20120828Staff 3-11 to INTG.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECEiVED
EHO PUEiL.tC
UT tLI It-:S
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF INTERMOUNTAIN GAS COMPANY )
FOR AUTHORITY TO DECREASE ITS )
PRICES )
)
)
)
)
CASE NO. INT-G-12-01
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN
GAS COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Intermountain Gas Company (Company;
Intermountain Gas) provide the following documents and information as soon as possible, but no
later than TUESDAY, SEPTEMBER 11, 2012.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Intermountain Gas 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.
SECOND PRODUCTION REQUEST TO
INTERMOUNTAIN GAS 1 AUGUST 28, 2012
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 3: Please provide the analysis used to determine monthly normalized
2011 sales volumes for Exhibit No. 4. This should include the total actual therms and weather
normalized therm adjustments used to determine the normalized volumes for each customer class
(See audit request #29 from 2011 PGA). Please provide analysis in Excel format with all
formula intact.
REQUEST NO. 4: Please provide actual purchased gas volumes, 2 years historic
(October, 2010— September 2011) and one year forecasted (October 2012-September 2013) of
both storage and flowing supply purchases from Sumas, Rocky Mountain, and AECO basins
(See audit request #27 from 2011 PGA).
REQUEST NO. 5: Please provide 12 months of historic and 12 months of forecasted
average monthly purchased cost of gas (per dekatherm) for all injections into the Nampa and
Plymouth storage facilities.
REQUEST NO. 6: Please provide an explanation of changes that the Company has
made in its procurement practices and hedging strategies as a result of current low gas prices.
Please justify changes to the Company's practices and/or explain why the Company has decided
to continue with current practices.
REQUEST NO. 7: Please provide an explanation and a breakdown of the costs used to
determine the purchased price per dekatherm for gas forecasted to be pulled out of Jackson
Prairie and Clay Basin storage as shown on Workpaper #9. Please include an explanation why
there are differences in cost between IGI Resources and Occidental Marketing for pulls from the
same storage facility.
SECOND PRODUCTION REQUEST TO
INTERMOUNTAIN GAS 2 AUGUST 28, 2012
REQUEST NO. 8: Please provide a list of transactions and contracts for locked-in gas
that is included in load requirements for this years's PGA. For each transaction, please provide a
transaction reference number, the type of contract, the basin from which the gas was purchased,
the transaction date, the transaction beginning and ending dates, the volume or quantity, and the
price per dekatherm.
REQUEST NO. 9: Please provide an explanation and a breakdown of the contractual
terms used to determine prices for option priced and fixed priced physical gas as shown on
Workpaper #9.
REQUEST NO. 10: Please explain Rockies Index Gas cost differences between IGI and
Occidental Marketing as shown on Workpaper #9.
REQUEST NO. 11: Please provide the amount of incremental capacity included in
future capacity contracts (see page 4, section IV. of application) and the analysis used to
determine the incremantal amount. Please provide analysis in Excel format with all formula
intact.
DATED at Boise, Idaho, this Zay of August 2012.
Deputy Attorney General
Technical Staff: Mike Louis/3-11
i:umisc:prodreq/intg12. lnpml prod req2
SECOND PRODUCTION REQUEST TO
INTERMOUNTAIN GAS 3 AUGUST 28, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28 ' DAY OF AUGUST 2012,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-12-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
SCOTT MADISON
VP & CHIEF ACCT OFFICER
INTERMOUNTAIN GAS CO
P0 BOX 7608
BOISE ID 83707
SCOTT.MADISON(intgas.com
[e-mail]
STEPHEN R THOMAS
MOFFATT THOMAS ET AL
STE 1000
101 S CAPITOL BLVD
BOISE ID 83702
\JO/UY(
SECRET4Y
CERTIFICATE OF SERVICE