20170317Petition for Funding.pdf

Benjamin Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
botto @idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE )
APPLTCATTON OF )
INTERMOUNTAIN GAS COMPAI\'Y )
FOR THE AUTHORTTY TO )
CHANGE ITS RATES AND )
CHARGES FORNAUTRAL GAS )
SERYICE TO NATURAL GAS )
cusroMERS rN THE STATE OF )
IDAHO
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BEFORT THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. INT.G.16.O2
IDAHO CONSERVATION LEAGUE
AND NW ENERGY COALTION
APPLICATION FOR INTERVENOR
FUNDING
COMES NOW, the Idaho Conservation League ("ICL") and the NW Energy Coalition
('NWEC)", pursuant to Idaho Code $ 6l-617A and IDAPA 31.01.01.161-165 with the
following application for intervenor funding. ICL and NWEC are intervenors in this case
pursuant to Order No. 3361l. This application is timely pursuant to the Commissions instruction
at the technical hearing to submit such applications by March 17,2017.
I.Idaho Code S 61-617A and IDAPA Rule 31.01.01.161. Requirement
Intermountain Gas Company is a regulated public utility with gross Idaho intrastate,
annual revenues exceeding three million, five hundred thousand dollars ($3,500,000.00).
II. IDAPA Rule 31.01.01.162 Requirements
l.Itemized list of Expenses
The attached Exhibit A includes an itemized list of expenses incurred by ICL and NWEC
ICLAIWEC Application for Intervenor Funding
INT-G-16-02
I
March 17,2017
for Mr. Rivas travel costs to attend the technical hearing. Exhibit A also indicates the hours spent
investigating the direct testimony of Intermountain Gas, reviewing the direct and rebuttal
testimony of other parties, preparing for cross examination of witnesses, and participating in the
hearing. ICL and NWEC incurred, but are not seeking recovery of, additional expenses for
printing and reproduction.
2. Statement of Proposed Findings
ICL and NWEC propose the Commission:
a Approve Intermountain Gas Company's proposed conservation programs with Staff s
proposed adjustments
Delay Intermountain's proposed Fixed Cost Collection Mechanism until the company
increases conservation achievements; adopt ICL and NWEC changes to the mechanism
Order Intermountain Gas to convene an Energy Efficiency Advisory Group and rapidly
pursue additional co st-effective conservation pro grams
Set the customer charge for the Residential class at $3.50 per month and the General
Service class at $10 per month, along with adjusting the per therm charge accordingly to
achieve the class revenue requirement
Reject the proposed fourth block for the General Service class; change to inverted block
per therm rates
Grant this request for intervenor funding
a
a
a
a
a
3. Statement Showing Costs
ICL and NWEC requests $5,678.00 in intervenor funding, as shown in Exhibit A and
rounded down for ease of accounting. Both the hourly rate and hours expended are reasonable
ICLA{WEC Application for Intervenor Funding
INT-G-16-02
2
March 17,2017
for this complex case and in line with the current range for other intervening parties in Idaho.
As the first general rate case filed by Intermountain Gas in 31 years, this case presented a
host of new issues and information to review andanalyze. ICL and NWEC reviewed the direct
testimony of Intermountain, the extensive discovery requests of other parties, and submitted our
own. We filed Direct Testimony of Diego Rivas addressing the proposed gas conservation
programs, the Fixed Cost Collection Mechanism, and rate design for the Residential and General
Service classes. Council for ICL was an active participant in the technical hearing on these issues
as well as others concerning all customers. For each of these efforts we endeavored to limit the
number of hours expended to the maximum extent possible, primarily by focusing on issues
relevant to our constituents, and only seek recovery for a fraction of the total hours spent. We
request a reasonable hourly rate for both counsel and Mr. Rivas that is well below market rates
for equivalent levels ofexperience. For all these reasons our request is reasonable.
4. Explanation of Cost Statement
ICL and NWEC are both nonprofit organizations supported solely through charitable
donations from our members and foundations. In this proceeding, we represent our members and
supporters who are ratepayers of Intermountain Gas. To provide consistent, professional, and
impactful advocacy for our members and supporters both ICL and NWEC dedicated full-time,
highly trained staff members to work solely on energy issues. The cost of employing and training
these employees is a significant financial commitment for a charitable organization. Mr. Otto and
Mr. Rivas have complementary skills and rolls, each of which is necessary to effectively
advocate for our constituents. Because charitable contributions are inherently unstable, the
availability of intervener funding is essential for ICL and NWEC to participate in these
proceedings. Our groups have no pecuniary interest in the outcome of this case; rather we
ICLAIWEC Application for Intervenor Funding
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March 17,2017
dedicated our time and resources to represent the interests of our 25,000 supporters around the
state who have a strong interest in conserving natural gas while keeping bills affordable in Idaho.
5. Statement of Difference
ICL and NWEC's proposed findings are materially different than the Staff. Staff
criticized the depth and breadth of Intermountain's gas conservation portfolio and recommended
further assessment as part of the 20l9Integrated Resource Plan cycle. Because we believe
additional cost effective conservation potential exists today, ICL and NWEC's testimony and
cross-examination at hearing argued for the Commission to order Intermountain to begin
developing additional cost effective programs immediately. Our testimony suggests specific
additional conservation measures including Exhibit 401 showing additional conservation
programs currently offered by Intermountain sister company Cascade Natural Gas. Staff did not
provide evidence of specific additional measures for the Company to consider. In sum, ICL and
NWEC's position is for a much faster and deeper development of cost effective conservation
than the Staff advocated for.
