20161109Staff 200-225 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
REC IVED
2D/S 1:0'. -9 PH 4: 18
I ' . ' . ·>L .1..~ . ·~'1,/,.;1SSIOtJ
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMP ANY'S APPLICATION TO CHANGE ITS )
RATES AND CHARGES FOR NATURAL GAS )
SERVICE. )
)
)
)
) __________________ )
CASE NO. INT-G-16-02
NINTH 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; Company) provide the following documents and information as soon
as possible, and no later than WEDNESDAY, NOVEMBER 30, 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 .
NINTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 NOVEMBER 9, 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. 200: In its Meter Study, the Company identifies three different meter
groups. Please explain the rationale for these groups, and how they are used in the Company's
Cost-of-Service study.
REQUEST NO. 201: In its supplemental response to Staffs Production Request No. 27,
the Company provided per-customer consumption for the period October 1989 through March
2015. Please: (1) explain the source for the consumption data and numbers of customers used to
determine per-customer consumption; (2) identify and explain all adjustment and data processing
that was performed on these numbers; and (3) provide workpapers, with in-tact links, showing how
per-customer consumption was obtained from the original source data.
REQUEST NO. 202: Please provide a breakdown of Capital Expenditures in FERC
accounts 380,381,382,383, 384, and 385 and by existing rate class.
REQUEST NO. 203: Please describe: (1) the procedures the Company uses to notify
interruptible snowmelt service customers (IS-Rand IS-C) that their service will be interrupted; and
(2) the method the Company uses to interrupt these customers' service.
REQUEST NO. 204: Please describe the criteria the Company uses to decide whether to
interrupt service to its interruptible snowmelt service customers (IS-Rand IS-C).
REQUEST NO. 205: Please provide the dates and circumstances that have resulted in
interrupted service to the Company's snowmelt customers (IS-Rand IS-C) since these tariffs were
implemented.
NINTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 NOVEMBER 9, 2016
REQUEST NO. 206: Please provide total expenses for each year from 2011 to present for
each of the cost categories mentioned in Exhibit II and Exhibit III of the MDU Cost Allocation
manual. Please break out these expenses into the following categories:
• Salary and payroll costs
• Operations & Maintenance
• Depreciation
• Return on Investment
REQUEST NO. 207: Following up on Staff Production Request No 7, please provide a
schedule showing where each employee code and salary is applied by FERC accounts.
REQUEST NO. 208: Please provide copies of all invoices (not Purchase Orders) for:
(1) encoder receiver transmitter (ERT) additions totaling $4,630,982, and Meter additions totaling
$802,819.
REQUEST NO. 209: For miscellaneous Revenue Account (Account #488-4880), please
provide supporting documentation for monthly recurring Intercompany AR entries and IGC Tran
entries totaling $606,844. If an entry occurs monthly for the same amount, please provide only one
month's documentation.
REQUEST NO. 210: For Account Initiation Charge Account (Account #488-4883), please
provide supporting documentation for monthly recurring IGC Tran entries totaling $481 ,284. If
entry occurs monthly for the same amount, please provide only one month's documentation.
REQUEST NO. 211: For Interest on Past Due Accounts (Account #488-4885), please
provide supporting documentation for: (1) monthly recurring IGC Tran entries totaling $367,312. If
entry occurs monthly for the same amount please provide only one month's documentation; and (2)
forecasted data in test year (Jul-Dec 2016) totaling $139,696.
REQUEST NO. 212: For Reconnection charge (Account #4880-4884), please provide
supporting documentation for Forecasted data in test year (Jul-Dec 2016) totaling $8,162.
NINTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 NOVEMBER 9, 2016
REQUEST NO. 213: On page 6 of Mr. Gilchrist's testimony, he mentions the
implementation of ER Ts on customer meters. Please: (1) describe in detail the Company's ER Ts,
including how usage data is managed, reported and archived; (2) explain and provide the criteria to
select a particular ERT manufacturer; and (3) provide all benefit-cost analysis and all RFQs or RFPs
associated with the implementation of ER Ts.
REQUEST NO. 214: Staff understands that AMI (Advanced Metering Infrastructure)
could benefit gas utilities by providing lower meter reading cost, hourly usage information, remote
communication, reduced labor cost, reduced vehicle cost, and detailed system analytic benefits. Did
the Company consider implementing AMI? If not, please explain why not. If so, please provide the
analysis and explain the results.
REQUEST NO. 215: As a follow-up to Staff Production Request No. 76, please provide:
(1) a detailed narrative project description for work order numbers 207889, 207890, 193836,
229153, 208536, 218433, 48535051 , 219873, 228933, and 229606; and (2) the rationale or business
need for each project. 1
REQUEST NO. 216: Has the Company estimated how many customers are switching fuel
(gas to electric, or electric to gas) in each class, and the average per-customer impact (in therms)?
If so, for each class please provide the estimates along with the historical data used to derive the
estimates. If not, please provide at least five years of historical data and explain why the Company
has not estimated how many customers are switching fuels in for each class.
REQUEST NO. 217: Ms. Spector states, on page 8 of her testimony, that the Company
expects to initially budget approximately $225,000 for program outreach and the hiring of a staff
dedicated to DSM support. Please state: (1) how much of the funds will be used for outreach; (2)
how much of the funds will be used to hire DSM staff; (3) the annual percent growth estimate for
program outreach and hiring; and ( 4) the annual percent growth estimate for hiring.
1 Staff asked for the project description and rationale in the original request, but the Company's response was either
incomplete or not provided for each project listed above.
NINTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 4 NOVEMBER 9, 2016
REQUEST NO. 218: Ms. Spector states, on page 9 of her testimony, that the Company
anticipates an initial rebate payment amount of $200,000-$600,000 for the Residential Energy
Efficiency Rebate Program. Please provide annual percent growth estimates for rebate payments.
REQUEST NO. 219: Ms. Spector states, on page 20 of her testimony, that the target DSM
savings for year 1 has been set at 65,000 therms, roughly 66% of Achievable DSM Savings. Does
the Company expect to only reach 66% of Achievable DSM Savings each year, or does the
Company expect to reach higher levels of Achievable Savings in later program years? If the
Company expects to reach higher levels of Achievable Savings in later program years, please
provide estimates of those savings.
REQUEST NO. 220: The Company has developed a levelized target cost of $0.531 for
DSM cost-effectiveness, as described by Ms. Spector on page 21 of her testimony. Is this cost
levelized over the lifespan of the DSM measures? If not, please provide a levelized target cost over
the lifespan of the DSM measures. If this information is not available, please provide an annual
percent growth estimate for DSM cost-effectiveness.
REQUEST NO. 221: Please provide a workbook, with links enabled, showing a
discounted cash flow and net present value of expected DSM costs and savings.
REQUEST NO. 222: Ms. Spector states, on page 22 of her testimony, that the TEAPot
model utilizes a 20-year mortgage rate to determine the average lifespan of measures within the
rebate portfolio (APR of 3.69%). Please provide results of the DSM Rebate Program Analysis
using the Company's proposed Rate of Return of 7.42%.
REQUEST NO. 223: In response to Staff Production Request 63, the Company states that,
each quarter, it reviews the largest commercial (GS-1) accounts to determine if any have grown
large enough to merit large volume service. Staff, however, has been advised informally that
reviews are done less frequently. YTD 2016, how many reviews were conducted, on what dates
were those reviews conducted, and what was the outcome?
NINTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 5 NOVEMBER 9, 2016
REQUEST NO. 224: Please explain in detail the process used to determine whether a GS 1
customer is on the correct rate schedule, or should be moved to a residential schedule or a different
non-residential schedule.
REQUEST NO. 225: In response to Staff Production Request 115, the Company states that
it does not use a therm matrix to estimate annual therms for commercial customers. Instead, it uses
"like entities." Please explain how the Company identifies a like entity. What characteristics of a
like entity are used to estimate consumption?
DATED at Boise, Idaho, this C/ f~ day of November 2016.
Technical Staff: Michael Morrison/200-205
Joseph Terry/206-207
Barbara Romano/208-212
Kevin Keyt/213-215
Bentley Erdwurm/216
Mark Rogers/217-222
Johnathan Farley/223-225
i: umisc: prodreq/intg 16 .2kkscmm jtbrkskbemrj f prod req9
NINTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
Karl T. Klein
Deputy Attorney General
6 NOVEMBER 9, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF NOVEMBER 2016,
SERVED THE FOREGOING NINTH 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 -REGULA TORY AFFAIRS
INTERMOUNTAIN 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 83702
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 83 702
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. l @us.af.mil
[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]
SECRE~f20M__
CERTIFICATE OF SERVICE