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Home My WebLink About20240326INT to Staff 28-32.pdf INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S THIRD PRODUCTION REQUEST PAGE 1 OF 2 18274378.1) Preston N. Carter, ISB No. 8462 Morgan D. Goodin, ISB No. 11184 Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 prestoncarter@givenspursley.com morgangoodin@givenspursley.com Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S 2023 INTEGRATED RESOURCE PLAN Case No. INT-G-23-07 INTERMOUNTAIN GAS COMPANY’S RESPONSES TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Intermountain Gas Company (“Intermountain” or “Company”), in response to the Third Production Request of the Commission Staff to Intermountain Gas Company dated February 28, 2024, submits the following responses. Responsive documents are available for download using the link provided in the accompanying email. DATED: March 25, 2024. By:_____________________________ Preston N. Carter Givens Pursley LLP Attorneys for Intermountain Gas Company RECEIVED Monday, March 25, 2024 4:47PM IDAHO PUBLIC UTILITIES COMMISSION INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S THIRD PRODUCTION REQUEST PAGE 2 OF 2 18274378.1) CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT on March 25, 2024, I caused a true and correct copy of the foregoing to be served upon the following parties as indicated below: Monica Barrios-Sanchez Commission Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 monica.barriossanchez@puc.idaho.gov Email U.S. Mail Fax Hand Delivery Preston N. Carter INTERMOUNTAIN GAS COMPANY CASE INT-G-23-07 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathleen Campbell/ Brian Robertson REQUEST NO. 28: In Section 4.3.2 of its report, the Company states that "Ustick Phase III was chosen in 2021 as the largest capacity increasing alternative." IRP at 100. Please provide the business case analysis the Company developed when it decided that Ustick Phase III was the most cost- effective solution. If not provided in the analysis, please identify all other feasible alternatives the Company evaluated and an NPV net cost comparison between them. RESPONSE NO. 28: The Canyon County deficit alternative analysis was discussed in IGC’s 2021 IRP filing on pages 96-100. The 2021 IRP includes the NPV cost and alternative capacity of the four alternatives discussed for the Canyon County AOI deficit, as shown in the table below: Intermountain uses alternative analysis to select the most favorable alternative to meet its five- year core growth needs to address a deficit. Cost is a consideration in the alternative analysis but is not the deciding factor, as discussed in section 4.2.8 of the 2023 IRP, for example environmental concerns may outweigh cost consideration. Another way to compare cost for INT-G-23-07 IPUC Staff PR 28 Page 1 of 2 alternative analysis would be to compare the cost per capacity gained for each alternative. The Canyon County Capacity back in 2021 before any of the proposed alternative was 1,002,786 therms/day, below is the cost per therm of each alternative for the capacity gained. 1.Ustick Phase II – $3,255,074 / (1,032,000 - 1,002,786 therms) = $111/therms 2.Ustick Phase III - $8,613,403 / (1,390,000 - 1,032,000* therms) = $24/therms 3.Ustick Uprate - $1,300,000 / ( 1,178,000 - 1,032,000* therms) = $8.9/therms 4.8-inch HP Extension north of Ustick - $6,551,492 / (1,232,000 - 1,032,000* therms) = $33/therms *Assumed that Ustick Phase II is completed Intermountain chose to select Ustick Phase III as the highest capacity option since it will offset the need for future reinforcements to this area. Even if the Ustick uprate was completed at some point in a future IRP an additional reinforcement would be needed to get to the same capacity gain as Ustick Phase III, the additional cost was not considered in this IRP alternative analysis review since both Ustick Phase III and the Ustick Uprate met the 5-year growth needs assessed for this IRP. INT-G-23-07 IPUC Staff PR 28 Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-07 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathleen Campbell/ Brian Robertson REQUEST NO. 29: In Section 4.3.5 of its report, the Company states that "The Shoshone compressor station was selected in the 2019 IRP." IRP at 106. Please provide the business case analysis the Company developed when it decided that the Shoshone Compressor Station was the most cost- effective solution. If not provided in the analysis, please identify all other feasible alternatives the Company evaluated and an NPV net cost comparison between them. RESPONSE NO. 29: The Sun Valley Lateral deficit was discussed in Intermountain’s 2019 IRP filing on pages 129. Intermountain added alternative analysis with NPV net cost comparison and capacity gained to its IRP processes starting in 2021. Previous to 2021 Intermountain did not discuss alternatives in the IRP but did consider alternatives based on its alternative guidance discussed on page 88-89 in the 2019 IRP. Alternatives to the Sun Valley lateral compressor were discussed in INT-G-19- 07 Production Request No. 27. Prior to selecting the Shoshone compressor station in 2019, Intermountain did consider a 13 mile 12-inch pipeline loop as an alternative to the compressor. The pipeline loop was estimated at $1.1-1.6 million per mile in 2019, for a total cost estimated between $14-$20 million. The pipeline loop was more expensive than the Shoshone Compressor Station due to the known rock construction conditions along the Sun Valley Lateral pipeline route. INT-G-23-07 IPUC Staff PR 29 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-07 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathleen Campbell/ Brian Robertson REQUEST NO. 30: In Section 4.3.6 of its report, the Company states that "For this IRP IGC has two gate upgrades that are needed to support core growth, the Payette Gate Upgrade and the New Plymouth Upgrade." IRP at 110. Please provide the analysis, including the load and capacity data, the Company used to make this determination. RESPONSE NO. 30: Payette Gate Upgrade: Williams NWP stated capacity: 388 mcfh IGC design day model capacity need: 378 mcfh (note that this does not include our 5-year growth prediction) New Plymouth Upgrade: Williams NWP stated capacity: 32 mcfh IGC design day model capacity need: 33 mcfh (note that this does not include our 5-year growth prediction) INT-G-23-07 IPUC Staff PR 30 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-07 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Brian Robertson/ Brian Robertson REQUEST NO. 31: Please address the following apparent errors and omissions in the report: a.Please identify the location of the Stanfield Interconnect in Figure 24 of the report. b.Section 4.6.3 refers to "Table 9 on page 64." IRP at 154. Table 9 is on page 69, and it does not pertain to the referenced topic. Please identify which Table or Figure the report intended to reference. c.Pages 152 to 156 refer to Figures 62 to 65, but the corresponding graphs are Figures 61 to 64. d.Section 4.7.5 refers in the future tense about Nampa LNG operations scheduled to occur in January of 2022, which is almost two years in the past. RESPONSE NO. 31: a.Intermountain has added an arrow that identifies the Stanfield Interconnect. This is the location where GTN and NWP connect and where Intermountain and other INT-G-23-07 IPUC Staff PR 31 Page 1 of 2 transporters can move gas from one pipeline to the next. b. Thanks for catching this. The correct reference should be table 8 on page 57. c. Thanks for catching this. Intermountain agrees that those are referenced incorrectly. The references in the actual text for 62-65 should be shifted back one to 61-64. d. This language was left to provide historical context to a recent down time of the LNG facility. With that said, Intermountain does agree the paragraph could have been rephrased to better capture the intent of the language. INT-G-23-07 IPUC Staff PR 31 Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-07 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Brian Robertson/ Brian Robertson REQUEST NO. 32: Figure 63 on page 154 of the report shows an upstream resource deficit in January 2029, but the graph only displays a 12-month window. Please provide similar graphs for each of the two preceding years (October 2026 through September 2028). RESPONSE NO. 32: The graphs below explain the upstream resource deficit. With the addition of GTN Xpress, Intermountain is able to serve customers under design day conditions up through 2027. Intermountain would then need to secure more delivery services beginning in the year 2028 in order to meet design day load. INT-G-23-07 IPUC Staff PR 32 Page 1 of 2 INT-G-23-07 IPUC Staff PR 32 Page 2 of 2