20101028Staff 1-35 to INT.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
RECEl\/
ioinOCT 28 PH 2:38
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 INTERMOUNTAIN GAS )
COMPANY'S 2011- 2015 INTEGRATED )RESOURCE PLAN (IRP). )
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CASE NO. INT-G-I0-4
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Intermountain Gas Company
(Company; IGC) provide the following documents and information as soon as possible, but no
later than FRIDAY, NOVEMBER 12,2010.
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 different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Intermountain 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 wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 1 OCTOBER 28,2010
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: On page 8 of the Integrated Resource Plan (IRP), regarding the
Company's reliance on industrial customer facilities to help meet peak, the Company states "short
duration peak day distribution delivery deficits in the futue can be mitigated by working with
these customers to faciltate the use of fuel oil at these customer's facilties." How many
contracts has the Company negotiated to facilitate the use of fuel oil at these customer's facilties?
As part of your response, please include the number of therms offset by relying on each customer
facilty, and the expiration date of each contract.
REQUEST NO.2: Please provide an executable electronic copy of all analysis used to
evaluate the success of the Company's ongoing advertising promotion of high-efficiency new
homes and Energy Star. As par of your response, please include an explanation of how the
advertising promotions have changed as a result of your evaluations.
REQUEST NO.3: In the Company's high growth scenaro, it forecasts growth in
Idaho's electronics industry. Specifically, the Company references "the projected opening of a
new production plant in the Boise MSA." Please provide a detailed explanation about this new
production plant. As par of your answer, please provide the source and perceived accuracy of
this. information.
REQUEST NO.4: Within IGC's forecasts, explain why a binar variable has not been
tested that captures holiday consumption, specifically on the Sun Valley Lateral (SVL) where
holiday occupancy can significantly impact peak.
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 2 OCTOBER 28,2010
REQUEST NO.5: When designing the SVL peak day, has the Company evaluated the
combined impact of large snowfall accumulation (i.e. - snowmelt) surrounding a high Heating
Degree Day (HDD)?
REQUEST NO.6: Please explain how you determined that a "company-wide 50 year
probabilty event, which is an 81 degree day, would be appropriate to use for the design weather
modeL."
REQUEST NO.7: Please explain why the Company did not test more explanatory
independent variables (e.g. - household size, wind speed, and persons per household) to help
explain peak and non peak usage per customer.
REQUEST NO.8: Why does the Company use two different dependent variables to
forecast peak customer usage and non peak customer usage, "daily usage per customer" for peak,
and "monthly usage per customer" for non peak? In your response, please explain how using
different dependent variables impacts the results of the final forecast.
REQUEST NO.9: Has the Company notified city leaders of its IRP filing, specifically
on the laterals where work will be completed to eliminate capacity constraints? If so, how was
notice provided? If not, why not?
REQUEST NO. 10: The Company describes the "IGC conversion rate" as "the
anticipated percentage .of conversion customers relative to new construction customers." Does
the relationship between residential new construction and conversions have a significant
correlation? As part of your response, please explain which years were used to determine the
"IGC conversion rate," and provide an executable electronic copy ilustrating the correlations.
REQUEST NO. 11: When the Company estimates the number of conversions, does it
differentiate discretionary vs. mandatory replacements? If so, how is this estimated? If not, why
not?
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 3 OCTOBER 28,2010
REQUEST NO. 12: When the Company estimates the number of conversions, does it
estimate the potential impact of the rebate conversion program it has been evaluating over the last
several IRPs? If so, please provide the estimated anual impact of the potential rebate conversion
program if implemented. If not, please explain why this has not been par of your evaluation.
REQUEST NO. 13: Has the Company looked into financing options available for
conversions and upgrades to high efficiency equipment? As part of your response, please explain
whether the. Company has evaluated the reasonableness of the interest rates.
REQUEST NO. 14: Has the Company considered reinstituting a gas equipment
financing program, similar to the prior program through Wells Fargo Bank? If not because of a
reservation about limited prior participation, has the Company considered a more targeted
marketing effort?
REQUEST NO. 15: The Company describes the "IGC commercial multiplier rate" as
"the anticipated percentage of commercial customers relative to residential new construction
customers." Does the relationship between residential new construction and commercial growth
display a significant correlation? As part of your response, please explain which years were used
to determine the IGC "commercial multiplier rate," and provide an executable electronic copy
ilustrating the correlations.
REQUEST NO. 16: Please provide all executable electronic analysis comparing the
Company's last four IRP conversion forecasts to actual. Please include each segment as par of
your response.
REQUEST NO. 17: Please provide all executable electronic analysis comparing the
Company's last four IRP customer forecasts to actual. Please include each segment as par of
your response.
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 4 OCTOBER 28,2010
REQUEST NO. 18: Please provide all executable electronic analysis comparing the
Company's last four IRP usage forecasts to actual. Please include each segment as par of your
response.
REQUEST NO. 19: Over the last two IRPs, the Company has stated it is evaluating the
rebate options shown below. Please explain why it has not implemented the rebates. As par of
your response, please provide a future timeline ilustrating milestones for completing the
evaluations:
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 furace with a 90%-or-greater efficiency natural gas furace.
c) $30 rebate when an existing customer replaces a .59-or-below EF natural gas water
heater with a .64-or-greater EF natural gas unit.
REQUEST NO. 20: Given the challenging economic times, has the Company evaluated
the number of existing customers replacing burned out effcient equipment (90%-or-greater
furnace, .64-or-greater water heater) with less efficient equipment? If so, please summarize the
results and provide all executable electronic workpapers. If not, why not?
REQUEST NO. 21: According to the Company's response to a prior IRP production
request, the Company sets its DSM rebate amount no higher than 30% of the incremental cost of
the upgrade. Does the Company stil set its DSM rebate amount no higher than 30% of the
incremental cost of the upgrade? As par of your response, please provide all executable
electronic work papers supporting 30% of the incremental upgrade cost as the appropriate rebate
amount. Also include an explanation of whether this includes installation costs. If installation
costs are included, how often are they evaluated?
REQUEST NO. 22: When evaluating the 2008 IRP, Staff asked how the Company
determines its avoided cost when evaluating curent and future DSM (Production Request No.
24). In response, the Company stated "at a minimum, the benchmark for DSM savings would be
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 5 OCTOBER 28, 2010
based on the then current WACOG of$.63583 per therm." Since storage facilities offset more
expensive winter purchases, and increase the Company's abilty to meet a design day, why hasn't
the Company included the costs of Jackson Prairie, Clay Basin, Plymouth Liquid Storage, and
Nampa LNG storage as par of the avoided cost? If storage costs are included in some tests but
not others, please explain.
REQUEST NO. 23: Why have the forecasted market penetration rates dropped
compared to the 2006 and 2009 IRPs? In your response, please explain how conditions have
changed or why IGC has been too optimistic in the past. Also, how does the Company plan to
reevaluate its initiatives to increase market penetration?
REQUEST NO. 24: Has the Company analyzed the penetration rates of gas fireplaces,
stoves, and barbecues? If so, please summarize the results and provide all executable electronic
workpapers. If not, why not?
REQUEST NO. 25: On page 36, regarding the inabilty to forecast GS price elasticity,
the Company states "in reviewing the statistics of the model, it appeared that perhaps something
was influencing usage that was not being captured by the weather variable alone. The GS
customer class is very diverse, ranging from office buildings all the way up to small food
processors. The statistical 'noise' created by this diversity may have made it difficult to isolate
the tre response to price." Please provide an explanation of how the Company plans to improve
its modeling of the GS customer class price elasticity.
