20161102Staff 163-199 to INT.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
R_CEI VED
· ". r·,111 -2 PH 2: 25 .JI V I -~ J
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE ITS )
RA TES AND CHARGES FOR NATURAL GAS )
SERVICE. )
)
)
)
) ___________________ )
CASE NO. INT-G-16-02
EIGHTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (Intermountain Gas; IGC; Company) provide the following documents and information as
soon as possible, and no later than WEDNESDAY, NOVEMBER 23, 2016.
This Production Request is 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 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
different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 1 NOVEMBER 2, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 163: Please explain how gas storage inventory levels are determined.
Furthermore, please explain if the thirteen month average gas storage inventory reflects normal
conditions. If the thirteen month average does not reflect normal conditions, please explain why the
inventory level was not adjusted to reflect normal conditions.
REQUEST NO. 164: Please describe the composition of gas storage inventory to include
an explanation of how operational and contractual obligations impact inventory levels.
REQUEST NO. 165: Following up to Staff Production Request No. 7, please provide the
amounts for each salary category that were applied to capital projects as well as the amounts
allocated to affiliate companies.
REQUEST NO. 166: Following up on Staff Production Request No. 66, please provide
copies of the sources used as mentioned in the Compensation Program Audit -Summary of
Findings, as well as all surveys used since the publication of the document, used in determining
compensation structure and salary increase budgets.
REQUEST NO. 167: Please provide a copy of the "Total Rewards Philosophy" document
mentioned in the response to Staff Production Request No. 66, confidential attachment.
REQUEST NO. 168: Please provide all risk management policies and procedures
surrounding the issuance and use of company owned visa cards. Please include the policy
determining which employees should have Company owned visa cards.
REQUEST NO. 169: Please provide a list of all training events or other classes that
employees attended from 2011 to present. Please include an explanation of the event, number of
employees that attended, and costs associated for each event.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 NOVEMBER 2, 2016
REQUEST NO. 170: Following up on Staff Production Request No. 17, please provide
detail of which controls were tested and the methods used to test those controls.
REQUEST NO. 171: Following up on Staff Production Request No. 18, please provide the
detail write-up of Audit No 119-Corporate Plane.
REQUEST NO. 172: Please provide a listing of all expenses of the Corporate Plane for
2013 to present, both in total and the amount allocated to the Company. Please also include all
flights for the plane and purpose of each flight.
REQUEST NO. 173: Please provide a schedule showing all costs of the Customer Call
Center by FERC category for 2014 to present. Please break out 2015 and 2016 by month. Please
breakout the salary expense by employee category similar to the format done in Staff Production
Request No. 7.
REQUEST NO. 174: Following up on Staff Production Request No. 1, please provide the
following amount for each of the Companies that receive allocations according to the Manual for
2011 to present by year:
• Plant in Service
• Revenues
• Customer Counts
• Employee Counts
• · Total Salary Expense
• Number of Connections
• Net Operating Income
• Income Taxes
• Operation and Maintenance Expense
REQUEST NO. 175: Following up on Staff Production Request No. 71 , please provide all
policies and procedures for risk management for injuries and damages as well as all insurance
policies active during the times these events happened.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 NOVEMBER 2, 2016
REQUEST NO. 176: Following up on Staff Production Request No. 80, please reconcile
the amounts by FERC Accounts to the Actual Data Ending as provided in Exhibit No. 08, page 1.
REQUEST N0.177: Following up on Staff Production Request No. 7, please explain the
reasons for increasing the employee count from 219 to 239 in 2016.
REQUEST NO. 178: Please provide actual data by FERC Account as of September 30,
2016. Also, please provide updated forecasts for the months of October, November and December.
REQUEST NO. 179: Please provide a listing of all expenses removed on Exhibit 15, page
22, line 13, totaling $256,321.
REQUEST NO. 180: Please provide the paper titled: "Natural Selection: The Evolution of
DSM Valuation and the Use of the UCT," referenced on page 2 of Ms. Spector's testimony.
REQUEST NO. 181: Please provide the workpapers used to calculate the cost­
effectiveness ratios for each measure in Exhibit 26. The workpapers should identify the amounts,
values, assumptions, and sources for all calculation inputs, including natural gas and non-natural
gas benefits.
REQUEST NO. 182: Please explain why fuel switching is considered demand-side
management for IGC when it increases natural gas consumption.
REQUEST NO. 183: Please explain why IGC did not include many standard DSM
offerings, including shell/weatherization measures (such as insulation or duct-sealing), smart
thermostats, NEEA's natural gas market transformation effort, a home energy reports program, or
low income weatherization, in its DSM proposal.
REQUEST NO. 184: Commercial and Industrial programs are often more cost-effective
than residential programs because the savings per customer are often larger. With that in mind,
please explain why IGC chose to start with residential DSM.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 4 NOVEMBER 2, 2016
REQUEST NO. 185: Please provide the TEAPot tool in executable electronic format. If
the TEAPot tool cannot be provided, please make it available to Staff.
REQUEST NO. 186: Please provide the total list of measures analyzed in the TEAPot
model.
REQUEST NO. 187: Did the TEAPot study include an analysis of Commercial and
Industrial savings potential? If so, please provide those results. If not, please explain why not.
REQUEST NO. 188: Please provide the complete TEAPot study, including narrative and
workpapers, used to develop the technical, economic, and "Achl " results in Exhibit 25 (DSM
Potential Assessment).
REQUEST NO. 189: On page 11 of Ms. Spector's testimony, she states the TEAPot tool
was developed in 2014 by Nexant for Cascade Natural Gas Corporation. Please provide a full
reconciliation for all the updates made to this model in order to make the study relevant to
Intermountain Gas in 2016. As part of the response, please include updates made to available
technologies, load forecasts, and market segments.
REQUEST NO. 190: Most utilities, even those with extensive DSM experience, hire
consultants to run their Conservation Potential Assessment (CPA) models. Please explain how the
IGC staff had sufficient previous experience with DSM modeling to run the TEAPot model, and
why that was preferable to Nexant running the model.
REQUEST NO. 191: Please explain why the TEAPot study only included a 5-year forecast
of technical, economic, and "Achl " savings when most Conservation Potential Assessments include
a 20-year forecast.
REQUEST NO. 192: What assumptions did IGC use to decrease the Economic potential to
Achievable potential? Please provide all workpapers and supporting analysis.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 5 NOVEMBER 2, 2016
REQUEST NO. 193: According to page 14 of Ms. Spector's testimony, the "Achl " targets
on page 3 of Exhibit No. 25 were developed as a "number blended between the Achievable
Potential estimates modeled in its analysis and further refined by in-depth discussions with IGC
[district] staff regarding the on-the-ground realities oflntermountain's service area." Please provide
a detailed explanation about how the "Achl" targets were developed, including all supporting
workpapers, analysis, and industry best practice citations. This explanation should fully account for
the 96% reduction from Economic to Achl potential.
REQUEST NO. 194: On page 20 of Ms. Spector's testimony, she states that JGC set a first
year target of 65,000 therms. This does not align with the "Achl" first year target of 97,825.
Please provide the quantitative analysis justifying this reduction.
REQUEST NO. 195: Please explain the differences between the "real-world conditions"
used to determine the Achievable Potential and the "real-world constraints" used to determine
Programmatic Potential referenced on page 13 of Ms. Spector's testimony. Please include all
supporting workpapers, analysis, and sources.
REQUEST NO. 196: Did IGC study the potential for commercial and industrial electric to
gas conversions as it developed its DSM proposal? If so, please provide the results of that study.
REQUEST NO. 197: On page 22 of Ms. Spector's testimony, she referenced "on-the­
ground market research performed by the Company." Please provide a detailed explanation of the
market research performed by the Company. Furthermore, please provide all analysis showing how
this market research was used to determine the incremental cost levels.
REQUEST NO. 198: Please provide the trade ally and rebate eligibility guidelines
referenced on page 3 of Ms . Imlach's testimony.
REQUEST NO. 199: For each Large Volume or Transportation customer, please calculate
monthly bills under current and proposed rates based on actual billing determinates from January
2015 through September 2016 (e.g., MDFQ, therms by block). Please break current and proposed
EIGHTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 6 NOVEMBER 2, 2016
bills into demand, cost of gas, and distribution components, as defined in the respective tariffs.
Please state the percentage change in the total annual bill for each customer. Additionally, please
indicate the rate schedule ( current and proposed) under which the customer is served. Please
provide the calculations in executable electronic format, and include all assumptions.
;a,(
DATED at Boise, Idaho, this 2 day ofNovember 2016.
Technical Staff: Kevin Keyt/163-164
Joseph Terry/165-178
Barbara Romano/I 79
Stacey Donohue/180-198
Bentley Erdwurm/199
i:umisc:prodreq/intg l 6.2kksckkjtbrsdbe prod req8
EIGHTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS
Sean Costello
Deputy Attorney General
7 NOVEMBER 2, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF NOVEMBER 2016,
SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR-REGULATORY AFFAIRS
INTERMOUNT AIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83 702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. [e-mail]
[e-mail]
[e-mail]
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: [e-mail]
SECRETARY,
CERTIFICATE OF SERVICE