20101203Reply Comments.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY Fl-ECEl
555 SOUTH COLE ROAD · P.O. BOX 7608 · BOISE, IDAHO 83707 · [phone] · FAX: 377-60fnrnflEc -3 PM 12:11December 3, 2010 . ..
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702-5983
RE: INT-G-10-04
Reply Comments of Intermountain Gas Company
Dear Ms. 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 the Staff's analysis and appreciates its suggestions for
enhancements to the planning process. The Company notes that Staff included comments, assertions
and recommendations within the body of the Staff's Comments, which Il1termountain mayor may not
agree with. However, the Company will limit its Reply Comments only to the three (3)
recommendations found in "STAFF RECOMMENDATION."
Staff Recommendation NO.1: In future IRPs, the Company provides a forecasted versus actual
comparison over the past severallRPs ilustrating the number of conversions per class, number of
customers per class, and usages.
Intermountain's future IRPs will include a summary comparison of number of conversions per class,
number of customers per class, and usage in the "Relationship Between Consecutive Plans" section of
the document. However, due to the 5-year planning horizon of Intermountain's IRP, comparisons
beyond the two consecutive plans would not be meaningfuL.
Staff Recommendation No.2: The Commission clarify the intent of its language in Order No. 26546
regarding future Core-market DSM programs.
Intermountain maintains that the intent of the language in Order No. 26546 was to refrain from the
deployment of Company sponsored conservation rebate programs unless they could be proven to be
cost effective and necessary and therefore in the best interest of Intermountain's customers. As
discussed in the intervening IRPs, the Company has focused its conservation efforts on low cost/no cost
customer education programs and has utilized other cost effective ways to promote reduced energy
usage while limiting the use of cash incentive rebate programs. However, the Company continues to
evaluate whether or not providing cash incentives - to assist customers in choosing the most energy
effcient equipment - meets the quantitative benchmarks as described in the IRP.
Staff Recommendation No.3: The Company notify city leaders in advance offuture IRP public meetings
and filngs.
Intermountain has always appreciated public participation in the IRP process. Two public meetings are
held as part of the IRP process, one in Boise and the other in Pocatello. The Boise area IRP public
meetings have traditionally been well attended. As Staff noted, however, the participation was not as
high at the Pocatello meeting. Intermountain is committed to improve its public participation
throughout the rest ofthe state, and wil reassess its strategies in that regard.
Please feel free to call me at 377-6168 should you have any questions regarding the above Reply
Comments.
Respectfully,
Katherine J. Barnard
Manager - Regulatory and Gas Supply