20161130INT to Staff 200-225.pdf

WILLIAMS · BRADBURY
November 30, 2016
Jean D. Jewell
Commission Secretary
A T T O R
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702
EYS A T L A W
RE: IGC Response to Staffs Ninth Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
RECE IVED
7.016 .!01.I 30 PM Lt: 00
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Response to Staffs Ninth 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,
j)wk/ L tJ.Ji.-_
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -www.williamsbradbury.com
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
RE CEIVED
2016 WW 30 PH 4: 00
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. -" .. -. -.• ' .,. ,! f ii(' C IO I 1 _ . • ,,, , ti r 11 u ,) ,
BEFORE THE IDAHO PUBLIC UTILITES 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
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO NINTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and in response to the Ninth Production
Request of the Commission Staff to Intermountain Gas Company dated November 9, 2016,
herewith submits the following information:
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.
RESPONSE TO REQUEST NO. 200:
The three different meter groups represent the type of meter. As included in the file
submitted as part of Production Request No. 33, "PR 33 2015 Meter Study.xlsx "; Group I are
positive displacement diaphragm meters ("meters ''), Group 2 are turbine meters, and Group 3
are rotary meters.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page I
Group 1 meters are generally used in residential and small commercial applications.
Group 2 turbine meters and Group 3 rotary meters are most commonly used in large commercial
and industrial applications. lntermountain used Group 1 meters to create a weighted customer
allocator (WEIGHTED]) that was used to allocate costs included in Ratebase accounts,
1010.3810, 3820, 3830, and 3840. It was also used to allocate the O&M accounts 4010.28780
and 28783 as well as 4020.28930.
lntermountain combined Group 2 and Group 3 meters to create a weighted customer
allocator (WEIGHTED2) that was used to allocate costs included in Rate base account
1010.3850.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
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.
RESPONSE TO REQUEST NO. 201:
(1) The source for the usage per customer data provided in response to Production
Request No. 27 is the Company 's Weather System that is explained in detail as part of
Production Request No. 151. The data housed in that system originated from the Company's
billing database.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 2
(2) As Production Request No. 151 outlines, the data housed in the Weather System is
downloaded from the Company 's billing database based upon a certain set of parameters.
Therefore, no data processing was performed on these numbers. The Company does not include
therm adjustments/cancel-rebills in the usage per customer data loaded into the Weather System.
Beginning in July of 2004, the Company also limited the customer count to those customers with
therm usage. Although the Company provided all the data that resides in its Weather System
database, only datafrom October 2003 -December 2014 was used in the development of the
regression equations.
(3) The calculations for usage per customer are performed internally in the Company 's
Weather System software. The customer information system database was queried to select
customers and therms based on the parameters outlined in lntermountain 's reply to Production
Request No. 151. The query data that was extracted from Jntermountain 's CJS systems and that
was used in the calculation of usage per customer is included with this response as "PR 201
WTHRO 120 1989-2016csv.xlsx ".
The definitions of the file heading are as follows:
bill _rate_ class is the rate class (RS-1 = 1; RS-2 = 2; GS = 11)
bill_ nbr _services is the number of services (customers)
bill_ nbr _therms is the number of therms
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
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.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 3
RESPONSE TO REQUEST NO. 202:
Please see the CD file labeled "PR #202 Plant Act Bats YTD Sep 2016.xlsx "for the
breakdown of actual account balances for January through September 2016. For the forecasted
months of October -December 2016, please refer to file "Gas Plant in Service.xlsx" submitted
in response to Production Request No. 178.
Intermountain 's accounting records have never provided the functionality to track plant
and accumulated depreciation by rate class for FERC accounts 380, 381, 382, 383, 384, and
385. Since this type of direct assignment was not possible, Intermountain chose to use an
industry accepted practice to allocate these accounts to the various customer classes.
