20180112Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 10177
RECEIVED
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Street Address for Express Mail
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMTSSION
IN THE MATTER OF THE 2OI7-202I
INTEGRATED RESOURCE PLAN OF
INTERMOUNTAIN GAS COMPANY.
CASE NO. INT.G.I7-04
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Afforney General, and in response to the Notice of
Modified Procedure issued in Order No. 33922 on October 26,2017, submits the following
comments.
BACKGROUND
On August 4,20lT,Intermountain Gas Company (Company) filed its Integrated
Resource Plan (IRP) for the years 2017 -2021. The Company files an IRP every two years to
describe the Company's plans to meet its customers' future natural gas needs. The IRP must
discuss the subjects required by Commission Order Nos. 25342 ,27024 and27098 and Section
303(bX3) of the Public Utility Regulatory Policies Act (PURPA), 15 U.S.C. $ 3202. The
Commission reviews the IRP to ensure that it discusses these subjects and represents a diligent
effort by the Company to plan for the anticipated supply and demand for natural gas.
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ISTAFF COMMENTS JANUARY I2,2OI8
IRP Requirements
In Order No. 25342, the Commission adopted IRP requirements for local gas distribution
companies in response to amended Section 303 of PURPA. The Commission revised the
requirements in Order Nos. 27024 and27098. In summary, these Orders direct gas utilities to
file an IRP every two years that includes:
1. A forecast of future gas demand for each customer class;
2. An analysis of gas supply options for each customer class;
3. A comparative analysis of gas purchasing options, and an explanation of
whether there are cost-effective Demand-Side Management (DSM)
opportunities;
4. The integration of the demand forecast and resource evaluations into a
long range (at least a five-year) plan describing the strategies designed to
meet current and future needs at the lowest cost to the utility and its
ratepayers;
5. A short-term (e.9., two-year) plan outlining the specific actions to be taken
by the utility in implementing the IRP;
6. A progress report that relates the new plan to the previously filed plan; and
7. Public participation.
In Order Nos. 32855 and 33314, the Commission adopted additional requirements
relating to lost and unaccounted for (LAUF) gasl reports and avoided cost calculations to
evaluate DSM opportunities.
Intermountain Gas Company's 2017 -2021 IRP
The Company's 2017-2021 IRP explains that the Company regularly forecasts its
customers' gas needs and determines how to meet those needs. The Company states that its IRP
represents a snapshot in time of the Company's ongoing planning process; it describes the
anticipated conditions over a five-year planning horizon, the anticipated resource selections, and
the process for making resource decisions. IRP at 2.
I Lost and unaccounted for gas is the difference between the amount of natural gas delivered to the Company's
distribution system at the city gate and amount of natural gas billed to customers.
2STAFF COMMENTS JANUARY 72,2018
The Company sells natural gas to two major markets: the residential/commercial market
and the industrial market. The Company forecasts changes in its peak-day loads due to customer
growth under base case, high, and low growth economic scenarios and analyzes five geographic
regions. The Company measured peak-day delivery under each customer growth scenario
against the available natural gas delivery systems to project the magnitude and timing of delivery
deficits on a total Company and regional perspective. The Company analyzed the resources
needed to meet any projected deficits within a framework of options to help determine the most
cost-effective means to manage the deficits.
The Company did not predict any deficits over the next five years when it matched its
forecasted peak-day delivery against its existing resources and planned enhancements to existing
resources.2 Id. at3- 4,5-10.
STAFF ANALYSIS
Staff examined the Company's IRP to determine whether it meets the Commission
requirements and adequately plans for the capability to meet demand from 2017 through 2021.
In general, Staff believes the Company's IRP is reasonable and should be acknowledged.
However, Staff also identified areas for improvement. Staff s review found that while the
Company's IRP demand forecast methodology is generally reasonable, the Company did not
identify the magnitude or timing of deficits that would occur without enhancements to existing
resources. The Company's IRP also did not discuss or compare supply and demand side options
for meeting those deficits. Without this type of gap analysis, it is difficult to determine if the
Company plans to acquire the least cost, least risk resource for customers. Staff recommends
that the Commission direct the Company correct this problem by conducting a gap analysis
similar to what other natural gas utilities conduct. In addition, Staff believes the Company
should provide more information about how it models its storage facilities and DSM resources,
and that it should increase public involvement in the development of the IRP.
