20210113INT to Staff 12-13.pdf

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:jii ",1,1H I3 PH 3: S3Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley.com
Attorneys for Intermountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERGY EFFICIENCY
PROGRAM AND FUNDING MECHAI\{ISM
CASE NO.INT-GAO.O4)
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RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO THIRI)
PRODUCTION REQUEST OF THE
COMMISSION STAFF
Intermountain Gas Company, in response to the Third Production Request of the ldaho
Public Utilities Commission Staff to Intermountain Gas Company dated December 23, 2020,
submits the information below. Confidential information is noted in the responses. The requested
confidential documents will be provided via the Company's Sharepoint site under the terms of the
Protective Agreement.
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.
RESPONSE TO REQUEST NO. 12:
The Company formed a Commercial EESC subcommittee of its already established
Energy Efficiency Stakeholder Committee to assist in developing this Commercial Program
proposal. The subcommittee brings expertise and industry knowledge from the commercial
market sector and focuses on commercial energy efficiency topics, just as the residential EESC
subcommittee focuses on topics relevant to the residential market. Whole group EESC meetings,
with both residential and commercial subcommittee members, can more efficiently cover topics
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like the annual report or EM&V which impact the program as a whole, rather than a specific
market sector.
The initial stakeholder meeting to discuss the proposed commercial program, included
several members from the residential committee including representatives from Idaho
Conservation League, the Governor's Office of Energy and Mineral Resources, Idaho Public
Utilities Commission Staff, and the Company. Additional participants with commercial expertise
included: commercial HVAC specialists, an Ada County Energy & Sustainability representative,
and a commercial kitchen equipment and design specialist. Both the commercial HVAC and
kitchen equipment representatives were familiar with and experienced in energy efficiency
rebate programs.
If the commercial program is approved, the Company will look to grow the knowledge
base and composition of the EESC through three main avenues: industry networking,
recommendations, and gas company working relationships. Events like the annual ldaho
American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE)
conference provide opportunities to meet and network with commercial experts. EESC members
with expertise in the residential field provide great references of commercial experts. Finally,
Intermountain's own Energy Services Representatives (ESRs), through their daily work in the
community in their respective districts, have been an excellent source of subject matter experts.
In additional to industry representatives, the Company will also look for commercial customers
that would be interested in participating on the EESC.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer: KathvWold. 208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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REQUEST NO. 13: Please answer the following questions in response to Production
Request No. 7(c):
a. The Commercial energy 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 GS-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 veri$ which, if any, components of the kit are
installed?
g. How does the Company plan to measure and veriff the energy savings effected by the
kits?
h. Aside from being a commercial customer on the GS-l rate, does the Company plan to
use any other criteria to determine who gets the kits?
RESPONSE TO REQUEST NO. 13:
a. The Company would certainly partner with plumbing contractors for the outreach and
distribution of the energy saving kits. Speciffing HVAC contractors in production
request No. 7, part c, was purely an oversight since the majority of contractors
participating in the energy efficiency program thus far have been HVAC contractors.
The energy saving kits would serve as an excellent opportunity to grow the
participation of plumbing contractors and increase awareness about both commercial
and residential high-efficiency water heating options.
b. At this time, the Company does not plan to compensate contractors for on-site
installation. One recommendation from the process evaluation performed by ADM
Associates, Inc (ADM) as part of the Evaluation, Measurement, and Verification
(EM&V) study was for the Company to provide contractors with more marketing
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materials in order to promote high efficiency. The Commercial EESC subcommiffee
suggested the Company make these kits available to contractors as an energy
efficiency promotional tool, which would allow the contractor to install equipment at
delivery. To simpliff installation, energy saving kits will include an installation
instruction insert and energy efficiency tips.
c. The Company does not plan to pay for installation of appliances supplied in the
energy saving kits, therefore, no installation costs will be charged to the rider. The
only distribution costs that will be charged to the rider are shipping costs. These are
yet to be determined due to variable volume shipping costs from the energy saving kit
provider, and any additional shipping costs incurred to ship from the Company
directly to customers or partnering contractors.
d. The Company would like to reach as many GS-l customers as possible and plans to
make energy savings kits available in several ways: directly to customers by
completing an application, use of the Company's ESR team to provide kits to
commercial customers to raise awareness about the energy efficiency program, and
by allowing contractors to provide kits to commercial customers in the same way as
an ESR. Regardless of the means of delivery, a completed application is required. The
Company already utilizes a customizable software to create on-line applications and
plans to make the energy savings kits application available in paper format and in an
electronic format that is accessible and compatible with any mobile device.
e. The application would need to be completed by the customer. Many contractors assist
customers with applications, but a customer signature is required.
f. The Company will use a follow up survey to measure installation rates and customer
feedback and satisfaction regarding the energy saving kits. Kits delivered directly to
customers will be considered self-installed and these customers will receive a follow
up survey. For kits provided through contractors, the contractors will be required to
submit a form veri$ing appliances installed.
g. The Company will follow the same approach other Idaho utilities have taken when
using energy saving kits. Based on the information provided in the follow up surveys
of customers and forms submitted by contractors, the Company will apply the
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appropriate therm savings per individual appliance installed to the reported number of
installed appliances to arrive at total therm savings.
h. The customer must be on the GS-l rate and use nafural gas for water heating to
quali$ for the energy saving kit. There will be a one kit per business limit.
Record Lori Blattner. 208-377-60 1 5
Sponsor/Preparer: KathyWold. 208-377-6128
Location:555 S Cole Rd.se. ID R77O7
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DATED: January 13,2021
GTVENS PURSLEY LLP
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Preston N. Carter
Attorneys for lntermountain Gas Company
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CERTIFICATE OF SERYICE
I certiff that on January 13,202I, a true and correct copy of INTERMOUNTAIN GAS
COMPANY'S RESPONSE TO THIRD 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
I1331 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
ldaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,lD 83714
j [e-mail]
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
[e-mail]
ilhk$ltM
Lori A. Blattner
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