20191017Staff 24-38 to INT.pdf

DAYN HARDIE
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
REC EIVED
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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 OF 2017.2018 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED.
CASE NO. INT.G-19-04
SECOND 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 Attorney General, request that Intermountain Gas Company (Intermountain
Gas; Company) provide the following documents and information as soon as possible, or by
THURSDAY, NOVEMBER 7, 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, including any 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. See IDAPA
3t.0t.01.228.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS
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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. 24: Please identify the energy efficiency measures incented by the
Company to Boise Valley Habitat for Humanity during this review period.
REQUEST NO. 25: How much money was spent to produce and host the ENERGY STAR
certification and air sealing videos in partnership with Boise Valley Habitat for Humanity?
a. Which account was charged for the production of these videos?
b. How many views did the videos receive during the past year?
REQUEST NO. 26: Please desuibe how the Company's sponsorship of a golf tournament
raised awareness of Appliance and Whole Home rebates.
a. Please describe how the Company measured effectiveness of the golf tournament
sponsorship in terms of energy efficiency program participation.
b. What was the cost of being a sponsor of the golf tournament?
c. Which account was charged for this expense?
REQUEST NO. 27: What Home Energy Rating System (HERS) Score does the Company
use as a base case to determine Whole Home Program energy performance and energy savings?
REQUEST NO.28: After reviewing the distribution of HERS Index scores in Figure 2 (at
l0) of the Annual Report, Staff is interested in how these values compare to new building stock.
Please provide a random sampling of HERS scores of new homes within the Intermountain Gas
service territory not included in the Whole Home Program. If the building stock is highly variable
across the service territory, please provide separate numbers rather than an average for distinct
areas, such as region or climate zone. If information is unavailable, please explain why the
Company cannot provide it.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 ocToBER 17,2019
REQUEST NO. 29: In Response to Request No. 16, the Company identified a correction
made to the avoided cost model, which consequently required an update to its beneht-cost analysis.
a. Please explain the updates made to information in file "PR I 16-23 (b)" to correct
the minor calculation error mentioned above.
b. What is the net impact of this change?
REQUEST NO.30: In Response to Request No. 10, the Company identified it had
discovered a minor error in its avoided cost model.
a. Please explain the change between the information that was used to prepare the
Annual Report and the corrected information provided as "PR 1_10 (b)".
b. What is the net impact of this change?
REQUEST NO. 31: Please provide the following information regarding the Company's
vendor selection for its Conservation Potential Assessment (CPA).
a. The criteria used to evaluate CPA vendors including all requests for quotes,
proposals, or other similar documents.
b. The names of all vendors that provided quotes or proposals; include quoted costs for
each vendor.
c. Copies of all documents and financial records related to final vendor selection.
Please include meeting minutes, memos, and other applicable correspondence and
documentation.
d. A copy of all contracts or agreements entered into with the selected vendor.
REQUEST NO. 32: Please describe any and all services Dunsky Energy Consultants will
provide post CPA release. This description should include the services and deliverables to be
provided, when they are expected to be provided, and the expected cost.
REQUEST NO.33: Please provide the workpapers used to determine the Annual Therm
Savings listed in cells (e2) through (e8) in the table labeled "Benefit Costs" in the file labeled "PR
1-16-23(b). Please include all supporting assumptions. Please provide all workpapers in Excel or
electronic format with formulas enabled.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS aJ ocToBER 17,2019
REQUEST NO. 34: In its response to Staff Production Request No. 19, the Company
stated "therm savings associated with space heating measures were based on deemed energy
savings." Please provide all workpapers used to determine the deemed savings in Excel or
electronic format with formulas enabled. Please include all supporting assumptions used by the
Company.
REQUEST NO.35: Please provide monthly billed therms (October 2017 through
September 2019) for all 619 Whole Home Program participants in Excel or electronic format with
formulas enabled. For each participant, please also include the square footage of the home, whether
or not the home has a gas water heater, and the date on which each participant began taking service.
(Reference cell (c2), Benefits Cost tab, PR l_16-23(b).xlsx).
REQUEST NO. 36: Please provide the workpapers used to determine the Measure
Incremental Costs listed in cells (cl 1) through (c22) in the tab labeled "Benefit Costs" in the file
labeled "PR 1-16_23(b)." Please include all supporting assumptions used by the Company. Please
provide workpapers in Excel or electronic format with formulas enabled.
REQUEST NO. 37: Please explain why the Measure Incremental Cost ($1,142) is less than
the program rebate ($1,200) for the ENERGY STAR Certified Homes measure.
REQUEST NO. 38: Please provide the workpapers used to determine the Portfolio
Nominal Cost per Therm values listed in cells Cl2:C4l in the tab labeled "Avoided Costs" in the
file labeled "PR 1_16-23(b)." Please include all supporting assumptions. Please provide
workpapers in Excel or electronic format with formulas enabled.
1l #-DATED at Boise, Idaho, this day of October 2019.
Hardie
Deputy Attorney General
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SECOND PRODUCTION REQUEST
TO INTERMOLINTAIN GAS 4 ocToBER 17,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITth DAY OF OCTOBER 2019,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, N CASE
NO. INT-G-79-04, BY MAILING A COPY THEREOF, POSTAGE PREPATD, TO THE
FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOI.INTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
kendrah@ givenspursl ey. com
Y
CERTIFICATE OF SERVICE