20161212INT to Sugar 4-8.pdf

WILLIAMS · BRADBURY
December 12, 2016
Jean D. Jewell
Commission Secretary
ATTORNEYS AT LAW
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Response to Amalgamated Second Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
REC EIVED
20 I DL, I 2 PM '1: 2 7
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Response to Amalgamated Sugar Company's Second Request
for Production.
By separate confidential CD, please find the responses to Amalgamated Sugar Company's
request No. 4 and 5.
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: [e-mail]
Attorneys for Intermountain Gas Company
RE CEIVED
20!& DEC I 2 PM 4: 27
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
_________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SECOND
PRODUCTION REQUEST OF THE
AMALGAMATED SUGAR
COMPANYLLC
COMES NOW, Intermountain Gas Company, and in response to the Second Production
Request of the Amalgamated Sugar Company LLC dated November 21, 2016, herewith submits
the following information:
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
Please see the Confidential CD file labeled "AMAL PR #4" to find a billing comparison
for the three Amalgamated plants, at the plant's current MDFQ, using Intermountain 's currently
effective rates compared to the Company's proposed rates as filed in Case INT-G-16-02.
Also included with this file is a comparison for these same three plants using the updated
MDFQ 's as recently negotiated with Intermountain. This additional comparison used a revised
volumetric charge that would be necessary to arrive at the Company's filed customer class
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE AMALGAMATED SUGAR
COMPANY, Pagel
specific revenue requirement in light of the reduction in MDFQ 's. The impact of that revised
volumetric charge is small as compared to the savings realized by the revised MDFQ 's.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Dave Swenson, 208-377-6000
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
Please see the CD file labeled "AMAL PR #5-Confidential contracts " to find copies of all
Facilities Agreements between the Company and its T-4/T-5 customers. Redacted from each
facilities agreement is information that would allow a reader to identify which customer is
receiving what volume of service at any particular location, and the price paid for the facilities
upgrades unique to each T-4/T-5 customer. The Company believes these redactions are
necessary so that that the Company is not providing competitive or trade secret information
about a T-4/T-5 customer to another T-4/T-5 customer competing in the same industry,
regardless of the fact that the various parties to this case and their corporate principles may
have signed Protective Agreements.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
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
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE AMA LG AMA TED SUGAR
COMPANY, Page 2
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
Please go to the Commission 's file room to see a copy of the Company 's tariff related to
General Service Provisions: http://www.puc. idaho.govlfileroomltariff/gas/lntermountaingas.pdf
The General Service Provisions (GSP) Tariff was approved by the Commission on March 23,
2015. Subsection 2.4, of Section A of the GSP Tariff provides that T-4/T-5 customers must sign
12 month service contracts, and that such contracts may be renegotiated whenever the customer
desires to increase usage. Subsection 2.4 also requires that "[o}ther special contracts may be
required where large or special investment in facilities is necessary to supply the requested
service, and the Company reserves the right to require contributions toward such investment and
to establish such minimum charges as are deemed necessary. "
The General Service Provisions of its Tariff on file with the Commission provides the
Company and each T-4/T-5 customer the ability and flexibility to negotiate and execute facilities
agreements that are unique and responsive to the needs, facts and circumstances of each T-4/T-5
customer, without requiring further review or approval of such facilities agreements by the
Commission.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Mike McGrath, 208-377-6000
REQUEST FOR PRODUCTION NO. 7:
Please provide a copy of the Company's line extension policy for Transportation
customers. Please include workpapers and supporting documents used to develop the
RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE AMALGAMATED SUGAR
COMPANY, Page 3
Company's line extension policy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
Line extension terms and conditions for transportation customers are incorporated within
the facilities agreements for such customers, as provided in Subsection 2. 4, of Section A of the
Company 's GSP Tariff approved by the Commission.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
Please see answers to questions 5 through 7 above.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Mike McGrath, 208-377-6000
DATED at Boise, Idaho, this 12th day of December, 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE AMALGAMATED SUGAR
COMPANY, Page 4
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 12th day of December, 2016, I caused to be served a
true and correct copy of the Response of Intermountain Gas Company to Second Production
Request of the Amalgamated Sugar Company 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 83707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
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
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~ Electronic Transmission
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D Hand Delivery
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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 83709
E-Mail: s b [e-mail]
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 2ih Street
Boise, ID 83702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
Company LLC
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
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
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
Ronald L. Williams