20251121Application.pdf

RECEIVED
NOVEMBER 21, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Megann E. Meier, ISB No. 11948
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. INT-G-25-07
OF INTERMOUNTAIN GAS COMPANY
FOR AUTHORITY TO REVISE RATE APPLICATION
SCHEDULE EE-GS—GENERAL SERVICE
ENERGY EFFICIENCY REBATE
PROGRAM
Intermountain Gas Company, ("Intermountain," "Applicant," 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"), requests authority to revise Rate Schedule EE-GS—General Service Energy
Efficiency Rebate Program as outlined in this application, effective January 1, 2026.
Please address communications regarding this Application to:
Preston N. Carter
Megann E. Meier
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
[e-mail]
[e-mail]
[e-mail]
and
APPLICATION PAGE 1 OF 8

Michael Parvinen
Director—Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608
Boise, ID 83707
[e-mail]
[e-mail]
In support of this Application,Intermountain alleges and states as follows.
I. 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;
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.
APPLICATION PAGE 2 OF 8

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.
II. BACKGROUND
Intermountain Gas Company("Intermountain"or"Company")launched its Commercial
Energy Efficiency Program in April 2021, following authorization from the Idaho Public Utilities
Commission(Order No. 34941, Case No. INT-G-20-04). The program, funded through Rate
Schedule EEC-GS,was designed to provide incentives for commercial space heating and kitchen
equipment,with the goal of promoting energy efficiency among commercial customers.
III. COMMERCIAL ENERGY EFFICIENCY PROGRAM
Despite initial efforts,participation in the commercial program has been limited. Several
factors have contributed to this outcome including outreach challenges and program design
limitations.
Outreach Challen
Marketing efforts have mirrored those used for residential customers, such as bill inserts and
opt-in emails. However,these channels did not effectively reach building operators and facilities
managers,the individuals most familiar with commercial equipment. Instead, communications often
reached administrative staff responsible for bill payment,missing the target audience for energy
efficiency decisions.
Pram Desi�r Limitations
The initial offering was intentionally modest to ensure cost-effectiveness and manageable
administration. Feedback from Energy Service Representatives,the Stakeholder Committee, and
customer inquiries revealed that small or"light commercial"customers—those using residential-
APPLICATION PAGE 3 OF 8

sized equipment—had few opportunities to participate. Additionally,the program lacked incentives
for water heating, further limiting its appeal.
In response,Intermountain expanded its Conservation Potential Assessment(CPA) in 2023
to include the light commercial sector, identifying 18 measures with savings potential for smaller
commercial customers. The Company also commissioned an independent process evaluation,which
recommended enhancing marketing and outreach, formalizing contractor engagement, collecting
more data at rebate approval, and expanding rebate offerings.' The Company has already taken
several steps to follow these recommendations:
• Enhance marketing and outreach: To enhance commercial outreach,the Company
dedicated a full-time energy efficiency analyst to promoting commercial energy
efficiency. This is not a new expense but a reallocation of responsibility and expense.
Commercial outreach responsibilities were removed from the Energy Services
Representatives,which was the equivalent expense of one FTE. Expenses shifted from
funding the ESR role to promote commercial energy efficiency,to funding a full-time
energy efficiency analyst dedicated solely to the commercial program.
The commercial analyst hired in February 2025 has already made strides to promote
the program with new industry partners such as Building Operators and Manager
Association(BOMA),making presentations speaking directly to building managers and
Commercial HVAC contractors at the Facility and Maintenance Expo and conducting
personal visits with mechanical contractors who are learning about the Company's
commercial energy efficiency program for the first time.
'Please see the Commercial Process Evaluation provided in Case No.INT-G-25-05,Attachment I -Supplement
APPLICATION PAGE 4 OF 8

• Formalize Contractor Engagement: The Company has developed an internal product
that will serve as a contractor portal. In January 2026,the Company plans to launch a
contractor trade ally that will allow for more robust communications with contractors,
enable customers to more easily identify contractors familiar with the energy efficiency
program, and enable contractors to submit rebates for customers, streamlining the overall
selection, implementation, and application process for customers. The portal will also
allow the Company to more easily customize the data points being collected with each
rebate, as recommended in the Commercial Process Evaluation.
• Expand the Rebate Offering: Several preparatory steps have been completed in order to
implement the recommendation to expand the commercial offering. As part of the
Commercial Process Evaluation,the Company commissioned the development of a
technical reference manual(TRM). Measures identified in the CPA to have savings
potential were provided to the evaluator for the development of the TRM and focused on
prescriptive measures that could be easily installed by customers,validated by the
Company, and cost-effectively administered by the Program.
The resulting IGC Commercial TRM' served as the basis of the commercial program
planning. Without a billing analysis to inform measure savings (and to date there has not
been enough participation for a meaningful billing analysis),the IGC TRM provides the
unit energy saving estimates,estimated useful life, incremental cost, and measure
efficiencies for each measure. All measures were tested for cost-effectiveness using the
Utility Cost Test(UCT) and the results of the cost-effectiveness testing are provided as
Exhibit No. 1. The condensing unit heater, connected thermostat, Energy Star
z Please see the Commercial TRM provided in Case No.INT-G-25-05,Attachment 1—Supplement 2
APPLICATION PAGE 5 OF 8

