20080820INT to Staff 5-8,12-15, 17, 20.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD · P.O. BOX 7608. BOISE, IDAHO 83707. [phone] . FAX: [phone]
iUUU L¡: 47
August 20,2008
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington St.
P. O. Box 83720
Boise,ID 83720-0074
RE: First Production Request of the Commission Staff to Intermountain Gas Company
Case No. INT-G-08-02
Dear Ms. Jewell:
Attached for filing with the Idaho Public Utilities Commission are the original and seven
copies of Intermountain Gas Company's initial response to the First Production Request
of the Commission Staff, in the above referenced Case.
If there are any questions regarding the attached, please contact me at [phone].
I P. Mc
Director
Gas Supply and Regulatory Affairs
MPM/sc
Attachments
cc W. C. Glynn
E. Book
P. Powell
M. Rich
Request No.5: Within the 2004 Staff Comments "Staff notes that the Company does not track water and
Space heater conversions separately and that migration from RS1 (space heat only) to RS2 (space and
water heat) is not projected in the IRP. Furthermore, the Company no longer tracks gas appliance
penetration yet it has indicated that there is anecdotal evidence of increased penetration of gas
fireplaces, stoves, dryers, and barbecues" (2004 IRP Staff Comments page 3). How has IGC begun
tracking water and space heater conversions separately, migration from RS1 to RS2, or penetrating gas
appliances? Please explain your answer. (IRP page 19).
Responder:Byron Defenbach
Ph 208.377.6080
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208.377-6168
Byron Defenbach
Record Holder:
Witness:...i--1
Response:
IGC tracks space and water heater conversions (electric appliances converting to natural gas appliances)
via our marketing reporting system. (See attached "Request NO.5 Exhibit 5.1")
The column headings on the attached Exhibit 5.1 that read "Existing" are sales to existing homes which
were built with another heating energy source, and are converting to natural gas:
. "Existing space heat" refers to a dwelling which is converting only to at a natural gas furnace.
. "Existing multi-use" refers to a home switching to at least both a gas furnace and a gas water
heater.
Intermountain's existing price structure provides a lower price to the user of both natural gas space and
water heating, so we track them.
Since Intermountain doesn't go "past the metet' as part of our normal service work, it's possible that an
RS-1 customer could add a natural gas water heater using a third party vendor without Intermountain's
knowledge. Intermountain is currently working on a system to report those customers who call
Intermountain to convert from RS-1 to RS-2 (which would then be reported as a "migration") and also
continues to solicit the support of appliance vendors to encourage customers to make the call to
Intermountain anytime a natural gas water heater is installed in addition to an existing natural gas
furnace.
We assume that there is increasing usage of other natural gas appliances such as stoves, barbecues,
clothes dryers, etc. based on feedback from our representatives who work with homebuilders and
HVAC/appliance dealers.
Request No.6 Based on IGC's assumption that household growth drives small commercial customer
growth (IRP page 20):
a) How long a lag period is evaluated between residential growth occurring and commercial growth
arriving to serve this residential population?
b) How many years has this lag been researched or observed?
c) How predictive has it been?
Responder:Byron Defenbach
Ph 208-377-6080
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Record Holder:
Page 1
Witness:
Boise, Id 83709
Ph 208.377.6168
Byron Defenbach
Response:
a) Based on the historic relationship between residential growth and commercial growth, our
forecast employs a lag of one year between household growth, and the corresponding growth in
commercial customers. That is the relationship employed in the IRP forecasts.
b) This one year lag has been observed since 2003.
c) It has been reasonably predictive tool (See attached "Request NO.6 Exhibit 6.1"). This chart
shows that the recent annual increases in residential new construction were followed by
increases in commercial new construction a year later.
Request No.7: Within the 2006 IRP, Staff commented, "The Company may wish to consider modeling
the RS-1, RS-2 and small commercial classes separately. It is reasonable to expect a different response
to weather patterns for the three groups of customers based on their characteristics." (Staff Comments
2006, IRP page 6).
a) What "slightly different data set" enabled IGC to model RS-1, RS-2 and small commercial classes
separately during non-peak but not peak? (IRP page 28 and Exhibit 2, Appendix A).
b) Are there technological or methodological advances being made in order to achieve more
accurate modeling by customer class? (IRP page 27).
c) What is IGC's plan to improve the results of a peak price variable previously derived from
aggregating RS-1, RS-2 and small commercial? (IRP page 30).
Responder:Lori Blattner
Ph 208.377.6000
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Michael McGrath
Record Holder:
Witness:
Response:
a) Intermountain collects monthly usage data by customer class coincident with its customer
billing process. This customer class specific billing cycle information is then regressed against
various predictive variables, not the least of which is the coincident weather, to arrive at a non-
peak day related forecasting tool. During the non-peak months, usage for the total month was
modeled based upon this customer class specific database.
In order to measure daily (peak-day) responses to the weather (and other predictive variables),
IGC collects daily usage data on the aggregate core market (or sales customers) as provided by
and through the Company's Gas Control Department. Intermountain's "daily sendout" from Gas
Control is measured in aggregate (not specific to each sales customer class) as the Company's
distribution system is managed each day on an aggregate sendout basis level irrespective of
each customer class's usage. Intermountain must meet its peak-day delivery to the aggregate
core market as each of the separate sales customer classes have equal rights to firm deliveries
on the peak day.
b) Intermountain continually looks for methods to enhance peak-load modeling. However,
Intermountain believes the current method of developing peak loads based upon aggregate daily
reads using eighteen years of data is a sound one. As we move forward, technology may be
helpful in allowing Intermountain to collect daily core market usage data by customer class which
Page 2
can be used to test/benchmark the current modeling methods. A technological advance that may
be of some help in the future is Intermountain's ERT system. This system may be able to collect
daily usage data by customer class, although all the required infrastructure pieces are not
currently in place to do so. One issue yet to be resolved is the problem that more frequently
interrogating the ERT devices may accelerate the need for costly capital improvements to the
ERT system. As is always the case, Intermountain works to balance the cost to our customers of
acquiring more specific data with the benefits that data may provide. As technology improves,
however, we hope to resolve these issues and continue to move toward additional types of data
collection.
c) Intermountain is very interested in the results of price elasticity upon usage per customer.
Because of this, Intermountain continually tests for the effects of price elasticity to help develop
better forecasting models. Although price remained in the non-peak month models as a
significant variable for the RS-1 and RS-2 customer classes in this IRP filing, some testing done
this summer has shown that this may not be the case by the time the next IRP is filed. The data
is showing a declining customer response to price changes. As customers have responded to
higher prices by making equipment upgrades and installng permanent conservation measures,
there is less of an opportunity for price response than there was during the first major increase in
prices after 2000. The permanent responses to higher prices become part of the constant of the
model and are thus incorporated in future models not as a response to price, but as a more
permanent decrease to usage. Because of this, it may not be possible for Intermountain to
improve the results of a peak price variable in the peak month models, and we may find that the
price variable becomes insignificant in the non-peak models as welL. Because price is an
important variable to consider, however, Intermountain will continue to employ statistical methods
to test for price elasticity in the development of the usage models.
Request NO.8: Please provide more insight as to IGC's goals or milestones in achieving "Usage per
Customer by Geographic Area." Specifically (IRP page 30):
a) What effort has been made in initiating a sampling meter program aside from the website
provided to commercial customers for tracking consumption?
b) How many sampling meters are currently installed by lateral or region?
c) Is a customer sample plan in place by lateral or region? Please explain.
d) How were the "targeted areas" chosen for sample?
e) What level of statistical significance is IGC targeting?
f) How many more meters are expected to be put in per year to keep the sample up to date?
g) When will you have actionable results to incorporate into an IRP?
Responder:Lori Blattner
Ph 208.377.6000
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Michael McGrath
Record Holder:
Witness:
Response:
a) The Sun Valley and Idaho Falls Laterals are unique regions on Intermountain's system in that
correctly placed meters can measure and recall the total daily usage for the entire lateraL.
Intermountain has installed a meter on both the Sun Valley and Idaho Falls laterals that measures
the total daily usage for each lateraL. Then by removing the industrial customer's telemetered
daily usage, Intermountain is able to arrive at a very accurate core market daily usage for each
lateraL. So, Intermountain is not sampling the usage, it is measuring all the usage on these two
Page 3
laterals and then regressing this usage against the coincident weather as well as other predictive
variables.
b) There is one large meter on each of the Idaho Falls and Sun Valley laterals to measure the
total daily usage for each lateraL.
c) Since Intermountain is able to accurately capture the entire (100%) core market daily usage
on both of these laterals, there wil not be a need for any sampling meters.
d) The "targeted areas" are areas within Intermountain's system that are known for robust
growth. The growth in these areas creates the potential need for enhancements on these laterals
to serve the growing demand. Careful attention to these "targeted areas" ensures that any
necessary enhancements are made in a timely manner.
e) The models derived (data used) during this IRP process included too few data points (not
enough history). Intermountain is hopeful that greater than 5 years of data wil begin to yield
statistically significant results at the 95% confidence level (poeO.05) for the next IRP filing.
f) Again, since Intermountain is able to capture all the usage data on the laterals, no additional
meters wil be necessary.
g) Even though Intermountain was not able to develop statistically significant lateral specific
models for this IRP, the small amount of data that has been collected did provide actionable
results for the Sun Valley Lateral (IRP page 30). Studying the Sun Valley Lateral data led
Intermountain to conclude that the Total Company models may not be accurately accounting for
what appears to be a higher peak day usage per customer on the Sun Valley Lateral, an area that
includes a housing stock with significantly larger average square footage per household. To
account for this difference and based on more anecdotal evidence, the peak day period usage
was adjusted upward by three therms for the Sun Valley lateraL. Intermountain will continue this
fine-tuning process for the Idaho Falls and Sun Valley laterals in the next IRP filing.
Request No. 12: Please provide the Order number and specific Order language where "the IPUC
ordered IGC not to deploy any new core-market DSM programs". (IRP Page 64).
Responder:Michael McGrath
Ph 208.377.6168
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Michael McGrath
Record Holder:
Witness:
Response: Per Case No. INT-G-96-4, Order No. 26546, the Commission denied Intermountain's
proposal to implement a new faucet aerator program and in the same proceeding ordered Intermountain
to discontinue its water heater rebate.
This Order highlights how changing market trends can affect the need for these types of programs. It also
highlights the necessity for Staff and Company to continue to communicate regarding the availability of
applicable technologies in the marketplace and the appropriate implementation of these technologies
within Intermountain's service territory.
Request No. 13: IGC has offered to consult and help direct leak detection and corrosion control
efforts on the natural gas piping systems within the industrial customer's facilities: how often
have these services been utilized and what is IGC's estimated anual savings in therms?
Page 4
Responder:Brent Wilde
Ph 208.377.6053
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208.377.6168
Brent Wilde
Record Holder:
Witness:
Response:
Intermountain Gas Company has performed leak survey and/or corrosion control activities at three
industrial customers in the past.
Intermountain has and will always respond to an emergency or safety situations.
Most inquiries, now, for both conservation and system integrity are referred to outside contractors who
perform these surveys and maintenance on a fee basis.
The savings in therms is impossible to accurately document, however, it would be minimal compared to
the overall customer's usage. Probably more important is the greenhouse gas savings by stopping direct
release of methane to the atmosphere.
Request No. 14: With regards to customers located along the Idaho Falls Lateral having the ability to
use Non-traditional Supplies in lowering their natural gas requirement during peak (IRP page 51):
a) Is IGC currently engaged in any negotiations with specific industrial customers operating
within the Idaho Falls Lateral having the ability to use non-traditional resources during peak,
and if so, how many?
b) What overall positive or negative responses has IGC received in negotiations?
Responder:Brent Wilde
Ph 208.377.6053
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Brent Wilde
Record Holder:
Witness:
Response:
a) Prior to each winter heating season, Intermountain re-confirms all alternate fuel customer's ability
to use their alternate fuel and the length of time their alternate fuel supplies might off-set their
natural usage. Customers with alternate energy capabiliies (3 on the Idaho Falls Lateral) have
always been responsive if the need to use an alternate fuel arises.
b) It is very expensive to build, operate, and maintain storage facilities to keep alternate fuels on
hand - not to mention the requisite government permitting. However, as was stated above,
customers with alternate energy capabilities have always been responsive if the need to use their
alternate fuel arises.
Request No. 15: When targeting residential customers for DSM programs, has IGC engaged in end-use
studies? If so, please provide them (IRP page 30).
Responder:Byron Defenbach
Page 5
Record Holder:
Witness:
Ph 208-377.6080
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208.377.6168
Byron Defenbach
Response:
IGC has not performed any end-use studies in its DSM analysis. When Intermountain engaged Navigant
Consulting, Navigant provided a group of already-established DSM programs being utilized by other
similar utilities which embedded end-use statistics. The end-use studies and other analysis of the
programs had already been performed as a prerequisite to their inclusion in the group.
Request No. 17: With regards to the Gas Equipment Financing Program in place on previous IRPs
(2004 IRP Staff Comments page 4 and 2006 IRP page 61):
a) Has IGC considered reinstituting a gas equipment financing program through Wells Fargo Bank
which provided current and prospective customers with an equipment financing avenue that
included competitive rates and an expedited approval process? If not, why not?
b) Why was this program eliminated?
Responder:
Record Holder:
Witness:
Byron Defenbach
Ph 208.377-6080
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Byron Defenbach
Response:
Intermountain has not considered reinstituting a gas equipment financing program through Wells Fargo
that would include competitive rates and an expedited approval. The Wells program did not appear to
provide any significant advantage over manufacturer or dealer financing over the years, and its utilization
level never reached expectations. Based on these low participation levels, Wells Fargo decided, on their
own, to eliminate the IGC Finance Program.
Request No. 20: What milestones are in place for IGC to evaluate, consider, reach a decision, and
implement the following (IRP page 66):
a) $30 rebate when a homeowner converts to a natural gas water heater from another energy
source, and installs a .64-or-greater energy factor (EF) gas water heater?
b) $200 rebate when an existing customer replaces a below 90% efficiency natural gas furnace with
a 90%-or-greater efficiency natural gas furnace?
c) $30 rebate when an existing customer replaces a .59-or-below EF natural gas water heater with a
.64-or-greater EF natural gas unit?
Responder:
Record Holder:
Byron Defenbach
Ph 208-377-6080
Michael McGrath
Intermountain Gas Company
555 S. Cole Rd.
Boise, Id 83709
Ph 208-377-6168
Page 6
Witness:Byron Defenbach
Response: Regarding the three DSM programs cited, some milestones considered by IGC include the
determination of a specific geographic area in which to perform the pilot programs. In this case, the Idaho
Falls lateral has been selected. Establishing the "technical potential" for DSM along that Lateral was also
an important milestone in determining costs and therm savings. Another important milestone is whether
the equipment covered by the DSM program is widely available in the proposed area, and the proposed
equipment is available.
The outcome of further discussions with IPUC Staff, and the direction provided by that interaction will be
important for setting further milestones in the DSM process.
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