20161024NWIGU 41-43 to INT.pdf

CABLE HUSTONLLP
CHAD M . STOKES
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 93702
October 20, 2016
RECE IVED
2016 OCi 24 PM 3: 59
• • '. 1 :1J3LIC 1-,..: -1'":DM~l/SS /O
[e-mail]
Re: Northwest Industrial Gas Users' Second 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 three copies of Northwest
Industrial Gas Users' Second Request for Production of Documents to Intermountain Gas
Company.
Please let me know if you have any questions. Thank you.
CMS/sk
Enclosure
26678.885\4829-7524-9723.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]
RECEIVE D
20/o CT 24 PH 3: 59
i-,., .' J /:-·UBLIC ' ;~ ""9. '/ (' 1 ' • --.,,:: ~, 0S/ON
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
SECOND PRODUCTION REQUEST
OF NORTHWEST INDUSTRIAL
GAS USERS TO INTERMOUNT AIN
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 SECOND 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 SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNT AIN 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
informatio·n 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 SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN 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.
II II I
II I II
II I II
I II I I
II II I
I II II
II I II
I I II I
I II I I
I II II
II II I
Page 4 NWIGU'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNTAIN GAS COMPANY
PRODUCTION REQUESTS
NWIGU REQUEST NO 41 TO COMPANY:
As explained in the Direct Testimony of David Swenson, Intermountain has proposed to
implement a demand charge on the redesigned rate schedule TF-4. The demand charge,
if approved, would be the product of the demand rate times the effective Maximum Daily
Firm Quantity (MDFQ) contained in a written service contract between the customer and
Intermountain. Because a demand charge has never been used on TF-4 customers, is
Intermountain willing to conduct an open season to allow TF-4 customers, and all other
industrial customers who contract with the Company for an MDFQ, the ability to reset
their MDFQs in the event the rate redesign ofrate schedule TF-4 is approved?
NWIGU REQUEST NO 42 TO COMPANY:
Assuming Intermountain's proposed rate redesign for rate schedule TF-4 is approved, and
customers are allowed to reset their MDFQs, please explain how the rates for TF-4
customers will be impacted in the following scenarios:
I II
II I
II I
II I
II I
I II
I II
II I
a. Some customers elect MDFQs that are higher than needed based on current
gas consumption, and some customers elect MDFQs that are lower than
needed based on current gas consumption;
b. All customers elect MDFQs that are higher than needed based on current gas
consumption;
c. All customers elect MDFQs than are lower than needed based on current gas
consumption.
Page 5 NWIGU'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS TO
INTERMOUNT AIN GAS COMPANY
NWIGU REQUEST NO 43 TO COMPANY:
If TF-4 customers are allowed to reset their MDFQs, would this impact any other rate
schedule?
Dated this 201h 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 6 NWIGU'S SECOND 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]
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
[e-mail]
Page 1 -CERTIFICATE OF SERVICE
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 83 702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8111 Avenue
Helena, MT 59601
[e-mail]
Karl Klein
Sean Costello
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]
26678.885\4844-63 50-674 7. v I
Brad M. Purdy
2019 N 17th Street
Boise, ID 93 702
[e-mail]
Michael C. Creamer
Givens Pursley
[e-mail]
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. J emigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall, AFB FL 32403
Andrew. [e-mail]
Lanny.zieman. [e-mail]
[e-mail]
Thomas. j ernigan. [e-mail]
[e-mail]
Dated in Portland, Oregon, this 20th d~-ay~o--ct_o_b-er_2_0_1_6_. --------­
Chad M. Stokes, OSB No. 004007
Page 2 -CERTIFICATE OF SERVICE
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
26678.885\4844-6350-674 7. v I