20200916Staff 1-14 to INT.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 10655
ii{IL;I tvfii]
;l*:tt $iP 16 Plt l.2: I I
i r. .?L.1"
, .': rjlii-:: *i]$-iF'gi$Si*1"*
Street Address for Express Mail:
I1331 W CHINDEN BVLD, BLDG 8, SUME 2OT-A
BOISE,ID 83714
Attorney for the Commission Staff
BEF'ORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPAI\IY'S APPLICATION FOR A
DETERMINATION OF 2019 ENERGY
EFFICIENCY EXPENSES AS PRT]DENTLY
INCURRED
CASE NO. INT.G.2O-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOT]NTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that lntermountain Gas
Company (Intermountain Gas; Company) provide the following documents and information as
soon as possible, by WEDNESDAY, OCTOBER 7,2020.
This Production Request is continuing, and the 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDApA
31.01.0t.228.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS SEPTEMBER 16,2020
)
)
)
)
)
)
)
)
I
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please explain how and when the Evaluation, Measurement, and
Verification (EM&V) study results will be used to evaluate the Furnace and Whole Home
programs. See Application at 10. If modifications to these programs are required, please explain
how and when the Company intends to implement them.
REQUEST NO. 2: Please provide an explanation for using a HERS Score of 75 as the
threshold for Whole Home rebate qualification given that the largest number of homes which
participated in the program achieved a HERS Score of 63. See Annual Report, Figure 3.
REQUEST NO.3: Regarding Figure 3 of the Annual Report, please provide a
representative HERS score of Intermountain Gas customers homes consffucted within the last
three years and not in the Whole Home program.
REQUEST NO. 4: On page 19 of the Annual Report, the Company explains that a
HERS score threshold set too low can prohibit participation. Please provide the HERS score and
supporting data that depicts the point where participation is affected.
REQUEST NO. 5: On page 16 of the Annual Report, the Company shows that the
Whole Home program is not cost effective using the UCT or TRC. Please explain what actions
the Company is taking to achieve cost effectiveness for this program and when it is expected to
occur.
RBQUEST NO. 6: Please furnish the following information regarding the Company's
vendor selection for the EM&V study:
a. Provide the criteria used to evaluate EM&V vendors, including all requests for
quotes, proposals, or other similar documents;
b. Provide the names of all vendors that provided quotes or proposals. Please include
quoted costs for each vendor;
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS SEPTEMBER 16,20202
c. Provide copies of all documents and financial records related to final vendor
selection. Please include meeting minutes, memos, and other applicable
correspondence and documentation; and
d. Provide a copy of all agreements or contracts entered into with the selected
vendor (ADIO.
REQUEST NO. 7: Please describe all services ADM will provide after it releases its
EM&V study. Please include what services and deliverables will be provided, when they are
expected to be provided, and at what cost.
REQUEST NO. 8: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2019. Please include date, vendor, amount, a brief description of the expense,
and the account to which the charges were booked. Please separate all expenses by program so
that the expenditures provided reconcile with the amounts listed in the Company's Annual
Report. Please also identiff if each expense is an incentive payment, purchased service,
labor/administrative, materials and equipment, or other expense. Please provide the requested
information in Excel format with all formulas intact and enabled.
REQUEST NO. 9: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for 2019 to 202},to date. If no reports
were issued, please provide the date and scope of the audit and all internal auditor workpapers.
REQUEST NO. 10: Please provide a current organizational chart by title and name
showing all MDU, lntermountain Gas, and contract employees who charge time to the energy
efficiency tariff rider. Please include complete job descriptions, required qualifications, salary
ranges, bonus opporttrnities, and total compensation ranges, including benefits, for all employees
identified in this request.
REQUEST NO. 11: Please provide the workpapers used to determine all values in
Tables 1 through l5 of the Company's Energy Efficiency 2019 Annual Report. Please provide
workpapers in electronic format with links enabled.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS SEPTEMBER 16,2020J
REQUEST NO. 12: Please explain if and how the Therm savings in Tables 4 through 9,
14, and 15 of the Company's Energy Effrciency 2019 annual report were adjusted for the effects
of weather? Please explain the rationale for including or not including the effects of weather.
REQUEST NO. 13: On page 10 of its Application, the Company states that the results
of its EM&V study are nearly complete. Please provide the EM&V Therm savings for the
Company's 2019 furnace and Whole Home programs.
REQUEST NO. 14: Please provide, in electronic format, monthly billed Therms for all
1,079 Whole Home program participants (ENERGY STAR Certified Homes) described on page
18 of the Company's Energy Efficiency 2019 Annual Report. For eachparticipant, please
include the square footage of the home, whether or not the home has a gas water heater, and the
date on which each participant began taking service from the Company.
DATED at Boise, Idaho, this 1?rh auy of September2020.
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/intg20.6mhkkblmm prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 4 SEPTEMBER 16,2020
CERTIF'ICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16ff DAY oF SEPTEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COM1VIISSION
STAFF TO INTERMOT]NTAIN GAS COMPANY, IN CASE NO. INT-G-20-06, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GTVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarter@ sivenspurslev.com
kendrah@ eivenspursley. com
SECRETARY
CERTIFICATE OF SERVICE