20250303INT to Staff 8-21.pdf

RECEIVED
March 3, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
[phone]
[e-mail]
[e-mail]
18813504.1 [14168.18]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. INT-G-24-05
OF INTERMOUNTAIN GAS COMPANY
FOR A DETERMINATION OF 2023 INTERMOUNTAIN GAS COMPANY'S
ENERGY EFFICIENCY EXPENSES AS RESPONSE TO THE SECOND PRODUCTION
PRUDENTLY INCURRED AND REQUEST OF COMMISSION STAFF
APPROVAL OF RATE SCHEDULE EE-RS
In response to the Second Production Request of the Commission Staff to Intermountain
Gas Company("Intermountain Gas" or"Company") dated February 10, 2025, Intermountain Gas
submits the following responses. Confidential responses and documents are subject to the
protective agreement in this case, and are available for download using a password-protected link
that will be provided separately by email. The password will be provided in a separate email.
Dated: March 3, 2025.
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
RESPONSES TO STAFF'S SECOND PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I hereby certify that on March 3, 2025, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
monica.barriossanchez(d_puc.idaho.gov
secretgagpuc.Idaho.gov
/s/Preston N. Carter
Preston N. Carter
RESPONSES TO STAFF'S SECOND PRODUCTION REQUEST PAGE 2 OF 2

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 8:
Please provide the Energy Efficiency Program Impact Evaluation Guide referenced in the
Application in footnote 4.
RESPONSE NO. 8:
The Impact Evaluation Guide referenced in the Application in footnote 4 is included as
the file "INT-G-24-05-PR 8—SEE Action Energy Efficiency Program Impact Evaluation Guide."
This guide was provided to the Company by IPUC Staff during initial discussions on best
practices as the Intermountain Energy Efficiency Program was being established.
INT-G-24-05
IPUC Staff PR 8
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
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.
RESPONSE NO. 9:
The proposed deemed savings approach for evaluations provides a transparent method for
evaluation that is determined at the time of program planning. However, the Company
understands the deemed savings value should incorporate billing analysis results when billing
analysis is feasible. The Company's Technical Reference Manual (TRM) is based on guidance
from ADM Associates, Inc. The process for determining how to savings values is outlined in a
memorandum prepared by ADM Associates, Inc. and included as "CONFIDENTIAL - INT-G-
24-05 PR 9_TRM Update":
"If a billing analysis completed during impact evaluation displays statistically significant
results, the billing analysis results would therefore represent the actual observable
energy savings demonstrated by the IGC customers who installed the measure, and
therefore is more accurate than the assumed deemed savings and its assumptions.
However, the TRH deemed savings units and its assumptions stand as a unit energy
savings source in the case billing analysis is infeasible. If a billing analysis is infeasible,
likely due to low participation, or lack of statistical significance, the engineering
algorithms will be used to estimate savings. This provides the company with a secondary
method for estimating verified savings should billing analysis be infeasible for a given
measure.
In the case of the Company's residential program, the storage tank water heater, combi
boiler, boiler, and tankless water heater did not have enough participation to enable a statistically
significant billing analysis in the current evaluation, so savings were verified via savings
methods as discussed in detail in Supplement 1 to the 2023 Annual Report.
INT-G-24-05
IPUC Staff PR 9
Page 1 of 3

The furnace and smart thermostat measures did have enough data to perform a
statistically significant billing analysis. The Company, in collaboration with the Evaluator,
reviewed the resulting billing analysis in comparison to the unit energy savings (UES)values
provided by the Regional Technical Forum (RTF). Because the billing analysis results were
relatively close to the UES values, the Company chose to use the RTF values for the 95 and 97%
efficient furnaces in a weighted rebate based on actual participation data from the EM&V study.
In the last couple of weeks, the Company has become aware that the RTF has updated their
savings estimates for furnace measures. Based on this information, the Company believes it will
be appropriate to discuss this new information with Commission Staff and adjust the furnace
rebate proposal accordingly. Although the billing analysis results for the smart thermostat were
actually slightly higher than the RTF values, the Company again chose to use the RTF value.
For the Whole Home rebates, the Company is proposing to use the RTF New Homes
Protocol, which is modeled savings, as the deemed savings. The Whole Home new construction
measures were evaluated using modeling in the 2024 EM&V impact evaluation. Although the
Evaluators attempted to conduct a billing analysis, the Evaluators suggested that evaluating new
construction projects using billing analysis is not an approved best practice. In Supplement 1 to
the 2023 Annual Report, pages 28 through 32, the Evaluator outlines the reasons billing analysis
is not the appropriate evaluation method. For convenience, the summary of the four concerns
with using billing analysis for residential new construction is included below. The Evaluator
provides detail on each of these concerns in Supplement 1,pages 28 through 32.
1. Other Idaho Utilities: Other Idaho utilities evaluate their residential new construction
programs through energy modeling software, in line with the methods completed in
Section 4.1.5.
INT-G-24-05
IPUC Staff PR 9
Page 2 of 3

2. RTF New Homes Protocol: The Regional Technical Forum has published a"New Homes
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
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.
INT-G-24-05
IPUC Staff PR 9
Page 3 of 3

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
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.
RESPONSE NO. 10:
In the file "CONFIDENTIAL - INT-G-24-05 PR 9—TRM Update", Evaluators have
provided a recommended cycle of planning, evaluation, and updates, including recommended
frequency for evaluation and TRM updates. This means that based on the proposed evaluation plan
included on INT-G-24-05, Exhibit No. 1, Page 22, the program would undergo an EM&V impact
evaluation with a resulting TRM review and update that would incorporate the results of the
evaluation in 2027. It is the Company's intent to update the TRM with results from each EM&V
impact evaluation. The TRM may also need to be updated if there are changes to any of the
resources upon which the TRM is broadly based. One example of this process is the very recent
Regional Technical Forum update for furnaces that is discussed further in the Response to
Production Request No. 9.
Topics of Interest Recommendation
Program planning approach ADM recommends that for future program planning,
for deemed savings Intermountain Gas Company utilize the estimated
measure-level savings presented in the Technical
Reference Manual as reasonable deemed, prescriptive
savings
INT-G-24-05
IPUC Staff PR 10
Page 1 of 2

Future evaluations Once a timeline of activities is approved by the
methodology for validating Commission, ADM recommends the impact evaluation
deemed savings from independently verify the deemed savings established in
Technical Reference Manual the TRM using primary project-level details and/or
facility consumption data and methodology aligns with
the four options provided in the Department of Energy
IPMVP
Cadence of impact evaluation ADM recommends Intermountain Gas Company
and Technical Reference complete an impact evaluation report of its Residential
Manual update activities and Commercial Program every one to two years, and a
TRM update aligning TRM assumptions to impact
evaluation results every two to four years
INT-G-24-05
IPUC Staff PR 10
Page 2 of 2

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 11:
Please explain how the Company will"align evaluation practices"when each peer utility
maintains evaluation practices that are not aligned.
RESPONSE NO. 11:
By proposing the use of a Technical Reference Manual (TRM) in this proceeding, the
Company is attempting to align its practices with the way other utilities in Idaho use TRM
deemed savings in program planning, verify program-level savings,update TRM assumptions,
and plan the cadence of each of the previous activities mentioned. The "CONFIDENTIAL -
INT-G-24-05 PR 9—TRM Update"provides recommendations for improvement of the
Intermountain Gas Energy Efficiency Program based on aligning with the process followed by
other Idaho utilities. If the assessment of the Evaluator is incorrect, the Company would like to
collaboratively work with Commission Staff to edit the document which the Company hopes will
form the basis of a procedure document going forward.
INT-G-24-05
IPUC Staff PR 11
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 12:
Please provide the 2023 CPA participation forecast for each of the Residential and
Commercial measures in excel format.
RESPONSE NO. 12:
In the attached file, "CONFIDENTIAL_INT-G-24-05-PR 12—Measure Inputs Database",
column Y is the `Baseline Initial Saturation," and column Z is the "Efficient Measure Initial
Saturation" field. These two columns represent how much of the building stock has already
adopted the efficient level of the technology(versus the portion that has the baseline and thus is
available to adopt the efficient measures).
To use the residential furnace measure as an example, the assumption is that 18.9% of
households already have a 95 AFUE or better furnace, meaning that 81.1% of the stock is at the
baseline of 80 AFUE or below and remains available to contribute to savings potential.
INT-G-24-05
IPUC Staff PR 12
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. 12
CONFIDENTIAL ATTACHMENT PROVIDED UNDER
SEPARATE COVER

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
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.
RESPONSE NO. 13:
The Company used the results of the 2020 EM&V to redesign the rebates that were studied in that
analysis. Those redesigned rebates were implemented in April 2021. The 2024 EM&V analysis
was performed on the rebates implemented in 2021.Although the Company provided both EM&V
studies to the Evaluator that developed the IGC Technical Reference Manual (TRM), the most
applicable data is the most recent, so the data from the 2024 EM&V was used to inform deemed
savings in the TRM.
a. The results of the 2020 EM&V(i.e., billing analysis and simulation analysis)were not
used to inform the deemed savings amounts in the IGC TRM. Based on the
recommendation from the Evaluator, a prior evaluation would only be used to inform
future savings if updated evaluation of a rebate was not feasible and could not be
performed. In that case a prior evaluation could be used.
b. The Company used the results of the 2024 EM&V to inform the development of the
TRM. In the case of the storage tank water heater, combi boiler, boiler, and tankless
INT-G-24-05
IPUC Staff PR 13
Page 1 of 3

water heater there was not enough participation to enable a statistically significant billing
analysis in the current evaluation, so savings were verified via savings methods as
discussed in detail in Supplement 1 to the 2023 Annual Report. These measures relied on
the recommendations from the 2024 EM&V to develop deemed savings numbers in the
TRM.
The furnace and smart thermostat measures did have enough data to perform a
statistically significant billing analysis. The Company, in collaboration with the
Evaluator, reviewed the resulting billing analysis in comparison to the unit energy
savings (UES) values provided by the Regional Technical Forum(RTF). Because the
billing analysis results were relatively close to the UES values, the Company chose to use
the RTF values for the 95 and 97% efficient furnaces in a weighted rebate based on actual
participation data from the EM&V study. In the last couple of weeks, the Company has
become aware that the RTF has updated their savings estimates for furnace measures.
Based on this information, the Company believes it will be appropriate to discuss this
new information with Commission Staff and adjust the furnace rebate proposal
accordingly. Although the billing analysis results for the smart thermostat were slightly
higher than the RTF UES values, the Company chose to use the RTF value for deemed
savings.
For the Whole Home rebates, the Company is proposing to use the RTF New
Homes Protocol, which is modeled savings, as the deemed savings. The Whole Home
new construction measures were evaluated using modeling in the 2024 EM&V impact
evaluation. Although the Evaluators attempted to conduct a billing analysis, the
Evaluators suggested that evaluating new construction projects using billing analysis is
INT-G-24-05
IPUC Staff PR 13
Page 2 of 3

not an approved best practice. The TRM relies on the findings of the 2024 EM&V study
as the basis for using the RTF New Homes Protocol as the deemed savings.
INT-G-24-05
IPUC Staff PR 13
Page 3 of 3

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 14:
Please explain how future evaluation results will be included into the new TRM.
RESPONSE NO. 14:
Based on Evaluator guidance provided in the file "CONFIDENTIAL - INT-G-24-05 PR
9—TRM Update", the Company will update the TRM following an EM&V impact evaluation.
Page 7 of the above referenced document walks through an example of how the TRM would be
updated. An excerpt from page 7 is provided below.
Once the evaluation is completed and verified savings are completed by a third party
evaluator, the evaluator may suggest that IGC update the TRM to align with the results of
the impact evaluation. If the measure is already included in the TRH, this may be
suggested in the case that the evaluator references more up to date engineering
algorithm assumptions, such as an update in the RTF workbooks, an update on EFLH
assumptions, or if a billing analysis was completed, which more accurately reflects
actual observed energy savings on the IGC system.
IGC may then request the TRH to be updated using the impact evaluation results.
Whether or not the TRM is officially updated to reflect the impact evaluation results,
which requires additional budgeting, contracting, and time, IGC may choose to select the
impact evaluation result savings per unit for future program year claimed savings or
choose to select the current TRH savings per unit for future program year claimed
savings. This decision may be informed by the magnitude of discrepancy found between
the impact evaluation resulting savings value and the TRH deemed savings value,
typically a discrepancy equal to or more than 10%.
It is important, however, that IGC track and reference the impact evaluation report or
TRM section selected to identify unit-level claimed savings for the measure,for example,
in a workbook,for each measure type rebated in the program year. It is important that
the Commission is able to assess whether the source of the claimed savings value is
reasonable to use. The prior year impact evaluation report and the TRH are both
reasonable sources for claimed savings. IGC may then start planning the next program
year cycle and expected savings for each measure. From here, the process starts again.
INT-G-24-05
IPUC Staff PR 14
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 15:
Please explain how frequently the Company plans to update its TRM.
RESPONSE NO. 15:
In the application in this case, Exhibit No. 1, Page 22, the Company provided a proposed
evaluation plan for 2025 —2028. As illustrated in that plan, the Company plans to conduct an
EM&V impact evaluation on the program in 2027 to review the program changes implemented
in 2025. At the conclusion of the EM&V impact evaluation, the TRM would be reviewed and
any necessary updates incorporated.
INT-G-24-05
IPUC Staff PR 15
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 16:
Page 25 of the 2023 Annual Report states 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.
RESPONSE NO. 16:
The Company Response to the questions related to the commercial customer survey are as
follows:
a. Commercial customers were invited to take the survey three separate times in 2024:
• Week of August 6, 2024 - Postcards were mailed to 500 commercial
customers.
• Week of September 24—A total of 8,769 emails were sent to commercial
customers who opt in to receiving email on topics related to energy efficiency.
• Month of November— 16,000 commercial customers received a bill insert
with their paper bill.
INT-G-24-05
IPUC Staff PR 16
Page 1 of 3

b. The 2024 survey effort is complete. The Company received 1 response to the August
outreach, 32 responses in September, and 1 response in November. The most
important use of the survey results has been to begin building a database that
identifies the building operator/facilities manager and their contact information,
enabling the Company to send out relevant, customized communications to those that
make energy-use related decisions rather than the accounts payable teams.
"C% 1
1 Let's Work Together:
Calling all facilities managers!
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we want to"n how to better s"your business by hesp r,
you save"toney and energy.Stan beiam to take ou,survey
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11 you are hawt trouble accessong the survey.or have any
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Scan tM OR code to umt the survey hoW
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c. While the 2024 survey effort is complete, the company intends to continue to use the
survey as a data collection method to learn what kind of equipment commercial
customers are using, identifying customers pursuing energy efficient projects, as well
as a guide for conversations with customers about their equipment, gas usage,
upcoming projects, and interest in energy efficiency. The survey method will provide
a uniform framework for collecting the same data points from customers. The new
Commerical Analyst will use the information collected by the survey to speak with
the correct contact for the commercial customers, for lead generation, and for
identifying those customers that are interested in learning about energy efficiency and
pursuing energy savings options. Data from the survey will also help the Company
craft more relvant outreach messaging. The Company also acknowleges that while the
INT-G-24-05
IPUC Staff PR 16
Page 2 of 3

intention of the survey was to be thorough, the length of the survey may have been a
barrier to particiation and will explore ways to pare back the survey to only the most
essential questions to encourage more participation.
INT-G-24-05
IPUC Staff PR 16
Page 3 of 3

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
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.
RESPONSE NO. 17:
The Company intends to have a list of qualifying models that meet the new requirements
outlined in the Technical Reference Manual, which will be available for customers to reference
when purchasing a smart thermostat. In addition, the Company will confirm the model number
for thermostats submitted for rebate meet the new requirements prior to payout of the rebate. The
Company will also provide additional information on the application to raise awareness that not
utilizing these settings can impact a customer's energy savings similar to messaging used by
other Idaho utilities that offer a smart thermostat incentive.
INT-G-24-05
IPUC Staff PR 17
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 18:
On Page 22 of its Application, the Company states that it is planning to "pull the
allocation of one FTE work 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.
d. Please provide 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.
INT-G-24-05
IPUC Staff PR 18
Page 1 of 4

RESPONSE NO. 18:
The Company Response to Request No. 18 is as follows:
a. Through the end of 2024, 20% of the ESR labor expense was charged to the Energy
Efficiency Program with 18% allocated to the residential program and 2% allocated
to the commercial program. The remaining 80% of all ESR labor was recovered
through base rates. Through 2024, there were 10 ESRs distributed throughout the
Company's service territory and each of them spent 20% of their time on energy
efficiency promotions (or the equivalent of 2 FTEs).
b. At the end of 2024, 1 ESR took another position with the Company. The Energy
Efficiency Program was also in the middle of a commercial program EM&V with one
of the main goals being to determine ways to improve participation. As the
Application outlines on Page 22,beginning in 2025 the Company eliminated one FTE
worth of ESR labor being charged to the Energy Efficiency Rider. Going forward,
only 10% of ESR labor will be charged to the Energy Efficiency Residential Rider,
while 90% of the remaining ESR labor will be charged to base rates. To provide more
specialized outreach for the Commercial Energy Efficiency Program, the Company
has hired an Energy Efficiency Analyst with the dedicated job of providing outreach
to commercial customers.
c. In 2025, the percentage of ESR labor charged to the energy efficiency rider will be
reduced from 20%to 10%. ESRs will continue to promote the Residential Energy
Efficiency Program. The 10%reduction of the ESR labor expenses will shift from an
ESR labor expense and will instead fund one full time Commercial Energy Efficiency
Analyst that will work solely on promoting the Commercial Program.
INT-G-24-05
IPUC Staff PR 18
Page 2 of 4

Going forward, ESRs will only be responsible for promoting the Residential
Program. This change will reduce labor charged to the Residential Energy Efficiency
Rider and increase the labor charged to the Commercial Energy Efficiency Rider.
The full ESR job descriptions are provided in the Response to Production Request
No. 3, in the folder"CONFIDENTIAL - INT-G-24-05 PR 3 JOB
DESCRIP BENEFITS_COMPENSATION". The relevant descriptions are
"CONFIDENTIAL Energy Services Representative" and "CONFIDENTIAL Energy
Services Representative, Sr.". In summary the ESRs are responsible for meeting with
prospective customers to negotiate line extensions and in those conversations
promoting the Energy Efficiency Program. They are also responsible for maintaining
close contact with existing customers, local builders, developers, trade allies,
businesses, economic and community development organizations and Chamber of
Commerce groups. They also participate in events and present informational
programs to groups and organizations.
The full EEA job descriptions are provided in the Response to Production Request
No. 3, in the folder"CONFIDENTIAL - INT-G-24-05 PR 3 JOB
DESCRIP BENEFITS_COMPENSATION". The relevant descriptions are
"CONFIDENTIAL Energy Efficiency Analyst I-III" and"CONFIDENTIAL Energy
Efficiency Analyst, Sr.". In summary the EEA is responsible for assisting with the
tactical implementation of the Company's Energy Efficiency Program. The particular
duties of the "Outreach"EEA include development and execution of the annual
outreach strategy and comprehensive campaigns, building relationships with industry
partners, and maintaining detailed tracking and reporting of outreach activities.
INT-G-24-05
IPUC Staff PR 18
Page 3 of 4

d. The wage scales for ESRs and EEAs are provided in the Response to Production
Request No. 3, in the folder"CONFIDENTIAL - INT-G-24-05 PR 3—JOB
DESCRIP BENEFITS_COMPENSATION", file "CONFIDENTIAL Job Summary".
The Company would be happy to walk through these confidential files during an in
person meeting with Staff.
e. At the time of the application, ESRs were promoting both residential and commercial
programs. As of 2025 that has changed and ESRs are only responsible for promoting
the Residential Energy Efficiency Program. If they see a commercial opportunity,
they can refer that to the new Commercial Energy Efficiency Analyst. The new
Commercial Energy Efficiency Analyst will be 100% dedicated to commercial energy
efficiency outreach, education, and awareness. While methods like bill inserts,bill
inserts and emails have been successful methods of reaching residential customers, it
has not been successful for commercial customers. Residential gas equipment is
uniform while commercial is not and in fact varies a great deal. One size fits all
communications are not working to reach our diversified commercial customer base.
The ability to have more one-on-one contact with the Company's commercial
customers in addition to having a person dedicated to creating more customized
communications should make outreach efforts to this diverse customer class more
effective. The Company believes an energy efficiency analyst dedicated 100%to this
effort, in conjunction with a more robust offering will help grow the commercial
program.
INT-G-24-05
IPUC Staff PR 18
Page 4 of 4

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Min Park/Kathy Wold
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 priced
imputed.
RESPONSE NO. 49:
Please see the file "CONFIDENTIAL - INT-G-24-05-PR 19 Avoided Cost". An updated
natural gas commodity forecast can be found on the worksheet"COMMODITY COST". The
resulting levelized avoided cost per therm is provided on the worksheet"LEVELIZED
AVOIDED COST"in column"I". Inflation rate, transport costs and discount rates were also
updated.
INT-G-24-05
IPUC Staff PR 19
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. 19
CONFIDENTIAL ATTACHMENT PROVIDED UNDER
SEPARATE COVER

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
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.
RESPONSE NO. 20:
As the Company noted in the Response to Request No. 2, the MDUR Audit Committee
approved the 2025 Internal Auditing Plan which includes an audit of the Intermountain Energy
Efficiency Program. Below is an excerpt from the meeting agenda held on February 12, 2025.
February Audit Meeting
02 12 2025 01 30 Phi-05 00 Pld
5.2 Report on Internal Auditing/Review Kelhe Erhardt
and approve 2025 Internal Audit Plan
INT-G-24-05
IPUC Staff PR 20
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 21:
On Page 11 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 mechanisms 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.
c. The Company state 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.
RESPONSE NO. 21:
The Enterprise Rebate Application("ERA") is comprised of two parts 1)the internal
component, EE Rebates, and 2)the customer facing component, the customer webapp. EE
Rebates was implemented in 2023, while the customer webapp was not implemented until 2024.
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a. No expenses for ERA were booked to the energy efficiency rider account.
Existing company software was modified to accommodate energy efficiency
workflows. A system used for issuing customer refunds was modified to enable it
to be used to also pay customer rebates for the EE Rebates portion of ERA. The
customer self-serve portal was modified to include pages for customers to apply
for rebates which created the customer webapp. Work on ERA was done using
internal resources which are already embedded in the Company's base rates.
b. No expenses for ERA maintenance or operations expenses will be booked to the
rider account. Work on ERA is being done using internal resources which are
already embedded in the Company's base rates. The intent of ERA is to improve
internal processes and data security going forward. While there will be some
efficiency gains, so far those have allowed the Company to stay current with the
rebate processing volumes without the need to bring in temporary processing
assistance. The Company believes that encouraging customers to use the self-
service customer webapp will continue to provide efficiencies over manual rebate
input that will allow for some continued program growth without the need for
incremental rebate processing staffing going forward. One of the harder to
quantity benefits, is the data security. The implementation of EE Rebates
transferred rebate processing to a more secure data storage option and eliminated
the use of an excel spreadsheet for data tracking. The customer webapp replaced
the use of a third-party software for the transmission of sensitive customer
information and transferred this process to the Company's secure site and
infrastructure protected behind customer accounts.
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c. As discussed earlier, ERA is a rebate processing system that consists of several
components: the internal component, EE Rebates, and the customer facing
component, the customer webapp. EE Rebates was implemented in the spring of
2023, and the customer webapp was implemented in the spring of 2024. In order
to migrate to EE Rebates, the Company paused rebate processing for
approximately one month, creating a considerable rebate processing queue.
Although significant testing was conducted prior to implementation, time was
spent on data validation to ensure the system was working as expected. The same
is true for the implementation of the customer web app. This prudency filing only
covers the implementation of the internal facing part of ERA, EE Rebates, which
occurred in 2023. The significant post-implementation validation and catching up
on the backlog created by the pause in rebate processing meant the full benefit of
EE Rebates was not realized in 2023. The same was true for the implementation
of the external facing customer webapp during 2024.
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IPUC Staff PR 21
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