20061102final_order_no_30159.pdf

Office of the Secretary
Service Date
November 2, 2006
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S 2007-2011 INTEGRATED RESOURCE PLAN CASE NO. INT -06-
ORDER NO. 30159
On May 1 , 2006, Intermountain Gas Company ("Intermountain" or "Company ) filed
its 2006 Integrated Resource Plan (IRP) for the years 2007-2011 with the Commission. On June
2006, the Commission issued a Notice of Filing and solicited comments. Order No. 30090.
The only comments received were submitted by Commission Staff. The Company filed Reply
Comments on September 14 2006.
BACKGROUND
This filing is pursuant to the directives in Order No. 25342, Case No. GNR-93-
(PURPA ~ 303(b)(3), Energy Policy Act of 1992). Order No. 25342 set forth the original
requirements for IRPs for local gas distribution companies in accordance with amended Section
303 of the Public Utility Regulatory Policies Act of 1978 (PURPA). The Commission has twice
modified the requirements for natural gas IRPs: Order No. 27024 allowed the Company and
Avista Corporation (f.k.a. Washington Water Power Company) to shorten the planning horizon
to five years to match the companies' planning horizon and available market products; and Order
No. 27098 removed the requirement that IRPs include a formal evaluation of the costs and
benefits of potential demand-side management (DSM) programs, stating that a general
explanation of whether there are cost-effective DSM opportunities will be sufficient.
THE INTEGRA TED RESOURCE PLAN
In the Executive Summary of the Company s IRP, the Company stated that the IRP is
meant to describe the currently anticipated conditions from 2007-2011. It further stated that the
document is meant to present strong guidelines rather than be "a prescription for all future
energy resources." IRP at 1. The Company is the sole distributor of natural gas in southern
Idaho, serving 275 800 customers in 74 communities during the first half of fiscal year 2006. Its
system contains over 10 000 miles of transmission, distribution and service lines. Id. In fiscal
year 2005, over 446 miles of distribution and service lines were added in response to new
customer additions and to maintain service for the growing customer base. Id.
ORDER NO. 30159
Intermountain s two major markets are the residential/commercial market (the "core
market") and the industrial market.Id.Intermountain saw an increase of 5% III average
residential and commercial customers during the first half of fiscal year 2006. Id. Forty-four
percent (44%) of the throughput on Intermountain s system during fiscal year 2005 was
attributable to industrial sales and transportation. Id.
Forecast Peak Day Send-Out
According to the IRP, peak day send-out studies and load duration curves were
developed under design weather conditions to determine the magnitude and timing of future
deficiencies in firm peak day delivery capability. Residential, commercial and industrial peak
day load growth on the Company s system is forecast to grow at an annual average rate of 4%
over the next five years. The Company calculated the growth for the system as a whole as well
as for the separate regions in which the Company operates. When forecasted peak day send-out
is matched against existing resources, a peak day delivery deficit occurs during January 2007 and
increases at a rate of 38%. According to the Company s calculations, a deficit of firm capacity
begins to occur near the peak day beginning in the winter of 2009. Id. at 4.
Idaho Falls Lateral Region
The Idaho Falls Lateral (IFL) region serves many cities between Pocatello to the
south and St. Anthony to the north. The residential, commercial and industrial load served off
the IFL represents approximately 15% of the total Company customers and 18% of the
Company s total winter send-out during December of 2005. Id. When forecasted peak day
send-out on the IFL is matched against the existing peak day distribution capacity, a peak day
delivery deficit occurs during 2007 and increases thereafter. Id. Intermountain believes that
small, short duration peak day distribution delivery deficits in the future can be mitigated by
working with customers who have the potential to cut their peak day consumption by switching
to fuel oil during extremely cold temperatures. IRP at 5. However, the Company stated that the
projected delivery deficits are of such magnitude that "looping" of the existing system is
warranted to add necessary firm delivery capability to the area.
Sun Valley Lateral Region
The Company s residential, commercial and industrial customers in the Sun Valley
Lateral (SVL) region account for 4% of the total customer base and 4% of the Company s total
winter send-out during December of 2005. Id. When forecasted peak day send-out on the SVL
ORDER NO. 30159
is matched against the existing peak day distribution capacity, a peak day delivery deficit occurs
during 2009 and increases thereafter. The tourism industry-related industrial load on the SVL is
limited in size and does not currently have the capability to switch to alternative fuels in order to
mitigate peak day send-out. Id. at 6. The Company believes that the growth in the SVL will
warrant future upgrades to the existing pipeline system, and the Company plans to increase the
delivery capability and capacity on the SVL through a series of cost-effective system upgrades.
Id.
Canyon County Region
Fourteen percent (14%) ofthe Company s residential, commercial and industrial load
is served off the Canyon County Lateral (CCL) region, and it accounted for 13% of the
Company s total winter send-out during December of 2005. Id. When forecasted peak day
send-out on the CCL is matched against the existing peak day distribution capacity, a peak day
delivery deficit occurs during 2007 and increases thereafter. Id. The industrial customer base in
the CCL region does not currently have the capability to switch to alternative fuels as a means of
mitigating peak day send-out and the Company stated that it is currently exploring optional
means of enhancing the distribution capability in this region. Id. at 7.
COMMENTS
Staff timely filed its comments on August 29, 2006. In accordance with PURPA (as
amended by the 1992 Energy Policy Act), and Commission Order Nos. 25342, 27024 and 27098
the Company submitted an IRP that addressed the following elements:
Demand Forecasting
Assessment of Efficiency Improvements (DSM Actions) & Avoided Costs
Natural Gas Supply Options
Natural Gas Purchasing Options and Cost effectiveness
Integration of Demand and Resources
. Two-Year Action Plan
Relationship Between Consecutive Plans (2004 Plan to 2006 Plan)
Public Participation
Legal Effect
Staffs comments addressed each of these in turn. After a complete evaluation ofthe Company
IRP, its methodology and conclusions, the Staff presented four recommendations to the
Commission that focused on the Company s demand forecasting, DSM program and integration
of demand and resources. The Company timely filed its reply comments on September 14 2006.
ORDER NO. 30159
The Company s reply comments addressed each of the Staffs four formal recommendations to
the Commission.
Demand Forecasting
In June 1997 the Commission granted the Company s request to change the planning
horizon for the Company s IRP process from 20 years to 5 years. See Order No. 27024. The
planning period of 2007-2011 used for this IRP meets that requirement. The Company forecast,
that is the basis for the five-year planning period, provides daily, monthly and peak demands and
predicts significant growth of peak demand in the core sectors of residential and commercial
customers and stable peak demand in the industrial sector over the planning period. The forecast,
is based on: (1) growth in the number of households in the service territory commensurate with
growth of the population and the economy, (2) corresponding growth in the number of small
commercial customers, and (3) conversion to natural gas use by residences that presently do not
use natural gas. The Staff stated that it believes the economic forecast issued by John S. Church
in May 2005 and the conservative design heating degree year were appropriate to use in the IRP;
however, it is Staffs opinion that, in general, the forecasting inputs and methodologies used by
the Company are neither as comprehensive nor as robust as they could be. Staff Comments at 4.
The Staff noted the following areas where it felt the IRP was deficient in some
manner:
1. Market Penetration Data.The Staff believes that the market penetration numbers
presented in the IRP are more realistic than those presented in the 2004 IRP. However, the
increasing market penetration going forward seems contradictory to market conditions and
invites more explanation. Id. at 5.
2. Conversion Rate Data.The conversion rates for existing homes noted in this IRP
are less optimistic than in the previous IRP, however, those conversion rates are presented as
generally increasing over the planning period. This seems counter-intuitive because conversion
reduces the size of the non-natural gas users market. Staff suggested that the Company should
provide a fuller explanation of its data and conclusions regarding conversion rates to clarify this
inconsistency. Id.
3. Forecasting Method.Staff believes that the Company employed an overly
simplistic forecasting method that ignores other factors driving demand, such as prices of natural
gas and electricity, seasonality, and timed heating systems among other factors.Staff
ORDER NO. 30159
commented that use of one or more of these other factors could be included to improve the
model with little computational cost. Id. at 6.
4. Range of Pricing Forecasts. Staff commented that the Company used a single
source for the natural gas pricing used in the IRP (the NYMEX market close data), and that no
effective date or dates for the price data was stated in the IRP. Id. The Company stated in its
response to a production request that an additional pricing data point from November 6, 2005
was used in the model to check for the impacts of differing pricing. Id. According to the
Company, the results did not materially effect the model's optimization, thus the Company did
not include details of the modeling run. Staff expressed the need to have more information on
such other data points used and the effect, rather than have the Company omit that information
from the IRP. Id.
5. Price Elasticity of Demand. In Staff s opinion, the demand forecast appears to
lack a consideration of the price elasticity of demand. Id. at 7. Staff noted that although this
factor has not been thought to be significant within the retail price levels of natural gas, the
recent large price increases could result in an expected change in demand of 2.50-75%. Id.
Staff considers this to be a significant change. Id. Staff noted that in its response to a production
request on this topic, the Company stated that it has considered addressing price elasticity of
demand but believes it is not appropriate, primarily due to its belief that price elasticity of
demand will not effect the design weather assumptions for the coldest day to be served. Id.
The Staff recommended that in future IRPs, models that were tested but subsequently
rejected in favor of the documented models be reported (along with a summary of why the
alternatives were rejected), including customer usage over seasonal and annual time periods, a
range of natural gas price forecasts from multiple sources, and price elasticity of demand. Id.
15.
In response to this recommendation, the Company noted that a primary driver of an
IRP is a mathematically-based model created from a system of inputs and constraints. Reply
Comments at 1. Many models with varying inputs and constraints are likely to be run, and the
outcome of a model run may be "rejected" simply because the model could not run to completion
or did not provide satisfactory results without violating any number of model or mathematical
constraints or criteria. Id.
ORDER NO. 30159
The Company asserted that it does include seasonal differences in consumption in the
IRP. Id. at 2. The Company performs individual regression models for peak usage months of
November through February, takes into account the unique usage numbers of the "shoulder
months " and because there are very few heating degree days in July and August, it assumes that
usage in those months is strictly baseload usage. Id.
Intermountain stated that its usage of NYMEX is reasonable as the price reflects the
market consensus of future prices at a given point in time and, when combined with basin
differentials, provide the most reasonable estimate of forecast prices available to the Company.
Id. Further, the Company asserted that other forecast prices have no tie to the economic forecast
provided by John Church, and there is no way to know whether the other price forecast would
provide better or worse results. Id. Lastly, the Company commented "adding several different
price forecasts to each demand scenario could result in a multitude of models when the main
focus of the Company and the Commission is to develop a most likely scenario from which to
build an overall strategy or action plan.Id.
Intermountain commented that because its regression models already include the
impact of declining usage, it believes that including price elasticity in the models would be
inappropriate
. . .
because it has the potential to underestimate the Company s peak-day
requirements. . . .Id. The Company believes that most of the decline in usage is related to non-
peak load and "has masked the true peaking load that will occur" when Idaho again experiences
severely cold weather. Id. at 3. The Company has installed metering equipment in the Sun
Valley and Idaho Falls laterals, where the peak usage per customer is higher than the average
peak user per customer for the rest of its customers. Id. The Company stated that it has not yet
collected sufficient data to conduct statistically significant analyses regarding the customer
usage, but as it accumulates such data, it "look( s J forward to having enough data to test those
correlations in a future IRP.Id.
Assessment of Efficiency Improvements (DSM Resource Options)
Order No. 27098 directed the Company to address efficiency measures in its biennial
IRP with a "general explanation with each IRP filing of whether there are cost effective DSM
opportunities." Order No. 27098 at 2. Prior to that time the Commission required that the IRP
address ". . . a full spectrum of opportunities available to the Company, including conservation
and efficiency measures. . . ." Order No. 25342.
ORDER NO. 30159
In addressing efficiency, the IRP provides an overview of growth of the North
American natural gas markets and makes its case for natural gas being the most efficient energy
source available. IRP at 58-63. Staff recognized that Intermountain goes further by addressing,
among other things, its support and promotion of certain conservation-based programs. Staff
Comments at 8. Staff commented "except for a very general statement of support for these and
similar activities, there is no mention in the IRP of any efficiency or DSM programs or
evaluations of those programs being performed or reviewed by the Company.Id. Staff also
believes that any analysis to identify whether there are other cost-effective DSM opportunities
available is absent from the IRP. Id.
The Staff recommended that in future IRPs, the Company address the "full spectrum
of DSM opportunities available to the Company, including conservation and efficiency
measures" that were part of the IRP process prior to Order No. 27098 and that the IRP process be
modified to require that a cost/benefit evaluation of all feasible DSM measures be performed and
that the Commission consider actions aimed at creating a mechanism that will result in all cost-
effective DSM measures being implemented. Id. at 15.
Intermountain stated in its reply comments to this recommendation that it believes it
has met the requirements of Order No. 27098 that it provide "a general explanation with each
IRP filing of whether there are cost effective demand-side management (DSM) opportunities.
