20200117Staff 1-31 to INT.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOTSE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO.5470
Strcet Address fbr Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 20I-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA'I'TER OF'INTERMoUNTAIN GAS
COMPANY'S 21119 -21123 INTEG RATED
RESOURCE PLAN
cASU NO. INT-(;-l9-07
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staffof the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond, Jr., Deputy Attomey General, requests that Intermountain Gas Company
provide the following documents and information as soon as possible, but no later than
FRIDAY, FEBRUARY 7, 2020.
This Production Request is to be considered as continuing, and Intermountain Gas
Company is requested to provide, by way of supplementary responses, additional documents t]rat
it, or any person acting on its behalf, may later obtain that will augment the documents or
information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
FIRST PRODUCTION REQUEST
TO INTERMOUN'IAIN GAS
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.IANT-IARY 17,2O2O
RECEIVED
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the person preparing the documents. Please also identity the name, job title, location, and
telephone number olthe record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with fbrmulas intact and enabled.
REQUEST NO. l: Please descrihe the process by which the IRP advisory group was
formcd. Additionally, provide the results achieved through IRP advisory group participation in
development ofthis IRP. See OrderNo. 33997.
REQUEST NO.2: Please provide a thorough explanation of how the system growth
rate is determined. See Order No. 33997.
REQUEST NO.3: Please respond to the following regarding the Company's Energy
Ef'liciency (EE) and Demand Side Management (DSM) avoided costs:
a. Explain hou,the Supplement I Drall Avoided Costs is consistent with Order No.
33997.
b. On page 2 of Supplement l, in the Fixed Transportation Costs section, the Company
states that "contracts through 2025 are already committed and so not avoidable."
Were thc contract costs through 2025 rcmoved liom avoided cost calculations? Il
not, why not? Provide a supporting spreadsheet with formulas enabled that shows
how Fixed Transportation Costs were calculated.
c. Explain how Variable Transportation Costs were determined and provide a
supporting spreadsheet with fbrmulas enabled that shows how Variable
Transponation Costs were calculated.
d. Dxplain why the maximum price lrom all three basins was used in the Commodity
Cost calculation.
e. Explain how Distribution System Costs are avoided. Please also provide supporting
evidence that distribution costs are not cunently recovered in embedded rates.
t. Provide an explanation ofthe rationale in the Company's method ("For this IRP
cycle. IGC calculates distribution system costs as its system weighted average of its
authorized margins.") used to calculate distribution costs.
FI RSl' PRODI,JC-f ION REQUEST
TO INTERMOLINTAIN GAS 1 JANUARY 17.2020
g. Please explain and provide workpapers that illustrate how the effects of the
Company's EE and DSM programs are I'actored into the Company's load growth
projections.
h. Plcase provide u,orkpapers showing how the cllbcts ofthe Company's EE and DSM
programs were included in the Company's load grouth projections fbr the Sun Valley
Lateral.
REQUEST NO.4: On pages 65 and 66 of the IRP, a biogas production lhcility is
mentioned as being contracted to start supplying renewable natural gas (RNG) in 2019.
a. Please explain more fully and provide documentation that describes the facility's
volumetric potential, when it may become viable, and a description ofpotential costs
and benefits.
b. Please provide a copy ofthe contract.
REQUEST NO. 5: On page 23, Tabte 4 of the IRP, the Company lists conversion rates.
a. Please provide an explanation of how conversion rates are determincd and calculated
b. Please include a supporting spreadsheet with fbrmulas enabled.
REQUEST NO.6: On pagc 125 of the IRP, the Company discusses State Street
enhancements achieved through pipeline retests. Please provide a detailed description of20l9
and 2022 enhancement projects including costs for each and explain how the costs oompare to all
other viable alternatives the Conrpany considered.
REQUEST NO. 7: On pages 127 and 128 of the IRP, the Company discusses multiple
Canyon County enhancements. Plcasc provide a detailed description including documents and
u'orkpapers fbr the Orchard 2020, Ustick 2021 . and Happy Valley 2022 projects including costs
for each enhanccment and how the costs comparc to other viable altematives the Company
considered.
REQUEST NO. 8: On page 128 of the IRP, the Company discusses the Idaho Falls
Lateral. The Company mentions that compression has been retired on this lateral.
FIRST PRODUC'|ION REQTJESI'
TO INTERMOT-]N'IAIN GAS J JANUARY 17.2020
a. Please describe ifand how compression sites were installed.
b. Please describc how the site(s) could be used by the Company
RXQUEST NO.9: On pagc 129 olthe IRP, the Company stated that a second [,NG
storage tank at the Rexburg LNC F'acility will be added in 2022. Please provide a detailcd
description ofthe LNG tank addition inoluding expected costs and pro.ject timing.
REQUEST NO. l0: On page 127 of the IRP, the Company discusses the Central Ada
Lateral retest it 202l. Please provide a detailed description ofthe projcct including expected
costs and how the costs compare to othcr viable alternatives the Company considered.
REQUEST NO. 12: Please describe the Company's *ork u.ith the IRP advisory group
to determine the most cost-effective solution to all identilled deficits and enhancements for the
State Slrect, Canyon County, Idaho Falls, Sun Valley, and Central Ada Laterals.
REQUEST NO. l3: On page 142 of the IRP. the Company states that about iive miles
of Aldyl-A pipe is replaced pcr year bascd on risk metrics.
a. Please provide details ofhow the Company's risk metrics are calculated and
mcasured.
b. How many feet of pipe by size require replacement.
c. Provide an estimate ofthe annual replacement cost by size and feet ofpipe to be
replaced per year until all at risk pipe is replaced. (i.e., in 2020, 100 feet ol'2 inch
pipe is expected to be replaccd at a cost of $ l.)
FIRST PRODUCTION RLQUEST
I'o IN'I'F]RMOLNTAIN GAS 4 JANUARY 17,2O2O
REQUEST NO. 11: On page l4l of the IRP, the Company describes the Rexburg
Snake River crossing.
a. Please explain why the 2021 favored alternative is "tentatively scheduled".
b. What other alternatives were considered.
c. How the costs compare for each altemativc.
REQUEST NO. 14: On page 140 of the IRP, the Company explains that adding or
upgrading liquefaction capability may be required if the non-utility sales market conlinues 10
grow. Please explain the following:
a. The expansion alternatives availablc.
b. Potential costs ofeach altemative.
c. Describe how an expansion project would be funded ifpursued and what accounting
treatment(s) would be applied.
d. Describe how core customers will be shielded from financial exposure if an
expansion project is pursued for non-utility sales.
REQUEST NO. 15: Please provide a list of avoided and program characterization costs
uscd in the model describcd in Exhibit 4. Exhibit 4 at 4.
RR,QIIEST NO. l6: Please provide a list and delinition of each barrier reduction
invcstment the Conrpany has idcntit'ied or considered. Exhibit 4 at 11.
REQUEST NO. l7: Please explain when and hou'the Company intends to address
Commcrcial and Industria[ DSM/lrl] mcasurcs.
RXQUEST NO. l8: Please describe and quantif! savings to customers due to the
reduction ofmarket barriers. Exhibit4at 17.
REQUEST NO. l9: Please describe the Company's plans to acquire identified energy
efficiency savings potential for both single family and commercial sectors. Exhibit 4 at 20.
REQUEST NO. 20: Please explain how measures listed in Table 4 will be reconciled
lor current offerings and how additional measlres will be implemented. Please provide
supporting spreadsheets with formulas enabled. Exhibit 4 at 2l .
REQUEST NO. 2l: Please explain how and when the Company will address envelope
irnprovements opportunities. Exhibit 4 at 22.
FIRSI' PRODUC]'[ION REQUEST
TO INTERMOLIN'I'AIN GAS 5 JANUARY 17,2O2O
REQUEST NO. 22: Please provide supporting document(s) that describes how the
Company calculated the annual therm savings impact of$125,474 and an annual budget increase
o1'$930,000 due to a delay in tumace efliciency standards until 2028. Provide supporting
spreadshects with formulas intact. Exhibit 4 at 23.
REQUEST NO. 23: The CPA report suggests there is greater potenlial in existing home
upgrades/retrofits than new homes. Please explain how the Company will address existing home
opportunities and determine appropriate funding fbr both cxisting and ncw homc mcasures.
Exhibit 4 at29,30.
REQUEST NO. 24: On pages 56 and 57 olits 2019 IRP, the Company states that the
Nampa LNG Facility can store up to 600 million cubic lbet o['natural gas in liquid form, and can
re-gasity back into Intermountain's system at a rate of approximately 60 million cubic feet per
day. Please provide a system map with the following information:
a. The points at which the facility would injeot gas into the system in the event that it
was needed to provide gas for a peaking evenl. Include the diameters of pipes
connecting the facility to each delivery point.
b. Equipment used to gasily the I-NG for delivery into the system, including this
equipment's maximum capacity during the Company's peak design weather cvent.
c. Equipment used to compress the gasified LNG for delivery into the system, including
this equipment's maximum rated pressure and capacity during the Company's peak
design weather event.
