20161230INT 1-17 to ICL.pdf

WILLIAMS · BRADBURY
December 30, 2016
Jean D. Jewell
Commission Secretary
ATTORNEYS AT LAW
Idaho Public Utilities Commission
4 72 W. Washington Street
Boise, ID 83 702
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RE: IGC First Production Request to Idaho Conservation League -Case No. INT-G-16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's First Production Request to the Idaho Conservation League.
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [phone] -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
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
FIRST PRODUCTION REQUEST
OF INTERMOUNTAIN GAS
COMP ANY TO IDAHO
CONSERVATION LEAGUE
Intermountain Gas Company ("Intermountain" or "Company"), a subsidiary of MDU
Resources Group, Inc., by and through its attorney of record Ronald L. Williams and pursuant to
the Rules of Procedure of the Idaho Public Utilities Commission ("Commission"), hereby
requests that the Idaho Conservation League provide the following documents and information
as soon as possible, and no later than Friday, January 20, 2017.
This Production Request is continuing, and Idaho Conservation League 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, and supporting work papers that provide detail
or are the source of information used in calculations. 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. IDAPA 31.01.01.228.
IGC First Production Request to ICL Page 1
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. 1: What specific characteristics of the Company's DSM program make
it "more of a fuel switching incentive than a true DSM program" as stated in Witness Riva's
testimony on page 1, lines 18-21?
REQUEST NO. 2: Is the direct use of natural gas mutually exclusive to a program that
drives upgrades from existing natural gas to high-efficiency natural gas equipment?
REQUEST NO. 3: What specifically in the design of the Company's DSM program
prohibits or discourages customers from migrating from standard efficiency to high-efficiency
natural gas equipment?
REQUEST NO. 4: What "large segment" of the Company's residential customer base,
referenced on page two, lines 3-5 is being ignored by the design of its current rebate program?
REQUEST NO. 5: Does ICL have any recommendations regarding the quantification of
savings achieved through engagement in market transformation efforts such as NEEA?
REQUEST NO. 6: On page 8 lines 8-11, Witness Rivas notes that "generally speaking,
the floor for achievable potential in utility conservation assessments is around 70% of economic
potential." Please provide examples of situations where potential has been assessed under the
Utility Cost Test, that achievable potential reflects 70% of economic potential.
REQUEST NO. 7: Please explain how ICL's proposed portfolio of direct install
showerheads and weatherization, paired with equipment incentives would lead to an anticipated
first-year savings achievement of 1.71 million therms saved during the ramp-up year. Please
provide all working papers and analysis validating this estimate.
IGC First Production Request to ICL Page 2
REQUEST NO. 8: Please provide a detailed description of and examples of similarly
sized natural gas utilities in the region with an achievable residential potential of 1. 71 million
therms in the first program year.
REQUEST NO. 9: Does ICL have a specific valuation methodology its recommends for
quantifying the benefits of Low Income Weatherization Programs? What recommendations does
ICL have regarding treatment of recovery from a regulatory standpoint?
REQUEST NO. 10: In reference to the direct testimony of Diego Rivas, Page 3 L 13-14
that due to additional gas fired electric generation "the price of natural gas would undoubtedly
increase", and Page 4, L 10-11 "[W]e can expect the price of natural gas to increase" please
provide:
a.) All workpapers or documentation relied on to support these statements of expecting
natural gas prices to be rising,
b) At what locations or gas trading hubs in the US would these prices expect to occur?
Are all prices at all hubs expected to rise at the same time and same rate?
c) What are annual natural gas volumes sold in USA, in the northwest and in Idaho?
d) What is the expected annual increase in natural gas sales in Northwest and in Idaho
that are anticipated by Mr. Rivas to be due to fuel switching, projected out for the next 5 years?
e.) Does Mr. Rivas agree or disagree that conservations programs could or do lead to
lower gas sales, in the US, the region or in Idaho?
f.) Does Mr. Rivas agree or disagree that replacement of older gas appliances by new
more efficient ones lead to lower natural gas sales?
JGC First Production Request to ICL Page 3
g) Is it Mr. Rivas' opinion that it is more likely, or less likely, that the volumetric
changes in gas consumption due to conservation and fuel switching affects Idaho, regional or
national gas prices more than or less than changes in the weather?
REQUEST NO. 11: In reference to the direct testimony of Diego Rivas, Page 6 L 6
"high capital cost equipment":
a) At what point does capital equipment become "high cost."
b) What are some of the examples and the costs of "low cost, easy to install" measures
referred to by Mr. Rivas?
c) At what point does the price of equipment become high cost, and a price inhibitor or
barrier for a consumer to purchase such equipment?
d) Please provide any workpapers, data or analysis showing prices for appliances that are
high-cost, low-cost or what Mr. Rivas considers to be median or regular cost.
REQUEST NO. 12: In reference to the direct testimony of Diego Rivas, Page 9 L 20
""decoupling should address forgone fixed cost recovery attributable to utility actions to promote
conservation." Is it ICL's position that revenue decoupling is inappropriate for any reason other
than revenue loss associated with DSM or conservation? IflCL believes revenue decoupling is
also appropriate for other reasons, what would be those reasons?
REQUEST NO. 13: Please explain how "fixed costs" become "volatile" as discussed in
the testimony of Mr. Rivas at page 10, lines 2 and 3.
REQUEST NO. 14: In reference to the direct testimony of Mr. Rivas, P. 11 L 21 "total
gas sales ... will likely increase." Please provide all workpapers or studies relied on to support this
statement?
IGC First Production Request to ICL Page4
REQUEST NO. 15: Referring to Mr. Rivas testimony at page 12, L 17, that of the 25
natural gas decoupled utilities, "19 of them used an annual rate true-up mechanism," would ICL
support a rate true-up mechanism similar to what a majority of other state regulatory
commissions do for natural gas decoupled utilities?
REQUEST NO. 17: In reference to the direct testimony of Diego Rivas, P. 18 L 1
'"'better policy option ... inclining block rate" ... Would I CL support of oppose "budget billing"?
DA TED at Boise, Idaho, this 'J /--day of [)rt f I., ht1 , 2016.
IGC First Production Request to ICL
Respectfully submitted,
~4LlJAA =
Ronald L. Williams v 0
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
Page 5
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 30th day of December, 2016, I caused to be served
a true and correct copy of the First Production Request of Intermountain Gas Company to the
Idaho Conservation League upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 W. Washington Street
Boise, ID 83720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83707
E-Mail: [e-mail]
Brad M. Purdy
2019 N. 1 ?1h Street
Boise, ID 83702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP AI)
Benjamin J. Otto
Idaho Conservation League
710 N. 61h Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 81h 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]
IGC First Production Request to ICL
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
rg) Electronic Transmission
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D Facsimile Transmission D Federal Express
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Page 6
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. 2ih Street
Boise, ID 83702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
CompanyLLC
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 61h St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
IGC First Production Request to ICL
D Hand Delivery
D US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
[8J Electronic Transmission
[8J Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission D Federal Express
[8J Electronic Transmission
D Hand Delivery
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Page 7
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny .zieman. [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Federal Executive Agencies
(FEA)
IGC First Production Request to ICL
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Ronald L. Williams
Page 8