20200610Formal Comments.pdf

ftf;C H IVEB
?tj?$ JUH I O PH 5: OO
iij ..,;-','r :,u;iLlc::'r 'r : ir::, :.:Ctt&llSSl$'tj
JAYME B. SULLIVAN
BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, tD 83701-0500
Telephone: [phone]
Facsimile : (208) 38 4 -445 4
Idaho State BarNo.: 9231
Email: [e-mail]
Attorney for lntervenor
BEFORE TIIE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. INT-G-20-01IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO REVISE ITS GENERAL
SERVICE PROVISIONS RELATED TO THE
INSTALLATION AND EXTENSION OF
NATURAL GAS MAINS AND SERVICES
CITY OF BOISE CITY'S
FORMAL COMMENTS
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant to
Rule 202 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA 3l .01.01.202)
and, pursuant to that Notice of Modified Procedure, Order No. 34636, filed on April 21, 2020,
hereby submits its formal written comments and states as follows:
l. Boise City has an interest in the equitable assessment of costs for the installation
and extension of natural gas mains and services both as a customer of Intermountain Gas and for
the City's role in ensuring the public benefit to residents and businesses, economic development,
CITY OF BOISE'S FORMAL COMMENTS -Page I
and environmental protection. ln addition, the City has identified goals that encourage the
transition to clean and renewable energy sources. Achieving these goals will be reliant upon
increasing customer participation in natural gas efficiency programs, expanding geothermal
systems, increasing the usage of renewable natural gas.
2. On January 27, 2020, Intermountain Gas Company ("lntermountain") filed this
Application, Application for Authority to Revise its General Service Provisions Related to the
Installation and Extension ofNatural Gas Mains and Services, which among other items, describes
Intermountain using an embedded cost methodology approach to calculate the Allowable
Investnent for residential and commercial line extension projects. Intermountain Gas Company's
Application ("Application"), at 5. lntermountain states that the proposed tariff calculates the
Allowable Investment by estimating the annual therm usage of the customer, then multiplying the
estimated annual therm usage by the Allowable lnvestment Factor.ld. Intermountain also proposes
a methodology to determine the cost of installation for Service Lines, Main extensions, and Line
Extensions. Id. at 6-7.
3. Boise City acknowledges that the financial impacts of the proposed tariffwill vary
based on the nature of the type of installation or extension, whether it constitutes an extension of
a main, a main and a service line, or a service line only. The proposed tariff indicates that the
allowable investment will decrease for service line extensions. Boise City is curious as to whether
the decrease in the allowable investment will affect individual customer costs, including increasing
the cost of residential and commercial construction projects in Boise, where particularly, housing
prices and affordability remain a significant concern. The proposed tariff also indicates that the
CITY OF BOISE'S FORMAL COMMENTS - Page 2
allowable investment will increase forprojects that involve installation or extension of a main line
and a service line. Application at 8-9.
4. The proposed tariff includes a construction overhead of 11.92o/o. Boise City
requests additional information and justification for the use of this overhead percentage.
Application, Exhibit No. 2, Rate Schedule C, Section 5.
5. The supporting report for the proposed tariff includes 80% efficient fumaces as part
of the analysis, while at the same time mentioning that these will no longer meet minimum code
requirements after January 1,2020. Considering this, Boise City requests explanation of why
the 80% efficient fumaces were used in the analysis instead of the 95o/o efficient fumaces, which
would likely be used in new construction resulting from main line and/or service line extensions.
Application, Exhibit No. 3, Musgrove Engineering Residential Energy Consumption Study, 2-4;
12-13.
6. Boise City requests that the Commission obtain clarity on the questions identified
within the comments herein and determine the appropriateness of the noted aspects of the
methodology while considering the proposed tariff. Boise City would encourage lntermountain to
provide supplemental information relating to the comments for the methodology raised by the
City's comments and consider appropriate revisions to the proposed tariff, if appropriate.
DATED this l0th day of June 2020.
ry A,@
Abigail R. Germaine
Deputy City Attorney
CITY OF BOISE'S FORMAL COMMENTS - Page 3
CERTIFICATE OF SERYICE
I hereby certiff that I have on this lOth day of June 2020, served the foregoing documents
on all parties of counsel as follows:
Lori A. Blattner
Director - Regulatory Affairs
lntermountain Gas Company
P.O. Box 7608
Boise,Idaho 83707
Lori. B [e-mail]
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Preston N. Carter
Givens Pursley LLP
601 W. Bannock Street
Boise, Idaho 83702
pnc@ givenspursley. com
kendrah@ givenspursley. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702
diane. holt(@Fuc. idaho. eov
[e-mail]. eov
g U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
Benjamin J. Otto
Idaho Conservation League
710 N 66 Street
Boise,ID 83701
botto@idahoconservation. org
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
@ l,,M
Abigail R. Germaine
Deputy City Attomey
CITY OF BOISE'S FORMAL COMMENTS -Page4