20230517Direct B. Mullins - Settlement.pdf

Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]

Attorneys for Alliance of Western Energy Consumers

BEFORE THE IDAHO PUBLIC UTILITY COMMISSION

CASE NO. INT-G-22-07

SETTLEMENT TESTIMONY OF BRADLEY G. MULLINS

ON BEHALF OF THE ALLIANCE OF WESTERN ENERGY CONSUMERS

May 17, 2023
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR NATURAL GAS
SERVICE IN THE STATE OF IDAHO
)
)
)
)
)
)
RECEIVED
Wednesday, May 17, 2023 2:12:06 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAGE 1 of 8
B. MULLINS, Di
AWEC
I.INTRODUCTION AND SUMMARY1
Q.PLEASE STATE YOUR NAME AND OCCUPATION.2
A.My name is Bradley G. Mullins. I am a consultant representing utility customers before state3
public utility commissions in the Northwest and Intermountain West. My witness qualification4
statement can be found at Mullins Exhibit 201.5
Q.PLEASE IDENTIFY THE PARTY ON WHOSE BEHALF YOU ARE TESTIFYING.6
A.I am testifying on behalf of the Alliance of Western Energy Consumers (“AWEC”). AWEC is7
a non-profit trade association whose members are large energy users in the Western United8
States, including customers receiving gas sales and transportation services from Intermountain9
Gas Company (“Intermountain”).10
Q.WHAT IS THE PURPOSE OF YOUR TESTIMONY?11
A.I discuss AWEC’s support for the May 4, 2023 Stipulation and Settlement (“Stipulation”)12
entered into by Intermountain, Staff for the Idaho Public Utilities Commission (“Staff”),13
AWEC, and the Idaho Conservation League (collectively, “Settling Parties”). The City of14
Boise, the only intervenor which is not a party to the Stipulation, has indicated that they do not15
intend to oppose the Stipulation. The Settling Parties and the City of Boise are collectively16
referred to herein as (“Parties”).17
Q.PLEASE SUMMARIZE AWEC’S SUPPORT FOR THE STIPULATION.18
A.The under the terms of the Stipulation, the Settling Parties agreed to increase Intermountain’s19
margin rates by $3,050,000 or 2.75%. The Stipulation represents an $8,287,947 reduction20
from the $11,337,947 revenue requirement increase Intermountain requested in its initial filing.21
In addition, the Stipulation provides a rate spread recognizing that large volume sales and22
PAGE 2 of 8
B. MULLINS, Di
AWEC
transportation customers are paying rates in excess of their class cost of service. While the rate 1
spread does not move the large volume sales and transportation rate classes to parity, AWEC 2
supports the gradual move in this case due to overall size of the rate increase, which is 3
relatively small in comparison to Intermountain’s filed case. Finally, the Stipulation contains 4
requirements for Intermountain to provide information about intercorporate cost allocations in 5
its next general rate case filing, a provision that AWEC supported. AWEC finds that the 6
Stipulation represents a reasonable comprise of the issues raised in this docket and 7
recommends that the Commission approve the Stipulation. 8
Q.WHAT STANDARD DOES THE COMMISSION APPLY WHEN CONSIDERING A9
SETTLEMENT?10
A.The Commission has jurisdiction over this matter under Idaho Code §§ 61-502 and 61-503,11
and has the express statutory authority to investigate rates, charges, rules, regulations,12
practices, and contracts of public utilities and to determine whether they are just, reasonable,13
preferential or discriminatory, or in violation of any provision of law, and may fix the same by14
Order. Idaho Code §§ 61-502 and 61-503. Proponents of a proposed settlement must show15
“that the settlement is reasonable, in the public interest, or otherwise in accordance with law or16
regulatory policy.” IDAPA 31.01.01.275. Notwithstanding, the Commission is not bound by17
settlement agreements. IDAPA 31.01.01.276. Instead, the Commission “will independently18
review any settlement proposed to it to determine whether the settlement is just, fair and19
reasonable, in the public interest, or otherwise in accordance with law or regulatory policy.” Id.20
Q.PLEASE DISCUSS AWEC’S REVIEW OF INTERMOUNTAIN’S FILING.21
A.AWEC performed a detailed review of Intermountain’s revenue requirement and rate spread22
and rate design. AWEC submitted 95 production requests and reviewed Intermountain’s23
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B. MULLINS, Di
AWEC
responses to Production Requests. AWEC also reviewed Intermountain’s responses to the 1
numerous production requests from Staff. AWEC also participated in settlement negotiations. 2
Based on its review of discovery, AWEC prepared a detailed revenue requirement proposal 3
which was provided to settlement participants for consideration in the settlement process. 4
Q.PLEASE DISCUSS THE REVENUE REQUIREMENT CHANGES IN5
INTERMOUNTAIN’S MARCH 9, 2023 UPDATED DIRECT FILINGS.6
A.In its initial filing, Intermountain requested a $11,337,947 or 10.56% margin rate increase.7
The initial filing used a historical test period, consistent with the Commission’s preferred8
practice, based on the year ending December 31, 2022. The full year of test period results was9
not available at the time of Intermountain’s filing, which occurred on December 1, 2022.10
Accordingly, the revenue requirement in Intermountain’s initial filing included forecast data11
for the fourth quarter of 2022. In AWEC Production Request 02, AWEC requested that12
Intermountain update its test period results to include actual data for the fourth quarter of 2022.13
Intermountain responded to AWEC Data Request 02 on February 28, 2023, providing updated14
revenue requirement calculations with the full year of historical data, and later filed Updated15
Direct Testimony on March 9, 2023 incorporating the results of that analysis into its filing.16
In addition to updating the test period results described above, Intermountain also 17
corrected several errors that AWEC had identified in discovery. In AWEC Production 18
Requests 21 and 23, AWEC identified errors related to Intermountain’s calculation of income 19
tax expenses. In its response to AWEC’s requests, Intermountain acknowledged its mistake 20
and committed to correcting the error in its Updated Direct Filings. 21
In Intermountain’s March 9, 2023 Updated Direct Filings, Intermountain included an 22
update of its revenue requirement with actual data for the entire test period. Intermountain also 23
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B. MULLINS, Di
AWEC
corrected the above referenced tax expense errors. The result of the March 9, 2023 Updated 1
Direct Filings was a proposed revenue requirement of $6,752,224, representing a $4,585,723 2
reduction from Intermountain’s initial filing. Of this reduction, approximately $4,138,315 of 3
the difference in revenue requirement from Intermountain’s initial filing was attributable to 4
reduced tax expenses. In response to AWEC Production Request 63, Intermountain confirmed 5
that the reduction to income tax expenses was attributable to the tax expense items identified in 6
AWEC Production Requests 21 and 23. Copies of these requests have been attached as 7
Mullins Exhibit 202. 8
Q.PLEASE GIVE AN OVERVIEW OF THE SETTLEMENT PROCESS.9
A.The Parties met for settlement conferences on March 30 and 31, 2023. In the settlement10
conferences, the Parties presented their respective positions and proposed adjustments to11
Intermountain’s revenue requirement and Parties discussed the merits of each adjustment.12
Ultimately, the Settling Parties were unable to reach consensus on all of the individual revenue13
requirement adjustments that had been proposed. Notwithstanding, the Settling Parties were14
able to reach a compromise position in which Intermountain would be provided with a15
$3,050,000 revenue requirement increase, reflecting an overall margin rate increase of16
approximately 2.75%. Each Settling Party came to this result independently. Other than the17
items specified in Paragraph 2 of the Stipulation, there was no consensus on the specific18
adjustments that were made to arrive at this result. Based on AWEC’s proposed adjustments19
and analysis prepared in advance of the settlement conference, however, AWEC found the20
stipulated level of revenue requirement to be a reasonable result.21
PAGE 5 of 8
B. MULLINS, Di
AWEC
Q.WHY DID AWEC AGREE TO A 9.5% ROE?1
A.Paragraph 2(a.) of the Stipulation provides Intermountain with a 9.5% return on equity2
(“ROE”). From AWEC’s perspective, in the context of the overall Stipulation and taking into3
consideration the unique factors facing Intermountain, AWEC was willing to accept a 9.5%4
ROE. AWEC finds that the Stipulation, taken as a whole, results in fair, just and reasonable5
rates.6
Q.PLEASE DISCUSS THE RATE SPREAD INCLUDED IN THE STIPULATION.7
A.The rate spread included in the Stipulation was based on Intermountain’s filed case, which8
provided schedule LV sales and T-4 transportation customers with a rate increase that is 53%9
of the system average rate increase, or approximately 1.5%. Similarly, the rate spread included10
in the Stipulation provides T-3 interruptible transportation customers with a rate increase that is11
25% of the system average rate increase, or approximately 0.7%. Based on the cost of service12
study contained in Intermountain’s March 9, 2023 Updated Direct Testimony, Schedules LV13
and T-4 had parity ratios of 1.38 and 1.37, respectively. By definition, the rates for those14
schedules would need to be reduced significantly to bring those customer rates in line with15
their actual cost of service. Schedule T-3 transportation customers had an even larger parity16
ratio of 6.55, meaning that the rates for those customers would need to be reduced by several17
multiples to reach cost of service rates. In the Stipulation, there was no consensus on the cost-18
of-service study assumptions and results. Notwithstanding, AWEC was willing to agree to a19
more gradual shift towards parity, particularly considering the magnitude of the revenue20
requirement increase in the Stipulation. AWEC recognizes that high energy costs present a21
challenge for all customers, and in the context of gradualism and the spirit of compromise,22
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B. MULLINS, Di
AWEC
AWEC was willing to accept Intermountain’s proposed rate spread as part of a global 1
settlement. 2
Q.PLEASE EXPLAIN THE SETTLEMENT PROVISIONS SURROUNDING CROSS3
COMPANY COST ALLOCATIONS.4
A.One of AWEC’s concerns with Intermountain’s filed case had to do with cross company cost5
allocations. Since Intermountain was acquired by MDU Resources (“MDU”) in 2008, the6
amount of costs that have been allocated from Intermountain’s corporate parent and between7
other affiliate utilities have been increasing. MDU and its family of utilities are also becoming8
increasingly integrated, making it more difficult to segregate costs from one utility to another.9
While AWEC recognizes that there can be some benefits to integrated operation of certain10
utility functions, AWEC was concerned with the level of detail supporting the cost allocations11
that were proposed in revenue requirement. Accordingly, as a provision of the Stipulation,12
AWEC requested that Intermountain provide further information regarding intercorporate cost13
allocations in its next general rate case filings. Specifically, AWEC requested that14
Intermountain file testimony describing the allocation methods, and that Intermountain provide15
workpapers supporting the allocation factors and the allocated costs in its filing. Accordingly,16
in Paragraph 5 of the Stipulation, Intermountain agreed to provide more cost allocation17
information in its next general rate case. This provision of the Stipulation is designed to18
improve staff and intervenors’ ability to review the cost allocation and provide a better19
understanding of how the intercorporate cost allocations are being performed.20
Q.PLEASE EXPLAIN WHY THE STIPULATION SATISFIES THE INTERESTS AND21
CONCERNS OF AWEC.22
A.Based on its review of Intermountain’s filing and through the discovery process, AWEC had23
issues with the requested ROE, income tax expense, several revenue requirements adjustments,24
PAGE 7 of 8
B. MULLINS, Di
AWEC
intercompany allocations, and rate spread and rate design. Although the Stipulation does not 1
incorporate all of AWEC’s proposed adjustments, it does incorporate many of AWEC 2
adjustments and positions. Accordingly, the overall result is fair and provides a significant 3
benefit to customers. 4
Q.PLEASE EXPLAIN WHY AWEC BELIEVES THE STIPULATION IS IN THE5
PUBLIC INTEREST.6
A.AWEC believes the Stipulation is in the public interest and recommends the Commission7
approve the Stipulation because the best interests of Intermountain’s natural gas customers are8
served by the underlying fair compromise on certain revenue requirement and rate spread and9
design issues. While the Stipulating Parties may each hold different positions on the individual10
components of Intermountain’s natural gas revenue requirement addressed in the Stipulation,11
AWEC supports the Stipulation because it decreased the proposed revenue requirement12
increase by $8,287,947 from Intermountain’s initial filing, which results in a revenue13
requirement increase of $3,050,000. AWEC supports the Stipulation as an overall result that is14
a fair compromise between Intermountain and its customers. AWEC also finds the Stipulation15
to be in the public interest as the spread of the gas rate increase is done in a manner to better16
align rates based on Intermountain’s cost of service study. For the reasons set forth above,17
AWEC believes the Stipulation is in the public interest and should be approved by the18
Commission.19
Q.DO YOU HAVE ANY CLOSING REMARKS?20
A.AWEC appreciates the opportunity to participate in this proceeding. AWEC also appreciates21
Staff’s thorough review of, and attention to, the matters at issue in this proceeding, and22
Intermountain’s willingness to engage in settlement negotiations in good faith in order to reach23
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B. MULLINS, Di
AWEC
a compromise position that all parties could support. While this Stipulation did not necessarily 1
resolve all the issues that AWEC identified in its review, AWEC found that it represented a 2
reasonable compromise, resulting in just a 2.75% rate increase relative to the 10.56% rate 3
increase included in Intermountain’s initial filing. AWEC supports the stipulation as just, fair 4
and reasonable and in the public interest. 5
Q.DOES THIS CONCLUDE YOUR SETTLEMENT TESTIMONY?6
A.Yes.7
Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]
ATTORNEYS FOR ALLIANCE OF WESTERN ENERGY CONSUMERS
BEFORE THE IDAHO PUBLIC UTILITY COMMISSION
CASE NO. INT-G-22-07
EXHIBIT 201 TO ACCOMPANY THE
SETTLEMENT TESTIMONY OF BRADLEY G. MULLINS
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR NATURAL GAS
SERVICE IN THE STATE OF IDAHO
Tietotie 2, Suite 208 | FI-90460, Oulunsalo Finland
Bradley Mullins
Principal Consultant [e-mail]
MW Analytics is the professional practice of Bradley Mullins, a consultant and expert witness that
represents utility customers in regulatory proceedings before state utility commissions throughout the western United States. Since starting MW Analytics in 2013, Mr. Mullins has sponsored expert witness testimony in over 100 regulatory proceedings on a variety of subject matters, including revenue requirements, regulatory accounting, rate development, and new resource additions. MW
Analytics also assists clients through informal regulatory, legislative and energy policy matters. In
addition to providing regulatory services, MW Analytics also provides advisory and other energy consulting services.
Education
•Master of Accounting, Tax Emphasis, University of Utah
•Bachelor of Finance, University of Utah
•Bachelor of Accounting, University of Utah
Relevant Prior Experience
PacifiCorp, Portland, OR: Net Power Cost Consultant 2010 – 2013
•Analyst involved in power cost modeling and forecasting
•Responsible for preparing power cost forecasts, supporting testimony for regulatory filings,
preparing annual power cost deferral filings, and developing qualifying facility avoided cost
calculations
Deloitte, San Jose, CA: Tax Senior 2007 – 2009
•Staff accountant responsible for preparing corporate tax returns for multinational corporateclients and partnership returns for hedge fund clients
•Joined to national tax practice specializing research and development tax credit studies
Regulatory Appearances
Docket Party Topics
In re Joint Application of Nevada Power Company d/b/a NV Energy and Sierra Pacific Power Company d/b/a NV Energy for approval of the fourth
amendment to its 2021 Joint Integrated Resource Plan, PUC Nv. Docket No. 22-11032.
Enterprise Services, LLC; MGM Resorts International; Nevada Resorts
Resource Planning
In re Joint Application of Nevada Power Company d/b/a NV Energy and
Sierra Pacific Power Company d/b/a NV Energy for approval of the Third Amendment to its 2021 Joint Integrated Resource Plan., PUC Nv. Docket No. 22-09006.
Enterprise Services, LLC; MGM Resorts International; Nevada Resorts
Transportation Electrification
In re Portland General Electric Company, Advice No. 22-18 New Schedule
151 Wildfire Mitigation Cost Recovery, Or.PUC Docket No. UE 412. Western Energy Regulatory Accounting
CASE NO. INT-G-22-07
B. MULLINS, Di
EXHIBIT NO. 201 PAGE 1 OF 8
Docket Party Topics
In re PacifiCorp, Automatic Adjustment Clause for Wildfire Protection Plan Costs, Or.PUC Docket No. UE 407. Western Energy Regulatory Accounting
In re Portland General Electric Company, Application for Authority to Amortize Deferred Amounts Related to 2020 and 2021 Or.PUC Docket No. UE 408.
Alliance of Western Energy Regulatory
Accounting
In re PacifiCorp 2021 Power Cost Adjustment Mechanism, Or.PUC Docket No. UE 404. Western Energy Power Cost Deferral
In re Portland General Electric Company, 2021 Annual Power Cost Variance
Mechanism, Or. PUC UE 406 Western Energy Power Cost
Deferral
In re Portland General Electric Company, Application Regarding Amortization of Boardman Deferral, Or.PUC Docket No. UE 410. Western Energy Regulatory Accounting
In re the application of Sierra Pacific Power Company d/b/a NV Energy for
authority to adjust its annual revenue requirement for general rates charged to all classes of electric customers and for relief properly related thereto,
PUC Nv. Docket No. 22-06014.
Alliance and Caesars Enterprise
Revenue Requirement
In re the Application of Dominion Energy Utah to Increase Distribution Rates and Charges and Make Tariff Modifications Ut.PSC Docket No. 22-Nucor Steel-Utah Rate Spread and
In re Joint Application of Nevada Power Company d/b/a NV Energy(“NPC”) and Sierra Pacific Power Company d/b/a NV Energy (“SPPC”) forapproval to merge into a single corporate entity, to transfer Certificates ofPublic Convenience and Necessity (“CPC”) 685 Sub 20, 688, and 688 Sub 6from SPPC to NPC, and to consolidate generation assets, PUC Nv. Docket
Wynn Las Vegas, LLC and Smart Energy Alliance
Merger
In re Puget Sound Energy Requests for a General Rate Revision, Wa.UTC
Docket. UE-220026 (cons.). Western Energy Revenue
Requirement
In re Northwest Natural Gas Company, dba, NW Natural, Updated Depreciation Study Pursuant to OAR 860-027-0350, Or.PUC Docket No. UM Western Energy Power Cost Modeling
In re Portland General Electric Company, 2023 Annual Update Tariff,
Schedule 125, Or.PUC Docket No. UE 402. Western Energy Requirement /
In re PacifiCorp d.b.a Pacific Power, Request for a General Rate Revision, Or.PUC Docket No. UE 399. Western Energy Revenue Requirement
In re the Joint Application of Nevada Power Company d/b/a NV Energy and Sierra Pacific Power Company d/b/a NV Energy for approval of the cost recovery of the regulatory assets relating to the development and implementation of their Joint Natural Disaster Protection Plan., PUC NV.
Alliance of Western Energy Consumers
Single-Issue Rate Filing
In re PacifiCorp d.b.a. Pacific Power, 2023 Transition Adjustment Mechanism, Or.PUC Docket No. UE 400. Western Energy Power Cost Modeling
In re Cascade Natural Gas Corporation, Request for a General Rate
Revision, Wa.UTC Docket No. UG-210755 Western Energy Requirement /
In re Northwest Natural Gas Company, dba NW Natural, Request for A General Rate Revision, Or.PUC. Docket No. UG 435 Western Energy Requirement /
CASE NO. INT-G-22-07
B. MULLINS, Di EXHIBIT NO. 201 PAGE 2 OF 8
Docket Party Topics
In re Formal Complaint of Tree Top Inc. against Cascade Natural Gas Corporation, Wa.UTC Docket No. UG-210745 Tree Top, Inc. Entitlement
In re Northwest Natural Gas Company, dba NW Natural, Request for
Approval of an Affiliated Interest Agreement with Lexington Renewables, LLC, Or.PUC. Docket No. UI 451.
Alliance of
Western Energy Consumers
Affiliated Interest
In re Avista Corporation, Request for a General Rate Revision, Or.PUC Docket No. UG 433 Western Energy Requirement /
In re PacifiCorp Power Cost Only Rate Case, Wa.UTC Docket No. UE-
210402. Western Energy Power Cost
Modeling
In re PacifiCorp Limited Issue Rate Filing, Wa.UTC Docket No. UE-210532. Western Energy Requirement /
In re the Application of Rocky Mountain Power for Authority to Increase Its Rates and Charges in Idaho and Approval of Proposed Electric Service
Schedules and Regulations, Id.PUC Case No. PAC-E-21-07.
PacifiCorp Idaho Industrial
Customers
Revenue Requirement /
Settlement
In re Portland General Electric, Request for a General Rate Revision,
Or.PUC Docket No. UE 394. Western Energy Power Cost
Modeling
In re Joint Application of Nevada Power Company d/b/a NV Energy and Sierra Pacific Power Company d/b/a NV Energy for approval of their Economic Recovery Transportation Electrification Plan for the period 2022-2024, PUC Nv. Docket No. 21-09004
Nevada Resort Association Transportation Electrification
In re PacifiCorp, dba Pacific Power, 2020 Power Cost Adjustment Mechanism, Or.PUC Docket No. UE 392. Western Energy Power Cost Deferral
In re the Application of Rocky Mountain Power for Authority to Decrease
Current Rates by $14.9 Million to Refund Deferred Net Power Costs Under Tariff Schedule 95 Energy Cost Adjustment Mechanism and to Decrease
Current Rates by $166 Thousand Under Tariff Schedule 93, REC and SO2 Revenue Adjustment Mechanism, Wy.PSC Docket No. 20000-599-EM-21.
Wyoming Industrial Energy
Consumers
Power Cost Deferral
In re Portland General Electric 2021 Annual Update Tariff Schedule 125, Or.
PUC Docket No. UE 391. Western Energy Power Cost
Modeling
In re Joint Application of Nevada Power Company d/b/a NV Energy and Sierra Pacific Power Company d/b/a NV Energy for approval of a regulatory asset account to recover costs relating to the development and implementation of their Joint Natural Disaster Protection Plan, PUC NV.
Wynn Las Vegas, LLC;
Smart Energy Alliance
Single-Issue
Rate Filing
In re PacifiCorp d.b.a. Pacific Power, 2022 Transition Adjustment
Mechanism, Or.PUC Docket No. UE 390. Western Energy Power Cost
Modeling
In re Avista 2020 General Rate Case, Wa.U.T.C. Docket No. UE-200900 (Cons.). Western Energy Revenue Requirement
In re NV Energy’s Fourth Amendment to Its 2018 Joint Integrated Resource Plan, PUC Nv. Docket No 20-07023. Vegas, LLC; Smart Energy Transmission Planning
In Re Cascade Natural Gas Corporation, 2020 General Rate Case,
Wa.U.T.C. Docket No. UG-200568 Western Energy Revenue
Requirement
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201 PAGE 3 OF 8
Docket Party Topics
In re Cascade Natural Gas Corporation, Petition to File Depreciation Study, Or.PUC Docket No. UM 2073 Western Energy Depreciation Rates
In re the Application of Rocky Mountain Power for Authority to Increase
Current Rates By $7.4 Million to Recover Deferred Net Power Costs Under Tariff Schedule 95 Energy Cost Adjustment Mechanism and to Decrease
Current Rates by $604 Thousand Under Tariff Schedule 93, Rec and So2 Revenue Adjustment Mechanism, Wy.PSC Docket No. 20000-582-EM-20
Wyoming Industrial Energy
Consumers
Power Cost Deferral
In re the Complaint of Willamette Falls Paper Company and West Linn Paper Company against Portland General Electric Company, Or.PUC Docket No.
UM 2107
Willamette Falls Paper Company
Consumer Direct Access, Tariff
Dispute
In re The Application of Rocky Mountain Power for Authority to Increase its Retail Electric Service Rates by Approximately $7.1 Million Per Year or 1.1 Percent, to Revise the Energy Cost Adjustment Mechanism, and to Discontinue Operations at Cholla Unit 4, Wy.PSC Docket No. 2000-578-ER-
Wyoming Industrial Energy Consumers
Power Cost Modeling
Avista Corporation 2021 General Rate Case, Or.PUC Docket No. UG 389 Western Energy Requirement,
In re NW Natural Request for a General Rate Revision, Or.PUC Docket No.
UG 388. Western Energy Requirement,
In re PacifiCorp, Request to Initiate an Investigation of Multi-Jurisdictional Issues and Approve an Inter-Jurisdictional Cost Allocation Protocol, Western Energy Jurisdictional Allocation
In re Puget Sound Energy 2019 General Rate Case, Wa.UTC Docket No. UE 190529.
Alliance of
Western Energy Consumers
Requirement, Coal Retirement
Avista Corporation 2020 General Rate Case, Wa.UTC Docket No. UE-
190334 (Cons.) Western Energy Requirement,
In re Cascade Natural Gas Corporation Application for Approval of a Safety Cost Recovery Mechanism, Or. PUC Docket No. UM 2026. Western Energy Ratemaking Policy
In re Avista Corporation, Request for a General Rate Revision, Or.PUC
Docket No. UG 366. Western Energy Requirement,
In re Portland General Electric, 2020 Annual Update Tariff (Schedule 125), Or.PUC Docket No UE 359. Western Energy Power Cost Modeling
In re PacifiCorp 2020 Transition Adjustment Mechanism, Or.PUC Docket
No. UE 356. Western Energy Power Cost
Modeling
In re PacifiCorp 2020 Renewable Adjustment Clause, Or.PUC Docket No. UE 352. Western Energy Single-Issue Rate Filing
2020 Joint Power and Transmission Rate Proceeding, Bonneville Power
Administration, Case No. BP-20. Western Energy Requirement,
In the Matter of the Application of MSG Las Vegas, LLC for a Proposed
Transaction with a Provider of New Electric Resources, PUC Nv. Docket No. 18-10034
Madison Square Garden Customer Direct Access
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201
PAGE 4 OF 8
Docket Party Topics
Puget Sound Energy 2018 Expedited Rate Filing, Wa.UTC Dockets UE-180899/UG-180900 (Cons.). Western Energy Requirement,
Georgia Pacific Gypsum LLC’s Application to Purchase Energy, Capacity, and/or Ancillary Services from a Provider of New Electric Resources, PUC
Nv. Docket No. 18-09015.
Georgia Pacific Customer Direct Access
Joint Application of Nevada Power Company d/b/a NV Energy for approval of their 2018-2038 Triennial Integrated Resource Plan and 2019-2021
Energy Supply Plan, PUCN Docket No. 18-06003.
Smart Energy Alliance Resource Planning
In re Cascade Natural Gas Corporation Request for a General Rate Revision,
Or.PUC, Docket No. UE 347. Western Energy Requirement,
In re Portland General Electric Company Request for a General Rate Revision, Or.PUC Docket No UE 335. Western Energy Requirement,
In re Northwest Natural Gas Company, dba NW Natural, Request for a
General Rate Revision, Or.PUC Docket No. UG 344. Western Energy Requirement,
In re Cascade Natural Gas Corporation Request for a General Rate Revision, Wa.UTC, Docket No. UE-170929. Industrial Gas Requirement,
In the Matter of Hydro One Limited, Application for Authorization to Exercise Substantial Influence over the Policies and Actions of Avista
Corporation, Or.PUC, Docket No. UM 1897.
Alliance of Western Energy
Consumers
Merger
Application of Rocky Mountain Power for Approval of a Significant Energy Resource Decision and Voluntary Request for Approval of Resource Decision, Ut.PSC Docket No. 17-035-40
Energy Consumers, & Utah Associated
New Resource Addition
In re PacifiCorp, dba Rocky Mountain Power, for a CPCN and Binding
Ratemaking Treatment for New Wind and Transmission Facilities, Id.PUC Case No. PAC-E-17-07
PacifiCorp Idaho
Industrial Customers
New Resource Addition
In re PacifiCorp, dba Pacific Power, 2016 Power Cost Adjustment Mechanism, Or.PUC, Docket No. UE 327. Western Energy Power Cost Deferral
In re PacifiCorp 2016 Power Cost Adjustment Mechanism, Wa.UTC Docket
No. UE-170717 Whitepaper, Power Cost
Deferral
In re Avista Corporation 2018 General Rate Case, Wa.UTC Dockets UE-170485 and UG-170486 (Consolidated).
