20250616Comments.pdf

RECEIVED
June 16, 2025
JAYME B. SULLIVAN IDAHO PUBLIC
BOISE CITY ATTORNEY UTILITIES COMMISSION
Ed Jewell ISB No. 10446
Jessica Harrison ISB No. 9768
Deputy City Attorneys
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttorneykeityofboise.org
ei ewell(ae,cityofboise.org
jharrisonncityofboise.org
Attorneys for Intervenor
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 CITY OF BOISE CITY'S
INCURRED COMMENTS
The city of Boise City ("City") submits these formal comments on the application
submitted by Intermountain Gas Company ("Intermountain Gas") for a determination of 2023
energy efficiency program expenses as prudently incurred. Boise City,pursuant to Rule 203 of
the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of
Modified Procedure, Order No. 36495, issued by the Commission on March 10, 2025, hereby
submits its formal written comments and states as follows:
SUMMARY
The City appreciates Intermountain Gas's continued investment in energy efficiency
initiatives and recognizes the importance of maintaining and expanding access to cost-effective,
equitable energy efficiency programs.In particular,the City acknowledges Intermountain Gas's
CITY OF BOISE CITY'S COMMENTS 1

implementation of the Evaluation,Measurement, and Verification(EM&V) study that includes
a billing analysis, as directed by prior Commission orders. The 2023 report reflects increased
participation, with 6.9% more residential rebates issued than in 2022. However, the City
remains concerned about the high proportion of incentives applied to new construction projects
as well as the discrepancy in cost-effectiveness of the portfolio with regard to a deemed-savings
or billing impact analysis. The City urges continued attention to balancing program delivery
between new builds and existing homes, particularly those occupied by low-income
households.
IMPACT OF NEW CONSTRUCTION PROJECTS
As in the 2022 prudency filing, a substantial percentage of residential rebates and
associated savings are from new construction. In 2023 this was —30% (Calculations based on
Application, Attachment 1). While improved natural gas efficiency benefits all customers, the
City believes the Commission should provide assurance that existing ratepayer revenues don't
over-incentivize efficiency measures in new construction, as new construction does not
immediately benefit existing ratepayers and savings can only be estimated until otherwise
verified. The City urges Intermountain Gas to continue to find ways to reach the existing
customer base,particularly lower-income customers.
COST-EFFECTIVENESS
The City recognizes the effort Intermountain Gas has made to address the billing impact
concerns raised in INT-G-23-06, the 2022 energy efficiency prudency determination. The City
also appreciates the continuous review process through which deemed savings are compared
against claimed savings to ensure accurate savings and cost-effectiveness calculations. Upon
reviewing the findings of the updated EM&V,the City does not have any further comments and
CITY OF BOISE CITY'S COMMENTS 2

is supportive of the deemed-savings approach recommended by the evaluator for the time being,
in the absence of more robust data for a billing impact approach to energy savings, and with the
caveat that differences in the evaluation approach are made transparent (see comments below).
The City is particularly focused on the impact of energy efficiency programs on customer
affordability. Cost-effectiveness according to deemed savings was 1.2 for the entire portfolio
but dropped to 0.9 when using the impact evaluation approach outlined in the EM&V study of
the residential portion(Application Attachment 1,page 1). This disparity between the evaluated
energy savings and the deemed energy savings raises questions about the allocation of program
funds to ensure incentives are driving actual reductions in energy consumption. The City
commends Intermountain Gas on its continued improvement of the savings measurement
method, while urging movement toward the method outlined in the EM&V which relies more
on actual—measured—savings. Additionally, as the measurement methods continue to evolve,
the energy efficiency programs should be continually evaluated for cost-effectiveness and
adjusted accordingly. Of note, the cost-effectiveness for the commercial rebates portion
remained the same at 0.9 with both evaluation methods.
CONTINUED EFFICIENCY OFFERINGS
The City continues to recommend the Company evaluate and present a behavioral energy
efficiency program offering to its Energy Efficiency Savings Committee for future
implementation. A behavior-change focused offering could lead to significant savings without
the traditional overhead expenses or customer costs associated with current equipment
replacement rebates. The City also looks forward to the Company's continued evaluation of do-
it-yourself weatherization kits that could increase customer awareness of energy efficiency
program offerings and deliver savings to low-income customers.
CITY OF BOISE CITY'S COMMENTS 3

Along the same lines as the weatherization kits, the City of Boise would also like to
recommend that Intermountain Gas continue to look for other cost-effective ways to include
low-income customers who may not otherwise be able to participate in a rebate program.
RECOMMENDATIONS
As stated above, the City appreciates the variety of offerings, and the efforts undertaken
in continuing to refine the evaluated savings. The City respectfully recommends that the
Commission direct Intermountain Gas to maintain and publish clear savings calculation
differences between new construction and retrofit projects, particularly in calculating therm
savings and incentive cost-effectiveness. While much improved, the City supports the
continued refinement of billing analysis methodologies, especially for programs with primarily
existing construction, where data would be available (i.e. evaluated savings approach). Lastly,
the City encourages Intermountain Gas to implement specific strategies to increase low-income
customer participation in energy efficiency programs.
Dated this 16th day of June 2025
Ede ll, Deputy City Attorney
CITY OF BOISE CITY'S COMMENTS 4

CERTIFICATE OF SERVICE
I hereby certify that I have on this 16th day of June 2025 served the foregoing documents
on all parties of record as follows:
Monica Barrios-Sanchez ❑ U.S. Mail
Commission Secretary ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
secretgakpuc.idaho._og_v
Chris Burdin ❑ U.S. Mail
Deputy Attorney General ❑ Personal Delivery
Idaho Public Utilities Commission ❑ Facsimile
11331 W. Chinden Blvd., Ste. 201-A 0 Electronic
Boise, ID 83714 ❑ Other:
chris.burdinkpuc.idaho.gov
Lori A. Blattner ❑ U.S. Mail
Director—Regulatory Affairs ❑ Personal Delivery
Intermountain Gas Company ❑ Facsimile
PO Box 7608 Q Electronic
Boise, ID 83707 ❑ Other:
lori.blattner(a),int ag s.com
igcre ug latory(kint ag s.com
Preston N. Carter ❑ U.S. Mail
Givens Pursley LLP ❑ Personal Delivery
601 W. Bannock St. ❑ Facsimile
Boise, ID 83702 Q Electronic
prestoncarterk ig venspursley.com ❑ Other:
morgan og odinkgivenspursley.com
stephaniewkgivenspursle,
Michelle Steel,
Paralegal
CITY OF BOISE CITY'S COMMENTS 5