20190927INT to Staff 1-23.pdf

GtvENS PunsLEY,,*
Attorneys and Counselors at Law
601 W. Bonnock Slreel
PO Box2720
Boise, lD 83701
Telephone: 208-388-l 200
Focsimile: 208-388-l 300
M.giYenspursley.com
Preslon N. Corter
[e-mail]
208-388-1222
VIA HAND DELIVERY
Diane Hanian
Idaho Public Utilities Commission
11331W. ChindenBlvd.
Bldg. 8 Suite 201-A
Boise,ID 83713
September 27,2019
Gory G. Allen
Chorlie S- Boser
Chrislopher J. Beeson
Joson J. Blokley
Clint R. Bolinder
Jeff W. Bower
Preslon N. Corler
Jeremy C. Chou
Michoel C. Creomer
Amber N. Dino
Brodley J. Dixon
Thomos E. Dvorok
Deboro Kristensen Groshom
Donold Z. Groy
Brion J. Holleron
Kersli H. Kennedy
Neol A. Koskello
Michoel P. Lowrence
Fronklin G. Lee
Dovid R. Lombordi
Kimberly D. Moloney
Kennelh R. McClure
Kelly Greene McConnell
Alex P. Mcloughlin
Melodie A. McQuode
Chrislopher H. Meyer
L. Edword Miller
Judson B. Montgomery
Deboroh E. Nelson
W. Hugh O'Riordon, LL.M.
Rondoll A. Petermon
Jock w. Relf
Michoel O. Roe
Jomie Coplon Smilh
Jeffrey A. Wor
Robert B. White
Williom C. Cole {Of Counsel)
Kennelh L. Pursley (1940-2015)
Jomes A. Mcclure (1924-2011)
Roymond D. Givens (1917-2008)
a':r:
N
..e(-/) -ntrl N*U ITINIOrm
1r<*m q)
(!,-)
Confidential Responsive Documents - Requests Nos. ll,14 & 15 ' "
Case No.: INT-G-I9-04
Dear Ms. Hanian:
This firm represents Intermountain Gas Company ("Intermountain Gas"). Enclosed for
filing is a CD containing documents in response to Requests Nos. 1 l, 14, and 15 of the Commission
StafPs First Production Request in the above-referenced case. The information contained in these
documents are confidential, proprietary, and trade secret information protected from public
inspections, examination, or copying under Idaho Code sectionsT4-106,107, and 48-801.
The enclosed CD contains documents responsive to Requests Nos. ll,14 and 15 and is
marked "Confidential" per Commission Rules 67,233,7, and the Protective Agreement entered
into between Intermountain Gas and Commission Staff.
Thank you for maintaining the confidentiality of this information. If you have questions,
please do not hesitate to contact me.
Sincerely,
,p
PNC/Klh
Enclosure
I 4828872_l.docx [ 141 68.6]
Re:
Preston N. Carter
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@ givenspursley. com
14828668 2.docx [4168.6]
Afforneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPAIIY
FOR A DETERMINATION OF 2017.2018
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
)
)
)
)
)
)
)
CASE NO.INT.G-I9-04
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
Intermountain Gas Company, in response to the First Production Request of the
Commission Staff to Intermountain Gas Company dated September 6, 2019, submits the
following information :
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 1
ftrcEtv[0
i*i9 SIP 27 pH t: SS
.t r\, . .-i i,,r:;.; , ,"i I rili".l,r 1, 'i;:;liir:il
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.
RESPONSE TO REQUEST NO. 1:
As mentioned in the Annual Report,lntermountain is currently developing an EM&V
program. As the program is created, Intermountain intends to meet with its stakeholder
group to discuss best practices for EM&V and to make sure all the necessary elements are
included. The process of outside consultant selection would be one of the topics thatwould be
discussed with the Company's stakeholder group.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd. Boise.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 2
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.
RESPONSE TO REQUEST NO. 2:
DunslE Energy Consultants presented draft results of the study at the May 20, 2019
stakeholder meeting in Twin Falls. The Conservation Potential Assessment is nearly complete
and will befiled with Intermountain's 2019 Integrated Resource Plon.
Record Lori Blattner- 208-377 -6015
Sponsor/Preparer Kathv Wold. 208-377-6128
Location: 555 S Cole Rd, Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 3
Lf ^1.1o.'
REQUEST NO.3: tn the Annual Report, the Company said that "further study is
required to find the right incentive" for 0.61 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.
RESPONSE TO REQUEST NO.3:
The Company will use the results of the conservation potential assessment to guide the
determination of the proper incentive level for the .67 EF water heater rebate and will also
consider stakeholderfeedbackfrom a planned October meeting. An October 2019 filing is
planned to revise this incentive, with a January l, 2020 effective date.
Based on a sample of retail outlets by Intermountain staff, the average cost of a water
heater which would qualrfy fu Intermountain's program (.67 EF or higher) is curuently $945.
This price excludes labor and ony additional parts necessary to install the water heater.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold, 817I 6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 4
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.
RESPONSE TO REQUEST NO. 4:
The tariffupdate to change to the water heater fficiency rating will be presented at the
stakeholder meeting in October and the Company plans tofilefor tariff changes in October, with
a proposed January 1, 2020 effective date.
Record Holder: Lori Blattner. 208-377-6015
SponsorlPreparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 5
REQUEST NO. 5: How does the Company plan to re-evaluate the Fireplace lnsert
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.
RESPONSE TO REQUEST NO. 5:
It is the Company's intent to discontinue the 80% AFUE fireplace insert incentive due to
lack of availability in the marketplace. During program design, the 80% AFUEfireplace was
considered emerging technology, and unfortunately never "emerged." One explanationfor lack
of availability and adoption is that the 80% AFUE fireploce is a condensing unit and requires
venting to achieve this level of efficiency. This requirement is a barrier to adoption as the
location of thefireplace in the home often cannot accommodate a condensate line.
Future planning and any changes for the measure offering will be guided by the findings
of the conservation potential assessment. The plan to discontinue the 80% AFUE fireplace
rebate and the intent to continue to offer a singlefireplace rebate offering (70% FE), will be
presented at the October stakeholder meetingfor consideration. The Company plans tofilefor
approval in October with a planned ffictive date of January l, 2020.
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer:Kathy Wold. 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 6
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?
RESPONSE TO REQUEST NO. 6:
a) The meeting took place on July I I , 20 I I at Johnstone Supply in ldaho Falls.
Johnstone Supply, an HVAC wholesale distributor, donated the use of their
conference room for the meeting. The Company was invited to present an overview of
the energt fficiency program, and lunch was provided by Clear Result. Clear Result
is the energy efficiency program agentfor Roclqt Mountain Power (RMP).
b) After introductions, the Company presented a history of the energy fficiency
program including development and program launch and provided a detailed
overview of program offirings. Clear Result (as agentfor RMP), presented an
overview of their respective energy fficiency program, specifically highlighting the
unique opportunity for customers to maximize energy savings and earn both the
Intermountain high fficiencyfurnoce rebate in conjunctionwith the RMP rebatefor
electronically commutated motors (ECM) forfurnoces. An fficial attendance list was
not collected. However, there were approximately 6 HVAC contractors in attendance.
The meeting lastedfor approximately one hour.
c) The unique opportunity to couple two rebate offerings ftigh fficiencyfurnace with
ECM motor) has since expired as the new ECM motor standard for furnaces went
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 7
into effect in July 2019. The Company continues to seek out opportunities and
partnerships, such as this, to maximize customer benefit and energlt savings.
Record Holder:Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 8
REQUEST NO. 7: Please describe and quantify the influence the Company had in 13
incremental builders becoming Energy Star certified. Energy Efficiency 2018 Annual Report at
11.
RESPONSE TO REQUEST NO. 7:
On May 23, 2019, the Company received the ENERGY STAR Certified Home Market
Leader Awardfrom ENERGY STARfor "outstanding commitment to energy fficient new homes
andfor contributing 619 ENERGY STAR certified homes in 2018" (see thefile labeled "PR
I_7").When Intermountain's Energl Efficiency program began in late 2017, therewere 2
builders in Intermountain's service territory listed on the Energy Star website as having their
homes Energt Star certified. Through the end of 2018, Intermountain saw l3 additional builders
submit applications for rebates.
The Company's Wole Home measure requires the home to be ENERGY STAR certified
with a HERS (Home Energy Rating Score) score of 75 or better. The lower the HERS score, the
more energy efficient the home. Taking climate zone into consideration, a home moy earn
ENERGY STAR certification with a HERS score of 80-85, for zones 5 and 6. Intermountain's
energy ffictency program incents builders to exceed minimum allowable fficiency requirements
by ENERGY STAR by requiring a HERS of 75.
The Company utilized existing memberships with the Building Contractor Associations
(BCA) throughout the service teruitory, starting with personal meetings with the executive
director of the statewide organization, Idaho Building Contractor Association, and meetings
with both local Treasure Valley associations (Building Contractor Association of Southwest
Idaho and Snake River Valley Building Contractor Association). These meetings allowed the
Company to better understand the potential outreach opportunities within tlte associations. To
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAIF, Page 9
"test the waters" the Company explored opportunities with the two Treasure Valley
associations, with the hope of replicating success and taking lessons learned across the service
territory to other associotions.
While a number of outreach approaches were tested, from hosting information tables to
presentations at general membership meetings, three particular BCA events routinely had the
highest builder attendance and provided the most opportunity to influence builders: golf
tournaments, builders showcase, and parade of homes.
The Company started builder outreach efforts by sponsoring general membership lunches
as the guest speaker or hosting information tables at these meetings. Wile it was beneficial to
raise awareness about the energy fficiency program with BCA members at large, builder
attendance at these meetings was typically very low. It was recommended that the Company
reach builders at the highest attended builder events: golf tournaments. The Company sponsored
a hole at two separate golf tournaments (in Boise and ldaho Falls) which provided brief, but
valuable time to explain the program to key decision makers: the builder.
The builder showcase is a mandatory eventfor builders who want to participate in the
parade of homes. It is an opportunity for vendors to promote products to parade builders
(everythingfrom granite to garage doors), and builders attend the event to explore products for
their home while securing their place in the parade of homes. The Company hosted a table at
builders showcase events to raise awareness about the energy fficiency program. To creote
additional interest in building an ENERGY STAR home in the parade of homes, the Company
offered to provide builders with ENERGY STAR and HERS marketing materials and additional
parade home promotionfor any ENERGY STAR certified parade home. The Company
participated in two builder showcase events (Boise ond Nampa).
RISPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 10
"Wat is an ENERGY STAR home? " was one of the mostfrequent questions asked by
builders and home buyers alike. In order to provide an example of an ENERGY STAR home, the
Company partneredwith an early adopter of the Intermountain Wole Home rebate, an
ENERGY STAR builder who was also a member of the Southwest ldaho BCA and building a
Spring 2018 parade home. To highlight the rebate program, educate about home energy
fficiency and assist in marketing the energy fficient attributes of the home, the Company and
the builder launched an ENERGY STAR pilot program. The builder allowed the Company to host
an information booth at the parade home to better explain and highlight the benefits of an
ENERGY STAR home andfocused education on the ENERGY STAR "blue label"; one of the
most recognized consumer brands, and the mark of home certification. The Company conducted
an ENERGY STAR certified home Facebook campaign simultaneously with the parade of home
dates and encouraged the community to visit an ENERGY STAR home. From this pilot, the
Intermountain parade promotion was born. The ENERGY STAR parade of homes pilot occurred
during the Spring 2018 BCA Southwest ldaho (BCASWI) Parade of Homes. In the Fall of 2018,
the Compony reached out to all BCASWI parade builders sending 23 recruitment letters offering
ENERGY STAR parade promotions and secured 2 ENERGY STAR homes in the parade of
homes. As the Company has fostered relationships with BCA's throughout its service territory,
this process has been replicated with all BCA's in the teruitory. For the 2018 program year, the
ENERGY STAR parade of homes promotion was offered to approximately 60 builders
throughout the service teruitory.
In conjunction with porticipating in the parade of homes, the Company olso visited
parade homes and reviewed parade home magazines. Visiting the parade homes allowed the
Company to informally survey the types of equipment and fficiency of equipment being installed
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAIF, Page I I
in these show homes. Personal visits to parade homes proved especially beneficial when the
builder was present, and the Company was able to engoge in a conversation about the home with
the builder. Finally, if the home was advertised as HERS scored, the Company reached out
directly to the builder to promote the rebate program, encouraging the builder to take the next
step in home energy fficiency by becoming ENERGY STAR certified. Wile personal visits to
parade homes are often beneficial and can provide direct interactions with key decision makers,
this type of personal outreach is limited by available manpowen For instance, the parade of
homes of Southwest ldaho alone consists of 40 homes and overlaps with the occuruence of the
Magic Valley parade of homes. Internal conversations about outreach by the Company revealed
a duplication of outreach efforts. Intermountain's Energy Services Representatives (ESR) also
visit parade homes to deliver complimentary welcome mats to builders. By partnering with the
ESRs, the Company is able to fficiently leverage outreoch efforts, not just in parade of homes
builder targeted outreaclt, but in their overall day+o-day interactions. ESRs routinely work with
developers, builders, HVAC contractors, residential and commercial customers. The benefit of
adding energy fficiency to the suite of services ESRs are able to offer when talking to these
customers is two-fold: it provides customers an additional, green, fficient option, and it
provides a "one-stop-shop" approach where customers can simultaneously learn about
opportunities to choose high fficient options upon initiating gas service. Rather than try to
broaden outreach efforts by hiring tvvo energy fficiency analysts, the Company instead
underwrites a portion of eight ESR positions which are located throughout the service territory.
By taking a "divide and conquer" approoch, the program now underwrites 250% of each ESR,
who in turn dedicotes 25o% of their time to energy fficiency outreach and education-
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 12
Record Holder: Lori 208-377-60rs
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd. Boise. ID 837!7
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 13
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.
RESPONSE TO REQUEST NO. 8:
For a home to be ENERGY STAR certified, several key design taslcs must be completed by
an HVAC designer. These requirements are contained in the HVAC Design report, which must
be submitted to the home rater in order to certify an ENERGY STAR home, and per the ENERGY
STAR Requirements and Resources for HVAC Designers, "includes designing a whole-house
ventilation system, calculating room-by-room heating and cooling loads, and selecting heating
and cooling equipment using those loads." This ENERGY STAR requirement is essentially to
ensure proper sizing of HVAC equipment, one of the mainfactors that can impact HVAC
fficiency.
ENERGY STAR has communicated that the intent of this requirement is to address proper
HVAC design and sizing, particularly in places where there were no code requirements
addressing such. Idaho has historically been one of those places lacking code requirements. The
Idaho Division of Building Salbty (DBS) only recently (January 2019 ffictive date) began
requiring a Manual J (HVAC contractors use the Manual J calculation to determine the heating
and cooling load of a home, and recommend the capacity of HVAC equipment needed) to be
submitted as part of the plan reviewfor new residential construction to insure proper sizing of
HI/AC equipment. With this new requirement, the ENERGY STAR credentialed contractor
requirement should be more attoinablefor contractors because the lcnowledge and concepts now
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 14
requiredfor Manual J to meet the ldaho new construction plan review are the samefor ENERGY
STAR credentialing.
Despite the new plan review requirements by DBS, use of an ENERGY STAR
credentialed HVAC contractor is still requiredfor ENERGY STAR home certffication. To
become q credentialed ENERGY STAR HVAC contractor, contractors must submit an
application with license, proof of insurance, and refrigerant card, then take a course and pass an
exam. Application, coltrse instruction and exam can all be completed on-line. The course and
exam are estimated to require approximately 2 hours. First time credentialing is approximotely
5900, with a $600 annual renewalfee (no additional course time or exams are requiredfor
renewal). The Company has taken steps to help alleviate potential builder roadblocl<s to building
ENERGY STAR certified homes due to lack of ENERGY STAR credentialed HVAC contractors.
