20191011INT to Staff Amended 17.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: (208) 388-l 200
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley.com
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPAI\Y
FOR A DETERMINATION OF 2017.2018
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
REC E IVED
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Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
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CASE NO.INT-G.I9-04
AMENDED 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 amended response to Request No. l7:
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.
AMENDED RESPONSE TO REQUEST NO. 17:
ln discusstons with Staff, Intermountain discovered a mistake in the response to
Production Request No. 17. In the discussion of costs used to calculate the TRC benefit to cost
ratio, the Company incorrectly states that "The costs used are the incremental costs, program
delivery & administration, and total rebates cost". Instead, the reply should have stated that
AMENDED RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF TI# COMMISSION STAFF, Page 1
the costs used in the TRC benefitto cost ratio are only the incremental costs and the program
delivery & administration costs. Rebate costs are not included in the TRC beneftt to cost
calculation.
The calculation itself was handled correctly in the Excelfiles "PR L-L6-23 (a).xls" and
"PR 1_76-23 (b).xls" that accompanied the written documenL In the Excel files, the TRC
benefit to cost ratios in Column (g), Lines 29 - 36 pull the incremental costs from Column (c),
Lines 77 - 78 and the program delivery & administration costs from Column (b), Lines 20 -
27.
We regret any confusion this may have caused. Please let me know if you have
questions reg arding this correction.
Record Lori 208-377-6015
Sponsor/Preparer: KathvWold. 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
DATED: October ll, 2019.
GIVENS PURSLEY LLP
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Preston N. Carter
Attorneys for Intermountain Gas Company
AMENDED RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF TFM COMMISSION STAFF, Page2
CERTIFICATE OF SERVICE
I certify that on October 11,2019, a true and correct copy of AvEDNED RpspoNsp or
INrpRiraorxrArN GAS CovrpeNv ro FrRST PRooucrroN RpQupsr oF THE CouvrrssroN SrArr was
served upon all parties of record in this proceeding via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd.
Bldg. 8 Suite 201-A
Boise, ID 83713
D iane. Ho lt@,puc. idaho. gov
Hand Delivery
(Original and 3 copies)
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8 Suite 201-A
Boise, ID 83713
Dayn.Hard ie@puc. idaho. gov
Electronic Delivery
AMENDED RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 3
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