20161006INT to Staff Supplemental 27, 28.pdf

WILLIAMS · BRADBURY
October 6, 2016
Jean D. Jewell
Commission Secretary
ATTORNEYS AT LAW
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE CEIVED
2016GvT -6 PM 1:51
RE: IGC Supplemental Response to Staffs Second Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are one original and two conformed copies of
Intermountain Gas Company's Supplemental Response to Staffs Second Request for
Production, and one CD-ROM that contains the answers and attachments.
Please direct any questions related to the transmittal of this filing to Mike McGrath at
208-377-6168.
Sincerely, . fl~ lJAAi-
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -www.williamsbradbury.com
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 6th day of October, 2016, I caused to be served a true
and correct copy of the Supplemental Response of Intermountain Gas Company to Second
Production Request of the Commission Staff upon the following individuals in the manner
indicated below:
Hand Delivery: (original and 2 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83 707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83 702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83 702
E-Mail : [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 3th Avenue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[2J Electronic Transmission
D Hand Delivery
[2J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[2J Electronic Transmission
D Hand Delivery
[2J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[2J Electronic Transmission
D Hand Delivery
[2J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[2J Electronic Transmission
D Hand Delivery
[2J US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
[2J Electronic Transmission
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: [e-mail]
[e-mail]
Attorneys for NWIGU
Electronic service only:
Michael C. Creamer
Givens Pursley LLP
E-Mail: [e-mail]
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 702
E-Mail: [e-mail]
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
CompanyLLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
~ Electronic Transmission
Ronald L. Williams
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
,E CEIVEO
20160 . -6 Pf I: 52
' ' ,.1 ;:1~;J UC
. ,-:,,_\·: ~1~ISSI ON
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RATES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
)
Case No. INT-G-16-02
SUPPLEMENTAL RESPONSE OF
INTERMOUNTAIN GAS
COMP ANY TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and supplements its response to the Second
Production Request of the Commission Staff to Intermountain Gas Company as follows:
REQUEST NO. 27: Please provide the data and workpapers used to develop the regression
equations described on pages 3-5 of Ms. Blattner's testimony.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 27:
In the data files attached to the original response to PR 27, Intermountain inadvertently left
out the "therms " variable from the 3 data files that were provided. In each of the data files
included as part of this amended response and attached hereto, the therms variable has been
incorporated as Column B. Additionally, a sheet has been added to the front of each file that
provides an explanation of all the variables used throughout the regression study.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath; 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner; 208-377-6000
SUPPLEMENTAL RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Page I
REQUEST NO. 28: Please describe the method and provide the workpapers used to weigh
customer weather data described on page 4 of Ms. Blattner's testimony.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 28:
In an effort to better explain the weather weighting process discussed in the Company 's
initial response to Staff Production Request No. 28, Intermountain submits the following additional
information.
Intermountain contracts with DTN, a private provider, to collect weather data for 7 weather
stations spread across the Company's service territory: Caldwell, Boise, Twin Falls, Sun Valley,
Pocatello, Idaho Falls and Rexburg. The station codes for these weather stations are as follows:
Caldwell = KEUL
Boise= KBOI
Twin Falls = KTWF
Sun Valley = KSUN
Pocatello= KPIH
Idaho Falls= KIDA
Rexburg = KRXE
The weather data is stored in a Sq/Server database. Also stored in the database is
Intermountain 's customer billing data by district. These districts are: Nampa, Boise, Twin Falls,
Hailey, Pocatello, Idaho Falls and Rexburg. The districts are associated with the corresponding
weather station in the database. The customer data is used to weight the weather data so that the
weather used by the Company is weighted by the proportion of customers in each weather region
and billing cycle. The file "PR 28Weighting Factors.xlsx " shows the weighting that results from
the Sql Server process on a total company basis. In this file, "# srvcs" means number of services
which is equivalent to the number of customers.
By way of example, the following formula approximates the process outlined by the SQL
code: Company Weighted HDD65 (or HDD45) = ((Ccu/ cu)* Cndd) + ((Beul cu)* Bndd) + ((I'cu/
cu)* Tndd) +((Seu/cu)* Sndd) + ((Pcu/ cu)* Pndd) + ((!cul cu)* Indd) + ((Reul cu)* Rndd)
Where:
Ccu = Caldwell customers
Beu = Boise customers
Tcu = Twin Falls customers
Seu= Sun Valley customers
Pcu = Pocatello customers
!cu= Idaho Falls customers
Rcu = Rexburg customers
Cu = Total customers
Cndd = Caldwell normal degree days
Bndd = Boise normal degree days
Tndd = Twin Falls normal degree days
Sndd = Sun Valley normal degree days
Pndd = Pocatello normal degree days
Indd = Idaho Falls normal degree days
Rndd = Rexburg normal degree days
SUPPLEMENT AL RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Page 2
The actual code that does the weighting is as follows:
CREATE VIEW [dbo].[TMP_ACTUAL_TEMPS_WEIGHTED_CYCLE_DATE_V]
AS
SELECT bdw .bill_cycle_date, bdw.bill_division ,
bdw .bill_rate_class, tatcd .act_45_sum * bdw .weighted_nbr_services AS
bill_cycle_weighted_a45,
tatcd .act_65_sum * bdw.weighted_nbr_services AS bill_cycle_weighted_a65
FROM dbo .BILL_DATA_WEIGHTED_V bdw INNER JOIN
dbo .TMP_ACTUAL_TEMPS_CYCLE_DATE tatcd
ON bdw .bill_cycle_date = tatcd .cycle_date AND bdw.bill_division = tatcd .division
CREATE VIEW [dbo].[BILL_DATA_WEIGHTED_V]
AS
SELECT bd .bill_cycle_date, bd .bill_division, bd .bill_rate_class, (bd .bill_nbr_services
I (case bds .total_nbr_services when 0 then 1 else bds .total_nbr_services end )) AS
weighted_nbr_services
FROM dbo .BILL_DATA bd
JOIN dbo .BILL_DATA_SUMMARY_V bds
ON YEAR (bd .bill_cycle_date) = bds .bill_cycle_year
AND MONTH (bd .bill_cycle_date ) = bds .bill_cycle_month AND
bd .bill_rate_class bds .bill_rate_class
Note that the BILL_DATA_WEIGHTED _V code is executedfirst.
HDD65 is an industry-wide standard, measuring how cold the weather is based on the
extent to which the daily mean temperature falls below a reference temperature base, which in this
case is 65 degrees (F). HDD45 uses the same calculation as HDD65, but with 45 degrees (F) as
the reference temperature. The calculation of HDD65 is as follows:
65 degrees -mean daily temperature = HDD65
An example of this calculation would be:
High temperature today = 54
Low temperature today= 34
Average of high and low = 44
65 degrees minus 44 degrees = 21 HDD65
SUPPLEMENT AL RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Page 3
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath; 208-377-6000
555 S Cole Rd, Boise, ID 83707
Lori Blattner, 208-377-6000
DATED at Boise, Idaho, this 6th day of October, 2016.
Respectfully submitted,
Rt«11 1-w )JC_,
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
SUPPLEMENTAL RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
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