20150319Staff 1-7 to INT.pdf

KARL T. KLEIN , l'. i; :
DEPUTY ATTORNEY GENERAL
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PO BOX 83720 t:j,, , , i
BOISE, IDAHO 93720-0074 ' ,'l'li.i'i'ii_!', ,,.i, ;l::,;,,,:,,
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S 2015-2019 rNTEGRATED ) CASE NO. INT-G-15-01
RESOURCE PLAN.)) FIRST PRODUCTION
) REQUEST OF THE) coMMrssloN srAFF To
) INTERMOUNTAIN GAS
) COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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 Iater than
THURSDAY, APRIL 2, 2015.1
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
' Staffis asking for an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS I MARCH I9,2OI5
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
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. l: Page 46 of the Integrated Resource Plan (IRP) states: "It should be
noted that during the preparation of the data provided in the survey, it was discovered that the
historical daily [Supervisory Control and Data Acquisition] (SCADA) data indicated that quite a
few of the large volume customer's peak day usage exceeded their actual contract [Maximum
Daily Firm Demand] (MDFQ)." Please describe how SCADA data is monitored, analyzed and
compared to customers MDQF. Please include applicable process descriptions and procedures.
REQUEST NO.2: Page 46 of the IRP states: "The variance between these figures
ISCADA vs. contract MDFQ] were compared and assessed customer-by-customer by AOI with
the assistance of the engineering group to determine which of the customers were located in
geographic areas that currently have available peak day capacity. Where possible, Intermountain
will allow those customers to adjust the contract MDFQ to levels consistent with actual peak day
use. Those located in areas that do not have available capacity will be required to invest in new
facilities in order to increase their MDFQ. The Base Case MDFQ quantities beginning in 2015
include these adjusted MDFQ assumptions."
a) Please provide and explain the adjusted MDFQ assumptions used to develop
the Base Case.
b) For each schedule, please provide the number and percentage of large-volume
customers with peak day usages exceeding their actual contract MDFQ.
c) How many customers does the Company estimate will adjust their contract
MDFQ to levels consistent with actual peak day use?
d) Why are some customers being required to invest in new facilities in order to
increase their MDQF, when historically, the Company has been able to
provide service given their actual peak day use?
e) Based on the Company's assumptions, please describe the estimated financial
impact to all customer classes.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS MARCH 19,2015
REQUEST NO.3: Page 83 of the IRP states: "IGC has participated in [Gas Technology
Institute Research and Development (GTI R&D)] projects, and will continue that collaboration
as the opportunities arise." Please describe how the Company selects which GTI R&D projects
it becomes involved in. As part of the response, please provide the Company's GTI R&D budget
and forecast. If the Company does not have a GTI R&D budget and forecast, please explain how
it accounts for and plans its projects.
REQUEST NO. 4: Page 83 of the IRP states: "In the Fall of 2014, GTI and IGC [the
Company] will collaborate on cold-climate testing of the NextAire natural gas heat pump." On
the same page, the Company also states: "As of Summer 2014,IGC [the Company] is also
working with GTI to collaborate with the Northwest Energy Efficiency Alliance (NEEA) on
Idaho field testing of residential Gas Heat Pump Water Heater (GHPWH)." Please provide a
status update on both projects. As part of the response, please explain whether the Company
plans to include a summary of these projects in the next IRP, If not, please explain why not.
REQUEST NO. 5: Aside from the Company's collaboration with the Gas Technology
Institute (GTI), please describe how the Company works independently with the Northwest
Energy Efficiency Alliance (NEEA) natural gas efforts. As a part of the response, please explain
whether or not the Company plans to be an active member in NEEA's natural gas efforts?
REQUEST NO. 6: Page 83 of the IRP states: "IGC has provided financial assistance to
the University of Idaho Integrated Design Lab to further that entity's energy efficiency research
and training." Please describe the Integrated Design Lab's natural gas research and training. As
part of the response, please provide the historical and forecasted funding levels, and explain how
the Company has applied this research to benefit customers.
REQUEST NO. 7: Page 91 of the IRP states "As a result of the nearly 40% residential
price reduction since 2008, the residential DSM programs previously analyzed for pilot
implementation still will not provide the cost-benefits estimated under the significantly higher
gas prices seen by [the Company] in recent earlier years." Please provide the avoided cost
calculations the Company used to determine that natural gas demand-side management is not
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS MARCH 19,2075
cost-effective. Please provide and explain the assumptions used, including the avoided costs of
additional storage, distibution capacity, and interstate transportation capacity. Please separate
the fixed and variable components of the avoided cost.
DATED at Boise,Idaho, this l4h.yof March 2015.
Karl T. Klein
Deputy Attorney General
Technical Staff: Kevin Keyt
i:umisc:prodrc{intgl4. lkkkk prod reql
FIRST PRODUCTION REQI]EST
TO INTERMOUNTAIN GAS 4 MARCH I9,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF MARCH 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, N CASE
NO. INT.G-15.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P MoGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE TD 83707
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE