20201029INT to Staff 9-11.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ gi venspursley. com
IN THE MATTER OF INTERMOUNTAIN
GAS COMPAIIY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERGY EFFICIENCY
PROGRAM AND FUNDING MECHANISM
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Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. INT.G-20.04
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SECONI)
PRODUCTION REQUEST OF THE
COMN{ISSION STAFF
Intermountain Gas Company, in response to the Second Production Request of the Idaho
Public Utilities Commission Staff to Intermountain Gas Company dated Octob er 8,2020,submits
the information below.
REQUEST NO. 9: Please explain the Company's rationale for maintaining separate
accounts for its Residential and proposed Commercial programs.
RESPONSE TO REQUEST NO.9:
Because the Energy Efficiency Charge will be a unique charge for both the Residential
and Commercial customer classes, Intermountain believes separate accounting will enable more
accurate adjustments to the respective Energy Efficiency Charges.
Revenues will be tracked using separate work orders. Rebates will be identified using a
unique work order for each rebate, which will allow the costs to be assigned to the correct
customer class. The labor and program delivery costs will be split at the end of each program
year between the two programs based on therm savings. The over or under collected balance for
each customer class will be tracked in separate sub accounts. This accounting plan will allow
REspoNsp oF INTERMoUNTAIN Gas CotupaNy ro SECoND
PRooucuoN RrquEsr oF THE CorrlurssloN Srapp - pecs I
Intermountain to easily document any requested revisions to the rate charged for either the
Residential or Commercial Energy Efficiency Charges.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer: Jacob Darrington. 208-377-6041
Location:555 S Cole Rd.rD 8i707
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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.
RESPONSE TO REQUEST NO. l0:
The Company's first priority in developing an energy efficiency program was to create
and successfully launch a program for its residential customers. Following that successful
launch, the Company planned to develop a rebate portfolio for its commercial customers.
The TEAPot model developed in2014 by Nexant for IGC's sister company, Cascade
Natural Gas, was the basis for the design of the Company's initial residential offering. TEApot is
an acronym for Technical, Economic, and Achievable Potential. The model incorporates an
analysis of available technologies, climate zone, load forecasts and market segments. The
Company's Residential EE Program was based on this data until Intermountain Energy
Efficiency could commission its own Conservation Potential Assessment (CPA). Intermountain's
CPA was completed by Dunsky Energy Consulting in mid-2019.
In the Company's 2019 Annual Report on the Residential EE Program, included in Case
No. NT-G-20-06,Intermountain used the terms "Pre-CPA" and "Post-CPA" to refer to the
TEAPot modeling results and the Dunsky CPA results respectively. Since final CPA results were
available mid-year, to compare the initial program savings estimates to the savings estimates
reported in the Company's CPA, the Company referred to measure savings and ultimately all
UCT calculations as Pre-CPA (initial savings estimates based on TEAPot) and post-CpA
(savings estimates based on Dunsky Energy Consulting CpA).
There are no Pre-CPA/Post-CPA considerations for the Commercial EE program since
there was no commercial program planned using TEAPot, or Pre-CPA, information. The
Commercial EE Program design is strictly based on the measure charucterization included in the
2019 CPA conducted by Dunsky. The data source for all measure therm savings can be found in
the measure characterization that was provided as file CONFIDENTAL pR#2_Annual Therm
savings as part of the first production request in this case, [NT-G -20-04.
Record Holder:Blattner.77-601s
Sponsor/Preparer:Kathv Wold.20 77-6128
Location:5ss s Rd- Boise- ID 8i707
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REeUEST 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.
RESPONSE TO REQUEST NO. 11:
Intermountain did not plan to have the proposed Commercial EE Program reimburse the
Residential EE program for portions of the CPA associated with the proposed Commercial EE
program. Since the CPA study was already being performed, it was more cost effective and
efficient to have commercial measures evaluated at the same time as residential. During its
November Zg,Z1ltEnergy Effrciency Stakeholder Committee meeting, Intermountain outlined
its plans to have the CPA "include a review of potential commercial programs that could be
offered,'(see the file "PR#I I EESC Supplement 2", page 2). There were no concerns raised with
this plan from members of the Committee. Minutes from that meeting were included in Case No.
INT-G-I9-04 as Supplement2and have been included with this response for reference (see the
file "PR#l1 EESC Supplement 2").
All of the functions of the CPA would have been performed regardless of whether
commercial measures were part of the analysis. AdditionallY, there is some benefit to
Intermountain's residential customers of beginning a commercial program. Encouraging
commercial customers to also use natural gas as efficiently as possible will ensure the entire
system is managed as cost effectively as possible, which keeps costs low for both classes.
Record Holder: Lori Blattner. 208-377-6015
SponsorlPreparer:Kathv Wold.20 77-6128
Location:s55 S Cole Rd^ Boi rD 8i707
RpspoT.ISP OF INTERMOLTNTAIN GAS COUPEUY TO SECOND
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DATED: October 29,2020
GIVENS PURSLEY LLP
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Preston N. Carter
Attorneys for Intermountain Gas Company
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CERTIFICATE OF SERYICE
I certiff that on October 29,2020, a true and correct copy of INTERMOUNTAIN GAS
COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF was served upon all parties of record in this proceeding via electronic mail as indicated
below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,lD 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
John R. Hammond
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-4.
Boise,lD 83714
j ohn.hammond@puc. idaho. gov
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,ID 83702
[e-mail]
flhLBLM
Lori A. Blattner
RsspoNsp or INrrnuoLrNTAIN Gas CotrlpaNv ro SpcoNp
PRoDUCTIoN RBQUEST oF TUE Cotrlrratsslol.t Srarr - Pece 6
lntermountain Gas Company
Supplement 2: Energy Efiiciency Open House
Meeting Notes
INTERMOUNTAIN'
GAS COMPANY
A Subsidiary of MDU Resources Group, lnc.
ln the Community to Serve@
Energy Efficiency OPen llouse
Meeting Notes
November 29r 2018
Attendees:
Bruce Walter - Boise Valley Habitat for Humanity
Katie Pegan - Office of Energy & Mineral Resources
Brian Bennett - The Energy Auditor, Inc.
Emily Bennett - The Energy Auditor, Inc.
Lars Hansen - Brighton Corporation
Ben Otto - Idaho Conservation League
Connor Grossman - Building Energy, Inc.
Heath Chisholm - Building Energy, Inc.
Tom Lay - Boise Valley Habitat for Humanity
Calvin Howell - TML Service ExPerts
John Chatburn - Office of Energy & Mineral
Resources
Scott Pugrud - Office of Energy & Mineral
Resources
Donn English - Idaho Public Utilities Commission
Ingo Stroup - Building EnergY, Inc.
Cassie Koerner - Idaho Public Utilities Commission
Intermountain Gas Representatives:
Mark Chiles
Lori Blattner
KathyWold
Kody Thompson
Mike McGrath
Ben Marconi
Note Taker: Kody ThomPson
10:00 am - Meeting Convened
Mark Chiles opened the meeting, by welcoming the group to Intermountain Gas Company's first meeting
regarding the Energy Efficiency Program. The intent of the meeting is to provide information on the
program, its goals, and to obtain feedback from those present'
10:15 am - Energy Elliciency 101 - Lori Blattner
Lori highlighted the program goals, which were as follows:
o Ensure the most efficient use of current infrastructure and available resources
r Keeping consumer Prices low
o Provide a positive customer experience.
Lori then discussed the different methodologies that exist to accomplish these goals:
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o Conservation - Encouraging consumers to adopt behaviors that will result in using less energy
o Demand Side Managernent (DSM) - Targeted usage reduction at constraint points, which are
accomplished by time of use pricing and intemrptible rate schedules.
o Energy Efficiency - Encouraging the best use of energy by using technology that will perform the
same function, while using less energy.
An overview of how the program began, which customers are eligible for the program, how the program
is funded, and program cost effectiveness was presented.
10:30 am - Program Design - Lori Blattner
Lori provided background on the design of the current Energy Efficiency program, and what is being
done to help inform and desigrr the program going forward. The following key points were presented:
o Conservation Potential Assessment (CPA) results from Intermountain's sister company were used
to create the framework for the program as it currently exists.
r Intermountain selected measures that performed well in other utility's programs, were more
simple to implement and that were cost effective. A couple of stretch measures were also
included in the portfolio. The 80% AFUE Fireplace lnsert rebate was the least successful
measure. It was considered emerging technology at the time the program was designed but did
not become available in the market as anticipated. The Company received feedback on the lack
of available product in this category and plans to eliminate this offering when the new portfolio is
designed.
o The program is in a ramp up phase. Current measures were selected to help ensure the program
could be implemented effectively and would create a solid foundation to build the program.
o Dunsky Energy Consulting has been retained to perform a new CPA for the program to provide
insight into the potential that is available for the future. They have been asked to include a review
of potential commercial programs that could be offered.
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o The Idaho Public Utilities Commission is given reports on the progress of the program quarterly,
with the first annual report pending completion of the current program year.
There were questions regarding whether the CPA results are going to be provided as a dynamic model
that will allow adjustment of assumptions, measures that should be considered as part of the assessment,
and whether the program was IPUC mandated. A comment attributed quick turn-around time for rebates
as helping promotion and interest in the program.
