20230727Reply Comments.pdf

REPLY COMMENTS PAGE 1 OF 3
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Intermountain Gas Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF
INTERMOUNTAIN GAS
COMPANY’S APPLICATION FOR
AUTHORITY TO UPDATE THE
RENEWABLE NATURAL GAS
FACILITATION PLAN
CASE NO. INT-G-23-03

INTERMOUNTAIN GAS COMPANY’S
REPLY COMMENTS
Intermountain Gas Company (“Intermountain” or “Company”) respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission Staff (“Staff”).
BACKGROUND
On June 9, 2023, Intermountain requested authorization from the Idaho Public Utilities
Commission (“Commission”) to update its Renewable Natural Gas (“RNG”) Facilitation Plan
with the following three changes: 1) introduce a Maintenance Fee for RNG producers that
require use of export facilities to physically move natural gas onto an interstate pipeline; 2)
establish a calculation methodology for the monthly Access Fee; and 3) make clear that the
Company’s Tariff Rate Schedule T-3 Interruptible Distribution Transportation Service
(“Schedule T-3”) will be applicable to the transportation of RNG on Intermountain’s distribution
system to a point of interconnection with Northwest Pipeline LLC.
RECEIVED
2023 JULY 27, 2023 3:44PM
IDAHO PUBLIC
UTILITIES COMMISSION
REPLY COMMENTS PAGE 2 OF 3
On July 26, 2023, Staff submitted its comments, recommending the Commission approve
the Company’s proposed modification as filed with the exception of the annual minimum bill
language provided in the proposed Schedule T-3.
COMPANY REPLY COMMENTS
Intermountain appreciates Staff’s analysis of the Application and the proposed
modifications to the RNG Facilitation Plan. Intermountain agrees with Staff’s recommendation
to revise the language in Schedule T-3 as set forth in Staff’s comments. The revised language
improves clarity regarding the intent of the minimum for RNG facilities.
Intermountain will submit a compliance filing of Schedule T-3, including the revised
language and most recent rates, when the final approved tariff sheets have been received from
the Company’s most recent general rate case.1
Dated: July 27, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company

1 See Case No. INT-G-22-07. The Commission has issued Order No. 35836, approving the Settlement. However, the
final approved tariff sheets have not been issued.
REPLY COMMENTS PAGE 3 OF 3
CERTIFICATE OF SERVICE
I certify that on July 27, 2023, a true and correct copy of INTERMOUNTAIN GAS
COMPANY’S REPLY COMMENTS was served upon all parties of record in this proceeding
via the manner indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Preston N. Carter