20241220Application.pdf

RECEIVED
AINTERMOUNTAIN°' Friday, December 20, 2024
GAS COMPANY IDAHO PUBLIC
A Subsidiary ofMOUResources Group,Inc. UTILITIES COMMISSION
In the Community to Serve'
December 20, 2024
Ms. Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
RE: Case No. INT-G-24-05
Dear Ms. Barrios-Sanchez:
Attached for consideration by this Commission is an electronic submission of Intermountain Gas
Company's Application for a Determination of 2023 Energy Efficiency Expenses as Prudently
Incurred, including proposed revisions to Rate Schedule EE-RS as well as the Company's 2023
Energy Efficiency Annual Report.
If you should have any questions regarding the attached,please don't hesitate to contact me at(208)
377-6015.
Sincerely,
Is/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-24-05
APPLICATION
AND
EXHIBITS
In the Matter of the Application of Intermountain Gas Company for a
Determination of 2023 Energy Efficiency Expenses as Prudently Incurred and
Approval of Rate Schedule EE-RS

Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
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-24-05
INTERMOUNTAIN GAS COMPANY
for a Determination of 2023 Energy APPLICATION
Efficiency Expenses as Prudently
Incurred and Approval of Rate Schedule
EE-RS
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"), 1) submits its
2023 Energy Efficiency Annual Report, 2) submits an Evaluation,Measurement and Verification
(`BM&V") Study including a billing analysis, 3)makes application to the Commission for an order
designating$3,846,358 of 2023 Energy Efficiency expenditures as prudently incurred and 4)makes
application to revise Rate Schedule EE-RS.
Please address communications regarding this Application to:
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
[e-mail]
[e-mail]
[e-mail]
and
Lori A. Blattner
Director—Regulatory Affairs
APPLICATION-2

Intermountain Gas Company
Post Office Box 7608
Boise, ID 83707
[e-mail]
[e-mail]
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-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 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.
APPLICATION-3

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.
IL BACKGROUND
In the Company's General Rate Case No. INT-G-16-02, Intermountain petitioned the
Commission for authority to begin a residential Energy Efficiency Program. The Commission
granted the Company's request in Order No. 33757.
Subsequently, in Case No. INT-G-17-03,the Company requested authority to implement
Rate Schedule EE—Residential Energy Efficiency Rebate Program,which outlined the program
offerings, and Rate Schedule EEC-RS—Energy Efficiency Charge,which established a charge to
fund the program. In Order No. 33888,the Commission approved both rate schedules effective
October 1, 2017.
In Case No. INT-G-19-04, Intermountain requested that the Commission approve the
Company's 2017-2018 EE Program expenses as prudently incurred. In Order No. 34536,the
Commission approved the prudency of the expenses with several conditions attached. Those
conditions were to commission a third-parry Evaluation,Measurement and Verification("EM&V")
study,review and update the avoided cost calculation with the Energy Efficiency Stakeholder
Committee("EESC"),immediately and continuously monitor, evaluate, and update its Energy
Efficiency Program incentives with the best available data, and discontinue the 80%AFUE
condensing fireplace incentive.
To allow all interested customers to participate in the Residential Energy Efficiency Rebate
Program, and to continue to grow the Program, Intermountain requested authority to revise Rate
APPLICATION-4

Schedule EEC-RS ("EEC-RS") from$0.00367 to $0.02093 per therm in Case No. INT-G-19-05.
The Commission approved the requested revision in Order No. 34454, effective October 1, 2019.
Order No. 34941 in Case No. INT-G-20-04 authorized the Company to implement a
Commercial Energy Efficiency program in Rate Schedule EE-GS and established a funding
mechanism for program costs in Rate Schedule EEC-GS ("EEC-GS"). The Commission directed
the Company to develop an EM&V plan, file an Annual Commercial Energy Efficiency Program
Report, include representatives from the GS-1 rate class in its EESC, and immediately and
continuously monitor, evaluate, and update its Commercial Energy Efficiency Program incentives
with the best available data. The Company launched its Commercial Energy Efficiency Program on
April 1, 2021, consisting of incentives for commercial space heating and commercial kitchen
equipment.
In Case No. INT-G-20-06, Intermountain requested that the Commission approve the
Company's 2019 EE Program expenses as prudently incurred. In Order No. 34980,the Commission
approved the prudency of the expenses. The Company also requested significant changes to the
program based on its first ever EM&V study that was filed as part of the case. The Commission
approved the proposed modifications effective April 1,2021. The Commission also ordered the
Company to continue to review its avoided costs and update its avoided cost calculations based on
the review, and to immediately and continuously monitor, evaluate, and update its EE Program
incentives with the best available data.
In Case No. INT-G-21-03, Intermountain requested that the Commission approve the
Company's 2020 EE Program expenses as prudently incurred. In Order No. 35313,the Commission
approved the prudency of the expenses. The Commission ordered the Company to continuously
monitor, evaluate and update its Energy Efficiency Program incentives with the best available data
APPLICATION-5

using the most accurate evaluation method to do so. The Commission acknowledged the overfunded
rider balance of$1,318,197 and permitted the Company to carry forward the balance to meet
anticipated increased Program participation,with the understanding the Company would seek
adjustment if increased participation does not materialize.
During program year 2021,the Company retired, modified, or added residential program
incentives as approved in Order No. 34980.
In Case No. INT-G-22-03, Order No. 35663, issued on January 13,2023,the Commission
approved the prudency of the 2021 Energy Efficiency Program expenses. The Commission
identified improvements to be made for future DSM prudency filings, specifically directing the
Company to directly assign Energy Efficiency Program costs to either the appropriate residential or
commercial program,when possible, and to provide explanations when costs are not assignable.
The Commission directed the Company to use a billing analysis to evaluate program
performance for the Furnace and Whole Home measures,while giving the option for the Company
to submit argument and evidence to justify other empirical analysis as part of its annual DSM
prudency filing. The Commission directed the Company to submit an RFP for a third-parry contract
to conduct an impact evaluation with billing analysis for Whole Home and Furnace measures using
April 1, 2021 through 2022 for the Whole Home and 2021 through 2022 for the Furnace program
year data,to be included with its 2023 prudency filing.
The Commission also approved the Company's proposal of the following treatment of
avoided costs: to update the transportation component of avoided costs as an exhibit to I P filing,to
no longer file avoided cost calculations as exhibits to the annual DSM prudency filing,to update all
avoided costs as exhibits to IRP filing, and to base cost-effectiveness testing off the avoided costs in
place at the time of program planning.
APPLICATION-6

