20080926Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECE\VEO
tUUB SEP 25 PM i.i 58
lOft\10 PUBUCON
UT'L\l',ÈS COMM\SS\
Street Address for Express mail
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
INTERMOUNTAIN GAS COMPANY FOR )
AUTHORITY TO CHANGE ITS PRICES (2008 )
PURCHASED GAS COST ADJUSTMENT) )
)
)
CASE NO. INT-G-08-3
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission, by and through its Attorney of
record, Kristine A. Sasser, Deputy Attorney General, in response to the Notice of Application
and Notice of Modified Procedure issued in Order No. 30634 submit the following comments.
BACKGROUND
On August 15, 2008, Intermountain Gas Company (Intermountain, Company) fied its
anual Purchased Gas Cost Adjustment (PGA) Application requesting authority to increase its
anualized revenues by $54.3 milion. Application at 2. The PGA mechanism is used to adjust
rates to reflect annual changes in Intermountain's costs for the purchase of natural gas from
suppliers - including transportation, storage, and other related costs. See Order No. 26019.
Intermountain's earnings wil not be increased as a result of the proposed changes in prices and
revenues. The Company requests that its Application be processed by Modified Procedure and
that new rates become effective October 1, 2008.
Intermountain Gas seeks to pass through to each of its customer classes a change in gas-
related costs resulting from: (1) a decrease in costs biled to Intermountain pursuant to the
STAFF COMMENTS 1 SEPTEMBER 25, 2008
Settlement of the General Rate Case fied by Gas Transmission Northwest Corporation (Gas
Transmission Northwest or GTN); (2) the procurement of discounted interstate transportation on
Northwest Pipeline GP (Northwest or Northwest Pipeline); (3) benefits included in
Intermountain's firm transportation and storage costs resulting from Intermountain's
management of its storage and firm capacity rights on pipeline systems including Northwest
Pipeline, GTN and TransCanada's BC system; (4) an increase in Intermountain's Weighted
Average Cost of Gas, or "W ACOG"; (5) an updated customer allocation of gas-related costs
pursuant to the Company's Purchased Gas Cost Adjustment provision; and (6) the inclusion of
temporar surcharges and credits for one year relating to gas and interstate transportation costs
from Intermountain's deferred gas cost accounts. Application at 3-4.
The Company calculates that, if its Application is approved, residential customers using
natural gas for space heating alone could experience an average increase of $7.90 on their
monthly bil (15% increase per therm). Residential customers using natural gas for both space
and water heating could experience an increase of $12.30 on an average monthly bil (18%
increase per therm). Commercial customers could realize a $55.30 increase in monthly billng
(18% increase per therm).
Intermountain Gas proposes to increase the W ACOG from the currently approved
$0.63583 per therm to $0.78484 per thermo Additionally, the Application states that, in an effort
to further stabilze the prices paid by customers during the upcoming winter period,
Intermountain has entered into various hedging agreements to lock-in the price for significant
portions of its underground storage and other winter "flowing" supplies. Application at 6.
STAFF ANALYSIS
Staffhas reviewed the Company's Application and gas purchases for the year to verify
that the Company's earings wil not change as a result of the filing, that the deferred costs are
prudent, and to determine the reasonableness of the W ACOG request. The table below
ilustrates the impact the proposed increase wil have on the various customer classes served by
the Company:
STAFF COMMENTS 2 SEPTEMBER 25, 2008
Proposed
Change in
Class
Revenue
5,565,294
30,333,595
17,460,213
553,740
78,842
162,140
176,433
54,330,257
*Includes both Commodity and Demand charges
Customer Class
RS-1 Residential
RS-2 Residential
GS-1 General Service
LV-1 Large Volume
T -3 Transportation
T -4 Transportation
T-5 Transportation*
Proposed
Average
Change in
$/Therm
0.16761
0.18281
0.17570
0.20782
0.00130
0.00130
0.00849
0.10709
Proposed
Average %
Change
14.85%
18.09%
18.40%
27.24%
6.60%
2.89%
35.42%
17.56%
Proposed
Average
Price
$/Therm
1.29607
1.19353
1.13050
0.97066
0.02099
0.04628
0.03246
0.71695
The overall effect of the proposed changes in the Company's Application would increase the
anual revenue received by Intermountain Gas Company by $54,330,257. This increase is
comprised of the following items:
Deferrals:
Removal ofINT-G-07-03 Temporaries
INT -G-08-03 Temporaries
Total Deferrals
Lost and Unaccounted for Gas
Re-allocation of Fixed Costs
Changes in the Weighted Average Cost of Gas
Fixed Cost Changes:
Northwest Pipeline
New Upstream Capacity Costs
LS & SGS Storage Cost Changes
AECO & Clay Basin Cost Changes
Total Fixed Cost Changes
Total Annual Price Change
$ 7,185,859
(2,121, 191)
$ 5,064,668
2,661,460
293,797
44,877,806
$ 3,446,343
(1,409,160)
(45,965)
(558,691)
$ 1,432,527
$ 54,330,257
Pursuant to Order No. 30443, The Company included temporar surcharges and credits in
PGA rates last October. The removal of the temporary credits is reflected on ExhibitNo. 4, line
26 and amounts to $7,185,859 as ilustrated above. The new temporar credits shown above
consist of three separate items: (1) A credit of approximately $9 milion in benefits generated
from releasing some pipeline transportation capacity that Intermountain is proposing to pass back
to customers; (2) an additional $8.4 milion attributable to the collection of pipeline capacity
STAFF COMMENTS 3 SEPTEMBER 25, 2008
costs, the true-up of expenses from the previous PGA case, and the refunds attributable to the
settlement of the GTN General Rate Case with the Federal Energy Regulatory Commission
(FERC); and (3) the $15.4 milion deferred balance, which is the difference from the commodity
costs that Intermountain actually paid for natural gas and the W ACOG that was included in rates
for the past year.
Weighted Average Cost of Gas (W ACOG)
In the curent Application, Intermountain Gas is proposing a W ACOG of $0.78484 per
therm, which is an increase of approximately 23.43% from the $0.63583 WACOG currently
included in the Company's rates. The curent WACOG (approved last year by Order No. 30443
in Case No. INT-G-07-03) has been in effect since October 1,2007. Although the request
reflects the first increase since 2005, the table below ilustrates the increases in the natural gas
market over the past eleven years and the volatilty experienced over the same time:
Percentage
Increase/(Decrease)
Year WACOG From Prior Year
1998 0.15684 n/a
1999 0.18252 16.37%
2000 0.28673 57.10%
2001 0.38796 35.30%
2002 0.32000 -17.52%
2003 0.47500 48.44%
2004 0.55492 16.83%
2005 0.73219 31.95%
2006 0.68500 -6.45%
2007 0.63583 -7.18%
2008 0.78484 23.43%
Intermountain has seen significant fluctuations in natual gas prices throughout the past
year. In the sumer months a number of concurent uncontrollable factors influenced prices and
market stabilty, primarily: (1) last winter's usage due to colder than normal temperatures
dropped storage levels; (2) a forecasted worse than average hurricane season caused supply
speculation; (3) higher than normal international LNG (Liquid Natural Gas) demand; (4)
Independence Hub, which typically produces about 1 BCF per day went offline for repair; (5)
STAFF COMMENTS 4 SEPTEMBER 25,2008
demand speculation caused by the completion of a Midwest flowing pipeline; and (6) industry
wide industrial demand increased by 3.7 percent in parallel with exports as the dollar devalued
relative to other curencies.
Last year's WACOG of $0.63583 per therm was based on forward gas prices for the
Company's supply sources as of the date of the Company's 2007 amended PGA filing. With
actual gas prices increasing and varing throughout the year, last year's WACOG estimates were
low compared to what Intermountain paid for gas throughout the year. The result was an under
collection of the Company's variable costs, which will be recovered by the Company over the
next twelve months through a per therm surcharge.
When reviewing the Company's forecasted natural gas prices through September 2009
and the proposed WACOG of $0.78484, Staff utilized the NYMEX Futures Index, Global
Insights Forecast, and the Energy Information Administration's (EIA) outlook. When comparing
these information sources to the forward prices indicated by Intermountain, the Company
appears slightly optimistic but has predicted reasonable estimates. The fragility of curent
economic conditions, the addition of extended pipeline east, and the near term impacts of
huricane disruptions may add upward pressure to prices. September has historically been the
peak month for huricane activity often times setting the tone for Gulf Coast production and
volatility to the market. However, Intermountain's optimism is understandable based on the
following factors: 1) production declines attributable to Gulf Coast storms are expected to only
contribute to short ru price increases; 2) growth in onshore natural gas production continues to
increase; 3) winter temperatures are forecasted to be warmer than normal; 4) industry demand by
the industrial sector is expected to decline; and 5) the Company's extensive storage allows it to
hedge prices. It is also understadable that given the curent economic conditions forecasting is
difficult as evidenced by significant variations in futue prices even among companies
specializing in natural gas predictions.
Intermountain has continued to store gas at Northwest's Plymouth LNG and Jackson
Prairie's facilties, Questar Pipeline's Clay Basin facilty and the AECO storage facility in
Alberta, Canada. The Company has the abilty to utilze 12.3% of their total storage as LNG
(Liquid Natural Gas) for design weather peaking puroses and entitlements. Entitlements occur
when the pipeline imposes stringent control of pipeline flows, leaving Intermountain with limited
supply options other than LNG. Based on Intermountain's design weather IRP (Integrated
STAFF COMMENTS 5 SEPTEMBER 25, 2008
Resource Plan) projections, liquid storage is at 48.1 % of capacity going into this winter season
which is adequate to meet the expected potential demand. Storing significantly more than what
is expected to be used in LNG during the winter season would come at an additional expense to
ratepayers because ofIntermountain's cost to maintain the LNG temperature. Although
Intermountain is able to utilze 87.7% of its total storage as underground at full storage capacity
by the end of the injection period ending October 31st, this year's underground storage
represents 93.6% of storage because LNG is being maintained below capacity. Underground
storage is tyically used for fulfillng the Company's basic core market needs. By the end of the
injection season Intermountain will have 121,120,960 therms in underground storage accounting
for roughly 51 % of the total core markets supply requirement from November 2008 to March
2009. Intermountain can avoid high winter prices by procuring gas during the summer when
prices are cheaper. In addition, Intermountain has entered into various hedging agreements to
lock-in the price for significant portions of its underground storage and other winter flowing
supplies. Intermountain has already purchased a significant amount of storage gas locking with
over $600,000 in savings from the management of these assets, therefore the resulting affect of
the Company's forward purchasing plan on the WACOG is small and any difference wil be
reconciled in customer rates next year.
Staff has also reviewed the established WACOG of other northwest gas utilities, and with
the exception ofPuget Sound Energy, the proposed WACOG for Intermountain Gas is less than
others in the region. Much of the disparity can be attributed to Intermountain's reliance on a
significant portion of its gas supply coming from Rockies. Although in the past Rockies prices
have benefited Intermountain's region due to lack of pipeline infrastrcture to move gas east, this
is beginning to change. Rockies Express (Mid-west) (a recently added pipeline infrastructure to
connect resources produced in Wyoming, Colorado and Utah with Mid-west consumers) created
upward pressure on prices based on speculative demand. Since producer supply was
dramatically increased to account for potential Mid-west demand most of the impact was offset,
and although Rockies prices never "bottomed out" like last year, the full change in prices remain
to be realized. Another planed section of pipeline expected to balance prices nationwide is the
eastern ar of Rockies Express (Rex-East), this is expected to serve some customers in the east
as early as this December with full service anticipated for June 2009.
STAFF COMMENTS 6 SEPTEMBER 25, 2008
Although current commodity futures prices support the use of a $0.78484 per therm
WACOG, the Company should remain vigilant in monitoring natual gas prices and work toward
favorably purchasing the remaining 43.4% of unlocked necessar winter flowing gas supplies.
Although 56.5% of the Company's expected winter flowing supplies have been purchased, if
forward prices for the remaining natual gas purchases materially deviate from $0.78484 per
therm, the Company should return to the Commission prior to this winter's heating season to
amend these proposed rates.
Pipeline Transportation Rate Cases
On June 30, 2006, GTN fied a general system rate case with the Federal Energy
Regulatory Commission in Docket No. RP06-407-000. The FERC suspended the effective date
ofGTN's proposed rates until January 1,2007, subject to refund and the outcome of the FERC
hearing. Intermountain's prices, as approved in Case No. INT-G-07-03, remain currently
reflective of OTN's proposed Januar 1, 2007 prices. The outcome of GTN's General Rate Case
is now final; this has resulted in FERC allowing GTN lower shipper prices than originally
proposed. This lower price first became effective November 1, 2007 and was revised effective
January 1,2008. Therefore Intermountain proposes with this Application to incorporate the
lower prices and credit customers back the amount that has been over collected.
Foothils Pipeline System ("Foothils") and its Albert system also known as Nova Gas
Transmission ("Nova"), implemented price changes durng 2008. Foothils tarff prices
decreased effective April 1, 2008 largely reflecting a settlement stemming from the bankptcy
of a shipper on the Foothils system while Nova's taiff prices increased relating to a revenue
requirement settlement with the Alberta Energy and Utilties Board. Although this capacity
remains a key component in serving customers and maintaining supply diversity, Intermountain's
capacity costs have increased on these Canadian pipelines due to the tightening exchange rate
between U.S. and Canadian curencies. As outlined in the 2008 IRP, Intermountain performed
an adequacy review of its interstate transportation and storage services forward looking under
design weather and with certain load growth assumptions. Within the pipeline capacity
component of the review, it was indicated that a need existed to procure additional Northwest
Pipeline capacity in order to more closely align deliveries from upstream pipelines with
Intermountain's take-away rights on Northwest at its Stafield interconnect with GTN. The
STAFF COMMENTS 7 SEPTEMBER 25, 2008
additional cost was approximately $3,079,646, however this is misleading since Intermountain
was able to obtain this capacity at a price equal to 85% of Northwest's maximum TF-l Rate
which generated an anual savings to Intermountain's customers of approximately $595,000.
Staff agrees with the importance of aligning upstream pipeline deliveries to its take-away rights
on Northwest at Stanfield. This is an important component for diversifying the basin supply
Intermountain counts on to provide customers the lowest possible price. As prices potentially
increase from the Rockies Express pipeline movement eastward, this could someday hedge the
abundant Canadian supply.
Recovery of Lost and Unaccounted for Gas
Intermountain Gas requests the recovery of Lost and Unaccounted for Gas (L&U)
through a per therm surcharge. The PGA surcharge request reflects L&U amounts above those
which are included in base rates as approved by the Commission in 1985. In the 2007-2008
PGA the surcharge for L&U was $1.6 millon of the total $2.5 milion. However, in the 2008-
2009 PGA the Company has requested a surcharge increase of 27%, or $2 milion above base
rates for a total L&U of$3 milion. This year the Company has alleged an increase in L&U to
.85% of throughput, a 19% increase over the 2007-2008 PGA.
Lost and unaccounted for gas is simply the difference between the physical inputs and
physical outputs of the system. The causes for unaccounted for gas can be grouped into two
main categories, primarily leaks and measurements. Leaks are defined as gas escaping from the
system at a given rate unknown on the pipeline system. These can occur from leaking valves,
pipeline ruptures, relief valve releases, and compressor rod packing leaks. Gas measurement is
defined as the accounting of all bought and sold gas, and is often times a significant source of
unaccounted for gas. Measurement error can occur in reporting or metering. Some companies
have a business process to address reporting which tracks nominations, scheduling,
measurement, flow volume allocation, biling, and financial accounting. Other companies have
measurement inaccuracies because of poor application, operation and maintenance. Although
metering errors because of temporar gas measurement device failures are inevitable, there have
been significant advances in control systems and best measurement practices for quickly
identifying these failures. Staff recognizes that the percentage of L&U gas is dependent on the
complexity of a pipeline distribution system and the flow measurement complexities involved.
STAFF COMMENTS 8 SEPTEMBER 25, 2008
However, there is some concern as to the increase of 19%, despite Intermountain's historically
reasonable loss levels.
The normalized unit cost collection as par of base rates was established as $0.00182 per
therm in 1985. However, adjusted for growth and the natural gas rate of recovery approved per
Case No. INT-G-07-03, the normalized level is $1,017,951, as ilustrated on Workpaper NO.8
included with the Company's Application. Intermountain is requesting to recover the difference
between the projected total FY08 L&U gas and the normalized level ofL&U gas revenue
already collected in current base rates. As stated above, the normalized level ofL&U already
collected is $1,017,951 while the projected FY08 amount is $3,051,984. Thus Intermountain is
requesting an additional $2,034,033. If the Company decreases its level of unaccounted for gas
during the coming PGA year, the Company wil credit the difference back to customers in next
year's PGA filing.
Staff recommends that the Commission allow the Company to recover the additional
amount for L&U gas in this PGA. However, as mentioned in the 2006 Staff Comments, "if the
system were to experience a catastrophic failure, Staff would expect the Company to fie for an
accounting order authorizing it to defer the costs of the repair and lost gas." Staff also maintains
its viewpoint that losses due to errors in faulty meters or measurement control practices should
not be recovered in the PGA. In order to evaluate these losses more closely, Staff recommends
the Commission order Intermountain to provide a quarterly report outlining the Company's
framework for how it has tested for, identified, and remediated equipment measurement errors or
leaks. Additionally, this report should outline the Company's business process for alleviating
measurement errors through its financial accounting of nominations, scheduling, measurements,
flow volume allocation, and biling. Staff also would like to meet with the Company to outline
steps that the Company is taking toward identifying the source of L&U gas and how these may
be working toward improvement. Also, because of the significant increase in L&U gas from last
year to this year, Staff recommends that the Commission place a cap on the amount recovered
for L&U gas at 0.85% ofthroughput, which is the curent level proposed for recovery in this
case. After the Company has adequately shown its practices to limit the causes of L&U gas and
the Company's approach towards reducing it, Staff would then consider recommending removal
of the imposed cap.
STAFF COMMENTS 9 SEPTEMBER 25, 2008
Risk Management and Gas Purchasing
The Company's risk management and gas purchasing strategies ensure adequate gas
supplies are available to its customers, the adverse impact of significant price movements in the
natural gas commodity is mitigated, and the credit risk inherent in the implementation of certin
price risk reducing strategies is minimized. The Company and Staff continue to evaluate the
market fundamentals and management guidelines within the "Gas Supply Risk Management
Program" to evaluate the risk of price volatility to customers. This program provides for the use
of the judgment of the Gas Management Committee in reviewing the fundamentals of the natural
gas environment and relating those to the curent and futue price expectations. In so doing, the
Committee may then decide to periodically layer in the execution of a given hedge strategy,
whether it be fixing the price of natural gas for a given time frame specific to certain supply
basins or utilizing other forms of financial pricing. The Company's documentation of these
market evaluations, along with fundamentals in hedging strategies and price management,
continues to improve.
The Company's contracts for physical gas supplies are typically based on the first-of
month index price. However, forecasting this summer's volatile price swings has been difficult.
In August, the Company contracted its Rockies gas at a first-of month price averaging $6.97 per
dekatherm. As par of the short-term hedging strategy, the Company utilzed its risk
management program to evaluate the incremental fees associated with converting the first-of-
month price to daily pricing and determined it beneficial to move on the opportunity. This
strategy, foresight, and flexibilty reduced the price customers would pay by an average price of
$1.13 per dekatherm.
As indicated by the Company's Risk Management program, Intermountain Gas does not
acquire financial hedges to obtain the lowest possible price, but rather to mitigate the volatilty in
the natural gas markets by hedging in comparson to the WACOG. During the 2007-2008 PGA
year, the Company executed numerous financial hedges by locking in specific prices for gas.
Prior hedges for the last heating season mitigated much of the volatilty. The colder than usual
spring weather along with rapid fluctuations in spot prices during the spring and summer months
caused the Company to purchase gas at prices much higher than the W ACOG currently set in
rates, which contributed substantially to the $15 milion deferral balance.
STAFF COMMENTS 10 SEPTEMBER 25, 2008
As previously mentioned, Intermountain Gas physically hedges the price of gas with its
abundance of storage capacity. Intermountain locked in the price of the gas injected into storage,
and had to make significant cash settlements. However, these cash settlements are misleading
since the benefit from those hedges wil provide price stabilty for customers when it is
withdrawn. The $7.84 per dekatherm requested in the WACOG fiing embeds an underground
storage price of $8.13 per dekatherm. However, when the storage hedges currently in place are
incorporated, that same storage W ACOG is reduced to $8.05 per dekatherm. Although the run
up in this summer's (injection season) prices impacted this WACOG, Staff understands that the
trends shown below (ilustrating the market price this past summer as being higher than the
outlook for this upcoming winter) are very unusuaL.
Intermountain's proximity to several interstate pipelines allows it to effectively allocate
its natural gas supply mix from different basins based on price differentials, and subsequently
redeliver that specified volume on its own distribution pipeline network at the lowest possible
price. Since Northwest Pipeline (a large pipeline connecting the Rockies supply basin) runs
directly through Intermountain's service territory, Intermountain is able to geographically utilze
this service more directly. Curently nearly 62% percent of the Company's gas is purchased
from the Rockies basin, leaving approximately 38% between Sumas and AECO. This diversity
of supply basins has enabled the Company to hedge expected winter flowing gas requirements at
favorably contracted prices.
CONSUMER ISSUES
Customer Notice and Press Release
The Customer Notice and Press Release were included in Intermountain's Application.
