20170208CAPAI to INT 1-4.docx

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID 83702
[e-mail]
208-384-1299
ISB No. 3472
Attorney for Community Action
Partnership Association of Idaho
BEFORE THE IDAHO PUBLIC UTILITES COMMISSIONIN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S APPLICATION TO CHANGE ITS RATES AND CHARGES FOR NATURAL GAS SERVICE
)
)
)
)
)
)
)
Case No. INT-G-16-02
CAPAI’S RESPONSES TO
INTERMOUNTAIN GAS’
FIRST PRODUCTION REQUESTSThe Community Action Partnership Association of Idaho (CAPAI), by and through its attorney of record Brad M. Purdy and pursuant to the Rules of Procedure of the Idaho Public Utilities Commission (“Commission”), hereby hereby submits its responses to Intermountain Gas Company’s First Production Requests to CAPAI.
How many low income natural gas homes are currently being served by agencies delivering weatherization services in Intermountain’s service area?RESPONSE: During January 1 through December 31, 2016, 206 low-income homes where the primary heat source is natural gas and whose occupants had accounts with Intermountain Gas received weatherization services. See Attachment 1- 2016 Weatherized Units for the source data.
What is average total cost of natural gas weatherization (excluding electric measures) in homes served by CAPAI’s member agencies? Please provide all workpapers or studies relied on in answering this question.RESPONSE: The average total of natural gas weatherization provided by CAPAI’s member agencies, excluding electric measures, is $7,455. See Attachment 1- 2016 Weatherized units for the source data.
Please describe the characteristics of a “well-tailored” energy conservation program as described by witness Zamora on page seven, lines three through six.RESPONSE: The characteristics of a well-tailored energy conservation program include ease of implementation for CAPAI’s member agencies and the Company, the use of experience in existing energy conservation program design to inform the design of a natural gas energy conservation program, a focus on measures which will provide the highest savings, the ability to leverage federal funding sources on a single unit, clear requirements for reimbursement of expenses, clear documentation of what measures were provided on a unit and engagement of stakeholders, including CAPAI’s member agencies in program design.
Reference page 6, lines 10-12, Zamora’s testimony, that there is “lack of low income data” for the Company, please provide examples of instances where natural gas utilities have collected low income information, and the provisions put in place to protect both the Company and its customers in regards to this data.RESPONSE: CAPAI does not have information regarding examples of instances where natural gas utilities have collected low income information nor the provisions put in place to protect the Company and its customers in regards to this data.
DATED this 7th day of February, 2017.
Respectfully submitted,
___________/S/________________________
Brad M. Purdy
Attorney for CAPAI