Because Intermountain can associate its meters in service with a customer class, the
Company was able to determine the number of each type of meter currently installed for each
rate class. Intermountain then valued those meters at the current replacement cost for each
meter. The total current cost of the meters for each class was calculated and then averaged by
the number of meters in each class. That average meter cost was indexed and then multiplied by
annual customers to create a weighted customer allocator. The weighted customer allocator
was split into Group 1 and Group 2 categories as outlined in the response to Production Request
No. 200. The calculation of the weighted customer allocator was included in response to
Production Request No. 33, "PR 33 2015 Meter Study -CONFIDENTIAL.xlsx ". These
allocators were used to assign the FERC accounts 380-385 to Intermountain 's customer classes.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Ted Dedden, 208-377-6000
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 4
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.
RESPONSE TO REQUEST NO. 203:
(I) The Company uses the procedures outlined in its tariffs (see JS-R Section 5 and
JS-C Section 4) to notify customers in the event that their service will be interrupted. Per those
sections of the tariffs, the Company will provide a minimum of two hours notification prior to
interrupting Customer 's Snowmelt application using the Customer 's preferred method of
communication (telephone or email). The communication will contain the Company's best
estimate of the time and duration of interruption. A subsequent notice will be made when the
service has been restored.
(2) A service work order is used to schedule and perform an interruption to a
Customer 's Snowmelt application. Company personnel will use a Customer provided remote
on/off electrical switch to the Snowmelt equipment or use Company metering assemblies to
ensure service has been interrupted. When restored to service, the Company will, if necessary,
relight and/or recycle applicable Snowmelt equipment.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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).
RESPONSE TO REQUEST NO. 204:
The Company would choose to interrupt service if a system load reduction is needed to
maintain service to Customers falling under a firm service tariff. The company uses pressure
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 5
monitoring equipment along with weather forecasting to help identify a situation when
interruption could be needed.
Record Holder:
Location:
Sponsor/Preparer:.
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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.
RESPONSE TO REQUEST NO. 205:
There are no dates or circumstances that have resulted in interrupted service to the
Company's snowmelt customers (IS-R and IS-CJ.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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
RESPONSE TO REQUEST NO. 206:
Please see file folder labeled PR #206. Please note there are no Depreciation or Return
on Investment components of MDUR and MDU cost pools.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 6
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.
RESPONSE TO REQUEST NO. 207:
Raw data related to Production Request No. 7, was provided/or Request No. 165 in
spreadsheet form . This data can be used to identify salaries by employee; by FERC account.
FERC accounts are found in column "R" titled "Sub ". Blank accounts have an "Obj Acct" with
a leading "O " which identifies the time as Capital Project related as discussed in Request No.
165.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Craig Pulley, 208-377-6000
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 208:
The company has requested an extension through 12/ 1 I 16.
Record Holder:
Location:
Preparer/Sponsor:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 7
RESPONSE TO REQUEST NO. 209:
Please see file labeled "PR #209 "for sample bill and bill processing invoices.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 210:
Please see file folder labeled "PR #210. "
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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.
RESPONSE TO REQUEST NO. 211:
Please see file folder labeled "PR #211." The 2016 forecasted reconnection charge was
based on the actual 2015 amounts for the same months as demonstrated in the attached
spreadsheet.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 8
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.
RESPONSE TO REQUEST NO. 212:
Please see file labeled "PR #212 Reconnection Charge forecast. " The attached
spreadsheet provides the forecasted amounts for July through December 2016 which is based on
the actual 2015 amounts for the same months of July through December.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
REQUEST NO. 213: On page 6 of Mr. Gilchrist's testimony, he mentions the
implementation ofERTs on customer meters. Please: (1) describe in detail the Company's
ERTs, 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.
RESPONSE TO REQUEST NO. 213:
(I) Detail Description of Company ERTs: JGC is in the process of replacing the
legacy 40G ER Ts with the new 1 OOG ERT. The preponderance of ERTs will be replaced during
this project scheduled to be completed in 201 7. These remaining ERTs are planned to be
replaced along with the legacy meters by the end of 2020. The 1 OOG ERT maintains the core
design features of the 40G series, but has improved features to allow for more efficient mobile
reads and an economical migration path to fixed network operations. Increased transmit power
allows a Mobile Automatic Meter Reading (MAMR) truck to skip streets along the route and still
maintain a read rate similar to that achieved with the 40G series. The 1 OOG ERT has data
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 9
logging capabilities which allows it to store the most recent 40 days of interval data.
The I OOG ERT module can be reconfigured to connect to a fixed network system. JGC is
piloting a.fixed network in Boise, and if successful is planned to be deployed company-wide by
the end of 2020. In a fixed network, reads can be requested at the time the module bubbles-up
allowing collection of same day and move-in/move-out readings. Network communication
reduces the need for truck rolls and provides better customer billing accuracy. Network
connectivity also allows near real-time tamper event reporting from the module. This
functionality can help in the effective investigation and reduction of energy diversion. The
corporate meter data system can store 400 days of data, so on any given day as long as the ERT
is heard on the fixed network the Company can retrieve the last 400 days of ERT readings. This
makes the I OOG ERT gas modules valuable in providing an additional data source to assist in
the investigative process following an outage.
From a mechanical perspective, the I OOG ERT offers a mechanical, electronic, and
battery design-life of 20 years. Other significant mechanical improvements over the 40G ERT
include: long-lasting molded Santoprene gaskets replace cork gaskets and improved wriggler
design on all residential direct mount ERT modules, thus helping to reduce the number of billing
errors as a result of ERT failures going forward. I OOG ERT deployment does not require an
FCC license. The I OOG ERT operates in bubble-up mode in the unlicensed ISM band. As long as
40G series ERTs are being read in any route, the wake-up signal requires an FCC license. In the
mixed system that JGC currently has (40G series and I OOG ERT modules), JGC will keep the
required FCC licenses up-to-date.
Usage Data, Managed, Reported and Archived: JGC 's current FCS system is designed
to capture monthly reads for billing purposes. Meter read data is also collected by JGC meter
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page IO
readers driving trucks equipped with a MAMR system. The collected reads are transmitted by a
mobile interface application to the Field Collection Service (FCS). The FCS can capture 6 days
of reads maximum. Then the reads are sent from FCS to the CIS system, Customer Care and
Billing (CCB); where the billing process occurs. The meter read information is achieved and
reports are created in CCB. CCB stores monthly read data and CCB data is backed up and
archived indefinitely.
(2) JGC was utilizing !TRON for the legacy ERT program (40G ERTs). The new
1 OOG ERT is an !TRON product and was compatible with existing MAMR equipment, handheld
ERT programmers/meter reading devices, meter reading software, inventory systems and billing
systems. Changing to a different ERT manufacturer would have been too costly due to the need
to replace all of the supporting systems (Approximately $1.5Mfrom 2003 project). Additionally,
!TRON is an industry leader and has proven to be a reliable manufacturer of ERTs for JGC
through the 15 + year relationship. It is critical to use proven technology when we are dealing
with a system that reads meters and ultimately effects customer billing accuracy.
(3) JGC originally selected !TRON in the late 1990 's, early 2000 's because !TRON
was the only major manufacturer that had a proven option for an ERT implementation.
Additionally, during the original deployment in 2003, JGC had already field tested the 40G ERTs
along with the equipment to read the ERTs in small quantities.
There are multiple considerations when evaluating the cost-benefit of the new 1 OOG ERT
project. The first consideration is the 1 OOG ERT project is a replacement of the legacy ERTs, so
it is not a new business case. The original 40G Legacy ERT project was implemented in 2002-
2003. This original AMR project increased JGC meter reading efficiency and had a 5-year
payback and AMR continues to provide efficiency gains.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 11
The primary drivers for replacement of the legacy 40G ERTs is that they nearing the end
of battery life (12-15 years), and are no longer being manufactured. Waiting/or 40G ERTs to
fail before replacement would cause an increase in billing adjustments, billing errors, estimated
usage and all the administrative work to ensure customers understand how their bill was
affected. Proactively replacing the 40G ERT before failure increases replacement efficiency
and overall customer satisfaction.
