20161230INT 1-13 to Sugar.pdf

WILLIAMS BRADBURY
ATTORN E YS AT LAW
December 30, 2016
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
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RE: IGC First Production Request to Amalgamated Sugar Company -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 First Production Request to the Amalgamated Sugar
Company.
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83 702
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
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNT AIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
) _________________ )
Case No. INT-G-16-02
FIRST PRODUCTION REQUEST
OF INTERMOUNTAIN GAS
COMP ANY TO AMALGAMATED
SUGAR COMP ANY
Intermountain Gas Company ("lntermountain" or "Company"), a subsidiary of MDU
Resources Group, Inc., by and through its attorney of record Ronald L. Williams and pursuant to
the Rules of Procedure of the Idaho Public Utilities Commission ("Commission"), hereby
requests that the Amalgamated Sugar Company ("Amalgamated") provide the following
documents and information as soon as possible, and no later than Friday, January 20, 2017.
This Production Request is continuing, and Amalgamated 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, and supporting work papers that provide detail
or are the source of information used in calculations. 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. IDAPA 31.01.01.228.
JGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page I
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. 1. Please identify all gas distribution companies, including Intermountain
Gas Company, that provide service to Amalgamated processing facilities, and the location of
each Amalgamated Sugar Company sugarbeet processing facility.
REQUEST NO. 2. For gas distribution companies listed above other than Intermountain,
please provide copies of the currently effective tariffs and rates that those gas distribution
companies charge to Amalgamated for service at each of the Amalgamated's sugarbeet
processing, and the length of time (approximate) since each of these distribution companies'
most recent rate case.
REQUEST NO. 3. Regarding Dr. Don Reading's testimony page 3 "On the other hand,
customers have built usage patterns, and even investment in plant, based on thirty years of
experience/expectations with the existing rate design. If over those thirty years rate design
changes were called for, the customers of the Gas Company were not made aware of those
pending changes and as a result have not been able to plan for or budget capital expenditures to
accommodate those pending rate design changes":
(a) If the Commission accepted the rate design changes proposed by the Company in this
case, please describe and explain the capital expenditures and operational practices
Amalgamated would make, or is or would consider making, in order to adjust to the rate
design changes proposed;
(b) With respect to (a) above, please identify the specific change in Intermountain's rate
design or cost of service proposal that will be accommodated by each potential Amalgamated
Sugar Company capital expenditure or operational change.
JGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page 2
REQUEST NO. 4. Regarding Dr. Don Reading's testimony, page 13 line 5 -page 14 line 2,
Please describe and explain the basis for the recommendation that the results of this cost of
service study, if adopted, should be implemented over the next five Intermountain Gas Company
general rate cases.
REQUEST NO. 5.Does Dr. Reading agree or disagree that the principals of promoting rate
stability and mitigating rate shock would be equally or even better served by a known phase in
period of a set number of years, as opposed to a set number of next general rate cases?
REQUEST NO. 6. Please provide all research and analysis referred to by Dr. Reading or
relied on in making the recommendation that the phase in period should be the Company's next
five rate cases. Please provide all testimony that you have prepared or sponsored in any other
proceeding in which you recommended a multi-year or multi rate case period to phase in cost of
service study studies and / or rate design recommendations. In addition to copies of your
testimony, please provide copies of the final regulatory commission order in each proceeding.
REQUEST NO. 7. What is the annual load factor at each of Amalgamated three plants? At
what cost and under what conditions could Amalgamated shift some of the winter production to
shoulder months?
REQUEST NO. 8. Does Amalgamated require firm capacity at its three plants served by the
Company during the months of November through March? If so, how much?
REQUEST NO. 9. Does Amalgamated require firm service for its entire load or could it load
shift or take interruptible service for some of that load?
REQUEST NO. 10. What percent of the Amalgamated' s total annual natural gas bill is
compromised by Intermountain's T-4 billing charges?
JGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page 3
REQUEST NO. 11 . Can Amalgamated bum coal instead of natural gas at any or all of
its three plants served by the Company? If so, how much and under what conditions and/or
constraints?
REQUESTNO. 12. Please identify all northwest gas distribution companies that do
not impose a demand charge on large volume customers for firm sales or transport service.
Please produce all workpapers and documents reviewed by Amalgamated in evaluating the
existence of and the level of demand charge imposed by local gas distribution companies other
than Intermountain.
REQUESTNO. 13. Please explain further why Amalgamated appears to believe that
seasonal transportation rates would be advantageous to a customer, such as Amalgamated, that
uses most of its natural gas in the winter months?
DATED at Boise, Idaho, this 1 r/f\ day of !J .,{{tl,,,t b,y , 2016.
Respectfully submitted,
;[ µv/ ~ lJ )Jl--
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
IGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page4
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 30th day of December, 2016, I caused to be served
a true and correct copy of the First Production Request of Intermountain Gas Company to 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. 1 ih Street
Boise, ID 83 702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 61h Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h 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
~ 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
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
IGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page 5
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. 2?1h 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. 61h St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
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
IGC FIRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page 6
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. [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
1:8:J Electronic Transmission
Ronald L. Williams
IGC FlRST PRODUCTION REQUEST TO AMALGAMATED SUGAR CO. Page 7