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LISA D. NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0314
IDAHO BAR NO. 5733
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
INTO THE PURCHASE GAS ADJUSTMENT
(PGA) MECHANISM AND THE NATURAL
GAS PURCHASING POLICIES OF
INTERMOUNTAIN GAS COMPANY.
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
CASE NO. INT-Ol-
The Staff of the Idaho Public Utilities Commission by and through its attorney of record
Lisa D. Nordstrom, Deputy Attorney General, requests Intermountain Gas Company
(Intermountain; Company) provide the following documents and information, pursuant to
Commission Rule of Procedure 225 , IDAP A 31.01.01.225. The Company shall be prepared to
answer the following list of questions at the scheduled April 9 meeting.
Please bring all supporting information and documents necessary to answer Staff
questions at the April 9 meeting. Based on the information provided at the meeting, Staff will
determine if additional written response is necessary.
Request No. 15: What is Intermountain Gas Company doing differently this year to
reduce the deferral account and cost of gas purchases to below the approved weighted average
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2 2001
cost of gas (W ACOG)? Please include an analysis showing this year as compared to previous
years.
Request No. 16: How does the Company plan to improve price stability for its
ratepayers? Please include all specific information available such as contracts, hedges, etc.
Request No. 17: In the letter dated March 8, 2001 , the Company stated that it made
decisions not to secure gas because gas prices were anticipated to go down in 1999 and 2000.
Please provide all meeting notes, memorandums, decision flow charts that include personnel
involved, or any other documentation the Company can provide that outlines the decision
process during this time period.
Request No. 18: Please provide (confidentially, if necessary) any written policies used
by the Company when making Natural Gas purchases.
Request No. 19: Provide an analysis showing the cost and any premium over the
physical price of gas for the possible financial hedge products outlined in your letter dated
March 8 , 2001 on page 6 (i., Price Caps, Price Collars, Portfolio Pricing, Extendables
Participating Options, and IGI Pool Participation). Please define all of the products and any
possible effects of these products to ratepayers.
Request No. 20: Given the Company s reliance on storage for price protection, please
provide a cost comparison between storage costs (including losses, fuel and any other costs
associated with storage use) as compared to all costs associated with financial hedges.
Request No. 21: What price is anticipated for storage gas in the next 12 months?
Request No. 22: What steps has Intermountain Gas taken to ensure storage gas is
purchased at the lowest price?
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2, 2001
Request No. 23: Please provide the information and resulting analysis upon which the
Company determined that it is operating at the optimum level of storage for its customers.
Request No. 24: Please provide an analysis showing storage injections and withdrawals
for fiscal years: 1996, 1997, 1998, 1999 2000 and proforma 2001. Please include the price paid
for stored gas and the market price for gas available on the wholesale market when storage gas
was withdrawn.
Request No. 25: Please provide the names, qualifications, and job descriptions of all
natural gas traders on Staff with the Company.
Request No. 26: How is IGI Resources directed to make spot market purchases for the
Company?
Request No. 27: What parameters or guidelines does the company impose on IGI
Resources when it makes spot market purchases for the Company?
Request No. 28: Which individuals are responsible for directing IGI Resources to make
spot market purchases for the Company?
Request No. 29: Which individuals at Intermountain Gas oversee the daily purchases
made by IGI Resources and confirm that purchases are made at the lowest prices and are in the
best interest of ratepayers?
Request No. 30: Which individuals at Intermountain Gas are responsible for making the
forward decisions on Gas Purchases?
Request No. 31: Which individuals at Intermountain Gas are involved in setting natural
gas purchase policy?
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2 2001
Request No. 32: Please provide confidential copies of all of the Company s existing gas
purchase contracts.
Request No. 33: Please provide the anticipated price (unit price and total contract
amount) for gas purchased under these contracts for the next 12 months.
Request No. 34: Please provide the annual quantity of gas purchased at index prices, the
actual index price, and any adders.
Request No. 35: Provide the Company s load projections in aggregate and by customer
class for the next 12 months.
Request No. 36: Provide the Company s market price projections for natural gas for the
next 5 years.
Request No. 37: Please provide the Company s annual natural gas purchase projections
for the next 5 years including quantity, price and W ACOG.
Request No. 38: Please provide an update of actual purchases shown on the
Intermountain Gas W ACOG Calculation spreadsheet from the most recent PGA filing.
Request No. 39: What is the expected deferral amount for the next 12 months under
current regulatory conditions?
Request No. 40: When does Intermountain Gas anticipate its next PGA filing will
occur? What does the Company anticipate that increase with be?
Request No. 41: Please provide any studies performed by the Company or its agents
determining the best natural gas supply portfolio with respect to both reliability and price.
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2 2001
Request No. 42: In the January 1996 Integrated Resource Plan (IRP) the Company
recognized potential problems with supply from Sumas. The Company stated that the percentage
of future natural gas supply from Sumas will be reduced from a high of about 63 % to
approximately the following:
Sumas 20%Alberta 40%Rockies 40%
Based on the Company s March 8 letter the Company s current supply portfolio is:
Location Daily Volume Annual VolumeSumas 28.1 % 48.Alberta 9.6% 16.Rockies 62.3% 35.
a) What were the assumptions made and analysis performed to determine the above
supply portfolio?
b) What situations changed that caused the Company to move away from the direction
stated in its 1996 IRP?
c) How does this new portfolio provide optimum price and reliability for Idaho
ratepayers?
d) How would ratepayers have been affected if the Company had achieved the 1996 IRP
goals?
Request No. 43: What is the availability oflonger term (greater than 2 year) fixed price
contracts?
Request No. 44: What are the typical terms included in fixed price contracts?
Request No. 45: What is the Company s evaluation of fixed price contracts with regard
to financial and other considerations?
Request No. 46: How much of the Company s gas is purchased on both firm supply and
firm price? What is the cost for this gas?
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2 2001
Request No. 47: When did the Company s last fixed price contract expire?
Request No. 48: Has the Company considered purchasing natural gas production?
Request No. 49: Please provide any analysis the Company or its agents have performed
regarding the purchase of natural gas production.
Request No. 50: Acquisition of natural gas resources can be obtained in many ways.
One method is through demand side management. What, if anything, is the Company proposing
in this area?
Request No. 51: Could the Company offer ratepayers longer term price stability? If so
at what cost?
Request No. 52: Could the Company offer individual customers supply options such as:
, 2, or 3- year contract prices, spot market prices, or Company portfolio pricing? If so, what is
the anticipated cost of these programs? Ifnot, why not?
Request No. 53: The Commission has ordered the Company on several occasions to
provide a price comparison and analysis of equivalent service providers other than IGI
Resources. When will the Company complete the required analysis?
Request No. 54: How can the price actually paid by IGI Resources be verified to ensure
that Intermountain Gas is paying the same price for the gas?
Request No. 55: Did Intermountain Gas, its customers, and/or IGI resources gain any
benefit from capacity releases or off-system sales in the past 6 months? If so, what are the dollar
amounts for each: Intermountain Gas, Intermountain Gas Customers, and IGI Resources?
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2, 2001
Request No. 56: Provide an analysis showing off-system sales in fiscal years 1999 2000
and 2001. In this analysis, please show if the sale was made from contracts or storage, the price
paid by Intermountain Gas (including any costs paid to IGI Resources), the price the gas was
sold for, and which company purchased the gas.
Request No. 57: How are Intermountain Gas Company stockholders affected by the
increased cost of gas?
0l-
Dated at Boise, Idaho, this day of April 2001.
A/
Lisa D. Nordstro
Deputy Attorney General
Technical Staff: Michael Fuss
Alden Holm
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SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY APRIL 2, 2001
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF APRIL 2001
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-
01-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MICHAEL E HUNTINGTON
VP GOVERNMENTAL AFFAIRS
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE ID 83707
MORGAN W RICHARDS JR
MOFFATT THOMAS ET AL
PO BOX 829
BOISE ill 83701-0829
MIKE McGRATH
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE, ID 83707
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SECRETARY
CERTIFICATE OF SERVICE