20161121Sugar 4-8 to INT.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar Company LLC
RECEIVED
2016140V 21 PM 3: 56
! ,.: ·) ul1LIC
,. It ·.-: 'L ·, MISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. INT-G-16-02
APPLICATION OF INTERMOUNTAIN ) SECOND PRODUCTION REQUEST
GAS COMP ANY FOR THE AUTHORITY ) OF THE AMALGAMATED SUGAR
TOCHANGEITSRATESAND ) COMPANYLLC
CHARGES FOR NATURAL GAS )
_S_E_R_V_IC_E_IN_T_HE_S_T_A_T_E_O_F_ID_AH_O __ )
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Amalgamated Sugar Company LLC (Amalgamated Sugar) by and
through their attorney of record, Peter J. Richardson, hereby requests that the Intermountain Gas
Company ("Company") provide the following documents.
This production request is to be considered as 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 one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above and to Scott Blickenstaff, The Amalgamated Sugar
Company LLC, 1951 S. Saturn Way, Ste. 100 Boise, Idaho 83702,
[e-mail] [phone] and one electronic copy to Dr. Don Reading at
[e-mail] [phone]. For each item, please indicate the name of the
person(s) preparing the answers, along with the job title of such person(s) and the witness at
hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO. 4
Please provide a bill comparison for the last twelve months, pursuant to the
confidentiality agreement, for Amalgamated Sugar between currently in effect rates and the
Company's proposed rates for the Nampa, Twin Falls and Paul factories.
REQUEST FOR PRODUCTION NO. 5
Please provide copies of all Facilities Agreements between the Company and all of its T-4
and T-5 customers.
REQUEST FOR PRODUCTION NO. 6
(A) Please provide copies of all filings or correspondence with the IPUC for approval,
acknowledgement or other review by the IPUC of the Company's Facilities Agreements identified
in response to Request for Production No. 5. (B) Is it the Company's position that Facilities
Agreements are subject to review or change by the IPUC? (C) Please explain and provide all
documentation supporting your response.
REQUEST FOR PRODUCTION NO. 7
Pease provide a copy of the Company's line extension policy for Transportation
customers. Please include workpapers and supporting documents used to develop the
Company's line extension policy.
REQUEST FOR PRODUCTION 8
Please provide copies of all of the Company's currently effective line extension
agreements with its T-4 and T-5 customers.
Second Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page2
DATED this 21st day of November, 2016
Richardson Adams, PLLC
By£.~~~, ----#
Peter J. Richardson
RICHARDSON ADAMS, PLLC, attorneys for
The Amalgamated Sugar Company LLC
CERTIFICATE OF SERVICE
I hereby certify that on November 21, 2016, copies of the foregoing Second Production
Request of The Amalgamated Sugar Company LLC were delivered via U.S. Mail postage
prepaid and electronically only as noted in the Second Amended Notice of Parties, to:
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
555 S. Cole Road
PO Box 7608
Boise, ID 83 707
[e-mail]
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1 136
[e-mail]
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]
Ronald L. Williams
Attorney for Intermountain Gas Company
1015 West Hays Street
Boise, Idaho 83 702
[e-mail]
Michael C. Creamer
Givens Pursley, LLP
601 West Bannock Street
Boise, Idaho 83 702
[e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, Idaho 83702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
[e-mail]
Second Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page 3
Edward Finklea
Northwest Industrial Gas Users
545 Grandview Drive
Ashland, OR 97520
[e-mail]
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Dr., Ste. 1
Tyndall AFB, FL 32403
[e-mail]
Lanny.zieman. [e-mail]
N [e-mail] mil
[e-mail]
[e-mail]
By: ~J{)f
Peter Richardson
Richardson Adams, PLLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
PO Box 1731
Boise, Idaho 83701
[e-mail]
Second Production Request of The Amalgamated Sugar Company
INT-G-16-02
Page4