20191107INT to Staff 24-38.pdf

RECEIVED
t0 t9 HOY -? Al'l ll : I 9
Attomeys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
l.l ,lo
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPA}IY
FOR A DETERMINATION OF 2017-2018
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. INT-G-19-04
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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Intermountain Gas Company, in response to the Second Production Request of the
Commission Staffto Intermountain Gas Company dated October 17, 2019, submits the following
information:
REQUEST NO. 24: Please identify the energy efficiency measures incented by the
Company to Boise Valley Habitat for Humanity during this review period.
RESPONSE TO REQUEST NO.24r
Boise l/alley Habitat for Humanity did not have any measures incented during the review
period ofOctober 2017 - December 2018. The ENERGY STAR home featured in the video
documentation wds not complete until April 2019, at which time the home was certiJied and
earned the $1,200 llthole Home rebate,
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer:KathyWold, 208-377-6128
Location: 555 S Cole Rd. Boise, lD 83707
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: (208) 3 88- 1300
prestoncarter@ givensoursley.com
i_l r-l
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page I
REQUEST NO. 25: How much money was spent to produce and host the ENERCY
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?
RESPONSE TO REQUEST NO.25:
a. The ENERGY STAR certification and air sealing videos were produced in-house by a
Customer Communications staffmember. No energt elficiency funds were usedfor the
production of the videos.
b. Video documentation of the BVHFH ENERGY STAR home began in October 2019 with
the groundbreaking ceremony. There were lhree videos produced and postecl in 2018, which
to&ether received 86 views. Rather than post the videos individually, at the end of 2018 the
collection ofvideos were hosted on a unique page, "The ENERGY STAR Diference", where
each video could be viewed sequentially to the build process. The page received 52 views in
2018 and 1,440 views lo dale in 2019.
The air sealing video was olso recorded by a Customer Communications staff member
and showed a live demonslration of proper air sealing technique demonstrated by then Division
of Building Safety Energt Program Manager, Jerry Peterson. Proper air sealing is a critical
componenl of home energt efficiency, so copturing this video demowtrolion will provide a useful
tool as the Company continues to develop educational progrsms around energt eficiency.
Because this video applies to home building subcontractors, Intermountain's plan is to use it in
targeted educational opporlunities with that group. It is nol currently on the Company's website,
but rather housed in Intermountain's reference library.
RESPoNSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMVISSTON STAFF, Page 2
Record Holdcr: Lori IJlattner, 208-377 -6015
Sponsor/Preparer: KathvWold. 208-377-6128Location: 555 S Cole Rd. Boise, ID 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 3
REQUEST NO. 26: Please describe 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 ofthe golftoumament
sponsorship in terms ofenergy efficiency program participation.
b. What was the cost of being a sponsor of the golf toumament?
c. Which account was charged for this expense?
RESPONSE TO REQUEST NO,26:
o. The llhole Home rebate ofering is essentially a new construction rebate offering since
many of the steps to meet certirtcdtion take place during the construction process, which is
entirely controlled by the builder. For this reason, it wds important to raise owareness aboul the
new program directly rsith builders. In order to achieve this, Intermountain leveraged existing
memberships with Building Contractor Associalions (BCA) throughoul the service terrilory.
Initially, Intermountain tried a number ofapproaches to reach builders from sponsoring general
membership meetings as o guesl presenter lo hosting information tables at general membership
meetings and hosting information booths at builder showcase events (a manddlory meetingfor
parade of homes builders). While all ofthese events provided an opportunity to reach out to
builders, there were two specific challenges. First, builder attendance at general membership
meetings was very low. Second, despite the facl some events, like a builder showcase, were
mandalory for builders, visiting the information tables was not mandatory and builders could
easily bypass the inlbrmation table, many even remarking, "Oh, Intermountain, we already know
all about you... "
After careful consideration and consulting v,ith BCA directors obout the challenges of
connecting with builders speciJically, Intermountain decided to follore the advice from lhe BCA
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 4
to "go where they go...the golf tournamenl ". Rather than play in the tournoment and interacl
with afew participants at most, Inlermounlain chose an "active hole" sponsorship at a golf hole
during the tournoment. As an active hole sponsor, Intermo*ntain representatives slsyed at one
hole for the duration ofthe lournament, greeting and interacting with each golf tournament
participant as teams proceeded through the golfcourse. Hosting an information table as an
active hole sponsorship at a golf hole, rather than at a general membership meeting, addressed
the two builder oulreach challenges previously encountered: builder attendance was higher than
at any other BCA event, and the information table on the gofhok was not a passive outreoch
approach relying on builders coming to the information table. Instead, os o hole sponsor, every
gofparlicipant visited lntermountain's table by default as they progressed through the course of
tournamenl play. This setling also allowed Inlermountain to create a more interactive approach
to promoting the program wilh the "elrtciency hole ". Program stafl member.s hosting the hole
explained, "To make sure folkr know lhey can earn money backfor installing high-efficient
equipment or building ENERGY STAR certified homes, we're promoting the most efrcient gou'
leam". Teams were limedfrom "tee of" to "hole out" to determine the most e.frtcienl, or.fostesl,
team. No teams refused to play; infact, most enjoyed the challenge, arul no participant coukl
learn about the game without hearing dbout the efficiency program. While the larget audience
was builders, this outreach approach allowed Intermountain to simultaneously promote lhe
program to other "home building adjacent" BCA members critical lo progrom awareness such
as WAC contractors, realtors, appraisers and mortgage lenders, and of course, Intermountain
Gas customers.
IGC sponsored two aclive hole sponsorships, one with the Building Contraclor
Association ofSouthwest ldaho (BCASW, and the other with the Eastern ldaho Home Builder
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 5
Association (EIHBA). The effectiveness of the golf tournament hole sponsorship was based on
the ability to promote the program in a personal conversation with each golf participant at the
sponsored hole, and anecdotal evidence such as surveying if participants had previously heard
about the program. The overwhelming majority were not familior with the progrom or did not
understand that builders were eligible to eorn rebates on nett construction, despite previous
attempts to promote the program at BCA general membership meetings ancl hosting information
tables at BCA events. Many builders were slill under the impression that only residential
customers could apply for the rebates. These informal conversations provicled an opportunity to
raise owareness about the program, and an opporlunily for builders to ask queslion.\ and learn
abo nuo paths to home energt eficiency: the Whole Home rebate and the appliance rebate.
lnlermountain does attempt to tie outreach eforts to rebate applications by providing afield on
the application inquiring "How did you hear about this program? " It is nol a requiredfield, nor
is it frequently used by builders, but in 2019, a Twin Falls builder did respond " community
event" in thisfield on their.first rebate application. This was immediately afier a personal
conversation with progrom stalf at the Magic Valley Building Contractor Association goA
tournament in June of 2019, and Intermountain's f rst time sponsoring a golf hole with this
building association. This builder has routinely submitted rebates ever since. This outreach
approach was presented a.s part of the promotion and education update by Kathy Wold at the
November 29, 2018 Stakeholder meeting. Stakeholders were supryrtive ofthe Company's efforts
lo get the word oul about the new programs and did not specifically have any concerns with
hosting a table at a gofhole as opposed to hosting a table at a BCA membership meeting. The
Slakeholder comments, (Supplement 2 of the Annual Report, page 6) included, "Participation is
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 6
coming mainly through contractors, which is a great markcting tactic. It is hard to gauge other
media leading to someone pdrlicipaling in lhe program".
b. The .firsl golf hole sponsorship was truly experimental. Unsure of how the energt
effciency golf game would be received or how receptive participants would be to the energ)
efficiency message in this setting, Intermountain made o conservative decision to share the
sponsorship.fees with one of Intermountain's district offrces. Energt eficiency staff and the
district representatives hosted the hole together. The hole sponsorshipfor the EIHBA golf
tournament was 8300, shared 50/50 between the ldaho Falls district office and the Energt
Eficiency department and had 116 participants. Based on the positive reception lo the message,
and responses from participants at the EIHBA golf hole from "l didn't know IGC had a
program," to "I didn't know I could apply as a builder", Inlermountain decided to capitalize on
the additional opportunity to personally interact with BCAS\|4 builders, using solely program
resources for the BCASWI hole sponsorship. The BCASWI golf hole sponsorship was $ 175 and
hod 108 participants.
c. Both the EIHBA $ 150 sponsorship and BCASWI $ 175 sponsorship were chorged to
account 4 8 5 2 6. 5 7 4 0. 2 9 08 0.
Sponsor/Preparer:Kathy Wold,208-377-6128
Location:R Boise ID 83707
RESPONSE OF.lcC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 7
Record Holder: Lori Blattner. 208-377-6015
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?
RESPONSE TO REQUEST NO.27:
Unlike energt eficiency programs thal offer a custom optionfor new construction rebale
offerings, for example " 20ot6 better lhan code", Intermountain's Whole Home offering does not
rely on a base case, or what is often referred to as a reference home. The llhole Home measure
requires the home be ENERGY STAR certified with a HERS (Home Energ) Rating System) score
of 75 or lower (when it comes to HERS think golf notfootball: lower is better!). The HERS score
is based on the industry standard for measuring home energt eficiency: the RESNET HERS
Index. The HERS Index is the nationally recognized system of inspecting and calculating a
home's energt performance. The HERS Index offers a similar "mile per gallon" comparison
usedfor cars, when comparing two homes by their home energt performance. For example, a
HERS score of 100 means the home is the same level as a standard code-built new home, and
"there are still many energtt saving measures lhat you could implement to mal@ your home much
more energt eficient". On the other hand, a HERS score of 70 means the home is "30oh more
fficient than homes built according to current building code requirements". The average score
for homes rebated by Intermountain in 2018 was 61. A HEBS score of 60 means, "this house
has made good progress towards optimizing energt performance!" For more explanations about
various index scores, pl'ease vis it httos'./ lwww.hersindex.com/know-your-homes-hers-index-
score,4rers-index-understandins-the-hers-score/ or see an interactive demonstrulktn ofthe HERS
Index at httos:l/w*w.hersindex.com,/hers-index/interactive-hersindex/.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 8
Participotion in a recent roundtable discussion wilh program providers and home energt
raters at the Better Built Northwest Home Efrtciency Forum revealed the one thing progrcm
providers could do to incredse ddoption of energ,, eficient home building is consistency and
simpliciyt in program o.Lferings. Home energ) raters who must certifu homes shdred that it is
daunting, and frankly a deterrent, when a buikler is required to build according to a specialized
program. The HERS Index rating ofers an established, consistent, easy to understdnd dnd
implement, measurement of home energt performance. Given the fact that Idaho Building Code
adoption and enforcement varies by jurisdiction lhroughout the Intermountain service territory,
let alone throughout the state of ldaho, using the HERS Index lends consistency and ease of
understanding to the already complex issue of energt effcienl home building.
Record Ho Lori B lattner. 208-377 -6015
Sponsor/Preparer:Kathy Wold,8-377-6128
Location: 555 S Cole Rd, Boise, lD 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 9
REQUEST N0.28: After reviewing the distribution of HERS lndex scores in Figure 2
(at l0) ofthe 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 4! included in the Whole Home Program. If the building
stock is highly variable across the service tenitory, 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.
RESPONSE TO RI,QUEST NO.2E:
In regard to the distribution of HERS Index scores in Figure 2 (al l0) oJ the Annual
Report compared to new building stock, it is important to note that curuently ldaho residential
builders are not required to hove their homes HELS scored. Builders may elecl lo have their
homes HERS scored to quantifl the energt performance ofthe home, but it is not required by
code. Based on the RESNET HEP-S Index, ct HERS score of 100 "is at the same level as a
standard new home, which meets the current industry standardfor home eficiency". Based on
this RESNET definition, withoul on ofiicial certified rating being conducted, new building stock
can be assumed to be a starulard build and therefore assigned a comparative HERS score of 100
The average HERS score for all homes rebated under the Intermountain llhole Home offering
for Program Year I (the IS-month period from October 2017 - December 2018) was 61.
RESNET reports that for 2018, the average HEP.IS score for all homes scored in Idaho was 62. A
HEB.S lndex score of 60 mean.s the home is approximately 40'% more efficient than the standard
new home, and "has made good progress towards optimizing its energt performance". Wile
these are impressive achievements in home energt efficiency relative to new building stock, il is
worth noting th{tt in 2018, only I l%, of oll new single-family homes (or I ,616 homes) received a
RESPONSE OF IGC TO SECOND PRODUCTIOI] REQUEST OF THE COMMTSSION STAFF, Page l0
HERS Index score as reported by RESNET. The HERS score isjust one component of the ll'hole
Home rebate requirement; the other component requires the home be ENERGY STAR certified.