2 Enhancements to existing resources includes upgrades planned on the State Street Lateral and in Canyon County,
IRP at72-73.
STAFF COMMENTS J JANUARY 12,2OI8
Demand Forecast
The Company sells natural gas to industrial, commercial, and residential customers. The
Company forecasts that peak day load (demand) on its system will grow by 2.68% annually
under the base case scenario over the five-year planning period. IRP at 3. The majority of
forecasted growth occurs within the Company's core market (residential and small commercial)
customers.
The Company's demand forecast is used to determine the timing and capacity of new
fixed plant additions. The demand forecast is an important driver of expenditures that the
Company will eventually seek to include in its rate base. Overall, Staff believes that the
Company's demand forecast methodology adequately balances the risks of underinvesting in
production plant (and being unable to meet peak demands) and overinvesting in such plant.
Specific elements of the demand forecast are discussed below. In summary, the Company
provided a clear explanation of its customer growth and peak weather forecasting methodologies,
and Staff was able to conclude that these methodologies conform to industry best practices.
However, Staff believes the Company did not provide a complete explanation of the
methodology it used to estimate its usage per customer forecasts, and that these explanations
should be improved in future IRPs.
The Company developed forecasts of customer growth by region, class, cohort, and
market segment using regional, county, and state-wide demographic and economic data from
publicly available sources. The Company's customer growth forecast includes estimates of
customer growth due to new construction, as well as growth due to customers converting to
natural gas from other fuel sources. Staff believes the level of detail used to formulate the
Company's customer growth model is appropriate. Staff appreciates the detailed explanation of
the methodology included in the body of the IRP (pages 14 through 32) and in Exhibit 1.
The Company developed its estimates of peak and needle peak loads using weather
models. Qlleedle peak is a period of consumption due to prolonged periods of cold weather. The
Company uses needle peak loads to determine the size of its distribution mains, pumps, storage
facilities, and other fixed plant.) The Company provided a detailed explanation of its
methodology for developing the weather models. Staff appreciates the level of detail provided
and believes the methodology and estimates are reasonable.
4STAFF COMMENTS JANUARY I2,2OI8
The Company also discussed its usage per customer estimates. However, the Company
provided very little information about how its usage per customer model works and about how it
incorporates information from the Company's growth and peak weather models. The Company
stated it relied on a vendor's software to predict usage per customer and that the vendor uses a
"standard least-squares-fit" of usage and degree days with "additional proprietary
modifications." IRP at37. The Company provided no details about these proprietary
modifications, or why they might be needed. The Company also states that it applied a time
series to develop the usage per customer equations, but offers no details about how this time
series was derived or used.
In future IRPs, Staff would like to see a more thorough explanation of its usage per
customer models, and the time series models that the Company applies to them. In particular,
Staff believes that the Company should more thoroughly explain how it uses its customer growth
forecasts and weather models to determine a system growth rate.
Analysis of Regional Demand and Resources
The Company analyzes demand and available resources for five areas of its system: the
Idaho Falls Lateral, the Sun Valley Lateral, the Central Ada Area, the Canyon County Lateral,
and the State Street Lateral. For each of these areas, the Company does not show any peak day
deficits over the IRP planning period. Id. at3-10. For most of the areas, Staff believes this
analysis is reasonable. However, the Company also explains that enhancements are required in
the Canyon County Region and on the State Street Lateral. See id. at72-73. It thus appears the
Company includes future planned enhancements to its peak firm day delivery capability as
existing resources in its analysis of potential deficits. Staff does not believe that it is appropriate
to include planned enhancements as existing resources when establishing deficits. Staff
discusses these concerns in more detail below.
