20080806Staff to INT 1-35.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
POBOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INTERMOUNTAIN )
GAS COMPANY'S 2009 - 2013 INTEGRATED )RESOURCE PLAN. )
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CASE NO. INT -G-08-2
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,
Kristine A. Sasser, Deputy Attorney General, requests that Intermountain Gas Company
(Company; IGC) provide the following documents and information on or before WEDNESDAY,
AUGUST 20, 2008.
This Production Request is to be considered as continuing, and Intermountain Gas Company
is requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company 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 and if
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 1 AUGUST 6, 2008
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
Request No.1: Based on the calculations to derive the "IGC commercial multiplier rate",
does the historical relationship between new construction and commercial growth display a
significant correlation? If so, please explain which years were used and the significance of the
correlation. (IRP page 9).
Request No.2: The Company uses the Idaho Economic Forecast published by John S.
Church, dated May 2007 for its 2008 IRP. Did Mr. Church publish a later or updated Forecast?
(IRP page 11). If so, why wasn't this used? If not, have other data providers been considered?
Request No.3: How often does Wells Fargo report on building permits used to calculate
household growt? (lRP page 18).
Request No.4: Please explain how Wells Fargo and IGC's market penetration rates have
been reconciled to come up with a final forecast. (IRP page 18).
Request No.5: Within the 2004 Staff Comments "Staff notes that the Company does not
track water heater and space heater conversions separately and that migration from RSI (space heat
only) to RS2 (space and water heat) is not projected in the IRP. Furhermore, 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 barbeques." (2004 IRP Staff Comments
page 3). How has IGC begun tracking water and space heater conversions separately, migration
from RS 1 to RS2 or penetrating gas appliances? Please explain your answer. (lRP page 19).
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 2 AUGUST 6, 2008
Request No.6: Based on IGC's assumption that household growth drives small
commercial customer growth (lRP page 20):
a) How long a lag period is evaluated between residential growth occuring and
commercial growth ariving to serve this residential population?
b) How many years has this lag been researched or observed?
c) How predictive has it been?
Request No.7: Within the 2006 IRP, Staff commented, "The Company may wish to
consider modeling the RS-l, 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-l, RS-2, and small
commercial classes separately during non-peak but not peak? (lRP 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-l, RS-2 and small commercial? (IRP page 30).
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 curently 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 I GC 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?
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 3 AUGUST 6, 2008
Request No.9: When forecasting industrial customers' consumption (lRP page 31):
a) What... "other forecast data was then utilzed to adjust the surey data base for
two of the three forecasts (Base Case and Low Growth)"?
b) Please provide the "other forecast data" used in forecasting this group of customers
and describe how it was utilized.
Request No. 10: Within IGC's forecasts, how have consumption differences among
different days in the week been considered?
Request No. 11: With regards to DSM analysis (lRP page 64):
a) What research was conducted throughout the 90s indicating DSM actions did not
present a clear sensible solution?
b) Is there more recent research confirming this? If so, please provide it.
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).
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 customers facilties; how often
have these services been utilzed and what is IGC's estimated anual savings in therms? (IRP page
31).
Request No. 14: With regard to customers located along the Idaho Falls Lateral having the
abilty to use Non-Traditional Supplies in lowering their natural gas requirement during peak (IRP
page 51):
a) Is IGC curently engaged in any negotiations with specific industrial customers
operating within the Idaho Falls Lateral having the abilty to use non-traditional
resources during peak, and if so, how many?
b) What overall positive or negative responses has IGC received in negotiations?
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 4 AUGUST 6, 2008
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).
Request No. 16: Has research been completed differentiating between households
replacing equipment prior to burning out vs. replacement following buring out in evaluating DSM
program success?
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 Ban which provided curent 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?
Request No. 18: Please provide the list ofDSM programs and opportities Navigant
Consulting evaluated (IRP page 65).
Request No. 19: What tyes of weatherization assistance programs does IGC paricipate in
to reduce gas consumption?
Request No. 20: What milestones are in place for IGC to evaluate, consider, reach a
decision, and implement the following (lRP 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
fuace with a 90%-or-greater efficiency natural gas fuace?
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?
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 5 AUGUST 6, 2008
Request No. 21: Does IGC offer any rebate incentives to encourage existing customers
who have to replace efficient equipment (90%-or-greater fuace, .64-or-greater water heater) to
choose new efficient equipment in their replacement? If not, why not? If so, please provide a
description of the program (lRP page 66).
Request No. 22: How does IGC evaluate and determine the appropriate rebate amount on
any given DSM efficiency program?
Request No. 23: What avoided cost projections has IGC made to evaluate curent and
future DSM programs? Please explain.
Request No. 24: With regards to the elimination of the T-l and T-2 tariffs, and the
introduction of the T-5 tariff:
a) Wil the "Transportation Capacity" section of the IRP change? Please explain
(IRP page 47).
b) What implications will the changes have given the statement that "All curent
customers were assumed to remain on their curent tariff, while any new customers if
less than 500,000 therms were classified as a LV -1 customer and those over 500,000
anual therms were classified as a T -4 customer"? (IRP page 31).
Request No. 25: How has IGC or the companies it works with incorporated the electric
industries effect of peaker plant gas consumption growth on the NYMEX prices used in
forecasting? (IRP page 45).
Request No. 26: With regards to the multinational energy companies that were used in
evaluating future gas prices (IRP page 45):
a) What two multinational energy companies were used in evaluating futue gas prices?
b) How were they selected amongst others?
c) Please provide a comparison summar of these multinational energy companies'
methodologies and output in ariving at similarly projected natural gas prices.
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 6 AUGUST 6, 2008
Request No. 27: What futue plans beyond "city gate" storage are in place to utilze re-
delivery capacity ("city gate supplies") without having to use IGC's interstate capacity resources?
(lRP page 69).
Request No. 28: Please provide a legend for the acronyms shown in Colum 2 of Exhbit
No.8, Appendix D. (lRP page 70).
Request No. 29: With regards to the Sun Valley Lateral (IRP page 41):
a) What analysis has been done to support the assumption that rebuilding the gate
station andxelying on short-term line pack will remediate the deficit through 2011 ?
b) What will happen following the 2011 horizon?
Request No. 30: Do you feel it is reasonable to attribute a 30% average anual forecasted
growth change in customers between IRPs as being "mainly due to the downturn in housing
constrction"? If yes, explain why it is accurate to base projections on housing construction given
its volatility. If no, explain what other factors significantly impacted the average anual forecasted
growth change and how these impacts compare to housing constrction (lRP page 74).
Request No. 31: When comparing the declining industrial customer demand forecast
reported in 2008 vs. 2006, what proportion is associated with a decline in economic conditions vs.
progress made on alternative supply and DSM? (IRP page 74).
Request No. 32: When IGC changed from the "Parade of Homes sponsorship to a practice
wherein the Company now assists the local Building Contractor Associations" with promotion of
their respective Parades (IRP page 76):
a) Are these promotional efforts directed toward associations that would already be
installng efficient gas appliances?
b) What Building Contractor Associations is IGC teaming up with to encourage
effciency?
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 7 AUGUST 6, 2008
c) On what basis are these Associations selected?
d) What other means of advertising are you considering for the deployment ofIGC's
advertising promotion and what was done to ensure these are the most effective
avenues? (IRP page 66).
Request No. 33: With regards to DSM programs between 2006 and 2008 outlined in the
IRPs (IRP page 77):
a) Please describe any changes or progression IGC has made in the selection, design,
and assessment of DSM programs.
b) If changes are planed, what is the timeline?
Request No. 34: Why is there a net decrease in "Existing Distribution Transport Capacity"
shown in Table 9.3 when Tables 9.1 and 9.2 representing 2008 and 2006 "Load Duration" show no
change? (lRP page 87).
Request No. 35: Why was there a significant decline in market penetration rates when
comparing the 2008 IRP to the 2006 IRP, specifically in the Eastern division? (2008 IRP page 18
and 2006 IRP page 21).
DATED at Boise, Idaho, this CpU! day of August 2008.
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Kristne A. Sasser
Deputy Attorney General
Technical Staff: Matt Elam
i:umisc:prodreq/intg08.2ksme pr i .doc
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 8 AUGUST 6, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF AUGUST 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO.
INT-G-08-2, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH / DIRECTOR
GAS SUPPLY & REG. AFFAIRS
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE ID 83707
~îD.mL
SECRETARY
CERTIFICATE OF SERVICE