20180502Comments.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
P.ECEIVED
ifilB iiirY -2 Plt 2: lr I
In: ric ilJBLlcjrl : a;.-i C;LihilSSiON
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO IMPLEMENT AN
INFRASTRUCTURE INTEGRITY
MANAGEMENT MECHANISM
CASE NO. INT.G.I7.O7
COMMENTS OF THE
COMMISSION STAFF
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COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Sean Costello, Deputy Attorney General, and in response to the Notice of
Modified Procedure issued in Order No. 34008 on March 14,2018, in Case No. INT-G-17-07,
submits the following comments.
BACKGROUND
On December 18, 20lT,Intermountain Gas Company applied for authority to implement
an Infrastructure Integrity Management Mechanism (IIMM). The Application included the
Company's proposed rate schedule and asked that the Commission process the case by Modified
Procedure.
The Company asserts the IIMM is a cost recovery mechanism designed to allow the
Company to accelerate the replacement of aging infrastructure, to mitigate the increasing impact
of regulation on the Company's capital and operations and maintenance (O&M) budgets, and to
ISTAFF COMMENTS MAY 2,2018
more proactively address safety issues on its system. Application at 3. The Company believes
the IIMM is "an integral part of its mission to provide safe and reliable natural gas service." 1d
According to the Company, state utility commissions across the country have granted
approval to "gas utility companies to implement some form of integrity management and
infrastructure replacement programs," the common feature of which is safe and reliable service.
Id. at 4. Likewise, the Company is committed to safe and reliable service, and works to
proactively identify and remove risks to its system. 1d.
The Company describes its programs to proactively remove and replace pipe that has a
risk of failure. Id. The Company uses relative risk models to manage and assess the risk of
failures based on age, material, operating pressure, damage history, and other considerations, and
based on the outputs, the Company prioritizes infrastructure replacement projects within its total
capital investment demands. Id. The Company states it would like to accelerate replacement
projects, but budget limitations "often only allow the Company to maintain a more modest
replacement schedule." The Company anticipates the proposed IIMM will enable it to accelerate
the replacement programs and "stay ahead of schedule." Id. As an example, the Company
discusses its program to replace Aldyl-A pipe. Id. at 5.
The Company explains it must make certain capital investments to satisfy federal, state,
and local requirements, and sometimes must increase O&M spending and add personnel for
safety initiatives. Id. The Company asserts this capital and O&M spending can "challenge [its]
financial situation as [it does] not provide the necessary supporting revenues." Id. The
Company provides examples of projects that "contribute to budgetary constraints and compete
with other necessary capital investment projects," such as a proposed rule which would require
the use of automatic and remote controlled shutoff valves on transmission lines, and the
Company's hiring of additional employees to help comply with federal and state laws. 1d The
Company states that including these capital projects in the IIMM would "give the Company
more flexibility to concurrently pursue these pipeline related capital investments while also
implementing other necessary capital expenditures." Id.
The Company explains the IIMM would not include capital investment associated with
incremental growth on the Company's system, and the rate base and expenses embedded in the
Commission-approved IIMM charge would switch from the IIMM to general base rates through
future general rate cases. Id. at6.
2STAFF COMMENTS MAY 2,20t8
The Company explains how the proposed IIMM would work. Specifically, the Company
would consult the Commission's Pipeline Safety Division about the projects and expenses the
Company seeks to recover through the IIMM. Id. at7-8. The Company would then propose an
IIMM revenue requirement for allocation to each rate class based on the allocation of base rate
revenues from the Company's most recent general rate case. Id. The IIMM charge would equal
the allocated IIMM revenue requirement divided by normalized volumes from the Company's
Purchased Gas Adjustment (PGA). Id. Each year in May, the Company would ask the
Commission to update the IIMM charge, with the new prices to take effect October l. Id. The
Company provides examples of how it would calculate the above components. See id. Exhibit2.
The Commission issued a Notice of Application and set a deadline for petitions to
intervene. Order No. 33959. The Commission granted the Alliance of Westem Energy
Consumers' (AWEC)I petition to intervene. Order No. 33981.
STAFF REVIEW
Staff analyzed the Company's Application and recommends the Commission deny the
Company's request for an IIMM. While Staff supports the Company's work to maintain safe
and reliable service by replacing Aldyl-A pipe and upgrading other infrastructure, Staff
concludes that these costs are more appropriately established and recovered through traditional
ratemaking in general rate cases rather than through an annual cost recovery mechanism as
proposed by the Company. Further, the costs that the Company proposes to fund through the
IIMM are different from the costs the Commission has approved for recovery in other annual
adjustment mechanisms: these costs are not unpredictable or volatile, they do not remove the
disincentive for energy efficiency, they are within the Company's ability to plan and manage,
they do not present an urgent, immediate need for replacement (due to the absence of cast iron
and unprotected steel pipes, as discussed further below). To the contrary, these types of known,
predictable capital expenditures can be included for recovery in a general rate case, and the
Company has the financial ability and access to capital to fund these projects between rate cases.
I Formerly Northwest Industrial Gas Users (NWIGU). NWIGU merged with the Industrial Customers of Northwest
Utilities, which then changed its name to AWEC.
aJSTAFF COMMENTS MAY 2,2078
Staffs Review of the Need for the IIMM
Infrastructure Costs Should be Recovered in General Rate Coses
Staff does not believe that an annual adjustment mechanism is the proper recovery
method for large infrastructure projects. Staff believes that prudency and recovery of
infrastructure costs are best addressed through traditional ratemaking in a general rate case where
all expenses, rate base, and impacts on the Company's return on equity can be examined. In
addition, annual adjustment mechanisms lessen the incentive for utilities to control costs.
Other utilities in Idaho have successfully used rate cases to seek recovery for
infrastructure replacement similar to the projects Intermountain discusses in this case. Avista has
been replacing its Aldyl-A pipe for several years and has not proposed an annual adjustment
mechanism to recover those costs. Instead, Avista files regular rate cases to fund this ongoing
project. See Case Nos. AVU-G-12-07, AVU-G-I7-01. Staff supports this method of cost
recovery and does not believe it has harmed Avista's financial viability.
The Commission has never approved an open-ended, ongoing, annual cost recovery
mechanism for infrastructure upgrade projects similar to what Intermountain has requested in
this case. Because the Company has only filed one general rate case in the last 30 years, Staff
does not believe an inability to recover costs is an adequate explanation for the IIMM need. The
Company could file a rate case sooner. Staff also does not believe the IIMM should be adopted
to further discourage rate case filings. Greater familiarity with the Company's operational and
accounting practices is needed before recommending approval of an unprecedented mechanism
of this magnitude.
Volatility and Predictability of Costs
One reason for implementing an annual cost adjustment mechanism is that expenses are
both volatile and highly unpredictable. Staff reviewed the types of project expenses that the
Company proposes to recover through the IIMM and does not believe that any of these costs are
significantly unpredictable or variable that an adjustment mechanism is justified.
Unpredictable and volatile costs create an issue in traditional ratemaking when actual
costs vary significantly from the revenue requirement embedded in base rates. Power and gas
supply costs are a good example. Idaho Power requested the implementation of its Power Cost
4STAFF COMMENTS MAY 2,2018
Adjustment (PCA)2 after Idaho Power had previously been granted approval for two emergency
surcharges to meet volatile and unpredictable power supply costs in drought years.3 The
Commission agreed that the circumstances warranted an annual adjustment and wrote:
We find that the current system of normalizing power supply costs and
granting Idaho Power a surcharge during drought years is defective because
it is unpredictable...Presently, Idaho Power must take the initiative to seek a
drought related surcharge when it believes its financial condition has
deteriorated to the point where additional rate relief is critical.
Order No. 24806 at 5. The Commission emphasized "that our decision [to adopt a PCA]
is limited to the unique circumstances of Idaho Power's highly variable power supply costs." 1d
Thus, a driver for the Commission's adoption of Idaho Power's PCA was the highly
unpredictable and volatile nature of power supply costs and the resulting financial impact on the
Company impeding the utility's opportunity to earn a fair return. Id.
The Commission has since adopted annual power and/or gas supply adjustment
mechanisms for Rocky Mountain Power (PacifiCorp), Avista, and Intermountain Gas based on
the same combination of predictability and cost volatility. Intermountain Gas' Purchased Gas
Adjustment (PGA) was adopted, in part, because the Commission recognized that natural gas
wholesale prices fluctuate frequently. See Order No. 22058. Natural gas wholesale prices make
up7l.4Yo of the Company's total annual expenses. See Case No. INT-G-16-02.
Intermountain has not shown that the projects and expenses it proposes to recover
through the IIMM will be unpredictable or volatile. Rather, the expenses appear to be fairly
predictable and stable. One of the major costs the Company has identified for recovery through
the IIMM is Aldyl-A pipe replacement. The Company has provided the miles of pipe that will
need to be replaced by timeframe and vintage and is able to provide an average cost per foot
(based on 201 5 and 2016 historical costs) so that a total cost per year can be estimated. From its
recent experience replacing Aldyl-A pipe, the Company can predict the cost for replacing the
pipe with reasonable accuracy. See Intermountain Gas Company's Response to the First
Production Request of Commission Staff Nos. 5, 17, and24 (attached hereto as Attachment A).
There may be small variations associated with inflation of pipe and labor costs, but this variation
is not large enough to justify a cost recovery mechanism.
2 Case No. IPC-E-92-25
3 Case Nos. IPC-E-88-22 and IPC-E-92-10
5STAFF COMMENTS MAY 2,2018
Removing the Disincentive for Energy Efficiency
Another reason for implementing an annual adjustment mechanism is that the Company's
financial position is harmed by pursuing cost-effective energy efficiency. Because large scale,
Company-sponsored energy efficiency can reduce the volumetric sales needed to recover the
fixed costs of providing service, the Commission adopted the Fixed Cost Adjustment (FCA) for
Idaho Power and Avista to ensure that acquiring cost-effective energy efficiency does not
financially harm those utilities.
The FCA is only used to recover costs that were established in a rate case (the fixed cost
per customer). It provides a true-up of the actual collection of fixed costs per customer
compared to what was assumed in base rates. See Order No. 33527 at2. It is not used for
infrastructure replacement and upgrades costs.
Intermountain has launched a small residential energy efficiency program, but it is not yet
impacting sales in any meaningful way. The IIMM proposed by the Company is an annual
adjustment mechanism that would recover costs that are not evaluated in a rate case and that are
unrelated to energy efficiency.
Ability to Plan and Manage the Expenses
Staff also considered whether the type of costs proposed for recovery in the IIMM can be
managed through its planning process. Staff reviewed the projects and types of expenses the
Company plans to implement in the next five years and believes the Company has a significant
amount of control over the timing of these expenses. Staff believes the IIMM is unnecessary
because most of these expenses are project costs which the Company can manage through its
planning process.
One example of an expense that the Company cannot plan and control is the price of
natural gas. This lack of control is one reason justifying the Company's PGA. See Order No.
22058 (acknowledging that natural gas prices change frequently). Conversely, the costs
proposed for recovery in the IIMM can be planned and managed by the Company throughout the
course of the project. Within the next five years, the Company plans to replace Aldyl-A pipe and
to remove High-Pressure Service Sets (HPSS) as part of their infrastructure replacement
program. The Company can decide when to incur project expenses and cost of the projects
through their budgeting and infrastructure integrity processes. This gives the Company a
6STAFF COMMENTS MAY 2,2018
significant amount of flexibility to adjust its project plans and to incur costs as its budget for
each year allows.
A predictable capital expense which the Company can manage over time is ideal for
recovery through traditional ratemaking in a general rate case. Rates established in general rate
cases have a long history of successfully providing utilities adequate recovery of these types of
infrastructure costs.
Ur gency of Infrastructur e Replacement
The Company claims that the IIMM is needed to fund critical safety and reliability
concerns on its system including Aldyl-A pipe and HPSS replacement. It also claims that 42
states have implemented some form of integrity and infrastructure program. While this may be
true, Staffls research found that the most urgent infrastructure projects nationwide are
replacement of cast iron and unprotected steel pipes, rather than replacement of Aldyl-A pipes.
A2017 U.S. Department of Energy (DOE) report on natural gas infrastructure at local
distribution companies states "While the vast majority of the LDC system is plastic and coated
steel pipe, the cast iron and unprotected steel pipe are generally older, more prone to leaks, and
are the primary focus of pipe replacement programs aiming to improve the safety and reliability
of local distribution systems." 4 The plastic of Aldyl-A pipes tends to be flexible and less
susceptible to rupture unless disturbed. However, cast iron and unprotected steel pipes are much
more likely to crack and present a safety hazard.
In response to Staff discovery, the Company confirmed that there is no cast iron or
unprotected steel pipe in its system. See Intermountain Gas Company's Response to the First
Production Request of Commission Staff No. 3l (attached hereto as Attachment B). This
response is consistent with the DOE report which shows that there is limited to no cast iron or
unprotected steel pipe in Idaho.s In addition, Staff notes that Intermountain has some of the
lowest lost and unaccounted for natural gas rates in the nation. Staff agrees that the Aldyl-A pipe
should be replaced, but the low leak rates and resistance to rupture make it a much less urgent
safety issue than replacing cast iron or unprotected steel pipe.
a U.S. Department of Energy, 2017, "Natural Gas Infrastructure Modernization Program at Local Distribution
Companies: Key lssues and Considerations" at 9.
s U.S. Department of Energy at23.
7STAFF COMMENTS MAY 2,2018
Staff believes that natural gas utilities with significant amounts of cast iron pipe,
unprotected steel pipe, or natural gas leaks could warrant an infrastructure cost recovery
mechanism. However, the absence of those circumstances for Intermountain eliminates the
primary need of an annual adjustment mechanism. Staff believes the IIMM is unnecessary here
and that the Company is well positioned to request infrastructure recovery in regular rate cases.
Company's Financial Position
If the Company did not have other means to finance infrastructure improvements, a
mechanism like the proposed IIMM might be necessary to maintain the financial viability of the
Company. The Company did not show that it does not have the ability to finance these projects.
The Company has three sources of funding for capital projects. The first is internally generated
funds, such as depreciation or net income. The second source is from investors. Generally a
company would sell shares of stock to receive those funds, but since the Company is a wholly
owned subsidiary, the Company would instead request additional funds from its parent company
The third source is by issuing debt. Staff believes the Company has the resources available to
fund the infrastructure replacements projects it is proposing in this case and will be able to
request recovery ofthese costs in general rate cases.
Review of Prudency of Replacement Costs
In its Application, the Company proposed meeting with the Commission's Pipeline
Safety Staff to determine which projects would be considered for recovery in the IIMM:
The Company proposes that at regular intervals during the year, the Company and
the Pipeline Safety Division convene an "IMM Project Review Meeting" to review
and agree upon IIMM projects and O&M expenses that would qualify for
consideration and recovery in the IIMM. The Company will present IIMM projects
and O&M expenses identified by its [Transmission Integrity Management Program
(TIMP) and Distribution Integrity Management Program (DIMP)I as well as other
IIMM projects and [Operations and Maintenance (O&M)] expenses identified as a
result of federal, state or local regulations. The Pipeline Safety Division may also
present for discussion and analysis any IIMM projects and O&M expenses that
result from its analysis of the Company's distribution system.
Id at7. The Commission's Pipeline Safety Division conducts TIMP and DIMP audits
and inspects field-installed equipment on all intrastate natural gas pipeline operators
under the Commission's jurisdiction. Staff understands that the Pipeline Safety Staff
STAFF COMMENTS MAY 2,20t88
reviews the Company's Transmission Integrity Management Plan (TIMP) and
Distribution Integrity Management Plan (DIMP) and can require modifications or
additions to the plans, to be in compliance with Pipeline and Hazardous Materials Safety
Administration (PHMSA) rules and re gulations.
As part of the Company's responsibility to support its requests for cost recovery, Staff
expects that the Company will provide all information responsive to discovery requests issued to
it, rather than refer to (but not provide) information previously provided to Pipeline Safety Staff.
Meetings between the Company and Pipeline Safety Staff are not the appropriate method or
forum for determining if and at what value projects would qualify for cost recovery.
In a general rate case, the Company's request for cost recovery would appropriately be
evaluated by Commission Staff, other intervenors, the Company's customers, and ultimately, the
Commission.
Proposed Tariff
Staff reviewed the proposed Rate Schedule IIMM submitted as Exhibit No. I of the
Company's Application. Staff is concerned that the proposed rate schedule is too technical for
most customers to understand. If the Commission approves the Company's Application, Staff
recommends the Commission order the Company to work with Staff to revise the proposed
schedule to create a concise customer-facing document that clearly describes the purpose and
calculation of the IIMM charge.
Customer Notice and Comments
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure (IDAPA 31.01.01). The notice was included with customer
bills. The Company began mailing the customer notices on December 20,2017, with the last
notices mailed to customers on January 23,2018. As of May 2,2018, the Commission has
received four comments from members of the public, who were all opposed to the Company's
proposed IIMM.
9STAFF COMMENTS MAY 2,2018
STAFF RECOMMENDATIONS
Staff does not believe that the IIMM is justified in this case because the Company has not
shown that the costs are unique in a way that requires them to be addressed outside of traditional
ratemaking in a general rate case. These costs are not volatile, unpredictable, related to the
acquisition of energy efficiency, outside of the Company's ability to manage, or urgent enough
to warrant an annual adjustment mechanism. Furthermore, the Company has the financial
strength and access to capital to fund infrastructure improvements between rate cases.
Therefore, Staff recommends that the Commission deny the Company's request for an IIMM.
Respectfully submitted this z lJ
day of May 2018.
Sean Costello
Deputy Attorney General
Technical Staff: Joseph Terry
Kevin Keyt
Michael Eldred
i:umisc/comments/intg I 7. Tsckskjtjldeme comments
STAFF COMMENTS l0 MAY 2,2018
-l- c o,ffi
REQUEST NO. 5: Please provide back-up documentation for the Company's estimation
that it would cost ",.. approximately $158.4 million to replace all of this Aldyl-A pipe."
Application, p. 5,
RESPONSE TO REQUEST NO. 5:
The S I 58.4 million cost was derived using the octual overage cost of $50 per foot o/'pre-
I 9Ba Aldyl A pipe replaced in 201 5 and 201 6 multiplied by the estimated 600 miles of remoining
pipe in the system at thal time. T'he current number of miles o/'pre-1981 Aldyl A pipe scheduledfor
Page 4
Attachment A
Case No. INT-G-17-07
Staff Comments
05102118 Page I of 7
ICC RESPONSIi'rO FIRST REQUEST [.OR PRODTJC'I'ION
2015
District Footage Installed Actual Cost
AveraLe Cpst Per
Foot
Capital 12,542 $666,567 $s3.1 5
Owyhee 3,644 s227,536 $62,44
Skyline 3,090 $266,793 $86.34
Teton 7,1 50 $197,604 $27.64
Sawooth 3.046 $ 140,436 $46. I 1
29,472 s|,498,926 $50.86
2016
District Footagc Installed Actual Cost
Averase Qost Per
Foot
Capital 14,309 $747,927 $52.27
Owyhee 5,466 s326,338 s59.70
Skyline 3,910 $308,381 $78.87'feton 13,371 $516,425 $38.62
Sawtooth 7,034 $279,088 $39.68
44,090 s2,1 78, I 59 $49.40
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
555 S Cole Rd^ Boise. ID 83707
Crais Chapin 20 8-377 -6142
Attachment A
Case No. INT-G- 17-07
Staff Comments
05102118 Page 2 of 7
replacement is now 580 miles based on pipe replaced thru 20t7. The tables below show the
derivation of the average $50 per/bot co,st of replaced Aldyl A pipe in 2015 anrl 2016.
REQUEST NO. 17: Please describe in terms of material, number of miles, size, and age
each type of pipe in the Company's system that will require replacement within the next five years.
lnclude why it needs replacing, when it needs to be replaced, and at what cost.
RESPONSE TO REQUEST NO. 17:
Pre-1984 Aldyl A pipe is the only pipe required to be replaced in the nextfive years due to a
potential susceptibility to brittle-like cracking. Additional information on lhe pre-1984 vintage
Aldyt A pipe recornmendedfor replacement can be.fitund in the 728-page white paper by the
American Gqs Association titled " lnformation About Aldyl A Piping, " as described in the respanse
to Request No. 26. Aldyl A pipe is a mediunt density polyethylene material ranging in pipe size
.from %" to 1". Approximately 580 mites oJ'pre-1984 Atdyl A pipe remain in the rJistriburion system
Page l0
Attachment A
Case No. INT-G-17-07
staff comments
05102118 Page 3 of 7
ICC RESPONSE TO FIRS'T REQUI]S1'T'OR PRODUCI'ION
and it is fiscally and operalionally impractical to replace all 580 miles in,five years. The age of
Aldyl A pipe ronges from approximately 24-50 years. lnstallations began in 1968 and slarted to
phose out in 1994. The opproximate replacemenl cost per /bot is eslimated at $50, as desribed in
the response to Request No. 5. Inlermounlain is proposing a l0-15 yeor timeframefor replacemenl
of pre-1981 Aldyl Apipe, as explainedinthe response lo Request No, 24 below.
Record l{older: Mike McGrath 377 -6004
Location:555 S Cole Rd. Boise" tD 83707
Sponsor/Preparer:Crai s Chapin 208:37? -61 42
Attachment A
Case No. INT-G-17-07
Staff Comments
05102/18 Page 4 of 7
REQUEST NO. 24: Application at 5 - I'he Company states that it would like to accelerate
the replacement of Aldyl-A pipe.
(a) Please describe the Company's desired "accelerated" schedule for replacement of
Aldyl-A pipe including timing, costs, and benefits.
(b) Please provide the Company's procedures/ruleslregulations for handling of
Aldyl-A pipe.
RESPONSE TO REQUEST NO. 24:
(a) Based on lhe Company's l"llulP and DIMP risk models, the Company's Aldyl A
replacement program is currently projected to span 100 years, wilh 5-7 miles of
pipe replaced per year.
'l'he desirecl replacement schedule d'the Aldyl A pipe is I 0- I 5 years at a cost of
$ l0-81 5 million per year, hased on lhe currently estimqled $50 per foot, as
described in the response to Request No. 5.
Page l7
Attachment A
Case No. INT-G- l7-07
Staff Comments
05/02118 Page 5 of 7
ICC RESPONSE TO FIRST REQUEST FOR PRODUCTION
BeneJits include:
l. Reduced risk crssociated with potential hazardous lealds,
2. Reduced risk of potentiol major incidents resulting in bodily injury, loss
o./'life, and property damage, and
3. Improved long-term reliahility of service.
ft) lntermountuin's DIMP progrdm is the primary.federal regulation thal drives lhe
way the Company handles Aldyl A. Additionally, there are other advisories,
indusfry sludies and recommended praclices outlined in the AGA reporl litled
" lnformalion About Aldyl A Ptping, " which is provided in the response to
Request No. 26.
Regarding lhe physiccrl handling of Aldyl A, lntermountain handles it the same as
other plaslic pipe in the system. There are a.feu, special considerotions when
field employees encounrer Aldyl A. Early vintage Aldyl A service punch tees
6Pry are ,tusceptible to leaking. When service tee connections are exposed
during mainlenance activity, lhe section of moin u,here lhe SPT is located is
replaced or in some cases, an over-cap repair kit is installed on the SPT. The
following procedure is required on all plastic pipe, however; the requirement
was implemenled to avoid cracking of Aldyl A pipe. "Any pinch o.fflocation on
plastic pipe shall be marked with either a black permanent marker or black
electrical tape at the squeezed portion oJ the pipe to prevent additional pinch o.ffs
in lhul location."
Page l8
Attachment A
Case No. INT-G-17-07
staff comments
05102118 Page 6 of 7
IGC RESPONSE'fO I.-IRSl' REQUEST FOR PRODUCI'ION
Record Holder:
Location:
Sponsor/Preparcr:
Mike McG rath 208-37 7-6000
555 S Cole Rd.ID 83707
Craig Chapin & LanceEboy 208-377-6142 & 208-377-6122
Attachment A
Case No. INT-G-17-07
Staff Comments
O5l02ll8 PageT of 7
There are no bare steel or casl iron pipes in the Company's dislribution system.
Record I{older: Mike McGrath 208-377-6000
Location:555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer:Crais Chanin 2 77-6142
Attachment B
Case No. INT-G-17-07
Staff Comments
0st02118
REQUEST NO.31: Please describe all bare steel and cast iron pipe in the Company's
system including size, total length, and age.
nESPONSE TO REQUEST NO. 31:
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF MAY 2018, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. INT-G-17-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
JONATHAN J CAVANAGH
CHAD M STOKES
CABLE HUSTON LLP
1OO1 SW 5TH AVE STE 2OOO
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
EDWARD FTNKLEA
DIRECTOR OF NATURAL GAS
ALLIANCE OF WESTERN ENERGY
CONUMSERS
545 GRANDVIEW DR
ASHLAND OR 97520
E-MAIL: [e-mail]
,Lnz^
-
SECRETARY//
CERTIFICATE OF SERVICE