20161116Staff 226-230 to INT.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
RECEIVED
2016 .~ J 16 P l:47
BEFORE THE IDAHO PUBLIC UTILITIES 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
TENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (Intermountain Gas; Company) provide the following documents and information as soon
as possible, and no later than WEDNESDAY, DECEMBER 7, 2016.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
TENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 1 NOVEMBER 16, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 226: In response to Staff Production Request No. 117, the Company states
that the IGC Therm Factors spreadsheet (provided in response to Staff Production Request No. 116)
is used to estimate residential gas usage for the purpose of main extensions. How were the "Old
Factors" in the IGC Therm Factors spreadsheet derived? How were the "New Factors" in the
spreadsheet derived? How do these factors correlate to the Company's tariff currently filed with the
Commission?
REQUEST NO. 227: Please provide copies of the "Service Line Matrix" and "Main
Extension Matrix" referenced in the Company's response to Staff Production Request No. 118.
REQUEST NO. 228: In Response to Staff Production Request No. 123, the Company
references IGC Procedure 9375 for Service Line Installations. Please provide copies of the
following documents and tables listed in IGC Procedure 9375:
EXAMPLE 1: Service Line Work Order, TABLES Added Residential Appliances & Space
Heating Factors, SCHEDULE A Allowable Footage -Residential, SCHEDULE B Allowable
Footage -Commercial;
EXAMPLE 2: Service Extension Contract;
EXAMPLE 3: Service Extension Contract (Non-permanent)
REQUEST NO. 229: It appears that Intermountain Gas Company has revised its Extension
of Mains and Extension of Service policies, but Staff is not aware of any filings made by the
Company to update its tariff, which was last modified on June 25, 1986. If those revisions were
considered and approved by the Commission, please provide the case number, tari~f advice number,
or order number associated with that approval.
REQUEST NO. 230: Following up on Staff Production Request No. 7, please provide a
schedule separately identifying the employees and salary amounts between union and non-union
employees.
TENTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 2 NOVEMBER 16, 2016
DATED at Boise, Idaho, this lt11, day of November 2016.
Technical Staff: Johnathan Farley/226-229
Joseph Terry/230
i:umisc:prodreq/intg I 6.2kkscjfjt prod req I 0
TENTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
Sean Costello
Deputy Attorney General
3 NOVEMBER 16, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF NOVEMBER 2016,
SERVED THE FOREGOING TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMP ANY, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR-REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83 707
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
tbrooks@cab 1 eh uston. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. l @us.af.mil
N [e-mail]
Thomas.jernigan.3 @us.af.mil
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE