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Home My WebLink About20200407IGC Objections to ICL Production Requests.pdfINTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 1 15076226_3.docx Preston N. Carter, ISB No. 8462 Givens Pursley LLP 601 W. Bannock St. Boise, Idaho 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 prestoncarter@givenspursley.com Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S 2019-2023 INTEGRATED RESOURCE PLAN ) ) ) ) ) ) ) CASE NO. INT-G-19-07 INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO IDAHO CONSERVATION LEAGUE’S FIRST PRODUCTION REQUESTS Intermountain Gas Company, submits the following objections to Idaho Conservation League’s First Production Requests dated March 24, 2020. REQUEST NO. 5: At pages 5-7, the Company makes several claims about gas in regards to greenhouse gas emissions. a. Please explain how the Company evaluated the risk and costs to Idaho ratepayers associated with the Company’s greenhouse gas emissions. b. Please provide the Company’s annual greenhouse gas emissions for the past five years and the Company’s forecasted annual greenhouse gas emissions over the next 20 years. c. Please explain whether or not the Company accounted for upstream greenhouse gas emissions (also known as fugitive emissions) associated with the gas drilling and transportation processes that supply the Company’s gas. RECEIVED 2020 April 7,PM2:46 IDAHO PUBLIC UTILITIES COMMISSION INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 2 15076226_3.docx d. Please provide the greenhouse gas emission rate for the Company’s gas in pounds of carbon dioxide equivalent per dekatherm. OBJECTION TO REQUEST NO. 5: Intermountain Gas objects because this request seeks information that is not relevant to this proceeding and because the request is not reasonably calculated to lead to the discovery of admissible evidence. The statements on pages 5-7 of the IRP executive summary are a narrative introduction provided for context and readability that are not required components of the IRP. Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707 INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 3 15076226_3.docx REQUEST NO. 10: BlackRock, Inc., the second largest shareholder of MDU Resources, requires all the companies it invests in to make two disclosures related to climate change and sustainability, including:  A disclosure of climate-related risks in line with the Task Force on Climate-related Financial Disclosures (TCFD), including the Company’s plan for operating under a scenario where the Paris Agreement’s goal of limiting global warming to less than two degrees is fully realized; and  A disclosure in line with industry-specific Sustainability Accounting Standards Board (SASB) guidelines. a. Please provide these disclosures. OBJECTION TO REQUEST NO. 10: Intermountain Gas objects because this request seeks information that is not relevant to this proceeding and because the request is not reasonably calculated to lead to the discovery of admissible evidence. Nothing in the IRP relates to the referenced disclosures, nor are these referenced disclosures required components of the IRP. Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707 INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 4 15076226_3.docx REQUEST NO. 12: At pages 61-62, the Company discusses the capacity release process. a. Please provide the amount, duration, and sale value of every capacity release successfully sold via pre-arranged deal with IGI Resources, Inc. (IGI) or via auction through an Electronic Bulletin Board (EBB) over the last three years; b. Please provide the amount and duration of excess capacity that was not successfully released via pre-arranged deal with IGI or via auction through an EBB over the last three years. OBJECTION TO REQUEST NO. 12: Intermountain Gas objects because this request seeks information that is not relevant to this proceeding and because the request is not reasonably calculated to lead to the discovery of admissible evidence. The requested information is not a part of the IRP process, but is rather a part of the purchased gas adjustment (“PGA”) process. However, in the interest of cooperation and disclosure, Intermountain Gas is willing to provide Idaho Conservation League with those portions of the requested information that was previously provided to Staff of the Idaho Public Utilities Commission during the most recent PGA process, on the condition that Idaho Conservation League treat such information as confidential pursuant to the protective agreement in this proceeding. Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707 INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 5 15076226_3.docx REQUEST NO. 16: At pages 64-71, the Company discusses Lost and Unaccounted for (LAUF) gas. a. Please provide the annual amount of Lost and Unaccounted for (LAUF) gas over the last 20 years. b. Please provide a comparison table, showing the annual amount of LAUF gas from representative gas companies in the Intermountain West. c. At page 68, the Company refers to “Dead Meters.” Please explain what dead meters are and explain why the Company identifies several hundred dead meters annually. Please provide the annual number of dead meters over the past 10 years. d. Please provide the annual amount of “found gas” that escaped from the Company system over the last 10 years. e. Please answer whether or not the Company subtracted LAUF gas and “found gas” from the Company’s load demand curves. OBJECTION TO REQUEST NO. 16: Intermountain Gas objects because this request seeks information that is not relevant to this proceeding and because the request is not reasonably calculated to lead to the discovery of admissible evidence. In Order No. 32855, the Commission directed the Company to move the statistics related to LAUF to its annual PGA filing. The LAUF section of the IRP is meant to explain “the Company’s (a) framework for how it has tested for, identified, and remediated equipment measurement errors or leaks, and (b) business process for alleviating measurement errors through its financial accounting of nominations, scheduling, measurements, flow volume allocation, and billing.” Most of the sub-requests of Request No. 16 are not related to LAUF items covered in the IRP. Notwithstanding this INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 6 15076226_3.docx objection, and subject to this objection, the following responses correlate to each particular sub- request of Request No. 16.: a. In the interest of cooperation and disclosure, Intermountain Gas will provide Idaho Conservation League with the LAUF data that was reported in its most recent PGA filing. b. Intermountain Gas does not have the requested comparison table. However, information regarding the subject-matter of this request is publically available at https://www.phmsa.dot.gov/data-and-statistics/pipeline/gas-distribution-gas-gathering-gas- transmission-hazardous-liquids c. In the interest of cooperation and disclosure, Intermountain Gas will provide Idaho Conservation League with 3 years’ data of the amount of dead meters and the requested explanation. d. In the interest of cooperation and disclosure, Intermountain Gas is willing to provide Idaho Conservation League with the LAUF data that was reported in its most recent PGA filing. e. Intermountain Gas does not, and has no way to, forecast the amount of LAUF gas and found gas. Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707 INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 7 15076226_3.docx Dated: April 7, 2020. GIVENS PURSLEY LLP Preston N. Carter Attorneys for Intermountain Gas Company INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUESTS - Page 8 15076226_3.docx CERTIFICATE OF SERVICE I certify that on April 7, 2020, a true and correct copy of INTERMOUNTAIN GAS COMPANY’S OBJECTIONS TO ICL’S FIRST PRODUCTION REQUEST was served upon all parties of record in this proceeding via the manner indicated below: Commission Staff Diane Hanian, Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714 Diane.holt@puc.idaho.gov Electronic mail John R. Hammond, Jr. Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714 john.hammond@puc.idaho.gov Electronic Mail Idaho Conservation League Benjamin J. Otto Matt Nykiel 710 N. 6th Street Boise, ID 83702 botto@idahoconservation.org mnykiel@idahoconservation.org Electronic Mail Preston N. Carter