20030619Rebuttal of Reply Comments.pdf

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Jeffrey C. Brooks
Advanced Energy Strategies, Inc.
1027 E. Cayman Drive
Meridian, ill 83642
[phone]
brooksjcl~ao1.com
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UTlLlT ItS COr'H-1!SSIOH
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY
FOR AUTHORITY TO INCREASE ITS
RATES FOR SERVICE
CASE NO: INT-O3-
REBUTTAL OF INTERMOUNA TIN GAS
REPLY COMMENTS TO
JEFFREY C. BROOKS
ADVANCED ENERGY STRATEGIES, INC.
Comes now Intervenor, Advanced Energy Strategies (AES) by and through Jeffrey C.
Brooks, to rebut the reply comments offered by Mr. Mike McGrath of Intermountain Gas
Company.
Rebuttal
Incremental Rate Increase and Accounting
AES is gratified to hear IGC's assurances that no one has overlooked the simple matter of
applying profit percentages to the cost of energy. AES trusts that Commission Staff and IGC
have thoroughly reviewed W ACOG computations and, rather than simply check their math, AES
seeks to explore other, perhaps overlooked, areas of concern. Thus, AES believes it is valuable
and worthwhile that this Commission and its Staff be made aware of those areas of accounting
that may have eluded earlier scrutiny, such as the stored natural gas costs versus sales values, and
allocation of incremental revenues.
AES REBUTTAL COMMENTS
INT -03-0 1
June 19 2003
Conservation
AES stands by its earlier assertion that IGC gives short shrift to the wise and efficient use
of natural gas, but Mr. McGrath raises a good point. At the time IGC produced its current
Integrated Resource Plan for submission to the Commission, Mr. Brooks was employed by IGC
as a Marketing Representative, and thus, AES did not review or provide comment regarding
IGC's IRP. However, now that Mr. Brooks is no longer constrained by employment at IGC
AES will expend additional energy reviewing future Intermountain IRP's to assist the process
and provide alternative perspectives and expertise. Therefore, AES hereby requests that I GC
provide future IRP copies and drafts to it by mail service, so AES may provide additional
scrutiny and rigor to the IRP process.
Mr. McGrath did not respond to AES' assertion regarding the accounting treatment and
implementation strategy applied to its high efficiency furnace rebate program. Thus, these issues
remain as areas for additional scrutiny and consideration.
Moreover, to the degree that the comments and assertions provided by AES are
unsubstantiated, AES believes that this is the purpose of the comment process. Because IGC
requested modified procedure in this case, evidentiary proceedings are replaced with comments
which are not legally equivalent to testimony or evidentiary submissions. However, Mr. Brooks
comments are the direct result of his personal knowledge and twenty-plus years of experience in
the energy efficiency industry, as an engineer, Energy Services Department supervisor and
department director at two major electric utilities (Southern California Edison Company, and
Idaho Power Company), and his observance of practices and programs at Intermountain Gas.
AES regrets the hostile tone IGC brings to the comment process, and finds it inappropriate and
not constructive.
Building Practices
AES welcomes IGC's challenge to document its assertion of widespread poor building
practices and the complicit facilitation of same by IGC. AES believes that any investigation
should be conducted by an appropriate party, and asserts that the Department of Water Resources
AES REBUTTAL COMMENTS
INT-03-
June 19 2003
Energy Division, or Commission Staff, may be the correct group to either conduct or contract
such a study. AES is willing to supply advice, assistance and guidance if so desired by the
Commission. The key, of course, is knowing where to look and how to interpret the findings and
AES has a great deal of experience in this area that may be useful, and stands ready to bring
these issues forth for the benefit of all.
Slander
For clarity, it should be noted that slander describes the utterance of defamatory or
injurious statements. When such statements are written, the appropriate term is libel. In this
case, the comments provided by AES are not libelous, but AES asserts they do shed new light
into the practices and the attitudes prevalent at Intermountain Gas. This process of advice and
comment is part and parcel of public policy law, and AES is practicing good citizenship by its
participation and efforts in the regulatory decision-making process. The tone of rancor expressed
by IGC is of itself curious, and should flag additional attention. One can only wonder why IGC
has initiated and introduced such inappropriate character assassination into these proceedings.
IGC desires, AES will gladly provide evidentiary testimony regarding its comments and the basis
for same, however, any such proceedings will, by necessity, delay a decision by the Commission
in this matter. AES trusts the ability of this Commission to observe, understand, and reach wise
and appropriate consensus decisions in this matter.
Conclusion
AES has attempted to raise some of the issues that impact the cost of natural gas and
practices Intermountain Gas employs that may not represent the best interests of its captive
customers. AES believes that this comment, reply and rebuttal process has provided sufficient
cause to warrant closer examination of certain aspects of IGC's business practices , and asserts
the result of such additional scrutiny will ultimately benefit the energy consumers of Idaho.
Respectfully submitted this 19th day of June 2003.
AES REBUTTAL COMMENTS
INT-03-
June 19 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the day of June 2003, I caused to be served a true and
correct copy ofthe forgoing by the method indicated below, and addressed to the following:
John Hammond
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street (83702)
O. Box 83720
Boise, ID 83720-0074
7 copies
S. Mail Fax By Hand Email
Michael Huntington, Vice President - Marketing & External Affairs
Intermountain Gas Company
555 S. Cole Road
O. Box 7608
Boise, ID 83707
S. Mail Fax By Hand
Morgan W. Richards Jr.
Moffatt, Thomas, Barrett, Rock & Fields CHTD
US Bank Plaza Bldg 10th Floor
101 S. Capitol Blvd.
Boise, ID 83701-0829S. Mail Fax By Hand
AES REBUTTAL COMMENTS
INT -03-0 1
E mail
Email
June 19 2003