20200512Intermountain Gas Comments.pdf

INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 1
Preston N. Carter, ISB No. 8462 Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702 Telephone: [phone] Facsimile: [phone] [e-mail]

Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF DEFERRED ACCOUNTING OF INCREMENTAL COSTS ASSOCIATED WITH THE
COVID-19 PUBLIC HEALTH EMERGENCY
INTERMOUNTAIN GAS COMPANY’S
COMMENTS
Intermountain Gas Company (“Intermountain” or “Company”) in response to the Notice
of Application and Notice of Modified Procedure issued in Order No. 34643, respectfully
submits the following comments.
BACKGROUND
On March 13, 2020 Idaho Governor Brad Little issued a Proclamation declaring a state of
emergency and providing directives to combat the spread of COVID-19, provide essential
services and limit public exposure. Following this emergency declaration Idaho Power
Company, PacifiCorp D/B/A Rocky Mountain Power, Falls Water Company, Gem State Water
Company, and Avista Corporation D/B/A Avista Utilties, collectively the “Utilities”, applied to
the Idaho Public Utilities Commission (“Commission”) for orders authorizing them to account
for the unanticipated, COVID-19 emergency-related expenses by booking them as regulatory
assets for possible recovery through rates that would be set in future proceedings. The requested
deferrals do not seek to increase rates at this time.
RECEIVED
2020 May 12PM2:48
IDAHO PUBLIC
UTILITIES COMMISSION
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 2
The Commission decided during its April 14, 2020 open meeting to open a generic
docket and consolidate all the utility cases into it for purposes of issuing a single order that
would apply to each of the utilities that had filed applications. The Commission also specified
that, besides Avista, Idaho Power, PacifiCorp, Falls Water, and Gem State Water, any utility that
submitted timely comments in the case requesting deferred accounting treatment would be
eligible for any deferred accounting treatment authorized by the final order in this case.
Order No. 34643, issued on April 23, 2020 set a comment deadline of May 14, 2020 for
“other utilities who wish to have their Emergency-related deferred accounting authority decided
in this case.” Id.2
COMMENTS
Intermountain submits comments in support of deferred accounting treatment for
incremental costs associated with the COVID-19 public health emergency. Since March 13, 2020
when Idaho Governor Brad Little issued the Proclamation declaring a state of emergency,
Intermountain has established procedures to comply with public health directives while
maintaining safe, reliable and essential natural gas service for customers.
The spread of COVID-19 and associated proclamations and orders has resulted in
widespread economic disruption across the State of Idaho, the Pacific Northwest, the United
States, and internationally. Because of this economic disruption, Intermountain anticipates there
will be a new subset of its customers that will have an inability, or will be challenged financially,
to pay their Intermountain bills until they can return to work. In an effort to assist customers
facing extraordinary economic pressures as a result of COVID-19, Intermountain has temporarily
suspended disconnections of service for non-payment on all accounts and waived late fees on all
past due balances. The Company hopes that these measures will help contribute to the health and
safety of its customers during this unprecedented crisis.
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 3
Similar to the Utilities in this case, the measures Intermountain has put in place in
response to the pandemic are unprecedented and thus the Company expects it will incur
significant incremental costs in its response to the public health emergency. Anticipated COVID-
19 related response costs include expenses associated with the suspension of disconnections and
late payments, higher than average write-off expenses associated with uncollectible accounts
receivable, potential direct expenses for additional personal protective equipment (PPE), and
additional expense that the Company is currently unable to predict.
At the same time the Company expects to incur these additional costs, revenues that are
designed to recover Intermountain’s normal business costs could be reduced significantly due to
the statewide Stay-Home Order, which has caused shutdowns or slowdowns of many
commercial and industrial businesses throughout Intermountain’s service territory. Accordingly,
Intermountain requests authorization to establish a new regulatory asset to record the deferral of
incremental and unrecovered costs associated with its COVID-19 response.
Intermountain recognizes that the increased costs may be offset by certain reduced costs
caused by the public health emergency, and that decreased costs will be taken into account in any
future proceeding.
Intermountain agrees with the Utilities that the associated risks of the COVID-19 public
health emergency are well outside reasonable business risk for the Company that might
otherwise be considered normal “regulatory lag.” During this COVID-19 emergency,
Intermountain welcomes, and is fully capable of executing, its obligation to provide safe, reliable
natural gas service to its customers. At the same time, it is important to the ongoing financial
health of the Company to have a reasonable opportunity to recover its prudently incurred costs.
Thus, deferred accounting treatment for these costs is appropriate and reasonable.
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 4
As requested by the Utilities in this proceeding, Intermountain seeks authorization from
the Commission to defer, for future amortization, incremental costs incurred to respond to the
COVID-19 outbreak and normal business costs not recovered due to reduction in natural gas use
by its customers due to the statewide Stay-Home Order. Intermountain supports the proposal that
the Utilities record amounts that would be subject to the deferral in accordance with the Code of
Federal Regulations to the Federal Energy Regulatory Commission (“FERC”) Account 182.3
(Other Regulatory Assets), and credit the appropriate FERC account associated with the expense
or waived fee, such as FERC Account 904 (Uncollectible Accounts) and FERC Account 450
(Forfeited Discounts).
Given the unprecedented nature of this public health emergency, Intermountain cannot
estimate the incremental costs associated with its COVID-19 response, or the length of time in
which the costs will be incurred. Intermountain proposes to accrue interest on the unamortized
balance at a rate equal to the customer deposit rate most recently approved by the Commission.
Intermountain does not request that the Commission make a determination of prudency, or
determine whether these costs are recoverable, at this time. The Company understands that these
issues will be determined in a future proceeding.
RECOMMENDATION
Based on the comments provided above, Intermountain respectfully recommends the
following:
1. That Intermountain’s COVID-19 emergency response related deferred accounting
authority be decided in this generic case;
2. Intermountain supports the proposal of the Utilities for authorization to defer for later
ratemaking treatment the Utilities’ prudently incurred incremental costs from the
COVID-19 public health emergency and normal business costs not recovered due to
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 5
reduction in natural gas use to a regulatory asset until a request can be made for the
amortization of the deferred costs in a future Commission proceeding.