Battery replacement of the 40G is not a viable option; as the design life on the 40G is 20
years, so the new battery would outlive the life of the unit. Additionally, the 40G ERT contains a
small amount of mercury, so the retiring and proper disposal of the entire unit reduces the
chance mercury could spill into the environment. In summary, the time and money invested in
battery replacement is significant and provides no long term benefit.
Proactively replacing the 40G ERT with a 1 OOG ERT provides several advantages. The
Bubble up mode with the 1 OOG model allows for a longer battery life, and the higher power
allows for greater distances to read ERTs. The 20-year battery life matches the design life and is
mercury free. The updated housing optimizes antenna performance and maximizes RF signal.
Installation is easier than the legacy 40G ERT because of an improved wriggler design. The
JOOG ERT's biggest benefit is the ability to work on a fixed network meter reading system.
JGC is planning to phase in a fixed network for meter reading over the next 2-5 years.
This fixed network is designed to allow for meters to be read at any time from fixed locations
throughout the service territory. This allows for improved efficiency in reading meters in two
primary ways. The first is the reduction of 90-95% of JGC 's current mobile meter reading drive
routes. The second is the elimination of service trips for reading meters when customer move in
and out of homes. Additionally, real-time meter read data analytics allow for improved business
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 12
decision making regarding customer usage. Finally, the estimated overall increased efficiency
of fixed network results in a 10-12 year payback on the fixed network investment.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Hart Gilchrist, 208-377-6000
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.
RESPONSE TO REQUEST NO. 214:
The 1 OOG ERT allows for more AMI functionality and JGC is planning to phase this
functionality in over the next 3-5 years. JGC describes the JOOG ERT and fixed network
capabilities in Request Number 213. JGC is planning for a fixed network meter reading system
to be in place by the end of 2020. See the following excerpt from ITRON 's literature on fixed
network:
Itron 's latest fixed-network collector, the CCU 100, supports the needs of today 's
evolving utility by providing two-way communication to endpoints and to the
repeater to collect on-demand reads and issue network commands. It provides
robust collection of time-synchronized interval data, when coupled with a meter data
management system, helps utilities improve customer service, refine forecast
consumption, manage and control tamper and theft, synchronization of endpoint
clocks, ensuring data collected territory-wide is accurately time-stamped, and
retrieval of missing interval data in the event of a network outage.
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 13
This system will be capable of reading approximately 95% of the meters with a maximum
read frequency of 60 seconds per read. The 100G ERT (in data logging mode) is capable of
storing up to 40 days of data. The data logging mode can be used for the 5% of the meters not
read by the fixed network. This data can be downloaded by mobile truck read and uploaded to
the system. The read data can then be used for gas analytics capable of AMI functionality.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-377-6000
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
RESPONSE TO REQUEST NO. 215:
Work Order 207889 (Residential ERT Purchase) and Work Order 207890 (ERT
Installation) are work orders for the 40G ERT replacement project. The 40G ERTs have a
design life and battery life of approximately 15 years. JGC is replacing the ERTs with 1 OOG
ERTs to avoid an increase in ERT failures, causing unwanted billing errors and costly service
trips to investigate and replace dying legacy ERTs. JGC hired ITRON to manage the
replacement of the ERTs. ITRON is in the last phases of the installation project and will be
completed with their portion of the project in early 201 7.
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.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 14
Justification ... The original 40G Legacy ERT project was implemented in 2002-2003.
This original AMR project increased JGC meter reading efficiency and had a 5-year payback
and AMR continues to provide efficiency gains.
The primary drivers for replacement of the legacy 40G ERTs is they nearing end of
battery life (12-15 years), and are no longer being manufactured. Waiting for 40G ERTs to fail
before replacement would cause an increase in billing adjustments, billing errors, estimated
usage and all the administrative work to ensure customers understand how their bill was
affected. Proactively replacing the 40G ERT before failure, increases replacement efficiency
and our overall customer satisfaction.
Battery replacement of the 40G is not a viable option; as the design life on the 40G is 20
years, so the new battery would outlive the life of the unit. Additionally, the 40G ERT contains a
small amount of mercury, so the retiring and proper disposal of the entire unit reduces the
chance mercury could spill into the environment. In summary, the time and money invested in
battery replacement is significant and provides no long term benefit.
Proactively replacing the 40G ERT with a 1 OOG ERT provides several advantages. The
Bubble up mode with the 1 OOG model allows for a longer battery life, and the higher power
allows for greater distances to read ERTs. The 20-year battery life matches the design life and is
mercury free. The updated housing optimizes antenna performance and maximizes RF signal.
Installation is easier than the legacy 40G ERT because of an improved wriggler design. The
JOOG ERT's biggest benefit is the ability to work on a fixed network meter reading system.
As discuss prior, JGC is planning to phase in a fixed network for meter reading over the
next 2-5 years. This fixed network is designed to allow for meters to be read at any time from
fixed locations throughout the service territory. This allows for improved efficiency in reading
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 15
meters in two primary ways. The first is the reduction o/90-95% of our current mobile meter
reading drive routes. The second is the elimination of service trips for reading meters when
customer move in and out of homes. Additionally, real-time meter read data analytics allow for
improved business decision making regarding customer usage. Finally, the estimated overall
increased efficiency of fixed network results in a 10-12 year payback on the fixed network
investment.
Work Order 193836-Datum 6 Cycle Gas Compressor. Project Description ... purchase
and installation of a new two stage Datum 6 Cycle Gas Compressor located at the Nampa LNG
Plant. The Datum 6 compressor replaced the old, obsolete MG-2 compressor that was placed in
service in 1974 when the Plant was built.
Justification ... the Datum 6 is an integral part of the liquefaction process and
compresses and circulates a nitrogen/methane mixture that is used as a "refrigerant" to cool
methane gas into LNG. The MG-2 was an outdated, obsolete type compressor that was being
phased out with limited support from the manufacturer. It was not cost effective to repair the
shafts, bundles and rotors due to 1) outdated design, 2) limited resources capable to perform the
repairs, 3) long lead time on materials and 4) extreme repair costs.
The new Datum 6 Compressor is more efficient providing a 15% -20% increase in daily
LNG production and is supported by the manufacturer with readily available spare parts.
Work Order 229153-Ariel BoiloffCompressor. Project Description ... purchase and
installation of a new four stage Ariel BoilojJCompressor located at the Nampa LNG Plant that
compresses boiloff gas from the LNG tank at approximately 0. 75 psig up to 500 psig required for
delivery into the Nampa Distribution System. The new Ariel compressor will replace the JOY
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 16
boilojf compressor as the primary compressor and the JOY compressor will become the backup
boilojf compressor.
Justification ... the existing JOY compressor was installed in 1979 and is at the end of its
useful life. The JOY compressor requires increased maintenance on the valves and cylinders due
to the high operating temperature in the 3rd stage cylinders. Continued maintenance has not
lowered the temperature in the 3rd stage cylinders thus rendering the JOY unreliable and
susceptible to high temperature shutdowns. The JOY also consumes large quantities of
lubrication oil which increases the chance of oil getting into the distribution system.
The Ariel compressor will 1) increase reliability, 2) operate more efficiently due to the
variable frequency drive motor and 3) reduce maintenance costs.
Work Order 208536 Burley One Gate Station. Project Description ... upgrade and/or
replacement of 1) measurement and regulatingfacilities, 2) new odorizer and 1,000 gallon tank
and 3) new communications and SCADA equipment at the Burley One Gate Station to increase
capacity and deliverability into the Burley Distribution System. Williams Northwest Pipeline
removed their regulatingfacilities and installed new metering facilities to allow delivery of
pipeline pressure into Intermountain Gas ' new regulation facilities.
