20230727Comments_1.pdf

Shell USA
West Coast Government
Relations
1121 L Street,Suite 700
Sacramento,CA 95814July27,2023
Ms.Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O.Box 83720 Boise,ID 83720-0074 RE:
Case No.INT-G-23-03
Dear Ms.Noriyuki:
Attached for consideration by this Commission is an electronic submission of Shell
USA's Support letter for the Intermountain Gas Application for Authority to
Update the Renewable Natural Gas Facilitation Plan.
If you any questions regarding this submission,please don't hesitate to contact
me at [phone]
Thank you for your consideration of our comments.
Sincerely
SteveLesher
Manager of Corporate and Government Relations
U.S.West Coast
Shell USA
Comments in support of Intermountain Gas Company application before the ldaho Public
Utilities Commission in Case No.INT-G-23-03
Steve Lesher for Shell USA
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No.INT-G-23-03IntheMatteroftheApplicationof
INTERMOUNTAIN GAS COMPANY
for Authority to Update the Renewable Natural
Gas Facilitation Plan
APPLICATION
COMMENTS OF SHELL USA IN SUPPORT OF APPLICATION
Pursuant to Rule 203 of the Rules of Procedure of the ldaho Public Utilities Commission
("Commission"),Shell USA hereby submits these comments in support of the Application for
Authority to Update Renewable Natural Gas Facilitation Plan ("Application")that Intermountain
Gas Company ("Intermountain")submitted to the Commission on June 9,2023 in the above-
captioned proceeding.Shell supports the Application because it will provide Renewable Natural
gas ("RNG)producers that interconnect with the Intermountain system an additional outlet for
the produced RNG as well as access to interstate markets for the sale of the environmental
attributes associated with RNG.Shell believes RNG is a critical energy source for multiple
states and that ldaho,with its infrastructure and concentration of dairies is in a strong position to
benefit from the production and distribution of this important fuel.
Shell agrees with Intermountain's proposal to follow FERC's blanket transportation
certificate process to secure a limited jurisdiction of interstate service by FERC under NGPA S
311 and FERC ratemaking process that uses State-approved rates for similar services.(18
C.F.R.§284.123).
The fees proposed by Intermountain will apply only to the transportation of RNG on the
Intermountain system,ensuring that existing Intermountain customers will not bear costs related
to the export of RNG from the Intermountain system.
Shell's understanding is that the methodology for the proposed Access Fee is consistent
with FERC's ROE Policy Statement in the use of average of DCF and CAPM.
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Shell supports using process outlined in modified procedures to allow for action by the
Commission without hearing.The Application contains sufficient data and information for the
Commission to approve the Application without the need to resort to a hearing.A delay in the
approval of the Application will also delay the submission and approval of the FERC blanket
certificate.Delays are economically harmful to RNG producers who require EPA certification to
obtain access to the interstate markets for the sale of the environmental attributes of the
produced RNG.
effective.
The sale of these environmental attributes make RNG production cost-
Proof of service:
THEREBY CERTIFY that I have this 27h day of July,served these comments to the ldaho PUCviaelectronicmail.
Steve Lesher on behalf of Shell USA
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