REQUEST NO. 26: On pages 37 and 38, regarding the equipment malfunctions on the
SVL and IFL, please explain why the malfuctions occured, and why the 2003/2004 SVL and
2005/2006 IFL winter data was lost. As par of your response, please explain whether the
equipment malfunctions had anything to do with the 2005/2006 SVL winter data being too low,
and eventually being removed from the data set.
REQUEST NO. 27: On page 63, regarding the biofuel test facilties, the Company states
"Idaho is one of the nation's largest dairy producing states which makes ita prime location for
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 6 OCTOBER 28, 2010
biogas production." It then goes on to state, "These test facilities have proven the abilty to
produce acceptable pure natural gas, but currently do not transfer any product into Intermountain
facilties." Does the Company plan to integrate biofuel facilties into its existing resource
portfolio? If so, please explain. If not, why not?
REQUEST NO. 28: On page 70, regarding the Company's encouragement for customers
to consider high effciency equipment replacements, the Company states "IGC customer
communications, mass-media advertising, website, and marketing information all encourage
customers to consider high-efficiency equipment when making their equipment purchases or
upgrade decisions." Please describe how the Company estimates the impact of this advertising
(e.g. - hold out sample, customer surveys).
REQUEST NO. 29: On page 70, regarding the hard copy distribution of the Energy
Conservation Brochure, the Company states the "hard copy is also available at all of our customer
contact offices throughout the IGC service terrtory." Please provide an explanation of where
these customer contact offices are located thoughout the service territory and how often they are
utilzed.
REQUEST NO. 30: On page 75, regarding the 2007 "Audit Results," do the table's
blan cells under "Dead Meters" and "Gas loss occurences due to line damage," indicate zero
occurences? If this does not indicate zero occurrences, why is the information not available?
REQUEST NO. 31: On page 76, regarding non-energy benefits in the total resource cost
(TRC) test, the Company states "Non-energy benefits may include, for example, water savings
from low-flow showerheads and higher efficiency clothes washers or reductions in maintenance
costs." Has the company evaluated the impactofDSM on decreasing uncollectible expenses?
REQUEST NO. 32: On page 77, regarding core-market DSM, the Company states "the
IPUC ordered IGC not to deploy any Core-market DSM programs." Please provide the Order
number and specific Order language. If this language is not specifically used by the IPUC in an
Order, please explain why this is the Company's interpretation.
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 7 OCTOBER 28,2010
REQUEST NO. 33: On page 79, regarding the potential implementation of additional
programs, the Company states "water heater conversions, and the furnace/water heater upgrades
would be deployed in a pilot program on the Idaho Falls lateral in Calendar 2011." Please
explain:
a) How the Company will encourage pilot program paricipation and evaluate the
results prior to full implementation (e.g. - target marketing, internal processes).
b) How many customers would be included in the pilot program (e.g. - selected
samples, entire lateral).
c) Whether the Company has considered deploying the pilot across its service
territory or in other areas (e.g. - SVL).
REQUEST NO. 34: When the Company evaluates the "Low Usage Reports," comparing
biled consumption against the same customer's historical usage patterns, what difference causes
the account to be "flagged" and a courtesy phone call made? In your response, please include an
explanation of what historical data is used, and how the Company determined the difference
threshold to initiate a couresy phone call.
REQUEST NO. 35: On page 90, regarding the various agencies the Company continues
to parner with regarding conservation information outreach, please provide the names of these
agencies and the Company's role in the parnership.
DATED at Boise, Idaho, this iß~day of October 2010.ß~
Weldon Stutzman
Deputy Attorney General
(
Technical Staff: Matt Elam
i:umisc:prodreq/intgIO.4wsme prod reql
FIRST PRODUCTION REQUEST TO
INTERMOUNTAIN GAS COMPANY 8 OCTOBER 28,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF OCTOBER 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-1O-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
KATHERINE BARNARD DIR
MANAGER REG AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: Kathie.barard(ßcngc.com
~.\(
SECRETARY
CERTIFICATE OF SERVICE