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Interstate Gas Supply and Clean Energy Fuel Response to Delta Natural Gas Data Request

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Interstate Gas Supply and Clean Energy Fuel Response to Delta Natural Gas Data Request HURT,CROSBIE ~L MAY rLLc William C. Hurt, Jr. THE EQUUS BUILDING Matthew R. Malone Scott A. Crosbie 127 WEST MAIN STREET Aaron D. Reedy William H. May, III LEXINGTON,KENTUCI£Y 40507 James L. Deckard Michael D. Kalinyak Jacob K. Michul Telephone -(859) 254-0000 Facsimile -(859 254-4765 RECEIVED Apri111, 2014 APR 11.2014 Via Hand-Delivery PUBLIC SERVICE Mr. Jeff Derouen, Executive Director COMMISSION Kentucky Public Service Commission 211 Sower Boulevard Frankfort, Kentucky 40602 RE: Case No. 2013-00365; Application of Delta Natural Gas Company, Inc.for an Order Declaring That it is Authorized to Construct, Ozcm and Operate a Compressed Natural Gas Station in Berea, Kentucky Dear Mr. Derouen: Please find enclosed the original and twelve (12) copies of Interstate Gas Supply Inc.'s and Clean Energy Fuel Corp.'s responses to the data requests from the Attorney General, Delta Natural Gas Company, Inc. and the Commission Staff in the above-referenced case. Please place the documents of file. Regards, ~~ Matthew Malone C: File; Parties Offices in Lexington and Louisville RE~~~~~p COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION APR 112014 PUBLIC SERVICE Application of Delta Natural Gas ) COMMISSION Company,Inc. for An Order Declaring ) Case. 2013-00365 That it is Authorized to Construct, Own ) and Operate a Compressed Natural Gas Station in Berea, Kentucky INTERSTATE GAS SUPPLY INC.'S AND CLEAN ENERGY FUEL CORP.'S CERTIFICATE OF SERVICE REGARDING DATA REQUEST RESPONSES TO DELTA NATURAL GAS COMPANY,INC. Comes Interstate Gas Supply, Inc. and Clean Energy Fuel Corp., by counsel, and hereby certifies that an original and twelve (12) copies of the attached data request responses to Delta Natural Gas Company, Inc. were served via hand-delivery upon Jeff Derouen, Executive Director, Public Service Commission, 211 Sower Boulevard, Frankfort, Kentucky 40602-0615; furthermore, it was served by mailing a copy by first class U.S. Mail, postage prepaid, on the following, and by electronic mail where available all on this 11 ~' day of Apri12014. Hon. Robert M. Watt, III Stoll Keenon Ogden 300 W. Vine Street Suite 2100 Lexington, KY 40507-1801 Hon. Dennis Howard Assistant Attorney General Office of the Attorney General Utility &Rate 1024 Capital Center Drive Suite 200 Frankfort, Kentucky 40601-8204 Matthew R. Malone William H. May, II. Hurt, Crosbie &May PLLC The Equus Building 127 West Main Street Lexington, Kentucky 40507 (859) 254-0000 (office) (859) 254-4763 (facsimile) Counsel for the Petitioner, IGS CNG Services and Clean Energy Fuels Corp. DECEIVED COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION ApR 112014 PUBLIC SERVICE COMMISSION In the Matter of: THE APPLICATION OF DELTA NATURAL GAS COMPANY INC. FOR AN ORDER DECLARING THAT IT IS AUTHORIZED TO CONSTRUCT, CASE NO. OWN AND OPERATE A COMPRESSED NATURAL 2013-00365 GAS STATION 1N BEREA,KENTUCKY RESPONSE OF INTERSTATE GAS SUPPLY TO THE FIRST SET OF DISCOVERY FROM DELTA NATURAL GAS COMPANY FILED: April ll, 2014 COMMONWEALTH OF KENTUCKY BEFORC THE PUBLIC SERVICE COMMISSION In the matter of: CASE NO. 2013-00365 APPLICATION OF DELTA NATURAL GAS COMPANY,INC. POR AN ORDER DECLARING THAT IT 1S AUTHORIZED TO CONSTRUCT', OWN AND OPERATE A COMPRESSED NATURAL GAS STATION IN IiEREA, KENTUCKY AFFIDAVIT OF DAVE. MROWZINSKI Conies the undersigned, Dave Mrowzinski, being duly sworn, deposes and states that he is the CNG Program Manager far [GS CNG, that he has personal knowledge of the matters set forth in the foregoing discovery responses, said responses were prepared by him and under his direction and supervision, if inquiries were made as to the facts in said responses he would respond as therein set forth and the answers contained therein are true and correct to the best of his knowledge. Dave Mrowzinski STATE OF OHIO ) COUNTY OF !,"'',r ~~% `~~ ~ ) Subscribed and sworn to me this 11 day of9.~i1„29~I'4, by Dave Mrowzinski. Public My Commission expires: RONALD L. WA`fkliMAtj Attorney At[aw Notary Public, State of(gyp PVIy commission Has No F jpp~ S~ctiorr 147.Q3 R.~, COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION The Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) RESPONSE OF INTERSTATE GAS SUPPLY TO THE FIRST SET OF DISCOVERY FROM DELTA NATURAL GAS COMPANY In response to Delta Natural Gas Company's ("Delta") First Set of Discovery to Interstate Gas Supply Inc. ("IGS") and Clean Energy Fuel Corp ("Clean Energy") collectively ("The Parties") submits the following: COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) Question No. 1 of Delta Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski 1. What kind of business organization is IGS CNG Services a. Please identify all shareholders, members, partners, joint venturers, owners, as applicable, of IGS CNG Services IGS CNG Services is a d/b/a used by CNG Services, LLC. CNG Services is owned by IGS Ventures, Inc. b. Does Clean Energy or any of its affiliates have any ownership or equity interest in IGS CNG Services? No. i. If so, Please quantify such ownership interest. N/A. 2 COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) Question No. 2 of Delta Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski 2. Please produce a corporate organization chart for IGS and all of its affiliated entities. RESPONSE: Please see corporate structure chart attached as IGS Requestfor Document Production 1. Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) Question No. 3 of Delta Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski 3. Please produce a corporate organization chart for Clean Energy and all of its affiliated entities. RESPONSE: Please see corporate structure chart attached as Clean Energy Request for Document Production 1. Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) Question No. 4 of Delta Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski 4. Please describe in detail the relationship, if any, between IGS and Clean Energy. RESPONSE: IGS and Clean Energy are competitors in the CNG Industry Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural Gas Station in Berea, Kentucky ) Question No. 5 of Delta Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski 5. For each compressed natural gas("CNG") refueling station owned by IGS or IGS CNG Services, please provide the following: a. The location of each station, IGS owns three stations in Charleston, WV, Jane Lew, WV and Bridgeport, WV. IGS will be opening another station in Youngstown Ohio shortly with an intent to continue building stations in OH, WV, PA, IN, KY in the near term. b. The identity of the operator of each station; IGS is the operator ofthe stations references in S(a). c. The electric compression costs per gasoline gallon equivalent("GGE") (in KWH and monthly fixed KW demand charges) of each station; Objection this request is overly board, vague and overly burdensome. Further, Mr. Mrowzinski provides estimates of station costs in his testimony. However, individual stations electric compression costs per GGE are afactor ofstation usage (which changes constantly) multiplied KWH charges, in addition to factoring in demand charges and fixed utility customer charges, thus there is no set electric compression costs per GGE at an individual station as this cost would be changing constantly. Without waiving this objection, IGS estimates that its average electric compression costs for each of its stations are roughly 20-30 cents per GGE. Further, the stations referenced in this question are located in Appalachian Power, Monongahela Power and Harrison RuYal Electrification Association service territories and these tariffs are publically available information and can be accessed independently by Delta in orderfor Delta to obtain the KWH, demand and customer chargesfor those utilities. d. The state and federal road taxes per GGE for each station; Objection this information is publically available and can be easily obtained by Delta. Without waiving this objection, federal and state road tax for CNG in WV is 18.3 cents and 24.4 cents respectively. Any discussion of U.S. tax matters included herein (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of(i) promoting, marketing, or recommending to another party any transaction or matter addressed herein, or (ii) avoiding U.S. tax-related penalties J Application of Delta Natural Gas Company ) Case No. 2013-00365 Inc. for an Order Declaring that it is Authorized ) to Construct, Own and Operate a Compressed ) Natural
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