REQUEST NO. 25: Has the Nampa LNG Facility been used to deliver gas to the
system during an emergency? lfso, please provide the following information for each event.
a. Description ol'the emergency including the date ol'the emergency.
b. The quantity ofgas dclivered to thc systcm during thc cmcrgcncy.
c. The time interval over which the facility provided emergency gas to the system.
REQUEST NO. 26: Please provide the lbllowing infbrmation regarding delivcrics to
the Rexburg LNG Facility from the Nampa LNG Facility.
FIRST PRODUCTION REQIJEST
TO INI'ERMOI.JNTAIN GAS .rANrjARY 17.20206
a. What was t}re maximum quantity of LNG delivered during any winter?
b. During what winter did this maximum occur?
REQUEST NO.27: On pages 129 and 130 of its 2019lRP, the Company describes a
new compressor station that it proposes in order to increase capacity on the Sun Valley Lateral.
Please provide the following workpapers in electronic format with links enabled:
a. Workpapers showing how the Company determincd thc costs lor the proposed
compressor station.
b. Workpapers showing how costs tbr each of the altematives studied by the Company
were estimated.
REQUEST NO.28: On pages 129 and 130 of its 2019 IRP, the Company describes a
new compressor station that it proposes in order to increasc capacity on the Sun Valley Lateral
Please answer the following questions:
a. What is the capacity ofthe Sun Valley Lateral as currently conligured?
b. What would be the capacity of the Sun Valley Latcral afier construction ofthe
proposed compressor station?
c. Where would the proposed station be located?
d. What would be the input and output operating pressures of the proposed station
during needle peak conditions?
e. What is the rated horsepower and capacity ofthe proposed compressor station
during needle peak conditions?
f. What is the proposed power source lbr the proposed compressor station?
g. What would be the Company's contingency plan in the event thal the compressor
station becomes inoperable during a needle peaking event?
REQUEST NO.29: In its description of the proposed compressor station tbr the Sun
Valley Lateral (lRP pages 129-130), the Company describes states that "...long sections ofthe
pipeline are installed in rock that imposc construction obstacles."
a. Please provide more infbrmation about thcsc obstacles.
FIRST PRODUCTION RLQUIST
TO INTERMOLINTAIN CAS 7 .IANI-IARY '11.2020
b. Please explain and provide documentation showing why and how they are a
consideration when deciding the best option to increase capacity of the existing Sun
Valley Lateral.
REQUEST NO. 309: In its description of the proposed compressor station for the Sun
Valley Lateral (lRP pages 129-130), the Company states that the second station will increase
capacity beyond the remaining five-year growth outlook ofthis IRP. When does the Company
estimate that this second station will no longer be adequate to serve the needs of its customers on
the Sun Valley Lateral?
REQUEST NO.3l: Please provide historical deliveries of LNG gas to the system (not
including LNG deliveries to the Rexburg LNG Facility or to non-core customers) by year over
thc past l0 years. For each delivery, please provide the range ol dates,/hours that the delivery
occurred, the amount ofgas delivered, and the reason for each delivery.
DATED at Boise, ldaho, this /1 da1, of January 2020.
Jo ond. Jr.
Atlomey General
i:umisc:prodrcq/intgl9.Tjhksk prod req I
FIRST PRODUCTION REQUITSI'
TO INTERMOL]NTAIN (iAS IJ JANUARY 17.2O2O
CERTIFICATE OF SERVICE
I HEREBY CER'|IFY TIIAT I HAVE '|HIS I7]'H DAY OF JANUARY 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STATF TO INTERMOUNTAIN GAS COMPANY, IN CASL NO.
INT.G-19.07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO ]'HE
FOLLOWING:
LORI BLATTNER
DIR _ RE(]ULATORY AFITAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: lori.blattner(rDintsas.com
BENJAMIN J OTTO
MATTNYKIEL
ID CONSERVATION LEAGUE
7IO N 6,I'H ST
BOISE ID 83702
E-MAI L: bofl o(zDidahoconscryation.ers
mnykiel(n)idahoconservation.org
PRISTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK SI'
BOISE ID 83702
E-MAIL : orestoncarter(Zlg vcnsnurslev.com
kendrah Yens c
Jofl"Z,,.
SECRFTA Y
CERTIFICATE OF SF,RVICE