20130129Staff 1-10 to IGC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
1061 -9-16YA-1191wil
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
2U3JAN29 ANII:51
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
INTERMOUNTAIN GAS COMPANY TO SELL )
LIQUIFIED NATURAL GAS. )
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CASE NO. INT-G-13-02
FIRST 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,
Karl T. Klein, Deputy Attorney General, requests that Intermountain Gas Company (Company)
provide the following documents and information as soon as possible, by but no later than
TUESDAY, FEBRUARY 19, 2013.
This Production Request is to be considered as continuing, and the 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 or information produced.
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.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 JANUARY 29, 2013
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Page 5 of the Application says: "the company proposes to separately
account for any quantities of natural gas liquefied for non-utility sales and track all related costs
independent of utility costs." Are these costs incremental or inclusive of the $0.25/gallon credit
for O&M and accelerated capital expense?
REQUEST NO. 2: How did the Company derive the $0.25/gallon rate for accelerated
future capital cost? Please provide the data and derivation of the cost as well as an explanation
of the method. Please include all workpapers with formulas intact.
REQUEST NO. 3: Please explain the following passage found on page 6 of the
Application: "the company also proposes to set aside an additional $0.25 per each gallon sold to
defray any such accelerated (capital) costs." Does this mean that the funds will be used "just-in-
case" there are additional capital expenditures or does this mean $0.25 will be credited to utility
customers for capital expenditures for every gallon of LNG sold to non-utility customers?
REQUEST NO. 4: How did the Company derive the $0.25/gallon rate for O&M
recovery? Please provide the data and derivation of the cost as well as an explanation of the
method. Please include all workpapers with formulas intact.
REQUEST NO. 5: Please provide the basis or rationale used to determine the 50/50
sharing allocation of net revenue in the Company's proposal.
REQUEST NO. 6: What are the Company's potential risks of selling LNG to non-utility
customers justifying the Company's 50/50 sharing proposal?
REQUEST NO. 7: Please explain operationally (procedurally) how the Company will
maintain minimum levels of LNG necessary to maintain full peak-shaving capability (plus 50%
reserve margins) while supplying LNG to non-utility customers.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 JANUARY 29, 2013
REQUEST NO. 8: Page 4 of the Application says: "Intermountain proposes to only use
capacity in excess of utility peak shaving needs for non-utility sales and only until such time as
system growth would indicate that all Nampa capacity might be needed to meet core market
needs." Please explain the criteria and the method for determining when this happens.
REQUEST NO. 9: Please explain how the Company will ensure that incremental gas
purchased to meet the needs for non-utility LNG sales will not adversely affect the cost of gas to
its utility customers. What cost will be used to determine actual mainline gas cost used for non-
utility LNG sales and how will it be determined?
REQUEST NO. 10: According to the Company's Application, LNG sales price to non-
utility customers will be market-based. Please provide the methods, standards and/or indexes the
Company plans to use as a basis for setting these prices.
DATED at Boise, Idaho, this 2 day of January 2013.
A / -
Karl T. V lein
Deputy Attorney General
Technical Staff: Mike Louis/1 -10
i:umisc:prodreq/intg13.2kkm1 1 pr.doc
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 3 JANUARY 29, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF JANUARY
2013, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO.
INT-G-13-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
SCOTT MADISON
EXEC. VP & GENERAL MANAGER
INTERMOUNTAIN GAS CO
P0 BOX 7608
BOISE ID 83707
CERTIFICATE OF SERVICE