20240806Application.pdf

RECEIVED
INTERMOUNTAIN' Tuesday, August 6, 20 A C GAS COMPANY IDAHO PUBLIC
A Subsidiary of MDU Resources Gmup,Inc.
UTILITIES COMMISSION
In the Community to Serve®
August 6, 2024
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
RE: Case No. INT-G-24-03
Dear Ms.Noriyuki:
Attached for consideration by this Commission is an electronic submission of Intermountain Gas
Company's Application for Authority to Revise Rate Schedule EEC-RS —Residential Energy
Efficiency Charge and the EEC-GS—Commercial Energy Efficiency Charge with prices proposed
to be effective on October 1, 2024.
If you should have any questions regarding the attached,please don't hesitate to contact me at(208)
377-6015.
Sincerely,
/s/Lori A. Blattner
Lori A. Blattner
Director, Regulatory Affairs
Intermountain Gas Company
Enclosure
cc: Mark Chiles
Preston Carter

INTERMOUNTAIN GAS COMPANY
CASE NO. INT-G-24-03
APPLICATION,
EXHIBITS,
AND
WORKPAPERS
In the Matter of the Application of INTERMOUNTAIN GAS COMPANY
For Authority to Revise Rate Schedule EEC-RS — Residential Energy Efficiency
Charge and EEC-GS - Commercial Energy Efficiency Charge

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of Case No. INT-G-24-03
INTERMOUNTAIN GAS COMPANY APPLICATION
for Authority to Revise Rate Schedule
EEC-RS—Residential Energy Efficiency
Charge and EEC-GS Commercial
Energy Efficiency Charge
Intermountain Gas Company("Intermountain"or"Company"), a subsidiary of MDU
Resources Group, Inc.with general offices located at 555 South Cole Road,Boise, Idaho,pursuant
to the Rules of Procedure of the Idaho Public Utilities Commission("Commission"),requests an
order: 1) authorizing a decrease in the Residential Energy Efficiency Charge,Rate Schedule EEC-
RS, from$0.015640 per therm to $0.01149 per therm, effective October 1,2024; and 2) authorizing
a decrease in the Commercial Energy Efficiency Charge, Rate Schedule EEC-GS from$0.00320 to
zero.
Please address communications regarding this Application to:
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
[e-mail]
[e-mail]
and
Lori A. Blattner
Director—Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608
Boise, ID 83707
[e-mail]
CASE NO. INT-G-24-03
APPLICATION Page 1

In support of this Application,Intermountain alleges and states as follows.
I.INTRODUCTION
Intermountain is a gas utility, subject to the jurisdiction of the Commission, engaged in the
sale of and distribution of natural gas within the State of Idaho under authority of Commission
Certificate No. 219, issued December 2, 1955, as amended and supplemented by Order No. 6564,
dated October 3, 1962.
Intermountain provides natural gas service to the following Idaho communities and counties
and adjoining areas:
Ada County-Boise,Eagle,Garden City,Kuna,Meridian, and Star;
Bannock County-Arimo,Chubbuck,Inkom,Lava Hot Springs,McCammon, and Pocatello;
Bear Lake County-Georgetown,and Montpelier;
Bingham County-Aberdeen,Basalt,Blackfoot,Firth,Fort Hall,Moreland/Riverside, and
Shelley;
Blaine County-Bellevue,Hailey,Ketchum,and Sun Valley;
Bonneville County-Ammon,Idaho Falls,Iona, and Ucon;
Canyon County-Caldwell, Greenleaf,Middleton,Nampa,Parma, and Wilder;
Caribou County-Bancroft, Grace, and Soda Springs;
Cassia County-Burley,Declo,Malta,and Raft River;
Elmore County-Glenns Ferry,Hammett,and Mountain Home;
Fremont County-Parker and St.Anthony;
Gem County-Emmett;
Gooding County-Bliss,Gooding,and Wendell;
Jefferson County-Lewisville,Menan,Rigby,and Ririe;
Jerome County-Jerome;
Lincoln County- Shoshone;
Madison County-Rexburg and Sugar City;
Minidoka County-Heyburn,Paul,and Rupert;
Owyhee County-Bruneau,Marsing,and Homedale;
Payette County-Fruitland,New Plymouth, and Payette;
Power County-American Falls;
Twin Falls County-Buhl,Filer,Hansen,Kimberly,Murtaugh,and Twin Falls;
Washington County-Weiser.
Intermountain's properties in these locations consist of transmission pipelines,liquefied
natural gas storage facilities, compressor stations, distribution mains, services,meters and
regulators, and general plant and equipment.
CASE NO. INT-G-24-03
APPLICATION Page 2

