20230714INT to Staff 3-4_10-11_14.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]
[16842691_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 14, 2023.

GIVENS PURSLEY LLP
By
Preston N. Carter
Intermountain Gas Company
RECEIVED
2023 JULY 14, 2023 4:53PM
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 14, 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: Dave Swenson/ Lori
Blattner
REQUEST NO. 3:
Please describe the range of renewable natural gas (“RNG”) services and configurations
that the Company would potentially serve under the proposed plan. For example, would the
company provide service to an RNG producer not consuming natural gas as a Company
customer and/or provide service to a RNG producer that would be interconnected to Northwest
pipeline without interconnecting to an existing Company distribution line?
RESPONSE NO. 3:
The Company currently has three different configurations either currently online or
currently proposed by an RNG producer:
1.The RNG producer injects the RNG into Intermountain’s distribution system and the RNG is
fully exported into Northwest Pipeline.
2.The RNG producer injects the RNG into Intermountain’s distribution system and the RNG is
fully consumed by retail customers on the same localized distribution system as the RNG
producer.
3.The RNG producer injects the RNG into Intermountain’s distribution system and the RNG is
partially consumed by retail customers on the same localized distribution system as the RNG
producer. The remaining excess RNG is exported into the Northwest Pipeline resulting in
comingled natural gas and requires export facilities.
In this rapidly evolving market, other configurations may exist that have not yet been requested
of the Company. In addition, RNG producers that require natural gas service from Intermountain
receive standard natural gas service under the Company’s retail natural gas Tariff as a large
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IPUC Staff PR 3
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industrial customer. The need or lack thereof for retail service does not impact the Company’s
ability to provide RNG facilitation service to RNG producers.
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IPUC Staff PR 3
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathleen Campbell

REQUEST NO. 4:
Please provide system maps for each configuration identified in the previous request
identifying all infrastructure necessary to serve customers who produce RNG for sale. In
addition, please provide references of the following information for each system map:
a. Identification of dedicated infrastructure needed to transport RNG from the
facility;
b. Identification of dedicated infrastructure needed to transport gas sold to the
facility;
c. Identification of common infrastructure needed to transport RNG from and gas
sold to the facility;
d. Identification of the party who will ultimately own each piece of infrastructure;
e. Identification of the party responsible for installing/constructing each piece of
infrastructure; and
f. Identification of the agencies responsible for regulating each piece or section of
infrastructure.
RESPONSE NO. 4:
Please see the attachments to this response. The attachments show the three types of
configurations discussed in the Company’s response to Staff’s Production Request No. 3. Each
configuration is summarized below:
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IPUC Staff PR 4
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 RNG Configuration 1 – The RNG producer injects the RNG into Intermountain’s
distribution system and the RNG is fully exported into Northwest Pipeline. There is no
comingling of traditional natural gas and RNG.
 RNG Configuration 2 – The RNG producer injects the RNG into Intermountain’s
distribution system and the RNG is fully consumed by retail customers on the same
localized distribution system as the RNG producer.
 RNG Configuration 3 – The RNG producer injects the RNG into Intermountain’s
distribution system and the RNG is partially consumed by retail customers on the same
localized distribution system as the RNG producer. The remaining RNG is exported into
the Northwest Pipeline resulting in comingled natural gas and requires export facilities.

a. Dedicated infrastructure to transport RNG from the facility would be infrastructure that is only
for the RNG producer and does not include IGC distribution system that could serve other
customers. Dedicated Infrastructure for each configuration is shown in orange in the attachments.
 RNG Configuration 1 – IGC RNG Interconnect
 RNG Configuration 2 – IGC RNG Interconnect
 RNG Configuration 3 – IGC RNG Interconnect

b. Dedicated infrastructure to transport gas sold to RNG facilities consists of the gas meter, service
line regulator and or HPSS (if applicable) and service line and is shown in purple in the
attachments.

c. Common infrastructure needed to transport RNG from and gas sold to the facility is defined as
IGC’s distribution system and is shown in blue in the attachments. Common Infrastructure for
each configuration is listed below.
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IPUC Staff PR 4
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 RNG Configuration 1 – IGC Distribution System
 RNG Configuration 2 – IGC Distribution System
 RNG Configuration 3 – IGC Distribution System

d. Identification of ownership is shown in the attachments by color.

e. Identification of the party responsible for installing and constructing each piece of infrastructure
is shown in the attachments by color and is consistent with ownership. It’s important to note
again that any infrastructure constructed to serve RNG producers will be completely offset with a
contribution in aid of construction (CIAC).

f. Company operated infrastructure is required to follow 192 regulation which is regulated at the
state level by the Idaho Public Utilities Commission. RNG producer operated infrastructure is
also required to follow Federal and State regulations as they apply. Williams Northwest Pipeline
operated infrastructure is regulated by FERC.
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IPUC Staff PR 4
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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. 10:
Please explain if the safety provisions discussed on page 12 of the Application are
different than the safety provisions used in the existing RNG Facilitation Plan. If safety
provisions are different than the current provisions, please explain the differences.
RESPONSE NO. 10:
The safety provisions discussed on page 12 of the Application are the same provisions
used in the existing RNG Facilitation Plan. No changes have been made.
INT-G-23-03
IPUC Staff PR 10
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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. 11:
Please provide a copy of the current RNG Facilitation Plan along with a redline version
showing the proposed changes to the RNG Facilitation Plan.
RESPONSE NO. 11:
See the attached documents for the current and proposed RNG Facilitation Plans.
INT-G-23-03
IPUC Staff PR 11
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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. 14:
The Maintenance fee is to be updated and adjusted annually based on the prior 12
month’s revenue and expenses. Please provide the calculations used to derive the updated
monthly Maintenance Fee and the adjustment for the last three years and for future years. Please
provide in workpaper format with all formulas intact and enabled. Please also include source
documents of actual revenues and expenses.
RESPONSE NO. 14:
See the attached documents for the calculations, including the general ledger download of
actual expenses, used to derive the monthly Maintenance Fee for the previous three years. The
Maintenance Fee is calculated based on the prior 12 month’s expenses and is updated annually.
Because the Maintenance Fee is determined based on the methodology of using historical costs,
the Company does not estimate a Maintenance Fee for future years.
As outlined in the original RNG Facilitation Plan case (INT-G-20-03, Page 9),
Intermountain had contracts with three producers prior to the Facilitation Plan being established.
Order No. 34693 in that case grandfathered the three existing producers in at their existing
contracts and asked the Company to update the Commission when the existing contracts conform
to the RNG Facilitation Plan (Order 34693 at 5). To date, none of the three contracts have been
revised. The three producers all paid a CIAC for their required plant, and each facility is being
billed for the actual maintenance cost for their individual facility. Because these are the only
three facilities that have been online to date, their costs are used to set the benchmark for the
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IPUC Staff PR 14
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Monthly Maintenance Fee. However, there has been no true-up since the inception of the RNG
Facilitation Plan because each facility is paying their own direct costs, meaning there is no
over/under of costs at the end of the year.
INT-G-23-03
IPUC Staff PR 14
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