20240222Staff 1-19 to INT.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX83720 BOISE, IDAHO 83720-0074 [phone]IDAHO BAR NO. 9810
Street Address for Express Mail: 11331 W CHINDEN BL VD, BLDG 8, SUITE 201-A BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS COMP ANY'S 2023 INTEGRATED RESOURCE PLAN
-------------------
) ) CASE NO. INT-G-23-07
) ) ) FIRST PRODUCTION ) REQUEST OF THE ) COMMISSION STAFF ) TO INTERMOUNTAIN GAS
) COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, 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 14, 2024.
This Production Request is to be considered as 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 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
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST TO INTERMOUNTAIN GAS COMPANY 1 FEBRUARY 22, 2024
In addition to the written copies provided as response to the requests, please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 1: Since the 2021 IRP, please describe activities and results achieved in providing the Commission with capacity enhancement project costs and NPV information when capacity improvement projects are completed and placed in service. See Order No. 35438 at 8. REQUEST NO. 2: Since the 2021 IRP, please describe the Company's activities and results achieved in providing materials to IGRAC members before meetings and making information accessible on its website. See Order No. 35438 at 8. REQUEST NO. 3: Please provide supporting workpapers and files with formulas enabled for all graphs, tables, models, exhibits, and forecasts included in the 2023 IRP. REQUEST NO. 4: For each of the three virtual IGRAC meetings conducted please provide the following: a)Feedback submitted for each meeting including meeting date and participant name ororganization;b)Information requests for each meeting including meeting date and participant name ororganization.REQUEST NO. 5: Please provide a five-year historical (2018-2022) view of the Company's Lost and Unaccounted for ("LAUF") natural gas including supporting workpapers and PHMSA reports. REQUEST NO. 6: In section 3.5.4 of the IRP, the Company describes education efforts as having a positive impact on reducing excavation damage. Please explain actions beyond education and awareness the Company is taking to increase locate requests and reduce excavation damage. FIRST PRODUCTION REQUEST TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY 22, 2024
REQUEST NO. 7: Please provide a worksheet that indicates the following information
regarding early vintage plastic pipe ("EVPP") in the Company's system.
a)Total amount of pipe by size and classification (main or service) that requires
replacement.
b)Total amount of EVPP pipe by size and classification (main or service) replaced each
year for the last five years.
c)Annual replacement cost.
d)A schedule by areas of interest(" AOI") of when replacement will be completed.
REQUEST NO. 8: Please provide a worksheet that indicates the following information
regarding early vintage steel pipe ("EVSP") in the Company's system.
a)Total amount of pipe by size and classification (main or service) that reqmres
replacement.
b)Total amount of EVSP pipe by size and classification (main or service) replaced each
year for the last five years.
c)Annual replacement cost.
d)A schedule by AOI of when replacement will be completed.
REQUEST NO. 9: Please provide historical deliveries of LNG gas from the Nampa LNG
facility to the system (not including LNG deliveries to the Rexburg LNG Facility or to non-core
customers) by year over the past five years. For each delivery, please provide the range of dates,
and hours that the delivery occurred, the amount of gas delivered, and the reason for each delivery.
REQUEST NO. 10: On page 101 of the IRP, the Company states that the Ustick Phase III
project has been delayed, please provide the following:
a)Current project status;
b)The latest expected project start date;
c)Current expected and direct cost estimates.
d)Please explain in detail how the project eliminated the need for the 8-inch Happy Valley
Extension project.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 FEBRUARY 22, 2024
REQUEST NO. 11: On page 102 of the IRP, the Company states that the State Street
Lateral requires a capacity enhancement in 2023 and the State Street Uprate Phase II was selected
in the 2021 IRP. However, on page 103 of the IRP the Company states that the State Street Phase
II project is budgeted for 2024. Please reconcile how the requirement for a 2023 enhancement will
be satisfied if the selected enhancement will not be completed until 2024.
REQUEST NO. 12: On page 104 of the IRP, the Company states that Central Ada County
requires a capacity enhancement in 2023. On page 105 of the IRP, the Company states that the
project will be online this fall. Please provide the following:
a)Current project status including regulator parts and fabrication;
b)The latest expected project completion date;
c)Current expected and direct cost estimates; and
d)Please explain in detail how 2023 capacity requirements were fulfilled absent this
enhancement.
REQUEST NO. 13: On page 107 of the IRP, the Company states that the Shoshone
Compressor will be commissioned in September. Please provide the following:
a)Current project status;
b)The actual or expected project completion date;
c)Current or expected actual and direct costs.
REQUEST NO. 14: On page 155 of the IRP, the Company states that the Gas Supply
Oversight Committee ("GSOC") makes final decisions to address transportation shortfalls. Please
provide the following:
a)Current members of the GSOC by job title and name;
b)How often the GSOC meets and topics discussed at meetings;
c)Alternatives the GSOC evaluated to satisfy transportation constraints or shortfalls.
REQUEST NO. 15: On page 161 of the IRP, the Company discusses the potential of new
commercial LNG facilities in the region as a risk to LNG sales. Please describe and quantify all
current and potential LNG facilities that pose a risk to the Company's LNG sales.
FIRST PRODUCTION REQUEST TO INTERMOUNTAIN GAS COMPANY 4 FEBRUARY 22, 2024
REQUEST NO. 16: Please provide all workpapers supporting Exhibit 5 (Avoided Cost
Model) in Excel format with equations intact and enabled.
REQUEST NO. 17: On page 134 of the IRP, the Company explains that it is using
PLEXOS for its optimization model. However, in multiple areas of the IRP, the use and outputs
of SENDOUT are described or referenced. Please explain what models were used to prepare this
IRP and where they apply.
REQUEST NO. 18: In the Supply Resources section of the IRP on page 140, The
Company explains that DSM resources are modeled as a supply resource in SENDOUT. Please
clarify if modeling DSM as a supply resource was done using SENDOUT OR PLEXOS and
answer the following:
a)Please explain the methodology and rationale for modeling DSM programs in this IRP;
b)Please explain what other considerations the Company gave to modeling the therm saving
impact of its DSM programs;
c)Please explain how this methodology selects DSM resources in an amount that
corresponds with the Company CPA savings estimates;
d)Please explain how selected DSM measures are used to inform the development of the
DSM supply resource;
e)Please explain how a selection of a DSM resource for an applicable AOI accounts for the
DSM impact in the relevant AOI;
f)Please explain how DSM resources are selected within the model or excluded as a not
least cost resource. Please detail all situations where DSM resources were not selected.
FIRST PRODUCTION REQUEST TO INTERMOUNTAIN GAS COMPANY 5 FEBRUARY 22, 2024
REQUEST N0.19: Please reconcile the Company's customer forecast annual growth
rate of2.8% on page 112 and base case scenario annual growth rate of2.56% on page 114.
Additionally, please answer the following:
a)Please explain which growth rate was used in the 2023 IRP model; and
b)Please explain the impact the used growth rate had on the modeled customer demand in
the 2023 IRP.
DATED at Boise, Idaho, this 22nd day of February, 2024.
Chris Btii-din
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\INT-G-23-07 PR #1.docx
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 6 FEBRUARY 22, 2024
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF FEBRUARY 2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THECOMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-23-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER DIR -REGULATORY AFFAIRS INTERMOUNTAIN GAS CO PO BOX7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER GIVENS PURSLEY LLP 601 W BANNOCK ST
BOISE ID 83702 E-MAIL: prestoncarter@gi venspursley. [e-mail]
SECRETAR
CERTIFICATE OF SERVICE