20161109INT to NWIGU 36.pdf

WILLIAMS BRADBURY
November 9, 2016
Jean D. Jewell
Commission Secretary
A TTOR NE Y S A T LAW
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
REC.E IVED
20loitl0. -9 PH != 22
, L :,J2 ,·:c &~IS ION
RE: IGC Supplemental Response to First Request ofNWIGU -Case No. INT-G-16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Supplemental Response to Northwest Industrial Gas Users'
First Request for Production No. 36, and one CD-ROM that contains the answers and
attachments.
Please direct any questions related to the transmittal of this filing to Mike McGrath at
208-377-6168.
Sincerely, .
l~V~
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [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
(
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201& m -9 P· 1: 22
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
Case No. INT-G-16-02
SUPPLEMENTAL RESPONSE OF
INTERMOUNTAIN GAS
COMPANY TO FIRST
PRODUCTION REQUEST OF
NORTHWEST INDUSTRIAL GAS
USERS NO. 36
)
)
)
)
COMES NOW, Intermountain Gas Company, and in response to the extension granted for
First Production Request of Northwest Industrial Gas Users No. 36, herewith submits the
following information:
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.
IGC SUPPLEMENTAL RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page I
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.
RESPONSE TO REQUEST NO. 36:
a) Montana Dakota/Great Plains, Cascade Natural Gas, and lntermountain Gas Co.
bill each utility for services rendered.
b) Please see CD file labeled "NWIGU #36 MDU and JGC x charges" and
"NWJGU #36 CNG X-charges. "Due to a major computer system conversion in
mid-2010, the information requested/or 2010 is incomplete and not readily
assessable electronically, and therefore cannot reasonably be provided. In
addition, due to system limitations and the volume of data requested, the
information for cross charge data from Cascade Natural Gas to lntermountain
Gas is provided for the months of June and December, for the calendar years
2011 -2015. Monthly cross charge data for January -June 2016 is also provided
on the attached CD.
c) Please see Exhibit # 10 of lntermountain 's Cost Allocation Manual, and the
Company 's reply to !PUC Staff's First Production Request.
d) Montana Dakota/Great Plains, Cascade Natural Gas and lntermountain have not
studied, or commissioned any studies, regarding whether costs charged to each
operating company are at or below costs that would have been charged by
independent third parties. In addition, the Company is of the opinion that a
JGC SUPPLEMENT AL RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 2
number of costs charged -such as costs for executive team leadership, experience
and expertise -are not services that can, or should be, acquired from
independent third-party providers.
e) Please see CD file labeled "NWIGU #36 MDU and JGC x charges" and
"NWJGU #36 CNG X-charges. "
j) lntermountain Gas Company is not required, and therefore has not, filed a FERC
Form 60.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
Dated this 9th day of November, 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
JGC SUPPLEMENT AL RESPONSE TO NWIGU FIRST REQUEST FOR PRODUCTION Page 3
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 9th day of November, 2016, I caused to be served a true
and correct copy of the Supplemental Response oflntermountain Gas Company to First Production
Request of Northwest Industrial Gas Users No. 36 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 83 702
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
D Federal Express IZI Electronic Transmission
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZI Electronic Transmission
D Hand Delivery
IZ! US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
IZ! Electronic Transmission
D Hand Delivery
IZI US Mail (postage prepaid) D Facsimile Transmission D Federal Express
IZ! Electronic Transmission
D Hand Delivery
IZI US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
IZ! 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 83702
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
CompanyLLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
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D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery
~ 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
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
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]
[e-mail]
Ebony. payton. [e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
D Hand Delivery
[8J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[8J Electronic Transmission
Ronald L. Williams