Customers of Northwest Utilities, & Northwest Industrial Gas
Revenue Requirement, Rate Design
Application of Nevada Power Company d/b/a NV Energy for authority to adjust its annual revenue requirement for general rates charged to all classes of electric customers and for relief properly related thereto, PUCN. Docket Smart Energy Alliance Revenue Requirement
In re the Application of Rocky Mountain Power for Authority to Decrease Current Rates by $15.7 Million to Refund Deferred Net Power Costs Under Tariff Schedule 95 Energy Cost Adjustment Mechanism and to Decrease Current Rates By $528 Thousand Under Tariff Schedule 93, REC and SO2 Revenue Adjustment Mechanism, Wy. PSC, Docket No. 20000-514-EA-17
Wyoming Industrial Energy Consumers
Power Cost Deferral
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201 PAGE 5 OF 8
Docket Party Topics
In re the 2018 General Rate Case of Puget Sound Energy, Wa.UTC, Docket No. UE-170033 (Cons.).
Customers of Northwest Utilities, & Northwest Industrial Gas
Revenue Requirement, Rate Design
In re PacifiCorp, dba Pacific Power, 2018 Transition Adjustment Mechanism, Or.PUC, Docket No. UE 323. Customers of Northwest Power Cost Modeling
In re Portland General Electric Company, Request for a General Rate Revision, Or.PUC, Docket No. UE 319. Customers of Northwest
Revenue
Requirement, Rate Design
In re Portland General Electric Company, Application for Transportation Electrification Programs, Or.PUC, UM 1811. Customers of Northwest Electric Vehicle Charging
In re Pacific Power & Light Company, Application for Transportation Electrification Programs, Or.PUC, Docket No. UM 1810. Customers of Northwest Single-issue Ratemaking
In re the Public Utility Commission of Oregon, Investigation to Examine
PacifiCorp, dba Pacific Power's Non-Standard Avoided Cost Pricing, Or.PUC, Docket No. UM 1802.
Customers of Northwest Qualifying Facilities
In re Pacific Power & Light Co., Revisions to Tariff WN U-75, Advice No. 16-05, to modify the Company’s existing tariffs governing permanent
disconnection and removal procedures, Wa.UTC, Docket No. UE-161204.
Boise Whitepaper,
LLC
Customer Direct Access
In re Puget Sound Energy’s Revisions to Tariff WN U-60, Adding Schedule
451, Implementing a New Retail Wheeling Service, Wa.UTC, Docket No. UE-161123.
Customers of Northwest Customer Direct Access
2018 Joint Power and Transmission Rate Proceeding, Bonneville Power Administration, Case No. BP-18. Customers of Northwest
Revenue
Requirement, Policy
In re Portland General Electric Company Application for Approval of Sale of
Harborton Restoration Project Property, Or.PUC, Docket No. UP 334 (Cons.).
Customers of Northwest Environmental Deferral
In re An Investigation of Policies Related to Renewable Distributed Electric
Generation, Ar.PSC, Matter No. 16-028-U. Electric Energy Net Metering
In re Net Metering and the Implementation of Act 827 of 2015, Ar.PSC, Matter No. 16-027-R. Electric Energy Net Metering
In re the Application of Rocky Mountain Power for Approval of the 2016 Ut.PSC, Docket No. 16-035-01 Utah Associated Power Cost
In re Avista Corporation Request for a General Rate Revision, Wa.UTC, Docket No. UE-160228 (Cons.).
Customers of Northwest Utilities, &
Revenue Requirement, Rate Design
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201 PAGE 6 OF 8
Docket Party Topics
Industrial Gas Users
In re the Application of Rocky Mountain Power to Decrease Current Rates by $2.7 Million to Recover Deferred Net Power Costs Pursuant to Tariff Schedule 95 and to Increase Rates by $50 Thousand Pursuant to Tariff
Schedule 93, Wy.PSC, Docket No. 20000-292-EA-16.
Wyoming Industrial Energy
Consumers
Power Cost Deferral
In re PacifiCorp, dba Pacific Power, 2017 Transition Adjustment Mechanism, Or.PUC, Docket No. UE 307. Customers of Northwest Power Cost Modeling
In re Portland General Electric Company, 2017 Annual Power Cost Update Tariff (Schedule 125), Or.PUC, Docket No. UE 308. Customers of Northwest Power Cost Modeling
In re Pacific Power & Light Company, General rate increase for electric services, Wa.UTC, Docket No. UE-152253. Whitepaper, Requirement,
In The Matter of the Application of Rocky Mountain Power for Authority of a General Rate Increase in Its Retail Electric Utility Service Rates in Wyoming of $32.4 Million Per Year or 4.5 Percent, Wy.PSC, Docket No. 20000-469-
Wyoming
Industrial Energy Consumers
Power Cost Modeling
In re Avista Corporation, General Rate Increase for Electric Services, Wa.UTC, Docket No. UE-150204. Customers of Northwest
Revenue
Requirement, Rate Design
In re the Application of Rocky Mountain Power to Decrease Rates by $17.6 Million to Recover Deferred Net Power Costs Pursuant to Tariff Schedule 95 to Decrease Rates by $4.7 Million Pursuant to Tariff Schedule 93, Wy.PSC, Docket No. 20000-472-EA-15.
Wyoming
Industrial Energy Consumers
Power Cost Deferral
Formal complaint of The Walla Walla Country Club against Pacific Power & Light Company for refusal to provide disconnection under Commission-approved terms and fees, as mandated under Company tariff rules, Wa.UTC, Docket No. UE-143932.
Columbia Rural
Electric Association
Customer Direct
Access / Customer Choice
In re PacifiCorp, dba Pacific Power, 2016 Transition Adjustment Mechanism, Or.PUC, Docket No. UE 296. Customers of Northwest Power Cost Modeling
In re Portland General Electric Company, Request for a General Rate Revision, Or.PUC, Docket No. UE 294. Customers of Northwest
Revenue
Requirement, Rate Design
In re Portland General Electric Company and PacifiCorp dba Pacific Power,
Request for Generic Power Cost Adjustment Mechanism Investigation, Or.PUC, Docket No. UM 1662.
Customers of Northwest Power Cost Deferral
In re PacifiCorp, dba Pacific Power, Application for Approval of Deer Creek Mine Transaction, Or.PUC, Docket No. UM 1712. Customers of Northwest Single-issue Ratemaking
In re Public Utility Commission of Oregon, Investigation to Explore Issues
Related to a Renewable Generator’s Contribution to Capacity, Or.PUC, Docket No. UM 1719.
Customers of Northwest Resource Planning
CASE NO. INT-G-22-07B. MULLINS, DIEXHIBIT NO. 201
PAGE 1 OF 8
CASE NO. INT-G-22-07B. MULLINS, DIEXHIBIT NO. 201
PAGE 1 OF 8
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201 PAGE 7 OF 8
Docket Party Topics
In re Portland General Electric Company, Application for Deferral Accounting of Excess Pension Costs and Carrying Costs on Cash
Contributions, Or.PUC, Docket No. UM 1623.
Customers of Northwest Single-issue Ratemaking
2016 Joint Power and Transmission Rate Proceeding, Bonneville Power Administration, Case No. BP-16. Customers of Northwest
Revenue Requirement,
Policy
In re Puget Sound Energy, Petition to Update Methodologies Used to Allocate Electric Cost of Service and for Electric Rate Design Purposes,
Wa.UTC, Docket No. UE-141368.
Customers of Northwest Cost of Service
In re Pacific Power & Light Company, Request for a General Rate Revision
Resulting in an Overall Price Change of 8.5 Percent, or $27.2 Million, Wa.UTC, Docket No. UE-140762.
Boise
Whitepaper, LLC
Revenue
Requirement, Rate Design
In re Puget Sound Energy, Revises the Power Cost Rate in WN U-60, Tariff G, Schedule 95, to reflect a decrease of $9,554,847 in the Company’s overall
normalized power supply costs, Wa.UTC, Docket No. UE-141141.
Customers of Northwest Power Cost Modeling
In re the Application of Rocky Mountain Power for Authority to Increase Its
Retail Electric Utility Service Rates in Wyoming Approximately $36.1 Million Per Year or 5.3 Percent, Wy.PSC, Docket No. 20000-446-ER-14.
Wyoming
Industrial Energy Consumers
Power Cost Modeling
In re Avista Corporation, General Rate Increase for Electric Services, RE, Tariff WN U-28, Which Proposes an Overall Net Electric Billed Increase of
5.5 Percent Effective January 1, 2015, Wa.UTC, Docket No. UE-140188.
Customers of Northwest Requirement, Rate Design,
In re PacifiCorp, dba Pacific Power, Application for Deferred Accounting and Prudence Determination Associated with the Energy Imbalance Market,
Or.PUC, Docket No. UM 1689.
Customers of Northwest Single-issue Ratemaking
In re PacifiCorp, dba Pacific Power, 2015 Transition Adjustment Mechanism, Or.PUC, Docket No. UE 287. Customers of Northwest Power Cost Modeling
In re Portland General Electric Company, Request for a General Rate Revision, Or.PUC, Docket No. UE 283. Customers of Northwest
Revenue Requirement,
Rate Design
In re Portland General Electric Company’s Net Variable Power Costs (NVPC) and Annual Power Cost Update (APCU), Or.PUC, Docket No. UE
286.
Customers of Northwest Power Cost Modeling
In re Portland General Electric Company 2014 Schedule 145 Boardman Power Plant Operating Adjustment, Or.PUC, Docket No. UE 281. Customers of Northwest Coal Retirement
In re PacifiCorp, dba Pacific Power, Transition Adjustment, Five-Year Cost of Service Opt-Out (adopting testimony of Donald W. Schoenbeck), Or.PUC,
Docket No. UE 267.
Customers of Northwest Customer Direct Access
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 201 PAGE 8 OF 8
Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]
ATTORNEYS FOR ALLIANCE OF WESTERN ENERGY CONSUMERS
BEFORE THE IDAHO PUBLIC UTILITY COMMISSION
CASE NO. INT-G-22-07
EXHIBIT 202 TO ACCOMPANY THE
SETTLEMENT TESTIMONY OF BRADLEY G. MULLINS
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR NATURAL GAS
SERVICE IN THE STATE OF IDAHO
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 2:
Please provide updated revenue requirement based on actual loads and actual test period
results. To the extent this information is not yet available at the time Intermountain responds to
this request, please state when the information will be available and supplement the response to
this request with the information when it becomes available.
RESPONSE NO. 2:
The Company is targeting a late February timeframe for providing an update to the
revenue requirement based on actuals through December 2022.
CASE NO. INT-G-22-07
B. MULLINS, Di
EXHIBIT NO. 202
PAGE 1 OF 6
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jessica
Anderson/Jacob Darrington
REQUEST NO. 21:
Reference Darrington Exhibit 11, Cell “E28”: Please reconcile the (-)$892,950 in plant
related deferred taxes to the approximate (-)$588,524 temporary plant book tax difference in
Exhibit 10, Cells “G47:G48,) which tax effected is just (-)123,590.
SUPPLEMENTAL RESPONSE NO. 21:
In conjunction with its December revenue requirement update provided in the response
Supplemental AWEC PR 2, the Company is supplementing this response to provide an update to
the deferred income taxes related to plant. As part of its December revenue requirement update,
the Company made changes to its tax workpapers and exhibits to make them easier to follow and
to correct issues that were identified while preparing responses to previous production requests.
Exhibit 11 no longer presents a separate value for plant related deferred taxes, but instead
presents total federal deferred income taxes. WP – Deferred Tax provides the breakout of the
federal deferred income taxes, including plant related deferred taxes. Please see the table below
for the components of plant related deferred taxes.
2022 Plant Timing Difference (see Exhibit 10, Cell G51) (2,086,151)
2022 AFUDC Equity Flowthrough Timing Difference (see Exhibit 10, Cell
G50)
217,065
2022 Total Plant/AFUDC Timing Difference (1,869,086)
CASE NO. INT-G-22-07
B. MULLINS, Di
EXHIBIT NO. 202
PAGE 2 OF 6
Deferred Tax Expense at Statutory (Plant Timing Difference ($2,085,790)
X 21% - 1031 LKE Timing Difference ($361) * 35%) (see Exhibit 10,
Cells C51 & E51 for timing differences)
438,142
Amortization of Excess Deferred Income Taxes – Plant ARAM (see
AWEC 19)
(984,992)
Total Deferred Income Tax Expense (Benefit) (see WP-Deferred Tax Cells
E58:E59)
(546,850)
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 202 PAGE 3 OF 6
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jessica
Anderson/Jacob Darrington
REQUEST NO. 23:
Reference Darrington Exhibit 11, Line 34: Please explain why the ITC Amortization is an
increase to income tax expense.
RESPONSE NO. 23:
While preparing its response to this data request, the Company found that it inadvertently
forgot to include the estimated amount of investment tax credit (ITC) generated in 2022 on
Darrington Exhibit 10, Line 50. To comply with IRS normalization rules, the ITC generated in
2022 should be netted with the amount on Darrington Exhibit 11, Line 22 (or cell C34 in the
Excel version) to produce a reduction to income tax expense. This correction will be made, and
an updated yearend value will be provided, when the Company files an update to its revenue
requirement model in late February 2022.
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 202 PAGE 4 OF 6
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jessica
Anderson/Jacob Darrington
REQUEST NO. 23:
Reference Darrington Exhibit 11, Line 34: Please explain why the ITC Amortization is an
increase to income tax expense.
SUPPLEMENTAL RESPONSE NO. 23:
In conjunction with its December revenue requirement update provided in the response
Supplemental AWEC PR 2, the Company is supplementing this response to explain that the
Company changed the presentation on Exhibit 10 to show the calculation of the ITC
Amortization more clearly. As the Company stated in its first response to Request No. 23, it
inadvertently excluded the amount of investment tax credit (ITC) generated in 2022. This issue
has been fixed in the updated presentation of Exhibit 10.
CASE NO. INT-G-22-07 B. MULLINS, Di EXHIBIT NO. 202 PAGE 5 OF 6
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 63:
Reference Intermountain’s Supplemental Response to AWEC Production Request 02:
Please explain the drivers for the reduction in income tax expense relative to Intermountain’s
initial filing. If the change was the result of a correlation identified in a Production Request,
please identify the Production Request.
RESPONSE NO. 63:
The two main drivers of the reduction in income tax expense relate to errors in the tax
workpapers/exhibits in the Company’s original filing. The first error was using an incorrect sign
on plant related deferred taxes on Exhibit No. 11. This error was identified while preparing the
Company’s response to AWEC Production Request No. 21. The second error related to
inadvertently excluding the amount of investment tax credit (ITC) generated in 2022 on Exhibit
No. 10. This error was identified while preparing the Company’s response to AWEC Production
Request No. 23.
Please see the Company’s original and supplemental responses to AWEC Production
Requests Nos. 21 and 23 for more information.
CASE NO. INT-G-22-07
B. MULLINS, Di
EXHIBIT NO. 202
PAGE 6 OF 6
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF MAY 2023 SERVED
THE FOREGOING SETTLEMENT TESTIMONY, IN CASE NO. INT-G-22-07, BY E-
MAILING A COPY THEREOF, TO THE FOLLOWING:
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE, ID 83702
EMAIL: [e-mail]
[e-mail]
BRAD HEUSINKVELD
IDAHO CONSERVATION LEAGUE,
ENERGY ASSOC.
710 N. 6TH ST
BOISE, ID 83702
EMAIL: [e-mail]
WIL GEHL
ENERGY PROGRAM MANAGER
BOISE CITY DEPT. OF PUBLIC WRKS
150 N. CAPITOL BLVD
P.O. BOX 500
BOISE, IDAHO 83701
EMAIL: [e-mail]
JAN NORIYUKI, COMMISSION SECRETARY
IDAHO PUBLIC UTILTIIES COMMISSION 11331 W. CHINDEN BLVD, BLDG 8 SUITE 201-A
BOISE ID 83707
E-MAIL: [e-mail]
MARIE CALLAWAY KELLNER ATTORNEY
IDAHO CONSERVATION LEAGUE
710 N. 6TH ST. BOISE, ID 83702
EMAIL: [e-mail]
DARRELL EARLY
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY’S OFFICE 150N.
CAPITOL BLVD
P.O. BOX 500
BOISE, IDAHO 83701-0500
EMAIL: [e-mail]
[e-mail]
[e-mail]
CLAIRE SHARP RILEY NEWTONDEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 11331 W. CHINDEN BLVD, BLDG 8 SUITE 201-A
BOISE, ID 83714EMAIL: [e-mail] [e-mail] __________________________
Chad M. Stokes
Attorneys At Law
1455 SW Broadway, Suite 1500
Portland, OR 9701
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Alliance of Western Energy
Consumers