20170202NWIGU 1-8 to Staff.PDF

Page 1 NWIGU’S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
Chad M. Stokes (OSB No. 004007)
Tommy A. Brooks (OSB No. 076071)
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Michael C. Creamer (ISB No. 4030)(Local Counsel)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: (208) -388-1300
[e-mail]

Attorneys for Northwest Industrial Gas Users

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF
INTERMOUNTAIN GAS COMPANY
FOR THE AUTHORITY TO
CHANGE ITS RATES AND
CHARGES FOR NATURAL GAS
SERVICE TO NATURAL GAS
CUSTOMERS IN THE STATE OF
IDAHO

CASE NO. INT-G-16-02

FIRST PRODUCTION REQUEST OF
NORTHWEST INDUSTRIAL GAS
USERS TO IDAHO PUBLIC
UTILITIES COMMISSION STAFF

Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
Commission (“Commission”), Northwest Industrial Gas Users (“NWIGU”) by and
through its attorney of record, Chad Stokes, granted limited admission by the
Commission in Order 33610, hereby requests that the Idaho Public Utilities Commission
Staff (“Staff”) provide the following documents and information as soon as possible, and
no later than Wednesday, February 22, 2017:

DEFINITIONS
1. "Company" refers to the Intermountain Gas Company, any affiliated company, or
any officer, director or employee of Intermountain Gas Company, or any
affiliated company.
2. "Commission Staff' or "Staff" refers to Idaho Public Utilities Commission Staff.
3. "Documents" refers to all writings and records of every type in your possession,
control, or custody, whether or not claimed to be privileged or otherwise
excludable from discovery, including but not limited to: testimony and exhibits,
memoranda, papers, correspondence, letters, reports (including drafts,
preliminary, intermediate, and final reports), surveys, analyses, studies (including
economic and market studies), summaries, comparisons, tabulations, bills,
invoices, statements of services rendered, charts, books, pamphlets, photographs,
maps, bulletins, corporate or other minutes, notes, diaries, log sheets, ledgers,
transcripts, microfilm, microfiche, computer data (including E-mail), computer
files, computer tapes, computer inputs, computer outputs and printouts, vouchers,
accounting statements, budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and
telegraphic communications, speeches, and all other records, written, electrical,
mechanical, or otherwise, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwritten or
other notations or which otherwise does not duplicate the original or any other
copy.
"Documents" also includes any attachments or appendices to any document.
4. "Identification" and "identify" mean:
When used with respect to a document, stating the nature of the document(~,
letter, memorandum, corporate minutes); the date, if any, appearing thereon; the
date, if known, on which the document was prepared; the title of the document;
the general subject matter of the document; the number of pages comprising the
document; the identity of each person who wrote, dictated, or otherwise
participated in the preparation of the document; the identity of each person who
signed or initiated the document; the identity of each person to whom the
document was addressed; the identity of each person who received the document
or reviewed it; the location of the document; and the identity of each person
having possession, custody, or control of the document.
Page 2 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
When used with respect to a person, stating his or her full name; his or her most
recently known home and business addresses and telephone numbers; his or her
present title and position; and his or her present and prior connections or
associations with any participant or party to this proceeding.
5. "Person" refers to, without limiting the generality of its meaning, every natural
person, corporation, partnership, association (whether formally organized or ad
hoc), joint venture, unit operation, cooperative, municipality, commission,
governmental body or agency, or any other group or organization.
6. "Studies" or "study" includes, without limitation, reports, reviews, analyses and
audits.
7. The terms "and" and "or" shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any
information or documents which might otherwise be considered to be beyond
their scope.
8. The singular form of a word shall be interpreted as plural, and the plural form of a
word shall be interpreted as singular, whenever appropriate in order to bring
within the scope of this discovery request any information or documents which
might otherwise be considered to be beyond their scope.
INSTRUCTIONS
1. These requests call for all information, including information contained in
documents, which relate to the subject matter of the Production Request and
which is known or available to Staff.
2. Where a Production Request has a number of separate subdivisions or related
parts or portions, a complete response is required to each such subdivision, part or
portion. Any objection to a Production Request should clearly indicate the
subdivision, part, or portion of the Production Request to which it is directed.
3. In addition to hard copy, electronic versions of the document, including studies
and analyses, must also be furnished if available.
4. If Staff cannot answer a Production Request in full, after exercising due diligence
to secure the information necessary to do so, state the answer to the extent
possible, state why Staff cannot answer the Production Request in full, and state
what information or knowledge Staff has concerning the unanswered portions.
5. If Staff refuses to respond to any Production Request by reason of a claim of
privilege, confidentiality, or for any other reason, state in writing the type of
privilege claimed and the facts and circumstances Staff relies upon to support the
claim of privilege or the reason for refusing to respond. With respect to requests
Page 3 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
for documents to which Staff refuses to respond, identify each such document,
and specify the number of pages it contains. Provide: (a) a brief description of
the document; (b) date of document; ( c) name of each author or preparer; ( d)
name of each person who received the document; and ( e) the reason for
withholding it and a statement of facts constituting the justification and basis for
withholding it.
6. Identify the person from whom the information and documents supplied in
response to each Production Request were obtained, the person who prepared
each response, the person who reviewed each response, and the person who will
bear ultimate responsibility for the truth of each response.
7. These requests for documents and responses are continuing in character so as to
require Staff to file supplemental answers as soon as possible if Staff obtains
further or different information. Any supplemental answer should refer to the
date and use the number of the original request or subpart thereof.
8. Whenever these Production Requests specifically request an answer rather than
the identification of documents, the answer is required and the production of
documents in lieu thereof will not substitute for an answer.
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Page 4 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
PRODUCTION REQUESTS
Regarding the Direct Testimony of Commission Staff Witness Morrison:
NWIGU REQUEST NO. 1 TO STAFF:
At page 2, lines 20-21 of Mr. Morrison's testimony, he states that the Company," ... is
proposing cost allocators that are both novel and inappropriate." Please specifically
identify the Company's allocators that Mr. Morrison has deemed "novel and
inappropriate," and describe the basis for this statement.
NWIGU REQUEST NO. 2 TO STAFF:
At page 6, Mr. Morrison states that, "When usage is mixed in large portions of the
distribution system, it may also be appropriate to use a peak and average allocator. Such
an allocator is particularly appropriate for large distribution mains, which often serve
diverse needs." With respect to his statement:
a. Please explain how the classes' usage impacts the Company's design of system
capacity to meet its system peak day demand.
b. Does Mr. Morrison believe there is a distinction between firm and interruptible
delivery service?
c. If the answer to subpart b. above is yes, how does firm versus interruptible service
impact: (i) usage and (ii) capacity on the delivery system?
NWIGU REQUEST NO. 3 TO STAFF:
Please indicate whether or not Mr. Morrison, or other Commission Staff members,
performed any analyses to support the conclusion that the Company's peak day allocators
would unfairly allocate costs, as discussed on page 7, lines 1-25, and page 8, lines 1-2 of
Mr. Morrison's testimony. If such analyses have been performed, please provide them on
an electronic spreadsheet with all formulas intact.
NWIGU REQUEST NO. 4 TO STAFF:
Mr. Morrison takes issue with the Company's use of January 1, 2016 as its system peak
day. Does Mr. Morrison have a specific recommendation of an alternative system peak
date? If so, please identify it and explain why it is appropriate.
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Page 5 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
NWIGU REQUEST NO. 5 TO STAFF:
At page 12, lines 10-12 of his testimony, Mr. Morrison takes issue with the Company's
proposal to classify a portion of distribution mains plant as customer-related. Please
respond to the following:
d. Has Mr. Morrison reviewed any documents pertaining to the planning and design
of the Company's distribution system to meet the peak load of its firm service
customers? If so, please provide copies of such documents.
e. Does Mr. Morrison agree that the Company's distribution mains must be sized to
accommodate the total demand of its firm service customers at the time of the
system peak?
f. Consider an example where the Company has 2 customers with the same peak day
demand connected to a distribution loop. If these customers are 2 miles apart from
each other, then the Company would need to install 2 miles of distribution main
with adequate capacity to meet the peak day demands of both customers. If the
customers were 10 miles apart, then the Company would need to install 10 miles of
distribution main to serve them. Would Mr. Morrison agree that the length of
distribution main needed to connect customers to the system is driven by the
geographic location of customers? If the response is anything other than an
unqualified "yes," please explain.
NWIGU REQUEST NO. 6 TO STAFF:
At page 13 of his testimony, Mr. Morrison takes issue with the Company's use of the
Minimum Intercept method of determining the customer-and demand-related portions of
distribution mains plant investment.
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g. Has Mr. Morrison recalculated the customer and demand components of
distribution mains plant investment? If so, please provide the results of such
calculations on an electronic spreadsheet with all formulas intact.
h. Does Mr. Morrison agree that connecting customers to the system is an issue in
designing the delivery distribution capacity and that there are factors other than
peak demand and usage that drive a utility's cost of delivery?
Page 6 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
Regarding the Direct Testimony of Commission Staff Witness Erdwurm:
NWIGU REQUEST NO. 7 TO STAFF:
At page 19, lines 9-11, Mr. Erdwurm recommends that the Company's proposed MDFQ
charge of $0.30 per therm be reduced to $0.20 per therm of MDFQ for Large Volume and
Transportation customers. Please explain how the recommended $0.20 per therm MDFQ
charge was derived. Please provide all supporting calculations on an electronic spreadsheet
with formulas intact.
NWIGU REQUEST NO. 8 TO STAFF:
Has Mr. Erdwurm considered the demand charges of other gas delivery utilities in
developing his recommendation of the $0.20 per therm MDFQ charge? If so, please
identify the gas utilities and specific large volume and transportation tariffs that were
considered.
Dated this I51 day of February 2017.
Chad M. Stokes, OSB No. 004007
Tommy A. Brooks, OSB No. 076071
Cable Huston, LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
Of Attorneys for
Northwest Industrial Gas Users
Page 7 NWIGU'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO
IDAHO PUBLIC UTILITIES COMMISSION STAFF
CERTIFICATE OF SERVICE
I CERTIFY that I have on this day served the foregoing document upon all parties
of record in this proceeding via electronic mail and/or by mailing a copy properly
addressed and first class postage prepaid.
Peter J. Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N 27111 Street
Boise, ID 83702
[e-mail]
[e-mail]
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays Street
Boise, ID 83 702
[e-mail]
Benjamin Otto
Idaho Conservation League
710 N 6111 Street
Boise, ID 83 702
[e-mail]
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
[e-mail]
Page 1 -CERTIFICATE OF SERVICE
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
PO Box 7608
Boise, ID 83707
[e-mail]
Scott Dale Blickenstaff
Amalgamated Sugar Co LLC
1951 S Saturn Way Ste 100
Boise, ID 83702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8111 Avenue
Helena, MT 59601
[e-mail]
Karl Klein
Sean Costello
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]
26678.885\4829-9229-6001.v I
Brad M. Purdy
2019 N 17111 Street
Boise, ID 93 702
bmpurd [e-mail]
Michael C. Creamer
Givens Pursley
[e-mail]
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]
Lanny.zieman. [e-mail]
[e-mail]
[e-mail]
[e-mail]
Dated in Portland, Oregon, this 1st day of F
26678.885\4829-9229-600 I. v I
Page 2 -CERTIFICATE OF SERVICE
Chad M. Stokes, OSB No. 004007
Tommy A. Brooks, OSB No. 076071
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
Of Attorneys for the
Northwest Industrial Gas Users
26678.885\4829-9229-600 I. vi