Justification ... the Burley One Gate was approaching capacity thus requiring an
upgrade to the gate station. Peak day flow in 2014 through the gate was projected at 11,470
dekatherms per day (Dth/day) which became a risk of exceeding the Williams Northwest Pipeline
stated gate station capacity of 11,621 Dthlday. Exceeding the Williams capacity ran the risk of
reduced capacity and deliveries into the JGC system thus putting our customers at risk by not
being able to meet customer demand. As a result of the station upgrade, the Burley One Gate
capacity increased to 25,000 Dth/day.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 17
Work Order 218433 Burley Two Gate Station. Project Description ... upgrade and/or
replacement of 1) measurement and regulatingfacilities, 2) new odorizer and 1,000 gallon tank
and 3) new communications and SCADA equipment at the Burley Two Gate Station to increase
capacity and deliverability into the Burley #2 high pressure system. Williams Northwest
Pipeline removed their regulating facilities and installed new metering facilities to allow
delivery of pipeline pressure into lntermountain Gas ' new regulation facilities.
Justification ... the Burley Two Gate Station upgrade was required in 2015 to
accommodate increased demand within the distribution system. Previous gate station capacity
prior to the upgrade was 21,890 Dth/ day and JGC 's projected peak day flow is approximately
30,000 Dth/day. Exceeding the Williams capacity ran the risk of reduced capacity and deliveries
into the JGC system thus putting our customers at risk by not being able to meet customer
demand.
Work Order 48535051 -Yi inch plastic services growth for Capital District is the work
order assigned out of Funding Project (FP) 101030 SERV_GROWTH_BOISE. This work order
accounts for all costs associated with Yi inch plastic service line installations including
contractor invoices, material cost, JGC labor and any associated overheads. The installation of
Yi inch service lines are installed at JGC customer premises based on volumetric design criteria
and are necessary to supply customer growth demands throughout the Capital District
distribution system.
Work Order 219873 and Work Order 228933 8" Steel Main Cloverdale. Project
Description (WO 21987 3) ... installation of approximately 1.1 miles of 8 " steel pipe and one
regulator station along Cloverdale Road between Victory Road and Overland Road in Boise.
The overall project was installed in two phases with Phase I in 2015 and Phase II in 2016.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 18
Project Description (WO 228933) ... installation of approximately 1.9 miles o/8" steel
pipe and one regulator station along Cloverdale Road between Overland Road and Fairview
Avenue in Boise. This project is considered Phase II. The overall project is further described in
the Company 's Integrated Resource Plan of which is on file with the PUC
Justification ... the project provides additional capacity into the Central Ada County
area. This area of Ada County is generally located in a 3 -4 square mile section north of
Fairview Avenue and east of Eagle Road. The growth in that area has higher than average
customer usage and experiences higher levels of growth from residential and commercial
development. This pressure betterment provides increased system capacity and reliability to
those customers located in the proximity of the Central Ada County distribution system.
Additional justification would be the backfeed tie-in to the high pressure system fed from
the Nampa Gate. In the event of loss of service from the Nampa Gate, the Cloverdale Project
can maintain service to those customers in north Meridian and south Eagle.
Work Order 229606 Cheyenne Gate. Project Description ... installation of a new gate
station consisting of measurement, regulating and odorization facilities near Williams Northwest
Pipeline located in Pocatello. The Cheyenne Gate Station isfedfrom Williams Northwest
Pipeline and was installed to provide an emergency back feed into Idaho Falls Lateral (IFL) in
the event of a shutdown of either the Idaho Falls Gate Station and/or the 16 " pipeline fed from
the I.F. Gate Station.
Justification ... the Cheyenne Gate receives pipeline pressure from Williams (up to 850
psig) and JGC cuts the pressure to 300 psigfeeding back into the old JO " IFL which ultimately
ties back into the 16" IFL at the old Fort Hall Compressor site. In the event of an emergency,
the Cheyenne Gate is a more reliable than the existing backfeed due to its 24/7 operation and
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 19
increased capacity. While the new Cheyenne Gate is not a I 00% redundant back feed into the
16" !FL and depending on the time of year, the gate can maintain service to the 50,000+
customers on the !FL by reducing the industrial load.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Hart Gilchrist, 208-377-6000
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.
RESPONSE TO REQUEST NO. 216:
The Company tracks customers that convert from other fuel sources to natural gas as
shown in the file "PR 216 Conversions.xlsx ".
Although the residential and commercial conversions are tracked in total, the Company
does not track the fuel source (electric, coal, oil) that customers are converting from. It is
extremely unlikely in today 's energy price environment for a customer to switch from natural gas
to a more expensive fuel source such as electricity. Intermountain uses a 3-year average of the
ratio of conversions to total sales to arrive at the conversion numbers embedded within the
overall total customer forecast. Approximately 2 7% of the residential customer additions are
RS-2 while the remainder are RS-I. The Company applies this same ratio to the total residential
fuel conversions to arrive at the proportion of fuel conversions belonging to each of these
residential classes. This is the same approach that is embodied within Intermountain 's !RP on
file with the Commission.
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 20
The average per-customer impact in therms is the same as the average per-customer
therms used to forecast all other customer usage (see "PR 120 Usage per Customer.xlsx '').
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
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.
RESPONSE TO REQUEST NO. 217:
The Company anticipates allocating approximately $30,000 in the first program year to
outreach, messaging, and trade ally support designed to drive customer participation in the
Company 's DSM program. The remainingfunds will be used to hire two new staff positions
dedicated to DSM support. The budget factors for a Conservation Analyst II, and a Senior
Analyst, with 1.5% added to account for benefits.
At this time, the Company has not developed a percent growth estimate for program
outreach and hiring, as we intend to base this from on-the-ground program results. Our intent is
to drive as much participation as possible with our initial program design, and build from
successes in order to grow staff and budgets as appropriate. A growth-rate estimate developed
today would be extremely imprecise and based off preliminary estimates of what could be
achieved through our program. lntermountain believes it is much more useful to allow the
program to achieve actual therm savings and participation results, and then adjust budgets
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 21
upward commensurate with maintaining an aggressive, but cost effective, DSM effort as
appropriate.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Allison Spector, 206-310-1120
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.
RESPONSE TO REQUEST NO. 218:
As stated in Intermountain 's response to earlier production requests, the Company has
developed preliminary estimates for DSM potential based on modeling a specific set of
residential measures in the TEAPot modeling tool. These numbers provide a starting point from
which a more robust conservation effort can then be developed. Since annual percent growth
estimates for rebate payments will be ultimately based from the ramp rate of DSM participation
levels from year-to-year, viable growth-rate estimates will be more accurately devised following
the first program year, and based from actual on-the-ground program results. Upon completion
of the first program year, the Company may also elect to engage in a formal potential
assessment to better determine ramp-rates and full potential, pending the Company 's ability to
recover such costs as part of DSM program administration.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Allison Spector, 206-310-1120
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
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 22
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.
RESPONSE TO REQUEST NO. 219:
As clarification, the 65,000 DSM savings target developed by the Company is the floor­
level achievement necessary to maintain the cost-effectiveness of the proposed residential
program portfolio based on a program budget of $225,000 and with rebates levels set at
approximately 30%+ of incremental cost. The 65,000 target was based from discussions with
district staff regarding what could be realistically accomplished in the first program year. It is
the safety-net from which the Company can ensure fiduciary stewardship of ratepayer money
while allowing Intermountain to implement an earnest effort to reach the Achievable potential of
97,825 identified in the TEAPot model. In other words, it is the Company 's intent to achieve as
much energy savings as possible in the first, and subsequent program years, but due to the
preliminary nature of the program design, a more comprehensive projection of annual program
savings will not be available until the completion of the first full program year, and subsequent
analysis.
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Allison Spector, 206-310-1120
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
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 23
over the lifespan of the DSM measures. If this information is not available, please provide an
annual percent growth estimate for DSM cost-effectiveness.