The Application was received on August 15, 2008. Staff reviewed the customer notice and press
release and determined they were in compliance with the requirements of Rule 102, Utilty
Customer Information Rules (UCIR), IDAPA 31.21.02.102. The customer notice was mailed
with cyclical bilings beginning August 15,2008 and ending September 15, 2008.
Customer Comments
Customers were given until September 25, 2008 to file comments. As of September 23,
2008, fifty-one comments had been received; all but one opposed the increase in rates. More
STAFF COMMENTS 11 SEPTEMBER 25, 2008
than one-half of the comments were from low and fixed income customers who were concerned
about being able to afford an additional 18% for natural gas rates.
Financial Assistance for Paying Heating Bils
If approved, customers wil see approximately an 18% increase in their natural gas rates.
Due to the rising cost of energy and many other basic needs, more and more customers are
finding it difficult to make ends meet. Staff encourages all qualified customers to apply for the
federally-funded Low Income Home Energy Assistace Program (LIHEAP). Bil payment
assistance is also available through organizations such as Project Share in southwestern Idaho
and Project Warmth and Helping Hand in southeastern Idaho. For more information on these
programs, customers may call the nearest Community Action Agency, Intermountain Gas
Company, the Idaho Public Utilties Commission, or the 2-1-1 Idaho Care Telephone Line.
Energy Affordabilty Workshops
Many factors are contributing to upward pressure on natural gas and electric rates. Low
and fixed income customers wil be the most negatively impacted by higher natural gas rates.
The Commission is concerned about the inabilty of many customers to pay for increased utilty
rates and the effect that eventually has on all ratepayers.
On September 8, 2008, the Commission initiated a formal generic case (GNR-U-08-01)
to examine issues surrounding energy affordability and customers' abilty to pay energy bils.
These issues will be examined at a series of scheduled workshops within the next few months.
Utilties wil be directed to participate. Staff recommends that Intermountain Gas Company
actively paricipate in these workshops and begin formulating ideas as to how residential
customers can be better served currently as well as in the future.
Low Income Weatherization
Staff also recommends that Intermountain create a low income weatherization program
for the purose of weatherizing homes of needy customers in its service territory. Monies from
Idaho Power and Rocky Mountain Power canot be used to weatherize homes that are heated by
natural gas.
STAFF COMMENTS 12 SEPTEMBER 25, 2008
RECOMMENDATION
After a complete examination of the Company's Application and gas procurements for
the year, Staff recommends that the Commission accept the Company's Application and fied
taiffs increasing the anual revenue of Intermountain Gas Company by $54,330,257 and
establishing a weighted average cost of gas at $0.78484/therm. Staff also recommends that the
Commission order Intermountain Gas Company to fie an Application with an amended
WACOG prior to this winter's heating season if gas prices materially deviate from the $0.78484
per thermo Regarding lost and unaccounted for gas, Staff recommends the Commission order
Intermountain to: (1) provide a quarterly report outlining the Company's framework for how it
has tested for, identified, and remediated equipment measurement errors or leaks; (2) provide a
quarerly report outlining the Company's business process for alleviating measurement errors
through its financial accounting of nominations, scheduling, measurements, flow volume
allocation, and biling; (3) work with Staff to outline steps towards identifying the sources of
L&U gas and work towards an improvement; (4) cap the total L&U gas at 0.85% of throughput
until the Company and Staffhave adequately evaluated the causes and approach the Company
utilzes to reduce L&U gas; (5) paricipate in the Energy Affordabilty Workshops to be
scheduled by the Commission in Case No. GNR-U-08-01; and (6) work with Staff to create low
income weatherization programs for its customers.
Respectfully submitted this 2.c: day of September 2008.
~~a.£u. tine A. Sasser
Deputy Attorney General
Technical Staff: Matt Elam
Donn English
Marilyn Parker
i: umisc:commentsintg08.3 i ksmedemp comments
STAFF COMMENTS 13 SEPTEMBER 25, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF SEPTEMBER 2008,
SERVED THE COMMENTS OF THE COMMISSION STAFF, IN CASE NO. INT-G-
08-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH / DIRECTOR
GAS SUPPLY & REG. AFFAIRS
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE ID 83707
STEPHEN R THOMAS
MOFFATT THOMAS BARRTT
ROCK & FIELDS
POBOX 829
BOISE ID 83701
\~,J(SECRET A "'
CERTIFICATE OF SERVICE