Canyon County Region
The Canyon County Region ("CCR") is located in southwest Idaho and serves
residential, commercial, and industrial customers. The CCR serves approximately l4oh of the
Company's core customers and approximately l9o/o of industrial peak day sendout in January
2017. The Company indicates that when "forecasted peak day sendout . . . is matched against
5STAFF COMMENTS JANUARY I2,2OT8
the existing peak day distribution capacity, a peak day delivery deficit does not occur during this
IRP period." Id. at7.
However, the Company projects that an enhancement in the CCR-a pipeline
replacement project-is needed within the next five years due to ongoing growth. Id. at73. The
Company states that the project "is the replacement of an existing, high pressure pipeline that has
an unacceptable pressure loss with a larger diameter pipeline that will not constrict flow." IRP at
73. Staffasked for project details in discovery. The Company responded that the project "is a
12" pipeline loop in Caldwell, scheduled for installation in FY20l 8 for an estimated cost of $ I .9
Million." Company Response to Staff Production Request No. 16 (Attachment A). The
Company's deficit analysis assumes distribution transport capacity increases in2020 (IRP at 8),
and Staff understands the increase is due to the enhancement project.
The Company's practice of including future enhancements as existing peak firm day
delivery capability in its analysis of demand and resources obscures the magnitude and timing of
potential capacity deficits and does not provide a transparent and robust method for comparing
alternatives. In future IRP filings, Staff recommends that the Company identify potential deficits
by comparing expected demand to existing capability without planned enhancements. After
deficits have been established, Staff recommends that the Company conduct a transparent and
robust analysis of supply and demand side alternatives to resolve the deficit. Without this
analysis, Staff is unable to determine if the proposed project is the most cost-effective solution.
State Street Lateral
The State Street Lateral ("SSL") is located in southwest Idaho and serves primarily
residential and commercial customers in the Eagle, Meridian, and northwest Boise areas. The
SSL is approximately 16 miles long and serves approximately l4o/o of the Company's total
customers and approximately l5% of the Company's peak day send-out in January 2017. The
Company indicates that when "forecasted peak day sendout . . . is matched against the existing
peak day distribution capacity, a peak day delivery deficit does not occur during this IRP
period." IRP at 9. However, the Company projects that an enhancement on the SSL-a pipeline
retest-is needed within the IRP period. Id. at72. A pipeline retest is a method used to expand
existing facilities by using maximum allowable operating pressure on a pipeline. The Company
states that "[t]he retest can be performed in phases over multiple years that provide increased
6STAFF COMMENTS JANUARY I2,2OI8
capacity as actual growth is experienced, and phasing will minimize the length of pipe that must
be taken out of service along each step." Id. at72. The Company's deficit analysis assumes
distribution transport capacity increases rn2020 (lRP at 9), and Staff understands the increase is
due to the enhancement project.
As with Canyon County, the Company did not discuss the magnitude or timing of any
deficits and did not conduct a transparent analysis of alternatives to meet any deficits. Staff s
concerns here are the same as those described above for Canyon County. Without a transparent
analysis of alternatives, it is not possible to determine if the Company's proposed enhancement
is the most cost-effective alternative.
In addition, Staff requested details about this project in discovery. The Company
responded with estimated cost ($2 million) and timing information (fiscal year 2019) for phase
one of the project, and described that it did not yet have estimates or timing information for
phase two, which is outside of the IRP planning period. See Company Response to Staff
Production Request No. 15 (Attachment A). Staff appreciates the information the Company
provided in discovery, but believes that this basic information should have been included in the
IRP initially. Staff believes that the Company should provide information regarding analysis of
alternatives and an explanation of why a specific solution was selected.
Supply Options
Staff believes that most of the Company's analysis of its supply options is reasonable, but
identified concerns with the Company's analysis of the Nampa liquefied natural gas (LNG)
facility and demand-side management (DSM) resources. Staff discusses these concerns below.
Nampa LNG Facility
In its IRP, the Company states that "Nampa LNG withdrawals go directly into the
Company's distribution system" and that liquid storage, such as the Nampa facility, "will serve
as a needle peak supply." IRP at 56.