RESPONSE TO REQUEST NO. 220:
The levelized cost estimates in the Company's proposed DSM portfolio are calculated
over the lifespan of the measure by discounting the total savings over the measure 's lifespan by
3.69%. The threshold of$0.531 must be met by each measure with the discount rate applied.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Allison Spector, 206-310-1120
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.
RESPONSE TO REQUEST NO. 221:
A link-enabled workbook detailing the discounted therm savings of each individual
measure in the proposed DSM portfolio can be found in Exhibit 26 of Ms. Spector 's testimony
under H20 -H26. This levelized savings was then used to determine the UCT and TRC results
found in F37 -F42 and F50 -F56.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Allison Spector, 206-310-1120
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%.
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 24
RESPONSE TO REQUEST NO. 222:
The Company uses a 20-year mortgage rate to determine the rate at which a measure
should be discounted in our proposed rebate portfolio. The use of a mortgage rate aligns with
the investment in a measure that improves the performance of a residential dwelling. It also
helps reflect the long-term value of long-lived energy efficiency improvements in a home, since
longer-lived measures encourage deeper energy savings over the lifespan of the home. A
preliminary run of the TEAPot model under the discount rate o/7.42% shows an Achievable
potential of 54,696 therms for the portfolio of DSM measures being proposed by the Company.
The proposed portfolio design under current budgets and rebate levels would not be viable under
this discount rate as it would exceed the $0.531 threshold , see CD File labeled "PR #222."
Record Holder: Mike McGrath, 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Allison Spector, 206-310-1120
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?
RESPONSE TO REQUEST NO. 223:
Staff's "informal" advice is incorrect and unwarranted as YTD 2016 at least four (4)
reviews have been run and analyzed (see below).
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 25
2016 Current Analysis Review dates
Date run 12 Mos. Ended Outcome
Identified and contacted three (3)
1 3/7/2016 12/31/2015 potential LV customers. To date, one
has elected LV service, one is still in
negotiation and one did not respond .
Identified and contacted four (4) new
potential LV customers. To date, one
2 4/8/2016 3/31/2016 has elected LV service, two are still in
negotiation and one subsequently
shut-down for a time.
No new potentials identified but
3 7/11/2016 6/30/2016 continued efforts to communicate to
the four (4) potential LV customers.
No new potentials customers
4 10/19/2016 9/30/2016 identified; two that formerly showed
annual usage slightly above 200,000
therms now dropped below 200,000.
Record Holder: Mike McGrath, 208-377-6000
Location:
Sponsor/Preparer:
555 S Cole Rd, Boise, ID 83707
Dave Swenson, 208-377-6000
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.
RESPONSE TO REQUEST NO. 224:
Determination of commercial accounts (GSI) is based on city zoning of the premise.
When a customer calls in for service, the customer service representative will inquiry about the
premise.
Account classification would change if IGC's Marketing staff informs the billing
department of a zoning change to the premise or if the customer calls in to report a change.
RESPONSE OF JGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 26
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Ted Dedden, 208-377-6000
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?
RESPONSE TO REQUEST NO. 225:
The Company makes every attempt to determine the type of commercial entity,
geographic location, square footage, and BTU loads for appliances. The Company finds up to
three similar customers in the Customer Information System -CC&B to determine actual loads.
The actual therm usage for the like customer is used, along with the square footage and BTU
loads, to approximate the estimated annual therm usage for the new commercial customer.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Hart Gilchrist, 208-3 77-6000
DATED at Boise, Idaho, this 30th day of November, 2016.
Respectfully submitted,
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
RESPONSE OF IGC TO NINTH PRODUCTION REQUEST OF COMMISSION STAFF Page 27
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 30th day of November, 2016, I caused to be served a
true and correct copy of the Response oflntermountain Gas Company to Ninth Production Request
of the Commission Staff upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 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 AI)
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 8th 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]
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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: sb [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
Company LLC
Electronic service only:
Dr. Don Reading
E-Mail : [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
2
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Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. J emigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny .zieman. l @us.af.mil
[e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
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Ronald L. Williams