20120830Staff 12-13 to INTG.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
ViAUItIi1JIW
cDAHO rrt! U I
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
THIRD 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 THURSDAY, SEPTEMBER 6, 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.
THIRD PRODUCTION REQUEST TO
INTERMOUNTAIN GAS 1 AUGUST 30, 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. 12: Please provide the amount of LNG storage capacity the Company
expects to utilize from September 2012 through March 2013 by providing a forecasted percent
utilization on the first day of each respective month for each facility.
REQUEST NO. 13: Please provide the Company's actual lost and unaccounted for gas
and corresponding total throughout the last three years. Also, please provide information that
shows that proper adjustments were made to L&U gas for losses due to errors in faulty meters
and measurement control practices.
DATED at Boise, Idaho, this 3y of August 2012.
Neil Price
Deputy Attorney General
Technical Staff: Mike Louis/12-13
i:umisc:prodreq/intgl 2.1 npml prod req3
THIRD PRODUCTION REQUEST TO
INTERMOUNTAIN GAS 2 AUGUST 30, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF AUGUST 2012,
SERVED THE FOREGOING THIRD 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
LORI.BLATTNER)intgas.com
STEPHEN R THOMAS
MOFFATT THOMAS ET AL
P0 BOX 829
BOISE ID 83701-0829
E-MAIL: [e-mail]
SECRETA
CERTIFICATE OF SERVICE