20200424INT to ICL Attachment 1-17.pdf

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 1
Preston N. Carter, ISB No. 8462 Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702 Telephone: [phone] Facsimile: [phone] [e-mail]

Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

-2023 INTEGRATED
CASE NO. INT-G-19-07
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST
PRODUCTION REQUEST OF THE

Intermountain Gas Company, in response to the First Production Request of the Idaho
Conservation League to Intermountain Gas Company dated March 24, 2020, submits the
information below. All files referenced in this document will be available to the parties via the
Company’s SharePoint site. Confidential files will be placed in the CONFIDENTIAL Responses
SharePoint folder and non-confidential files will be placed in the general Responses folder. Links
to the site will be emailed to those on the certificate of service.
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.
RESPONSE TO REQUEST NO. 1: The Company has provided all data request
responses in this proceeding to the Idaho Conservation League (“ICL”).
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Jacob Darrington, 208-377-6041 Location: 555 S Cole Rd, Boise, ID 83707
RECEIVED
2020 April 24,PM1:46
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 2
REQUEST NO. 2: Please provide a list of every individual and entity the Company
contacted with its July 11, 2018 letter invitation to join the IRP advisory group.
RESPONSE TO REQUEST NO. 2: The list of individuals invited to join the
Intermountain Gas Resource Advisory Committee is submitted as “PR 1_2_IGRAC Invitation
List”. For the complete list of individuals that accepted the invitation, please see Exhibit No. 1,
Section A, Page 2 of Intermountain’s 2019 – 2023 Integrated Resource Plan.
Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Raycee Thompson, 208-377-6046
Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 3
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.
RESPONSE TO REQUEST NO. 3: For committee members that were unable to attend
the meetings in person a call-in option was provided.

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Raycee Thompson, 208-377-6046 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 4
REQUEST NO. 4: Please discuss in detail the Company’s basis for limiting its IRP
planning period to 5 years.
RESPONSE TO REQUEST NO. 4: In Order No. 27024, Case No. INT-G-97-02, the
Commission approved Intermountain’s request to limit the forecasting horizon for Integrated
Resource Plans to a period of five (5) years to more closely align the IRP with business planning
practices. The five (5) year planning horizon, updated biennially, provides adequate time to act
upon any capacity issues identified through the IRP process. Given the inherent inaccuracies in
long-term forecasts, and the fact that five years provides sufficient time to act upon any capacity
issues, a longer planning horizon would result in little to no additional benefit but would
significantly increase the hours and potential consultant expenses necessary to complete the IRP.

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 5
REQUEST NO. 6: At page 5, the Company states: “…according to the American Gas
Association, households with natural gas versus all electric appliances produce 41% 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 Idaho.
RESPONSE TO REQUEST NO. 6:
a. This statement was included in a section of the IRP that is not required, but that was
included to improve the readability of the document and set the stage for the current
natural gas market. Please see the file labeled “PR 1_6_ea_2017-03”.
b. This study is compiled by the American Gas Association. Idaho’s households would
have been represented in the nation-wide study but were not separately studied.
Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015
Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 6
REQUEST NO. 7: At page 5, the Company states: “The Northwest Gas Association has
reported that the direct use of natural gas is about 92% efficient.”
a. Please provide this report.
RESPONSE TO REQUEST NO. 7:
a. This statement was included in a section of the IRP that is not required, but that was
included to improve the readability of the document and set the stage for the current
natural gas market. Please see the file labeled “PR 1_7_NWGA_FactsWEBF”.

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 7
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 a 27-year low in emissions.”
a. Please provide this report.
RESPONSE TO REQUEST NO. 8:
a. This statement was included in a section of the IRP that is not required, but that was
included to improve the readability of the document and set the stage for the current
natural gas market. Please see the file labeled “PR 1_8_EIA_Today in Energy”.

Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Lori Blattner, 208-377-6015
Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 8
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.
RESPONSE TO REQUEST NO. 9:
a. This statement was included in a section of the IRP that is not required, but that was
included to improve the readability of the document and set the stage for the current
natural gas market. The Idaho Energy Landscape discusses the use of natural gas for
peak power production in Idaho and can be found here: https://oemr.idaho.gov/wp-
content/uploads/FINAL-Energy-Landscape-2019-1.pdf

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Lori Blattner, 208-377-6015 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 9
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.
RESPONSE TO REQUEST NO. 11:
a. The Company’s annual low, base, and high 20-year gas supply price forecast used in
the Company’s IRP filing is provided in the confidential file labeled
“CONFIDENTIAL PR 1_11_Price Forecast".
b. The Company has provided the forecast for the AECO, Rockies, and Sumas pricing
points. The price forecast utilizes multiple outside sources to create the Company’s
price forecast. The price forecast methodology is provided in the confidential file
labeled “CONFIDENTIAL PR 1_11_Price Forecast Design Document”. Due to the
utilization in the Company’s model of some outside sources that require their
forecasts remain proprietary, Intermountain cannot provide a copy of the model.
However, Intermountain is willing to set up a video call with interested parties to
walk through the model and discuss the inputs and results.
c. As mentioned in section VI of the “CONFIDENTIAL PR 1_11_Price Forecast
Design Document” file, the Greenhouse Gas Pollution Pricing Act and the Canadian
Federal Fuel Charge (CFFC) impact costs apply to direct sales of natural gas. Since
Intermountain does not sell gas directly in Alberta or British Columbia, the CFFC is
not applicable and therefore does not impact the price forecast.
Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Brian Robertson, 509-734-4546 Location: 555 S Cole Rd, Boise, ID 83707
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 10
REQUEST NO. 12: At pages 61-62, the Company discusses the capacity release
process.
a. Please provide the amount, duration, and sale value of every capacity release
successfully sold via pre-arranged deal with IGI 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.
RESPONSE TO REQUEST NO. 12: Pursuant to Intermountain’s Objection, please see
the confidential information in the file labeled “CONFIDENTIAL PR 1_12_Capacity Releases”
regarding capacity releases that were previously provided to Staff of the Idaho Public Utilities
Commission during the most recent PGA process.
Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Jacob Darrington, 208-377-6041 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 11
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.
RESPONSE TO REQUEST NO. 13:
a. 110 large volume customers have installed SCADA units for tracking hourly
therm usage data.
b. About 84% of Intermountain’s large volume customers have installed SCADA
units.
c. The total annual page views for the Company’s Large Volume customer website
are as follows:
Intermountain Large Volume Customer Website Page View Count 2017 2018 2019

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Dave Swenson, 208-377-6118 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 12
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.
RESPONSE TO REQUEST NO. 14:
Intermountain Gas Energy Efficiency Program – Therm Savings by Program Year
Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Kathy Wold, 208-377-6128
Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 13
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.
RESPONSE TO REQUEST NO. 15:
a. Maintaining two days of onsite storage at the Rexburg LNG Facility to meet a peak
cold weather event on the Idaho Falls Lateral (IFL) is a balance of cost and risk
weighed by Intermountain. At the time of initial design, it was decided that the
Rexburg LNG Facility would be built with onsite storage to reduce its dependency on
LNG trailers for immediate supply, and to allow each LNG trailer the freedom to
transfer product into storage at a rapid rate and then leave the site, as opposed to
leaving an LNG trailer on site at an additional hourly cost to connect directly to the
vaporization facility without storage, and removing product directly from the LNG
trailer into the Lateral at a rate dictated by customer demand at the time.
The initial volume of onsite storage was determined by current and future demand,
along with an industry standard storage tank design for satellite facilities. The initial
facility design also allows for the potential expansion of two additional storage tanks
of equal size. The desired requirement of two days peak onsite storage is a rule set by
the Engineering department as it allows for Rexburg LNG to have enough supply to
cover the peaking event planned for within the IRP, which is a needle peak event with
a single peak day and relatively high heating degree days occurring on each side of
the peak (derived from historical events as described within the IRP). The pre and
post peak days utilize almost the same amount of LNG as the peak day itself, which
equates to the two peak day onsite supply. Should an extended cold event occur, or
the Operator controlled supply from Rexburg not be as perfectly precise as a modeled
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 14
prediction, then the LNG trailers in reserve can begin to supplement supply for
Rexburg. Intermountain chose not to rely solely on LNG trailer supply to meet a
peak event as highway and interstate transportation is not reliably open at all times
throughout the winter.

Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: Russ Nishikawa, 208-377-6038 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 15
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 Intermountain 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 10 years.
d. Please provide the annual amount of “found gas” that escaped from the Company
system over the last 10 years.
e. Please answer whether or not the Company subtracted LAUF gas and “found gas”
from the Company’s load demand curves.
RESPONSE TO REQUEST NO. 16:
a. Pursuant to Intermountain’s Objection, annual LAUF data reported in
Intermountain’s most recent PGA filing (INT-G-19-06) is included as “PR
1_16_INT-G-19-06 Workpaper No. 7”.
b. Pursuant to Intermountain’s Objection, the Company does not have the requested
table. However, information regarding the subject-matter of this request is
publicly available at https://www.phmsa.dot.gov/data-and-statistics/pipeline/gas-
distribution-gas-gathering-gas-transmission-hazardous-liquids.
c. A dead meter is a meter with a measurement discrepancy. These meters are
identified on a monthly basis by the Company’s billing department based on a
report that monitors variances in usage. These meters are then pulled by service
technicians for additional testing to determine the root cause of the error. The
annual number of dead meters is as follows:
Intermountain Dead Meter Count
2016 2017 2018

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 16
d. Pursuant to Intermountain’s Objection, found gas data reported in Intermountain’s
most recent PGA filing (INT-G-19-06) is included as “PR 1_16_INT-G-19-06
Workpaper No. 7”.
e. Intermountain does not, and has no way to, forecast the amount of LAUF gas and
found gas.

Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Raycee Thompson, 208-377-6046 Location: 555 S Cole Rd, Boise, ID 83707

RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 17
REQUEST NO. 17: In response to Staff’s Request No. 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.
RESPONSE TO REQUEST NO. 17:
a. The Company completed a program in 2017 which replaced a high-risk subset of
3.5” steel pipe (Thin-Skin). Between 2013 and 2017, the Company replaced
roughly 16.2 miles of this type of pipe at an approximate cost of $5.65 million.
Between 2013 and 2019, the Company replaced, as part of an ongoing program,
roughly 66.2 miles of Aldyl-A pipe at an approximate cost of $8.52 million.
b. Providing a meaningful estimated completion date for replacing all at-risk pipe is
extremely difficult. Constrained annual budgets, contractor availability and cost,
impacts to the public, and other considerations all affect the rate at which at-risk
pipe can be replaced. It should be noted that risk is relative, and the replacement
program targets areas of pipe with the highest relative risk as identified by the
Company’s GIS-based risk model. This model is updated annually to reflect new
information, and the replacement program priorities may be adjusted accordingly
based on the results.
c. Information including leak history and quantified relative risk are trended and
reviewed annually as part of IGC’s DIMP Performance Management program.
This data is considered when determining whether the replacement program is
effectively reducing risk on the system or whether program changes are needed.
Risk between distribution systems is relative and the Company’s DIMP model is
used to target high-risk systems for replacement first. Budgets, availability of
qualified contractors, and impacts to the public all affect the scopes of work and
rate of replacing at-risk pipe.
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 18
d. Given the quantity of targeted pipe and the variability of pricing in replacing it,
providing a meaningful estimated total cost would be purely speculative.

Record Holder: Lori Blattner, 208-377-6015 Sponsor/Preparer: Jesse Volk, 218-770-8481
Location: 555 S Cole Rd, Boise, ID 83707

Dated: April 14, 2020
GIVENS PURSLEY LLP
Preston N. Carter Attorneys for Intermountain Gas Company
RESPONSE OF INTERMOUNTAIN GAS COMPANY TO FIRST PRODUCTION REQUEST OF THE ICL – PAGE 19
CERTIFICATE OF SERVICE
I certify that on April 14, 2020, a true and correct copy of INTERMOUNTAIN GAS
COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE was served upon all parties of record in this proceeding via the manner indicated below:
Benjamin J. Otto Matt Nykiel 710 N. 6th Street Boise, ID 83702
[e-mail]
[e-mail]
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714 [e-mail]

John R. Hammond, Jr.
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714
[e-mail]

Electronic Mail

Lori A. Blattner