20251104Petition for Clarification.pdf

RECEIVED
NOVEMBER 4, 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
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
19193818.2
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 PETITION FOR CLARIFICATION OR
PRUDENTLY INCURRED AND RECONSIDERATION
APPROVAL OF RATE SCHEDULE EE-RS
Intermountain Gas Company(Intermountain or Company) files this Petition for
Clarification or Reconsideration of Commission Order No. 36797, under Commission Rules 325
and 331, IDAPA 31.01.01.325 & .331.
Petition
In relevant part, Order No. 36797 provides,
IT IS FURTHER ORDERED that the Company's next prudency
filing shall include an EM&V with a billing analysis covering
Whole Home Tier I and Furnace measures.
The Company may not have sufficient data on these measures to conduct a statistically
valid EM&V with billing analysis. The Company believes that it would not be efficient to incur
the costs of an EM&V if the results of that evaluation are not useful. Accordingly, the Company
requests that the Commission issue an order clarifying that the Company's next prudency filing
PETITION FOR CLARIFICATION/RECONSIDERATION PAGE 1 OF 4

must contain an EM&V evaluation with a billing analysis of the Whole Home Tier I and Furnace
measures if there is sufficient data regarding these measures to conduct a statistically valid and
useful EM&V study.
For context, EM&V studies typically include several years' worth of data. For example,
the 2024 EM&V study evaluated projects rebated between April 1, 2021 and December 31,
2023. The sample set included 3,174 rebated projects, 2,535 of which had adequate data for a
billing analysis, for the Whole Home offering. For the Furnace rebate, there were 7,878 rebated
projects, 1,532 of which had adequate data for a billing analysis.
The EM&V study required by Order No. 36797, in contrast,would include only projects
rebated in calendar years 2024 and 2025. The sample set would be quite small: for Whole Home
Tier I, 35 projects were rebated in 2024 and 57 have been rebated so far in 2025. For furnaces,
there were 4,023 rebates in 2024 and 2,473 so far in 2025.
Additionally, the usage history will be quite short: no measure will have two years' worth
of data, and many would include only a handful of months.
Both a sufficient sample size and sufficient timeframe are needed to conduct a useful
EM&V study. A robust billing analysis, in particular, requires at least two years of usage data.l
If the Company were to conduct an EM&V study as required by the Order, the Company
believes that the study may not yield statistically valid or helpful results. While the expenses
incurred in such a study would be prudent for regulatory purposes—since they would be
implementing a Commission Order—the expenses may not be an efficient use of ratepayer
dollars.
1 The Company believes that the time lag between implementing the measure;customer installation of a measure;
rebating the measure;and evaluating the measure,combined with the requirement of annual prudency filings and the
inherently backwards-looking nature of billing analyses,is the source of much of the misunderstandings that have
permeated the past few prudency filings.
PETITION FOR CLARIFICATION/RECONSIDERATION PAGE 2 OF 4

The Company is willing to ask an EM&V consultant to provide an opinion as to whether
the EM&V study required in this portion of Order No. 36797 is likely to result in a statistically
valid or useful study, and provide notice to Staff of the consultant's opinion during one of the
required quarterly meetings.
In addition, Order No. 36797 requires the Company to use billing data to evaluate the
cost-effectiveness of energy efficiency measures. The Company believes that the Whole Home
Tier 1 measure is not, or may not be, cost-effective using billing data. However, the Order
requires the Company"to continue offering the current rebate amounts for the Whole Home I . .
. offering[]," Order No. 36797 at 12, and to "make an EE filing . . . if it wishes to make changes
to its DSM program," id. at 13.
Given the Company's belief that the Whole Home Tier I measure is not, or may not be,
cost-effective under a billing-data approach, the Company would be willing to retire this measure
if the Commission clarifies that the Company is permitted to retire this measure, effective
December 31, 2025, without a separate filing.
Conclusion
For these reasons, the Company requests that the Commission issue an order clarifying
Order No. 36797 or, alternatively, reconsidering Order No. 36797, to the extent the Order
requires the Company to conduct an EM&V study that may not yield statistically valid or useful
results.
Specifically, the Company requests that the Commission issue an order indicating that the
Company's next prudency filing shall include an EM&V with a billing analysis covering Whole
Home Tier I and Furnace measures if there is sufficient data regarding these measures to
conduct a statistically valid and useful EM&V study. If sufficient data does not exist, the
Company shall provide notice to Staff of its EM&V consultant's opinion to this effect.
PETITION FOR CLARIFICATION/RECONSIDERATION PAGE 3 OF 4

In addition, if the Commission is of the position that the Company can or should retire
the Whole Home Tier 1 measures based upon the Company's belief that the measure is not or
may not be cost-effective under a billing analysis, the Company requests an order clarifying that
the Company is permitted to retire this measure effective December 31, 2025 without a separate
filing.
Dated: November 4, 2025
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
PETITION FOR CLARIFICATION/RECONSIDERATION PAGE 4 OF 4

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT on November 4,20251 caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez, Commission Secretary [e-mail]
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Chris Burdin [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
City of Boise
Ed Jewell [e-mail]
Jessica Harrison [e-mail]
Deputy City Attorneys [e-mail]
Boise City Attorney's Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
Katie O'Neil [e-mail]
Energy Program Manager
Is/Preston N. Carter
Preston N. Carter
PETITION FOR CLARIFICATION/RECONSIDERATION