20200324ICL 1-17 to INT.pdf

P.[CEIVED
l?il i"'lfiii 2t+ PH h: 28Matthew A. Nykiel (ISB No. 10270)
PO Box 2308
Sandpoint, ID 83864
Ph: [phone] (cell)
Fax: [phone]
mnykiel @idahoconservation. org
Attorney for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS)
COMPAI\IY'S 201 9.2023 INTEGRATED
RESOURCE PLAI\
CASE NO.INT.G-I9.07
FIRST PRODUCTION
REQUEST OF TIIE
IDAHO CONSERVATION
LEAGUE TO
INTERMOUNTAIN
GAS COMPAI\Y
The [daho Conservation League, by and through its attorney of record, Matthew A.
Nykiel, and pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), requests Intermountain Gas Company ("Company") provide the following
documents and information as soon they become available to the Company, but no later than
TUESDAY, APRrL 14, 2020.
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. IDAPA 3 I .01 .01 .228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on USB flash drive or CD (USB preferred) with formulas activated.
FIRST PRODUCTION REQUESTOF ICL TO INTERMOUNTAIN GAS COMPANY
March24,2020
)
)
)
)
)
)
)
REQUEST NO. 1: If not already provided, please provide electronic copies of all data
requests received from and Company responses sent to any party in this proceeding.
REQUEST NO.2: Please provide a list of every individual and entity the Company
contacted with its July l l,20l8 letter invitation to join the IRP advisory group.
REQUEST NO.3: Please answer whether or not the Company facilitates remote
participation in its IRP advisory group meetings? If not, please explain why not.
REQUEST NO.4: Please discuss in detail the Company's basis for limiting its IRP
planning period to 5 years.
REQUEST NO. 5: At pages 5-7, the Company makes several claims about gas in
regards to greenhouse gas emissions.
a. Please explain how the Company evaluated the risk and costs to Idaho ratepayers
associated with the Company's greenhouse gas emissions.
b. Please provide the Company's annual greenhouse gas emissions for the past five
years and the Company's forecasted annual greenhouse gas emissions over the
next 20 years.
c. Please explain whether or not the Company accounted for upstream greenhouse
gas emissions (also known as fugitive emissions) associated with the gas drilling
and transportation processes that supply the Company's gas.
d. Please provide the greenhouse gas emission rate for the Company's gas in pounds
of carbon dioxide equivalent per dekatherm.
REQUEST NO. 6: At page 5, the Company states: "...according to the American Gas
Association, households with natural gas versus all electric appliances produce 4l7o less
greenhouse gas emissions."
a. Please provide the study that supports this statement.
b. Please explain whether or not this statement is representative of the households in
the Company's service territory in ldaho.
FIRST PRODUCTION REQUEST OF ICL TO INTERMOUNTAIN GAS COMPA}.IY
March24,2020
2
REQUEST NO. 7: At page 5, the Company states: "The Northwest Gas Association has
reported that the direct use of natural gas is about92Yo efficient."
a. Please provide this report.
REQUEST NO. 8: At page 5, the Company states: "...the U.S. Energy Information
Administration (EIA) has reported that natural gas for electric generation has allowed U.S.
power plants to achieve a27-year low in emissions."
a. Please provide this report.
REQUEST NO. 9: At page 6, the Company states: "As electric generating capacity
becomes more constrained in the Pacific Northwest, additional peak generating capacity will
primarily be natural gas fired."
a. Please provide the basis for this claim.
REQUEST NO. 10: BlackRock, Inc., the second largest shareholder of MDU Resources,
requires all the companies it invests in to make two disclosures related to climate change and
sustainability, including :
o A disclosure of climate-related risks in line with the Task Force on Climate-related
Financial Disclosures (TCFD), including the Company's plan for operating under a
scenario where the Paris Agreement's goal of limiting global warming to less than
two degrees is fully realized; and
o A disclosure in line with industry-specific Sustainability Accounting Standards Board
(SASB) guidelines.
a. Please provide these disclosures.
FIRST PRODUCTION REQUEST OF ICL TO INTERMOUNTAIN GAS COMPANY
March24,2020
J
REQUEST NO. 11: At page 62,the Company discusses how it forecasts the price of
gas.
a. Please provide the Company's annual low, base, and high gas supply price
forecast over the next 20 years. Please provide this information in a table that
identifies the annual cost by year.
b. Please provide the pricing forecast information and reports from the AECO,
Rockies, and Sumas pricing points and the proprietary model that the Company
used to forecast gas supply cost.
c. Please explain how the Company evaluated the impacts to gas supply cost from
the Canadian federal government's Greenhouse Gas Pollution Pricing Act, which
was assented to and commenced on June 21,2018.
REQUEST NO. 12: At pages 6l-62, the Company discusses the capacity release
process
a. Please provide the amount, duration, and sale value of every capacity release
successfully sold via pre-aranged deal with tGI Resources, Inc. (IGI) or via
auction through an Electronic Bulletin Board (EBB) over the last three years;
b. Please provide the amount and duration of excess capacity that was not
successfully released via pre-arranged deal with IGI or via auction through an
EBB over the last three years.
REQUEST NO. 13: At pages 82-83, the Company discusses Large Volume customer
energy efficiency.
a. Please provide the total number of large volume customers that have installed
SCADA units for tracking hourly therm usage data.
b. Please provide the percentage of the Company's total large volume customers that
have installed SCADA units.
c. Please provide the total monthly page views of the Company's Large Volume
customer website over the last 3 years.
FIRST PRODUCTION REQUEST OF ICL TO INTERMOTINTAIN GAS COMPANY
March24,2020
4
REQUEST NO. 14: Please provide a table comparing the Company's annual
conservation targets with the Company's annual actuals, since the Company began implementing
its conservation program.
REQUEST NO. 15: In the Company's response to Staff s Request No. 9, the Company
states: "The proposed second LNG tank at the Rexburg LNG Facility will expand the storage
capacity of the Facility, allowing the Company to maintain approximately two days of peak day
storage onsite. The Company conservatively strives to maintain two days of onsite storage to
meet core customer demands, while at the same time, reserving LNG trailers that will be called
into service for LNG transfer from the Nampa LNG Plant."
a. Please provide the information and analysis the Company used to determine that
maintaining two days of onsite LNG storage is the least cost, least risk of all
available supply and demand side options to meet customer needs.
REQUEST NO. 16: At pages 67-71, the Company discusses Lost and Unaccounted For
(LAUF) gas.
a. Please provide the annual amount of Lost and Unaccounted For (LAUF) gas over
the last 20 years.
b. Please provide a comparison table, showing the annual amount of LAUF gas from
representative gas companies in the lntermountain West.
c. At page 68, the Company refers to "Dead Meters." Please explain what dead
meters are and explain why the Company identifies several hundred dead meters
annually. Please provide the annual number of dead meters over the past l0 years.
d. Please provide the annual amount of "found gas" that escaped from the Company
system over the last l0 years.
e. Please answer whether or not the Company subtracted LAUF gas and "found gas"
from the Company's load demand curves.
FIRST PRODUCTION REQUEST OF ICL TO INTERMOTINTAIN GAS COMPANY
March24,2020
5
REQUEST NO. 17: [n response to Staffs RequestNo. 13, the Company provided the
pipes targeted for replacement by length and pipe size.
a. Please provide the annual amounts of at-risk pipe the Company has replaced since
2013 and annual cost associated with these replacements.
b. Please provide the estimated date at which time all the at-risk pipe will be
replaced.
c. Please the information and analysis that supports the Company's replacement rate
for at-risk pipe.
d. Please provide the estimated total cost to replace all the at-risk pipe.
DATED this 24th day of March,2020.
ReyecttullV submitted,
Matthew A.
Idaho Conservation League
FIRST PRODUCTION REQUEST OF ICL TO INTERMOUNTAIN GAS COMPANY
March24,2020
6
CERTIFICATE OF SERYICE
I hereby certiff that on this 24ft day of March,202O,l served the foregoing FIRST
PRODUCTION REQUEST OF THE TDAHO CONSERVATION LEAGUE TO
INTERMOLJNTAIN GAS COMPANY, in Case No. INT-G-19-07 by emailing a copy thereof in
accordance with Idaho Public Utilities Commission Order No. 34602, to the following:
Lori Blattner
Dir - Regulatory Affairs
Intermountain Gas Co.
PO Box 7608
Boise,lD 83707
Email : [e-mail]
John R. Hammond, Jr.
Deputy Attorney General
Idaho Public Utilities Commission
PO Box 83720
Boise, lD 83720
Email : j ohn.hammond@puc. idaho.gov
Preston N. Carter
Givens Pursley LLP
601 W Bannock St.
Boise,lD 83702
Email: [e-mail]
kendrah@givenspursley. com
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, lD 83720
Email : [e-mail]. gov
1--.,J,
Matthew A. Nykiel
Idaho Conservation League
7CERTIFICATE OF SERVICE