20080909Reply Comments.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY RECE\VEO
555 SOUTH COLE ROAD · P.O. BOX 7608 · BOISE,IDAHO 83707 · [phone] · FAX: 377-6ñáa SEl -9 PM t.: 40
tOAHO p \~S\ONSeptember 9, 2008 UTtUT\E.S CO
Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 W. Washington
Boise,ID 83702-5983
RE: INT -G-08-02
Reply Comments of Intermountain Gas Company
Dear Mrs. Jewell,
In response to the Comments of the Commission Staff filed in regards to the above
referenced Case, Intermountain Gas Company hereby respectfully submits for consideration
by the Commission the following remarks.
The Company notes the thoroughness of Staffs analysis and appreciates its suggestions to
enhance the Company's efforts to construct a sound planing document that not only meets
Commission requirements but also provides meaningful information for Staff, Intermountain
and the natural gas customers of Southern Idaho.
Staff Recommendation No.1: That the Company provide an analysis of how accurately its
"IGC Conversion Rate" and "IGC Commercial Multiplier Rate" predict growth in number
of customers and load over time.
The Company does track the above rates on an ongoing basis and wil, in futue IRs,
provide that data showing the correlation between the projected and actual rates.
Staff Recommendation No.2: That the Company continue to monitor the benefit of
enhancing its ERT system technology for selected sampling given the associated costs.
Intermountain recognizes the value that more frequent data sampling provides, using data
gathered through the use of its' currently existing ERT technology or as provided through the
use of other data gathering techniques. As the Staff points out as par of the above
recommendation, there is an associated cost with any data collecting tool. At this juncture,
the Company is concerned about the effect (cost) that more frequent access (electronic
interrogations) to these ERT devices will have on the both the useful life of these devices and
the potential loss of data should these devices fail due to premature loss of battery life. The
Company is evaluating ways to improve access to the ERT data and will report on those
efforts as par of its next IR.
Staff Recommendation No.3: The Company wil continue to briefly summarize the
statistical signifcance, outcome, and decisions resulting from the Company's more complete
SVL and IFL total daily usage data.
Intermountain continues to collect the total daily usage data on both the Sun Valley and
Idaho Falls Laterals and is hopeful that the data wil soon provide statistically valid
information that wil assist in its efforts to more accurately analyze daily usage patterns on
these laterals. Intermountain will include a detailed sumary of these findings in future
IRs.
Staff Recommendation No.4: That the Company define the effectiveness of DSM
opportunities as both year-round and peak gas savings, and elaborate on cost effective
programs with a framework for program design, estimating costs, deployment potential, peak
savings, year-round savings and implementation deadlines.
Intermountain believes that one of the primary objectives or critical benchmarks of the IR
process is to plan for and ensure that suffcient interstate and distribution resources are
available to serve its firm sales customers durng an extreme weather event - or peak day.
The Company does recognize that the effcient use of natural gas provides year-round
benefits. The programs targeted by Intermountain not only provide peak day mitigation but
also year-round savings for the customer. Intermountain's future IR's wil better define the
effectiveness ofDSM opportunities both year-round and during the peak day.
Staff Recommendation No.5: That the Company provide more detail on the diferences in
DSM evaluation between its IRPs.
Intermountain's future IRP's wil provide this more detailed comparison.
Staff Recommendation No.6: That the Commission remove the statement requiring "A
short-term (e.g., two-year) plan outlining the specifc actions to be taken by the utility in
implementing the integrated resource plan. " Order 25342, page 4.
The Company agrees that the two-year plan is redundant and appreciates and supports Staffs
recommendation to remove it from future IR requirements.
Please fee free to call me at 377-6168 should you have any questions regarding the above
Reply Comments.