950317.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID  83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF STAR VALLEY ENERGY, INC. FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO PROVIDE NATURAL GAS SERVICE TO SALMON, IDAHO.
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CASE NO. SVE-G-95-1
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO STAR VALLEY
ENERGY, INC.
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests Star Valley Energy, Inc. (SVE; Company) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before FRIDAY, APRIL 7, 1995.
This production request is to be considered as continuing, and Star Valley Energy, Inc. is requested to provide by way of supplementary responses, additional documents that you or any person acting on your 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 name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
1.From telephone conversations between IPUC Staff and Brice Freeman of the Wyoming PSC, we understand the Company's Afton, Wyoming certificate filing was returned because of deficiencies.  Does the Company expect to refile?  If so, please supply a copy of any new certificate filing in Wyoming.  On a continuing basis please supply copies of all data, production requests and answers filed in the Wyoming Commission case.
2.Has any other company filed a certificate application for the Afton, Wyoming area?  If so, who has filed?
3.What is the estimated number of customers in Afton, Wyoming?
4.What is the estimated cost to construct and operate in Wyoming?
5.Is the $300,000 equity referred to in your Application total equity for the entire Company or is this the amount of equity for the Salmon, Idaho project?
6.What financing does Star Valley Energy, Inc. currently have in place?  Provide copies of all loan agreements and applications.  Provide details of what is being negotiated including expected time to completion, amount, restrictions, expected interest rates, expected payment schedules, etc.
7.Supply all data, workpapers, assumptions, surveys, etc. used to project customer penetration in Salmon, Idaho.  In addition supply name, phone number, and address of people contacted in connection with marketing, franchises, etc.  Supply any data or information these people supplied.
8.Show marketing breakdown between residential, commercial and light industry customers in Salmon, Idaho.  Identify commercial and light industry customers you expect to obtain in Salmon and their expected therm usage per year.
9.Explain how SVE will make residents of Salmon, Idaho aware of SVE service.  Show all marketing plans in detail.
10.Describe in detail any market incentive programs to be used.  Show how SVE intends to book, amortize and collect costs associated with the incentives if they are approved by the Idaho Public Utilities Commission.  Also provide estimated total cost of all incentives by year, amount and method of amortization and amount to be recovered from participating customers for each of the next five years.
11.Besides Afton, Wyoming and Salmon, Idaho identify other areas SVE expects to apply for certification in.  Show time line schedule for application and expected dates for approval.
12.Provide full proforma financial statements for the total Company and for Idaho specific.  Show assets, debt, equity, revenue and expenses including depreciation and taxes etc.  Show how depreciation was determined and if tax depreciation is not the same as regulated depreciation show deferred taxes.  Show how profit and overhead were determined.  Provide all workpapers and show where numbers were obtained or how they were estimated.
13.Show how common costs between Afton, Wyoming (plus any other business) and Salmon, Idaho were allocated to Idaho in the financial statements.  How was method chosen?  Supply workpapers.
14.Provide projected cash flows for the total Company and for Salmon, Idaho for 5 years.  Provide all workpapers and explain how estimates were made.
15.Provide 5 year budgets for total Company and for Salmon, Idaho.  Provide all workpapers and explain how estimates were made.  Also explain when new operations are being built (city, state, cost, financing, etc.).
16.Explain who will do customer billing in Idaho and how it will be done.
17.Explain how accounting will be done for Idaho and who will do it.
18.Provide copies (or draft copies) of any LNG supply agreements (both primary and back-up), including the terms of the agreement, costs of the LNG, annual adjustments to costs, and duration of the agreement.
19.Supply all workpapers, analyses, or other information used to compare expected LNG consumption in Salmon to other cities in the region.  Include heating degree day comparisons for each location examined.
20.Explain the expected time frame to acquire the expected 400-450 customers.  Will all of these customers be connected in the first year, or will it take several years before the distribution system's full capacity is utilized?  What penetration rate does 400-450 customers represent?  Will customers be asked to commit to interconnection prior to the Company beginning work on the system?  Is there a minimum number of customers required to insure viability of the system?
21.Provide workpapers, analyses, or other information showing how proposed residential and commercial rates have been determined.  How will these rates be influenced if either more or less than the anticipated number of customers are acquired?
22.Provide any workpapers or other analysis showing how the proposed residential and commercial rates compare to costs of other common energy sources such as propane, heating oil, and electricity for space or water heating in Salmon.
23.Provide a list of local vendors for gas appliances and heating equipment.
24.Describe how annual price adjustments for LNG supplies to the Company will be passed on to customers.
25.Provide copies of any contracts with LNG transport companies.  Discuss the size of the transport companies' fleets, and the frequency with which trucks can be dispatched for LNG deliveries, especially in critical winter periods.  Discuss contingency plans in the event transport service is not available when needed from either of the two transport companies described in the Application.
26.List all state, local, or other permits required for construction, storage, operation, or fuel transportation.  Discuss the status of each required permit.
27.Explain how LNG will be supplied to customers in the event of emergency, unscheduled, and scheduled maintenance and repair of equipment and facilities.
28.Discuss whether any LNG will be lost in storage or consumed on-site for compression, refrigeration, vaporization, or other purposes.
29.Discuss what recourse interconnected customers will have in the event the Company permanently discontinues its operation for any reason, especially if this were to occur during the heating season.
30.Describe any utility experience the Company or its employees have, either with this or any other type of utility plant.
31.Provide copies of proposed tariffs.
32.Describe the Company's line extension policy (or include it with the proposed tariffs).
33.Provide maps showing proposed locations of all storage, distribution and other project facilities.
34.Provide a curtailment plan as required by I.C. § 61-531 et. seq.
DATED  at Boise, Idaho, this              day of March,  1995.
______________________________________
Scott Woodbury
Deputy Attorney General
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