20240906INT to Staff 2-4.pdf

INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S FIRST PRODUCTION REQUEST PAGE 1 OF 2
18531774.1)
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY’S REQUEST FOR
AUTHORITY TO DECREASE ITS PRICES
Case No. INT-G-24-04
INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF
Intermountain Gas Company (“Intermountain” or “Company”), in response to the First
Production Request of the Commission Staff to Intermountain Gas Company dated August 16,
2024, submits the following responses. Confidential responses and documents are subject to the
protective agreement in this case, and will be provided separately by email.
DATED: September 6, 2024.
By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company.
RECEIVED
FRIDAY, SEPTEMBER 6, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S FIRST PRODUCTION REQUEST PAGE 2 OF 2
18531774.1)

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on September 6, 2024, I caused a true and correct copy of
the foregoing to be served upon the following parties as indicated below:

Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington/Lori Blattner
REQUEST NO. 2:
Please provide a copy of any changes made to the policies or procedures used to identify
the amount of capacity reservations maintained by the Company since the 2023 Purchase Gas
Adjustment (“PGA”).
RESPONSE NO. 2:
The Company’s current policies and procedures around identifying the amount of firm
transportation capacity reservation commitment include, but are not limited to, the following:
•The Company uses its Integrated Resource Plan (“IRP”) process to determine the
amount of firm transportation capacity to be held by Intermountain to serve its
residential, commercial, and industrial customer base now and into the future.
Measures assessed in the IRP include, but are not limited to, the following:
o The Company’s multi-year load duration curves under both normal as well as
design weather conditions
o Customer future load growth projections
o Available firm storage capacity – both supply source storage as well as LNG
peaking storage
o Cost effective and reliable alternatives to storage such as short-term city gate
delivered gas supply availability.
In addition to the above, the Company monitors the following items when determining
the amount of firm interstate pipeline transportation capacity to hold:
INT-G-24-04
IPUC Staff PR 2
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•Longer term forward price predictions on the futures market from supply regions
(Alberta, British Columbia and US Rockies) and applicable price points available to
Intermountain,
•Use of long-term temporary pipeline capacity segmentations,
•Unsubscribed capacity available on Northwest Pipeline, LLC (“NWP”), Gas
Transmission Northwest (“GTN”), Foothills and/or Nova that would deliver gas
supplies on a firm basis to the Company’s service territory,
•Upcoming potential pipeline capacity open seasons on NWP, GTN, Foothills and/or
Nova,
•Existing pipeline shippers, if any, interested in permanently releasing their firm
transportation capacity.
INT-G-24-04
IPUC Staff PR 2
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington/Lori Blattner
REQUEST NO. 3:
Please provide natural gas purchase invoices for November 2023 through June 2024
reconciled to the PGA deferrals in the quarterly reports.
RESPONSE NO. 3:
This information was provided during the on-site audit.
INT-G-24-04
IPUC Staff PR 3
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Niki Ogami/Lori Blattner
REQUEST NO. 4:
Please provide Lost and Unaccounted for Gas amounts by year reported to Pipeline and
Hazardous Material Safety Administration for the five-year period of 2020 through 2024.
Include the Company’s Lost and Unaccounted for Gas amounts reported in 2020 through 2024
PGAs and explain any differences between the two.
RESPONSE NO. 4:
The percent of Lost and Unaccounted for Gas reported to PHMSA and in the PGA are
included on the attachment “PR #4 – Percent of Lost and Unaccounted for Gas”. The Company
notes that the PHMSA report for the 2024 calendar year will be filed by March 15th of 2025,
therefore, the Company provided the percent of Lost and Unaccounted for Gas reported in the
2020-2023 PHMSA reports. The Company further notes that instances of found gas were
reported as zero to PHMSA for the 2020-2021 reports.
The difference between the Lost and Unaccounted for Gas numbers reported to PHMSA
versus those reported in the PGA filing is timing. The percent of Lost and Unaccounted for Gas
in the PHMSA report covers the reporting period of July 1 – June 30 and the PGA covers
October 1 – September 30. Because of this, the PHMSA report will include the prior year
unbilled true-up adjustment performed by the Company’s accounting department and the PGA
will include the current year unbilled true-up adjustment. Further, the amount of pipeline
imbalance fluctuates from month to month and will not be the same in June, which is the ending
period in the PHMSA report, as it is in September, which is the ending period in the PGA.
INT-G-24-04
IPUC Staff PR 4
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