20130318NWIGU Comments.pdf

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CFtD M. STOKES cswkecablehuston.com
March 18,2013
Commission Secretary Scott Madison
Idaho Public Utilities Commission Executive Vice President & General Manager
P.O. Box 83720 Intermountain Gas Company
Boise, ID 83720-0074 P0 Box 7608
Boise, ID 83707
Re: Case No. 1NT-G-13-02
Comments of the Northwest Industrial Gas Users
Dear Commissioners:
Pursuant to Order No. 32735 in the above-captioned matter, we submit these comments
on behalf of the Northwesi Industrial Gas Users ("NWIGU").
NW10U is a nonprofit association comprised of thirty-eight end-users of natural gas with
major facilities in the states of Idaho, Washington, and Oregon. NWIGU members include
diverse industrial and commercial interests, including food processing, pulp and paper, wood
products, electric generation, aluminum, steel, chemicals, electronics, aerospace, and healthcare
providers. The association provides an information service to its members and participates in
various regulatory matters that affect member interests. NWJGU member companies purchase
natural gas sales and transportation services from local distribution companies, including
Intermountain Gas.
NWIGU conditionally supports Intermountain Gas's proposal to sell surplus liquefied
natural gas ("LNG") to non-utility customers. According to Intermountain Gas, recent advances
in energy technologies and changes in the cost of natural gas have resulted in a growing market
for LNG as a vehicular fuel and for other remote applications. NWIGU acknowledged the
existence of these demand-side market conditions, but also notes a relative dearth of LNG
suppliers able to serve those demands. It is NWIGU's position that some additional competition
in this market could serve to reduce overall costs and erode some of the barriers to entry for other
suppliers.
NWIGU's support for Intermountain Gas's proposal is conditioned on the company's
commitment to hold all utility customers harmless as a result of these transactions. The
Commission should include in any order approving the proposal a requirement that
Intermountain Gas identify and track all costs associated with selling surplus LNG. The
Commission should further require Intermountain Gas to demonstrate that no customer class is
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March 18, 2013
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subsidizing in any way the service that a non-utility customer will receive through the purchase
of surplus LNG. A specific mechanism the Commission might consider is a periodic review, on
a multi-year basis, of all of the utilities' sales (and the associated costs and revenues) of surplus
LNG to non-utility customers, with an opportunity for other parties to review that information.
NWIGU appreciates having the opportunity to provide comments in the proceeding.
Very truly yours, Ae-*- ---
Chad M. Stokes