20250210Staff 8-21 to INT.pdf

RECEIVED
Monday, February 10, 2025 3:51:45 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )
GAS COMPANY'S APPLICATION FOR ) CASE NO. INT-G-24-05
DETERMINATION OF 2023 ENERGY )
EFFICIENCY EXPENSES AS PRUDENTLY )
INCURRED ) SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Intermountain Gas Company("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY,MARCH 3, 2025.
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
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 FEBRUARY 10, 2025

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. 8: Please provide the Energy Efficiency Program Impact Evaluation
Guide referenced by the Application in footnote 4.
REQUEST NO. 9: Please explain how the proposed deemed savings approach for
evaluations better reflects actual savings on the Company's system more than a savings value
informed by billing analysis.
REQUEST NO. 10: Please explain how the proposed deemed savings approach for
evaluations allows for adjustments to the assumed savings value in the future to better reflect
actual savings on the Company's system.
REQUEST NO. 11: Please explain how the Company will "align evaluation practices"
when each peer utility maintains evaluation practices that are not aligned.
REQUEST NO. 12: Please provide the 2023 CPA participation forecast for each of the
Residential and Commercial measures in excel format.
REQUEST NO. 13: Please explain how the Company incorporated past evaluation
results into the new Technical Resource Manual ("TRM"). Additionally,please answer the
following questions:
a. Please specify if and how the results of the 2020 EM&V(i.e., billing analysis and
simulation analysis) were used to inform the deemed savings amounts; and
b. Please specify if and how the results of the 2024 EM&V(i.e., billing analysis and
deemed savings analysis)were used to inform the deemed savings amounts.
REQUEST NO. 14: Please explain how future evaluation results will be included into
the new TRM.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY 10, 2025

REQUEST NO. 15: Please explain how frequently the Company plans to update its
TRM.
REQUEST NO. 16: Page 25 of the 2023 Annual Report stated the Company had
contracted with the Integrated Design Lab to develop a commercial customer survey. Please
answer the following questions:
a. Please provide the timeframe of when survey was conducted;
b. Please explain if the survey has been completed. If so,please explain when the
Company received the survey and how the Company used the results of the
survey; and
c. Please identify commercial program actions/adjustments made that are supported
by the results of the survey.
REQUEST NO. 17: For the Smart Thermostat measure, please explain how the
Company will verify the new requirements of the smart thermostat(i.e., Learning Based
Schedule, on-board motion occupancy, automatic HVAC reduction when home is unoccupied)
are enabled after the customer's rebate application is submitted.
REQUEST NO. 18: On Page 22 of its Application, the Company states that it is
planning to "pull the allocation of one FTE worth of labor funding from the Energy Services
Representatives ("ESR") allocation and use that funding to add a full time Energy Efficiency
Analyst("EEA") in 2025." On Page 11 of the Application, the Company states "ESRs engage in
business development for both the residential and commercial sector and also promote the
relevant energy efficiency program to customers." Please answer the following questions:
a. Please explain how the current ESR labor costs are recovered(i.e., base rates,
residential rider, commercial rider).
b. Please explain what recovery mechanisms the new ESR and EEA labor expenses
will be allocated to.
c. Please explain how the new division of responsibilities will impact the balances of
the Company's residential and commercial EE riders. Please describe the
different responsibilities between an EEA and an ESR positions.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 FEBRUARY 10, 2025

d. Please provide a comparison of the wage scales for the EEA and the ESR
positions.
e. On Page 22 of its Application, the Company states that ESRs are currently
promoting both residential and commercial programs. Additionally, the new EEA
and ESR maintain similar roles. Please provide additional detail regarding how
the Company expects the new EEA position will help grow the Commercial
Program.
REQUEST NO. 19: Please provide any forecasts the Company has for future gas prices.
Please provide the Company's avoided costs approved in the most recent IRP with the new
forecasted gas prices imputed.
REQUEST NO. 20: On Page 9 of the Application, the Company states, "The 2025
internal audit plan is currently under development and a biannual Energy Efficiency Program has
been proposed to the planning committee." Please provide copies of any proposals and
presentations made to the planning committee regarding the internal audits and schedules,
whether it be a power point presentation, or a written recommendation, or other.
REQUEST NO. 21: On Page I I of the Application, the Company states, "in 2023 the
Company implemented an internal software application for rebate processing called Enterprise
Rebate Application("ERA")." Also on Page 12 of the Application, the Company states, "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."
Please answer the following questions about these programs:
a. Please provide the total expense to date for building and implementing each of
these products.
b. Please explain what recovery mechanism the expenses for each product are
allocated to and the treatment of those expenses within that/those mechanisms.
Please provide estimates for the labor expense the Company forecasts they will
save from each of these products.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 FEBRUARY 10, 2025

c. The Company stated that the ERA was implemented in 2023, but on Page 8 of the
Application the Company also states: "the impacts of this implementation are not
seen in the data under review in this filing." Please explain why no impacts from
the ERA implementation were identified in 2023.
DATED at Boise, Idaho, this I Oth day of February 2025.
k,,a- (,I
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\INT-G-24-05 PR#2.docx
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 5 FEBRUARY 10, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ,v DAY OF FEBRUARY 2025,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-
G-24-05, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR—REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL: prestoncarter givenspursle .com
E-MAIL: lori.blattnernint ag_s.com morgan og oding ig venspursley.com
igcre ug_latoKykint ag s.com stephaniew(kgivenspursle .com
VA
PATRICINORD , SECRETARY
CERTIFICATE OF SERVICE