Combination oven, and Energy Star steamer included in the TRM were deemed to be
non-cost-effective and were not included in the proposed commercial offering discussed
in this Application. The proposed revision to Rate Schedule EE-GS included in this
application expands the Commercial rebate offering from the current 3 space heating
incentives and 3 commercial kitchen equipment incentives to 18 incentives for space
heating,water heating and commercial kitchen equipment.
• Collect more data points at the time of rebate approval: Expanding the rebate offering
will require developing a new rebate application. The Company will address more robust
data collection as a part of the revision to the rebate application.
IV. COMMERCIAL ENERGY EFFICIENCY CHARGE AND RIDER BALANCE
The Commercial Energy Efficiency Program is funded by the Energy Efficiency Charge
rider on Rate Schedule EEC-GS. Over time, the rider accumulated a significant over-collected
balance. To address this, Intermountain suspended the EEC-GS charge effective October 1, 2024,
reducing it from$0.00320 to $0.00. This action decreased the over-collected balance from
$1,034,285 in December 2024 to $716,924 by September 30, 2025.
Based on the over-collected rider balance of$716,924 as of September 30, 2025, the
Company anticipates that the proposed expanded rebate offering included in this Application
could switch to an under-collected balance within the first 12 months based on the new program's
estimated costs of$866,100, as seen on Exhibit No. 1. Intermountain will continue to monitor the
rider balance and provide updates in quarterly meetings with Commission Staf£3 Adjustments to
the EEC-GS rate will be made as needed to prevent significant over- or under-collection, ensuring
the program remains financially balanced.
3 In Order No. 36797,the Commission directed the Company"to begin quarterly meetings with Staff to monitor the
performance of its programs."
APPLICATION PAGE 6 OF 8

V. PROPOSED REVISIONS TO RATE SCHEDULE EE-GS
Based on the information provided above and the results of the cost-effectiveness testing
provided in Exhibit No. 1, the Company proposes to revise Rate Schedule EE-GS as shown in
Exhibit Nos. 2 and 3, which provide both legislative and clean copies of the proposed changes.
The Company proposes an effective date of January 1, 2026 for these proposed revisions
because Intermountain believes this timing will help to minimize customer confusion that may
result from mid-year program changes
VI. 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
consideration of this matter
VII. REQUEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Commission approve the proposed Revisions to Rate Schedule EE-GS
outlined in this application, effective January 1, 2026;
b. That this Application be heard and acted upon without hearing under modified
procedure; and
c. For such other relief as this Commission may determine just and proper
Dated: November 21, 2025.
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
APPLICATION PAGE 7 OF 8

CERTIFICATE OF SERVICE
I hereby certify that on November 21, 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:
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
/s/Maryalice Gresham
Maryalice Gresham—Regulatory Affairs Mgr
APPLICATION PAGE 8 OF 8

EXHIBIT NO. 1
CASE NO. INT-G-25-07
INTERMOUNTAIN GAS COMPANY
Commercial Program—Proposed Rebates Cost-Effectiveness Testing
(1 page)

Exhibit No. 1
Case No. INT-G-25-07
Intermountain Gas Company
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EXHIBIT NO. 2
CASE NO. INT-G-25-07
INTERMOUNTAIN GAS COMPANY
Proposed Tariff—Legislative Format
(2 pages)

I.P.U.C. Gas Tariff IDAHO PUBLIC UTILITIES COMMISSION
Rate Schedules Approved Effective
F-Irs.1049ipa4 Sheet No. 18(Page 2 of 2 Maretv 23, 2421 April ',., -, '-
Name Per ON 34941
of ut;,;t Intermountain Gas Company
Jan Noriyuki-Seoretafy
Rate Schedule EE-GS
GENERAL SERVICE ENERGY EFFICIENCY REBATE PROGRAM
(Continued)
MEASURES/INCENTIVES:
Measure Decrrir.4ier� Rebate Arv�oun
nrcaa-w-rc vc�crvrr
ENERGY STAR®
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vc-r-a-rrca
Cr nor ENERGY STAR@
-' a
Ge ifiorl
ov
ENEENERGY�RV STAR® Q�1 1��
Steame �Fil7
ie GeFtif
vc-r-a-rrccr
Boiler Reset Gantral Unit IRstalle $359
�Qini mi im Qr10/ Thermal
High_Effinionnv
('Onrtoncinry
RffirieRGY & 300 LRti�h $41. �50*13ti ih
inw
Reilor
Condensing Unit Heater 900% APvE- $-1,500
0
Measure Description Rebate Amount
Boiler Reset Control Unit Installed 1.50 Per
300kBtu/h capacity
High-Efficiency Condensing Boiler Minimum 84%thermal efficienc $6,000
> 300kBtu/h
High-Efficiency Condensing Boiler Minimum 93%AFUE $1,500
< 300kBtu/h
Storage Water Heater New ENERGY STAR Certified $3,500
Construction
Storage Water Heater Retrofit ENERGY STAR Certified $6,000
Less than 200 kBtu/hr: Minimum 0.81 UEF, or
Tankless Water Heater New minimum 85%thermal efficiency. 6 000
Construction Greater than or equal to 200 kBtu/hr: Mminimum
84%thermal efficiency.
Less than 200 kBtu/hr: Minimum 0.81 UEF, or
Tankless Water Heater Retrofit minimum 85%thermal efficiency. 8 000
Greater than or equal to 200 kBtu/hr: Mminimum
84%thermal efficiency.
Furnace 95%AFUE Minimum 95%AFUE 200
Gas Heat Pump <65kBtu > 1.2 COP for heating &> 1.0 COP for cooling 2 000
Gas Heat Pump 65- 135kBtu > 1.2 COP for heating &> 1.0 COP for cooling 6 000
Gas Heat Pump 135-240kBtu > 1.2 COP for heating &> 1.0 COP for cooling 10 000
Gas Heat Pump Water Heater > 1.2 COP for heating 150
Issued by: Intermountain Gas Company
By. l ri A. BlattRe f Michael Paryinen Title: Director— Regulatory Affairs
€ffeGtl April 1, 2021

I.P.U.C. Gas Tariff
Rate Schedules
First Sheet No. 18(Page 3 of 2
Name
of Utility Intermountain Gas Company
.Pipe Insulation Minimum 1"of insulation indoor. jLper foot
Energy Star Convection Oven ENERGY STAR Certified 150
Energy Star Dishwasher High ENERGY STAR Certified 500
Temp
Energy Star Dishwasher Low Temp ENERGY STAR Certified $1,000
Energy Star Fryer ENERGY STAR Certified 550
Energy Star Convection Griddle ENERGY STAR Certified 100
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 instructions of
the current rebate form. The Company reserves the right to verify installation prior to the payment of any
rebates.
Issued by: Intermountain Gas Company
By: L „r; A. Blattner Michael Parvinen Title: Director— Regulatory Affairs
€ffectl Aril 1 2021

EXHIBIT NO. 3
CASE NO. INT-G-25-07
INTERMOUNTAIN GAS COMPANY
Proposed Tariff—Clean Format
(1 page)

I.P.U.C. Gas Tariff
Rate Schedules
First Sheet No. 18(Page 2 of 2
Name
of Utility Intermountain Gas Company
Rate Schedule EE-GS
GENERAL SERVICE ENERGY EFFICIENCY REBATE PROGRAM
(Continued)
MEASURES/INCENTIVES:
Measure Description Rebate Amount
Boiler Reset Control Unit Installed $1.50 per
300kBtu/h capacity
High-Efficiency Condensing Boiler Minimum 84%thermal efficiency $6,000
> 300kBtu/h
High-Efficiency Condensing Boiler Minimum 93%AFUE $1,500
< 300kBtu/h
Storage Water Heater New ENERGY STAR Certified $3,500
Construction
Storage Water Heater Retrofit ENERGY STAR Certified $6,000
Less than 200 kBtu/hr: Minimum 0.81 UEF, or
Tankless Water Heater New minimum 85%thermal efficiency. $6,000
Construction Greater than or equal to 200 kBtu/hr: Mminimum
84%thermal efficiency.
Less than 200 kBtu/hr: Minimum 0.81 UEF, or
Tankless Water Heater Retrofit minimum 85%thermal efficiency. $8,000
Greater than or equal to 200 kBtu/hr: Mminimum
84%thermal efficiency.
Furnace 95%AFUE Minimum 95%AFUE $200
Gas Heat Pump <65kBtu > 1.2 COP for heating &> 1.0 COP for cooling $2,000
Gas Heat Pump 65- 135kBtu > 1.2 COP for heating &> 1.0 COP for cooling $6,000
Gas Heat Pump 135-240kBtu > 1.2 COP for heating &> 1.0 COP for cooling $10,000
Gas Heat Pump Water Heater > 1.2 COP for heating $150
Pipe Insulation Minimum 1"of insulation indoor. $2 per foot
Energy Star Convection Oven ENERGY STAR Certified $150
Energy Star Dishwasher High ENERGY STAR Certified $500
Temp
Energy Star Dishwasher Low Temp ENERGY STAR Certified $1,000
Energy Star Fryer ENERGY STAR Certified $550
Energy Star Convection Griddle ENERGY STAR Certified $100
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 instructions of
the current rebate form. The Company reserves the right to verify installation prior to the payment of any
rebates.
Issued by: Intermountain Gas Company
By: Michael Parvinen Title: Director— Regulatory Affairs