Dated: May 12, 2020
GIVENS PURSLEY LLP

Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company

INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 6
CERTIFICATE OF SERVICE
I certify that on May 12, 2020, a true and correct copy of INTERMOUNTAIN GAS
COMPANY’S COMMENTS, in Case No. GNR-U-20-03 was served upon all parties of record in this proceeding via the manner indicated below: Idaho Public Utilities Commission
Commission Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise, ID 83720-0074
[e-mail]
Electronic Mail
Avista Utilities
David J. Meyer
P.O. Box 3727
1411 E. Mission Ave., MSC 13
Spokane, WA 99220-3727
[e-mail]

Patrick Ehrbar
P.O. Box 3727
1411 E. Mission Ave., MSC 27 Spokane, WA 99220-3727
[e-mail]

Electronic Mail

Electronic Mail
Preston N. Carter
601 W. Bannock St.
Boise, ID 83702
[e-mail]
[e-mail]

Eric W. Nelson
NW Natural 220 NW 2nd Ave. Portland, OR 97209
[e-mail]

Electronic Mail

Electronic Mail
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 7
Gem State Water Company
Preston N. Carter
601 W. Bannock St.
Boise, ID 83702
[e-mail]
[e-mail]

Eric W. Nelson
NW Natural 220 NW 2nd Ave.
Portland, OR 97209
[e-mail]
Electronic Mail

Electronic Mail
Lisa D. Nordstrom
Matt Larkin
1221 West Idaho St (83702)
P.O. Box 70
Boise, ID 83707 [e-mail]
[e-mail]
[e-mail]
Electronic Mail
Rocky Mountain Power
Ted Weston
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Data Request Response Center
Rocky Mountain Power
825 NE Multnomah St. Suite 2000
Portland, OR 97232
[e-mail]

Electronic Mail

Electronic Mail
INTERMOUNTAIN GAS COMPANY’S REPLY COMMENTS - 8
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
P.O. Box 7218
Boise, ID 83702
[e-mail]

Dr. Don Reading
6070 Hill Road
Boise, Idaho 8373
[e-mail]

Electronic Mail

Electronic Mail
Randall C. Budge
Thomas J. Budge Racine Olson, PLLP
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]

Brian C. Collins
Maurice Brubaker
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
[e-mail]

Electronic Mail

Electronic Mail
Benjamin J. Otto
710 N 6th Street
Boise, Idaho 83702
[e-mail]

Electronic Mail

Lori A. Blattner