20230906INT to Staff 2-4_6-8.pdf

RESPONSES TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Intermountain Gas Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO CHANGE ITS PRICES

Case No. INT-G-23-04

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

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the First Production Request of the Commission Staff to Intermountain Gas
Company dated August 25, 2023, submits the following responses. Confidential documents are
subject to the protective agreement in this case, and are available for download using a
password-protected link that will be provided in a separate email. The password will be provided
in a third email.
DATED: September 6, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
Wednesday, September 6, 2023 3:05:20 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I certify that on September 6, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
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-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 2:
Please provide a copy of any changes made to the policies or procedures used to identify
the amount of capacity reservations maintained by the Company since the 2022 PGA.
RESPONSE NO. 2:
The Company’s current policies and procedures around identifying the amount of firm
transportation capacity reservation commitment include, but are not limited to, the following:
•The Company uses its Integrated Resource Plan (“IRP”) process to determine the
amount of firm transportation capacity to be held by Intermountain to serve its
residential, commercial, and industrial customer base now and into the future.
Measures assessed in the IRP include, but are not limited to, the following:
o The Company’s multi-year load duration curves under both normal as well as
design weather conditions
o Customer future load growth projections
o Available firm storage capacity – both supply source storage as well as LNG
peaking storage
o Cost effective and reliable alternatives to storage such as short-term city gate
delivered gas supply availability.
In addition to the above, the Company monitors the following items when determining
the amount of firm interstate pipeline transportation capacity to hold:
•Longer term forward price predictions on the futures market from supply regions
(Alberta, British Columbia and US Rockies) and applicable price points available to
Intermountain,
•Use of long-term temporary pipeline capacity segmentations,
•Unsubscribed capacity available on Northwest Pipeline, LLC (“NWP”), Gas
Transmission Northwest (“GTN”), Foothills and/or Nova that would deliver gas
supplies on a firm basis to the Company’s service territory,
INT-G-23-04
IPUC Staff PR 2
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•Upcoming potential pipeline capacity open seasons on NWP, GTN, Foothills and/or
Nova,
•Existing pipeline shippers, if any, interested in permanently releasing their firm
transportation capacity.
INT-G-23-04
IPUC Staff PR 2
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 3:
Please provide the natural gas purchase invoices for November 2022 through June 2023,
reconciled to the PGA deferrals in the quarterly reports.
RESPONSE NO. 3:
This information was provided during the on-site audit on August 29, 2023.
INT-G-23-04
IPUC Staff PR 3
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 4:
Please provide Lost and Unaccounted for Gas amounts by year reported to Pipeline and
Hazardous Material Safety Administration (PHMSA) for the five-year period of 2019 through
2023. Include the Company’s Lost and Unaccounted for Gas amounts reported in 2019 through
2023 PGAs and explain any differences between the two.
RESPONSE NO. 4:
The percent of Lost and Unaccounted for Gas reported to PHMSA and in the PGA are
included on the attachment “PR #4 – Percent of Lost and Unaccounted for Gas”. The Company
notes that the PHMSA report for the 2023 calendar year will be filed by March 15th of 2024,
therefore, the Company provided the percent of Lost and Unaccounted for Gas reported in the
2019-2022 PHMSA reports. The Company further notes that instances of found gas were
reported as zero to PHMSA for the 2020-2021 reports.
The difference between the Lost and Unaccounted for Gas numbers reported to PHMSA
versus those reported in the PGA filing is timing. The percent of Lost and Unaccounted for Gas
in the PHMSA report covers the reporting period of July 1 – June 30 and the PGA covers
October 1 – September 30. Because of this, the PHMSA report will include the prior year
unbilled true-up adjustment performed by the Company’s accounting department and the PGA
will include the current year unbilled true-up adjustment. Further, the amount of pipeline
imbalance fluctuates from month to month and will not be the same in June, which is the ending
period in the PHMSA report, as it is in September, which is the ending period in the PGA.
INT-G-23-04
IPUC Staff PR 4
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 6:
Please provide supporting documentation for the In Person Payment fees included in this
application.
RESPONSE NO. 6:
This information was provided during the on-site audit on August 29, 2023.
INT-G-23-04
IPUC Staff PR 6
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 7:
Please provide the details of the capacity releases detailed in Work Paper No. 5.
RESPONSE NO. 7:
This information was provided during the on-site audit on August 29, 2023.
INT-G-23-04
IPUC Staff PR 7
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-04
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington
/Lori Blattner
REQUEST NO. 8:
Please provide the contracts for the Upstream Agreements.
RESPONSE NO. 8:
This information was provided during the on-site audit on August 29, 2023.
INT-G-23-04
IPUC Staff PR 8
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