20130607Staff 1-6 to IGC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )coMpANy's 2013-20IT INTEGRATED ) CASE NO. INT-G-13-03
RESOURCE PLAN.)) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN STAFF To
) INTERMOUNTAIN GAS
) COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Intermountain Gas Company (Company)
provide the following documents and information as soon as possible, but no later than
FRIDAY, JUNE 28,2013.
This Production Request is to be considered as continuing, and the 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 will augment the documents or information produced.
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.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS JLTNE 7,2013
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: The Company's Application for authority to sell liquid natural gas
("LNG") says: "[t]he peak day plan from the IRP and other on-going forecasts are used to
determine the amount of Nampa LNG needed for core market peak day withdrawals for each
heating season. Under this request, the remaining tank capacity after core market needs, less a
5002 reserve margin, would be made available for non-utility sales." See Case No. INT-G-13-02,
Application p.4. Given the core market peak day withdrawals forecasted in this Integrated
Resource Plan ("IRP"), please provide the LNG capacity available to meet core market needs
and non-utility sales. As part of your response, please explain whether Large Volume Service
("LV-1") customers are included as core market customers when determining the LNG capacity
available for non-utility sales.
REQUEST NO. 2: Please provide a backcast analysis comparing the actual number of
LV-l customers and their usages to what has been forecasted in the last two IRPs. Similar to the
LV-l comparison, please provide a similar comparison by schedule for all other industrial
customers.
REQUEST NO. 3: Page72 defines lost and unaccounted for ("LAUF") gas asoothe
difference between volumes of natural gas delivered to Intermountain's distribution system and
volumes of natural gas billed to Intermountain's customers." Please explain how the Company
adjusts its LAUF gas calculations for known leaks and line breaks that may occur between the
city gate and customers meters.
REQUEST NO. 4: Several local distribution companies have recently established
protocols to systematically remove and replace select portions of DuPont Aldyl A medium
density polyethylene pipe. Does the Company have this type of pipe on its distribution system?
If so, does the Company have a replacement plan? If so, please provide the replacement plan.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS JLTNE 7,2013
REQUEST NO. 5: In Order No. 32139, the Commission stated the Company "should
provide appropriate notice to city and county leaders as part of the [IRP] process." Please
provide a list of city and county leaders the Company notified of the IRP process. As part of
your response, please provide the number of attendees at each IRP workshop, and any notable
feedback the Company may have received from city and county leaders regarding the IRP
process.
REQUEST NO.6: In OrderNo. 32139, the Commission stated "lntermountain should
carefully consider all DSM programs that are available to encourage customers to use natural gas
efficiently, and Company review of programs must be included in its IRPs. Its IRPs in the future
must reflect that it has evaluated DSM programs for all customer groups." Please provide all
cost-effectiveness tests the Company used in order to evaluate its current and potential demand-
side management ("DSM") programs.
DATED at Boise, Idaho, this |$ day of June 2013.
/4 1-Karl T. Klein
Deputy Attorney General
Technical Staff: Matt Elam/l-6
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FIRST PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS JLINE 7,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7', DAY oF JI.,NE 2013, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-I3-03, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
SCOTT MADISON
EXEC. VP & GENERAL MANAGER
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE