20160922SUGAR 1-3 to INT.pdf

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Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 2ih Street
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar Company LLC
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. INT-G-16-02
APPLICATION OF INTERMOUNTAIN )
GAS COMP ANY FOR THE AUTHORITY ) FIRST PRODUCTION REQUEST OF
TO CHANGE ITS RATES AND ) THE AMALGAMATED SUGAR
CHARGES FOR NATURAL GAS ) COMPANY LLC
_S_E_R_V_IC_E_IN_T_H_E_S_T_A_T_E_O_F_I_D_A_H_O __ )
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Amalgamated Sugar Company LLC (Amalgamated Sugar) by and
through their attorney of record, Peter J. Richardson, hereby requests that the Intermountain Gas
Company ("Company") provide the following documents.
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 produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please also provide one electronic copy and one
physical copy, to Scott Dale Blickenstaff, The Amalgamated Sugar Company LLC, 1951 S.
Saturn Way, Ste. 100 Boise, Idaho 83702, [e-mail] [phone]. For
each item, please indicate the name of the person(s) preparing the answers, along with the job
title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO. 1
Please provide all discovery responses along with the work papers and attachments
provided to all other parties.
REQUEST FOR PRODUCTION NO. 2
Please provide copies of all material provided to the PUC and/or its Staff regarding the
Company's Application that were provided other than through formal discovery.
REQUEST FOR PRODUCTION NO. 3
Page 4 of the Company's Application provides, "Microsoft Excel based computer
modeling, used by the Company to calculate revenue requirement and upon which allocations of
revenue requirement have been based will be provided to Commission Staff on computer disk."
Please provide copies of the referenced "computer disk[ s ]" with all formulae intact.
DATED this 22nd day of September, 2016
Richardson Adams, PLLC
Byiyd)~
Peter J. Richardson
RICHARDSON ADAMS, PLLC, attorneys for
The Amalgamated Sugar Company LLC
First Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page 2
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CERTIFICATE OF SERVICE
I hereby certify that on September 21, 2016, copies of the foregoing First Production
Request of The Amalgamated Sugar Company LLC were delivered via U.S. Mail postage
prepaid and electronically as indicated, to:
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
555 S. Cole Road
PO Box 7608
Boise, ID 83 707
[e-mail]
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1 136
[e-mail]
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83 702
[e-mail]
Ronald L. Williams
Attorney for Intermountain Gas Company
1015 West Hays Street
Boise, Idaho 83 702
[e-mail]
Michael C. Creamer
Givens Pursley, LLP
601 West Bannock Street
Boise, Idaho 83702
mcc@gi venspursley. com
Brad M. Purdy
2019 N. 17th Street
Boise, Idaho 83 702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h Ave.
Helena, MT 59601
[e-mail]
First Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page 3
Edward Finklea
Northwest Industrial Gas Users
545 Grandview Drive
Ashland, OR 97520
[e-mail]
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Kandi Walters, Administrative Assistant
Richardson Adams, PLLC
First Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page 4