10:45 am - Program Update - Lori Blattner
Lori provided an update on the performance of the program through third quarter actuals, as this
information is publicly available. The following key points were presented:
o Due to the first year of the program being fifteen months, rather than twelve as it will be going
forward, the program collected more funds than were originally planned in the annual budget.
. Through the end of September, the program has spent slightly more than the revenue generated to
tund it.
o The whole home and furnace rebates are the most popular measure in the program, with the
furnace providing the most deemed therm savings.
. When customers are surveyed about how they heard of the program there are mainly two
responses. For appliance rebates the installer is the most frequent response and for the whole
home rebate the energy rater is the most frequent response.
There were questions and comments regarding the distribution of the whole home rebates paid across
IGC's service territory, and how many new installations versus retrofit fumaces were installed, and
recommendations that IGC explore an offering to low income populations.
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11:15 am - Boise valley Habitat for Humanity Energy Star Home - Kathy wold
Kathy provided an update on the partnership with Boise Valley Habitat for Humanity. The following key
points were presented:
a The partnership is a great education opportunity. It was an opportunity to combat misperceptions
regarding quality and affordability of home energy efficiency.
Habitat for Humanity reached out to IGC initially seeking the appliance rebates, but through
additional discussion with them it was discovered that they were close to meeting the criteria for
the whole home rebate.
Videos documenting the process of the build are being created to use as an education resource for
both Energy Star certified homes and Habitat for Humanity homes. Segments of these videos are
being published to the IGC Facebook page and website coinciding with the real-time build
process.
Tom Lay, with Boise Valley Habitat for Humanity, was given time to discuss their history of
building effrcient homes and their thoughts on the TGC whole home rebate.
There were comments given regarding barriers that exist for builders to construct efficient homes,
specifically the lack of ENERGY STAR credentialed subcontractors that are required for ENERGy
srAR home certification and a HERS only based program was discussed.
11:45 am - Lunch
12:30 pm - Online Form Protoffpe - Kody Thompson
Kody previewed an online rebate form that is being developed for the appliance rebates in the program.
The following key points were presented:
The form will be hosted on the IGC website and will be optimized for mobile devices, with the
idea that rebate forms could be filled out in the freld during the install to help streamline the
submission process.
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a Rebates submitted through this format will reduce data entry time for rebate applications, which
will help keep the turn around time for rebate payouts within the stated 6 - 8 week timeframe as
the program grows.
The online form will be tested with a few contractors before being made available on IGC's
partnerships were sought during multiple Parade of Homes events with builders that had met the
whole home requirement. Co-branded signs were provided during the time of the parade to
highlight efficient features in the home, and IGC hosted a table in the home to talk about Energy
Star and HERS ratings.
IGC partnered with Idaho Department of Building Safety (DBS) to facilitate education of code
changes and plan review of Manual J. IGC provided a coursie subsidy to help contractors offset
training fees, partnering witlt DBS Wrightsoft, a software provider'
A collaborative presentation was done with Brian Bennett to highlight the shared savings that can
be achieved in Southeastern Idaho service territory with Rocky Mountain Power'
website.
There were questions and comments as to whether IGC was considering creating an online form for the
whole home rebate, and the importance of testing this new technology before release was mentioned'
12:45 pm - Promotion & Education Update - Kathy Wotd
Kathy provided details of what has been done to promote and provide education about the program' The
following key points were discussed:
o A booth kit was developed to be used at trade shows. A conscious efrort was made to visit trade
shows across IGC's service territory, with mixed results'
r Builders are busy and difficult to reach, because of this, IGC hosted a hole at golf tournaments'
This hole was designed around efficiency and provided time to speak with the builders about the
program.
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o A mailer is being prepared to send out to contractors that have participated in the program
throughout the year so far. This mailer highlights frequent errors on the form in an effort to help
ease the process for customers and confractors, with a raffle held at the end of the program.
Comments were given that a newsletter highlighting simple upkeep items that retain equipment
efficiency, would be worth exploring to get basic information in front of first-time home buyers.
1:30 pm - Open Discussion/Wrap-up
o Participation is coming mainly through contractors, which is a great marketing tactic. It is hard to
gauge other media leading to someone participating in the program.
o Has any consideration been given to limiting measures to specific contractors, similar to what
Idaho Power currently does? Lori answered IGC will continue to review this option, but it is not
planned for the immediate future.
. Highlight a customer or trade ally that had the biggest or most projects during the year, as this can
be a subtle marketing message to their peers.
o As the program matures and expands into commercial programs, the Office of Environmental and
Mineral Resources expressed a desire to see more tdaho Energy Efficiency awards applications
sent in for gas savings. They requested that field reps encourage companies to fill out applications
for the Governor's award.
o It would be nice to be able to have tangible data showing a comparison of homes built in the
1950's compared to a new construction build.
1:45 pm Meeting Adjourned
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