ICL and NWEC criticized the Intermountain's fixed cost collection mechanism, along
with Staff. ICL and NWEC went beyond Staff testimony to include specific recommendations to
improve the mechanism including capping rate increases, removing the per month reconciliation,
and excluding the 50 largest General Service customers. On rate design, ICL and NWEC
recommendations differ from Staff by proposing a much lower customer charge for the
residential class and, for the General Service class, opposing adding a fourth block and
maintaining a declining block structure. We further illuminated these material differences in rate
design at the hearing. In sum, ICL and NWEC differed from Staff by proposing improvements
to, not just denial of, the Fixed Cost Collection Mechanism and a different rate components for
ICLAIWEC Application for Intervenor Funding
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March 17,2017
both the Residential and General Service classes
6. Statement of Recommendation
All customers, regardless of class, share a strong interest in ensuring Idaho utilities spend
customer funds prudently, particularly here in regards to gas conservation programs, and collect
funds fairly, here through rate design. By engaging on these issues, tCL and NWEC address
matters of concern to all customers. Clearly, rate design affects all members of the class and, to
the extent rate design impacts overall revenue collection, rate design in one class is a matter of
concern for all ratepayers. Gas conservation programs have the ability to affect all customers by
avoiding higher cost supply-side options, as well as subgroups that are eligible to participate in
conservation incentives. Rate mechanisms like the Fixed Cost Collection Mechanism can also
affect all customers by reducing revenue volatility for the Company. Our organizations do not
have a monetary interest in the results of this case; rather our participation is to be a voice for
Intermountain Gas customers who desire to conserve gas while keeping bills affordable.
7. Statement Showing Class of Customer
Our individual members and supporters are predominately residential and with a few
small commercial customers of Intermountain Gas.
WHEREFORE,ICL and NWEC respectfully requests the Commission grant this application.
DATED this 17th dayof March}}l7.
submitted,
-z^e><
Benjamin I. Otto
Idaho Conservation League
ICLA{WEC Application for Intervenor Funding
INT-G-16-02
5
March 17,2017
Exhibit A
Cost Statement for Idaho Conservation League and NW Enerry Coalition
Investigating Intermountain Gas Company's application and direct testimony
Benjamin J Otto (Council): 1.25 hours
Diego Rivas (Witness): 3.25 hours
Reviewing relevant discovery by all parties, drafting ICLAIWEC discovery
Benjamin J Otto (Council): 2.25 hours
Diego Rivas (Witness): 3.75 hours
Preparing and filing the direct testimony of Mr. Rivas
Benjamin J Otto (Council): 3.25 hours
Diego Rivas (Witness): 6.25 hours
Reviewing the direct and rebuttal testimony of other parties, prepare cross
Benjamin J Otto (Council): 3.25 hours
Diego Rivas (Witness): 2.75 hours
Participating in the technical hearing of March I - 3
Benjamin J Otto (Council): 16 hours
Diego Rivas (Witness): 10 hours
Total Hours
Benjamin J Otto (Council):
Diego Rivas (Witness):
26 hours @ $l35ftrour
26 hours @ $50/hour
$3,510.00
$1,300.00
$t23.r7
$74s.10
Total: $5.678.27
Expenses
Travel for Diego Rivas
Lodging: Boise Guest House
Flight: Delta, Helena, MT to Boise,ID
ICLA{WEC Application for Intervenor Funding
INT-G-16-02
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March 17,2017
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of March20l7 I delivered true and correct copies of
the foregoing APPLICATION FOR INTERVENOR FUNDING to the following persons via the
method of service noted:
Benjamin J. Otto
Hand delivery:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original,3 copies)
Electronic Mail Only:
INTERMOUNTAIN GAS
Ronald L. Williams
Williams Bradbury, PC
1015 W. Hays Street
Boise, ID 83702
Phone: [phone]
ron@williamsbradbury. com
Michael P. McGrath
Director - Regulatory Affairs
Intermountain Gas Company
55 S. Cole Road
PO Box 7608
Boise,ID 83707
Phone: [phone]
[e-mail]
COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
Brad M Purdy
Attorney at Law
2019 N. 17'h St.
Boise, ID 83702
Phone: [phone]
[e-mail]
NORTHWEST INDUSTRIAL GAS USERS
c/o Edward A Finklea
Executive Director
545 Grandview Drive
Ashland, OR 97520
Phone: [phone]
[e-mail]
Chad M. Stokes
TommyA Brooks
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Phone: [phone]
[e-mail]
tbrooks@cablehuston. com
Michael C. Creamer (ISB No.4030)
Givens Pursley LLP
601 W Bannock St.
Boise, ID 83702
Phone: [phone]
[e-mail]
THE AMALGAMATED SUGAR CO. LLC
Peter fuchardson
Gregory M. Adams
Richardson Adams PLLC
5r5 N. 27ft st.
Boise, lD 83702
peter@richardsonadams. com
gr e g@richard s onadams. c om
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Suite 100
Boise,ID 83709
sblickenstaff@amalsugar. com
SNAKE RIVER ALLIANCE
Ken Miller
Snake River Alliance
223 N.6th St. Suite 317
P.O. Box 1731
Boise,ID 83701
kmiller@snakeriveralliance. org
FEDERAL EXECUTIVE AGENCIES
Andrew J. Unsicker
Lanny L.Zieman
Natalie A. Cepak
Thomas A. Jemigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Dr., Suite I
Tyndall AFB, FL32403
Andrew.unsicker@us. af.mil
Lanny.zieman. 1 @us.af.mil
Natalie. cepak. 2 @us. af.mil
Thomas j erni gan. 3 @us. af.mil
Ebony.payton. ctr@us. af.mil