20170117INT 92-94 to Staff.pdf

WILLIAMS · BRADBURY
A TTOR NEYS AT LAW
201"1 Jflr. 17 AM 10: 45
January 17, 2017
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Third Production Request to Staff-Case No. INT-G-16-02
Dear Ms. Hanian:
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Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Third Production Request to the Commission Staff. Six:w~
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
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
RE.:rr.:1\/ED " ... ..1 ··--
BEFORE THE IDAHO PUBLIC UTILITES 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
THIRD PRODUCTION REQUEST
OF INTERMOUNTAIN GAS
COMPANY TO COMMISSION
STAFF
Intermountain Gas Company ("Intermountain" 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 Staff of the Idaho Public Utilities Commission ("Staff') provide the following
documents and information as soon as possible, and no later than Tuesday, February 7, 2017.
This Production Request is continuing, and Staff 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.
IGC THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF 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.
THE FOLLOWING REQUEST RELATE TO THE TESTIMONY OF STAFF
WITNESS MIKE MORRISON
REQUEST NO. 92. Please provide all the necessary detail supporting the Revenue and
Cost of Gas dollar amounts corresponding to the adjustment for weather normalization on
Exhibit 103, Column 10, Lines 1 and 5.
THE FOLLOWING REQUESTS RELATE TO THE TESTIMONY OF STAFF
WITNESS JOE TERRY
REQUEST NO. 93. Please provide in Excel format with links activated, the supporting
calculations to Exhibit No. 106, including the determination of accumulated depreciation related
to the Company's Customer Service Center. Please also include all supporting documentation
relied on by Staff in the creation of Exhibit No. 106.
REQUEST NO. 94. Were the Net Book Values of the Company's Customer Service
Center building and land on Exhibit 106 determined using a 13-month average? If not, why
not? If so, please provide the 13-month calculation if not already included in the response to the
request above.
DATED at Boise, Idaho, this 17th day of January, 2017.
Respectfully submitted, ,
ivW1 ~ lvAr
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
JGC THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF Page2
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CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 17th day of January, 2017, I caused to be served a
true and correct copy of the Third Production Request of Intermountain Gas Company to the
Commission Staff upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 copies)
Diane Hanian
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 83 702
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
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
JGC THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF Page 3
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 83 702
E-Mail: [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. 6th 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
JGC THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF Page4
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. l @us.af.mil
N [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
[8J Electronic Transmission
Ronald L. Williams
IGC THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF Page 5