20130208Staff 11-14 to IGC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEVEiJ
?.813FE88 Mi113
IDAHO UTILrnES Cc4SO1
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. )
)
)
)
)
))
CASE NO. INT-G-13-02
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,
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
FRIDAY, FEBRUARY 22, 2013.1
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.
'Staff is asking for an expedited response. Please contact Staffs attorneys if you believe an expedited response will
be problematic.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 FEBRUARY 8, 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. 11: Please explain how the 50% allocation of margin (derived from the
"Sales Price Adder") will be credited to the different utility customer classes in the PGA.
REQUEST NO. 12: Please explain how the $0.25 per LNG gallon credit for O&M and
the $0.25 per LNG gallon credit for Accelerated Capital Cost will flow through the PGA
mechanism and how the credits will be allocated to the different classes.
REQUEST NO. 13: Please explain the differences between Exhibit No. 3 in the
Application and Workpaper No. 5 contained in the Application for Case No. INT-G- 12-01.
REQUEST NO. 14: On page 5 of the Company's Application, it 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." Please explain how the Company will ensure
that lower-cost gas purchases are not allocated to non-utility LNG sales rather than to purchases
required to meet utility customer demand. Also, please explain how the allocation methodology
can be verified in the PGA audit.
DATED at Boise, Idaho, this day of January 2013.
Al
I
Karl T. Klein
Deputy Attorney General
Technical Staff: Mike Louis! 11 -14
i:umisc:prodreq/intg13.2kkm1 2nd pr.doc
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 FEBRUARY 8,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF FEBRUARY 2013,
SERVED THE FOREGOING SECOND 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
DAVID SWENSON
LORI BLATTNER
INTERMOUNTAIN GAS CO
P0 BOX 7608
BOISE ID 83707
.\
S'fCkE-T-ARY
CERTIFICATE OF SERVICE