20080925NIGU Comments.pdf

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NORTHWEST INDUSTRIAL GAS USERS
4113 Wolf Berry Court
Lake Oswego, OR 97035-1827 Phone: [phone]
Facsimile: [phone]
Paula E. Pyron
Executive Director E-mail: ppvron&wigu.org
September 25, 2008
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Ms. Jean D. Jewell
Commission Secretar
Idaho Public Utilities Commission
472 W. Washington
Boise,ID 83702-5983
Via Electronic Filng
RE: Application of Intermountain Gas Company for Authority to Change its Prices
(2008 Purchased Gas Cost Adjustment), Comments of the Northwest Industrial Gas
Users
Dear Ms. Jewell:
In response to the Idaho Public Utilties Commission's September 3,2008 Notice of
Modified Procedure in Order No. 30634 in the above-captioned proceeding, the Nortwest
Industrial Gas Users ("NWIGU") respectfully submits its comments for the Commission's
consideration as follows:
NWIGU is a non-profit trade association comprised of thirty-eight end-users of natural
gas with major facilities in the States of Oregon, Washington, and Idaho. NWIGU members
include diverse industrial interests, including food processing, pulp and paper, wood products,
aluminum, steel, chemicals, electronics, and aerospace. The association provides an
informational service to its members and participates in various regulatory matters that afect
member interests. NWIGU member companies purchase transportation services from Nortwest
Pipeline GP, and from TransCanada's Gas Transmission Nortwest Corporation ("GTN") either
directly or through capacity release from marketers, and purchase sales and transportation
services from local distribution companies, including Intermountain Gas Company
("Intermountain"), that acquire service from these interstate pipelines.
NWIGU appreciates this opportunity to provide comments in this proceeding and
requests that communications in reference to these comments are addressed to:
fNT-G-OB-03 Comments of the Northwest Industrial Gas Users Page 1 of 3
Paula E. Pyron
Executive Director
Northwest Industrial Gas Users
4113 Wolf Berr Cour
Lake Oswego, OR 97035-1827
Phone: [phone]
Facsimile: 503.636-0703
E-Mail: ppyron~nwigu.org
In its 2008 PGA filing, Intermountain seeks to pass through changes in gas related costs
. as appropriate to each of its customer classes, including changes in costs with upstream
pipelines, an increase in Intermountain's weighted average cost of gas ("WACOG"), an updated
customer allocation of gas related costs and the utility's deferred gas cost accounts, including a
decrease in costs biled to Intermountain and resulting refund from the settlement of the general
rate case fied by GTN.
After thorough review of Intermountain's fiing and work papers, NWIGU raised
concerns with Intermountain to reassess the accounting for those customers who were on
cancelled T -1 and T -2 service (which service was terminated August i, 2008 pursuant to
Commission Order No. 30599) to analyze what allocations of tracking accounts arise from the
historical changes in upstream charges this last year (like the GTN rate case) as distinguished
from allocations in the 2008 PGA fiing that are based on forecasted use allocations (like
anticipated revenue for 2008-09 capacity release or market segmentation credits for which T-1
and T-2 customers received their appropriate allocation in the 2007 PGA for the 2007-08 PGA
year).
NWIGU has reached agreement with Intermountain that in reviewing all appropriate
historical upstream changes (i.e., both increases and decreases in applicable upstream charges),
in the last year collectively for T -1 and T -2 customers, there is a net credit of $51 ,533 for T-2
customers (and none in allocation for T -1 customers). This calculation of a net credit is the
result of not surcharging the T-1 customers for what would otherwise be an approximate $19,000
from this reassessment of the upstream accounting, which NWIGU and Intennountain have
agreed would appear contrary to the Commission's directive in Order No. 30599 not to penalize
the T-I and T-2 customers for the schedules' elimination. Accordingly NWIGU and
Intermountain have agreed in principle to net the total ofthe upstream changes applicable
collectively to both T -1 and T -2 so that each T -2 customer taking service immediately prior to
the schedule's termination should receive its appropriate refund allocation based on each T-2
customer's respective usage last year with a direct disburement by Intennountain upon approval
of the 2008 PGA fiing and with a true-up of the $51,533 in the tracking for the 2009 PGA to all
sales customer classes at that time. While this is a small adjustment, NWIGU and Intermountain
agree that this does not require an actual change in the pending tarffs in the filed application as
the amount at issue has negligible impact on the sales customers. NWIGU believe this is a fair
resolution that is appropriate for the now terminated schedules.
INT-G-08-03 Comments of the Northwest Industrial Gas Users Page 2 of 3
Accordingly, NWIGU 'wi.shes to advise the Commission of this resolution and its SUpport
for the 2008 PGA filing with this direct disbursement oftlis small credit directly by
Intermountain to impacted T -2 customers as outlined above.
If additional issues or revisions are brought forward in this docket. NWIGU
respectfully reserves the right to make additional comments.
With. the hard copy original of this fiing, NWIGU is submitting an original and seven
copies of the Northwest Industrial Gas Users' Comments for fiing in the above-referenced case.
If you have any questions, please call me at 503.636-2580. Thank you for your assistance with
this mauer.
Very truly yours,
P?i t.,6~
Paula E. Pyron
Executive Director
Northwest Industrial Gas Users
cc Stephen R. ThoTlias (via ovemight mail)
Chad Stokes via e-mail tocstokes(êcablehuston.com
Mike McGrath via e-mail to mmcgrath(âIntgas.coni
Kris Sasser via e-mail to Kris.Sasserúùpuc.idaho.gov
Matt Elam via e-mail to Matt.Elain(ipuddaho.gov
Domi English via e-mail to Donn. cnglishúVpuc.idaho.gov
INT.G-08-03 Comments of the Northwest Industrial Gas Users Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that I served the foregoing document upon all parties of record in
this proceeding by the following methods on:
Jean Jewell (via e-mail)
Idaho Public Utilties Commission
P.O. Box 83702
472 W. Washington St.
Boise, ID 83702-5983
J ean.J ewell(fpuc.daho.gov
Kristine Sasser (via e-mail)
Deputy Attorney General
P.O. Box 83702
472 W. Washington
Boise,ID 83702-5983
Kris.Sasser(fpuc.idaho.gov
Matt Elam (via e-mail)
Engineering Section
Idaho Public Utilties Commission
P.O. Box 83702
472 W. Washington St.
Boise,ID 83702-5983
Matt. El am(fpuc. idaho .gov
Don English (via e-mail)
Accounting Deparent
Idaho Public Utilities Commission
P.O. Box 83702
472 W. Washington
Boise,ID 83702-5983
Donn.English(fpuc.idaho.gov
Michael P. McGrath (via e-mail)
Director-Gas Supply &Regulatory Affairs
Intermountain Gas Company
P.O. Box 7608
555 South Cole Road
Boise,ID 83709
Stephen R. Moffat (via overnight mail)
Moffatt, Thomas, Barnett, Rock & Fields Chtd.
P.O. Box 829
101 S. Capitol Blvd., 10th Floor
Boise,ID 83701-0829
DATED Thuray, September 25,2008"/1 r
CHAD M. STOKES, OSB No. 00400
Cable Huston Benedict Haagensen & Lloyd LLP
1001 SW Fifth Avenue, Suite 2000
Portland, OR 97204- I 136
Telephone: [phone]
Facsimile: (503) 224-3 I 75
E-mail: cstokes~cablehuston.com
On Behalf of
the Northwest Industrial Gas Users
Page I - CERTIFICATE OF SERVICE
CABLE HUSTON BENEDICT HAAGENSEN & LLOYD I.lP
1001 SW FIFTH AVENUE, SUITE 2000
PORTLAND, OREGON 97204.1136
TELEPHONE [phone]. FACSIMILE [phone]