IL BACKGROUND
In Order No. 35539, Case No. INT-G-22-05,the Commission authorized the Company's
current Residential Energy Efficiency Charge("EEC-RS")of$0.01564 on Rate Schedule EEC—
RS. The EEC-RS allows the Company to fund its Residential Energy Efficiency Program("EE-RS
Program"). The current EEC-RS was based on a three-year average forecasted annual budget of
$4,129,712 of total annual program expenditures that included direct rebate expenses,personnel
expenses, and program delivery.
In Order No. 34941, Case No. INT-G-20-04,the Commission authorized the Company's
Commercial Energy Efficiency Charge("EEC-GS")of$0.00320 on Rate Schedule EEC—GS. The
EEC- GS allows the Company to fund its Commercial Residential Energy Efficiency Program
("EE-GS Program"). The current EEC-GS was based on a forecasted annual budget of$411,000 in
total annual program expenditures that included direct rebate expenses,personnel expenses, and
program delivery.
III. BALANCES
As of June 30,2024,the Company had an over-collected EE-RS Program balance of
$1,919,667.40. The over-collected balance has two primary causes. First,actual therm sales were
higher than the forecast used to calculate the current EEC-RS. Secondly,revisions to the Residential
Energy Efficiency Program that were effective in April 2021,resulted in changes to the total dollars
paid in rebates compared to the forecast.
As of June 30,2024,the Company had an over-collected EE-GS Program balance of
$1,029,904. The over-collected balance is due to the slow uptake in the Commercial Energy
Efficiency program by commercial customers.
IV.RESIDENTIAL PROPOSAL
To allow for participation in the program by all interested residential customers, while
more accurately matching revenues with expenses and reducing the over collected deferral
balance, the Company proposes to decrease the EEC-RS from$0.01564 to $0.01149. Exhibit No.
1,Page 1 shows the derivation of the proposed per therm EEC-RS,which is calculated by dividing
the Average Forecast Annual Budget minus the Over Collected Balance Amortization by
normalized therm sales for Rate Schedule RS, as determined in the Company's annual Purchased
Gas Adjustment("PGA") filing.
CASE NO. INT-G-24-03
APPLICATION Page 3

The proposed EEC-RS charge is based on estimated average annual program costs for the
time period of 2024 through 2026 of approximately $4,129,712. The estimated annual program
costs are shown on Exhibit No. 1, Page 2, Line 6, Column(e). Forecast EE-RS Program
expenses are comprised of labor, promotional and program delivery, and rebates paid directly to
residential customers.
Labor is forecast to increase by 2% over the 2024-2026 time period. Promotional
expenses are also forecast to increase by 2%. The three-year averages of the labor and
promotional and program delivery expense categories are found on Exhibit No. 1, Page 2, Lines
3 and 4, Column(e).
The forecast rebate expenses are based the current rebate offering,past performance and
a forecast of future rebate performance. Average forecasted rebate expenditures for 2024 thru
2026 are $3.3 million as shown on Exhibit No. 1, Page 2, Line 5, Column(e).
The 2021 program revision increased incentives on some underperforming, cost-effective
measures and reduced the incentives of other rebates like the new construction measures. To
account for improvements in building energy code implemented in 2021, therm savings
attributed to the whole home measure were reduced, which resulted in reducing the incentive
from $1,200 per home, to a two-tiered incentive of either $900 or$700 per home.
Supply chain issues in obtaining the 97% annual fuel utilization efficiency("AFUE") furnace
required for Whole Home Tier I, in addition to meeting the higher energy performance target of
three air change per hour("ACH"), resulted in low participation in the Whole Home Tier I rebate
reducing rebate expenditures in the new construction category.
Introduction of the smart thermostat rebate and increased incentive amounts for water
heating equipment have demonstrated upward trends in participation. While participation rates of
these rebates are projected to grow, the total rebate is much lower than the pre-2021 amount for
new construction. The Company believes the proposed reduction in the rate will eliminate the
over collected balance while still allowing the program to grow.
V. COMMERCIAL PROPOSAL
While the EE-GS Program continues to grow, that growth has been on a slower trajectory
that previously forecast. To reduce the over collected balance while still allowing for continued
program growth, the Company proposes to decrease the EEC-GS from $0.00320 to zero,
suspending EEC-GS collections. Exhibit No. 2, Page 1 shows the derivation of the proposed per
CASE NO. INT-G-24-03
APPLICATION Page 4

therm EEC-GS, which is calculated by dividing the Average Forecast Annual Budget to be
collected from commercial customers minus the Over Collected Balance Amortization by
normalized therm sales for Rate Schedule GS. Reducing the rate to zero allows full participation
in the program while reducing the deferral balance by approximately half by the end of 2026.
The proposed EEC-GS charge is based on estimated average annual program costs for the
time period of 2024 through 2026 of approximately $301,583. The estimated annual program
costs are shown on Exhibit No. 2, Page 2, Line 6, Column(e). Forecast EE-GS Program
expenses are comprised of labor, promotional and program delivery, and rebates paid directly to
commercial customers.
Labor is forecast to increase by 2% over the 2024-2026 time period. Promotional
expenses are also forecast to increase due to increased outreach and promotional expenses as
well as a planned evaluation, measurement and verification ("EM&V") study in 2025. The three-
year averages of the labor and promotional and program delivery expense categories are found
on Exhibit No. 2, Page 2, Lines 3 and 4, Column (e).
The forecast rebate expenses are based on the current rebate offering, past performance
and a forecast of future rebate performance. The forecast includes implementing additional
commercial measures as well as implementing custom energy efficiency commercial projects in
2026 which could have a dramatic impact on future rebate expenses. Average forecasted rebate
expenditures for 2024 through 2026 are $184,371 as shown on Exhibit No. 2, Page 2, Line 5,
Column(e).
VI. REVENUE AND BILL IMPACTS
By reducing the EEC-RS going forward,the Company estimates the over collected deferral
balance will be nearly eliminated by the end of 2026. The ending deferral balance, incorporating the
proposed changes, is illustrated on Exhibit No. 1, Page 2,Line 8.
The proposed EEC-RS will decrease annual revenues by approximately$1.23 million.A
typical Residential customer of Intermountain would see a monthly decrease of$0.27 or(0.53%) as
a result of the reduction in the EEC-RS charge.
Through suspending collections of the EEC-GS, the Company estimates the over
collected deferral balance will be reduced by approximately half by the end of 2026. Planned
program changes may result in a more rapid elimination of the deferral balance. The ending
CASE NO. INT-G-24-03
APPLICATION Page 5

deferral balances, incorporating the proposed changes, is illustrated on Exhibit No. 2, Page 2,
Line 8.
The proposed EEC-GS will decrease annual revenues by approximately $464,000. A
typical Commercial customer of Intermountain would see a monthly decrease of$1.09 or
(0.47%) as a result of the reduction in the EEC-GS charge.
VII.RATE SCHEDULES
The Company proposes to make the EEC-RS and EEC-GS reductions effective October 1,
2024,to coincide with the effective date of the price change related to the Company's annual PGA
filing. Intermountain believes this timing will provide an accurate picture to customers of what to
expect on their bills heading into winter.
Intermountain's current Rate Schedules EEC-RS and EEC-GS showing proposed changes in
legislative format are attached as Exhibit No. 3. The Company's resulting proposed Rate Schedules
EEC-RS and EEC-GS (clean versions)are attached as Exhibit No. 4. Exhibit Nos. 3 and 4 are
incorporated by reference.
The proposed changes to the EEC-RS and EEC-GS Rate Schedules will also flow through
to the Company's Rate Schedules RS and GS-1. Because those Rate Schedules will also be
impacted by the Company's annual PGA filing, Intermountain is not filing proposed changes to
Rate Schedules RS and GS-1 in this filing. The proposed EEC-RS and EEC-GS will be included in
the Rate Schedules RS and GS-1 that are filed in the PGA filing. Any changes to the proposed rates
in this proceeding would be made to Rate Schedules RS and GS-1 in a compliance filing.
VHI.PRESS RELEASE AND CUSTOMER NOTICE
This Application will be brought to the attention of Intermountain's customers by including
notice of this proposed rate change in the Company's PGA Customer Notice and Press Release sent
to daily and weekly newspapers, and major radio and television stations in Intermountain's service
area. The Press Release and Customer Notice will be included with the Company's PGA filing.
IX.MODIFIED PROCEDURE
Intermountain requests that this matter be handled under modified procedure pursuant to
Rules 201-204 of the Commission's Rules of Procedure. Intermountain stands ready for immediate
consideration of this matter.
CASE NO. INT-G-24-03
APPLICATION Page 6

X.REQUEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Commission approve a decrease in the Residential Energy Efficiency Charge,
Rate Schedule EEC-RS, from$0.015640 per therm to $0.01149 per therm, effective
October 1,2024; and
b. That the Commission also approve a decrease in the Commercial Energy Efficiency
Charge, Rate Schedule EEC-GS from$0.00320 to zero.
c. That this Application be heard and acted upon without hearing under modified procedure,
and,
d. For such other relief as this Commission may determine just and proper.
CASE NO. INT-G-24-03
APPLICATION Page 7

DATED: August 6, 2024
INTERMOUNTAIN GAS COMPANY GIVENS PURSLEY LLP
64 L,
By By
Lori A. Blattner Preston N. Carter
Director—Regulatory Affairs Attorney for Intermountain Gas Company
CASE NO. INT-G-24-03
APPLICATION Page 8

EXHIBIT NO. 1
CASE NO. INT-G-24-03
INTERMOUNTAIN GAS COMPANY
PROPOSED RESIDENTIAL ENERGY EFFICIENCY CHARGE
(2 pages)

Exhibit No. 1
Case No. INT-G-24-03
Intermountain Gas Company
Page 1 of 2
INTERMOUNTAIN GAS COMPANY
Proposed Residential Energy Efficiency Charge
Line No. Description Amount
(a) (b)
1 Average Forecast Annual Budget $ 4,129,712
2 Over Collected Balance Amortization (725,000)
3 Average Annual Collection 3,404,712
4 2023 Normalized Volumes 296,432,743
5 Proposed EEC-RS $ 0.01149

Exhibit No. 1
Case No. INT-G-24-03
Intermountain Gas Company
Page 2 of 2
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EXHIBIT NO. 2
CASE NO. INT-G-24-03
INTERMOUNTAIN GAS COMPANY
PROPOSED COMMERCIAL ENERGY EFFICIENCY CHARGE
(2 pages)

Exhibit No.2
Case No. INT-G-24-03
Intermountain Gas Company
Page 1 of 2
INTERMOUNTAIN GAS COMPANY
Proposed Commercial Energy Efficiency Charge
Line No. Description Amount
(a) (b)
1 Average Forecast Annual Budget $ 301,583
2 Over Collected Balance Amortization (301,583)
3 Average Annual Collection -
2 2023 Normalized Volumes 144,924,551
3 Proposed EEC-GS $ -