In Case No. INT-G-23-06, Order No. 36245, issued on June 27, 2024,the Commission
approved the prudency of the 2022 Energy Efficiency Program expenses. The Commission required
that the Company's next prudency filing include an EM&V with a billing analysis covering Whole
Home Tier I and Whole Home Tier II, Furnace and Smart Thermostat measures as well as
providing sufficient information to justify the EUL of its Smart Thermostat measure. The
Commission directed the Company to explore ways to reduce labor expenses related to offering the
EE Programs and to develop and follow a schedule for regular internal audits.
III.2023 PRUDENCY FILING
The Company's 2023 Energy Efficiency Annual Report ("Annual Report")is included as
Attachment 1 to this Application and incorporated by reference. The Annual Report of the
Company's sixth program year provides a review of the Company's Energy Efficiency Portfolio,
which consists of the Residential Program and the Commercial Program. The report outlines
revenues, expenditures, cost-effectiveness, and performance by measure for each Program. A
review of outreach and educational activities, discussion of the Company's participation in a
collaborative effort to accelerate market introduction of gas heat pump technologies, and future
plans complete the Annual Report.Attachment 1.
An EM&V Impact Evaluation of the Company's Residential EE Program as directed in
Order No. 36245 is included as Attachment 1 —Supplement 1 and incorporated by reference. In
addition,the Company requested the evaluator also perform a Process Evaluation of
Intermountain's Residential Program. Adding this evaluation on to the EM&V study provides a
thorough review of Program satisfaction, awareness and outreach efforts. The Process Evaluation is
included as Attachment 1 —Supplement 3 and incorporated by reference.
APPLICATION-7

This Application also includes proposed revisions to the Company's Residential EE
Program based on the results of the EM&V studies and discussions with the Company's Energy
Efficiency Stakeholder Committee("EESC").
IV. COMPLIANCE WITH ORDER NO.36245
The Company continues to work diligently to implement the directives included in previous
Commission Orders. Since receiving Order No. 36245 in June 2024,the Company took the
following steps:
• Included with this filing is an"EM&V with a billing analysis covering Whole
Home Tier I and Whole Home Tier II, Furnace, and Smart Thermostat."' In
addition, in this filing the Company submits"argument and evidence"to justify the
deemed-savings approach recommended by the Evaluators, as contemplated by
Order No. 35663.2
• Updated the EUL of the smart thermostat with the best data available. The
Company additionally updated all inputs for all residential measures using the best
available data.
• The Company continues to explore ways to reduce labor expenses related to
offering the EE Programs. The Company is implementing an internal rebate
processing software that increases internal controls and efficiencies in processing as
well as eliminating the need for repetitive,labor-consuming data entry in rebate
processing. Although the impacts of this implementation are not seen in the data
under review in this filing, it will improve the labor required per rebate in the future.
1 INT-G-23-06,Order No. 36245 at 13.
2 INT-G-22-03,Order No. 35663 at 11.
APPLICATION- 8

• The 2025 internal audit plan is currently under development and a biannual Energy
Efficiency Program audit has been proposed to the planning committee. The
EM&V study, as part of the evaluation of savings, included a review of rebate
verification, data tracking and rebate payments. Supplement 1. This external audit
of the Company's processes and procedures ensures the program is efficiently
administered and rebates are being paid as intended.
It is important to remember that there is a lag in the prudency process. For example,the
Company filed an application requesting a prudency determination on 2022 Energy Efficiency
Program expenses on October 6,2023. Following a robust process, Order No. 36245 was issued on
June 27,2024. This timeline means that the Company did not have the most recent Order until after
the 2023 program year was complete and 2024 was underway. While the Company has made
significant progress on implementing the Commission directives contained in Order No. 36245, as
this Application discusses, some changes will not be fully implemented until program year 2025
because some of the changes take some time to work through.
V.REVENUES
The EE Program expenditures are funded through collections from customers via Energy
Efficiency Charges. During the 2023 program year, the EEC-RS of$0.01564 per therm funded the
Residential Program. Total Residential Program revenues for calendar year 2023 were $4,702,205.
Attachment 1 at 5.
During program year 2023,the EEC-GS of$0.00320 funded the Commercial Program. The
revenue for 2023 was$474,181. Attachment 1 at 22.
Because both programs were over-collected, the Company filed to decrease the collection
rates. Both rates were reduced on October 1, 2024 per Order No. 36337.
APPLICATION-9

VI.EXPENDITURES
Expenditures for the Residential and Commercial Programs combined for January 1, 2023
through December 31, 2023 were $3,846,358. Of this amount, $2,794,294, or approximately 73%,
is for energy efficiency rebates paid directly to residential and commercial customers. Residential
rebates accounted for$2,767,789 and Commercial rebates accounted for$26,505 of the total.
Attachment 1 at 5 and 22.
In addition to the amount spent on energy efficiency rebates,the Company incurred
$821,804 of administrative expenses for labor,program delivery, direct expenses, and market
transformation. As a Portfolio,this was approximately 7 percent more than 2022 expenditures. The
Company also spent$230,260 on a Conservation Potential Assessment("CPA") in 2023 that
informed the 2023 Integrated Resource Plan. Labor expenses as a percent of rebate dollars paid
decreased by 1 percent from 2022.
The Company continued to directly assign as many Program expenses as possible.
Residential customer promotions like engagement activities or email campaigns are direct expensed
to the residential program. The Company also directly applies expenses as they occur,primarily
driven by the audience of the activity. As an example, expenses related to participation or promotion
in the Building Contractor Association, focused on residential home building,is expensed to the
Residential Program. Commercial customer email campaigns, as well as promotional and
educational activities whose primary audience is engineers and architects, is expensed to the
Commercial Program.
Labor is the largest Program expense. The Energy Efficiency Portfolio,which includes both
the Residential and Commercial Programs, is delivered and administered by all Energy Efficiency
staff;no team member works exclusively on either the Commercial or Residential program. This is
APPLICATION- 10

true for both dedicated energy efficiency department employees and the Energy Services
Representatives ("ESR"). ESRs engage in business development for both the residential and
commercial sector and also promote the relevant energy efficiency program to those customers.
This has allowed the Company to leverage the expertise and flexibility of the team to promote and
educate about either program as the opportunities arise across the service territory, creating a one-
stop-shop for customers.
Using the same procedure established and applied to 2022 expenses,the Company based the
2023 expense allocation on the distribution of service starts between the residential and commercial
sectors recorded in the Company's Construction Tracking system. In 2022,there were 8,091
residential service starts and 496 commercial sales starts or a 94.2%and 5.8% split between
residential and commercial activity. For continuity and administrative efficiency,the 95/5 allocation
used in 2022 was applied to 2023 expenses. Labor costs were assigned based on this analysis(95%
to the residential program and 5%to the Commercial program)through an automatic standard labor
distribution through the Company's payroll system. Utilizing employees that work on both the
residential and commercial programs is the most cost-effective approach until the Portfolio grows to
a size that can accommodate separate staff for each Program.
Any expense that could not be directly assigned was also allocated 95%to the residential
program and 5%to the Commercial Program. The expenses that could not be directly assigned were
$45,518 of the total.
In its continual effort to look for labor savings, in 2023 the Company implemented an
internal software application for rebate processing called Enterprise Rebate Application("ERA").
This application will eliminate the need for repetitive data entry and reduce the opportunities for
data entry errors. The addition of an equipment library of frequently redeemed equipment,
APPLICATION- 11

streamlined customer validation, static budget codes and elimination of the need to create individual
payment requests through multiple systems,will create efficiency gains and data integrity
improvements in processing. In 2024,the Company is also replacing the third-party online
application with an internal product that allows customers to access the rebate application from their
online customer account.An online customer account is required to use this option and therefore
eliminates the need for customer validation and requires minimal data entry from the rebate
processing team as all required data and support documents are submitted by the customer. As ERA
is further integrated with internal systems, customers as well as our internal customer service agents
will be able to see the status of the customer's rebate in their online account,which will provide a
better customer experience and reduce time spent on customer calls. Regardless of the method that
rebates are submitted to Intermountain, all rebates will still undergo manual review and validation
of rebate requirements. Attachment 1 at 13.
Intermountain is committed to working to secure an energy efficient future. In 2023
Intermountain renewed its membership in the North American Natural Gas Heat Pump
Collaborative("Collaborative")to help advance the adoption of gas heat pump technology. With
efficiencies of over 100%,gas heat pump technology promises to deliver significant efficiency
gains when compared to traditional heat and water heat technology. The Market Transformation
expense of$25,000 represents the Company's membership in the Collaborative. The Collaborative
has been instrumental in developing promotional materials,creating support documents related to
installation considerations, creating an ENERGY STAR certification pathway for gas heat pumps,
and providing information about gas heat pumps at industry conferences. The work of the
Collaborative has provided essential support in bringing natural gas heat pumps to market.
Attachment 1 at 26. In 2024,the Collaborative has moved beyond raising awareness with industry
APPLICATION- 12

partners about the benefits of gas heat pumps and embarked on specific projects that require
significantly more investment and would dramatically increase the investment required by each
Company. With natural gas heat pumps at the point of commercialized production, the Company
believes its market transformation dollars may be better spent on direct contractor training or a pilot
project and so did not renew its Collaborative membership in 2024.
VII.DEFERRAL BALANCE
The Residential Program began the year with an over-collected deferral balance of$450,521
and ended 2023 with an over-collected balance of$1,378,687. The balance continued to grow in
2024, so the Company filed an application in Case No. INT-G-24-03 to reduce the Residential
Energy Efficiency Charge("EEC-RS")to more accurately match on-going revenues with expenses
and reduce the over-collected balance. The Commission approved the Company's request in Order
No. 36337 to reduce the EEC-RS from$0.01564 per therm to $0.01149 per therm. Attachment 1 at
5.
The Commercial Program began the year with an over-collected balance of$463,938, and
ended 2023 with an over-collected balance of$865,801. Similar to the Residential Program,the
Commercial Program balance continued to grow throughout 2024, so the Company also requested
in Case No. INT-G-24-03 to reduce the Commercial Energy Efficiency Charge("EEC-GS") from
$0.00320 per therm to $0.00 per therm. Attachment 1 at 22. This will stop the balance from growing
as the Company works to revise and update the program based on recommendations from the CPA
as well as a Commercial EM&V study that is currently underway.
VIII. EVALUATION,MEASUREMENT &VERIFICATION
On June 27,2024,the Commission issued Order No. 36245 which required"that the
Company's next prudency filing shall include an EM&V with a billing analysis covering Whole
APPLICATION- 13

Home Tier I,Whole Home Tier II, Furnace and Smart Thermostat measures". To comply with the
Order, Intermountain contracted with a third-party evaluator("Evaluator")to perform an impact
evaluation of these measures as well as the first evaluation of all water heating measures. The
Evaluator conducted a billing analysis on the measures identified by the Order. A second evaluation
methodology was also used to evaluate Intermountain's measures in a way that is consistent with
the evaluation deemed saving methodologies employed by other Idaho utilities. This method used
the Regional Technical Forum("RTF")and Illinois Technical Reference Manual ("IL TRM")in a
deemed savings methodology. This analysis evaluated the Intermountain Program using the deemed
savings from the RTF and IL TRM workbooks. Evaluators compared these results to the billing
analysis approach. Ultimately,the Evaluators recommended that"Intermountain Gas align
evaluation methods with the utilities present in Idaho,"to"allow for programs to be evaluated and
compared across utilities with the same measuring stick with results that are supported through peer
reviewed and approved documentation."' For each measure,Evaluators recommended
Intermountain evaluate their program using the RTF or IL TRM 12.0. The complete impact
evaluation report is provided in Supplement 1.
IX. THERM SAVINGS
Therm savings have been a point of discussion since the first EM&V study was conducted
in 2020. It is important to start with clarifying the categories of therm savings presented in this
report:
• Deemed savings are an estimate of an energy savings outcome for a single unit of
an installed energy efficiency measure. This estimate(a)has been developed
s See Attachment 1 —Supplement 1.Evaluators make this recommendation for each measure(see pages 33,39 and
45)and additionally in the recommendations section(see pages 57-59.)
APPLICATION- 14

from data sources and analytical methods that are widely accepted for the
measure and purpose and(b) are applicable to the situation being evaluated.
• Claimed(or Expected) savings are values reported after the energy efficiency
activities have been completed. For example, the number of furnace rebates
multiplied by the expected savings per furnace would result in total therms of
expected furnace savings.
• Evaluated(or Verified) savings are savings reported by an independent third-
parry evaluator after the energy efficiency activities have been implemented and
an impact evaluation has been completed.4
The 2024 EM&V study included a billing analysis evaluation as required by Order No.
36245. This approach"involves estimating energy savings by applying a linear regression to
measured participant energy consumption utility meter billing data. Billing analyses included billing
data from nonparticipant customers." Supplement 1,page 9.
While the Evaluator conducted a billing analysis, it did not recommend evaluating
Intermountain's residential new construction program using a billing analysis. Instead,the Evaluator
recommend using a deemed-savings analysis.
The Evaluator's concerns included the following, discussed in Supplement 1,beginning on
page 28.
1. Other Idaho Utilities: Other Idaho utilities evaluate their residential new construction
programs through energy modeling software,rather than a billing analysis, in line with the
methods completed in Section 4.1.5 of the EM&V Impact Evaluation.
2. RTF New Homes Protocol: The Regional Technical Forum has published a"New Homes
4 Energy Efficiency Program Impact Evaluation Guide,Glossary,P.143
APPLICATION- 15

Protocol,"which stipulates that residential new construction programs are evaluated through
energy modeling software.
3. Lack of Randomized Control Trial: Billing analysis with matched control groups are unable
to eliminate bias in control group creation due to lack of randomization. For this reason, a
billing analysis of Intermountain's customers is unlikely to provide the most accurate
information on which to evaluate new residential construction programs.
4. Further Increased Bias: Further bias is introduced in control group creation due to lack of
pre-period consumption data and occupancy data for the program and non-program homes.
So, again, a billing analysis using Intermountain customers is unlikely to provide the most
accurate information on which to evaluate new residential construction programs.
The Evaluator also provided a billing analysis for the 95%AFUE Natural Gas Furnace and
smart thermostat. Again,however,the Evaluator recommended against using the billing analysis for
evaluation of these measures. The billing analysis is not aligned with the evaluation method of other
utilities present in Idaho with gas furnace and smart thermostat measures. Additionally,the billing
analysis for the measures include potential bias that is unable to be reversed or rectified, such as:
1. Requires assumption that inconsistent occupancy occurs randomly,which cannot be
proven true,which therefore biases the results towards homes that are consistently
occupied, and therefore inflating energy consumption behaviors of consistently occupied
homes. Supplement 1,Page 36-37 and 42.
2. Many homes have insufficient pre-period billing data, due to new construction or new
move in customers and therefore are not included in the billing analysis. This led to the
exclusion of 68%of the furnace customers and 58%of the smart thermostat customers
in the billing analysis. Supplement 1, Page 36-37 and 42.
APPLICATION- 16

Intermountain agrees with the Evaluator's recommendation, and believes that the deemed
savings approach used by the Evaluator,rather than a billing analysis, should be used to evaluate the
new residential construction programs and 95%AFUE Natural Gas Furnace and smart thermostat
offerings. Intermountain believes this approach is supported by both fact and law.
As a factual matter, a billing analysis uses bills from Intermountain's existing customers.
This is a small sample size, isolated to a specific geographical area. It also results in biases to the
data, as noted by the Evaluator and set forth above.
By contrast,the deemed savings methodology used by the Evaluator uses information
derived from large customer sets. And the data is corrected to reverse or rectify biases that can arise
in billing data. This creates information that is more accurate.
As a legal matter,the Commission must approve nondiscriminatory rates and policies. The
energy-efficiency measures of other Idaho utilities are evaluated using a deemed-savings approach,
analogous to that proposed by the Evaluator in this case. Other utilities in Idaho evaluate their
offerings using a deemed-savings approach.
This creates an issue of discrimination between utilities. As discussed in this Application,
Intermountain believes that billing analyses are flawed and, as such, are not the most accurate
source of information. However, if a billing analysis is the most accurate methodology,it should be
implemented by all utilities in the state. At a minimum,the Commission must recognize and justify,
with reference to relevant factors,the difference between approved evaluation methods for energy-
efficiency offerings provided by different utilities.
It also creates an issue of discrimination between customers. If Intermountain must evaluate
its offerings using billing analysis,while other utilities use a deemed-savings approach, customers
in different areas of the state will be subject to energy-efficiency charges set by a methodology
APPLICATION- 17

unrelated to cost of service or other relevant distinctions. Rather,the differences in charges will
stem from a different evaluation methodology that, in turn, is not justified by factors relevant to
ratemaking.
Intermountain recognizes, of course,that the Commission is not required to treat all utilities
exactly the same. At the level of methodology,however, differences should(at a minimum)be
recognized and justified on the bases of relevant factors. Intermountain suggests that the deemed-
savings approach developed by the Evaluator is similar to the deemed-savings approach used by
other utilities, and it should be adopted in the interests of uniformity and nondiscrimination.
In 2023 Intermountain paid out 8,496 rebates to residential customers, a 6.9%increase over
the previous year. In compliance with Order No. 36245, Intermountain commissioned an EM&V
impact study on Whole Home I, Whole Home II, Furnace and Smart Thermostat measures. Water
heating measures were not required as part of Order No. 36245 but were included in the impact
study in order to evaluate and update all residential measures. The EM&V study resulted in
evaluated savings of 422,683 therms. Attachment 1 at 1.
The Commercial program experienced low participation despite efforts to grow the
program. The Commercial Program accounted for a total of 11,498 claimed savings in 2023.
Attachment 1 at 1.
X.AVOIDED COSTS
In accordance with Order No. 35663,the Company no longer files avoided cost calculations
as exhibits to the annual DSM prudency filing. All avoided costs are updated as exhibits to IRP
filings. The Company based the 2023 program planning and performed cost-effectiveness testing
using the 2021 IRP avoided costs that were in place at the time of program planning.
APPLICATION- 18

Based on the schedule of updating avoided costs in line with the most recent IRP,the
avoided costs filed in the 2023 IRP Case No. INT-G-23-07,Exhibit No. 5,were used for all the
proposed program changes. Attachment 1 at 6.
XI. COST-EFFECTIVENESS
Intermountain reports the cost-effectiveness of its Portfolio based on two industry standard
metrics: the Utility Cost Test("UCT") and the Total Resource Cost("TRC"). The UCT measures
cost-effectiveness from the utility company's perspective and takes into consideration avoided
supply costs,program administration costs, and incentives paid by the utility. The TRC measures
cost-effectiveness from the customer's perspective and focuses on avoided supply costs,program
administration costs and net participant costs. Although both are common industry metrics for
measuring cost-effectiveness,the Company relies more on the UCT because it measures the cost-
effectiveness of items directly under the Company's control. Exhibit No. 1, attached and
incorporated by reference, outlines the cost-effectiveness for the Programs and for each individual
rebate offered. Cost-effectiveness testing for the Residential Program used the recommended
evaluated savings from the EM&V impact study. It also includes a proposed schedule to ensure
formal EM&V for each rebate on a regular basis.
XII. STAKEHOLDER MEETINGS
The Energy Efficiency Stakeholder Committee ("EESC")has been a valuable resource for
the Company as it builds the Energy Efficiency Program. As outlined in the Annual Report,
Intermountain hosted two full EESC meetings to address both the Residential and Commercial
Program. The meetings included good representation from a variety of groups including
representatives from the Commission Staff,the Governor's Office of Energy and Mineral
Resources, a not-for-profit residential home builder,home energy raters, and city and county
APPLICATION- 19

representatives involved in energy efficiency and sustainability with familiarity of both the
residential and commercial sectors. Minutes from the two meetings are included in Supplement 4.
As the Program grows,the EESC plans to meet more frequently and will now meet on a
quarterly basis in order to provide more frequent updates on topics like the rider balance,rebate
performance,promotions and outreach, and special studies.
XIII.PROPOSED RESIDENTIAL PROGRAM CHANGES
The proposed changes to the residential program attempt to achieve several goals. First,to
update program incentives with the best available data,per Order No. 35313. Second,to
incorporate Staff recommendations from Order No. 35663 encouraging the Company to"explore
other acceptable and vetted basis for deemed savings such as the Regional Technical Forum."Third,
to align the Program with other Idaho utilities per Evaluator recommendations.
The Company first conducted cost effectiveness testing using evaluated savings and the
2021 IRP avoided costs, as those were the avoided costs used during the time of program planning.
The evaluated savings were the only thing changed in this cost test. The cost effectiveness of the
measure determined if a measure could continue in the offering as designed, or if it should be
revised or retired. Next, in order to update all Program incentives with the best available data,the
Company commissioned the Evaluators to develop a technical reference manual for the
Intermountain Program,the IGC TRM. CONFIDENTIAL Supplement 2. The protocols used to
develop the IGC TRM provide a framework and a set of reference points for conducting cost-
effectiveness evaluations of the Intermountain energy efficiency rebate offering. The primary
resources used to prepare these protocols include the following:
• Regional Technical Forum
• Technical Reference Manuals for Illinois, Idaho Power
APPLICATION-20

• Previous impact evaluation reports for the Intermountain Program
The Company implemented the Evaluator's recommendations and updated all the measure
inputs using the IGC TRM which included: minimum efficiency requirements,unit energy therm
savings, estimated useful life, and incremental cost. While Order No. 36245 required sufficient
information specifically for the EUL of the smart thermostat measure, all inputs for all measures
were updated.Attachment 1 at 6..
In addition to updating the measure inputs related to cost-effectiveness testing,the
equipment specifications for each measure were also updated based on the IGC TRM. For example,
the current equipment specification for the smart thermostat requires the smart thermostat is
ENERGY STAR Certified. Based on the IGC TRM,there are five additional specifications in
addition to the ENERGY STAR Certified specification that will be required,providing a much
more robust set of specifications in order to secure the deemed savings. CONFIDENTIAL
Supplement 2.
In order to establish incentive amounts,the Company used the updated inputs from the IGC
TRM for each measure and conducted cost-effectiveness testing using the 2025 program budget
estimate,the 2023 IRP avoided costs and forecasted customer participation based on historical
performance. The 2023 IRP avoided costs represented an increase over the 2021 IRP avoided costs
and resulted in increased incentives for all residential measures except for the furnace,which
remained the same at$350, and the smart thermostat which was reduced from$100 to $50. The
storage water heater and Tier II tankless water heater rebates were retired. Exhibit No. 2 outlines the
proposed Residential Program and is incorporated by reference.
The proposed changes to the residential program offering comply with Order No. 35313
Case No. INT-G-21-03 which directed the Company to update the Program incentives with the best
APPLICATION-21

available data. The Company's proposal to utilize deemed savings as provided by the IGC TRM for
program planning,to implement the changes in 2025, and to apply a deemed savings evaluation
approach,will allow the Program to be evaluated and compared across Idaho utilities with the same
measuring stick, as recommended by the Evaluators in the Rebate-Level Findings and
Recommendations. Supplement 1,Page 57. The sum of the changes proposed by the Company is to
incorporate a deemed savings approach to program planning and evaluation, exercising the
requirement outlined in Order No. 35663,that to use anything other than billing analysis, "the
Company may submit argument and evidence to justify other empirical analysis as part of its annual
DSM prudency filing."The proposed deemed savings approach would be a change from using CPA
therm saving values for Program planning to using deemed savings that are developed from data
sources and analytical methods that are widely considered acceptable for the measure and purpose,
and will provide more robust equipment specifications for capturing said therm savings.
A proposed Rate Schedule EE-RS tariff incorporating the proposed changes is included as
Exhibit No. 3 and incorporated by reference.
XIV. COMMERCIAL PROGRAM PLANS
In order to grow the Commercial Program,the Company plans to pull the allocation of one
FTE worth of labor funding from the Energy Services Representative allocation and use that
funding to add a full time Energy Efficiency Analyst in 2025. The new Analyst will be dedicated to
commercial customer outreach and energy efficiency awareness for commercial customers. The
ESRs will only have responsibility for Residential Program promotion going forward.
To implement additional savings opportunities identified in the 2023 CPA,the Company
has commissioned the Evaluators to develop a Commercial TRM in order to apply a deemed
savings approach similar to the Residential Program. In addition to the development of a
APPLICATION-22

Commercial TRM, the Evaluators will also conduct a process evaluation which will refine and
refocus marketing strategies and increase program effectiveness, as well as identify barriers to
participation to improve program participation and satisfaction while achieving cost-effective
savings.
XV.INTERNAL AUDITS
In Order No. 36245,the Commission ordered the Company to"develop and follow a
schedule for regular internal audits."After receiving the Order in June 2024, Intermountain shared
the requirement with the MDU Resources' Internal Audit Director. The 2025 internal audit plan is
currently under development and a biannual Energy Efficiency Program audit has been proposed to
the planning committee.A proposed plan will go to the MDU Resources Board of Directors for
approval in February 2025.
As part of the EM&V study, Evaluators reviewed the tracking database for residential
measures and provided recommendations for each measure. Evaluators found the tracking database
was well-organized, efficiency requirements met or exceeded efficiency requirements and could be
verified through AHRI certificates or ENERGY STAR certificated equipment. One Whole Home
rebate was paid out as a Tier I rebate rather than a Tier II due to an error in the data recording of the
furnace efficiency. The data tracking procedure that allowed this error to occur was eliminated with
the implementation of the internal tracking software,ERA. Evaluators also identify data that could
not be verified, such as geolocation or occupancy sensors for smart thermostats,but because it was
not a requirement of the Program the data was not collected. These findings are outlined in the
Rebate-Level Findings and Recommendations table provided in the full report. Supplement 1,Page
57.
In the meantime,the Company added a process evaluation to the EM&V study that was
APPLICATION-23

already underway in 2024. The process evaluation recommendations focused on boosting
marketing and outreach with targeted messaging and contractor outreach,but also found quality
assurance procedures appropriate and effective. Supplement 3 at 3.
XVI.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.
APPLICATION-24

XI.REQUEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Commission issue an order designating $3,846,358 of 2023 Energy Efficiency
expenditures as prudently incurred,
b. That the proposed revisions to Rate Schedule EE-RS shown in Exhibit No. 3 be accepted
as filed,
c. That the Commission approve use of the deemed saving methodology developed and
proposed by the Evaluator and the Company in this Application,
d. That this Application be heard and acted upon without hearing under modified procedure,
and
e. For such other relief as this Commission may determine just and proper.
DATED: December 20,2024
INTERMOUNTAIN GAS COMPANY Givens Pursley LLP
By By
Lori A. Blattner Preston N. Carter
Director—Regulatory Affairs Attorney for Intermountain Gas Company
INTERMOUNTAIN GAS COMPANY Givens Pursley LLP
APPLICATION-25

EXHIBIT NO. I
CASE NO. INT-G-24-05
INTERMOUNTAIN GAS COMPANY
2023 Cost Effectiveness
(22 Pages)

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 1 of 22
Introduction
Intermountain's Energy Efficiency Program (EE Program) offers individual customers a way to
lower their usage and monthly energy bills. It additionally benefits all customers by ensuring
resources are used efficiently which delays the need for expensive system upgrades and
additional supply contracts, thereby keeping costs low for everyone. Cost-effectiveness testing
is vital to ensuring the Company's EE Program is in fact a least-cost resource, and is integral to
the design, implementation, and success of the EE Program.
Cost-Effectiveness and Methodology
Intermountain's objective is for all rebates to have benefit/cost ratios of one or greater for the
Utility Cost Test(UCT).The UCT measures cost-effectiveness from the utility company's
perspective and takes into consideration avoided supply costs, program administration costs
and incentives paid by the utility.
Rebates undergo cost tests at several stages: preliminary design, implementation, and an
annual review. For a different perspective, cost-effectiveness of rebates is also evaluated based
on the customer's perspective using avoided supply costs, program administration costs and
net participant costs, or the Total Resource Cost Test (TRC). However,the TRC is not the
primary cost test used for decisions regarding the inclusion or exclusion of rebate offerings. In
calculating the UCT and TRC, Intermountain relies on the calculations outlined in the California
Standard Practice Manual and the National Action Plan for Energy Efficiency's (NAPEE)
Understanding Cost Effectiveness of Energy Efficiency Programs:
Best Practices, Technical Methods, and Emerging Issues for Policy-Makers.
Cost-effectiveness of EE Program rebates are reviewed annually.The results are reported in
the annual report and reviewed with the Energy Efficiency Stakeholder Committee (EESC).
Rebate performance, cost-effectiveness, market insights, and lessons learned are taken into
consideration when deciding whether to continue, revise or retire a rebate.
Assumptions
In calculating cost-effectiveness for each rebate and for the Program as a whole, the Company
relied upon several assumptions as well as studies provided by independent third-party

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 2 of 22
sources.The section below discusses the key inputs used in calculating cost-effectiveness and
the assumptions and sources used.
Energy Savings
Energy savings for each rebate are calculated by multiplying each rebate's gross annual therm
savings by the total number of rebates issued.The Residential therm savings used are
evaluated savings based on the deemed savings evaluation methodology from the 2024 EM&V
study. The Commercial therm saving used are from the Dunksy DEEP model as filed in Case No.
INT-G-20-04, Order No. 34941. The energy savings are then valuated based on the Company's
Avoided Cost.The Avoided Cost is used both to economically evaluate the present value of the
therms saved over the life span of the measure and to track the performance of the EE
Program.A more in-depth discussion of the Avoided Cost calculation and its components can
be found in Case No. INT-G-22-03, Exhibit No. 1 which was originally filed as Exhibit No. 5 in
Intermountain's Integrated Resource Plan (Case No. INT-G-21-06).
Rebate Costs
Total rebate costs are calculated by multiplying the value of each rebate by the number of
rebates issued for the year.
Equipment& Installation Cost
The incremental equipment and installation costs are inputs to the TRC cost test and were
provided by the CPA.These costs represent the incremental purchase and installation costs the
participant will pay between a base case measure and a higher efficient alternative.These
costs are not offset by the amount of the rebate received by the participant.
Program Delivery&Administration
Program delivery and administration costs are direct assigned to their respective program,
either residential or commercial,when they can be specifically identified. For example,the
expense of a residential builder mailing list is charged to Residential Program delivery and
administration costs.After all direct costs are assigned,the remaining pool of program and
administration costs, are split between the residential program and commercial program based
on a respective 95/5 split.This 95/5 split was developed after re-evaluating the company's
expense allocation. An analysis of service starts by the ESRs,tracked in Construction Tracking,

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 3 of 22
also very closely followed this split, with 8,901 residential service starts and 496 commercial
sales starts or a 94.25%and 5.78%split in service starts in 2023. For continuity and
administrative efficiency,the 95/5 allocation used in 2022 was also applied to 2023 expenses.
Real Discount Rate
The real discount rate is used to account for the time-value of money and accurately compare
costs.The real discount rate is based on the Company's tax-affected weighted average cost of
capital.The calculation of the real discount rate can be found in Case No. INT-G-22-03, Exhibit
No. 1, Page 11. Per Case No. INT-G-22-03, Order No. 35663,the Company will update the
discount rate and inflation rate within the avoided cost filing in the IRP.
Inflation Rate
An inflation assumption is used in cost-effectiveness testing to convert nominal,forward-
looking costs into real dollars.The company assumes an inflation rate of 2.0%.
Net-to-Gross
Net-to-gross (NTG) is a ratio that adjusts the therm savings of rebates and/or programs, so
they solely reflect energy efficiency gains that are the direct result of energy efficiency
programs.The NTG deducts therm savings resulting from free-ridership, or savings that would
have occurred regardless of the program. It also increases therm savings to account for
spillover, or savings that occurred but were not counted by the program, as well as therm
savings resulting from market transformation. Unfortunately, estimates of net savings require
making sweeping assumptions to model a theoretical scenario where the EE Program did not
exist. Because of the difficulty in accurately calculating NTG percentages,the Company used an
NTG of 100%for all rebate and program cost-effectiveness analysis. Intermountain also
performs a sensitivity analysis for each rebate that determines the minimum allowable NTG
ratio where the rebate would remain (or become) cost effective under the Utility Cost Test.
Results
The Company performed cost-effectiveness testing at the program level and the individual
measure level. Neither the Residential Program, with a 0.8 UCT ratio, nor the Commercial
Program,with a 0.9 UCT ratio, met the 1.0 cost effectiveness test. As a result of the UCT
outcomes,the Company is proposing revisions to the Residential Program in this filing and will

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 4 of 22
propose changes to the Commercial Program pending an EM&V study that is currently
underway.
EM&V Schedule
The Company prepared a revised EM&V schedule. The dates on the schedule include the
changes proposed for 2025 and future program evaluations. Future evaluations will be
dependent on when the proposed 2025 program changes can be implemented, as well as
working with a 3rd party evaluator to determine if there is sufficient data to provide meaningful
evaluation, especially after a program change. Should the implementation of a TRM be
incorporated into the Program,the Company will plan to update the TRM with each
evaluation.

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 5 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
2023 UCT Results
Annual
Therm Therm
Rebate Savings* Savings UCT Benefits UCT Costs UCT Ratio
Whole Home Tier 1 183 367 $ 2,882 $ 2,037 1.4
Whole Home Tier 11 110 166,020 $ 1,304,587 $ 1,235,023 1.1
Furnace-95%AFUE 44 145,698 $ 993,849 $ 1,536,477 0.6
Combination Boiler-95%AFUE 168 1,178 $ 8,552 $ 6,429 1.3
Boiler-95%AFUE 103 1,035 $ 8,132 $ 9,184 0.9
Water Heater(<55 gallons) 25 504 $ 2,500 $ 4,669 0.5
Water Heater(>55 gallons) 2 21 $ 104 $ 2,334 0.0
Tankless Water Heater Tier 1 59 48,295 $ 379,500 $ 362,732 1.0
Tankless Water Heater Tier 11 48 476 $ 3,740 $ 4,184 0.9
Smart Thermostat 21 59,090 $ 256,627 $ 610,969 0.4
422,683 $ 2,960,474 $ 3,774,039 0.8
*Therm Savings Values are evaluated savings
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
2023 UCT Results
Annual
Therm Therm
Rebate Savings Savings UCT Benefits UCT Costs UCT Ratio
Condensing Unit Heater 409 $ $ -
Boiler Reset Control 1,212 $ $ - -
High-Efficiency Condensing Boiler 669 1,338 $ 10,514 $ 6,865 1.5
Fryer-Energy Star Certified 508 10,160 $ 47,315 $ 57,648 0.8
Steamer-Energy Star Certified 1,054 - $ - $ - -
Griddle-Energy Star Certified 76 - $ - $ - -
11,498 $ 57,829 $ 64,513 0.9

