20220210Staff 1-11 to INT.pdf

RILEY NEWTON.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S 202I-2026 INTEGRATED
RESOURCE PLAN
CASE NO.INT-G-2I-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Intermountain Gas Company
("Company") provide the following documents and information as soon as possible, but no later
than THURSDAY, MARCH 3,2022.
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 behall 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 INTERMOUNTAIN GAS COMPANY
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I FEBRUARY IO,2O22
the person preparing the documents. Please also identi$ 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 files on CD with formulas intact and enabled.
REQUEST NO. 1: Please describe the Company's efforts and results achieved in
seeking diverse stakeholder participation in the Intermountain Gas Resource Advisory
Committee ("IGRAC"). See Order No.34742.
REQUEST NO.2: Please describe 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. See Order No.34742.
REQUEST NO.3: Please respond to the following regarding the Company's Demand
Side Management ("DSM") avoided costs:
a. Please explain how the Company will determine a distribution cost component to
be used in its DSM avoided cost calculation.
b. Please provide workpapers with formulas enabled showing how the effects of the
Company's DSM programs were included in the Company's load growth
projections.
REQUEST NO. 4: On page 103 of the lntegrated Resource Plan ("IRP"), the Company
discusses the State Street enhancement selection of the State Street Phase II Uprate alternative to
meet2026 growth projections. The Company mentions increased Operations & Maintenance
("O&M") costs associated with uprating the 12-inch line. Please provide a detailed description
of the O&M costs the Company expects to increase including supporting workpapers with
formulas enabled.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY IO,2O22
REQUEST NO. 5: On page 100 of the IRP, the Company discusses the Ustick Phase III
enhancement selection to meet 2026 growth projections. Please provide a detailed status of the
Ustick Phase II project and updated cost and schedule projections for the Ustick Phase III project
including supporting workpapers with formulas enabled.
REQUEST NO. 6: On pages 114 and 115 of the IRP, the Company discusses the ldaho
Falls lateral. The Company selected compression as the preferred method to meet growth
predictions.
a. Please provide current cost estimates for the Idaho Falls Lateral Compressor
Station.
b. In the 2019 IRP, the Company also stated that a second LNG storage tank at the
Rexburg LNG facility would be added in2022. Please explain if the Company
still intends to add a second storage tank. If not, why not. If so, please provide a
detailed description of the LNG tank addition including need, expected costs, and
project timing.
c. Please explain the long-term need and use case for the Rexburg LNG facility.
REQUEST NO. 7: On page 108 of the IRP, the Company discusses a l}-inch South
Boise Loop project to meet 2026 growthpredictions. Please provide a detailed status of the
project and updated cost and schedule projections including workpapers with formulas enabled
REQUEST NO. 8: On page I l l of the IRP, the Company describes selection of the
Shoshone Compressor Station in the 2019 IRP to meet 2026 growthpredictions. Please provide
a detailed status of the Shoshone Compressor Station and updated cost and schedule projections
for the project including workpapers with formulas enabled.
REQUEST NO. 9: The Company is using SENDOUT@ to develop and analyze a
variety of resource portfolios and to determine the type, size, and timing of resources best
matched to forecast requirements. IRP at 140. Please describe modeling alternatives the
Company has evaluated, if any, to model optimization.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY J FEBRUARY IO,2O22
REQUEST NO. 10: Please provide workpapers with formulas enabled used to generate
the Regional Conversion Rate Table on page 28 of the IRP.
REQUEST NO. 11: Please explain how the Company validates its ARIMA model for
commercial customer projections. Provide any applicable spreadsheets with formulas enabled.
DATED at Boise, Idaho, this lrl1^day of Febru ary 2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/intg2 l.6mkk prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 FEBRUARY IO,2O22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ICIh DAY OF FEBRUARY 2022,
SERVED TI{E FOREGOING FIRST PRODUCTION REQUEST O[' TIIE
COMMISSION STAFF TO INTERMOT]NTAIN GAS COMPAI\Y, IN CASE
NO. INT-G-21.06, BY E.MAILING A COPY THEREOF, TO TIIE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
stephani ew@ givensoursley. com
CERTIFICATE OF SERVICE