20150728Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF QUESTAR GAS )
COMPANY'S PETITION TO CLARIFY ITS ) CASE NO. QST-G-15-01
SERVICE TERRITORY BOUNDARIES )) COMMENTS OF THE
) COMMISSION STAFF
)
The Staff of the Idaho Public Utilities Commission comments as follows on Questar Gas
Company's Application.
BACKGROUND
On June 22,2015, Questar Gas Company petitioned the Commission for an Order
clarifying that its certificated service area boundaries include all of Franklin County, Idaho.
Questar's Petition explains that, in 1990, Questar's predecessor, Mountain Fuel Supply
Company, applied to the Commission for an Order allowing Mountain Fuel Supply to provide
"natural gas service to communities in Franklin County, the town of Franklin, the city of Preston,
and other communities in the vicinity of the proposed extension where service is determined to
be economically feasible." Petition at l-2. Questar explains that the Commission ultimately
granted Mountain Fuel Company's request and issued Certificate No. 315, which requires
Mountain Fuel Company and its successors to provide natural gas service "in the southeast Idaho
County of Franklin and the Franklin County cities of Franklin and Preston. . . ." Id. at2, quoting
STAFF COMMENTS JULY 28,2015
Order No. 23282 at 6, and Certificate No. 315. Mountain Fuel Company and its successor,
Questar, have served the cities of Preston and Franklin since that time. Id. at l-2.
Questar's Petition states that entities in Dayton, another city in Franklin County, have
recently approached Questar about providing natural gas service in the Dayton area. Questar
believes Certificate No. 315 authorizes it to serve all of Franklin County, including the city of
Dayton. However, Questar would like the Commission to issue an Order clarifying that fact. Id.
at2-3.
STAFF ANALYSIS
Staff reviewed the Company's Petition and exhibits, Commission Order No. 23282, and
Certificate No. 315. Staff also reviewed the First Amendment to Certificate No. 315, Case No.
QST-G-01-1, which changed the name of the certificate holder from Mountain Fuel Supply
Company to Questar Gas Company. Staff notes that, besides changing the certificate holder's
name, the amended Certificate refers to the service area as the "southeastern portion of Franklin
County" rather than the "Southeast Idaho county of Franklin," as specified in the original
Certificate. Staff is unclear why the First Amendment to Certificate No. 315 changed the service
area description; the case ostensibly involved only a name change. However, because both the
original Certificate No. 3 l5 and the First Amendment to Certificate No. 315 specifically
reference Order No. 23282, which describes the service area as "the southeast Idaho County of
Franklin" (Id. at 6), Staff suspects the change in the service area description may have been
inadvertent.
Staff believes the service area is accurately described in Order No. 23282 and original
Certificate No. 315 and includes all of Franklin County. However, because both Certificate No.
315 and the First Amendment to Certificate No. 315 reference the cities of Franklin and Preston,
and because the First Amended Certificate No. 315 introduces some ambiguity into the service
area description, Staff recommends that the Commission issue a Second Amendment to
Certificate No. 315 that clarifies the service territory boundaries as requested by Questar.
References to the Southeastern portion of Franklin County and the cities of Franklin and Preston
should be deleted.
STAFF COMMENTS JULY 28,2015
As stated in Order No.23282:
As previously represented by the Commission in its letter to FERC, construction
and extension of facilities into the proposed service area will enable Mountain
Fuel to serve what is, to date, an unsatisfied market demand for natural gas sales
and transportation. As represented by Mountain Fuel, natural gas service is not
now rendered in the proposed service area. We therefore find that operation of
the proposed distribution system will not compete or interfere with any other
person rendering natural gas service or with the operation of any other natural gas
public utility.
Here, Questar is not seeking to expand its original service territory but merely to clarify
that the original territory includes all of Franklin County. Staff continues to believe that
allowing Questar to serve all of Franklin County will not conflict with any other utility
providing natural gas service in Idaho.
In the Petition, Questar stated that: "Recently, entities in Dayton, Idaho, a community in
Franklin County, have approached Questar Gas seeking extension of natural gas service to the
area." Consistent with the Commission Order No. 23282, Staff believes the availability of
natural gas significantly enhances the economy of southeastern Idaho. Questar has advised Staff
that any service supplied to Dayton would be done under tariff line extension provisions 9.03
(MAIN EXTENSIONS - COMPANY INSTALLED) and 9.04 (SERVICE LINE EXTENSIONS
- COMPANY INSTALLED) described in Questar Gas Company's Utah Natural Gas Tariff
PSCU 400. Staff reviewed the tariff provisions and determined that using the line extension
provisions would not impact existing Idaho Questar customers. Nevertheless, if Questar and the
city of Dayton pursue implementation of gas service, Staff requests copies of all documentation
filed with the Utah Public Service Commission (Utah) for the permitting, construction and
operation of the system also be filed with the Idaho Commission. Further, if there are requested
or anticipated future line extensions that do not fit under the extension tariff, a cost/benefit study
and recovery mechanism (i.e., surcharge) must be provided to the Idaho Commission.
STAFF CONCLUSION AND RECOMMENDATION
Staff recommends the Commission find it is in the public interest to modifi, the
Certif,rcate to clearly specify all of Franklin County as the service area. References to the
Southeastern portion of Franklin County, and the cities of Franklin and Preston should be
STAFF COMMENTS JULY 28,2015
omitted. The proposed modification supports Questar providing services throughout Franklin
County and recognizes the city of Dayton's recent inquiries about service in the city. If Questar
and the city of Dayton pursue implementation of gas service, Staff requests copies of all
documentation filed with Utah for the permitting, construction and operation of the system also
be filed with the Idaho Commission. Staff also recommends that if Questar extends service into
an area such that a surcharge rate filing is required with Utah, that the same information filed
with Utah be filed with the Commission. This would include (but not be limited to) the
calculation of the surcharge, the underlying workpapers documenting the components of the
surcharge calculation, and the cost-benefit analysis demonstrating the feasibility of the service.
Respecttully submitted this Z 511 day of July 2015.
Technical Staff: Patricia Harms
Matt Elam
Kevin Keyt
i:umisc/comments/qstgl 5. I kkphmeksk comments
1/f I ft
Karl T. Klein
Deputy Attomey General
STAFF COMMENTS JULY 28,2015
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF ruLY 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAF'tr', IN
CASE NO. QST-G-15-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
JENNIFFER NELSON CLARK
ANDRE N LITSTER
QUESTAR GAS COMPANY
PO BOX 4s433
SALT LAKE CITY UT 84145
E-Mail: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE