20190906Staff 1-23 to INT.pdf

DAYN HARDIE
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR A
DETERMINATION OB 2OI7.2OI8 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED.
CASE NO.INT-G-I9-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attomey General, request that Intermountain Gas Company (Intermountain
Gas; Company) provide the following documents and information as soon as possible, or by
FRIDAY, SEPTEMBER 27, 2019.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it, or any person acting on its behalf, may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses, pursuant
to Commission Rules of Procedure, must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder, and if
different, the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.0t.228.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
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I SEPTEMBER 6,2019
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In its Energy Efficiency 2018 Annual Report, the Company
stated that it will issue a Request For Proposal for an EM&V (Evaluation, Measurement, and
Verification) study. Please provide a copy of criteria the Company will use to evaluate EM&V
proposals. Energy Efficiency 2018 Annual Report at 1.
REQUEST NO. 2: What is the status of the Dunsky Energy Consultants Conservation
Potential Assessment and when does the Company expect to release it? Energy Efficiency 2018
Annual Report at23.
REQUEST NO. 3: In the Annual Report, the Company said that "further study is required
to find the right incentive" for 0.67 EF (Energy Factor) tanked water heaters. Please explain how
and when the Company will determine the correct incentive level for 0.67 EF water heaters.
Additionally, please provide the current average price of a natural gas water heater. Energy
Efficiency 2018 Annual Report at 9.
REQUEST NO. 4: When will Tariffs be updated to reflect the DOE change from using the
EF to the Uniform Energy Factor (UEF)? Energy Efficiency 2018 Annual Report at 9.
REQUEST NO. 5: How does the Company plan to re-evaluate the Fireplace Insert
Program? Energy Efficiency 2018 Annual Report at 7. What criteria will be used? Will the 80%
AFUE (Annual Fuel Utilization Efficiency) fireplace insert continue to be offered, even though it
was not available in the market during the 2018 program year? Please explain future planning for
this program and any changes to incentives and measures.
FIRST PRODUCTION REQUEST
TO INTERMOTINTAIN GAS 2 SEPTEMBER 6,2019
REQUEST NO. 6: In the Energy Efficiency 2018 Annual Report a joint meeting with
Rocky Mountain Power and HVAC contractors was described. Energy Efficiency 2018 Annual
Report at20.
a. When did the combined Intermountain Gas and Rocky Mountain Power meeting
with HVAC contractors take place?
b. Please provide meeting minutes and attendance records.
c. Has the Company pursued similar meetings with additional HVAC contractors and
energy providers in its' service territory? If yes, please provide details of such
pursuits. If not, what plans does the Company have for additional meetings?
REQUEST NO. 7: Please describe and quantify the influence the Company had in l3
incremental builders becoming Energy Star certified. Energy Efficiency 2018 Annual Report at I I
REQUEST NO. 8: In the Energy Efficiency 2018 Annual Report, the Company stated that
home energy raters mentioned a lack of credentialed HVAC contractors as a roadblock for builder
participation in the Whole Home Rebate Program. Energy Efficiency 2018 Annual Report at23.
Please describe how this concern is being addressed by both the Company and energy raters.
REQUEST NO. 9: The Company mentioned a scarcity of raters making it difficult to
certify Energy Star homes and give rebates in the service territory. Energy Efficiency 2018 Annual
Report at 12. Please provide the current number of home energy raters in Idaho and their locations.
Does the Company plan to take action to train, or incent, new home energy raters in areas with
shortages or does the Company have an alternative methodology to assess homes in these areas?