Exhibit No.2
Case No. INT-G-24-03
Intermountain Gas Company
Page 2 of 2
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EXHIBIT NO. 3
CASE NO. INT-G-24-03
INTERMOUNTAIN GAS COMPANY
PROPOSED TARIFF
(Legislative Format)
(2 pages)

I.P.U.C. Gas Tariff
Rate Schedules
Third Fourth Revised Sheet No. 17(Page IDAHO PUBLIC UTILITIES COMMISSION
1 of 1) Approved Effective
Name Intermountain Gas Company Oct. 4, 2022 Oct. 1, 2022
n n
of Utility p yPer ON 3553�
Jan Noriyuki Secretary
Rate Schedule EEC-RS
RESIDENTIAL ENERGY EFFICIENCY CHARGE
APPLICABILITY:
Applicable to customers taking service under Rate Schedule IRS. The Energy Efficiency Charge is
designed to fund administrative and program delivery costs incurred by the Company for energy
efficiency services provided to customers as outlined in Rate Schedule EE-RS.
MONTHLY RATE:
The Monthly Rate is equal to the applicable Energy Efficiency Charge multiplied by the monthly billed
therms.
Schedule Energy Efficiency Charge
Rate Schedule IRS $0.01-5640.01149
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director—Regulatory Affairs

I.P.U.C. Gas Tariff IDAHO PUBLIC UTILITIES COMMISSION
Rate Schedules
First RevisegQr� Sheet No. 19(Page 1 of 1) Approved Effective
Name Ill 74 7071 April
of Utility Intermountain Gas Company SAW 1A
Jan Noriyuki Secretary
Rate Schedule EEC-GS
GENERAL SERVICE ENERGY EFFICIENCY CHARGE
APPLICABILITY:
Applicable to customers taking service under Rate Schedule GS-1. The Energy Efficiency Charge is
designed to fund administrative and program delivery costs incurred by the Company for energy
efficiency services provided to customers as outlined in Rate Schedule EE-GS.
MONTHLY RATE:
The Monthly Rate is equal to the applicable Energy Efficiency Charge multiplied by the monthly billed
therms.
Schedule Energy Efficiency Charge
Rate Schedule GS-1 $0.003200.00000
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director— Regulatory Affairs
€ffeGtive: April 1, 2021

EXHIBIT NO. 4
CASE NO. INT-G-24-03
INTERMOUNTAIN GAS COMPANY
PROPOSED TARIFF
(Clean Format)
(2 pages)

I.P.U.C. Gas Tariff
Rate Schedules
Fourth Revised Sheet No. 17(Page 1 of 1)
Name Intermountain Gas Company
of Utility
Rate Schedule EEC-RS
RESIDENTIAL ENERGY EFFICIENCY CHARGE
APPLICABILITY:
Applicable to customers taking service under Rate Schedule RS. The Energy Efficiency Charge is
designed to fund administrative and program delivery costs incurred by the Company for energy
efficiency services provided to customers as outlined in Rate Schedule EE-RS.
MONTHLY RATE:
The Monthly Rate is equal to the applicable Energy Efficiency Charge multiplied by the monthly billed
therms.
Schedule Energy Efficiency Charge
Rate Schedule IRS $0.01149
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director— Regulatory Affairs

I.P.U.C. Gas Tariff
Rate Schedules
First Revised Sheet No. 19(Page 1 of 1)
Name Intermountain Gas Company
of Utility
Rate Schedule EEC-GS
GENERAL SERVICE ENERGY EFFICIENCY CHARGE
APPLICABILITY:
Applicable to customers taking service under Rate Schedule GS-1. The Energy Efficiency Charge is
designed to fund administrative and program delivery costs incurred by the Company for energy
efficiency services provided to customers as outlined in Rate Schedule EE-GS.
MONTHLY RATE:
The Monthly Rate is equal to the applicable Energy Efficiency Charge multiplied by the monthly billed
therms.
Schedule Energy Efficiency Charge
Rate Schedule GS-1 $0.00000
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director— Regulatory Affairs