20140822Staff 1-8 to INT-G.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO CHANGE ITS PRTCES (2014
PURCHASED GAS COST ADJUSTMENT).
RECr.i\1r r:
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. INT.G.14.O1
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the ldaho 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, but no later than
FRIDAY, SEPTEMBER 5, 2014.r
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
I Staffis asking for an expedited response.
attomey at [phone].
FIRST PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS
If responding by this date will be problematic, please call Staff s
AUGUST 22,2014
the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder.
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: Please provide the Gas Loss Reports from each line break that
occurred during this Purchased Gas Cost Adjustment (PGA) year.
REQUEST NO. 2: Aldyl-A pipe manufactured prior to 1984 has been shown to be
susceptible to cracking under certain circumstances. What percentage of the Company's annual
throughput is transported through Aldyl-A distribution pipe identified as being susceptible to
cracking?
REQUEST NO.3: Please explain how the Company plans to manage the replacement
of its Aldyl-A pipe susceptible to cracking. As part of your response, please describe the
replacement schedule and how it will impact gas loss.
REQUEST NO. 4: For this PGA year, please provide a schedule of the Company's
expenses at its Nampa Liquefied Natural Gas (LNG) facility. As part of the response, please
explain how the funds collected from the sale of LNG were used in accordance with Order No.
32793 (i.e. - Operations and Maintenance of the LNG facility, or LNG facility capital
improvements).
REQUEST NO. 5: Before 2012, the peak day used for allocating the volume-weighted
average costs of gas occurred in 1990. Since the2012 PGA, the Company has been using a2009
peak day. Has the Company experienced a higher peak day since 2009? If so, when did the
peak day occur, and how would the volume weighted average cost of gas be allocated using the
more recent peak day?
REQUEST NO. 6: Please explain how reduced throughput impacts the weighted
average cost of gas (WACOG).
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS AUGUST 22,2014
REQUEST NO. 7: For CY2013, please provide the number of customers that moved to
a different rate schedule, listing both the previous and new rate schedule assigned.
REQUEST NO. 8: For this PGA year, has the Company included a bill stuffer
explaining its different rate schedules and how they apply to various types of service, particularly
for the residential, small-commercial and intemrptible snowmelt schedules? If so, please provide
a copy of the bill stuffer and state when it was mailed to customers. If not, please explain why
not.
DATED at Boise, Idaho, this ?.')"1 day of August 2014.
ryl .t lc
Karl T. Klein
Deputy Attomey General
Technical Staff: Matt Elam/l-8
i:umisc:prodreq/intgl4. lkkme prod reql
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS AUGUST 22,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY oF AUGUST 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-I4-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P MoGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE