20200513Staff 1-5 to INT.pdf

FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 MAY 13, 2020
MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY’S APPLICATION FOR
AUTHORITY TO FACILITATE RENEWABLE
NATURAL GAS ACCESS
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CASE NO. INT-G-20-03

FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY

The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (Intermountain Gas; Company) provide the following documents and information as
soon as possible, by THURSDAY, MAY 21, 2020.1
This Production Request is continuing, and the Company 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, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that 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

1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff’s
attorney at [phone].
RECEIVED
2020 May 13PM4:40
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 MAY 13, 2020
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
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 describe the different configurations that are possible for
facilities that produce and sell Renewable Natural Gas (RNG) relative to the pipeline and
equipment infrastructure that the Company would install and maintain. In the description,
please:
a. Provide a system map of different configurations identifying all Company
installed infrastructure, dedicated infrastructure needed to move gas sold to and
consumed by the facility, dedicated infrastructure needed to transport RNG out of
the facility and injected into the Company’s pipeline, and common facilities
shared by both.
b. Provide a narrative describing the different configurations, including the purpose
of the major components.
c. Provide a cost breakdown of the facilities required for the different configurations
separating costs of dedicated infrastructure needed for gas sold to and consumed
by the facility, dedicated infrastructure needed to transport RNG out of the facility
and injected into the Company’s pipeline, and common facilities shared by both.

REQUEST NO. 2: If common infrastructure can be used to both provide gas to the
facility and take RNG from the facility, how does the Company propose to allocate Operations
and Maintenance cost? Please explain.

REQUEST NO. 3: The Company states in its Application that Idaho has the necessary
biomass to produce and transport a “significant” amount of RNG. Application at 4. Please
define significant in terms of potential and technically feasible volumes.

FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 3 MAY 13, 2020
REQUEST NO. 4: The Company states in its Application that is has executed contracts
with three RNG producers and plans to bring the contracts into alignment with the plan
ultimately approved by the Commission. Application at 9. Please describe steps the Company
intends to take to achieve alignment, including expected completion dates.

REQUEST NO. 5: Please provide work papers showing a sample of calculations of the
following items: maintenance fee, access fee, annual payment adjustment, startup and
extraordinary O&M expenses, the gross up of Contribution In Aid of Construction (CIAC), and
the overhead loading rate.

DATED at Boise, Idaho, this 13th day of May 2020.

________________________________
Matt Hunter
Deputy Attorney General

i/utility/umisc/production requests/intg20.3mhmekkjk prod req 1
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF MAY 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-20-03, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:

LORI BLATTNER
DIR – REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]

PRESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]

/s/ Reyna Quintero __
SECRETARY