20220414INT to Staff 12-18.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
orestoncarter(rD givenspursley. com
Attorneys for lntermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN
GAS COMPAI[Y'S 202I-2026 INTEGRATED
RESOURCE PLAN
CASE NO.INT.C-2I-06
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
Intermountain Gas Company ("Intermountain", "Company"), in response to the Second
Production Request of the ldaho Public Utilities Commission ("Commission") Staff to
lntermountain Gas Company dated March 24, 2022, submits the information below. The
requested documents have been provided on the Company's Sharepoint site under the terms of
the Protective Agreement.
REQUEST NO. 12: Please provide workpapers with formulas enabled used to calculate
NPV costs for all selected capacity enhancements listed in Table No. 16 on page 116 of the
lntegrated Resource Plan ("IRP").
RESPONSE TO REQUEST NO. 12:
The file titled "PR#12 Exhibit 6 NPV" on the Company's Sharepoint site shows the
calculation of the NPV costs for all selected capacity enhancements listed in Table No. l6 as
well as the alternative enhancements the Company evaluated.
Record Lori Blattner-208-377-601s
SponsorlPreparer: KathleenCampbell. 509-734-4541
Location: 555 S Cole Rd. Boise. ID 83707
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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.
RESPONSE TO REQTTEST NO. 13:
The file titled "PR#I3_Cumulative Therm Savings by AOI (Corrected)" found on the
Company's Sharepoint site contains the supporting details for the annual therm savings listed in
the Annual DSM Supply Resources Results table on page26 of Exhibit No. 8. The table
provided in the tab labeled "Updated Exhibit 8 table" contains hard coded values directly from
the Sendout modeling software. The therm savings inputs provided to Sendout are contained in
cells L29:R35 of the "INPUT TO SENDOUT" tab. These inputs are derived from values from
the 2019 CPA DEEP model. A series of adjustments are then performed in the other tabs in the
file to allocate potential savings by AOI. The "Take: Annually by Supply'' lines in the table are
calculated in Sendout based on the therm savings inputs. The "Commodity Cost" lines in the
table are calculated by multiplying the therm savings amounts (labeled in the table as "Take:
Annually by Supply") by the "Unit Commodity Cost". The "Unit Commodity Cost" lines
represent the DSM expenses associated with reducing demand by one unit. Sendout uses the
Company's avoided cost seen in Exhibit No. 5 as a proxy for program expenses.
While preparing this response, the IRP team found that it incorrectly labeled one of the
Iines in the "Annual DSM Supply Resources Results" table as'oTake: Monthly by Supply"
instead of "Take: Annually by Supply''. Additionally, the table that was copied from Sendout
into Exhibit No. 8 was incorrectly frltering out several months of the year from the overall
supply take modeled in Sendout. This filtering did not affect the results of the modeling in
Sendout. The tab labeled "Updated Exhibit 8 table" corrects both of these issues.
Record Holder: Lori Blaturer. 208-377-6015
SponsorlPreparer:Landon Barber. 208-377 -6199
Location: 555 S Cole Rd. Boise. ID 83707
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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.
RESPONSE TO REQTIEST NO. 14:
Please see the file "PR#14_CMM Peak Estimate Validation" on the Company's
Sharepoint site showing fixed network data compared to DNV GL's Customer Management
Module. lntermountain's analysis compared a 100 meter sample of 30 commercial meters and 70
residential meters with available AMI data.
As mentioned in response to Production Request No. 2, the AMI system curenfly has
limitations on the application of gas billing factors which makes the data challenging to use on a
widescale application. As AMI becomes fully deployed and processes are developed to apply gas
billing factors to the data, the Company will be able to utilize the gathered data to further refine
its usage per customer validation process.
Record T.ori Blattner-208-777-6015
Kathleen Camnbell- 509-714-4541
Location: 555 S Cole Rd. Boise. ID 83707
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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.
RESPONSE TO REQIIEST NO. 15:
After the Idaho Falls Lateral Compressor station is operationaln2023 the existing
Rexburg LNG facility will be used as an emergency backup source to the Idaho Falls lateral. A
second LNG tank at the Rexburg facility is not required to meet growth predictions in this IRP.
The existing LNG facility (as-is with one tank) will be used as the emergency backup source for
system reliability once the Idaho Falls Lateral compressor station is operational. A second LNG
tank at the Rexburg LNG facility could be considered as needed to support growth predications
in a future IRP.
Record Holder: Lori Blattrer. 208-377-6015
Kqfhlaen Cemnhell \O0-1?A-A<A1
Location: 555 S Cole Rd. Boise. ID 83707
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REQUEST NO. 16: In StaffComments in INT-G-20-06, Staffoutlined 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's202l IRP. In the response, please identiff any manual adjustrnents or other
modifications the Company made to the CPA results before incorporating.
RESPONSE TO REQUEST NO. 16:
The Final Order in Case No. INT-G-20-06, which included the EM&V study results and
the above noted Staff Comments was not available until March 30,2021. Because of the length
of time it takes to create the inputs for the IRP and complete all of the modeling, the therm
saving assumptions were required at about the same time the Final Order in Case No. INT-G-20-
06 was available. A CPA is a lengthy process that involves sending out an RFP, selecting a
consultant, and allowing enough time for the consultant to complete a study. Intermountain's
frnt CPA process took 15 months from the time the RFP was issued until receipt of the final
study. Because of the time involved in completing a CPA that would incorporate the EM&V
study results, lntermountain was not able to commission a new study for the 2021 IRP.
