20160907Staff 25-34 to INT.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
R'":CE!VED
20 l fJ SEP -7 A 9: 5 4
I · .: '. :,, PU8LIC
. 1 '..: ·:,:~. COM 41SSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE ITS )
RATES AND CHARGES FOR NATURAL GAS )
SERVICE. )
)
)
)
) ___________________ )
CASE NO. INT-G-16-02
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (lntermountain Gas; Company) provide the following documents and information as soon
as possible, and no later than WEDNESDAY, SEPTEMBER 28, 2016.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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 IDAP A
31.01.01.228.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 SEPTEMBER 7, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 25: Please provide a detailed explanation for the difference between the
Total RS Margin of $60,988,492 on line 6 of Exhibit No. 27, and the $56,830,872 Distribution
Revenue Requirement found on page 4 of Exhibit No. 20.
REQUEST NO. 26: Please describe in detail the components of the capacity, customer,
and commodity related revenue requirements for the storage, transmission, distribution and gas
functional groups shown on page 4 of Exhibit No. 20.
REQUEST NO. 27: Please provide the data and workpapers used to develop the regression
equations described on pages 3-5 of Ms. Blattner's testimony.
REQUEST NO. 28: Please describe the method and provide the workpapers used to weigh
customer weather data described on page 4 of Ms. Blattner's testimony.
REQUEST NO. 29: The Company provides different customer counts in its Application
and throughout the testimony of several witnesses. Please explain the following discrepancies,
particularly how any corrections might impact the proposed rates:
• Application at pg. 2 334,650
• Kivisto Direct at 2, ln. 14 339,000
• Madison Direct at 2, In. 9 334,650
• Gilchrist Direct at 5, lns. 2, 3 334,650
• Gaske Direct at 4, In. 13 320,000
• Blattner Workpaper No. 8 338,798
REQUEST NO. 30: Hart Gilchrist suggests in his testimony that the Infrastructure Cost
Recovery Mechanism (ICRM) would be a better way to fund and replace pipeline infrastructure.
Please explain how the ICRM mechanism would have changed the Company's pipeline
replacement practices incorporated into this case. Gilchrist Direct at 15, lines 5-7.
SECOND PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 2 SEPTEMBER 7, 2016
REQUEST NO. 31: Hart Gilchrist states in his testimony that " ... Intermountain is using
a systematic approach to identify the elevated risk pipe segments .... " Please describe the
Company's approach to prioritizing pipeline replacements. Gilchrist Direct at 15, lines 17-18.
REQUEST NO. 32: David Swenson states in his testimony that the Company educates
customers regarding the economic and operational value of properly setting the Maximum Daily
Firm Quantity (MDFQ). Please describe how the Company educates customers about MDFQ and
include any applicable publications, instructions, or other documentation. Swenson Direct at 8,
lines 10-13.
REQUEST NO. 33: Lori Blattner's testimony references a Cost of Meters Study in her
testimony. Please provide the Cost of Meters Study in executable electronic format with formulas
intact. Blattner Direct at 13 , lines 4, 5.
REQUEST NO. 34: Lori Blattner's Exhibit No. 19 references a 2015 Mains Study. Please
provide a copy of the 2015 Mains Study in executable electronic format with formulas intact.
DA TED at Boise, Idaho, this ? .,,,... day of September 2016.
Technical Staff: Mark Rogers/25-26
Mike Morrison/27-28
Kevin Keyt/29-34
i:umisc:prodreq/intg 16.2kkscmrmmksk prod req2
SECOND PRODUCTION REQUEST
TO INTERMOUNT AIN GAS
Sean Costello
Deputy Attorney General
3
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SEPTEMBER 7, 2016
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR -REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE