20201223Staff 15-27 to INT.pdf

MATT HTJNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX $72A
BOISE,IDAHO 83720.W4
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUME 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BETONE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE I\,IAT:TER OF IFITERMOUNTAIN GAS
COMPANY'S APPLICATION TOR A
DETERNIINATION OF 2019 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
casE No. INT-G-20.06
SECOND PRODUCflON
REQT]EST OF TrrE
COMMISSION ST^A.Fr TO
INTERMOUNTAIN GAS
COMPAiTIY
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,JANUARY 13,2021.
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, supponing 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, Iocation and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDApA
31.01.0r.228.
SECOND PRODUCTTON REQUEST
TO INTERMOUNTAIN GAS
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I DECEMBER 23, 2O2O
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. 15: Please provide all information collected by the Company rhar
demonstrates home builders and Home Energy Rating System (-'HERS") raters will participate in
the revised Whole Home program. Please explain how the Company will measure the impact of
the revised program on home builders and HERS raters.
REQUEST NO. 16: Please list all additional requirements beyond thc device being a
wi-fi enabled smart thermostat to be eligible for the Company's smart thermostat rebate, such as
professional installation or technical capabilities. Please explain how the Company will measure
savings achieved from the smart thermostat rebate measure.
REQUEST NO. 17; Please provide the source of the "estimated annual savings of 44
therms" for smart thermostats, as shown on page 2 of Exhibit No. 7.
REQUB.ST NO. l8: According to the Company, energy savings were determined by
comparing consumption of modeled User Defined Referencs Homes ('UDRH") with modeled
consumption for Program Homes. According to the Company (Exhibit No. 5, page g6), the
UDRH reflects the 2012 International Energy Code with Idaho's Amendments. Average
consumption of a UDRH home was 923.90 Therms (Exhibit No. 5, Table No.6-3). please
answer the following questions:
a. Please provide a list and explain all steps taken by the Company or its evaluator to
assure that the consumption of the UDRH home is representative of the energy
consumption that would be built absent participation in the Whole Homes program?
b. Please explain and provide supporting documentation showing why average
consumption of the UDRH home is so much larger than the 698 Therm average
residential consumption determined in the Company's tast general rate case
(rNT-c-16-02).
sEcoND PRODUCTTON REQUEST
TO INTERMOUNTAIN GAS DECEMBER23,2OzA2
REQUEST NO. 19: Please explain the Company's process for validating the REIvI/Rate
software used to estimate consumption of the UDRH, Energy Star, and Program Homes. Did the
Company or its evaluator compare modeled data with billing data? If so, please provide both the
modeled data and billing data for each home used in the validation.
REQUEST NO.20: Page 86 of Exhibit No. 5 explains that the evaluators used thc
simulation model to compare a sample of 80 participating homes with the UDRH. Please answer
the following questions:
a. For each of the 80 homes, please provide monthly modeled data and monthly
billing data.
b. Please explain tho stralification methodology used to determine the number of
homes sampled in each strata.
c. Was this a Stratified Random Sample?
d. Please provide the number of homes built by each builder and provide the number
of homes sampled from each builder.
REQUEST NO.21: In Final Order No. 34536 (INT-O-19-04), the Commission srated,
"The deemed savings value should be based on a comparison of actual billing data from similar
new homes constructed which received the rebate and ones that did not receive the rebate."
Given the Commission Order, why does the Company believe it continues to be appropriate to
evaluate the Whole Homes Program using modeled savings values?
REQTIEST NO.22r In Section 4.4.1 of the Impact Evaluation, the evaluators used
REM/Rate software to determine the correlation between HERS scores and the relative savings
of Whole Homes program rebated households to the UDRH. According to the report, the
evaluators "found the savings normalized by square footage remains relatively constant across a
2O-point HERS Index range." Given the lack of correlation between this methodology and the
HERS [ndex, why has the Company chosen to use this same methodology to model energy
savings?
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS DECEMBER23,2O2O3
REQUEST NO.23: According to the Whole Homes billing analysis, the acrual average
savings of Energy Star Certified Homes was 5?.54 Therms per participating home per year
(Table 4-3). This is far less than the 198.15 Therm modeled savings of Energy Star homes
relative to the UDRH (Table 4-31). Given the inaccuracy of the model in estimating Energy Star
Savings, why should the model be used to estimate savings values for the Company's revised
Whole Horues program?
REQUFST NO.24: In its proposed revisions to the Whole Home program, the
Company recommends requiring homes to be HERS scored even though the EM&V evaluation
found that lower HERS scores did not correlate with more Therm savings (Exhibit No. Z, page
5)- What information will the HERS evaluator provide to the Company, and how dms the
Company plan to use this information to evaluate and refine the Whole Home program?
REQUEST NO.25: On page 5 of its Application, the Company states it only conducted
impact evaluations on the Whole Home and Furnace rebate programs. Does the Company plan
to evaluate the e fficncy of its other programs? If so, please explain how the Company plans to
do this. Please include the Company's plans for evaluating the additions and revisions described
in Exhibit No.7.
REQI}EST NO.26: Please provide all workpapers used to prepare the tables in Exhibit
No. 6 in electronic format with formulae enabled and links intact. Please state all assumptions,
and include calculations showing how Therm Savings and Dollar Savings were computed.
REQUEST NO.27: Please provide all workpapers used to prepare the table on page 9
of Exhibit No. 7 in electronic format with formulae enabled and links intact. Please inctude
calculations showing how the Annual Therm Savings per Rebate in Column (e), the Forecasted
Rebate in Column (d), and the Proposed Incentive in Column (g) were determined.
sEcoND PRODUCTTON REQUEST
TO INTERMOIJNTAIN GAS DECEMBER.23,2OZA4
14DATEI) at Boise,Idaho, this 2- B day of December 2020.
Matt Hunter
Deputy Attorney General
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sEcoND PRODUCTTON REQT,JEST
TO INTERMOT.JNTAIN GAS 5 DECETT,TBER 23,2020
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF DECEMBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMTSSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT.G.2A-06, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LOzu BLATTNER
DIR - REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: lori.blattner@ !r!!!eas.com
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: pr.estgncarter@Si vensourslev.corn
kendruh @ gi venspursley.com
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CERTTFICATE OF SERVICE