20060803Staff to INT 1-8.pdf

CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6977
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEIVED
2006 AUG - 3 PH 2: 03
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S 2007-2011 INTEGRATED RESOURCE PLAN CASE NO. INT -06-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Cecelia A. Gassner, Deputy Attorney General, requests that Intennountain Gas Company
(Intennountain Gas; Company) provide the following documents and infonnation on or before
THURSDAY, AUGUST 17,2006.
Intennountain Gas is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Intennountain Gas is requested
to provide, by way of supplementary responses, additional documents that it or any person acting on its
behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
AUGUST 3 , 2006
Please provide answers to each question; supporting workpapers that provide detail or are the
source of infonnation used in calculations; the name and telephone number of the person preparing the
documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title
of such person( s) and the witness who can sponsor the answer at hearing.
Request No. 1: Economic Forecast.In the IRP the Company uses the Idaho economic forecast
published by John S. Church, dated May 2005. Did Mr. Church publish a later or updated forecast?
, was that subsequent work used in preparation of the IRP?
Request No.2: Linear Regression Modeling.The demand forecast model used by the
Company relies on the single variable of design heating-degree-days to predict natural gas usage.
There is a statement indicating that other variables have been considered. a) What are those other
variables and how do they affect the output of the model? b) The Durbin-Watson statistic suggests that
better specification of the model is possible. Has the Company followed up on that indication? If so
what were the results?
Request No.3: Natural Gas Pricing. The price curve used for the natural gas price forecast
(Exhibit 4, Appendix A, Chart 4-2) is not cited. Please provide the source for this chart. Did the
Company consider and review other price forecasts for this application? If so, what were they? Were
different price forecasts considered for application to the differing economic scenarios?
Request No.4: Sensitivity Analysis. Please identify and describe any sensitivity analysis
perfonned, and please provide the results of the sensitivity analysis. In your response, include a full
description and the range of inputs that were varied for the sensitivity analysis.
Request No.5: Has the Company considered addressing the effects of price elasticity on the
IRP process? If so, what were the results? If not, why not?
Request No.6: In the section entitled" Resource Optimization " a "Fill" resource is defined as
a generic resource used to eliminate a deficit. Does the Company have specific resource types, such as
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
AUGUST 3 , 2006
storage, spot, or tenn contract that it will use for each requirement? If so, please identify those
resources
Request No.7: What are the specific, planned actions that will eliminate the peak day
distribution deficits identified in the Resource Optimization section for the Sun Valley, Idaho Falls and
Canyon County service laterals?
Request No.8: Commission Order 27098 changed the requirement for addressing efficiency
measures to require only "a general explanation with each IRP filing of whether or nor there are cost
effective DSM opportunities." What efficiency measures did the Company review and consider in the
2006 IRP process and what were the results of those reviews?
Dated at Boise, Idaho this '?J day of August 2006.
cece
Deputy Attorney General
Technical Staff: Harry Hall
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FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
AUGUST 3 , 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF AUGUST 2006
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P. McGRATH, DIRECTOR
GAS SUPPLY & REG. AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE, ID 83707
MORGAN W. RICHARDS, JR.
ATTORNEY AT LAW
804 E PENNSYLVANIA LANE
BOISE, ID 83706
SECRETARY
CERTIFICATE OF SERVICE