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 6 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Whole Home Tier I-2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 367 Utility Cost $ 2,882 $ 2,037 1.4
Lifetime Energy Savings(therms) 25 Total Resource Cost $ 2,882 $ 4,471 0.6
Present Value of Energy Savings S $ 2,882
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 900 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 2
Total Rebate Costs R $ 1,800 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 2,117 Net-to-Gross Sensitivity[21 71%
Total Equipment&Installation Costs 1 $ 4,234
NOTES
Program Delivery&Administration
Overhead Expenses['[ $ 116 [']Allocated based on percentage of portfolio rebate count.
Direct Costs $ 121 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 237
`2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 7 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Whole Home Tier II-2023 Cost-Effectiveness Results`
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 166,020 Utility Cost $ 1,304,587 $ 1,235,023 1.1
Lifetime Energy Savings(therms) 4,150,505 Total Resource Cost $ 1,304,587 $ 3,373,276 0.4
Present Value of Energy Savings S $ 1,304,587
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 700 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 1,509
Total Rebate Costs R $ 1,056,300 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 2,117 Net-to-Gross Sensitivity[21 95%
Total Equipment&Installation Costs 1 $ 3,194,553
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 87,463 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 91,260 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 178,723
`2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 8 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Furnace-95%AFUE-2023 Cost-Effectiveness Results`
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 145,698 Utility Cost $ 993,849 $ 1,536,477 0.6
Lifetime Energy Savings(therms) 2,913,952 Total Resource Cost $ 993,849 $ 4,675,437 0.2
Present Value of Energy Savings S $ 993,849
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 350 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 3,280
Total Rebate Costs R $ 1,148,000 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 1,307 Net-to-Gross Sensitivity[21 155%
Total Equipment&Installation Costs 1 $ 4,286,960
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 190,113 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 198,364 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 388,477
`2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 9 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Combination Boiler-95%AFUE-2023 Cost-Effectiveness Results*
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 1,178 Utility Cost $ 8,552 $ 6,429 1.3
Lifetime Energy Savings(therms) 25,911 Total Resource Cost $ 8,552 $ 25,483 0.3
Present Value of Energy Savings S $ 8,552
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 800 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 7
Total Rebate Costs R $ 5,600 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 3,522 Net-to-Gross Sensitivity[21 75%
Total Equipment&Installation Costs 1 $ 24,654
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 406 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 423 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 829
`2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 10 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Boiler-95%AFUE-2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 1,035 Utility Cost $ 8,132 $ 9,184 0.9
Lifetime Energy Savings(therms) 25,873 Total Resource Cost $ 8,132 $ 12,844 0.6
Present Value of Energy Savings S $ 8,132
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 800 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 10
Total Rebate Costs R $ 8,000 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 1,166 Net-to-Gross Sensitivity[21 113%
Total Equipment&Installation Costs 1 $ 11,660
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 580 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 605 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 1,184
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 11 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Storage Water Heater(<55 Gallon)2023 Cost-Effectiveness Results*
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 504 Utility Cost $ 2,500 $ 4,669 0.5
Lifetime Energy Savings(therms) 6,547 Total Resource Cost $ 2,500 $ 10,169 0.2
Present Value of Energy Savings S $ 2,500
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 115 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 20
Total Rebate Costs R $ 2,300 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 390 Net-to-Gross Sensitivity[21 187%
Total Equipment&Installation Costs 1 $ 7,800
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 1,159 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 1,210 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 2,369
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 12 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Storage Water Heater(>55 Gallons)2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 21 Utility Cost $ 104 $ 2,334 0.0
Lifetime Energy Savings(therms) 273 Total Resource Cost $ 104 $ 5,084 0.0
Present Value of Energy Savings S $ 104
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 115 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 10
Total Rebate Costs R $ 1,150 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 390 Net-to-Gross Sensitivity[21 2245%
Total Equipment&Installation Costs 1 $ 3,900
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 580 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 605 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 1,184
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 13 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Tankless Water Heater Tier I-2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 48,295 Utility Cost $ 379,500 $ 362,732 1.0
Lifetime Energy Savings(therms) 1,207,368 Total Resource Cost $ 379,500 $ 1,569,282 0.2
Present Value of Energy Savings S $ 379,500
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 325 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 818
Total Rebate Costs R $ 265,850 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 1,800 Net-to-Gross Sensitivity[21 96%
Total Equipment&Installation Costs 1 $ 1,472,400
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 47,412 �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 49,470 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 96,882
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 14 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Tankless Water Heater Tier II-2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 476 Utility Cost $ 3,740 $ 4,184 0.9
Lifetime Energy Savings(therms) 11,898 Total Resource Cost $ 3,740 $ 12,704 0.3
Present Value of Energy Savings S $ 3,740
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 300 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 10
Total Rebate Costs R $ 3,000 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 1,152 Net-to-Gross Sensitivity[21 112%
Total Equipment&Installation Costs 1 $ 11,520
NOTES
Program Delivery&Administration
Overhead Expensesl'i $ 580 i'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ 605 [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 1,184
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 15 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
Smart Thermostat-2023 Cost-Effectiveness Results'
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 59,090 Utility Cost $ 256,627 $ 610,969 0.4
Lifetime Energy Savings(therms) 649,994 Total Resource Cost $ 256,627 $ 923,820 0.3
Present Value of Energy Savings S $ 256,627
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Average Rebated Amount�'l $ 97 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 2,830
Total Rebate Costs R $ 275,789 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 208 Net-to-Gross Sensitivityl31 238%
Total Equipment&Installation Costs 1 $ 588,640
NOTES
Program Delivery&Administration
Overhead Expenses[21 $ 164,030 [']Rebates pay the full cost of the individual thermostat up to a maximum of$100.
Direct Costs $ 171,150 I21Allocated based on percentage of portfolio rebate count.
Total Program Delivery&Administration Costs A $ 335,180 131Minimum NTG value where rebate remains cost-effective under UCT.
*2024 Evaluated Savings

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 16 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Condensing Unit Heater-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) - Utility Cost $ - $
Lifetime Energy Savings(therms) - Total Resource Cost $ - $
Present Value of Energy Savings S $ -
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 1,500 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count -
Total Rebate Costs R $ - Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 2,889 Net-to-Gross Sensitivity[21
Total Equipment&Installation Costs 1 $ -
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ - [']Allocated based on percentage of portfolio rebate count.
Direct Costs $ - [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ -

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 17 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Boiler Reset Control-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) - Utility Cost $ - $
Lifetime Energy Savings(therms) - Total Resource Cost $ - $
Present Value of Energy Savings S $ -
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 350 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count -
Total Rebate Costs R $ - Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 612 Net-to-Gross Sensitivity[21
Total Equipment&Installation Costs 1 $ -
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ - �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ - [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ -

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 18 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
High Efficiency Condensing Boiler-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 1,338 Utility Cost $ 10,514 $ 6,865 1.5
Lifetime Energy Savings(therms) 33,450 Total Resource Cost $ 10,514 $ 11,906 0.9
Present Value of Energy Savings S $ 10,514
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Average Rebated Amount�'l $ 1,350 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count 2
Total Rebate Costs R $ 2,700 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 3,870 Net-to-Gross Sensitivityl31 65%
Total Equipment&Installation Costs 1 $ 7,741
NOTES
Program Delivery&Administration
Overhead Expenses[21 $ 2,356 [']Rebates are based on the capacity of the unit.
Direct Costs $ 1,809 [2]Allocated based on percentage of portfolio rebate count.
Total Program Delivery&Administration Costs A $ 4,165 13IMinimum NTG value where rebate remains cost-effective under UCT.

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 19 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Fryer-Energy Star Certified-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) 10,160 Utility Cost $ 47,315 $ 57,648 0.8
Lifetime Energy Savings(therms) 121,920 Total Resource Cost $ 47,315 $ 42,648 1.1
Present Value of Energy Savings S $ 47,315
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG+(R+A)
Rebate Amount $ 800 Total Resource Cost Test =S x NTG_(I x NTG+A)
Rebate Count 20
Total Rebate Costs R $ 16,000 Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 50 Net-to-Gross Sensitivity[�1 122%
Total Equipment&Installation Costs 1 $ 1,000
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ 23,562 [']Allocated based on percentage of portfolio rebate count.
Direct Costs $ 18,087 l21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ 41,648

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 20 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Steamer-Energy Star Certified-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) - Utility Cost $ - $
Lifetime Energy Savings(therms) - Total Resource Cost $ - $
Present Value of Energy Savings S $ -
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 1,100 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count -
Total Rebate Costs R $ - Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 635 Net-to-Gross Sensitivity[21
Total Equipment&Installation Costs 1 $ -
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ - �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ - [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ -

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 21 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Griddle-Energy Star Certified-2023 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Energy Savings Value Test Benefits Costs Ratio
Annual Energy Savings(therms) - Utility Cost $ - $
Lifetime Energy Savings(therms) - Total Resource Cost $ - $
Present Value of Energy Savings S $ -
Costs Equations &Assumptions
Rebate Costs Value Utility Cost Test =S x NTG=(R+A)
Rebate Amount $ 200 Total Resource Cost Test =S x NTG=(I x NTG+A)
Rebate Count -
Total Rebate Costs R $ - Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment&Installation Costs Net-to-Gross(NTG) 100%
Incremental Cost Per Unit $ 360 Net-to-Gross Sensitivity[21
Total Equipment&Installation Costs 1 $ -
NOTES
Program Delivery&Administration
Overhead Expensesl'l $ - �'Wlocated based on percentage of portfolio rebate count.
Direct Costs $ - [21Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery&Administration Costs A $ -

Exhibit No. 1
Case No. INT-G-24-05
Intermountain Gas Company
Page 22 of 22
ENERGY EFFICIENCY PROPOSED EVALUATION PLAN 2025-2028
Energy Efficiency Program 2025 Proposed changes 2026 2027 2028
Residential Measures:
Whole Home Tier I Implement IGC TRM I P
Whole Home Tier II Implement IGC TRM I P
Combination Boiler for Space and Water Heat Implement IGC TRM I P
Furnace Implement IGC TRM I P
Boiler Implement IGC TRM I P
Storage Water Heater Retire
Tankless Water Heater Tier I Implement IGC TRM I P
Tankless Water Heater Tier II Retire
Smart Thermostat Implement IGC TRM I P
TRM Review X
Commercial Measures:
Condensing Unit Heater Process Evaluation Develop TRM I P
Boiler Reset Control Process Evaluation Develop TRM I P
High-Efficiency Condensing Boiler Process Evaluation Develop TRM I P
Fryer Process Evaluation Develop TRM I P
Steamer Process Evaluation Develop TRM I P
Griddle Process Evaluation Develop TRM I P
TRM Review X
Evaluation Type: 1=Impact, P=Process, O= Other

EXHIBIT NO. 2
CASE NO. INT-G-24-05
INTERMOUNTAIN GAS COMPANY
2025 Program Planning
(1 page)

Exhibit No. 2
Case No. INT-G-24-05
Intermountain Gas Company
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
Energy Efficiency Program
2025 Cost-Effectiveness Testing (Program Planning)
INPUT BY REBATE UCT
RESULTS
ANNUAL THERM INCREMENTAL 2025 REBATE
SAVINGS COST COUNT
REBATE NAME SEGMENT EUL REBATE AMOUNT UCT RATIO
Whole Home I Residential 183 22 $ 3,068 $ 1,500 15 1.2
Whole Home II Residential 110 22 $ 2,941 $ 1,000 2,001 1.1
Furnace(95%) Residential 46 22 $ 278 $ 350 5,000 1.1
Combi boiler Residential 168 25 $ 2,412 $ 1,500 12 1.2
Boiler Residential 107 25 $ 2,135 $ 1,000 14 1.1
Tankless (Energy Star Certified) Residential 51 20 $ 895 $400 1,516 1.1
Smart Thermostat Residential 26 7 $ 165 $ 50 2,000 1.0

EXHIBIT NO. 3
CASE NO. INT-G-24-05
INTERMOUNTAIN GAS COMPANY
Rate Schedule EE-RS
Redline and Clean Tariff
(2 pages)

I.P.U.C. Gas Tariff
Rate Schedules IDAHO PUBLIC UTILITIES COMMISSION
Feu th Fifth Revised Sheet No. 16(Page 2 Approved Effective
of 2) May 17, 2022 June 1, 2022
Name
of Utility Intermountain Gas Company Jan Noriyuki Secretary
Rate Schedule EE-RS
RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM
(Continued)
REBATES:
Rebate Rebate Type Minimum Efficiency Rating Rebate
Amount
Whole Home Tier I New Tier I Requirements: $0001,500
Construction 0 HERS rated
• Air sealing at or below 3 ACH at 50 Pa
• Ceiling insulation at or above R-49
• Ducts and air handler located inside
conditioned space or duct leakage to
outside of less than 4 CFM25/100 ft2 CFA
• Furnace efficiency at or above 97% AFUE
Whole Home Tier II New Tier 11 Requirements: $7001,000
Construction 0 HERS rated
• Air sealing at or below 4 ACH at 50 Pa
• Ducts and air handler located inside
conditioned space or duct leakage to
outside of less than 4 CFM25/100 ft2 CFA
• Furnace efficiency at or above 95% AFUE
Combination Boiler for Space Heating 95%AFUE $W01,500
Space and Water
Heat
Furnace Space Heating 95%AFUE $350
Boiler Space Heating 95%AFUE $8001, 000
Storage Water Heater Water Heating FR�F
Tankless Water Water Heating .91 UEF ENERGY STAR Certified $3 -5400
Heater T4e-r4
Tankless Water Water He tip 87UEF $3W
Heater Tr'e
Smart Thermostat Thermostat E^,,erg StarENERGY STAR Certified $49050
GENERAL PROVISIONS:
All installations of equipment must comply with all codes and permit requirements applicable in the state
of Idaho and must be properly inspected, if required, by appropriate agencies. Customers must submit
required documentation of purchase and installation to the Company under the Terms and Conditions of
the current rebate program. The Company reserves the right to verify installation prior to the payment of
any rebates.
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director—Regulatory Affairs
€ffestive: dune 1, 2022

I.P.U.C. Gas Tariff
Rate Schedules
Fifth Revised Sheet No. 16(Page 2 of 2
Name
of Utility Intermountain Gas Company
Rate Schedule EE-RS
RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM
(Continued)
REBATES:
Rebate Rebate Type Minimum Efficiency Rating Rebate
Amount
Whole Home Tier I New Tier I Requirements: $1,500
Construction 0 HERS rated
• Air sealing at or below 3 ACH at 50 Pa
• Ceiling insulation at or above R-49
• Ducts and air handler located inside
conditioned space or duct leakage to
outside of less than 4 CFM25/100 ft2 CFA
• Furnace efficiency at or above 97% AFUE
Whole Home Tier II New Tier II Requirements: $1,000
Construction 0 HERS rated
• Air sealing at or below 4 ACH at 50 Pa
• Ducts and air handler located inside
conditioned space or duct leakage to
outside of less than 4 CFM25/100 ft2 CFA
• Furnace efficiency at or above 95% AFUE
Combination Boiler for Space Heating 95%AFUE $1,500
Space and Water
Heat
Furnace Space Heating 95%AFUE $350
Boiler Space Heating 95%AFUE $1,000
Tankless Water Water Heating ENERGY STAR Certified $400
Heater
Smart Thermostat Thermostat ENERGY STAR Certified $50
GENERAL PROVISIONS:
All installations of equipment must comply with all codes and permit requirements applicable in the state
of Idaho and must be properly inspected, if required, by appropriate agencies. Customers must submit
required documentation of purchase and installation to the Company under the Terms and Conditions of
the current rebate program. The Company reserves the right to verify installation prior to the payment of
any rebates.
Issued by: Intermountain Gas Company
By: Lori A. Blattner Title: Director—Regulatory Affairs