Reply Comments at 4. Intermountain commented that it is continuing "in its efforts to improve
customer education regarding the wise and efficient use of natural gas./d. The Company
believes that market forces are the best motivator for conservation and that consumers have a
strong incentive" to conserve in their usage of natural gas as prices rise. Id. The Company
asserted that moving from "the current market based approach to a system where DSM measures
are Company funded through an incremental charge would put upward pressure on customers
bills at a time when they can least afford it. . ..Id. at 5. The Company does not believe a
return to the DSM measures in place prior to Order No. 29078 would be warranted. Id.
Natural Gas Supply Options
In Staffs opinion, the Company adequately addressed supply-side options in the IRP.
Intermountain provided detail regarding how it currently accesses natural gas from two supply
basins, and extensively uses natural gas storage to assure the ability to meet winter demands.
The Company utilizes both underground and liquefied storage and Intermountain owns
ORDER NO. 30159
underground storage in three different and geographically diverse locations. Staff Comments at
10.
Natural Gas Purchasing Options and Cost Effectiveness
Staff commented that the Company s documentation of its market evaluations and
market fundamentals continues to improve. /d. at 11. The market expertise and experience of
the Company and its purchasing agent are extensive and will provide the background to evaluate
the current guidelines and expand the Gas Supply Risk Management Program as Intermountain
and Staff continue to meet on this topic. Id.
Integration of Demand and Resources
Staff noted that the Company identified certain delivery constraints that fall into two
categories: (1) deficits in delivery to the Company s system from the interstate pipeline, and (2)
deficits in the Company s distribution system capacity for delivery to its customers. Id. These
deficits are addressed in the IRP section entitled "Resource Optimization." IRP at 64. Staff
commented that, according to the IRP, peak day deficits in delivery into the system will grow
substantially from 2007-20 II. Further, the IRP states that this deficit will be met by acquiring an
incremental 25 000 mmbtu of interstate delivery on Northwest Pipeline in Year 1 of the plan
(2007) along with unspecified contracts for matching commodity. Staff Comments at 12. Staff
noted that the IRP mentions merely "fill" (generic acquisition) as the method of meeting the
deficit without further explanation. Staff believes that an improvement to this part of the IRP
would be for Intermountain to define the linkage between identifying the necessary resources
and performance under its natural gas acquisition policies and the Risk Management Program.
Id.
Staff stated the Company set forth, in a response to a production request, how it
originally planned to meet the specific lateral deficits that comprised the basis for much of the
IRP itself. Id. at 13. Staff noted the Company stated in its response that it "has further refined
its plans to eliminate the projected distribution deficits in a more cost efficient manner" and that
further study has resulted in delaying the need for these resources with only brief explanatory
information. Id. (citing Response by Company to Staffs First Set of Production Requests at 5-
6).
Staff recommended that the Company be directed to specifically describe and
evaluate the additional resources that will be acquired, developed or constructed to eliminate
ORDER NO. 30159
demand deficits in commodity supply and transportation in all future IRPs. Id. at 15. Staff
further recommended that the Company be directed to publish an addendum to the Resource
Optimization section of the IRP addressing the changed lateral transportation capacity deficit
positions stated in the Company s response to a production request. Id. at 16.
Intermountain responded that it believes it supplied sufficient information regarding
the resources that will be needed to meet demand. Reply Comments at 5. The Company
commented that the difficulty in providing specific information regarding short-term gas
supplies, including "fill" resources "lies in the fact that they usually become available
unexpectedly" and the timing and availability of these rarely is within the Company s prior
knowledge. Id. at 6.
Further, the Company asserted that despite the errors in the data, they "in no way
affected the optimization model outcome.Id. Intermountain asserted that it has filed corrected
data and believes that filing an addendum would be redundant. Id.
Two-Year Plan
Order No. 25342 mandated that each IRP include a two-year plan "outlining the
specific actions to be taken by the utility in implementing" the IRP. Staff believes that the
Company s five-year IRP provides information that adequately addresses the original need for
requiring the two-year plan, and that it may no longer be necessary for the Company to submit a
two-year plan within its IRP. Staff Comments at 14.
Relationship Between the Plans (2006 IRP vs. 2004 IRP)
Staff believes that the IRP satisfies this requirement. In the comparative analysis
section of the IRP, the Company addresses the differences between the 2004 IRP and the present
IRP. Each major section of the IRP is addressed and the significant differences between the two
plans discussed. Id. at 15.
Public Participation
The Staff believes that the Company met the requirement for public participation in
the IRP process. Public involvement in the IRP process consisted of a half-day session wherein
the Company met with customers, concerned consumer groups and Commission Staff to discuss
the inputs to the IRP and questions and comments were solicited from all present. Id.
Legal Effect
The Staff had no comments on the legal effect of the IRP.
ORDER NO. 30159
DISCUSSION
The Commission has jurisdiction over Intermountain Gas Company, a natural gas
utility, and the issues raised in Case No. INT-06-3 pursuant to the jurisdiction granted under
Title 61 of the Idaho Code and the Commission s Rules of Procedure, IDAPA 31.01.01.000
seq.Commission Order No. 25342 initiated IRP requirements for local gas distribution
companies in accordance with amended Section 303 of PURP A. That Order lists the elements
that the IRP should contain. The Commission has twice modified the requirements for natural
gas IRPs: Order No. 27024 allowed natural gas utilities to shorten the planning horizon to five
years to match the Company s planning horizon and available market products; and Order No.
27098 removed the requirement that IRPs include a formal evaluation of the costs and benefits of
potential DSM programs, stating that a general explanation of whether there are cost effective
DSM opportunities will be sufficient.
An IRP is meant to be a planning document for the Company that takes into account
the many factors and variables that can arise, as it looks at supply and demand in the coming
years. The plan is not meant to be merely an academic or regulatory exercise but a showing to
the public that the Company has prepared for, and has considered, a multitude of scenarios. We
expect each company submitting an IRP to vigorously test each assumption used in its plan to
better ensure that the results of its IRP reflect the changing markets and demand, and
Intermountain is no exception.
The Company fulfilled most of the IRP requirements under our prior Orders and we
appreciate the Company s attention to and efforts regarding those requirements. For certain
requirements, however, we find that the Company did not apply the same rigor.
Demand Forecasting
The Company asserted that it subjected its modeling to a number of variables and
that some of these may have been "rejected" because the modeling could not run to completion
or the modeling did not provide "satisfactory results without violating any number of model or
mathematical constraints or criteria." Reply Comments at 1. That is easily understood, and is
actually expected. The Company should experience some of these results if it is truly pushing
the boundaries of its modeling. What is critical here is for the Company to include a summary of
those factors that may have challenged the modeling. Such a summary keeps the Commission
informed as to how certain factors contributed to the Company s final IRP and provides
ORDER NO. 30159
illumination to the public regarding the issues that the Company faces, including, inter alia
service growth and supply deficits.
The weather certainly plays a primary role in the availability and need for natural gas
and must be considered. However, we find that a healthy model should include other economic
factors to present a clearer picture of the Company s planning. One of these factors is the
difference among the customer classes. Currently, the Company provides a model that groups
the RS-, RS-2 and commercial customer classes together. We find that it would be useful for
the Company to consider scenarios for future IRPs in which the customer classes are separated
and for the IRP to include at least a brief summary of the Company s findings and analyses of
how the separate customers classes affect the modeling outcome and the Company s IRP as a
whole.
Also, we find that the Company should evaluate customer usage over seasonal, as
well as annual, time periods. The Company stated that it uses customers' summertime usage as
its base rate of use. Employing the summer usage may create an acceptable base from which to
compare usage at other times of the year; however, there is no analysis provided to substantiate
that premise. This can be critical as the Company bases a number of conclusions on this one
assumption. A testing of this assumption and disclosure of the results (in at least summary form)
is necessary to instill confidence that the plan is not premised on mere conjecture.
We find that another factor for the Company to include in its model and in the
discussion of its IRP is a range of natural gas price forecasts from multiple sources. The
NYMEX market close is one solid data point, but there are many perspectives and forecasts
available. There is no single consensus on where the market is headed and using additional
forecasts in the modeling will improve the IRP's robustness. Including the additional scenarios
or sensitivity analyses from a variety of forecasts are exactly the product that should be
published in the IRP in order to show that the IRP has resulted in selection of the best plan going
forward. The number of scenarios or the computer sensitivity runs necessary to develop those
scenarios is not an undue burden. Many other utilities in the region perform literally hundreds of
runs for many scenarios to arrive at their planning results. Several other natural gas price
forecasts exist that could be used for comparison, to ensure that not too much weight is placed in
any single forecast.
ORDER NO. 30159
Lastly, we find that the Company should factor the price elasticity of demand into its
calculations. The Company asserted that it includes the impact of declining usage, as caused by
a variety of factors, in its modeling. Unfortunately, the Company does not further identify how it
includes the impact of declining usage in its calculations, nor does it include any discussion in
the IRP of what effect the fluctuation in rates may have upon the consumption by its customers.
