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HomeMy WebLinkAbout20250606Supplemental to Application.pdf INTERMOUNTAIRR) RECEIVED GAS COMPANY .rune 6, 2025 A Subsidiary of MDU Resources Group,Inc. I DAH O PUBLIC In the Community to Serve UTILITIES COMMISSION June 6, 2025 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 Supplement to Application for a Determination of 2023 Energy Efficiency Expenses as Prudently Incurred, including proposed revisions to Rate Schedule EE-RS 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: Preston Carter INTERMOUNTAIN GAS COMPANY CASE NO. INT-G-24-05 SUPPLEMENT TO 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: (208) 388-1200 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 SUPPLEMENT TO Efficiency Expenses as Prudently APPLICATION 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"),submits additional information pertinent to this case in this Supplement ("Supplement to Application" or "Supplement")to the Application for Determination of 2023 Energy Efficiency Expense as Prudently Incurred, Case No. INT-G-24-05, filed December 20, 2024 ("Original Application"). This Supplement includes the proposed changes to the Company's Residential Energy Efficiency Program("EE Program") resulting from applying updated unit energy savings from the Regional Technical Forum ("RTF") furnace workbook V3.1 released in February 2025. The information included in this Supplement does not seek to replace, amend, or remove any portion of the Original Application related to the request for an order designating $3,846,358 of 2023 Energy Efficiency expenditures as prudently incurred. Rather, the Supplement seeks to replace the proposed Energy Efficiency program revisions provided in the Original Application as Exhibit No. 2 and the resulting Rate Schedule EE-RS tariff revisions provided in the Original SUPPLEMENT TO APPLICATION 3 Application as Exhibit No. 3 to reflect the results of incorporating the RTF furnace workbook changes that became available after this case was filed. Please address communications regarding this Application to: Preston N. Carter Givens Pursley LLP 601 W. Bannock St. Boise, Idaho 83702 prestoncarter(&aivenspursle. morgangoodin@givenspursley.com stephaniew@givenspursley.com and Lori A. Blattner Director—Regulatory Affairs Intermountain Gas Company Post Office Box 7608 Boise, ID 83707 lori.blattner@intgas.com igcregulatory@intgas.com In support of this Application,Intermountain alleges and states as follows. 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; SUPPLEMENT TO APPLICATION 4 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. 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. BACKGROUND On December 20, 2024, Intermountain filed the Original Application. The Original Application included proposed revisions to the Company's Residential EE Program based on the results of the EM&V study and the Company's proposed Technical Reference Manual("IGC TRM")that incorporated the EM&V results as well as"data sources and analytical methods that are widely considered acceptable for the measure and purpose"! An important data source for the Company's proposed IGC TRM is the RTF. On February 3,2025,the Commission issued a Notice of Application and Notice of Intervention Deadline in Order No. 36455. On March 10, 2025, the Commission issued a notice of Modified Procedure in Order No. 36495 setting a comment deadline of June 18,2025 and a reply comment deadline of July 9, 2025. The Company acknowledges that the filing of this Supplement will likely necessitate a change in the 1 Original Application INT-G-24-05,p 20 SUPPLEMENT TO APPLICATION 5 schedule for this case and will cooperate with the parties to establish a revised schedule. PROPOSED RESIDENTIAL PROGRAM CHANGES In February 2025,the RTF released the updated furnace workbook Version 3.1. Since the RTF is the basis of the underlying savings assumptions in the IGC TRM, Intermountain commissioned the third parry evaluator("Evaluator')to revise the IGC TRM to update all residential program incentives with the best available data. After the IGC TRM updates were implemented, the proposed furnace and smart thermostat measures were not cost effective, and the program level cost effectiveness resulted in a Utility Cost Test("UCT") of 0.9,which was not cost effective. As a result, in this Supplement Intermountain proposes to revise the following program changes filed in the Original Application, 1)retire the Whole Home Tier II incentive, 2)reduce the furnace incentive, 3) reduce the tankless water heater incentive and 4)retire the smart thermostat incentive. The revised proposed residential energy efficiency program is provided in Exhibit No. 4, incorporated by reference, which will replace the Original Application Exhibit No. 2. The Company has also included the updated IGC TRM as Exhibit No. 5 which is incorporated by reference. Workbook files for these exhibits will be provided with the filing. PROPOSED TARIFF The revisions outlined above will also impact the proposed tariff changes in the Original Application Exhibit No. 4. Exhibit No. 6, incorporated by reference, provides the legislative and clean copies of the proposed revisions to Rate Schedule EE-RS. 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 SUPPLEMENT TO APPLICATION 6 consideration of this matter. Because neither the Original Application nor this Supplement propose to change customer rates, Intermountain has not provided direct notice to customers. See Commission Rule of Procedure 125.01, ADAPA 3.01.01.125.01. 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, as requested in the Original Application, b. That the Commission include this Supplement, the attached Exhibits, and the issues identified in the Supplement and Exhibits within Case No. INT-G-24-05, c. That the proposed revisions to Rate Schedule EE-RS shown in Exhibit No. 6 to this Supplement be accepted as filed, d. That the Commission approve the requests in the Original Application that are not altered by this Supplement, including the use of the deemed saving methodology developed and proposed by the Evaluator and the Company, e. That the Original Application and Supplement be heard and acted upon without hearing under modified procedure, and fh. For such other relief as this Commission may determine just and proper. DATED: June 6, 2025 9. INTERMOUNTAIN GAS COMPANY Givens Pursley LLP By By AlPreston N. Carter Lori A. Blattner Preston N. Carter Director—Regulatory Affairs Attorney for Intermountain Gas Company INTERMOUNTAIN GAS COMPANY Givens Pursley LLP SUPPLEMENT TO APPLICATION 7 EXHIBIT NO. 4 CASE NO. INT-G-24-05 INTERMOUNTAIN GAS COMPANY 2025 Program Planning (1 Page) Exhibit No.4 Case No. INT-G-24-05 Intermountain Gas Company Page 1 of 1 INTERMOUNTAIN GAS COMPANY Energy Efficiency Program PROGRAM 2025 Cost-Effectiveness Testing(Program Planning V.2) Rebate Allocation Method %Rebate Count Residential Overhead Costs $ 810,466.00 INPUT BY REBATE UCT RESULTS Amended 2025 ANNUALTHERM INCREMENTAL rebate count REBATE NAME SEGMENT SAVINGS EUL COST REBATE AMOUNT forecast UCT RATIO Whole Home I Residential 183 22 $ 3,068 $ 1,500 200 1.1 Whole Home 11 Residential 110 22 $ 2,941 - 0.0 Furnace blended Residential 37 23 $ 228 $ 275 4,900 1.0 Combi boiler Residential 168 25 $ 2,412 $ 1,500 13 1.1 Boiler Residential 107 25 $ 2,135 $ 1,000 13 1.0 Tankless(Energy Star Certified) Residential 51 20 $ 895 $ 375 1 1,500 1.0 Smart Thermostat Residential 26 7 $ 165 0.0 1.0 Indicates a change from Program Proposal V.1. EXHIBIT NO. 5 CASE NO. INT-G-24-05 INTERMOUNTAIN GAS COMPANY Updated IGC TRM (1 page) Exhibit No.5 Case No.INT-G-24-05 Intermountain Gas Company Page 1 of 1 Therms per Incremental Measure Life (:02 reduction(to ra Primary Fuel Other Date Measure Unit cost (Years) over expected Type Sector End-use Technology Other Specifications 1 Specifications 21 Updated Source measure life) (1)Must be HERS rated,(2)Air sealing at or below 3 ACH at 50 Pa,(3)Ceiling insulation at or above R-49,(4)Ducts and air handler located inside conditioned space or duct leakage to outside of less than 4 CFM25/100 ft'CFA,and(5)Furnace efficiency at or Whole Home Tier 1 183.40 $3,068.16 22.00 18.66 Gas Residential Space&Water Heating New Construction above 97%AFUE 9/26/2024 PY2021-PY2023 Impact Evaluation (1)Must be HERS rated,(2)Air sealing at or below 4 ACH at 50 Pa,(3)Ducts and air handler located inside conditioned space or duct leakage to outside of less than 4 Whole Home Tier 11 110.02 $2,940.86 22.00 17.73 Gas Residential Space&Water Heating New Construction CFM25/100 ft'CFA,and(4)Furnace efficiency at or above 95%AFUE 9/26/2024 PY2021-PY2023 Impact Evaluation Natural Gas Furnace 95%AFUE + 36.18 $250.88 22.50 4.28 Gas Residential Space Heating Gas Furnace Must have AFUE rating equal to or greater than 95% 3/14/2025 Regional Technical Forum Gas Furnace Workbook V3.1 Natural Gas Furnace 97%AFUE + 44.10 $20.22 22.50 5.21 Gas Residential Space Heating Gas Furnace Must have AFUE rating equal to or greater than 97% 3/14/2025 Regional Technical Forum Gas Furnace Workbook V3.1 Natural Gas Furnace 95%AFUE +or 97%AFUE+(Mixed) 36.98 $227.58 22.50 4.37 Gas Residential Space Heating Gas Furnace Must have AFUE rating equal to or greater than 95%or 97% 3/14/2025 Regional Technical Forum Gas Furnace Workbook V3.1 (1)Must be ENERGY STAR qualified; (2)Must have 7-Day programmable or learning-based scheduling; (3)Must be Wi-Fi enabled,with remote access; (4)Must include on-board motion occupancy sensor or be packaged with a motion sensor. Geo-fencing is not considered motion sensing; (5)Must have automatic HVAC reduction when home is occupied; (6)Must minimize auxiliary electric resistance heat runtimes using lockout informed by outdoor temperature sensor or local weather via internet; Smart Thermostats 26.29 $165.03 7.00 3.11 Gas Residential Space Heating Smart Thermostat (7)Must be replacing a non-qualifying thermostat 9/26/2024 Regional Technical Forum Connected Thermostats Workbook V3.1 (1)Must be a storage tank gas water heater with less than or equal to 55 gallon tank and Uniform Energy Factor equal to or greater than 0.64 with medium draw pattern OR Must be a storage tank gas water heater with less than or equal to 55 gallon tank and Uniform Energy Factor equal to or greater than 0.68 with high draw pattern OR Must be a storage tank gas water heater with greater than 55 gallon tank and Uniform Energy Factor equal to or greater than 0.78 with medium draw pattern OR Must be a storage tank gas water heater with greater than 55 gallon tank and Uniform Energy Factor equal to or greater than 0.80 with high draw pattern; (2)Must be a condensing storage tank water heater; Storage Tank Water Heater, (3)Must have First Hour Rating of greater than or equal to 51 gallons per hour; ENERGY STAR-Qualified v4.0 (4)Must have warranty equal to or greater than 6 years system(including parts); only,condensing 23.14 $1,808.67 14.50 2.29 Gas Residential Water Heating Water Heater (5)Must have safety standards meeting ANSI Z21.10.1/CSA 4.1 9/26/2024 Regional Technical Forum Gas Water Heater Workbook V3.2 (1)Must be a storage tank gas water heater with Uniform Energy Factor equal to or greater than 0.81 with medium draw pattern OR Must be a storage tank gas water heater with Uniform Energy Factor equal to or greater than 0.86 with high draw pattern; (2)Must be a condensing storage tank water heater; Storage Tank Water Heater, (3)Must have First Hour Rating of greater than or equal to 67 gallons per hour; ENERGY STAR-Qualified v5.0, (4)Must have warranty equal to or greater than 6 years system(including parts); condensing 33.51 $1,808.67 14.50 3.61 Gas Residential Water Heating Water Heater (5)Must have safety standards meeting ANSI Z21.10.1/CSA 4.1 9/26/2024 Regional Technical Forum Gas Water Heater Workbook V3.2 Tankless(Not ENERGY STAR- qualified) 35.78 $259.53 20.00 4.00 Gas Residential Water Heating Water Heater (1)Must be a tankless gas water heater meeting minimum federal standards 9/26/2024 Regional Technical Forum Gas Water Heater Workbook V3.2 (1)Must be a tankless gas water heater with Uniform Energy Factor equal to or greater than 0.87; (2)Must have a GPM of equal to or greater than 2.8 over a 77°rise; Tankless UEF>_0.87(ENERGY (3)Must have warranty equal to or greater than 6 years on heat exchanger; STAR V4.0-qualified) 50.25 $727.65 20.00 5.65 Gas Residential Water Heating Water Heater (4)Must have warranty equal to or greater than 5 years on parts 9/26/2024 Regional Technical Forum Gas Water Heater Workbook V3.2 (1)Must be a tankless gas water heater with Uniform Energy Factor equal to or greater than 0.95; (2)Must have a GPM of equal to or greater than 2.9 over a 77'rise; Tankless UEF z 0.95(ENERGY (3)Must have warranty equal to or greater than 6 years on system(incliding parts); STAR V5.0-qualified) 51.19 $894.79 20.00 5.87 Gas Residential Water Heating Water Heater (4)Must have safety standards meeting ANSI Z21.10.3/CSA 4.3 9/26/2024 Regional Technical Forum Gas Water Heater Workbook V3.2 95%AFUE Boiler 107.12 $2,135.00 25.00 4.28 Gas Residential Space Heating Boiler Must have AFUE rating equal to or greater than 95% 9/26/2024 Illinois Technical Reference Manual V12.0 95%AFUE Combination Boiler 168.25 $2,412.00 25.00 8.27 Gas Residential Space&Water Heating Combination Boilerl Must have AFUE rating equal to or greater than 95% 9/26/2024 Illinois Technical Reference Manual V12.0 EXHIBIT NO. 6 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 Cn�r+h Fifth Revised Sheet No. 16(Page 2 Approved Effective of 2 Name May 17, 2022 jug-12022 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: $9GG1,500 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 Whele Heme Tier 11 New Tier 11 Requirements: $7-00 GenStFUGtien • HERS rated • Air sealing at or below 4 ACH at 50 Pa • D Gts and air handler Iegated inside eenrli+inned opaGe r d Gt leakage+e eutskde of loos than it ('FM25/100 f+7 GF 0 Combination Boiler for Space Heating 95%AFUE $N01, 000 Space and Water Heat Furnace Space Heating 95%AFUE $a50275 Boiler Space Heating 95%AFUE $N01, 000 Storage Water Heater Water Heating FR�F $44-5 Tankless Water Water Heating .Q1�1 UEFEnergy Star°Certified $35375 Heater Tier I Tankless Wa+or Water Hooting 87�C $3W Heater Toe" Smart Thermostat Them_meostat Energy Star Certified 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 €ffeGtiVe: 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 Combination Boiler for Space Heating 95%AFUE $1,500 Space and Water Heat Furnace Space Heating 95%AFUE $275 Boiler Space Heating 95%AFUE $1,000 Tankless Water Water Heating Energy Star'Certified $375 Heater Tier I 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