20250203Notice_of_Application_Order_No_36455.pdf

Office of the Secretary
Service Date
February 3,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN ) CASE NO. INT-G-24-05
GAS COMPANY'S APPLICATION FOR )
DETERMINATION OF 2023 ENERGY ) NOTICE OF APPLICATION
EFFICIENCY EXPENSES AS PRUDENTLY )
INCURRED ) NOTICE OF INTERVENTION
DEADLINE
ORDER NO. 36455
On December 20, 2024, Intermountain Gas Company ("Company") applied for an order
designating $3,846,358 of 2023 energy efficiency expenditures as prudently incurred. The
Company's Application included its 2023 Energy Efficiency Annual Report, an Evaluation,
Measurement, and Verification ("EM&V") Study with a billing analysis, and proposed revised
Rate Schedule EE-RS. The Company requested its Application be processed by Modified
Procedure.
With this Order, the Commission provides notice of the Company's Application and sets
a deadline for interested parties to intervene.
BACKGROUND
In 2017, in Case No. INT-G-16-02, the Commission authorized the Company to establish
the Energy Efficiency Program("EE Program") for its residential customers. Order No. 33757 at
35-37. The purpose of the EE Program "is to encourage upgrades to, or use of, high efficiency
natural gas equipment." Rate Schedule EE. Later in 2017, in Case No. INT-G-17-03, the
Company requested authority to implement a funding mechanism for the EE Program. The
Commission approved the Company's requested funding mechanism of an Energy Efficiency
Charge ("EEC"), and ultimately approved Rate Schedule EE, Rate Schedule EEC, and Rate
Schedule EEC-RS. Order No. 33888.
In Case No. INT-G-19-04, the Commission required the Company to conduct a third-
party EM&V study. This was meant to "review and update the avoided cost calculation with the
Energy Efficiency Stakeholder Committee" ("EESC"). It was also meant to regularly monitor
and update the EE Program incentives. See Order No. 34536.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 1

In Case No. INT-G-20-04, the Commission granted permission for the Company to
implement a Commercial EE Program. Order No. 34941. This established a way to fund energy
efficiency upgrades under Rate Schedule EEC-GS ("EEC-GS"). Additionally, the Company was
instructed to submit an Annual Commercial EE Program Report. This report must include
representatives from the GS-I rate class in its EESC.
In Case No. INT-G-23-06, the Commission approved the prudency of the Company's
2022 EE Program expenses and directed the Company to include an EM&V with a billing
analysis covering four Residential EE Program measures—Whole Home Tiers I and II, Furnace,
and Smart Thermostat. The Commission also directed the Company to look for ways to reduce
labor expenses. Order No. 36245.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that the Company represented that the EE Program
expenditures are funded through collections from customers via the EEC. The Company stated
that the EEC-RS of$0.01564 per therm funds the Residential EE Program; the total Residential
EE Program revenues for year 2023 were $4,702,205. The Company represented that the EEC-GS
remained at $0.00320 per therm and funds the Commercial EE Program; the Commercial EE
Program revenues for 2023 were $474,181. The Company noted that both the Commercial and
Residential EE Programs were overfunded and the Commission authorized a reduced collection
rate for both on October 1, 2024. See Order No. 36337.
YOU ARE FURTHER NOTIFIED that the Company represented that the combined
expenditures for the Residential and Commercial EE Programs for January 1, 2023, through
December 31, 2023, were $3,846,358. $2,767,789-73% of expenditures—accounts for EE
Program rebates paid out to residential and commercial customers. Expenditures for EE Program
administration including labor, program delivery, market transformation, and direct expenses
accounted for $821,804 of total expenditures. This represents a 7% increase over 2022 expenses,
respectively. The Company also spent $230,260 on a conservation potential assessment in 2023.
YOU ARE FURTHER NOTIFIED that the Company stated that it has assigned EE costs
to each respective EE Program where possible and offered explanations where costs could not be
assigned in compliance. The Company further stated that employees working on both Commercial
and Residential EE Programs remained the most cost-effective option until the programs each
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 2

grow. The Company allocated expenses that could not easily be attributed to either program based
on the ratio of service starts. Using this ratio, 95% of expenses were allocated to the Residential
EE Program and 5%were allocated to the Commercial EE Program. The total funds that could not
be separately allocated directly to either EE Program were $45,518.
YOU ARE FURTHER NOTIFIED that the Company stated it continues to seek ways to
reduce labor costs. In 2023 the Company implemented the Enterprise Rebate Application (a
software application to process rebates that eliminates the need for repetitive data entry and
eliminates the opportunity for error). In 2024 the Company replaced its third-parry online
application with an internal product where customers can access rebate application forms from
their customer accounts online. The Company also renewed its membership in the North American
Natural Gas Heat Pump Collaborative which focuses on the adoption of new heat pump
technologies with over 100% efficiencies
YOU ARE FURTHER NOTIFIED that the Company represented that the Residential EE
Program began the year with an over-funded deferral balance of$450,521 and experienced growth
of the over-funded balance to $1,378,687 by the end of 2023. To address this over-funded deferral
balance the Company's request to reduce the EEC-RS to $0.01149 was approved by the
Commission in the fall of 2024. Id.
YOU ARE FURTHER NOTIFIED that the Company represented that the Commercial EE
Program began 2023 with an over-funded deferral balance of$463,938 and experienced growth of
the over-funded deferral balance to $865,801 by the end of 2023. To address this over-funded
deferral balance the Company's request to reduce the EEC-GS to $0.00 was approved by the
Commission in the fall of 2024. Id.
YOU ARE FURTHER NOTIFIED that the Company represented that in 2023 the
Residential and Commercial EE Programs' cumulative claimed savings was 672,417 therms
660,919 therms for the Residential EE Program and 11,498 therms for the Commercial EE
Program. The Company, in compliance with Order No. 36245, which directed it to conduct an
EM&V impact study of the Whole Home Tiers I and II,Furnace, and Smart Thermostat measures,
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 3

included the results of the EM&V study which resulted in 422,683 therms saved by the Residential
EE Program.1
YOU ARE FURTHER NOTIFIED that the Company represented that it used the 2023
IRP's Avoided Costs as calculated in Case No. INT-G-23-07. See Case No. INT-G-23-07, IRP
Exhibit No. 5.
YOU ARE FURTHER NOTIFIED that the Company measures cost-effectiveness using
the Utility Cost Test ("UCT") and the Total Resource Cost. From a UCT perspective the
Residential EE Program had a 0.8 UCT ratio and the Commercial EE Program had a 0.9 UCT
ratio.2
YOU ARE FURTHER NOTIFIED that the Company stated that it has hosted two meetings
to address and discuss the parameters of the EESC with its stakeholders.
YOU ARE FURTHER NOTIFIED that the Company discussed proposed changes to the
Residential EE Program and plans for the Commercial EE Program.
YOU ARE FURTHER NOTIFIED that the Application and Annual Report have been filed
with the Commission and are available for public inspection during regular business hours at the
Commission's office. These documents are also available on the Commission's website at
www.puc.idaho.gov. Click on the "NATURAL GAS" icon, select "Open Cases," and then click
on the case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held pursuant
to the Commission's jurisdiction under Title 61 of the Idaho Code and all proceedings in this
matter will be conducted pursuant to the Commission's Rules of Procedure, IDAPA 31.01.01.000
et seq.
NOTICE OF INTERVENTION DEADLINE
YOU ARE FURTHER NOTIFIED that persons desiring to intervene in this matter to
obtain parties' rights of participation must file a Petition to Intervene with the Commission
pursuant to this Commission's Rules of Procedure 72 and 73, IDAPA 31.01.01.072 and -.073.
' The Company included a discussion about the alternative categories to measure savings from its EE efforts. The
Company discussed the benefits of using certain analyses compared to the EM&V.The Company also described the
evaluator's concerns with relying on the EM&V opposed to a deemed-savings analysis.
z The UCT for the Residential EE Program was based on the results of the EM&V.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 4

Persons who wish to intervene as a party must file a Petition to Intervene no later than 21
days after the date of service of this Order. Such persons shall also provide the Commission
Secretary with their email address to facilitate further communications. After the intervention
deadline runs, the Commission Secretary shall issue a Notice of Parties that identifies the parties
and assigns exhibit numbers to each parry. Once the Notice of Parties has issued, Commission
Staff shall informally confer with the Company and any intervening parties about how to further
process this case and shall then report back to the Commission on a proposed case schedule.
YOU ARE FURTHER NOTIFIED that persons who would like to present their views
without parties' rights of participation and cross-examination do not have to intervene but may
present their views by submitting written comments to the Commission.
YOU ARE FURTHER NOTIFIED that the following people are designated as the
Company's representatives in this matter:
Lori A. Blattner Preston N. Carter
Intermountain Gas Company Givens Pursley LLP
Post Office Box 7608 601 W. Bannock St.
Boise, ID 83707 Boise, ID 83702
lori.blattnergint ag s.com prestoncarter(k ig venspursley.com
igcre u�ry(kint ag s.com morgan og odin(k ig venspursle,
stephaniew(kgivenspursley.com
ORDER
IT IS HEREBY ORDERED that persons desiring to intervene in this matter must file a
Petition to Intervene no later than 21 days from the service date of this Order. Once the deadline
has passed, the Commission Secretary shall prepare and issue a Notice of Parties.
IT IS FURTHER ORDERED that,after the Notice of Parties has issued,Commission Staff
shall confer with the parties regarding a procedural schedule for this matter including,if necessary,
a hearing in this matter.
IT IS FURTHER ORDERED that parties comply with Order No. 35375, issued April 21,
2022. Generally, all pleadings should be filed with the Commission electronically and will be
deemed timely filed when received by the Commission Secretary.See Rule 14.02. Service between
parties should continue to be accomplished electronically when possible. However, voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 5

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 3rd day of
February 2025.
G
EDWARD LODGE, CO ISSIONER
95�—
?HN R. HAMMOND JR., COMMISSIONER
ATTEST:
L100,0—co—,
Xf i a i S
Commission Secre
;4�7
I:\Legal\GAS\INTG2405_prudence\orders\INTG2405_ntc app int_dh.docx
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36455 6