20100505Comments.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY
555 SOUTH COLE ROAD. P.O. BOX 7608. BOISE, IDAHO 83707. [phone]. FAX: [phone]
May 4,2010
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iDAHO PUBUG
UTiliTIES COMMtSS
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
P. O. Box 83720
Boise, ID 83720-0074
Re: IPUC Case No. INT-G-09-03
Comments relating to the Snowmelt Workshop
Dear Jean:
As a follow-up to the February 4th, 2010 Workshop in the above referenced Case, Intermountain Gas
Company hereby submits the following comments.
Intermountain Gas Company ("Intermountain" or "Company") wishes to express its appreciation
to the Commission for sponsoring the Workshop and to all participants for the positive
atmosphere and cooperative dialogue that occurred during the Workshop. Intermountain is
committed to meet customers natural gas needs, values their input and believes that useful ideas
were presented during the Workshop.
The Company wishes to assure any affected customers that because its revenues are based on
volumetric sales, Intermountain has no financial motive to unnecessarily interrupt gas sales on its
system. Further, the Company is supportive of practices that help it more thoroughly utilize
existing capacity. Intermountain recognizes that interrptible sales can help increase system load
factor - which can lead to lower costs for all customers - and therefore has the financial
incentive to encourage interruptible load by minimizing the frequency and duration of any
interruption. The purpose of the proposed Snowmelt tariff is to ensure that essential needs for
natural gas are not displaced by discretionary uses and that the Company's firm capacity is used
in the most efficient and cost effective maner possible.
The important issues or questions that were raised at the Workshop are listed below along with
Intermountain's response and/or explanation:
Intermountain Gas actively promoted Snowmelt use and now wants to interrpt it.
Intermountain Gas Company has an obligation to serve if an entity requesting service meets
the Company's approved service provisions. While Intermountain does promote natural gas
use in general, it has neither specifcally promoted, nor discouraged, Snowmelt applications.
Upon any customer requests service, the total required load is determined based on the
information provided and, if suffcient capacity is available, the service is installed. In many
instances however, the larger residential or commercial developments are multi-year
developments and by the time such a project is completed, the final required load has
increased several times over the initial projection. The increase in the final load requirement
is typically not known until the final meter is requested. More often than not, Snowmelt load
drives much of the unexpected load increase.
Do current City Ordinances require Snowmelt systems?
Intermountain reviewed city ordinances for Sun Valley, Ketchum,. Hailey, Bellevue and
Blaine Countyandfound no ordinance requiring Snowmelt. Snowmelt is mentioned in the
Cities of Sun Valley and Bellevue ordinances as a means to reduce the amount ofrequired
onsite snow storage.
All jurisdictions prohibit or limit storing snow in road right of ways. (Although a City of
Ketchum Street Department memo, located on their web site, provides for means whereby
entities in the downtown core may, under certain conditions, push snow into the street for
Street Department removal.) Also, State Codes 40-2319 and 49-613 prohibit debris and
obstructions being placed in road right of ways.
What percentage of Snowmelt customers are commercial vs. residential?
Of the 108 Snowmelt customers identifed in Blaine County, 76% (82) were residential and
24% (26) were commercial.
When would the Company begin to shut off the Snowmelt systems?
Events that would result in Snowmelt interruption are specifcally dependent upon the
pressures within an area in the distribution system; temperature is not necessarily the
determining factor.
Under the proposed Snowmelt tarif Intermountain wouldfirst interrupt Snowmelt in an
affected area of its distribution system when the pressure nears or drops below 20 psig. Per
the Company's General Service Provisions, interruptible services located in areas where gas
supply becomes insuffcient would be the first off
What types of options are available to shutoff Snowmelt applications?
The Company initially proposed to turn off Snowmelt at the Company's meter either
manually or by use of electronically controlled devices. However due to public input received
at the Workshop, Intermountain investigated alternate solutions and subsequently found that
interrupting Snowmelt at the Customer's boiler system offered advantages to both the
customer and the Company. Three (3) diferent types of remote control devices to control a
customer's boilers were researched. All three options eliminate the need for Company
personnel to enter the customer's home and they do not require Intermountain to shut off the
customer's meter eliminating the requirement to relight/recycle equipment when service is
restored:
1. Thefirst option uses a simplistic device similar to a garage door opener where an on/off
switch is installed on the boiler. Company personnel would drive to a point near the
Customer's premise and then remotely turn the Snowmelt system on or off using the
electronic switch. The advantages of such a system are its simplicity and low cost
(expected to be less than $100 per customer). Disadvantages include no abilty to verif
that the switch has turned the boiler on or off and there is no way to evaluate the
reliabilty of the system in real time.
2. The second option - which is the method the Company prefers in today's operating
environment - utilzes an externally located hardwire switch that controls the boiler. The
switch would be placed at a site easily accessible to only Company personnel and would
require the installation of a certain amount of wire, conduit and a locking control box.
Company personnel would drive out to each applicable residence to manually turn the
boiler on or off; a light would indicate the control status. The advantage of this type of
system is its reliability, the abilty to verif on/off status and the relative ease at which it
can be upgraded to a remote controlled system if and when technology and conditions
warrant such a change. The installed cost is estimated at $200 - $500 per customer.
3. The last alternative involves a more elaborate system that can remotely operate a
Snowmelt boiler thru the use of a cell or land-line phone, radio wave devices or the
internet. One particular system evaluated acts as a server, controller, platform and
browser, and can be monitored and controlled through any electronic device connected
to a phone line or the internet. Such a system would also allow for continuous
monitoring, feedback and status of each Snowmelt boiler and would thus offer a better
real-time view of the distribution system. Future upgrades include integrating the
retrieval of temperature, flow, pressure and historical data.
Advantages include a tamper-proof system that does not require an employee to drive to
the premise, provides verifcation of boiler shut-off and a great deal of real-time data.
Disadvantages include the necessity of the customer providing access to an internet
connection, working phone line or satellte service at the boiler location - none of which
Intermountain could control. Further, even if provided by the customer, there are
mountainous or remote areas where internet or other forms of wireless service is
unavailable or unreliable. Also, cost estimates are highest of the three options at $1,000-
$2,000 per customer after an initial startup cost to Intermountain of $3,000 - $5,000
(excluding costs associated with on-going maintenance of communication connections).
How difficult would it be to tie into the Snowmelt equipment's electrical system to control its
activation?
Intermountain contacted several HVAC contractors and received valuable feedback. All
contractors thought the tie-in would be easy to accomplish and indicated that it could be
done either on the 24 volt side or the 120 volt side of the boiler equipment. They also
recommended that the "on/off" switch be located at an outdoor site easily accessible to
Company personnel and that the use of a locking control box of suffcient size would provide
the flexibilty to upgrade the device to a remotely operated system whenfuture conditions
warrant.
The Company appreciates the opportunity to provide more information to the Commission and does
hereby respectfully petition that this Commission adopt Intermountain's Snowmelt tariff.
Katherine J. Barard
Manager
Gas Supply and Regulatory Affairs
cc: Parties of Record