20201008Staff 9-11 to INT.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-OO7 4
(208) 334-03s1
IDAHO BAR NO. 5470
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUME 2OT-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERGY EFFICIENCY
PROGRAM AND FUNDING MECHANISM
CASE NO.INT.G-20.04
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,
John R. Hammond, Jr., Deputy Attorney General, requests that lntermountain Gas Company
("Company") provide the following documents and information as soon as possible, but no later
than THURSDAY, OCTOBER 29, 2020.
This Production Request is to be considered as continuing, and lntermountain Gas
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 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
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY OCTOBER 8,2020
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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. 9: Please explain the Company's rationale for maintaining separate
accounts for its Residential and proposed Commercial programs.
REQUEST NO. 10: Please explain the assumptions or data source ("Pre-CPA," "Post-
CPA," other) used to establish therm savings for each measure and explain why that source was
selected.
REQUEST NO. 11: The CPA was funded out of the Residential EE Program, please
explain if and how the Company intends to reimburse the Residential EE Program for portions of
the CPA that are associated with the proposed Commercial program.
DATED at Boise, Idaho, this 64 duy of October ZOZO.
lU/ttf"(^: John R. Hammond, Jr.
Deputy Attorney General
Technical Staff: Mike Monison (9)
Kevin Keyt (10-11)
i:umisc:prodreq/intg20.4jhmm prod req 2
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 OCTOBER 8,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF OCTOBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THECOMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASENO. INT-G-20-04, 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
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarter@ givenspursley.com
kendrah @ givenspursley.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE D 83702
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE