20161012INT to SUGAR 1-3.pdf

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WILLIAMS · BRADBURY
October 12, 2016
Jean D. Jewell
Commission Secretary
ATT OR NEYS AT LAW
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Response to Amalgamated First Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
f~ CE IVED
20 ! 6 OCT I 2 PM 12: I 0
.. ~ 'J8! IC
1·. ;-. :; -:Ci'.~ ,1JSSION
Enclosed for filing with the Commission are one original and two conformed copies of
Intermountain Gas Company's Response to Amalgamated Sugar Company's First Request for
Production.
By separate confidential CD, please find the responses to Amalgamated Sugar Company's
request No. 2.
Please direct any questions related to the transmittal of this filing to Mike McGrath at
208-377-6168.
Sincerely,
Ronald L. Williams
Attorney at Law
RLW
1015 W. H ays Street -Boise, ID 83702
Phone: [phone] -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
or..:cEIVED I'\. L..
2016 OCT I 2 PM 12= I 0
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
_________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO FIRST
PRODUCTION REQUEST OF THE
AMALGAMATED SUGAR
COMPANYLLC
COMES NOW, Intermountain Gas Company, and in response to the First Production
Request of the Amalgamated Sugar Company LLC dated September 22, 2016, herewith submits
the following information:
REQUEST NO. 1: Please provide all discovery responses along with the work papers
and attachments provided to all other parties.
RESPONSE TO REQUEST NO. 1:
lntermountain believes it has provided copies of all prior discovery responses to all
Jntervenors in this case. If any Intervenor believes otherwise, please contact counsel for the
lntermountain to confirm or discuss.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-600
RESPONSE OF JGC TO FIRST PRODUCTION REQUEST OF THE AMALGAMATED SUGAR COMPANY,
Page I
REQUEST 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.
RESPONSE TO REQUEST NO. 2:
Please see file labeled Amal Resp. #2. Responses to this request involve confidential and
proprietary information of Intermountain and are contained on a CD identified as such, and are
only being provided to Intervenor 's that have previously executed and agreed to be bound by
Protective Agreements.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Mike McGrath, 208-377-6000
REQUEST 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 all copies of the referenced "computer disk[s]" with all
formulae intact.
RESPONSE TO REQUEST NO. 3:
Responses to this request involve highly sensitive and confidential and proprietary information
and computer modeling. Intermountain interprets !PUC Rulef 21.02 as only requiring that it
provide actual computer models, with formulae intact, to Commission Staff, but must provide
documentation of computer models to all other lntervenors. However, Intermountain is willing to
exceed the requirements of this rule and also provide the two models requested to any Intervenor
that has executed and agreed to be bound by a Protective Agreement and confirms to counsel for
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE AMALGAMATED SUGAR COMPANY,
Page 2
lntermountain that it desires to receive the CD containing the revenue requirement model and
the revenue allocation model, withformulae intact.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
DATED at Boise, Idaho, this / J__ day of October, 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE AMALGAMATED SUGAR COMP ANY,
Page 3
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 12th day of October, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to First Production Request of
the Amalgamated Sugar Company upon the following individuals in the manner indicated below:
Hand Delivery: (original and 2 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 1 ?1h Street
Boise, ID 83702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP AI)
Benjamin J. Otto
Idaho Conservation League
710 N . 61h Street
Boise, ID 83702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h Avenue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: [e-mail]
[e-mail]
Attorneys for NWIGU
Electronic service only:
Michael C. Creamer
Givens Pursley LLP
E-Mail: [e-mail]
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 702
E-Mail: [e-mail]
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 2ih Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
CompanyLLC
Ken Miller
Snake River Alliance
223 N. 61h St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Ronald L. Williams