REQUEST NO. 10: Please provide an Excel workbook with formulas intact and enabled to
show how "an escalator", as described in Supplement 1, was applied to commodity costs and
explain which measures require the escalator. Energy Efficiency 2018 Annual Report Supplement
7 at2.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 3 SEPTEMBER 6, 2019
REQUEST NO. 11: Please provide a list of all expenses charged to the energy efficiency
tariff rider from October 1,2017 to December 31,2018. Please include date, vendor, amount, a
brief description of the expense, and the account to which the charges were booked. Please separate
all expenses by program so that the expenditures provided reconcile with the amounts listed in the
Company's 2018 Energy Efficiency Annual Report. Please also identify if each expense is an
incentive payment, purchased service, labor/administrative, materials and equipment, or other
expense. Please provide the requested information in Excel format with all formulas intact and
enabled.
REQUEST NO. 12: Please provide invoices for all third-party evaluators
REQUEST NO. 13: Please provide copies of all internal audit reports referencing any of
the Company's DSM expenses and processes for 2017 through2}l9, to date. If no reports were
issued, please provide the date and scope of the audit and all internal auditor workpapers.
REQUEST NO. 14: Please provide a current organizational chart by title and name
showing all MDU, Intermountain Gas, and contract employees who charge time to the energi'
efficiency tariff rider. Please include complete job descriptions, required qualifications, salary
ranges, bonus opportunities, and total compensation ranges, including benefits, for all employees
identified in this request.
REQUEST NO. 15: Is the Company requesting recovery of Wrightsoft HVAC subsidy
costs of $500? Energy Efficiency 2018 Annual Report at 7. If yes, please provide copies of
accounting records.
REQUEST NO. 16: Please provide workpapers to support the TRC (Total Resource Cost)
and UCT (Utility Cost Test) for each measure/rebate offered. Please identify what costs and
benefits were calculated in the TRC for each program.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 4 SEPTEMBER 6,2019
REQUEST NO. 17: Please provide the workpapers used to determine the Benefits, Costs,
and Benefit/Cost ratios in the table titled "Program Cost-Effectiveness" on page 6 of the Company's
Energy Efficiency 2018 Annual Report. Please provide workpapers in Excel format with formulas
intact and enabled.
REQUEST NO. 18: Please provide the workpapers used to determine the Therm Savings,
UCT, and TRC ratios in the table titled "Space Heating Program Results" on page 6 of the
Company's Energy Efficiency 2018 Annual Report. Please provide workpapers in Excel format
with formulas intact and enabled.
REQUEST NO. 19: Were the Therm savings used to determine the values in the table
titled "Space Heating Program Results" on page 6 of the Company's Energy Efficiency 2018
Annual Report adjusted for the effects of weather? If so, please provide workpapers showing how
this was done. If not, please explain why this wasn't done.
REQUEST NO. 20: Please provide the workpapers used to determine the Therm Savings,
UCT, and TRC ratios for the 70%FE (Fireplace Efficiency) Natural Gas Hearth (Fireplace)" on
page 8 of the Company's Energy Efficiency 2018 Annual Report. Please provide workpapers in
Excel format with formulas intact and enabled.
REQUEST NO. 21: Please provide the workpapers used to determine the Therm Savings,
UCT, and TRC ratios for table titled "Water Heater Program Results" on page 9 of the Company's
Energy Efficiency 2018 Annual Report. Please provide workpapers in Excel format with formulas
intact and enabled.
REQUEST NO. 22: Please provide workpapers showing how the Annual Therm Savings,
UCT, and TRC ratios for the titled "Whole Home Program Results" on page l0 of the Company's
Energy Effrciency 2018 Annual Report were calculated. Please provide workpapers in Excel
format with formulas intact and enabled.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 5 SEPTEMBER 6,2019
REQUEST NO. 23: For each measure included in the Whole Home Program, please
provide workpapers showing how costs and savings for each measure were calculated. Please
provide workpapers in Excel format with formulas intact and enabled.
DATED at Boise, Idaho, this 6{L day of September 2019.
Dayn Hardie
Deputy Attomey General
i: umisc:prodreq/intg l9.4dhkkckblmm prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 6 SEPTEMBER 6,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6.h DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, N CASE
NO. INT-G-19-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOI.]NTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
kendrah@ eivenspursley. com
CERTIFICATE OF SERVICE