20230710INT to Staff 1-2_5-6_8-9_12_15.pdf

INTERMOUNTAIN GAS COMPANY’S RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[16813716_1.docx]

Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY’S APPLICATION FOR
AUTHORITY TO UPDATE THE
RENEWABLE NATURAL GAS
FACILITATION PLAN

Case No. INT-G-23-03

INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company (“Intermountain Gas,” “Applicant,” or “Company”) in
response to the First Production Request of the Commission Staff to Intermountain Gas
Company dated June 26, 2023, submits the following responses. Confidential documents are
provided under separate cover.
DATED July 10, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Intermountain Gas Company
RECEIVED
Monday, July 10, 2023 4:27:47 PM
IDAHO PUBLIC
UTILITIES COMMISSION
INTERMOUNTAIN GAS COMPANY’S RESPONSES TO FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I hereby certify that on July 10, 2023, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
_________________________________________
Preston N. Carter
INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris/ Lori
Blattner
REQUEST NO. 1:
Please explain who will be responsible for the installation and the cost to install the
Export Facilities discussed on page 5 of the Application. In addition, please explain how these
costs will be recovered if paid for by the Company.
RESPONSE NO. 1:
Intermountain Gas Company will install the compressor station, pipe, valves and other
related equipment. Northwest Pipeline will build the gate station interconnect that allows
Intermountain’s distribution system to connect with Northwest Pipeline’s system. The gate
station interconnect is considered part of the Export Facilities. The total of Intermountain’s costs
and Northwest Pipeline’s costs are the cost to install the Export Facilities discussed on page 5 of
the Application. The RNG Producer will pay for all costs of the Export Facilities via a
Contribution in Aid of Construction in full and up front.
INT-G-23-03
IPUC Staff PR 1
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dave Swenson/ Lori
Blattner
REQUEST NO. 2:
Please explain who will be responsible for the installation and the cost to install a new
interconnection between the Company’s distribution system and Northwest Pipeline discussed on
page 5 of the Application. In addition, please explain how these costs will be recovered.
RESPONSE NO. 2:
Intermountain Gas Company will install the compressor station, pipe, valves and other
related equipment. Northwest Pipeline will build the gate station interconnect that allows
Intermountain’s distribution system to connect with Northwest Pipeline’s system. The gate
station interconnect is considered part of the Export Facilities. The RNG Producer will pay for
all costs of the Export Facilities via a Contribution in Aid of Construction in full and up front.
INT-G-23-03
IPUC Staff PR 2
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris/Lori
Blattner
REQUEST NO. 5:
For each configuration identified in the Request No. 4, please provide a cost breakdown
that separates the cost of:
a. Dedicated infrastructure needed to transport RNG from the facility;
b. Dedicated infrastructure needed to transport gas sold to the facility; and
c. Common facilities shared by both.
RESPONSE NO. 5:
Please see the explanations below for each subsection of the production request:
a. Dedicated infrastructure needed to transport RNG from the facility;
Each project is different and requires unique costs for the interconnections that are
tracked through work orders. The costs for each project are recovered in full and up front via a
contribution in aid of construction (CIAC). See the Company’s response to Production Requests
1 and 2.
b.Dedicated infrastructure needed to transport gas sold to the facility;
Gas sold to the facility that requires dedicated infrastructure is treated the same as other
large industrial retail customers taking service under the Company’s retail Tariffs. The
infrastructure is processed under the Company’s line extension policy and the costs are
recovered via a CIAC.
c.Common facilities shared by both.
None.
INT-G-23-03
IPUC Staff PR 5
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris/ Lori
Blattner
REQUEST NO. 6:
In reference to “Intermountain filing an application with the Federal Energy Regulatory
Commission (“FERC”) to authorize the transportation of RNG in interstate commerce” discussed
on page 6 of the Application, please explain if this filing will subject any of the Company’s
facilities to FERC jurisdiction and how the filing could impact the State of Idaho’s jurisdictional
authority.
RESPONSE NO. 6:
The Company’s application with FERC to authorize the transportation of RNG interstate
commerce should not subject any of the Company’s facilities to FERC jurisdiction nor impact
the State of Idaho’s jurisdictional authority.
FERC’s jurisdiction over the specific interstate transportation service provided by local
distribution companies is limited to approval of the rates and terms and conditions of such
service. FERC’s exercise of jurisdiction over the rates and terms of service is more light-handed
than its review of the rates of interstate natural gas pipelines. Generally, FERC allows local
distribution companies to utilize rates approved by the state regulatory authority, provided that
such rates are cost-based.
The Company's filing for a blanket certificate of limited jurisdiction will not subject any
of the Company's facilities to FERC jurisdiction. For example, the Company will not be required
to file for a certificate under Section 7 of the Natural Gas Act (NGA) authorizing the
construction of facilities. Nor will the Company be required, as are natural gas pipelines, to file
INT-G-23-03
IPUC Staff PR 6
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annual financial reports. Instead, FERC approval of the Company's Application will allow the
Company to transport gas in interstate commerce, while ensuring that the Company's primary
role will continue to be that of a state-regulated local distribution company.
INT-G-23-03
IPUC Staff PR 6
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris/ Lori
Blattner
REQUEST NO. 8:
Please explain how often the Access Fee discussed on pages 9-10 in the Application will
be updated and explain the Company’s process for updating the Access Fee.
RESPONSE NO. 8:
The Company will review the Access Fee periodically as the RNG market continues to
grow and change to determine if an update to the fee is appropriate. In addition, because the
Access Fee is a Return on Equity (ROE) based charge, the Company will also periodically
review the ROEs of both the utility methodology and FERC’s methodology to assess the risk
premium. When a change to the Access Fee is needed, the Company will file the updated Access
Fee with the Commission under Docket No. INT-G-23-03.
INT-G-23-03
IPUC Staff PR 8
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dave Swenson/ Lori
Blattner
REQUEST NO. 9:
Please explain if the Biogas Standards outlined in Exhibit 3 is different than the standards
used in the existing RNG Facilitation Plan. If Exhibit 3 is different than the current standards,
please explain the differences.
RESPONSE NO. 9:
The Biogas Standards outlined in Exhibit 3 are the same standards used in the existing
RNG Facilitation Plan. No changes have been made.
INT-G-23-03
IPUC Staff PR 9
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris
REQUEST NO. 12:
In reference to Exhibit No. 4 of the Application and the statement “[a]n annual minimum
bill may not apply if the customer is a renewable natural gas production facility …” please
explain under which situations an annual minimum bill would or would not apply to RNG
production facilities. Please include the justification why the annual minimum bill applies or
does not apply for each situation.
RESPONSE NO. 12:
The Company appreciates Commission Staff questioning the language in the proposed
Rate Schedule T-3. After reviewing the schedule language, the Company proposes to clarify the
language in its proposed Rate Schedule T-3 to “An annual minimum bill will not apply if the
customer is a renewable natural gas production facility.”
INT-G-23-03
IPUC Staff PR 12
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Niki Ogami/Zach Harris
REQUEST NO. 15:
Please provide the accounting entries for T-3 revenues and expenses as they apply to
RNG producers.
RESPONSE NO. 15:
RNG producers that transport gas on Intermountain Gas Company’s distribution system
will be charged the T-3 tariff rate. The journal entry to record the revenue for any T-3 customer
is as follows:
(DR) Accounts Receivable 48.1420.13101
(CR) T-3 Revenue 48XXX.4890.4893
There are no additional expenses related to RNG producers that transport gas on Intermountain
Gas Company’s distribution system who are being charged the T-3 tariff rate.
INT-G-23-03
IPUC Staff PR 15
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