20161103INT to NWIGU 41-43.pdf

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
RE CE IVED
l.-,.·:·; 1U8LIC ,-<' ·· ~; CO\·i.\1 1SSION
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 SECOND
PRODUCTION REQUEST OF
NORTHWEST INDUSTRIAL GAS
USERS
COMES NOW, Intermountain Gas Company, and in response to the Second
Production Request of Northwest Industrial Gas Users dated October 20, 2016, herewith
submits the following information:
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?
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF NWIGU Page 1
RESPONSE TO NWIGU REQUEST NO 41 TO COMPANY:
Intermountain notified its industrial customers on Wednesday, October 261h, that
it is conducting an "Open Season " to facilitate a re-negotiation of the customer's
MDFQ. Attached hereto is a copy of that notification letter.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
David Swenson, 208-377-6000
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:
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.
RESPONSE TO NWIGU REQUEST NO 42 TO COMPANY:
a. If, under the Company's proposal, the net outcome of any +/-changes to
MDFQ 's result in no change to the overall total MDFQ 's, then the revenue
requirement collected through the proposed Demand Charge would be identical
to what's included in the Company's Application. Under that scenario, therefore,
changes to either the Demand Charge, the volumetric charge, or both would not
be necessary.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF NWIGU Page2
b. Under the Company 's proposal, customers who elect an MDFQ higher than their
actual needs would either experience an increase to their overall bill or "less of a
decrease " to their overall bill. With the Company 's proposal there is an inherent
linkage between the customers load factor (a measurement of the efficiency in
which they use the Company 's distributionfacilities) and their annual bill. The
higher the MDFQ becomes in relation to the customers true needs, the poorer the
load factor becomes resulting in a greater increase to the customer 's bill.
c. Customers who elect an MDFQ lower than their needs would more than likely
receive an overall cost decrease but these customers would put themselves at risk
that their peak day delivery would be held to their, now lower, MDFQ.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
David Swenson, 208-377-6000
NWIGU REQUEST NO 43 TO COMPANY: IfTF-4 customers are allowed to
reset their MDFQs, would this impact any other rate schedule?
RESPONSE TO NWIGU REQUEST NO 43 TO COMPANY:
No. Customer class allocations were not based on MDFQs.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
David Swenson, 208-377-6000
Dated this 3rd day of November, 2016.
Respectfully submitted,~
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF NWIGU Page 3
~
A INTERMOUNTAIN"' f' GAS COMPANY A~ofAIOUllntiLmlll~lnC.
In the Community to Setw"
October 21 , 2016
To All lntermountain Gas Company Large Volume Customers
Dear Customer,
As you have already been notified, lntermountain Gas Company filed its first General Rate Case in over
thirty (30) years requesting a rate reduction for lntermountain's firm large volume customers. You also
have been made aware of the Company's proposal to implement a Demand Charge whereby each
large volume customer receiving service through one of lntermountain's firm tariffs would be responsible
for paying a monthly Demand Charge based on the customer's contracted Maximum Daily Firm
Quantity, or MDFQ. Said another way, under this proposed billing mechanism, there will now be both
operational and financial ramifications relative to your contracted MDFQ.
lntermountain Gas Company has now initiated an "Open Season" whereby, irrespective of your current
contract term, you will now be given the opportunity to change your MDFQ election. Under the
Company's proposed rate design, aligning your MDFQ with your actual peak-day needs should, in most
cases, bring additional energy savings to your company while at the same time providing the peak day
gas delivery security you require.
I have attached some information that may help you determine whether any modifications to your
existing MDFQ are warranted. Over the next several weeks I, or other members of lntermountain's
team, will be communicating with you to answer questions you might have about our General Rate
Case or the attachment and assist you in making the best decision relative to the Open Season. Please
let me know if you would prefer a personal visit or if communications via phone or email work best for
you. I will also update your marketer with the same information.
This Open Season will end on Monday November 28th, 2016 and therefore your written response must
be received by the Company on or before Monday, November 281h. You can send your response to me
via US mail or email.
I look forward to visiting with you .
Respectfully,
David Swenson
Manager, Industrial Services
lntermountain Gas Company
555 S. Cole Road
Boise, Idaho 83709
Direct [phone]
Mobile [phone]
[e-mail]
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 3rd day of November, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to Second Production Request
of Northwest Industrial Gas Users upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 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 83 707
E-Mail: [e-mail]
Brad M. Purdy
2019 N . 17th Street
Boise, ID 83 702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP AI)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th 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
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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. 27th Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
Company LLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
2
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Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny.zieman. l @us.af.mil
N [e-mail]
Thomas.jemigan.3 @us.af.mil
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
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Ronald L. Williams