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Interstate Gas Supply and Clean Energy Fuel Response to Attorney

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Interstate Gas Supply and Clean Energy Fuel Response to Attorney COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION ~En~I~ l~ ~ ~D APR Application of Delta Natural Gas ) ~ Y z0~¢ Company,Inc. for An Order Declaring ) Case. 2013-00365 PCo~~C That it is Authorized to Construct, Own ) NIM/SSSERVICE/ pN 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 THE ATTORNEY GENERAL 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 the AG 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 11th 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. COMMONWEALTH OF KENTUCKY BEFORE THE PUBLIC SERVICE COMMISSION RECEI~/p 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 IN BEREA, KENTUCKY ) RESPONSE OF INTERSTATE GAS SUPPLY,INC. AND CLEAN ENERGY FUEL CORP. TO THE FIRST SET OF DISCOVERY FROM ATTORNEY GENERAL FILED: April 11, 2014 COMMONWEALTH OF KENTUCKY BEFORC THE PUBLIC SERVICE COMMISSION In the matter of: CASE NO. 2013-00365 APPLICATION OF DELTA NATURAL GAS COMPANY,INC. FOR AN URDER DECLARING THAT IT 1S AUTHORIZED TO CONSTRUCT, OVi'N AND OPERATE A COMPRESSED NATi1RAL GAS STATION IN BEREA, KENTUCKY AFFIDAVIT OF DAVE. MROWZINSKI Comes the undersigned, Dave Mrowzinski, being duly sworn, deposes and states that he is the CNG Program Manager far IGS CNG, that he has personal knowledge of the matters set forth in the fore6oinb discovery responses, said responses were prepared b}' 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 ~,~,i~;I ~ ) Subscribed and sworn to me this 11 day o~.pu'1,,29~4, by Dave Mrowzinski. ~/ Public My Commission Cxpires: RONALD L WA'TkA(WgN Attorney At [,.~,v~r Notary Public, State afQf~p ~Y emission Has No F jp~ Section 147.03 R.C. 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,INC. AND CLEAN ENERGY FUEL CORP. TO THE FIRST SET OF DISCOVERY FROM ATTORNEY GENERAL In response to Attorney General's ("AG") First Set of Discovery to Interstate Gas Supply Inc. ("IGS") and Clean Energy Fuel Corp ("Clean Energy") collectively ("The Parties") submits the following: 1 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 AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.1. Please reference the testimony of Mr. Mrowzinski in general. Provide a copy of the witness' curriculum vitae. RESPONSE: Please see CV attached as IGS Requestfor Document Production 1. 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 AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.2. Please reference the testimony of Mr. Mrowzinski at page 1. The page displays the following: "Direct Testimony of Dave Mrowzinski" and "On behalf of IGS CNG Services and Clean Energy Fuels Corp." Is the witness testifying on behalf of both parties? If so, explain the nature of his testimony which indicates that he is employed by IGS CNG and does not, at any point in his testimony, reference Clean Energy. RESPONSE: Mr. Mrowzinski is employed by IGS CNG Services but his testimony is on behalfof both IGS and Clean Energy Fuels Corp. IGS and Clean Energy have agreed to participate in this proceedingjointly (although we reserve our right to participate individually) to save resources, avoid duplicative arguments and save the time and resources ofother parties participating in the proceeding and the Commission. 3 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.3 of AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.3. Please reference the testimony of Mr. Mrowzinski in general. Provide a chart illustrating the corporate structure of IGS including the relationship between IGS and IGS CNG Services (IGS CNG). RESPONSE: Please see corporate structure chart attached as IGS Requestfor Document Production 2. ii 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.4 of AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.4. Please reference the testimony of Mr. Mrowzinski at page 3, lines 9-11. Describe in detail IGS CNG's "25 years of experience serving retail natural gas customers and has extensive institutional knowledge about the operations of natural gas markets in Kentucky and in other states" and at page 4, lines 3-5 whereat he states "I have overseen the construction of several CNG stations for IGS CNG and I understand both the technical and financial aspects of building, owning, and operating CNG stations." In the description, provide at least the following: a. Years of experience in the operations and maintenance of compressed natural gas fueling stations for the public, Approximately 2 '/z years. b. Specific details of the experience, IGS entered an agreement to partner with the City ofDublin for the construction ofa CNG station over 3 years ago. IGS began operation a CNG station open to the public, in a partnership with the City ofDublin approximately 2 years ago. IGS has since completed constructed and owns and operates 3 CNG stations in West Virginia. IGS also is currently constructing a station in Youngstown, Ohio which will open in June andjust announced the construction ofanother station in Findlay, Ohio. IGS also supplies the natural gas to a number ofother CNG stations. c. Number of stations, with locations for each one (by state and city), owned by IGS CNG, See response to discovery request 4(b). 5 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. 4(d)-(~ of AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski d. Number of stations, with locations for each one(by state and city), operated by IGS CNG, See response to discovery request 4(b). e. Number of stations, with locations for each one(by state and city), maintained by IGS CNG, and See response to discovery request 4(b). f. A listing of the IGS CNG's competitors in the compressed natural gas fuelling station industry in each state in which it has a fueling station. Objection this question is overly broad, overly burdensome and vague. Without waiving these objections, thefollowing is a list ofmajor competitors ofIGS CNG Services throughout the United States: Clean Energy, Trillium Fuels, U.S. Oil and Gain Clean Fuels., O'Ring. Further, www.cngnow.com contains a list ofactive and planned user reported stations. D 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.5 of AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.S. Please reference the testimony of Mr. Mrowzinski in general. Provide a chart illustrating the corporate structure of Clean Energy Fuels Corp. RESPONSE: Please see corporate structure chart attached as Clean Energy Requestfor Document Production 1. 7 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.6 of AG Data Requests to IGS/Clean Energy Responding Witness: Dave Mrowzinski Q.6. Please reference the testimony of Mr. Mrowzinski in general. Regarding Clean Energy Fuels Corp., provide the following: a. Years of experience in the operations and maintenance of compressed natural gas fueling stations for the public, Clean Energy Fuels Corp.
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