Staff attempted to determine which areas could be served by the Nampa LNG facility
and, in discovery, asked the Company to provide a map showing the portions of the Company's
distribution network that can be supplied directly from it. The Company declined to provide the
requested information, claiming the Company considers it "confidential and exempt from public
7 JANUARY 72,2078STAFF COMMENTS
review." Company Response to Staff Production Request No. 22 (Attachment A). Instead, the
Company directed Staff to a map previously supplied to the IPUC's Pipeline Safety Division. 1d
This map lacks sufficient detail to determine which regions of the Company's distribution
network are interconnected to the Nampa LNG facility. Without this information, Staff is unable
to determine which, if any, of the Company's regions could be served by this facility.
Staff also questioned why the Company uses the Nampa LNG facility to meet needle
peaks.3 Given the relatively high costs of gas drawn from its Nampa facility4, Staff asked the
Company to explain why it is preferable to use liquefied gas from the Nampa LNG facility,
rather than compressed gas via the Williams pipeline, to supply gas during needle peak events.
Although the Company's response explained some benefits that might be realized by the Nampa
LNG facility in an emergency or Force Majeure situation, it offered no explanation for why the
Company relies on the Nampa LNG facility to meet relatively common needle peak events. See
Company Response to Staff Production Request No. 23 (Attachment A).
Staff is concerned that the Company did not provide sufficient information on which to
assess the operation and cost-effectiveness of the Nampa LNG facility. This information is
critical in the development of a least cost, least risk resource plan. Similar to Staff s
recommendations regarding planned enhancement projects, Staff recommends that the
Company's 2019 IRP include operational and cost information for its Nampa LNG facility so
that Staffand other parties can assess the function and cost-effectiveness ofthis resource
compared to other options. If the Company believes the information is confidential, Staff will
enter into a protective agreement to safeguard that information.
Demond Side Management (DSM)
The Company's IRP states it promotes the efficient use and conservation of natural gas
through customer education on its website and through direct mailing. Additionally, the
3 Storage facilities, including the Nampa LNG facility, allow the Company to purchase and store gas when peak
demand and prices are low for use during periods ofhigh demand and prices. Staffgenerally agrees that this strategy
results in lower commodity prices for the Company's customers; however, the potential cost savings depend on the
costs of the particular storage method.a The Company explains that Iiquefoing natural gas, the process used at the Nampa LNG facility, is an energy
intensive process that requires the consumption ofone unit ofnatural gas for every three or four units to be
liquefied. IRP at 56. This is relatively more expensive than other storage methods, such as building and operating
underground storage facilities like Clay Basin and Jackson Prairie.
8STAFF COMMENTS JANUARY 12,2018
Company states that it is a member of the Energy Solutions Renewable Energy Workshop and
that it participates in forums that address Idaho's building and energy codes. Staff acknowledges
these efforts and supports the Company's ongoing commitment to advance building and energy
code improvements as a cost-effective resource.
The Company also states that it supports technological advancements in the natural gas
industry by funding and collaborating on projects with the Gas Technology Institute (GTI). The
IRP describes that the Company and GTI tested a commercial natural gas heat pump over the
course of two (2015-2016) winter heating seasons. According to the Company, this project
provided important information about gas heat pump technology in a cold climate. While Staff
does not oppose this research and development (R&D) work, this appears to be the same
research project that the Company discussed in its 2015 IRP. The Company did not explain what
it learned or how the benefits of the project have been or will be implemented in local programs
to help its customers. Staff recommends that the Company use the results of this research project
to develop or enhance the programs in its service territory.
Staff believes the Company has made progress on its DSM efforts. In Order No. 33757,
the Commission approved the Company's request to implement a DSM program. The program
has launched and provides (1) rebates to residential customers for installing high efficiency
natural gas appliances5 and (2) incentives for new homes that qualify as natural gas Energy Star
Certified.6 Staff supports these efforts, but has some concems about how the Company
approaches DSM in the IRP. The Company's IRP states that its DSM objectives are to:
o Provide customer service
o Accommodate high efficiency and off-peak load growth
o Mitigate the need for new staffing resources
o Maintain competitive position as a low-cost energy provider
. Provide environmental benefits
o Focus solely on the most cost-effective DSM measures (IPR at 83).
While Staff does not oppose most of these objectives as ancillary benefits, Staff reminds
the Company that the primary goal of DSM is to acquire cost-effective resources. Further, Staff
5 Including furnaces, combination radiant heat systems, fireplace inserts, and water heaters (standard high efficiency
and high efficiency tankless).
6 The Company estimates that these programs will generate 65,000 therms of savings in2017 and grow to
approximately 374,000 therms in202l. IRP at 85.
9STAFF COMMENTS JANUARY I2,2OI8
does not agree that the Company should focus solely on the most cost-effective DSM measures.
Consistent with the standard DSM expectations, Staff reminds the Company that it should pursue
all cost-effective DSM. Limiting efforts to only the most cost-effective measures would not
provide customers with all the available cost-effective resources.
Staff also believes that the Company has not adequately modeled DSM as a resource in
its IRP. The Company selected certain DSM measures and included only the therms savings
resulting from those measures. Staff believes the Company should have also modeled other
DSM measures to determine which are cost-effective and should therefore be pursued. The
Company also did not discuss how DSM could impact its need for future and planned capacity
upgrades or how its DSM acquisition will impact its load forecast. Nor did it discuss how its
DSM avoided costs will be updated as a result of this IRP.
Staff recognizes that the Company's DSM portfolio is new. The Company is still
building the expertise and collecting the data necessary to implement and model a fully
developed DSM portfolio. Staff understands this process will take time and recommends that the
Company leverage local expertise by convening an energy efficiency advisory group of
stakeholders to assist with the effort. Staff believes that the Company's 2019 IRP should include
a more robust analysis of DSM resources, including a modeling process by which DSM
measures are selected based on cost-effectiveness, an explanation and update ofavoided costs,
and an explanation of the impact of DSM on supply and capacity needs.
Progress since the Previous (2015-2019) IRP
In Order No. 33314 the Commission stated
...We find it reasonable that the Company's future IRPs should include more
detail about how the Company calculates avoided costs and uses those
calculations to determine whether natural gas DSM opportunities are or are
not cost-effective. We appreciate the Company's agreement to provide more
information about both its R&D projects and public participation in the IRP
process. We encourage the Company to work with Staff to improve how the
IRP directs readers to its discussion of improvement projects. Finally, we
appreciate the Company's willingness to participate in the Idaho Building
Code Collaborative to the extent that it is relevant to the Company's business
and services.
Order No. 333 14 at 9. Based on its review, Staff believes that the Company addressed some, but
not all, of these items. For example, the Company provided a summary of its R&D project and
STAFF COMMENTS 10 JANUARY 12,2018
began participating in Idaho Building Code Collaborative meetings. However, the Company
discussion of improvement projects in regional summaries is almost identical to the discussion
included in the last IRP and as noted previously, lacks important information. The IRP also did
not include any description about the Company calculated DSM avoided costs or how those costs
were used to determine the cost-effectiveness of DSM resources.
Public Participation
In addition, public participation in the Company's development of its IRP remains a
concern. Although the Company increased the number of public IRP presentations from three in
the 201 5 IRP to four in the 2017 IRP and encouraged public feedback and input,T Staff believes
the Company should provide an opportunity for public involvement as the IRP is being
developed-not simply after-the-fact. Staff encourages the Company to improve public
participation in the development of future IRPs by convening an IRP advisory group similar to
those used by other natural gas utilities during development of their IRPs.
Lost and Unaccountedfor Gas (LAUF)
In Order No. 32855, the Commission directed the Company to describe how LAUF gas is
managed and explain how those results were achieved. The Commission permits the Company
to recover a maximum of 0.85% of its total throughput as LAUF gas.8 The Company's IRP
reports that its five-year average LAUF rate of 0.31% is one of the best in the industry and
details how those results were achieved. IRP at 80. Staff recognizes the Company's
improvement and believes the Commission's requirements were satisfied in this filing.
STAFF RE,COMMENDATIONS
Staff s primary concern with the Company's IRP is that it does not include a robust or
transparent analysis of the supply and demand side options for meeting capacity deficits. In
addition, Staff believes that the Company should provide more information about how it models
its storage facilities and DSM resources, and that it should increase public involvement in the
development of its IRP.
7 See Company Responses to Staff Production Request Nos. 2, 24 (Attachment A).8 Order No. 30649.
STAFF COMMENTS 1l JANUARY 12,2OI8
Nevertheless, the IRP analyzed residential, commercial, and industrial customer growth
and its impact on the Company's system under multiple scenarios. Peak day sendout under each
scenario was measured against the Company's available natural gas delivery systems to project
deficits on a regional basis. The IRP determined that there are no peak day delivery deficits
when forecasted peak day send-out is matched against existing and planned resources for the
2017-2021IRP period.
Staff therefore recommends the Commission acknowledge the Company's 2017-2021
IRP. To improve future IRPs, Staff also recommends that the Commission require the Company
to:
1. Convene an IRP advisory group made up of key stakeholders and open to the
public.
2. Work with the IRP advisory group to develop an IRP that identifies the magnitude
and timing of potential deficits with existing resources and includes a transparent
analysis of supply and demand side resource options to determine the most cost-
effective solution to all identified deficits.
3. Include a more thorough explanation of per-customer consumption models and
the time series models that the Company applies to them. In particular, the
Company should explain in more detail how it uses its customer growth forecasts
and weather models to determine a system growth rate.
4. Describe how DSM avoided costs change as a result of the IRP.
Respectfully submitted this t{ dayofJanuary20lS
Camille Christen
Deputy Attorney General
Technical Staff: Stacey Donohue
Kevin Keyt
Mike Morrison
i : umisc/comments/intg I 7.4cckkmm comments
STAFF COMMENTS t2 JANUARY 12,2OI8
U"-ilL (a^-rr,--
REQUEST NO. 2: Please describe the Company's efforts to obtain public and
stakeholder participation in development of the 2017 IRP. How, if at all, did these efforts differ
from previous IRP processes?
RESPONSE TO REQUEST NO.2: The Company continued to expand its efforts in
obtaining public and stakeholder participation for the 2017 IRP by including an additional
(fourth) presentation location for the IRP team of employees. The public and stakeholder
participation meetings were held twice in western Idaho, once in central Idaho and once in
eastern Idaho. The Company purchased public meeting notif,rcations in four major newspapers
throughout the territory to advertise these meetings, and personal invitations were sent to public
officials and interested parties, all in an effort to continue to increase participation.
REQUEST NO. 15: On page 72 of the IRP, the Company discusses the State Street
enhancement achieved through a pipeline retest. Please provide a detailed description of the
project phases including cost and time estimates for each phase of the project.
RESPONSE TO REQUEST NO. 15: The planned enhancement for the State Street
Lateral area of interest is a two-phase pipeline retest that will increase operating pressure of the
existing, large diameter pipeline. Phase one of the retest is scheduled for planning in FY2018,
with execution in FY2019. The estimated cost of Phase one is $2,000,000. Phase two of the State
Street Lateral retest is currently outside of the IRP five-year forecast, and a timeline and cost
estimate have not yet been developed.
REQUEST NO. 16: On page 73 of the IRP, the Company discusses Canyon County
enhancements. Please provide cost and time estimates for the project.
RESPONSE TO REQUEST NO. 16: The Canyon County enhancement is a l2"pipeline
loop in Caldwell, scheduled for installation in FY 2018 for an estimated cost of $1.9 Million.
REQUEST NO.22: On page 56 of its application, the Company explains that "Nampa
LNG withdrawals go directly into the Company's distribution system." Please provide a map
showing the Nampa LNG facility and its interconnections with the Company' distribution
system. Identifu the portions of the Company's distribution network that can be supplied directly
from the Nampa LNG facility.
RESPONSE TO REQUEST NO. 22: The Nampa LNG Plant is connected directly to
the largest demand, high pressure pipeline system owned by the Company, which provides an
ideal LNG injection location. A map showing the system supplied directly from the Nampa LNG
Plant would include detailed locations of miles of high pressure pipeline, which the Company
must consider confidential and exempt from public review; although, on August 20,2016,the
Company filed an electronic pipeline and gas storage infrastructure map with the IPUC Pipeline
Safety Division that can be reviewed internally by certain IPUC staff.
Attachment A
Case No. INT-G-17-04
Staff Comments
01ll2lL8 Page I of 2
REQUEST NO. 23: On page 56 of its application, the Company explains that "liquid
storage will serve as a needle peak supply." Please explain why it is preferable to use liquefied
gas from the Nampa LNG facility, rather than compressed gas from the Williams pipeline, to
supply gas during needle peak. Please discuss the benefits of using the LNG facility to supply
gas during needle peak for each of the Company's customer classes (RS, GS, LV, T3 and T4).
RESPONSE TO REQUEST NO. 23: The Nampa LNG Facility plays a vital role in the
overall gas supply portfolio of the Company. LNG is necessary for Peak Shaving during events
such as an Artic Express type of event. The Nampa LNG facility is "behind the gate" meaning
that this facility is within the direct distribution side of the Intermountain system and requires no
upstream capacity requirements and costs as would be needed for other types of resources. This
also provides a secure method of delivering that gas on a peak day where there is no chance of
upstream constraints or supply cuts, In the event of an Operational Flow Order ("OFO" l), the
Nampa LNG facility can mitigate the risks of supply cuts due to OFO's or Force Majeure
situations where contracted flowing gas from suppliers can be disrupted. In addition, LNG is a
very quick delivery method, meaning that the vaporization of LNG can occur at a rapid rate and
can provide 60,000 DTH of natural gas injected into the system daily during a peak event,
ultimately providing the needed supply during high demand. The Nampa LNG Facility benefits
all rate classes within Intermountain's Largest Demand Area. This facility can provide a quick
reliable method of delivering gas needed for the Boise, Nampa and Meridian areas. The gas
delivered to this area also frees up other resources for other parts of the system, along with the
needed upstream capacity requirements. While the T-3 and T-4 customers are required to provide
their own upstream capacity and supply resources as part of their contract with Intermountain,
they do benefit from the LNG plant. In the event a curtailment may be needed, the supply of the
LNG plant would mitigate the risk of curtailment to T-3 and T-4 customers.
REQUEST NO. 24: In Production Request No. 2, Staff asked the Company to describe
efforts to obtain public and stakeholder participation in development of the 2017 IRP. In its
response, the Company described how it expanded public participation by adding a fourth
presentation of the IRP. Did the Company conduct any public outreach prior to performing the
IRP analysis? If yes, please describe such outreach. Additionally, please describe any working
groups or forums that the Company utilized as it developed plans, requirements, and assumptions
for the IRP analysis.
RESPONSE TO REQUEST NO.24: The Company held four public meetings
throughout the service territory with public notification and a robust invitation list to a cross
section of the public to include potentially interested parties and large customers. A key part of
the public meetings was the request and encouragement for feedback and input. The Company
also maintains numerous seats on local economic development boards and committees
throughout the service territory to continually be knowledgeable and involved with growth and
development plans that contribute to the IRP. Lastly, the Company reached out to industrial
customers during the planning and analysis phase as part of our industrial survey, see additional
information on the provided CD under the PR24 folder titled: 2016 IRP Industrial Survey Letter
v2.pdf Survey Sample.pdf
Attachment A
Case No. INT-G-I7-04
Staff Comments
0lll2ll8 Page 2 of 2
CERTIFICATE OF SERVICE
MICHAEL P McGRATH
DIR _ REGULATORY AFFAIRS
INTERMOLINTAIN GAS CO
PO BOX 7608
BOISE TD 83707
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l2th DAY OF JANUARY 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. INT-G-17-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWNG: