20230626Staff 1-15 to INT.pdf

DAYN HARDIE
'
-
'
DEPUTY ATTORNEY GENERAL r gy p .
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 -'
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )COMPANY'S APPLICATION FOR )CASE NO.INT-G-23-03AUTHORITYTOUPDATETHERENEWABLE)NATURAL GAS FACILITATION PLAN )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
MONDAY,JULY 10,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
I Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 JUNE 26,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please explain who will be responsible for the installation and the
cost to install the Export Facilities discussed on page 5 of the Application.In addition,please
explain how these costs will be recovered if paid for by the Company.
REQUESTNO.2:Please explain who will be responsible for the installation and the
cost to install a new interconnection between the Company's distribution system and Northwest
Pipeline discussed on page 5 of the Application.In addition,please explain how these costs will
be recovered.
REQUESTNO.3:Please describe the range of renewable natural gas ("RNG")services
and configurations that the Company would potentiallyserve under the proposed plan.For
example,would the Company provide service to an RNG producer not consuming natural gas as
a Company customer and/or provide service to a RNG producer that would be interconnectedto
Northwest pipeline without interconnecting to an existing Company distribution line?
REQUESTNO.4:Please provide system maps for each configuration identified in the
previous request identifying all infrastructure necessary to serve customers who produce RNG
for sale.In addition,please provide references of the followinginformation for each system
map:
a.Identification of dedicated infrastructure needed to transport RNG from the
facility;
b.Identification of dedicated infrastructure needed to transport gas sold to the
facility;
c.Identification of common infrastructure needed to transport RNG from and gas
sold to the facility;
d.Identification of the party who will ultimatelyown each piece of infrastructure;
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 JUNE 26,2023
e.Identification of the party responsible for installing/constructingeach piece of
infrastructure;and
f.Identification of the agencies responsible for regulating each piece or section of
infrastructure.
REQUESTNO.5:For each configuration identified in the Request No.4,please
provide a cost breakdown that separates the cost of:
a.Dedicated infrastructure needed to transport RNG from the facility;
b.Dedicated infrastructure needed to transport gas sold to the facility;and
c.Common facilities shared by both.
REQUESTNO.6:In reference to "Intermountain filing an application with the Federal
Energy Regulatory Commission ("FERC")to authorize the transportation of RNG in interstate
commerce"discussed on page 6 of the Application,please explain if this filing will subject any
of the Company's facilities to FERC jurisdiction and how the filing could impact the State of
Idaho's jurisdictional authority.
REQUESTNO.7:In reference to the proposed Export Facility MaintenanceFee
("EFMF"),please respond to the following:
a.Please provide all workpapers in electronic format with formulas enabled
including source documents of actual compressor station's Operation and
Maintenance (O&M)expenses used to determine the EFMF.
b.For the examples listed below,please explain if the applicabilityof the EFMF will
change if retail loads change in the RNG producers'distribution area.
i.Example 1:Retail loads increase in the distribution area to the point
where export facilities are not required,would the EFMF still apply to the
RNG producer?
ii.Example 2:Retail loads decrease in the distribution area to the point
where export facilities are required,would the EFMF start applying to the
RNG producer?
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 JUNE 26,2023
iii.Example 3:If an existing RNG producer decides it wants to access
interstate markets,would a new agreement be necessary and would the
EFMF be applicable if Export Facilities are required?
c.Please identify any other examples where the applicability of EFMF would
change and how it would be modified.
d.Please explain how the need for a EFMF will be monitored as retail loads change
in RNG producers'distribution areas.
REQUESTNO.8:Please explain how often the Access Fee discussed on pages 9-10 in
the Applicationwill be updated and explain the Company's process for updating the Access Fee.
REQUESTNO.9:Please explain if the Biogas Standards outlined in Exhibit 3 is
different than the standards used in the existing RNG Facilitation Plan.If Exhibit 3 is different
than the current standards,please explain the differences.
REQUESTNO.10:Please explain if the safety provisions discussed on page 12 of the
Application are different than the safety provisions used in the existing RNG Facilitation Plan.If
safety provisions are different than the current provisions,please explain the differences.
REQUESTNO.11:Please provide a copy of the current RNG Facilitation Plan along
with a redline version showing the proposed changes to the RNG Facilitation Plan.
REQUESTNO.12:In reference to Exhibit No.4 of the Application and the statement
"[a]n annual minimum bill may not apply if the customer is a renewable natural gas production
facility..."please explain under which situations an annual minimum bill would or would not
apply to RNG production facilities.Please include the justification why the annual minimum bill
applies or does not apply for each situation.
REQUESTNO.13:Please provide workpapers,with all formulas intact and enabled,
includingsource documents,used to calculate the Access Charge in Exhibit No.1 of the
Application.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 JUNE 26,2023
REQUESTNO.14:The Maintenance fee is to be updated and adjusted annuallybased
on the prior 12 month's revenue and expenses.Please provide the calculations used to derive the
updated monthly Maintenance Fee and the adjustment for the last three years and for future
years.Please provide in workpaper format with all formulas intact and enabled.Please also
include source documents of actual revenues and expenses.
REQUESTNO.15:Please provide the accounting entries for T-3 revenues and
expenses as they apply to RNG producers.
DATED at Boise,Idaho,this day of June 2023.
yn Hardie V
Deputy Att ey General
i:umise:prodreq/intg23.3dhmelg prod req l
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 5 JUNE 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF JUNE 2023,SERVEDTHEFOREGOINGFIRSTPRODUCTIONREQUESTOFTHECOMMISSIONSTAFFTOINTERMOUNTAINGASCOMPANY,IN CASE NO.INT-G-23-03,BYE-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTERDIR-REGULATORY AFFAIRS MORGAN D GOODIN
INTERMOUNTAIN GAS CO GIVENS PURSLEY LLP
PO BOX 7608 601 W BANNOCK ST
BOISE ID 83707 BOISE ID 83702E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE