20240410Staff 33 to INT.pdf

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Wednesday,Apri110,202412.4213 PM
IDAHOPUB IC
UIIIITIES Cb1VMS4ON
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )
GAS COMPANY'S 2023 INTEGRATED ) CASE NO. INT-G-23-07
RESOURCE PLAN )
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Intermountain Gas Company("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY,APRIL 24, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
' Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff's
attorney at(208)334-0314.
FOURTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 APRIL 10, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 33: In its response to Production Request No. 25, the Company
explains that measures without existing data are calibrated with respect to existing measures with
a similar end use. Please provide a list of measures that are calibrated in this way to the same
end use as the existing furnace and whole home rebates.
a. For each of these measures,please identify if they are classified as technical,
economic, or achievable selections by the CPA; and
b. Please define the end use or uses associated with the furnace and whole home
measures.
DATED at Boise, Idaho, this 10th day of April, 2024.
61, LZI.-
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\INT-G-23-07 PR#4.docx
FOURTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 APRIL 10, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10"'DAY OF APRIL 2024, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-23-07, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR—REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL: prestoncarter givenspursley com
E-MAIL: lori.blattner(o),int as.com stephaniew givenspursley.com
PATRICIA JORDAN
CERTIFICATE OF SERVICE