20201223Staff 12-13 to INT.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PI.JBLIC UTILITIES COMMISSION
PO BOX 8372A
BOISE, IDAHO 83720-007 4
QAU fi4-O357
IDAHO BAR NO. 5470
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDO 8, SUTTE 2OI.A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTEN OF IITITERMOUNTAIN GAs
COMPANY'S APPLICATION TOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERCY EFHCIENCY
PROGRAM AND FUNDING MECHANISM
CASE NO.INT.G.aO.O4
THIRD PRODUCTION
REQUEST OF TIIE
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 Attomey General, requests that Intermountain Oas Company
("Company") provide the following documents and information as soon as possible, but no later
than WEDNESDAY, JANUARY ll,zD?.t.
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 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 lhe name, job title, and telephone number of
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY DECEMBER 23,2020
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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 wriuen copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 12: Please provide and explain the Company's plans to include
commercial stakeholders, including customers and suppliers, in its Energy Efficiency
Stakeholder group. Please describe the different types of commercial stakeholders that the
Company plans to have on the Energy Efficiency Stakeholder group, and the Company's plans
for finding and selecting commercial group members.
REQUEST NO. 13: Please answer the following questions in response to Production
Request No. 7(c):
a. The Commercialenergy savings kits' components include aerators and sprayers
typically installed in kitchen sinks. Why does the Company believe that it should
partner with HVAC contractors, not plumbers, to deliver and install these
components?
b. Does the Company plan to compensate the HVAC contractors for on-site
installation assistance? If so, what is the projected cost for installation?
c. Please provide all expected delivery and installation costs that will be charged to
the rider.
d. Does the Company plan to distribute kits directly to its OS-l customers, or will all
kits be delivered through the Company's partner HVAC companies?
e. Would the application for these kits be filled-out by the customer or by an HVAC
contractor?
f. How does the Company plan to verify which, if any, components of the kit are
installed?
E. How does the Company plan to measure and verify the energy savings effected by
the kits?
h. Aside from being a commercial customer on the 65-l rate, does the Company
plan to use any other criteria to determine who gets the kits?
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY DECEMBER23,2O2A,
DATED at Boise, Idaho, this *4-of December 202O.
Jr.
Attorney General
i:umirc prodrcqdntg20.4jhmm prod nq !
THIRD PRODUCTTON REQT,TEST
TO INTERMOI.'NTAIN GAS COMPANY 3 DECEMBER23,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS T'd DAY OF DECEMBER 2O2O,SERVED THE FOREGOINo THIRI} PRODUCTION REQTJEST OF TIIE
COMMISSION STATT TO INTERMOT'NTAIN GAS COMPANY, IN CASENO. INT.G.2O44, BY E-MAILING A COPY THEREOR TO THE FOLLOWING:
LORI BLATTNER
DIR - RECULATORY AFFAIRS
INTERMOUT.ITAIN cAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: lori.blattnqrQinteas.com
PRESTON N CARTER
CIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarler @ si venspur.sley.com
f, pJ[drah @ g i venspursley.com
BENJAMIN J OTTO
ID CONSERVATION LEAGI.JE
7IO N 6TH STREET
BOISE ID 83702
E-MAIL: botlq @ ididrpconservation.org
ARY
CERTTFICATE OF SERVICE