20200902Staff 1-8 to INT.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-OO7 4
(208) 334-03s7
IDAHO BAR NO. 5470
a:q* i;; iiiVilLi
:i1;* 5[F -? PH tr: 01
' ',"ii';Ji*e*,E***
Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837T4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTBR OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERGY EFFICIENCY
PROGRAM AND FUNDING MECHANISM
CASE NO. INT-G.20.04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Intermountain Gas Company
("Company") provide the following documents and information as soon as possible, but no later
than WEDNESDAY, SEPTEMBER 23, 2020.
This Production Request is to be considered as continuing, and Intermountain Gas
Company is requested to provide, by way of supplementary responses, additional documents that
it, or any person acting on its behall may later obtain that will augment the documents or
information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY
)
)
)
)
)
)
)
)
)
1 SEPTEMBERZ,2O2O
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: In its Application, the Company stated that the Conservation
Potential Assessment found commercial retrofit cost-effectiveness is low and that commercial
equipment can provide savings. Application at 5. Please provide workpapers, with formulas
intact, for all calculations used to determine cost effectiveness of both the commercial retrofit
and commercial equipment programs.
REQUEST NO.2: Please provide workpapers, with formulas intact, for all calculations
used in Exhibit No. 1. Please provide the source for the Annual Therms Savings for each
measure listed in column d.
REQUEST NO.3: Please provide the projected budget for the "total residential and
commercial program administration" expense, as mentioned on page 8 of the Application, and
the rationale for assigning20 percent of that expense to the commercial program.
REQUEST NO.4: Does the Company expect current economic conditions affecting
commercial customers to have any effect on the "Forecasted Measures Installed" shown in
Exhibit No. 1? Please explain any effects for each measure.
REQUEST NO.5: Please provide the file "IGC-CPA-App F.xlsx" referenced in
Appendix F of the July 2019 Conservation Potential Assessment Final Report provided by
Dunsky Energy Consulting.
REQUEST NO. 6: Please explain the Company's plan for Evaluating, Measuring, and
Verifying (EM&V) the actual savings of each measure listed in Exhibit No. 1. Please explain
how the Company will use the results of their EM&V to evaluate and adjust incentive levels for
each of these measures.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 SEPTEMBER2,2O2O
REQUEST NO. 7: For the Energy Savings Kit ("Kit"), please provide the following:
a. The source used to determine the savings of each item in the Kit;
b. Workpapers showing how the UCT was determined;
c. The criteria that the Company will use for determining who will receive the Kits;
and
d. Specifications for Kit contents, packaging, and cost requirements.
REQUEST NO.8: Please explain if, and how, the Company will use a separate
balancing account for the proposed Commercial Energy Efficiency Program. If not part of the
proposal, please explain why not.
DATED at Boise, Idaho, thi du^,of September 2020.
J Hammond, Jr.
Attorney General
i:umisc:prodreq/intg20.4jhmm prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 SEPTEMBER2,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF SEPTEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, N CASE
NO. INT-G-20-O4, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER
DIR - REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE D 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GTVENS PURSLEY LLP
601 W BANNOCK ST
BOISE D 83702
E-MAIL: prestoncarter@si vensourslev.com
kendrah @ givenspursle)r.com
Y
CERTIFICATE OF SERVICE