20161017NWIGU 1-40 to INT.pdf

CABLE HUSTON ur
CHAD M . STOKES
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 93 702
October 13, 2016
RECEI VED
ZOIG OCT 17 PH 2: 59
-·· · :: ) 1 -.JU.IC 1 , ·: -~ r i ' ' ~ 11 In cstokes@cablefrns O .c'6
Re: Northwest Industrial Gas Users' First Request for Production of Documents to
Intermountain Gas Company
Case No. INT-G-16-02
Dear Ms. Jewell,
Enclosed for filing with the Commission are an original and two copies of Northwest
Industrial Gas Users' First Request for Production of Documents to lntermountain Gas
Company.
Please let me know if you have any questions. Thank you.
~ Chad M"'Stokes
CMS/sk
Enclosure
26678.885\4844-0750-7770. v I
Suite 2000, 1001 SW Fifth Avenue, Portland, Oregon 97204-1136 • Phone: [phone] • Fax: [phone] • www.cablehuston.com
..
Chad M. Stokes (OSB No. 004007)
Tommy A. Brooks (OSB No. 076071)
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
RECEIVED
201 & OCT 17 PM 2: 59
Michael C. Creamer (ISB No. 4030)(Local Counsel)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: (208) -388-1300
[e-mail]
Attorneys for Northwest Industrial Gas Users
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOUNTAIN GAS COMPANY
FOR THE AUTHORITY TO
CHANGE ITS RATES AND
CHARGES FOR NATURAL GAS
SERVICE TO NATURAL GAS
CUSTOMERS IN THE STATE OF
IDAHO
CASE NO. INT-G-16-02
FIRST PRODUCTION REQUEST OF
NORTHWEST INDUSTRIAL GAS
USERS TO INTERMOUNTAIN GAS
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"), Northwest Industrial Gas Users ("NWIGU") by and
through its attorney of record, Chad Stokes, granted limited admission by the
Commission in Order 33610, hereby requests that the Intermountain Gas Company
("Company") provide the following documents:
Page 1 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
DEFINITIONS
1. "Company" refers to the Intermountain Gas Company, any affiliated company, or
any officer, director or employee of Intermountain Gas Company, or any
affiliated company.
2. "Documents" refers to all writings and records of every type in your possession,
control, or custody, whether or not claimed to be privileged or otherwise
excludable from discovery, including but not limited to: testimony and exhibits,
memoranda, papers, correspondence, letters, reports (including drafts,
preliminary, intermediate, and final reports), surveys, analyses, studies (including
economic and market studies), summaries, comparisons, tabulations, bills,
invoices, statements of services rendered, charts, books, pamphlets, photographs,
maps, bulletins, corporate or other minutes, notes, diaries, log sheets, ledgers,
transcripts, microfilm, microfiche, computer data (including E-mail), computer
files, computer tapes, computer inputs, computer outputs and printouts, vouchers,
accounting statements, budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and
telegraphic communications, speeches, and all other records, written, electrical,
mechanical, or otherwise, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or
other notations or which otherwise does not duplicate the original or any other
copy.
"Documents" also includes any attachments or appendices to any document.
3. "Identification" and "identify" mean :
When used with respect to a document, stating the nature of the document (~,
letter, memorandum, corporate minutes); the date, if any, appearing thereon; the
date, if known, on which the document was prepared; the title of the document;
the general subject matter of the document; the number of pages comprising the
document; the identity of each person who wrote, dictated, or otherwise
participated in the preparation of the document; the identity of each person who
signed or initiated the document; the identity of each person to whom the
document was addressed; the identity of each person who received the document
or reviewed it; the location of the document; and the identity of each person
having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most
recently known home and business addresses and telephone numbers; his or her
Page 2 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
present title and position; and his or her present and prior connections or
associations with any participant or party to this proceeding.
4. "Person" refers to, without limiting the generality of its meaning, every natural
person, corporation, partnership, association (whether formally organized or ad
hoc),joint venture, unit operation, cooperative, municipality, commission,
governmental body or agency, or any other group or organization.
5. "Studies" or "study" includes, without limitation, reports, reviews, analyses and
audits.
6. The terms "and" and "or" shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any
information or documents which might otherwise be considered to be beyond
their scope.
7. The singular form of a word shall be interpreted as plural, and the plural form of a
word shall be interpreted as singular, whenever appropriate in order to bring
within the scope of this discovery request any information or documents which
might otherwise be considered to be beyond their scope.
INSTRUCTIONS
1. These requests call for all information, including information contained in
documents, which relate to the subject matter of the Production Request and
which is known or available to Company.
2. Where a Production Request has a number of separate subdivisions or related
parts or portions, a complete response is required to each such subdivision, part or
portion. Any objection to a Production Request should clearly indicate the
subdivision, part, or portion of the Production Request to which it is directed.
3. The time period encompassed by these Production Requests is from 2010 to the
present unless otherwise specified.
4. Each response should be furnished on a separate page. In addition to hard copy,
electronic versions of the document, including studies and analyses, must also be
furnished if available.
5. If Company cannot answer a Production Request in full, after exercising due
diligence to secure the information necessary to do so, state the answer to the
extent possible, state why Company cannot answer the Production Request in full,
and state what information or knowledge Company has concerning the
unanswered portions.
6. If Company refuses to respond to any Production Request by reason of a claim of
Page 3 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNT AIN GAS COMPANY
privilege, confidentiality, or for any other reason, state in writing the type of
privilege claimed and the facts and circumstances Company relies upon to support
the claim of privilege or the reason for refusing to respond. With respect to
requests for documents to which Company refuses to respond, identify each such
document, and specify the number of pages it contains. Provide: (a) a brief
description of the document; (b) date of document; ( c) name of each author or
preparer; (d) name of each person who received the document; and (e) the reason
for withholding it and a statement of facts constituting the justification and basis
for withholding it.
7. Identify the person from whom the information and documents supplied in
response to each Production Request were obtained, the person who prepared
each response, the person who reviewed each response, and the person who will
bear ultimate responsibility for the truth of each response.
8. These requests for documents and responses are continuing in character so as to
require Company to file supplemental answers as soon as possible if Company
obtains further or different information. Any supplemental answer should refer to
the date and use the number of the original request or subpart thereof.
9. Whenever these Production Requests specifically request an answer rather than
the identification of documents, the answer is required and the production of
documents in lieu thereof will not substitute for an answer.
I II II
I II II
II II I
II II I
II II I
I II II
II II I
I II I I
I II I I
I II II
II I II
Page 4 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
PRODUCTION REQUESTS
NWIGU REQUEST NO 1 TO COMPANY:
Please provide copies of all publications and credit reports referenced in the direct
testimony of Dr. Gaske and Mr. Chiles.
NWIGU REQUEST NO 2 TO COMPANY:
Please provide all of Dr. Gaske's exhibits and workpapers in electronic format with all
formulas intact.
NWIGU REQUEST NO 3 TO COMPANY:
Please provide Intermountain Gas Company's ("IGC") capital structure, requested capital
cost rates, and revenue conversion, or tax gross up, factor in electronic format with all
formulas intact.
NWIGU REQUEST NO 4 TO COMPANY:
Please provide copies of all credit reports published by Standard & Poor's ("S&P"),
Moody's and Fitch Ratings for IGC, all of its affiliates issued and parent Company issues
over the last two years.
NWIGU REQUEST NO 5 TO COMPANY:
Please provide complete copies of all recent credit reports issued by Standard & Poor's,
Moody's and Fitch Ratings that discuss the natural gas utility industry.
NWIGU REQUEST NO 6 TO COMPANY:
Please provide the most recent senior secured, unsecured and corporate credit rating of
IGC assigned by S&P, Moody's and Fitch. Also, please provide IGC's S&P business
and financial risk profiles.
NWIGU REQUEST NO 7 TO COMPANY:
Please provide copies of all correspondence, presentations and all other materials that
IGC and its parent provided to credit and equity analysts over the last two years.
NWIGU REQUEST NO 8 TO COMPANY:
On an electronic spreadsheet with all formulas intact, please provide the monthly average
balances for construction work in progress and short-term debt for the most recent 13-
month period.
Page 5 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNT AIN GAS COMPANY
NWIGU REQUEST NO 9 TO COMPANY:
Please provide the amount of capitalized interest paid during the test year related to
construction projects.
NWIGU REQUEST NO 10 TO COMPANY:
Please state whether IGC has any off-balance sheet debt such as purchased power
agreements and operating leases. If in the affirmative, provide the amount of each off­
balance sheet debt item and estimate the related imputed interest and amortization
expense associated with these off-balance sheet debt equivalents.
NWIGU REQUEST NO 11 TO COMPANY:
On an electronic spreadsheet with all formulas intact, please provide the five-year
projected and five-year historical capital structure, capital expenditures and capital
funding.
NWIGU REQUEST NO 12 TO COMPANY:
Please provide a detailed explanation ofIGC's dividend payment and debt financing
plans through the test period.
NWIGU REQUEST NO 13 TO COMPANY:
Do any ofIGC's outstanding long-term debt issues have call provisions? If the answer is
"yes," please provide a list of the callable issues with the following: a) outstanding
balance, b) issuance date, c) maturity date, d) coupon payment percent, e) annual interest
expense, and f) call price (as a percent of par).
NWIGU REQUEST NO 14 TO COMPANY:
Has IGC performed any debt refinancing feasibility studies on its outstanding debt
issues? If the answer is "yes," please provide the following:
a. A detailed description of the results from the study.
b. A detailed description of the conclusion(s) made by IGC based on the
results of the study.
c. All debt refinancing feasibility studies in an electronic spreadsheet with
all formulas intact.
NWIGU REQUEST NO 15 TO COMPANY:
Please provide all workpapers in native electronic format with all formulas intact that
support the direct testimony of Mr. David Swenson.
Page 6 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
NWIGU REQUEST NO 16 TO COMPANY:
Please provide all workpapers in native electronic format with all formulas intact that
support the direct testimony of Mr. Branko Terzic.
NWIGU REQUEST NO 17 TO COMPANY:
Please provide all workpapers in native electronic format with all formulas intact that
support the direct testimony of Ms. Lori A Blattner.
NWIGU REQUEST NO 18 TO COMPANY:
With respect to the direct testimony of Ms. Lori A. Blattner, to the extent not already
provided, please provide the following information with respect to class cost of service
and rate design:
a. Exhibit 19 in native electronic format with all formulas intact.
b. Exhibit 20 in native electronic format with all formulas intact.
c. Exhibit 21 in native electronic format with all formulas intact.
d. Exhibit 22 in native electronic format with all formulas intact.
e. Exhibit 23 in native electronic format with all formulas intact.
f. Exhibit 24 in native electronic format with all formulas intact.
NWIGU REQUEST NO 19 TO COMPANY:
Please provide a complete copy oflGC's most recent management approved integrated
resource plan.
NWIGU REQUEST NO 20 TO COMPANY:
Concerning IGC's distribution main planning process, please answer the following:
a. How were main sizes determined based on customers' load on the
system, and the length of mains needed to connect customers the
distribution system.
b. How does the length of distribution main impact distribution related
equipment such as compression, pressure regulation, safety equipment,
etc. needed to reliably and safely provide gas delivery service. Please
explain answer.
Page 7 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
c. Please provide a copy of any distribution main system modernization
plan currently being considered or approved by IGC's management.
d. Please provide a complete copy oflGC's main extension rules.
NWIGU REQUEST NO 21 TO COMPANY:
Please provide all workpapers, schedules and exhibits discussed in witness testimony in
working Excel electronic format with all formulas intact.
NWIGU REQUEST NO 22 TO COMPANY:
Please provide all schedules and exhibits supporting the Company's filing in working
Excel electronic format with all formulas intact.
NWIGU REQUEST NO 23 TO COMPANY:
Please provide all workpapers and spread sheets supporting the Company's filing in
working Excel electronic format with all formulas intact.
NWIGU REQUEST NO 24 TO COMPANY:
Please provide the O&M expenses by FERC account, annually beginning in 2007
through 2015 in working Excel electronic format with all formulas intact.
NWIGU REQUEST NO 25 TO COMPANY:
Please provide the O&M expenses by FERC account, monthly, beginning in 2011
through 2015 in working Excel electronic format with all formulas intact.
NWIGU REQUEST NO 26 TO COMPANY:
Please provide the actual O&M expenses by FERC account, monthly for 2016, as the
data becomes available, in working Excel electronic format with all formulas intact.
NWIGU REQUEST NO 27 TO COMPANY:
In working Excel electronic format with all formulas intact, please provide a calculation
showing the determination of the revenue requirement increase requested in the current
case.
The following questions are related to the Direct Testimony of Hart Gilchrist
NWIGU REQUEST NO 28 TO COMPANY:
Please provide the following regarding pipe replacement.
a. The dollar amount and miles of pipe that have been identified annually
in each of the last five years as being in need of replacement.
Page 8 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
b. The dollar amount and miles of pipe that were replaced annually in each
of the last five years as a result of being identified as being in need of
replacement?
c. As specifically as possible, identify the annual sources of funding used
for the pipe replacements identified in subpart b.