The Company has communicated to EPA, through appropriate ENERGY STAR representatives,
that while well intentioned, the HVAC contractor credentialing requirement is creating a
potential roadblock to ENERGY STAR certified home building. In a more proactive approach,
the Company is offering a $300 coursefee reimbursement to help ffiet HVAC contractor
credentialing costs. Contractors will be reimbursed the $300 upon becoming credentialed. The
course subsidy was first promoted through a postcard mailer sent in April 2019 and an email
blast in July 2019. Promotion of this opportunity, and the postcard itself, has been shared with
Intermountain ESRs and home roters to provide to HVAC contractors they may encounter. The
course subsidy will be offered through December 31, 2019. Please see thefile labeled "PR l_8."
Record Holder: Lori 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAIF, Page 15
Location: 555 S Cole Rd. Boise. ID 83707
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?
RESPONSE TO REQUEST NO. 9:
Currently, the Company does not have plans to train or incent new home energl raters.
The strateglt to incent energy efficient home building has been to raise awareness and educate
consumers and builders about home energy fficiency, and by so doing, create a market pull for
home energy raters. Rather than employing an "rf you build it, they will come" approach, the
Company is focusing on education and marketing of the high fficient attributes of homes and
educating consumers so they askfor high fficient homes from builders. This will in turn lead
builders to build high efficient homes and create the demandfor home raters.
Intermountain's strategy appears to be working. For example, one of the existing home
raters has added a certified HERS rater and has also become a HERS Rating Field Inspector.
Another rating company has added one HERS rater and a halftime administrative position.
Three raters, in the West, East and Central regions of the Company's service territory are
willing to travel to serve builders in other regions.
Currently, the Company does not have an alternative methodology to a,s,se,s,s homes in
areas lacking home raters. The benefit of basing the Intermountain Whole Home rebate
requirement on ENERGY STAR certification and HERS scoring allows the Company to leverage
two important factors to the success of the program: brand recognition and quality assurance.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 16
ENERGY STAR is one of the most powerful consumer brands, it is recognized by 87% of
consltmers, and 90% of consumers say it in/luences their purchasing decisions. Thefamiliar blue
label with the big message conveys to home buyers, "peace of mind, proven value and enduring
quality." Likewise, HERS is a nationally recognized systemfor inspecting and calculating a
home's energl performance and is considered tlte "gold standardfor home energl fficiency."
Part of this gold standard recognition is due to the robust set of policy and procedures in place
to ensure quality standards. Thefollowing is from the Residential Energt Services Network
@ESNED website :
RATERS
Learn About HERSE I Blog I
PROVIDERS BUILDERS
RESNET created and maintains
. The HERS lndex to allow for easy comparison of energy performance of homes
. The HERS H20 rating to compare indoor and outdoor water usage of homes
. National training and certification and quality assurance standards for Home Energy Raters
. Two American National Standards lnstitute (ANSI) Standards supporting energy and water
efficiency in homes
. Four Slandard Development Committees
RESNET's standards are utilized in a variety of applications such as: verification of
energ)l savings for energ/ fficient mortgages, code compliance by the International Energl,t
Conservation Code, quality ossuronce oversight of home energl ratings (HERS), and
verification of a home's energy performance in the EPA's ENERGY STAR homes program. The
RESNET website provides a detailed overvtew of the procedures employedfor quality assuronce
within the rating industry :
RESNEI
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 77
WHO WE ARE
. Each Rating Provider must employ a certified Quality Assurance Designee
. The Quality Assurance Designee must independently verify internal consistency of a minimum '10%
of all building input ftles
. The Quality Assurance Designee must independently freld verify the accuracy of a minimum of 1"/o ot
each certifred Raters' homes
. RESNET monitors the Rating Providers compliance with quality assurance requirements through
annual quality assurance report submissions
. RESNET Staff also does enhanced quality assurance monitoring with 507" of all rating providers
each year through online reviews and in-field site visits
. Tracking QA reviews in realtime in the RESNET Registry
Unlike custom, or user defined programs, ENERGY STAR certified homes and HERS
scored homes are required to be submitted to a national, publicly available database,
automatically making these homes subject to a detailed quality assurance process. Additionally,
these certifications are based on raters trained through a rigorous certification process.
Adopting the established and time-tested energl saving standards of ENERGY STAR and HERS
into the Company's program design and utilizing the oversight and quality control provided by
RESNET, allows the Company to wisely use resources for program implementation and quality
assurqnce of energy savings.
