20240327INT to Staff 27.pdf

RECEIVED
Tuesday, March 26, 2024 4:52PM
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
morgan og odin(i�givenspursley.com
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN Case No. INT-G-23-07
GAS COMPANY'S 2023 INTEGRATED
RESOURCE PLAN 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 response.
DATED: March 26, 2024.
By: --
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
INTERMOUNTAIN GAS COMPANY'S RESPONSES TO STAFF's THIRD PRODUCTION REQUEST PAGE 1 OF 2
18276570.1)

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT on March 26, 2024, I caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
monica.barrio s sanchez(&_puc.Idaho.gov
Preston N. Carter
INTERMOUNTAIN GAS COMPANY'S RESPONSES TO STAFF'S THIRD PRODUCTION REQUEST PAGE 2 OF 2
18276570.1)

INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-07
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Brian Robertson/Brian Robertson
REQUEST NO. 27:
In Section 4.3 of its report, the Company provided narrative descriptions of required
capacity enhancement projects in each Area of Interest("AOI"). The narrative included the year
of need for that project. At the end of Section 4.3, the Company provided Table 10 that listed the
same projects and identified a year of need for each project. Also, Section 4.4.3 provided the
Load Deficit Curves ("LDC") showing the first year of capacity deficit, or year of need, for each
AOI. These three different sources were not consistent about the year of need. Staff tabulated
the information below:
Section 4.3
AOI Narrative Narrative Table 10 year f�N Need
Page Year of Need 'car of Need (Base Growlh)
Canyon 99 2023 2023 2024
State Street 101 2023 2025 2028
Central Ada 103 2023 2023 2025
Sun Valley 105 2023 2023 2024
Idaho Falls 107 2024 2024 2027
Please answer the following questions:
a. Please reconcile which is the year of need for each of the AOIs, and explain why there
are differences.
b. For any project with a year of need in 2023,please explain if the associated project was
placed in service in 2023. If the project was not, please describe when the Company
estimates the project will be placed in service, and any past or present impacts to the
affected customer base.
INT-G-23-07
IPUC Staff PR 27
Page 1 of 2

RESPONSE NO. 27:
a. The correct year of need is based on the LDC Year or Need. The differences can be
explained as the Company must take a bit of a conservative approach when planning
distribution system projects for reliability. The projected LDC Year of Need includes
expected,but not guaranteed, future DSM. As noted in other production request
responses, there are also delays that push these projects back, so starting them prior to the
projected need is critical.
b. Please see response to Request#10 on the Status of Canyon County. See response to
Request#11 for the status of the State Street AOI. See response to Request#12 for the
status of Central Ada. See response to Request#13 and#29 for the status of Sun Valley.
INT-G-23-07
IPUC Staff PR 27
Page 2 of 2