously been incorporated into base rates through an Order from this Commission.
IxrnnuouNruu's Supponr FoR TIrE SrrrlrunNT STIpULATIoN
Intermountain believes the Settlement in this case represents a reasonable compromise on
the average service life estimates, rate of projected retirements, and net salvage percentages
included in this case. Intermountain believes the depreciation and amortization rates resulting
from this Sefflement will appropriately reflect the cost of the Company's assets over time. The
proposed Settlement is a reasonable resolution of the issues and is in the public interest.
For all the reasons presented in these comments, Intermountain urges the Commission to
adopt the Settlement submitted in this proceeding as filed, without modification, and to issue an
order authoizing the terms of the Settlement with depreciation and amortization rates effective
January 1,2021.
Dated: June 30, 2021
GIVENS PURSLEY LLP
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Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
Ii.rrERMotrNTaN Ges CotupeNy's REpLy CoMMEI.ms - 3
CERTIX'ICATE OF SERVICE
I certiff that on June 30, 2021, a true and correct copy of INTERMOUNTAIN GAS
COMPANY'S REPLY COMMENTS was served upon all parties of record in this proceeding
via the manner indicated below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idatro Public Utilities Commission
11331 W. ChindenBlvd., Bldg.8, Suite 201-A
Boise,lD 83714
Dayn Hardie
Deputy Attomey General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-4
Boise,ID 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
Dayn.Hardie@puc. idaho. gov
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Lori A. Blattner
INTERMoLTNTAIN Ges CorceNY's REPLY CouurNrs. 4