The following questions are related to the Direct Testimony of Ted Dedden
NWIGU REQUEST NO 29 TO COMPANY:
Please provide the following regarding Customer Deposits.
a. Does the Company collect Customer Deposits?
b. If the response to subpart a. is "no," explain why.
c. If yes to subpart a., explain in detail how these funds are accounted for
in the Company's books and records?
d. The monthly dollar amount balances for Customer Deposits for the
period December 31 , 2010 through December 31 , 2016 as the data
becomes available, in working Excel electronic format with all formulas
intact.
e. Explain in detail the cause of any month to month deviations, of+ or -
10% or more, in the amounts provided in response to subpart d.
f. The rate of interest paid on customer deposits.
g. Explain in detail why Customer Deposits are not included m the
Company's rate base, including cites to Commission orders and/or
policies.
NWIGU REQUEST NO 30 TO COMPANY:
Please provide the following regarding Customer Advances.
a. The monthly balances of the dollar amount of Customer advances for
the period December 31 , 2010 through December 31, 2016 as the data
becomes available, in working Excel electronic format with all formulas
intact.
b. Explain in detail the cause of any month to month deviations, of+ or -
10% or more, in the amounts provided in response to subpart a.
Page 9 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
NWIGU REQUEST NO 31 TO COMPANY:
Please provide following regarding other revenues.
a. The annual amount of other revenues for the 2011 through 2015, and
monthly for 2016 as actual data becomes available, consistent with the
income statement values used in the Company's case filing (Dedden
Exhibit 09), in working Excel electronic format with all formulas intact.
b. A detailed explanation for year to year variances of+ or -10% or more,
by revenue item.
NWIGU REQUEST NO 32 TO COMPANY:
Please provide the actual July through December 2016 balances as they become available
for plant, depreciation and amortization reserves, materials and supplies, customer
advances, accumulated deferred income taxes and gas storage, consistent with the rate
base values used in the Company's case filing (Dedden Exhibit 07), in working Excel
electronic format with all formulas intact.
NWIGU REQUEST NO 33 TO COMPANY:
Please provide the following:
a. The Cross Charge Summary annually for 2011 through 2015 and
monthly for 2016 as actual data becomes available, consistent with the
line item values used in the Company's case filing (Dedden Exhibit 11).
b. Data for the 2015 summary.
c. Provide subparts a. and b. in working Excel electronic format with all
formulas intact.
NWIGU REQUEST NO 34 TO COMPANY:
Please provide the following regarding the deferred income tax reserves included in rate
base.
a. Supporting calculations demonstrating that the deferred income taxes
included in rate base reflect the timing difference associated with bonus
depreciation available on 2016 plant additions, in working Excel
electronic format with all formulas intact.
b. Supporting calculations demonstrating that the deferred income taxes
included in rate base reflect the timing difference associated with non­
bonus tax depreciation available on 2016 plant additions, in working
Excel electronic format with all formulas intact.
Page 10 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
c. Supporting calculations demonstrating that the deferred income taxes
included in rate base reflect the timing difference associated with tax
depreciation on pre-2016 plant additions, in working Excel electronic
format with all formulas intact.
d. Detailed explanations associated with subparts a. through c.
NWIGU REQUEST NO 35 TO COMPANY:
Please provide the following regarding costs charged by MDUR.
a. The amount, by function/category, annually for 2010 through 2016, as
the data becomes available, charged to the following entities:
1. Montana Dakota -Electric utility segment;
2. Montana Dakota/Great Plains -Gas utility segment;
3. Cascade Natural Gas ("CNG");
4. Intermountain Gas Company ("IGC");
5. WBI Energy Transmission;
6. WBI Midstream;
7. Knife River Construction ("KRC"); and
8. MDU Construction Services Group, Inc. ("CSG")
b. A description of the business performed by each entity in subpart a.
c. Describe in detail the basis of the cost charged by MDUR (actual, or
other) and how it is determined, including the rate of return and
depreciation rates used for recovery of assets.
d. Describe in detail the process used to determine that the costs charged
for services are necessary, reasonable and equal to or below the cost that
would be charged by an independent third-party.
e. Identify where these costs are charged in the books and records ofIGC
and the amount included in the cost of service in this case.
Page 11 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
NWIGU REQUEST NO 36 TO COMPANY:
Please provide the following regarding costs charged to each operating company by
Montana Dakota/Great Plains, Cascade Natural Gas and IGC.
a. Identify the operating companies receiving costs from each of the above
providers.
b. The amount, by function/category, annually for 2010 through 2016, as
the data becomes available, charged to the companies in subpart a.
c. For the period 2010 to 2016, describe in detail the services provided and
the cost charged by Montana Dakota/Great Plains (actual, or other) for
services provided and a description of how the cost is determined,
including the rate of return and depreciation rates used for recovery of
assets.
d. Describe in detail the process used to determine that the costs charged
for services are necessary, reasonable and equal to or below the cost that
would be charged by an independent third-party.
e. Identify where these costs are charged in the books and records of IGC
and the amount included in the cost of service in this case.
f. Provide complete copies of all regulated filings of the service Company
charges including FERC Form 60.
The following questions are related to the Direct Testimony of Jacob Darrington
NWIGU REQUEST NO 37 TO COMPANY:
Please provide the following regarding Incentive compensation cost included in the 2016
cost of service.
a. Identify the different incentive plans included in the cost of service.
b. Identify the amount of each plan in subpart a., and how it was
determined for each category (financial, safety, cost control, etc.).
c. Provide the plan documents for each incentive plan that fully describe
the terms of the plan, its intended purpose, the employees covered, how
payouts are determined by category, what adjustments can be made in
the determination of payouts and the level of control management has
over the administration of the plan.
d. The five most recent annual amounts of payout for each plan, by
category, in working Excel electronic format with all formulas intact.
Page 12 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
e. Calculations, in working Excel electronic format with all formulas
intact, and other documentation supporting the amounts in subpart b.
and d., including weightings, scorecards, comparisons to benchmarks,
etc.
f. Describe how the Idaho Public Utilities Commission has ruled with
regard to the recovery of incentive compensation, including cites to past
orders.
NWIGU REQUEST NO 38 TO COMPANY:
Please provide the following regarding the adjustments to the deferred income tax reserve
shown on Exhibit 12, page 2.
a. All calculations supporting the amount of each adjustments, in working
Excel electronic format with all formulas intact.
b. Supporting calculations for the determination of the FAS l 09 and APB
11 amounts and detailed explanations of how these amounts were used
in the calculations in subpart a., in working Excel electronic format with
all formulas intact.
c. References to the specific IRS code sections that require the proposed
adjustments.
d. Excerpts from prior Commission orders that support the adjustments
and the method of calculation.
NWIGU REQUEST NO 39 TO COMPANY:
Provide the following regarding the adjustments associated with non-utility LNG
adjustments .
a. Rationale for characterizing these transactions as non-utility.
b. Explain whether utility assets and personnel were used to facilitate these
transactions.
c. A detailed explanation of the circumstances that gave rise to these
transactions.
d. Excerpts from Commission orders that support the Company's proposed
treatment of these transactions.
Page 13 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
e. A calculation showing the total cost associated with these transactions,
including storage cost, in working Excel electronic format with all
formulas intact.
NWIGU REQUEST NO 40 TO COMPANY:
In working Excel electronic format with all formulas intact, please provide the actual
number of customers by rate class, by month, for the period January 1, 2011 through
December 31 , 2016, as the data becomes available
Dated this 13th day of October 2016.
Respectfully submitted,
~
Chad M. Stokes, OSB No. 004007
Tommy A. Brooks, OSB No. 076071
Cable Huston, LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
Of Attorneys for
Northwest Industrial Gas Users
Page 14 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
CERTIFICATE OF SERVICE
I CERTIFY that I have on this day served the foregoing document upon all parties
of record in this proceeding via electronic mail and/or by mailing a copy properly
addressed and first class postage prepaid.
Peter J. Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N 27th Street
Boise, ID 83 702
[e-mail]
[e-mail]
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays Street
Boise, ID 83702
[e-mail]
Benjamin Otto
Idaho Conservation League
710 N 6th Street
Boise, ID 83 702
[e-mail]
Brad M. Purdy
2019 N 17th Street
Boise, ID 93 702
[e-mail]
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
PO Box 7608
Boise, ID 83707
[e-mail]
Scott Dale Blickenstaff
Amalgamated Sugar Co LLC
1951 S Saturn Way Ste 100
Boise, ID 83702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h Avenue
Helena, MT 59601
[e-mail]
Dated in Portland, Oregon, this 13th day of
Page 1 -CERTIFICATE OF SERVICE
Chad M. Stokes, OSB No. 004007
Tommy A. Brooks, OSB No. 076071
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
Of Attorneys for the
Northwest Industrial Gas Users