20260319Reply Comments.pdf

RECEIVED
March 19, 2026
Preston N. Carter, ISB No. 8462 IDAHO PUBLIC
Megann E. Meier, ISB No. 11948 UTILITIES COMMISSION
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
19388651 [14168.181
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 REPLY COMMENTS
SCHEDULE EE-GS —GENERAL SERVICE
ENERGY EFFICIENCY REBATE
PROGRAM
Intermountain Gas Company, ("Intermountain,""Applicant," or"Company") submits the
following comments in reply to the comments filed by the Idaho Public Utilities Commission
Staff("Staff').
Introduction
The Company appreciates Staff s review of the proposed energy efficiency commercial
program changes, and Staff s continued focus on ensuring program completeness and
cost-effectiveness. The Company also appreciates Staff s acknowledgment of the steps taken to
improve the commercial program, including more focused staffing, expanded outreach efforts,
and planned increases in engagement with trade allies and contractors.
While the Company generally acknowledges and supports Staff s intent of improving the
commercial energy efficiency program, the Company believes certain conclusions in Staffs
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comments merit clarification and response to ensure the record accurately reflects the Company's
understanding and actions.
In addition, while the Company is willing to reconsider certain aspects of the program and
re-file its application to revise its Rate Schedule EE-GS, Intermountain requests clarity from the
Idaho Public Utilities Commission("Commission") on certain aspects of the program to ensure
the re-filing addresses the issues raised by Staff in this proceeding.
Reply comments
Although the Company values Staffs input, aspects of the review process have resulted in
uncertainty. During a meeting convened to clarify elements of the proposed program, as well as in
Production Request No. 12—which requested a comparison of commercial and residential
measures—Staff raised questions regarding commercial therm savings estimates relative to those
associated with similar residential measures. The Company understood that Staffs inquiries were
motivated by a desire to attain internal consistency between residential and commercial measures.
The Company's understanding formed the basis of the information provided during this
proceeding.
However,based on Staffs Comments in this case, it seems that Staffs concerns were not
with consistency across Intermountain's residential and commercial programs, but instead with
consistency between Intermountain's savings estimates and savings estimates used by peer
utilities. Had the concern been framed earlier as a general question regarding whether certain
commercial savings estimates may be high, or as an interest in peer-utility comparisons, the
Company could have engaged on that topic more directly during development of the application.
Instead, the Company reasonably understood Staffs requests to be focused on comparisons
between residential and commercial measures within Intermountain's own programs and
responded accordingly.
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Staff s position that certain comparisons—such as comparing Intermountain's and
Avista's programs—can be used to evaluate the Company's offerings, is important input. The
Company believes this is the first time Avista's program has been used for comparison purposes.
If comparison to Avista's program will be a consistent method used by Staff and the Commission
in energy-efficiency casesor, at a minimum, in evaluating a re-filing of this case—the Company
can attempt to include this comparison as part of preparing the case,but will need to understand
the relevant detail prior to filing. The Company believes this can be part of pre-filing discussions
proposed in these comments. Intermountain will also engage the Energy Efficiency Stakeholder
Committee ("EESC") each quarter to improve communication with interested parties and alleviate
potential communication issues and program concerns.
Staff appropriately recognizes that forecasting participation and rebate activity involves
uncertainty and has noted the Company's historical tendency to over-forecast rebate counts in
prior filings. Coincidentally, Staff relied on the Company's forecasts in this case to suggest
potential non-compliance with Order No. 36337. However, Order No. 36337 ordered the
Company to file a case before the earlier of any program supported by the Commercial Energy
Efficiency Charge ("EEC-GS")becomes underfunded or the end of 2026. If the Company's
proposal was approved, Intermountain's intent was to subsequently file and increase the EEC-GS
rider. Without the clarity and approval of its application, the Company was unable to request an
increase to the rider. For context, the commercial rider balance remains $624,907.77
over-collected as of January 31, 2026, and any projected reduction in the balance is largely
dependent on the proposed program changes. Forecasts, and the uncertainty associated with
forecasts, appear to be unavoidable in this context, and the basis for Staff s forecasted
noncompliance is not clear.
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Notwithstanding these issues, the Company made a good-faith effort to develop
reasonable, supportable, and transparent savings estimates for the commercial program. For this
reason, the Company relied on additional credible sources to estimate savings for commercial
offerings. To support a more robust commercial rebate portfolio—consistent with savings
potential identified in the conservation potential assessment—the Company commissioned an
industry technical expert to develop a technical reference manual establishing appropriate savings
assumptions.
The Company is encouraged that Staff"believes there may be potential to develop a cost-
effective portfolio after adjusting the rebate levels and saving estimates for water heating," Staff
Comments at 13, and supports Staff s recommendation to refile following the Commission ruling
in this case. As the Company moves toward a revised filing, it intends to continue collaborating
with Staff. As part of that process, the Company anticipates sharing Staff s comments with its
technical consultant to confirm the appropriateness of the current technical reference manual
savings estimates for water heating measures and, if necessary, to develop revised estimates
responsive to Staffs concerns. The Company is also open to presenting any revised savings
estimates to Staff in advance of refiling, should Staff find that approach helpful.
Once new savings estimates are established and discussed with Staff, the Company
intends to reevaluate all proposed commercial measures for cost-effectiveness based on the Utility
Cost Test. Consistent with Staff comments in this and prior proceedings, the Company further
understands that incentive levels should not exceed 100 percent of incremental cost and that
measures must be cost-effective, as reflected in a Utility Cost Test greater than 1.0, to determine
whether a measure should proceed. Such a discussion could also provide clarity regarding
whether cost-effectiveness is being evaluated at the measure level or the program level.
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Conclusion
For these reasons, if the Commission does not approve the Application as filed, the
Company requests that the Commission issue an order that: 1) the Company and Staff hold one or
more workshops to discuss proposed changes to the technical reference manual used to evaluate
the Company's program, potential revised savings estimates for the Company's offerings related
to water heaters, and any related topics; and 2) the Company re-file an application to revise
Schedule EE-GS that takes into account the information exchanged during the workshop.
Dated: March 19, 2026
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
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CERTIFICATE OF SERVICE
I hereby certify that on March 19, 2026, 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 [e-mail]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Jeff Loll [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
Is/Preston N. Carter
Preston N. Carter
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