20161207INT to Staff 226-230.pdf

WILLIAMS · BRADBURY
December 7, 2016
Jean D. Jewell
Commission Secretary
A TT O R NE Y S A T L A W
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Response to Staff's Tenth Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
R.::CE IVED
20 l&OEC -7 AHii : 13
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Response to Staffs Tenth Request for Production.
By separate confidential CD, please find the response to Staff s Request No. 230.
Please direct any questions related to the transmittal of this filing to Mike McGrath at
208-377-6168.
Sincerely,
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [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: ron@williarns brad bury. corn
Attorneys for Intermountain Gas Company
R'"=CEIVED
20 l & DEC --7 ·111: I 4
"" , 1 I ~· 1 (°' , . ,.'L·L . ..,
·. :c1.1r.,1SS I01
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
RESPONSE OF INTERMOUNTAIN
GAS COMP ANY TO TENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and in response to the Tenth Production
Request of the Commission Staff to Intermountain Gas Company dated November 16, 2016,
herewith submits the following information:
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?
RESPONSE TO REQUEST NO. 226:
The methodology and models.from which Main and Service Line Extensionfinancial
evaluations were based are outdated and in need of revision. Consequently, rather than expend
the significant time and effort to answer this question, and the following questions 227 through
RESPONSE OF IGC TO TENTH PRODUCTION REQUEST OF COMMISSION STAFF Page I
229, the Company discussed with Staff and proposes that, following this case (INT-G-16-02), it
work with Staff and prepare a compliance filing that updates lntermountain 's Main & Service
Extension provisions last approved by this Commission in June of 1986. The outcome of this
General Rate Case will establish the foundation for the parameters necessary for that exercise to
go forward. During the interim period between the outcome of this case and the preparation and
approval of the Company 's revised Main & Service Extension provisions, the Company will
record and keep all amounts received as Contributions in Aid of Construction ("CIAC ") and
thereafter provide customer adjustments as necessary.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6078
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6078
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.
RESPONSE TO REQUEST NO. 227:
Please see the answer to Request No. 226 above.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6078
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6078
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;
RESPONSE OF JGC TO TENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 2
EXAMPLE 2: Service Extension Contract;
EXAMPLE 3: Service Extension Contract (Non-permanent)
RESPONSE TO REQUEST NO. 228:
Please see the answer to Request No. 226 above.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6078
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6078
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, tariff advice
number, or order number associated with that approval.
RESPONSE TO REQUEST NO. 229:
Please see the answer to Request No. 226 above.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6078
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6078
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.
RESPONSE OF IGC TO TENTH PRODUCTION REQUEST OF COMMISSION STAFF Page 3
RESPONSE TO REQUEST NO. 230:
Please see Confidential CD file labeled PR #230.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-6078
555 S Cole Rd, Boise, ID 83707
Craig Pulley, 208-377-6000
Linda Murray, 208-377-6000
DATED at Boise, Idaho, this 7th day of December, 2016.
Respectfully submitted,
P~LV~
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
RESPONSE OF IGC TO TENTH PRODUCTION REQUEST OF COMMISSION STAFF Page4
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 7th day of December, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to Tenth Production Request of
the Commission Staff 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]
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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: mcc@ givenspursley.com
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83702
E-Mail: s [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
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 61h St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: kmiller@ snakeriveralliance.org
2
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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
E-Mail: [e-mail]
Lanny .zieman. l @us.af.mil
[e-mail]
[e-mail]
Ebony. payton. [e-mail]
Attorneys for Federal Executive Agencies
(FEA)
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Ronald L. Williams