Record Holder:Lori Blattner. 208-377 -6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location:555 S Cole Rd. B ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 18
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 I at2.
RESPONSE TO REQUEST NO. 10:
Please see thefile labeled "PR l_10 (a)." The escalator applied to commodity costs can
be seen on the tab labeled "Avoided Nominal Cost by Year", beginning in cell D4l. The
Company's priceforecastfor the natural gas commodity only went through 2036. After20j6,
Intermountain assumed prices would continue to grow at the rate they grew between 2035 and
2036. This escalator, represented by the percentage change in commodity costs from the
previous two years, was applied to the years 2037 through 2048.
An inflation escalator of 2% based on the Consumer Price Index was used to escalate
Distribution System Costs, Variable Transportation Costs and Fixed Transportation Costs. The
escalation of these costs can also be seen on the tab labeled "Avoided Nominal Cost by Year".
After filing its Energlt Eficiency 20I8 Annual Report, the Company discovered a minor
error in its avotded cost model. This eruor has been coruected and is provided as "PR I _10
(b)," whichwill be included in the Company's Integrated Resource Plan. Thefile labeled "PR
1_10 (a)" was used in the preparation of the Annual Report.
Record Holder: Lori Bl 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location:555 S Cole Rd.ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 19
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.
RESPONSE TO REQUEST NO. 11:
Please see the confidential file labeled "PRl_l I " on the attached CD marked
"Confidential - Trode Secrets" .fo, o list of all program expenses. This file includes a summary
tab of all progrom accounts and expenses, with additional occount detail on eachfollowing tab.
Each line item within each tab includes the date, vendor, amount, a brief description of the
expense, and the account to which the charges were booked.
Wile preparing the annual report, the Companyfound that several Wole Home
measure rebates, totaling $52,800, were incorrectly coded in the general ledger as rebates for
the .91 EF tankless woter heaters measure. This adjustment is noted on the "Summary" tab and
in the adjustment column of the "Acct 5731" tab.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold- 2Q8 377 -6128
Location: 555 S Cole Rd, Boise, lD 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 20
REQUEST NO. 12: Please provide invoices for all third-party evaluators.
RESPONSE TO REQUEST NO. 12:
No third-party evaluators have been employed.
Record Holder: Lori B 208-377-60t5
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd,ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page2l
REQUEST NO. 13: Please provide copies of all intemal 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.
RESPONSE TO REQUEST NO. 13:
No internal audits of the Company's DSM expenses and processes have been completed.
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer:Ted Dedden, 208-377-6149
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 22
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 energy
efficiency tariff rider. Please include complete job descriptions, required qualifications, salary
ranges, bonus opporfunities, and total compensation ranges, including benefits, for all employees
identified in this request.
RESPONSE TO REQUEST NO. 14:
Please see tlte confidentialfile labeled "PR l_14" on the attached CD marked
"Confidential - Trade Secrets" for the requested information.
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer:Linda Murray. 208-37 7 -6055
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAI'F, Page 23
Location: 555 S Cole Rd. Boise. ID 83707
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.
RESPONSE TO REQUEST NO. 15:
Yes, the Company is requesting recovery of the Wrightsoft HVAC course subsidy
expenses of $500. As mentioned in Response No. 8, heat load calculation and proper selection of
equipment for the calculation, also lvtown as Manual J, is essential to home energy efficiency. As
of January 2019, the ldaho Division of Building Safety now requires a Manual J be submittedfor
the plan review for all new residential buildings. In order to assist contractors in meeting this
new requirement, DBS aruangedfor Wrightsoft, a soffi,vare provider that calculates Manual J, to
host an instruction course in ldaho.
In a shared mission to help contractors better understand the procedure and importance
of heat load calculation and equipment sizing in HVAC energy fficiency, the Company offered a
Wrigh*oft course subsidyfor contractors in the Intermountain service territory (determined by
zip code). One of the primaryfactors in ensuring equipment achieves its energy efficiency rating
is making sure it is sized cotectly. The Wrightsoft course helps train HI/AC contractors on
correctly sizing thefurnacefor a home. This training should help equtpment rebated by
Intermountain's EE Program achieve the labeled fficiency roting.
The course was conducted by Wrightsoft, and took place on September l0 and I l, 2018
in ldaho Folls. Ten contractors qualifiedfor the subsidy and completed the Wrightsoft course.
Please see the confidential files labeled "PR I _l5-l " and "PR I _l5-2 " on the attached CD
marked "Confidential - Trade Secrets. "
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 24
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold. 208-377-6128
Location: 555 S Cplc&L rD 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 25
REQUEST NO. 16: Please provide workpapers to support the TRC (Total Resource
Cost) and UCT (Utility Cost Test) for each measurehebate offered. Please identiff what costs
and benefits were calculated in the TRC for each program.
RESPONSE TO REQUEST NO. 16:
Please see the tab labeled "Benefit Costs" in thefile labeled "PR l_16-23 (o)" tofind
the requested information. The TRC benefit to cost ratio for each measure/rebate offered can be
found in column (g), rows 29 through 35. The UCT benefit to cost ratio for each measure/rebate
offered can befound in column (d), rows 29 through 35. Since the Company has only one
program at this time, all program costs were included in the calculations. The cost of rebates is
attributed to each measure/rebate to which they are associated. All other costs were allocated
according to the percentage of rebates issuedfor each measure/rebate. The benefits considered
were the avoided costs of the measure multiplied by therm savings. TRC and UCT therm savings
for each meosure/rebate can befound in columns (e) and (fl, rows l1 through 17.
As previously stated in Request No.10, the avoided cost model was updated to correct a
minor calculation error. Consequently, the Company updated the benefit-cost anolysis in thefile
labeled " PR I _1 6-2 3 (b). " All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer : Kathy Wold, 208-377-6128
Location:555 S Cole Rd.ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 26
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 Effrciency 2018 Annual Report. Please provide workpapers in Excel format
with formulas intact and enabled.
RESPONSE TO REQUEST NO. 17:
Please see the tab labeled "Benefit Costs" in thefile labeled "PR l_16-23 (q)" tofind
the requested information. The benefits used in the calculation of the TRC benefit to cost ratio
are the avoided costs multiplied by therm savings. The costs used are the incremental costs,
program delivery & administration, and total rebates cost. The TRC benefit to cost ratio can be
found in column (g), row j6.
The benefits used in the calculation of the UCT benefit to cost ratio are the avoided costs
multiplied by therm savings. The costs used are the program delivery & administration and total
rebates cost. The UCT benefit to cost ratio can befound in column (d), row 36.
As previously stated in Request No.l0, the avoided cost model was updated to coruect a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in thefile
labeled "PR I _l6-23 (b)." All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer Kathy Wold,208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 27
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.
RESPONSE TO REQUEST NO. 18:
Please see the tob labeled " Benefit Costs " in the file labeled " PRl _l 6-23 (a) " for the
requested information. For therm savings, please see column (fl, rows 3 and 4. For the UCT and
TRC ratios, please see columns (d) and (g), rows 30 and 3i,.
As previously stated in Request No.l0, the avoided cost model was updated to coruect a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in thefile
labeled "PR I_16-23 (b)." All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer:Katby lMal4 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 28
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.
RESPONSE TO REQUEST NO. 19:
Therm savings associated with space heating measures were based on deemed energy
savings developedfrom engineering best practices and datafrom the initial potential analysis
performed at the beginning of the program. With o new Conservation Potential Assessment
completed, the Company has been able to apply even more regionally specific deemed savings
based on the average home size, usage, and heating degree days in Intermountain' s respective
climate zones for the therm savings that will be included in the Integrated Resource Plan.
Weather normalization is generally applied during a program's Evaluation,
Measurement and Verification (EM&V) phase and takes into consideration pre and post upgrade
usage over a period ofyears. The dffirence in energl used pre and post measure is then
adjustedfor the effects of weather.
As Intermountain completes its first EM&V process in 2020, it will continue to improve
the accuracy ofits therm savings reports.
Record Ho Lori Blattner. 208-37 7 -60t5
Sponsor/Preparer: KathyWold. 208-377-6128
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAIF, Page 29
Location: 555 S Cole Rd" Boise. ID 83707
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.
RESPONSE TO REQUEST NO. 20:
Please see the tab labeled "Benefit Costs" in thefile labeled "PRl_16-23 (a)" for the
requested information. For therm savings, please see column (fl, row 5. For the UCT and TRC
ratios, please see columns (d) and (g), row 32.
As previously stated in Request No.l0, the avoided cost model was updated to coruect a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in the file
labeled "PR l_16-23 (b)." All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner, 208-377-6015
Sponsor/Preparer: KathyWold. 208-377-6128
Location: 555 S Cole Rd, Boise, ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAIF, Page 30
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.
RESPONSE TO REQUEST NO. 21:
Please see the tab labeled "Benefit Costs" in thefile labeled "PRl _16-23 (a)" for the
requested information. For therm savings, please see column (/), rows 7 and 8. For the UCT
and TRC ratios, please see columns (d) and (g), rows 34 and 35.
As previously stated in Request No.l0, the avoided cost model was updated to correct a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in thefile
labeled " PR I _l6-23 (b). " All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 3l
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 10 of the
Company's Energy Efficiency 2018 Annual Report were calculated. Please provide workpapers
in Excel format with formulas intact and enabled.
RESPONSE TO REQUEST NO. 22:
Please see the tab labeled "Benefit Costs" in thefile labeled "PRl _16-23 (a)" for the
requested information. For therm savings, please see column (fl, row 2. For the UCT and TRC
ratios, please see columns (d) and (g), row 29.
As previously stated in Request No.l0, the avoided cost model was updated to correct a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in the file
labeled "PR I _l6-23 (b)." All column and line number references will be the same as listed
above.
Record Holder: Lori Blattner. 208-377-6015
SponsorlPreparer:Kathy Wold. 208-377-6128
Location: 555S@
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 32
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.
RESPONSE TO REQUEST NO. 23:
The "Wole Home Program" is infact a single measure within the Company's energy
fficiency progrom, and not a program in and of itself, Intermountain's Wole Home meosure
requires that the home earn ENERGY STAR certification and a HERS score of 75 or better.
Referring to the measure as the "Whole Home Program," allowed the Company to dffirentiate
between appliance rebates and the Wole Home rebate, specificallyfor builders. Wen
explaining the program to builders, the Company was deliberate to explain appliance rebates
and whole home rebates as an either/or option, and that they could not qualify for both.
Promoting the options in this way allowed the Company to offer an alternate high fficient
optionfor builders who elected not to pursue ENERGY STAR certification, but could instead
install high efficient appliances.
Please see the tab labeled "Benefit Costs" in thefile labeled "PR I _16-23 (a)" for the
costs and savings of the Wole Home measure and how they were calculated. The costs of the
program are the cost of the rebate/measure, found in column (d), row 20, with all other costs
allocated to the measure based on the percentage of rebates provided, which can befound in
column (b), row 20. The savings of the rebate/measure cqn befound in column (fl, row 2.
As previously stated in Request No.l0, the avoided cost model was updated to correct a
minor calculation error. Consequently, the Company updated the benefit-cost analysis in thefile
labeled "PR I _l6-23 (b)." All column and line number references will be the same as listed
above.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 33
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold, 208-377-6128
Location: 555 S Cole Rd,D 83707
DATED: September 27 2019.
GrvsNs PuRsr,pv r-r.p
/
Preston N. Carter
Attomeys for Intermountain Gas Company
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STA-FF, Page 34
e.*-L='
CERTIFICATE OF SERVICE
I certify that on September 27,2019, a true and correct copy of R-esPoNSE oF
INrpRvor-rNTArN GAS CoupaNv ro FIRST PRorucrtoN Rrquesr oF THE CovvrssroN Srlrn was
served upon all parties of record in this proceeding via the manner indicated below:
Lori Blattner
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd.
Bldg. 8 Suite 201-A
Boise, ID 83713
Diane. Ho lt(Epuc. i daho. gov
Hand Delivery
(Original and 3 copies)
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
I 1331 W. Chinden Blvd.
Bldg. 8 Suite 201-A
Boise,ID 83713
DaSm.Hardie@puc. idaho. gov
Electronic Delivery
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 35