According to an ENERGY STAR 2018 markzt share report, only 6.29/6 of total home completions
(based on single-family homes) were ENERGY STAR certified, or 723 homes. Intermountain
received a "Certified Homes Market Leader Award" from the Environmental Prolection Agency
(EPA),for "outstonding commitment to energ,l-eficient new homes" and "contribuling 619
ENERGY STAR certified homes in 2018" (see thefile labeled "PR 2_28_2019 Energt Star
Market Leader Award"). These 619 homes rebated under the Intermountain program, represent
85% of all ENERGY STAR certiJied homes in ldaho. llhile the number of ENERGY STAR
certified homes and HERS scored homes participating in the Intermountain rebale program ss a
percentage of total participation by Idaho is notable, there is still signiJicant potential to
increase energt eficient home buildingfrom 2018 marl<et share levels of I lok HERS scored
homes and 6.296 ENERGY STAR certified homes, respectively.
Thefollowing steps were taken to provide a random sampling of HERS scored homes
within the Intermountain service territory that did NOT earn a l4lhole Home rebate from
Inlermountain. First, Intermountdin contacted RESNET to request their database of homes
scored between October 2017 and December 2018. From lhe original population of 1,932 HERS
scored homesfrom October 2017 - December 2018, homes that did receive a rebate:from
lnlermountoin \ryere removed, as were homes outside of Intermountain's seryice territory. This
resulted in a population size of I,0j5. lntermountain has provided the 1,035 records as
confidentialJile "PR 2 28 HERS Sampling" on the CD marked "Confidential". Note, this
comparison sample will be impreci.se as HERS scored home data provided by RESNET does
NOT dffirentiate homes byfuel source, bul simply represents all homes that underwent energ)
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFI.', Page I I
performance lesting and received a certiJietl HERS Index score, therefore the sample may
inaccurately reJlect homes thal would not qualify for the Intermountain energt eficiency
program based onfuel source selection.
Location:555 S Cole Rd, Bo - tD 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 12
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer: Kath),Wold. 208-377-6128
REQUEST NO.29: ln Response to Request No. 16, the Company identified a
correction made to the avoided cost model, which consequently required an update to its benefit-
cost analysis.
a. Please explain the updates made to information in file'PR l_16-23 (b)" to correct
the minor calculation error mentioned above.
b. What is the net impact of this change?
RESPONSE TO REQUEST NO.29:
a. As explained in the Company's response to Request No. l6 ofthe First Production
Request of the Commission Slaff, the correction ofthe calculation error in lhe avoided cost
model coused the benefit cost analysis to chonge. The Company's response to Request No. j0
below explains lhe nature of the calculation error in more detail. The Company updated the
benefit cost analysis infile "PR 1_16-23 (b)" by replacing the table beginning in cell A10 on the
tab labeled "Avoided Costs" with the corrected avoided cost summary. The updaled table on the
"Avoided Costs" tab infle "PR 1_16-23 (b)" is used in the calculation ofthe "UCT Benefit to
Cost Ratio" beginning in column (d), rows 29-36 and the "TRC Benefit to Cost Ratio" beginning
in column (g), rows 29-36 on the " Benefit Costs" tab.
b. The file labeled "PR 2_29 UCT Benefit Cost Comparison" shows the impact to the
UCT of the change explained above.
Four measures had a nominal increase to their individual UCT benefit cost ratio vdlues,
increasing their cost effectiveness slightly. The measures that exryrienced this increase were as
follows: 90'% Combination Radiant Heat System, 70% FE Fireplace, .67 EF Water Heater, .91
EF Water Heater. The total program's UCT benefit cost ratio value was unaffected, remaining at
1.22, as stated in the Annual Report.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAF'F', Page l3
The file labeled "PR 2_37 TRC Beneft Cost Comparison" shows the net impdct to lhe
TRC benefit cost ratiofor the change explained above and.for the change explained in the
response to Request No. 37. As can be seen in this file, lhe only measure impacted by these
changes is the ENERGY STAR Certified Homes measure.
Sponsor/Preparer:Kathv Wold, 208-377-6128
Location: 555 S Cole Rd. Bo . tD 83707
RESPONSE OF tGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page l4
Record Holder: l-ori Blattner. 208-377-6015
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 conected information provided as "PR l_1 0 (b)".
b. What is the net impact of this change?
RESPONSE TO REQUEST NO.30:
a. As discussed inthe Company's response to Request No. l0 oflhe first Production
Request of the Commission Staff, the Company.found and corrected a calculalion error in ils
avoided cost model. The calculation error was the result of incorrectly summing the annual
commodity costs. The impact ofthe calculation error can be seen in the comparison between the
original annual commodity cost and lhe corrected annual commodity costs, as seen on the lab
labeled "AC Monthly Commodity" in thefile labeled "PR 2_30 Avoided Cost Comparison". The
values on the "AC Monthly Commodity" tab are inpuls lo the final result of lhe avoifudcost
model.
b. The tab labeled "Avoided Costs" in thefile "PR 2_30 Avoided Cost Compari.son"
shows the het impoct of lhe calculation error on the Company's avoided costs. The Company's
resrynse to Request No. 29 above explains how the changes to the avoided cost model impacted
the benefit cost analysis results published in the Annual Report.
Record Holder: l.ori Blattner. 208-377-6015
Sponsor/Preparer:Kathy Wold. 208-377-6128
Location: 555 S Cole Rd, Boise, ID 83707
RESPONSE OF tGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page l5
REQUEST NO.3l: 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 ofall vendors that provided quotes or proposals; include quoted costs
for each vendor.
c. Copies ofall documents and financial records related to final vendor selection.
Please include meeting minutes, memos, and other applicable correspondence and
documentation.
d. A copy ofall contracts or agreements entered into with the selected vendor.
RESPONSE TO REQUEST NO,3I:
The Jiles mentioned in in this Response can all be found on the CD markzd
" Confidential " accompanying this Response.
a. The Request for Proposal for lhe CPA study, which includes the evaluotion criteria is
included as file " PR 2_31(a) IGC Request for Proposal".
b. A list of the vendors lhal provided proposals olong with lhe quoted costs are included
in "PR 2_jl(b) Vendors and costs
c. All interviews were conducled over the phone, so there was no expense incurred in the
consuhant selection process- Therefore, no financial records relaled to consullant selection have
been included. Documents related to the final vendor selection include the following:
t Proposals.from lhe six vendors lhal replied to the RFP (AEG, Cadmus, Dunsky,
EES +E350, Forefront, and GDS). All six proposals are included as separate
PDFJiles.
RESPONSE OF IGC TO SECOND PRODUCTION REQI.IEST OF THE COMMISSION S'l'AIrtr, Page l6
. A presentation Dunsky provided as part of its interview (" PR 2 _31 (c) DunslE
Presentation"). AEG ond Cadmus also presented a demonstrdtion of their models
via webinar, but they did not provide a slide deck.
. The.file "PR 2_il(c) 2018 CPA Ranking" includes the list of companies lo which
Intermountain sent an RFP.
. The file " P R 2_i I (c) CPA Contraclor Selection Meeting" contoins notes from the
Company's internal meeting to select from among the Jinal three candidates.
d. A copy of the contract between Dunslqt Energt Consulting and Intermountain Gas
Company is included as "PR 2_31k|) Dunslcy Controct".
Record Holder Lori Blattner. 208-377 -6015
Sponsor/Preparcr:Kathv Wold, 208-377-6128
Location: 555 S Cole Rd, Boise. ID 83707
RESPONSE OF ICC TO SECOND PRODUCT1ON REQUEST OF THE COMMISSION STAFF, Page 17
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.
R-ESPONSE TO REQUEST NO.32:
Per the Independent Services Consultont Agreement, Dunslry Energt Consultants stated
' following the presentation ofrtnal results, we witl hold a two-hour model training workshop Jbr
IGC staff. l e will record the screen video and audio of the training for future IGC use." These
post presentdtion requirements have beenfulfilled at this time and required no additionalfees
since it was part of the agreed upon services and deliverobles. Intermountain has since
requested tvto minor revisions to the model: incorporating delayed implementation of the 9294'
AFUEfurrutce equipment standard, and revision ofthe storage woter hedter measure
characterizalion lo betler reflect current progtam fficiency requirements and lhe UEF
eficiency metric. The furnace modification has been completed, and the water heater adjustment
is expected to be complete in early November.
Intermountain has requested Dunsky Energt Consultanls provide a suggested rale
schedulefor additional model training to be applied on an "as needed" basis to provide training
for new model users.
Record Holdcr: Lori Blattner 208-377-60 t 5
Sponsor/PreparerLocation: 55
Kathv Wold. 2 77 -6128
5SC . ID 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page l8
REQUEST NO. 33r 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 l-16-23(b). Please include all supporting assumptions. Please provide all
workpapers in ExceI or electronic format with formulas enabled.
RESPONSE TO REQUEST NO.33:
llhen Intermountain proposed its Energt Efiiciency Program in Case No. INT-G-16-02,
the Company acknowledged that "a formal full-length potenlial assessment has not been
conducted at this time" (INT-G-16-02 Eighth PR at 2l). Instead, in an ellort to get a program
started without huge upfront costs, lntermountain utilized a Conservation Potenlial Assessment
model that had been developedfor Cascade Natural Gas by Nexant. Stafffrom Cascade Natural
Gas assisted Intermountain in updating the model, where possible, with Intermountain specific
inputs.
In the Response of IGC to Eighth Production Request of Commission Staff in LNT-G-|6-
02, Response No. I I I , Intermountain outlined the following process that was used to determine
annual therm sot,ings:
The annual therm savings for all measures with the exception ofthe 70% AFUE heanh
can be found in the CD file labeled "PR # l8l Annual Therm Savings" lrenamed "PR
2-33 GRC PR #181 Annual Therm Savings" in this Responsel. These savings have been
averaged across all end-uses identified in the spreadsheet. This approach was taken in
order to reflect the varied applications of installed equipment (new construction; energy
efficiency upgrade; emergency change-out, etc.) that the Company may experience in our
first program year. A more refined distribution will take place, if necessary, following on-
the-ground program fi ndings.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 19
It is the Company's understanding that Nexant savings numbers were derived from the
consultant's analysis ofbaseline energy usage for standard-efficiency equipment
compared against the anticipated usage ofthe higher efficiency upgrade. These numbers
were developed based on an analysis ofregional per-captia energy consumption, people
per household. housing stock assumptions, and other key variables derived from the
Lawrence Berkeley National Laboratory, NEEA, lntemational Energy Conservation
Code, and other similar sources, as well as from pre and post measure analysis perlormed
for Cascade Natural Gas. Intermountain based its assumed savings from those that were
developed for Climate Zone Three in the Nexant analysis since the climate zone was
comparable to Intermountain's blended service area.
The annual therm savings for 70% AFUE hearths, a high-efficiency alternative to the
typically less-efficient fireplace insert models on the market, were taken from Cascade
Natural Gas, having been developed by Cascade with the support of their program
contractor, Lockheed Martin (INT-G-16-02 Eighth PR at l2).
The final therm savings that were used in the developmenl of Intermountain's progrdm
can be found on lines 14 through 20 of the file labeled "PR2_33 GRC Exhibil 26" which is
Exhibil No. 26from Intermountain's Case No. INT-G-16-02. These are the same therm savings
that were used in the Jile labeled "PR I _16-23(b)" submitted in Production Request No. l.
Intermountain was i the process of wrapping up its inaugural Conservation Potential
Assessment (CPA) when this Case (INT-G-19-01) wasfiled. That compleled CPA has since been
filed as part of Intermountain's Integrated Resource Plan in Cose No. INT-G-19-07.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 20
Record Ho Lori Blattner 208-377 -6015
Sponsor/Preparer: KathvWold. 208-377-6128
Location: 555 S Cole Rd,tD 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUESl'OF THE COMMISSION STAFF, Page 2l
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.
RESPONSE TO REQUEST NO,34:
Please see Response to Production Request No. 33for a discussion of the method
Intermountain used to arrive at therm savings associated with all measures, including space
heating measures.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer: KathyWold. 208-377-6128Location: 555 S Cole Rd, Boise, lD 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE CoMMISSION STAFF, Pase 22
REQUEST NO. 35: Please provide monthly billed therms (October 201 7 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 ofthe 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 I _16-23(b).xlsx).
RESPONSE TO REQUEST NO.35:
Please see the confidential file labeled "PR 2_35 Wole Home Participants" on the
attached CD marked "Confidential" for the requesled information. The earliest "Accounting
Date " for eoch of the 619 Whole Home Participants represents the date for which that premise
began being billedfor service. The "Certification Date" represents the date on which the
premise became ENERGY STAR certified. Monthly billed therms before the "Certification
Dale" may represenl usage for heating the home during construction and mqt not be an
accurate depiction of typical home energt usage. Conversely, monthly billed therms after the
"Certification Dale" more likely represent typical home energ) usage.
Sponsor/Preparer: JacobDanineton.208-377-6041
Location: 555 S Cole Rd, Boi . ID 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 23
Record Holder: Lori Blattner. 208-377-6015
REQUEST NO.36: Please provide the workpapers used to determine the Measure
lncremental Costs listed in cells (c11) through (c22) in the tab labeled "Benefit Costs" in the file
labeled "PR l-16_23(b).' Please include all supporting assumptions used by the Company.
Please provide workpapers in Excel or electronic format with formulas enabled.
RESPONSE TO REQUEST NO.36:
The Measure Incremental Costs were derived in the method explained in the Response of
IGC to Eighth Production Request of Commission Stalf in INT-G-16-02, Response No. 197
(beginning at j5):
Incremental costs are fluid and can vary over time with the evolution ofthe market. In
order to ensure the use ofreasonable cost inputs in our analysis, the Company worked
with its district staff to perform a call-down oflocal builders and HVAC contractors as
needed to help refine our understanding ofincremental costs for each measure. This
information was taken into consideration when determining the most relevant installed
cost for each measure. The following procedure was utilized:
l) Priority was given to inputs from the Nexant potential assessment which reflects the
NW market. Costs were averaged across all end-uses identified in the spreadsheet.
These were compared to the feedback given by our district staff. Ifthe numbers
seemed unusually high or low based on our understanding of lntermountain's market
and feedback from our district staff, we utilized the assumptions under #2.
2) CNGC assumptions were developed from both prior shared analysis with the Energy
Trust ofOregon, and Lockheed Martin. These were used where the assumed costs
from Nexant appeared inconsistent with the Company's understanding ofthe region's
HVAC market.
RESPONSE OF IGC TO SECOND PRODUCTION R-EQUEST OF THE COMMISSION STAFF, Page 24
3) When both Nexant and Cascade cost assumptions appeared outside ofthe Company's
understanding of the region's HVAC market, the Company then refined its
understanding of incremental costs with additional feedback and figures for cost
assumptions from area contractors. This was how the Company developed its
incremental cost assumptions for Energy STAR homes.
Ultimately, incremental costs were derived from the following sources:
Enerev STAR Certified Homes: Value taken from the results ofa call-down to local
builders in order to gauge current incremental market costs for Energy STAR homes as
compared to standard construction. The Company also spoke with lntermountain District
Staff most familiar with the local Energy Star market. These conversations indicated that
incremental costs for Energy STAR homes were in the $4,000 - $5,000 range.
Intermountain chose to set the incremental cost at the low end ofthe range for planning
purposes, commensurate with the incremental cost utilized by sister company Cascade
Natural Gas due to similar market characteristics.
95% AFUE Gas lrurnaces: Value taken from TEAPot model as an average ofcosts
associated with all end-uses identified in the spreadsheet. A more refined distribution will
take place, if necessary, following actual program findings
High Efficiency Combination Radiant Heat: Value consistent with incremental cost
utilized by sister company Cascade Natural Cas due to similar market characteristics.
80% AFUE Hearth: Value consistent with incremental cost utilized by sister company
Cascade Natural Gas due to similar market characteristics.
70% FE Hearth wrlh lqt l-c!!!ia!i Value consistent with incremental cost utilized by sister
company Cascade Natural Gas due to similar market characteristics and replication of
RESPONSE OF IGC TO SECoND PRoDUCTION REQUEST OF THE COMMISSION STAFF, Page 25
measure based on CNCC program measure and inputs.
67 Water Heater: Value taken from TEAPot model as an average of costs associated
with all end-uses identified in the spreadsheet. A more refined distribution will take
place. if necessary, following actual program findings.
.91 EF Tankless Water Heater: Value taken fiom TEAPot model as an average of costs
associated with all end-uses identified in the spreadsheet. A more refined distribution will
take place, if necessary, following actual program findings.
The TEAPot model Incrementol Costs can be found in Column P of thefle "PR 2 33
GRC PR #l8l Annual therm Scvings"
Record Holder:Lori Blattn 208-377 -6015
Sponsor/Preparer:Kathv Wold, 208-377-6128
Location: 555 S Cole Rd, Boise, ID 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUESI OF THE COMMISSION STAFF, Page 26
REQUEST N0.37: Please explain why the Measure Incremental Cost ($1,142) is less
than the program rebate ($1,200) for the ENERGY STAR Certified Homes measure.
RESPONSE TO REQUEST NO.37:
The Measure Incremental Cost of $ I , 142 is the amount recomfiended by the TEAPot
model. Based on discussions with represenlalives of lhe ldaho building industry and Company
StafJ, Intermountain did not believe thal number accurately reflected the climate in its service
territory. For that reason, in the original programfiling made in Case No. INT-G-16-02,
Intermountain used a Measure Incremental Cost of54,000 to set the rebate level.
Unfortunately, when creating lhe spreadsheel u,sed in annual reporting, Intermountain
reverted to the TEAPot model Incremental Cost. The $1,000 Medsure Incremental Cost used in
the original program development should have been used instead. The file "PR 2_37 Measure
Incremental Cost" shows the corrected Incremental Cost.fbr ENERGY STAR Certified Homes ot
$4,000. TheJile "PR 2_37 TRC Benefrt Cost Comparison" shows the net impact of this revision,
as well as the revision discussed in Response No. 29 above.
tlecordlloldcr: Lorilllattner. 208-377-6015
Sponsor/Preparer:Kath Wo 208-377-6t28
Location: 555 S Cole Rd, Boise. ID 83707
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMTSSION STAFF, Page 27
REQUEST NO.38: Please provide the workpapers used to determine the Portfolio
Nominal Cost per Therm values listed in cells C l2:C4l in the tab labeled "Avoided Costs" in the
file labeled'PR l_16-23(b)." Please include all supporting assumptions. Please provide
workpapers in Excel or electronic format with formulas enabled.
RESPONSE TO REQUEST NO.38:
The Portfolio Nominal Cost per Therm values originally comefrom the Company's
avoided cost model. The avoided cost model was provided in resgtnse to Request No. I0 in the
first Production Request ofthe Commission Stafasfile "PR 1_10 (b)". The "PR 1_10 (b)"rtb
pulls "Portfolio Nominal Cost per Therm" on the "Avoided Cost" tabfrom Column H of the
"Avoided Nominol Cost by Year" tab. It is calculated by summing the assumptions for
Commodity Cost, Distribution System Cost, Incremental Fixed Transport Cost, and Variable
Transport Cost. The formulas are all enabled in the Jile "PR 1_10 (b)" which should allow those
underlying calculations to be traced back to their source assumptions. The source assumptions
are also included in "PR l_10(b)".
Record Holder: Lori Blattn r- 208-377-6015
Sponsor/Preparer:Kathv Wold, 208-377-6128
Location: 555 S Cole Rd. Boise. lD 83707
DATED: November 7, 2019
GIVENS PURSLEY LLP
,t e---1:--
Preston N. Carter
Attorneys for lntermountain Gas Company
RESPONSE OF ICC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 28
CERTIFICATE OF SERVICE
I certifo that on November 7, 2019, a true and correct copy ofRESPoNSD ot,
INTERMoUNTATN Ges Covp.qNv ro SECoND PRoDtJcIoN Rr,euEST oF THE CoMMrssroN STAIT,
was served upon all parties ofrecord in this proceeding via the manner indicated below:
b
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
I 133 | W. Chinden Blvd.
Bldg. 8 Suite 201-A
Boise, ID 83713
[e-mail]. gov
Hand Delivery
(Original and 3 copies)
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd.
Bldg. 8 Suite 201 -A
Boise, lD 83713
[e-mail]. gov
Electronic Delivery
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 29