Instead, the Company dismisses price elasticity as a factor because it believes that it will not
affect the design weather assumptions. Though the Company may logically come to that
conclusion in its analysis, the Commission would prefer to see the analysis conducted and
presented rather than have the appearance of an IRP driven by an assumption.
In future IRPs, if the Company deems that any of the above factors provide no
improvement on formulating its resource plan, we expect documentation and at least a narrative
summary to support that conclusion. Such information may appear in the body of the IRP or in
an appendix, as appropriate, but it should be included to demonstrate the factors that determined
the Company s filing.
Assessment of Efficiency Improvements (DSM Resource Options)
We commend the Company for its efforts in providing resources on its website, in
brochures and other media to educate its consumers on ways they can conserve energy, as well
as its participation in Rebuild Idaho, its support of the Gas Technology Initiative, and certain
other activities. These activities are relatively passive, however, and comprise only one part of
the equation in formulating a complete DSM program. Education and information are an
important aspect of a DSM program even though providing information and education is not a
DSM measure in and of itself and does not create alternative resources that can be quantified and
substituted for supply side resources.
The DSM measures set forth in the 2006 IRP mirror those in the 2004 IRP without
any mention of whether additional measures were evaluated for cost-efficiency in the intervening
years. Prior Commission Orders require that the Company continually seek out and evaluate
new measures that may be added to its DSM program. We find that for future IRPs, the
Company should address the full spectrum of DSM opportunities available to it, including both
conservation and efficiency improvement measures, and that the Company shall provide a
summary as to the cost-effectiveness of all measures considered even if they are not selected for
implementation.
ORDER NO. 30159
A DSM program based on a robust mixture of measures selected and implemented
after appropriate analysis will produce positive results. The entire premise of Commission Order
No. 27098 is that the Company examine and implement cost-effective DSM opportunities. The
Commission reaffirms that it does not intend for the Company to chase opportunities that would
be counter-productive and inefficient. The Commission s philosophy regarding DSM has been
clearly stated in its Orders - it strongly supports the development and implementation of DSM
measures and wants natural gas utilities in Idaho to investigate and implement cost-effective
measures that improve energy efficiency.
Integration of Demand and Resources
We recognize the difficulty of predicting the exact timing necessary to assure that
both transport and commodity are available when a deficit appears in a growing service area;
however, we are confident that the Company can provide accurate planning at least two years in
advance. Additionally, we appreciate that the Company revisited its IRP during the review
period and further refined its plans to mitigate or eliminate projected capital improvements
needed to meet distribution deficits. It is welcome to learn that the Company has conducted
some early research that shows that new technology may allow the Company to delay certain
expensive pipeline upgrades in areas of the system. Upon review, however, the IRP does not
clearly and adequately match those deficits with planned resources so that any reader of the IRP
can understand what is needed and what is planned. The Company s brief statements in its
response to a production request leave the Commission desiring additional explanation.
Based upon its review ofthe Company s filings in this case, as well as the review and
recommendations of the Staff, the Commission accepts Intermountain Gas Company s 2006
Natural Gas IRP for filing. This acknowledgement and acceptance of the IRP should not be
interpreted as approval of the plan or as a judgment of the prudence of any transactions
undertaken as part of the plan.
ORDER
IT IS HEREBY ORDERED that the Commission accepts the Intermountain Gas
Company 2006 Natural Gas Integrated Resource Plan for filing.
IT IS FURTHER ORDERED that in future IRPs, Intermountain Gas Company shall
report models that were tested and rejected along with a summary of why they were rejected, and
ORDER NO. 30159
will include in the models customer usage over seasonal and annual time periods, a range of
natural gas price forecasts from multiple sources and the price elasticity of demand.
IT IS FURTHER ORDERED that in future IRPs, the Company shall address the full
spectrum ofDSM opportunities available to the Company, including conservation and efficiency
measures and shall submit a cost/benefit evaluation of all feasible DSM measures be performed.
IT IS FURTHER ORDERED that the Company shall specifically describe and
evaluate the additional resources that will be acquired, developed or constructed to eliminate
demand deficits in commodity supply and transportation in all future IRPs.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally
decided by this Order) may petition for reconsideration within twenty-one (21) days of the
service date of this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code ~~ 61-
626 and 62-619.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this Z-rJ.--
day of November 2006.
~ER
ATTEST:
()zttAh~ ~WJ
Jean D. Jewell
Commission Secretary
O:INT -06-03 - cg2
ORDER NO. 30159