20220324Staff 12-18 to INT.pdf

RILEY NEWTON.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2 Boise, ldaho
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPAII"Y'S 202I.2026 INTEGRATED
RESOURCE PLAN
CASE NO.INT.G-2I.06
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staff of the Idatro Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attomey General, requests that Intermountain Gas Company
("Company") provide the following documents and information as soon as possible, but no later
than THURSDAY, APRIL 14,2022.
This Production Request is to be considered as continuing, and Intermountain Gas
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 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
SECOND PRODUCTION REQUEST
TO INTERMOI.INTAIN GAS COMPANY
ldaho Public Utilities Commission
Office of the SecretarvRECEIVED
MAR 2 \ 2022
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1 MARCH 24,2022
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic hles on CD with formulas intact and enabled.
REQUEST NO. 12: Please provide workpapers with formulas enabled used to calculate
NPV costs for all selected capacity enhancements listed in Table No. l6 on page I l6 of the
Integrated Resource Plan ("IRP").
REQUEST NO. 13: Please provide supporting workpapers with formulas enabled for
the "Annual DSM Supply Resources Results" table found on page 26 in Exhibit No. 8 of the
IRP.
REQUEST NO. 14: Regarding the Company's response to Production Request No. 2,
please provide the workpapers with formulas enabled supporting the information provided on the
Company's work to validate the accuracy of peak estimates from DNV GL's Customer
Management Module using the peak consumption information from the Company's AMI meters.
REQUEST NO. 15: Please explain if a second tank at the Rexburg facility will be
required in the future to support emergency backup and system reliability after 2023 as described
on page 115 of the IRP.
REQUEST NO. 16: In Staff Comments in INT-G-20-06, Staff outlined numerous
occasions where measure savings values from the Conservation Potential Assessment ("CPA")
conducted by Dunsky Energy Consultants may be overstated from the results of the Evaluation,
Measurement and Verification ("EM&V") study. Please describe the steps and processes the
Company took to ensure the results from the CPA were vetted for accuracy prior to being used in
the Company's2021IRP. In the response, please identify any manual adjustments or other
modifications the Company made to the CPA results before incorporating.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 MARCH 24,2022
REQUEST NO. 17: On page 86-87 of the IRP, the Company discusses "Ensuring an
Energy Efficient Future." From the areas discussed in this section, such as the with the Gas
Technology Institute and the North American Gas Heat Pump Collaborative, please describe
how the work in these areas impacts the Company's lntegrated Resource Plan. Specifically,
detail any savings, energy efficient measures, or other items that will drive the results in the IRP
planning period from202l to 2026 for work with the Gas Technology Institute and the North
American Gas Heat Pump Collaborative.
REQUEST NO. 18: Please identiff and provide all data and assumptions from the IRP
used in the calculation of the variable distribution cost presented to Staff in the Avoided Cost
Subcommittee meeting on March 9,2022, including but not limited to, the annual budgets for
distribution cost, percent growth, and peak load growth. Please provide data in excel format with
all formulas attached. If available, please provide the Company workpapers for the Variable
Distribution Cost calculation.
DATED at Boise, Idaho, this 2t{t day of Mar ch2022.
i:umisc:prodreq/intg2 l.6mkk prod req 2
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY J
D Attorney General
MARCH 24,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF MARCH 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQ[]EST OF THE
CoMMISSION STAFF TO TNTERMOUNTATN GAS COMPAN'Y, IN CASE
NO. INT.G-21-06, BY E.MAILING A COPY THEREOF, TO TTM FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GTVENS PURSLEY LLP
60I W BANNOCK ST
BOISE TD 83702
E-MAIL : prestoncarter@ givenspursley.com
stephaniew@ givenspursley. com
CERTIFICATE OF SERVICE