20010215First Production Request.pdf

- 531
LISA D. NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5733
pr:rr:I\Id,_VI...i Ii
:-i
, ",- -
('3
2001 FE8 15 AH 9: 39
;:.;"\. ,
0 ;~U8LjC
' 1
"-';:
""C'Ui LI it:...; '
;:'.)
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.
FIRST 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 Intennountain Gas Company
(Intennountain; Company) provide the following documents and infonnation, pursuant to
Commission Rule of Procedure 225 , IDAPA 31.01.01.225 , on or before MARCH 8, 2001.
This Production Request is to be considered as continuing, and Intennountain Gas
Company is requested to provide, by way of supplementary responses, additional documents that
it or any person acting on its behalf may later obtain that will augment the documents produced.
When answering each question please submit supporting workpapers that provide detail
or are the source of infonnation used in calculations. Pursuant to Commission Rules of
Procedure, responses must include the name and phone number of the person preparing the
document as well as the name, location and phone number of the record holder. Reference
IDAPA 31.01.01.228. If the person who prepared the answer to a particular question is different
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY FEBRUARY 15 2001
than the individual responsible for the document as a whole, please indicate the name of the
person(s) preparing the particular answer, their job title, and the witness who can sponsor the
answer at hearing. For all responses to the following requests, please provide all
workpapers, diskettes (3.5 in.) and all underlying formulas in Excel (version 5) language.
Request No.1: In Order No. 28578 of Case No. ~T-00-2 the Commission ordered
that "
.. .
Intennountain Gas analyze the cost-effectiveness of its relationship with its gas suppliers
and gas purchasing policies, and file results of that analysis with the Commission..." Please
provide copies of all analyses with all supporting workpapers and documentation.
Request No.2: Please provide a description of Intennountain s decision-making process
when contracting for gas purchases.
Request No.3: Please provide any written policies and descriptions of any unwritten
policies that have been consulted by Intennountain Gas when making natural gas purchases.
Request No.4: Please provide:
a) any studies perfonned by the Company or its agents
to detennine the best natural gas supply portfolio;
b) any Company and/or customer risk assessments consulted by
the Company when detennining its natural gas supply
portfolio; and
c) all analyses that justify the decision to become 100%
dependant on the spot market.
Request No.5: In regards to the Company s use of storage:
a) What are the costs and/or benefits (financial and otherwise) of using
storage versus financial instruments or other physical purchases for a
natural gas hedge against prices fluctuations?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY FEBRUARY 15 2001
b) Please provide the infonnation upon which the Company detennined
that it is operating at the optimum level of storage for customers.
Request No.6: Please provide the analysis from which the Company detennined that its
Duke Energy storage agreement was the best alternative for Idaho customers.
a) What benefits have customers received as a result of the Duke
Agreement?
b) What benefits have accrued to IGI Resources as a result of the Duke
storage contract?
Request No.7: Please explain Intennountain s decision since 1999 not to hedge against
market volatility (other than with storage) and provide any supporting documentation.
Request No.8: In Case No. INT-99-1 the Commission ordered (Order No. 28109)
that due to the continuously changing gas industry
. . .
the Company should periodically test the
waters to detennine whether other marketers have the ability to provide similar or better services
at competitive prices.
a) Please provide the Company s latest assessment of other marketers
services and the costs thereof.
b) Please provide Intennountain s criteria for choosing a gas marketer
documentation for the decision to retain IGI upon completion of the
study, and the rankings of other marketers considered by
Intennountain based upon the Company s criteria.
Request No.9: Please provide a copy of the current gas marketing agreement between
IGI and Intennountain Gas.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY FEBRUARY 15 2001
Request No. 10: Given the recent change in ownership ofIGI Resources, please explain
how the current contract differs from the contract used while IGI was an affiliate of
Intennountain Gas.
Request No. 11: In accordance with Commission Order No. 25342 (Case No. GNR-93-
2) and as modified by Order Nos. 27098 and 27024 (Case No. INT-97-2), Intennountain Gas is
required to biennially file a Natural Gas Integrated Resource Plan (IRP). Please provide a copy of
Intennountain s current IRP. If it is not yet complete, please state when it will be complete and
provide a copy of Intennountain s last IRP.
Request No. 12: Given the current instability of natural gas prices, please provide
Intennountain s assessment of:
a) potential demand side management programs;
b) alternative resource locations;
c) storage usage;
d) long-tenn fixed price contracts; and
e) price hedging alternatives over the entire planning horizon
of the IRP.
Please ensure the above topics are also considered in the pending Integrated Resource Plan along
with any other statutory requirements.
Request No. 13: Please provide the Company s recommendation on how the Commission
could structure an incentive-based purchase gas cost adjustment (PGA) mechanism.
Request No. 14: What percentage of risk is reasonable for the Company to share for its
gas purchase decisions?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY FEBRUARY 15 2001
'ib
Dated at Boise, Idaho, this /5 day of February 2001.
Technical Staff: Michael Fuss
Alden Holm
LN: gdk:i :lumisc/comments/intgO l.lnrnfussah
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
INTERMOUNTAIN GAS COMPANY
Lisa D. Nordstrom
Deputy Attorney
FEBRUARY 15 2001
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF FEBRUARY 2001
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-Ol-, 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 ID 83701-0829
MIKE McGRATH
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE, ID 83707
~jla:o~
SECRETARY
CERTIFICATE OF SERVICE