20170130Sugar to INT 14-15.pdf

Peter Richardson [SB #3195
Gregory M. Adams ISB #7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for the Amalgamated Sugar Company
RECE IVED
ZD!7 J!irl 30 PH 2: 36
I ,j,-UGLI C
'· 't ,, C0:,1~A 1SSION
BEFORE THE
IDAHO PUBLlC UTILlTIES COMMISSION
IN THE MATTER OF lNTERMOUNTAlN )
GAS COMPANY'S APPLICATION TO )
CHANGE ITS RA TES AND CHARGES FOR )
NATURAL GAS SERVICE IN THE STATE OF)
IDAHO )
)
)
)
)
CASE NO. INT-G-16-02
AMALGAMATED SUGAR
COMP ANY LLC RESPONSE TO
lNTERMOUNTAlN GAS
COMPANY'S SECOND
PRODUCTION REQUEST
COMES NOW, The Amalgamated Sugar Company, LLC, and hereby provides the
following responses to the First Production Request of Intermountain Gas Company (the "Gas
Company"). Dr. Reading is the witness who can sponsor these responses at hearing.
REQUEST NO. 14. Would a demand charge provide an incentive, or a disincentive, for
large volume customers to make an efficient choice in regards to MDFQ election?
RESPONSE TO REQUEST NO. 1.
Having to pay a demand charge based on the magnitude of a customer's MDFQ
nomination would incent accurate (to the extent possible) MDFQ nominations in order to
minimize payment for MDFQ that is not utilized. If that is what is meant by the term
"efficient choice" then it would tend to incent an efficient choice.
Amalgamated Sugar
Response to JGC DR #2 -INT-G-16-02 2
REQUEST NO 15. Please provide the Rate Shock Mitigation publication referred to at page
7, line 3 of Dr. Reading's testimony.
RESPONSE TO REQUEST NO. 15:
The publication may be downloaded and printed at:
http://www.eei.org/w hatwedo/Pu blicPolicyAdvocacy/S ta teRegula tion/Docu men ts/rate s
hock mitigation.pdf
Amalgamated Sugar
Response to IGC DR #2 -INT-G-16-02 3
DA TED this 27th day of January, 2017.
Peter J. Richardson
RICHARDSON ADAMS, PLLC
Attorneys for the Amalgamated Sugar
Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th day of January, 2017, a true and correct copy of the
within and foregoing RESPONSE OF THE AMALGAMATED SUGAR COMPANY, LLC TO
THE SECOND PRODUCTION REQUEST OF THE INTERMOUNTAIN GAS COMPANY
was served by Electronic and U.S. Mail:
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
555 S. Cole Road
PO Box 7608
Boise, ID 83707
[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]
Amalgamated Sugar
Response to IGC DR #2 -INT-G-16-02 4
Ronald L. Williams
Attorney for Intermountain Gas Company
1015 West Hays Street
Boise, Idaho 83702
ron@wi 11 iamsbradbury.com
Michael C. Creamer
Givens Pursley, LLP
601 West Bannock Street
Boise, Idaho 83702
[e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, Idaho 83702
bmpurdy@hotmai I .com
Karl Klein
Sean Costello
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
[e-mail]
[e-mail]
Michael C. Creamer
Givens Pursley
[e-mail]
(electronic copy only)
Ken Miller
Snake River Alliance
km i ller@snakeriveral I iance.org
(electronic copy only)
Andrew Unsicker
Lanny Zieman
Natalie Cepak
Thomas Jernigan
Ebony Payong
United States Air Force
[e-mail]
Lanny.zieman. l @us.af.mil
Natal [e-mail].m i I
[e-mail]
[e-mail]
(electronic copy only)
By: ________________ _
Kandi Walters, Administrative Assistant
Richardson Adams, PLLC
Amalgamated Sugar
Response to JGC DR #2 -fNT-G-1 6-02 5
Ed Finklea
Northwest Industrial Gas Users
545 Grandview Drive
Ashland, OR 97520
[e-mail]
Benjamin Otto
ldaho Conservation League
[e-mail]
(electronic copy only)
F. Diego Rivas
NW Energy Coalition
[e-mail]
(electronic copy only)