20240822Staff 1-9 to INT.pdf

RECEIVED
Thursday, August 22, 2024 1.06.53 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
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 APPLICATION TO ) CASE NO. INT-G-24-03
REVISE RATE SCHEDULE EEC-RS— )
RESIDENTIAL ENERGY EFFICIENCY )
CHARGE AND EEC-GS COMMERCIAL ) FIRST PRODUCTION
ENERGY EFFICIENCY CHARGE ) REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Intermountain Gas Company
("Company")provide the following documents and information as soon as possible, but no later
than THURSDAY, SEPTEMBER 5, 2024.'
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 AUGUST 22, 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. 1: Please provide all previous forecasts used to determine the EEC-RS
and EEC-GS rates since inception. Please describe the factors that the Company adjusted when
updating the forecasts.
REQUEST NO. 2: For the most recent EEC-RS and EEC-GS forecasts,please provide
all documentation and justifications showing how the forecast was determined. Please note
which factors are driving the doubling of rebate expenditures in 2025 and 2026 in the EEC-GS
forecast.
REQUEST NO. 3: Please explain if the Company included any forecasted expenses for
programs or measures that are not currently approved by the Commission.
REQUEST NO. 4: Please provide Company workbooks detailing forecasted revenues
for 2025 and 2026 with all equations intact and enabled.
REQUEST NO. 5: Please provide a workbook detailing forecasted expenditures within
the residential and commercial program in the 2025 and 2026 program years.
REQUEST NO. 6: In its Application, the Company describes the effects that 2021
program changes have had on participation and expenditures. Application at 4. Please describe
what changes, trends, and information from the 2022 and 2023 program years the Company used
to inform its forecast for the 2024-2026 program years.
REQUEST NO. 7: Please explain the "Potential program changes" adjustment present
in the 2025 and 2026 forecast years and how the Company estimated these values.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 22, 2024

REQUEST NO. 8: In its Application, the Company states that additional commercial
measures included in the forecast are expected to have a dramatic impact on future expenses.
Application at 5. Please provide a list of these additional measures, their estimated cost, their
estimated launch date, participation ramp up, and the source for each of these metrics.
REQUEST NO. 9: In its Application, the Company states that commercial custom
projects included in the forecast are expected to have a dramatic impact on future expenses.
Application at 5. Please provide a description of the efforts the Company has made in pursuit of
custom projects, the results of those efforts to date, a timeline detailing next steps, and a count of
customers engaged in active discussion with the Company on future custom projects.
DATED at Boise, Idaho, this 22nd day of August 2024.
Adam Triplett
Deputy Attorney General
L\Utility\UMISC\PRDREQ\INT-G-24-03 PR#I.docx
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 AUGUST 22, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3!1� DAY OF AUGUST 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-24-03, 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: [e-mail]
E-MAIL: [e-mail] stephaniew(cr�,givenspursle xom
PATRICIAJORDAN
CERTIFICATE OF SERVICE