20171127Staff 24-29 to INT.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
REC E IVE D
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Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S 2017.2021 INTEGRATED
RESOURCE PLAN.
CASE NO. INT.G-17.04
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attorney General, request that Intermountain Gas Company
(lntermountain Gas; Company) provide the following documents and information as soon as
possible, or by MONDAY, DECEMBER 18,2017.
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 IDAPA
31.0r.0r.228.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
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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. 24: In Production Request No. 2, Staff asked the Company to describe
efforts to obtain public and stakeholder participation in development of the 2017 IRP. In its
response, the Company described how it expanded public participation by adding a fourth
presentation of the IRP. Did the Company conduct any public outreach prior to performing the IRP
analysis? If yes, please describe such outreach. Additionally, please describe any working groups
or forums that the Company utilized as it developed plans, requirements, and assumptions for the
IRP analysis.
REQUEST NO. 25: In its response to Production Request No. 13, the Company states that
it has been determined there is potential for two coal altemative locations throughout the
Company's service territory. Please provide details on the potential alternative coal locations,
including location and potential volume impact on natural gas in therms.
REQUEST NO. 26: In its response to Production Request No. 19, the Company states;
"The replacement project is not growth driven, so the installation timeline may change depending
on capital budget planning and construction workload." Please provide an explanation of what
factors are considered in the capital budget and construction workload processes and how these
factors may impact the installation timeline for the Rexburg Snake River Crossing project.
Additionally, please describe all alternatives evaluated and costs of each for crossing the Snake
River.
REQUEST NO. 27: In its response to Staffs Production Request No. 20, the Company
stated that the Rexburg LNG facility has onsite storage designed to hold two or more days of peak
shaving LNG. Please provide the workpapers, assumptions, and data used to make this calculation
REQUEST NO. 28: Please provide an estimate of the number of days that the Nampa LNG
facility can supply peak shaving LNG. Please provide the workpapers, assumptions, and data used
to make this calculation.
SECOND PRODUCTION REQUEST
TO INTERMOLINTAIN GAS 2 NOVEMBER27,2OI7
REQUEST NO. 29: In response to Staff s Production Request No. 23, the Company stated
that T-3 and T-4 customers do benefit from the Nampa LNG facility, and that "[i]n the event a
curtailment may be needed, the supply of the LNG plant would mitigate the risk of curtailment to T-
3 and T-4 customers." How does the supply of the LNG plant mitigate the risk of curtailment to T-
3 and T-4 customers? Is the Company obligated to provide natural gas from the Nampa LNG
facility to T3 and T4 customers in the event that these customers' upstream capacity and supply
resources are curtailed? If yes, please describe the Company's obligation.
DATED at Boise, Idaho, this L{ aurof Novemb er 2017
0"";xl, I l^^***
CamYe Christen
Deputy Attomey General
Technical Staff: Kevin Kefi Qa-26)
Mike Monison(27-29)
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SECOND PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS 3 NOVEMBER27,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF NOVEMBER 2017,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-17-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
MICHAEL P McGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE