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HomeMy WebLinkAbout20200309INT to Staff Supplemental Responses.pdfPreston N. Carter, ISB No. 8462 Givens Pursley LLP 601 W. Bannock St. Boise,Idaho 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 pre stonc art erfrD qi venspurs I e y. co m RICEIVTD lliil t:f{il -9 PH 3: 05 , . t:.t t,,a., r iii"-lv- l -' :.lo:,:l,tissl0N Attorneys for lntermountain Gas Company BEFORE THE IDAIIO PTIBLIC UTILITES COMMISSION IN TIIE MATTER OF INTERMOUNTAIN GAS COMPAIIY'S 2019.2023 INTEGRATED RESOT'RCE PLAII CASE NO. INT-C,-I9.07 SUPPLEMENTAL RESPONSE OF INTERMOTINTAIN GAS COMPAI\Y TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF Intermountain Gas Company, in response to informal follow-up questions related to the First Production Request of the Commission Staff to lntermountain Gas Company dated January 17,2020, submits the following information: REQUEST NO.21: Please explain how and when the Company will address envelope improvements opportunities. Exhibit 4 at22. REQUEST NO. 23: The CPA report suggests there is greater potential in existing home upgrades/retrofits than new homes. Please explain how the Company will address existing home opportunities and determine appropriate funding for both existing and new home measures. Exhibit 4 at29,30. SUPPLEMENTAL RESPONSE TO REQUEST NOS.21 AIrtD 23: Intermountain's CPA stqted that envelope improvements can provide signiJicant savings opportunities. The top measures identified by the CPA were insulation, new construction and air SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF - Page I ) ) ) ) ) ) ) sealing. Intermountain's current new construction Wole Home rebate provides an incentive for builders to upgrade the entire building envelope of a home. The Company plans to continue to offer a new construction Wole Home rebate. Tofurther capitalize on savings in the nq,y construction market, Intermountain is considering the addition of a multi-family new construction rebate. Intermountain is currently in the process of updating its Avoided Cost calculation, as well as contractingfor an EM&V study that will include an impact evaluation of the Wole Home program. Intermountain will waitfor the completion of these two projects before moving forward with any revisions to its residential program offerings. Once these two projects are completed, Intermountain will begin to look at existing home envelope measures suggested by the CPA. Addressing envelope measures in the existing home market will require additional research and planning. In discussions with other utilities, Intermountain has been warned about out of state contractors that may take advantage of a new program and try to scam customers. Other utilities have shared examples of situations where out-of-state contractors come into a market because of a new utility program. This seems to be especially true of new insulation programs. The contractors will sell insulation to the customers, citing the utilily's program, and sometimes even representing that they are associated with the utility. Wen the utility goes back to perform quality control on the work, the contractor caused damage to the residence, and/or didn't install the right insulation, and/or the quality of the work is sub-par. By the time the work is audited, the disreputable contractor is long gone, leaving the customer and the utility with no recourse- SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQI]EST OF THE COMMISSION STAFF - Page2 Because of this type of anecdotal evidence, Intermountain believes an additional layer of overhead will be necessary to administer envelope measuresfor existing homes and to make sure customers are protected. Because the overhead costs could be significant, Intermountain plans to attempt to quantifu the additional costs a residential existing home envelope program would require. These additional costs would be layered on to the program costs for envelope measures and specific cost ffictiveness tests will be calculatedfor the proposed envelope measure based on the measure specific program costs. Following the completion of the Avoided Cost review and the EM&Y study, Intermountain will discuss plans for all proposed changes to its Residential Energt Efficiency program, including potential envelope measures, with its Stal(eholder group. After incorporating suggestions from the group, Intermountain plans tofile a revised program later this year. Record Holder:Lori Blattner.77-6015 Sponsor/Preparer: KathyWold. 208-377-6128 Location:555 S Cole Rd.TD 83707 SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF TI{E COMMISSION STAFF - Page 3 REQUEST NO. 27: On pages 129 and,130 of its 2019 IRP, 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 determined the costs for the proposed compressor station. b. Workpapers showing how costs for each of the alternatives studied by the Company were estimated. SIIPPLEMENTAL RESPONSE TO REQIIEST NO.27: a. Theflow capacity of only the new Shoshone Compressor Station, reviewed as an isolated unit separate from the entire lateral, is currently being designed at approximately 260,000 to 300,000 therms per day. Thisflow is significantly higher than the IW stated capacity increase of the SVL after the Shoshone _ compressor is installed, as stated in original response to request number 27 in section A. The IkP stated capacity is restricted due to other limitations on the SYL system, not related to the Shoshone compressor. Thefuture projected capacity constraint on the SVL is the currently installed Jerome Compressor Station (JCS), which has limited horsepower to meet afuture peakhourlyflow at estimated suction and discharge pressures. The JCS was intentionally designed to be installed in two phases with a second compressor pad and plumbing already in placefor the second unit. The second phase of the JCS lateral enhancement is outside the IRP's S-year planning horizon and could change depending onfuture growth shape and system dynamics. SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQI.]EST OF TI{E COMMISSION STAFF - Page 4 The Intermountoin Gas planning processfor AOI's typically begins with a design limitation that is monitored during growth analysis modeling. Once the predetermined tigger is metfor that design limitation the AOI is considered to have reached capacity. At this point engineering analysis of the AOI determines the most feasible and best cost solution enhancement. Once selected, the enhancement option is placed into the correctfuture planning and construction budget years. b. The pipeline loop in the original response to request number 27 in section B was supposed to state a 7.7 mile, 12" high pressure pipeline. At the same cost per mile the estimated cost is between $8.5-12.3 million. The calculated capacity increase is the same. The tab labeled "NPV" on the Excelfile labeled "PR I 27 SYL NPV Analysis" included with this filing shows the net present value of both the Shoshone Compressor Station at $4.4million and the 7.7 mile, 12" high pressure pipeline loop at $l0.tmiltion. Operation and maintenance estimatesfor both alternatives are listed on the tabs labeled "Transmission O&M per Mile" and "Compressor O&M Est". These costs were inflated by 2% each year over the 2)-year life of the analysis. For the pipeline loop, the Company determined the upfront cost by using the median value of $1.35 million per mile. Additionally, the Company used the real discount rate of 4.68ok, whichwas calculated in the Company's ovoided cost model presented in Exhibit No. 5. Blattner- 208-377-601s Sponsor/Preparer: RussNishikawa.208-377-6038 Location:555 S Cole Rd.rD 83707 SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF - Page 5 Record REQUEST NO. 29: In its description of the proposed compressor station for the Sun Valley Lateral (IRP pages 129-130), the Company describes states that "...long sections of the pipeline are installed in rock that impose construction obstacles." a. Please provide more information about these obstacles. 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. SUPPLEMENTAL RESPONSE TO REQUEST NO.29: a. The Company is not proposing to install new pipeline loops on sections of the SVL that carrently run through long sections of rock. Therefore, there is no need to invest in rock drill studies at this time. Record I.nri Flleffner )oR-111-6015 Sponsor/Preparer: RussNishikawa.208-377-6038 Location: 555 S Cole Rd-D 83707 SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQT]EST OF TIIE COMMISSION STAFF - Page 6 REQUEST NO. 30: ln its description of the proposed compressor station for the Sun Valley Lateral (IRP pages 129-130), the Company states that the second station will increase capacitybeyond the remaining five-year growth outlook of this 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? SUPPLEMENTAL RESPONSE TO REQUEST NO.30: a. Theflow capacity of only the new Shoshone Compressor Station, reviewed as an isolated unit separatefrom the entire lateral, is currently being designed at approximately 260,000 to 300,000 therms per day. Using an unsubstantiated annual load growth of 2.26% into perpetuity, and assuming no change in the location of anyfuture load growth past the S-year planning horizon, the Shoshone Compressor Station would theoretically reach capacity near 2037. Record Holder: Lori BlatErer. 208-377-6015 Sponsor/Preparer: RussNishikawa"208-377-6038 Location:555 S Cole Rd.lD 81707 Dated: March 9,2020 GTVENS PURSLEY LLP ,/ --"-- -. 2-a---- Preston N. Carter Attorneys for Intermountain Gas Company SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQI.]EST OF TIIE COMMISSION STAFF - PageT CERTTFICATE OF SERVICE - I certify that o_n March :L2020, atrue and comect copy of INTERMOLJNTAIN GAScoMPANY's SUPPLEMENTAL RESPoNsE To FIRST prtopucuoN REeuesr or urpCoMMISSION STAFF was served upon all parties of rpcord in this proceeain!iL th. runn .indicated below: Commf,ssion Staff Diane Hanian, Commission Secretary Idaho Public Utilities Commission I l33l W. Chinden Blvd., Bldg. g, Suire 20t-A Boise,ID 83714 Diane.holt@puc.idaho. gov John R. Hammond, Jr. Deputy Attomey General Idalro Public Utilities Commission I l33l W. Chinden Blvd., Bldg. g, Suite 201-A Boise, ID 83714 iohn.hammond@nuc.idaho. gov Idatro Conservation lrague Benjamin J. Otto MattNykiel 7l0N.6n Stcet Boise, ID 83702 botto@idahoconservati on.ore mnykiel@ idahoconservation.org Lori A. Electronic mail Electronic Mail Electronic lVlail SUPPLEMENTAL RESPONSE OF IGC TO FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF - page 8 lntermountaln Gas Company Sun Valley lateral Net PresentValue Net PrEsentValue Year 0 Year 1 Year 2 Shoshone Compressor Station 7.7 mile Pipeline Loop (s4,449,698.55) s (s10,058,148.97) s (4,ooo,ooo)s (43,s69) s l$,4r'.Ll (10,395,000) s (8,865)s (9,042) Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Year 9s (4s,330) ss (9,223) s (46,236) s (9,/S08) S (47,151) s (9,596) s (48,104) s (9,788) s (49,066) s (9,983) s (50,047) s (10,183) s (51,0481 (10,387) Year 10 Year 11 Year 12 Year 13 Year 14 Year 15 Year 16s (s2,069) ss (10,s94) s (s3,111)s (s4,173) ss (11,022) s (55,256) s (11,243) s (56,362) s (11,468) s (57,489) s (11,597) s (58,639) (11,931)(10,806) Year 17 Year 18 Year 19 Year 20 S (s9,811) Ss (12,170) s (61,008) s (62,228) 112,4L31 s (12,661) 5 163,4721s (12,91s)