The Company did make three updates to the 2019 DEEP model for the 2021 IRP:
o Updated the Real Discount Rate assumption to 4.68% to align with value used in
Avoided Cost model.
. Updated the nominal Avoided Cost values as listed in Exhibit No. 5.
. Added a one-year lag to commercial saving results to account for the commercial
program not starting at the same time as the residential program.
As Intermountain's Energy Efficiency program matures, it will get into a planning-
implementation-verification loop that will align with the IRP timeline. In fact, the Company
plans to include the CPA as an agenda item for its Energy Efficiency Stakeholder Committee
later this year prior to beginning the process of selecting a consultant this fall to complete a CPA
forthe 2023 IRP filing. The next CPA will be informed by the results of the Company's EM&V
study as well as market changes that have occurred since the initial study was completed.
Record Holder: Lori Blather. 208-377-6015
Sponsor/Preparer: KathyWold. 208-377-6128
Location:555 S Cole Rd- Boise- ID 83707
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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 lnstitute and the North American Gas Heat Pump Collaborative, please describe
how the work in these areas impacts the Company's Integrated Resource Plan. Specifically,
detail any savings, energy effrcient measures, or other items that will drive the results in the IRP
planning period from 2021 to2026 for work with the Gas Technology Institute and the North
American Gas Heat Pump Collaborative.
RESPONSE TO REQUEST NO. 17:
Intermountain Gas has been an integral partner in several initiatives to accelerate the
market acceptance of gas heat pump technology: Gas Technology institute's (GTD Gas Heat
Pump Technology and Roadmapr (Roadmap), GTI's "Residential Thermal Heat Pump-Combi
Field Demonstrations, Phase I &2," and the formation of the North American Natural Gas Heat
Pump Collaborative (Collaborative).2 Providing feedback to manufacturers regarding product
viability and required perforrnance improvements necessary for commercialization of this
technology has largely been the work of the Roadmap and the field demonstrations. There are
several demonstrations, in various stages of completion, to verify efficiencies and savings related
to gas heat pump technology for commercial and residential applications. There are currently two
manufacturers of gas heat pumps for commercial use that are commercially available in the
United States. There are four manufacturers of residential and small commercial gas heat pumps
that are planned to be commercially available as soon as 2023. The next step beyond product
testing and veriffing savings is the focus of the work of the Collaborative: to ensure a successful
market launch of gas heat pump products, and more importantly, to provide a market landing.
The Collaborative is developing the traditional tools of market transformatioq such as market
research, engagement with manufacturers, training tools for installers, and supporting product
specifications to prime the market to receive this new technology. Collaboration, the purpose of
the Collaborative, will allow members to leverage working together to standardize incentives and
develop innovative program designs to provide a market landing for gas heat pumps more
quickly than Intermountain could achieve working alone. Specific energy savings, energy
I Gas-Heat-Pump-Roadmap-Industry-White-Paper-Nov20 I 9.pdf ( eti.enerey)
2 North American Gas Heat Pump Collaborative I Technolosy for a Cleaner Future
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efficient measures, or other items that vill imFact results in the IRP planning period of 2021to
2026 are at this time unknown. The Company will explore opportunities like de'monstrations,
educational webinars and pilot programs to raise awareness about gas heat pump technology
with both customers and contactors. Despite aligning utility readiness with the market
commercialization of gas heat pumps, specific impacts will largely rely on market acceptance.
Therm savings related to gas heat pump technology will be included in the Company's next
CPA.
Record Holder:208-377-6015
KathvWold 2OR-?77-61),R
Location:555 S Cole Rd- Boise- ID 83707
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REQUEST NO. 18: Please identify and provide all data and assumptions from the IRP
used in the calculation of the variable distribution cost presented to Staffin 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.
RESPONSE TO REQTTEST NO. 18:
The file titled "PR#I8_IGC Distribution Cost Model - Draft", found on the Company's
Sharepoint site, contains the proposed model as well as the underlying data and assumptions for
the distribution cost component of the Company's avoided costs. The basic inputs as well as final
outputs can be found in the "Dashboard" tab. A description of the inputs and an explanation of
each step of the calculation can be found in the "Assumptions" tab.
During the March 9,2022 Avoided Cost Subcommittee meeting, the Commission Staff
suggested that the Company's model would be more transparent if it did not use confidential
plan data for forecasting capital expenditures. The Company acted upon this suggestion and
updated its distribution cost model to utilize a five-year average of actual capital expenditures
(2017 -202I) instead of confidential plan data. These expenditures are publicly available and
can be found in the Company's annual FERC Form 2 filings. For forecast years, the five-year
average expenditure is escalated by inflation as well as system growth.
In addition to providing the model in this response, the Company will also distribute the
model to the Avoided Cost Subcommittee for its review and approval.
Record Holder: Lori Blatfrrer. 208-377-6015
Sponsor/Preparer: LandonBarber. 208-377-6199
Location: 555 S Cole Rd. Boise. ID 83707
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DATED: Aptill4,2022
GTVENS PU&SLEY LLP
PrmtonN Cartcr
Attomrys for Intermountain Gas Company
Rrspo*snor INrrmtouNrenc Gas Cotrnpelw ro sEcoND
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CERTIFICATE OF SERYICE
I certiff that on April 14, 2022, a tnre and correct copy of INTERMOUNTAIN GAS
COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF was served upon all parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idatro Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
RileyNewton
Deputy Attomey General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
riley.newton@puc. idaho. gov
Jacob Darrington
RnspousE oF INTERMoT.TNTATN Ges CourpeNy ro SECoND
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