20210113INT to Staff 15-27.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
orestoncarter@ gi venspursley.com
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN TIIE MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION FOR A
DETERMINATION OF 2019 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
CASE NO.INT-G.20-06
RESPONSE OF INTERMOUNTAIN
GAS COMPAI\Y TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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lntermountain Gas Company, in response to the Second Production Request of the Idaho
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. 15: Please provide all information collected by the Company that
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.
RESPONSE TO REQUEST NO. 15:
Meeting notes from the EESC meetings provide the best indication that home builders
and HERS raters will participate in the revised Whole Home program (see Exhibit No. 4 Energy
Efficiency Stakeholder Committee Meeting Minutes). The Company proposed an initial revision
of the Whole Home rebate at the September 16, 2020 meeting. The revision proposed at this
meeting removed the ENERGY STAR certification requirement, reduced the rebate amount to
$650 and required a maximum HERS score of 60 (15 points more efficient than the current
program) with specific energy efficiency targets for air change per hour, duct leakage allowances
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and minimum furnace efficiencies. EESC members expressed concern that builders would drop
out ofthe program due to the reduced incentive and aggressive energy efficiency targets.
Home raters and energy code specialists both expressed concern the duct leakage target
alone would be unattainable. One home energy rater estimated that of the 5 builders currently
participating in his region, only I would "probably continue," while the other four would see it
as o'not worth the time." Several participants suggested the Company explore a tiered rebate
structure. Another member recommended the Company allow builders to stack the Whole Home
rebate and water heater and thermostat rebates, as this is not currently allowed.
The Company took into consideration the concems and suggestions of the EESC,
consulted the 2019 Idaho Residential Energy Code Field Study (see Exhibit No. 8), reviewed
upcoming changes in the Idaho Energy Code, worked with ADM Associates, Inc (ADM) to
identiff rebate requirements that would have the most impact on therm savings (see Exhibit No.
8), and sought additional feedback from the EESC.
On October 27, at the second EESC meeting, the Company presented a second draft of
revisions to the whole home rebate that incorporated a two-tier rebate structure. The second draft
relied heavily on the work done by ADM to identitr rebate requirements that would have the
most impact on therm savings and tried to address all of the concerns raised by EESC members.
Both rebates incorporate targets for air changes per hour, duct leakage and furnace efficiency.
The Tier I rebate of $900 also includes a ceiling insulation requirement. For builders that believe
the requirements of Tier t will be too much of a stretch, the Tier II rebate serves as an
introduction to energy efficient building with a $700 rebate and slightly lower efficiency targets.
This second draft also provided an option for builders to layer on water heating and thermostat
rebates. To address an EESC member suggestion that the Company require HVAC systems and
air handlers be placed in conditioned space rather than seffing a specific duct leakage target, the
Company added HVAC system placement as an alternative to duct leakage targets, to arive at
the proposed whole home rebate revision as filed.
The Company has worked to provide a forum for input and feedback. Because home
energy raters work with a very diverse population of builders and are well-versed in both energy
efficiency and "builder speak" they are often in a unique position to be the "the voice of the
builder." While raters cannot necessarily predict the actions of builders, experience has shown
Idaho energy raters have the pulse of residential home builders and provide valuable, candid
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feedback. Code experts, like raters, also have a thorough understanding of current building
practices, gaps or proficiencies in contractor knowledge, and builder attitudes. Intermountain has
excellent representation of raters from across its service territory on the EESC as well as code
experts. The Company considered EESC feedback, studied building code and current building
practices, and attempted to balance efficiency goals, cost-effectiveness, and real-world
circumstances. Intermountain believes it has taken the proper steps to design a rebate that will
incentivize builders to pursue energy efficient home building.
The most observable way for the Company to measure the impact of the revised program
on home builders and home energy raters is by participation levels. The Company will also rely
on feedback from builders, contractors and home energy raters to uncover any unforeseen market
barriers or challenges to participation under this revised rebate structure. The Company will
continue to leverage opportunities to promote the program with builders through the Building
Contractor Association and explore partnerships to provide educational opportunities with
organizations like the Idaho Code Collaborative, Division of Building Safety, and others integral
to the residential building industry.
Record Lori Blattner 208-177-601 5
Sponsor/Preparer:Kathv Wold. 208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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REQUEST NO. 16: Please list all additional requirements beyond the 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.
RESPONSE TO REQTTEST NO. 16:
In addition to the requirement that smart thermostats be wi-fi enabled, Intermountain will
require that the device be ENERGY STAR@ certified. Professional installation in most instances
is not necessary unless the device installation is part of a larger overhaul or rehabilitation of an
HVAC system. Smart thermostats are commonly included in utility marketplace programs with
the intent of customer self-install. Intermountain plans to encourage HVAC contractors to
recommend smart thermostats when installing a fumace. The Company believes pairing the two
appliances and rebates should help maximize the therm savings from installing a new furnace.
For initial cost testing of the smart thermostat rebate, the Company will use the estimated
44 therms of annual savings identified in the Dunsky CPA study. Once Intermountain has
enough smart thermostats installed to create a sample with adequate heating season usage, the
Company will commission a third-party EM&V study to develop a method for measuring
savings related to the smart thermostat rebate.
Record Holder:Lori . 208-377-6015
Sponsor/Preparer:Kathv Wold. 208-377-6128
Location: 555 S Cole Rd. Boise. lD 83707
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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.
RESPONSE TO REQIIEST NO. 17:
Please see CONFIDENTIAL PR#2_17_Dunsky CPA Measure Assumptions for the
source of the smart thermostat annual therm savings.
Record Holder: Lori Blattner. 208-377-6015
Sponsor/Preparer: KathyWold. 208-377-6128
Location:555 S Cole Rd ise.ID 83707
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REQUEST NO. 18: According to the Company, energy savings were determined by
comparing consumption of modeled User Defined Reference Homes ("UDRH") with modeled
consumption for Program Homes. According to the Company (Exhibit No. 5, Page 86), the
UDRH reflects the 2}l2lnternational Energy Code with Idaho's Amendments. Average
consumption of a UDRH home was 923.90 Therms (ExhibitNo. 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 last general rate case (INT-G-l6-02).
RESPONSE TO REQITEST NO. 18:
a. The UDRH represents the minimum allowable energy efficiency building metrics using
the Idaho building code in effect during the program. This method is used to estimate
gross savings. The UDRH aligns with the construction practices observed in new
construction rebated through Intermountain's program and thus is not representative of
building stock as a whole. The UDRH was built to match program-rebated homes in size
and configuration, only adjusting parameters that were higher-than-code in the efficient
case. Due to the difference in builders in the program versus the non-program builder
population, it is not readily apparent that non-program participants are the correct
counterfactual for what the specific program builders would have done without the
program. Using non-program builders as the counterfactual presumes that because one
segment of the home builder market may have advanced the efficiency level of their new
construction without the program, therefore all builders must have done so. The UDRH
method provides a comparison of homes that meet the Intermountain energy efficiency
targets with those same homes built to code. This gross method of calculating therm
savings is consistent with the methods employed by other Idaho utilities in measuring
energy savings in their new construction programs and helps to ensure Intermountain's
program will be able to continue to encourage efficient building among builders that
would otherwise lag behind in energy efficient building.
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b. The average usage per customer settled upon in Intermountain's last general rate case
was based on a whole-territory average. This average includes older single-family homes.
While these older homes are generally less efficient per square foot, they may in many
instances have lower annual consumption per customer because they are significantly
smaller in size than the homes included in Intermountain's Whole Home program. The
Idaho statewide average home size is 1,932 square feet based on Census Bureau data. In
contrast, the homes included in Intermountain's 2019 Whole Homes program are
significantly larger than that at an average 2,388 square feet. The newly constructed
energy efficient home provides important energy savings compared to a similar size
home that is not built to Intermountain's Whole Home program requirements. However,
it is neither fair nor reasonable to compare that energy efficient larger home to the aging
housing stock that makes up Intermountain's total customer base.
Record Lori Blattner. 2O8-177-60 I 5
SponsoriPreparer:Kathv Wold. 208-377-6128Location: 555 S Cole Rd. Boise. lD 83707
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REQUEST NO. 19: Please explain the Company's process for validating the REM/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.
RESPONSE TO REQUEST NO. 19:
REM/Rate is an accredited Home Energy Ratings (HERS) Software that meets the
applicable Mortgage Industry National Home Energy Rating System Standards. The UDRH,
Energy Star, and Program Home consumption estimates are direct outputs from REM/Rate.
ADM did not conduct a per home comparison between simulated consumption and observed
consumption. However, ADM compared the average household heating load and base load from
the simulated outputs with the average household heating load and base load from the participant
billing data. The heating load comparison is provided in CONFIDENTIAL PR#2-19-Heating
Load. The REM/Rate outputs for each of the sampled households is provided in
CONFIDENTIAL PR#2_19_REMRate Outputs. Of the 80 households sampled, ADM was able
to run REMlRate simulations on 68. This was due to unresolvable erors when converting
Ekotrope files, provided by the Energy Raters, to REM/Rate files. The billing data for each home
used in the validation is provided in CONFIDENTIAL PR#2_19_Billing Data. Of the 80
households sampled, the billing data of 59 homes met the criteria to be included in the analysis
conducted by ADM.
Record 208-377-601
Sponsor/Preparer: KathyWold. 208-377-6128
Location:555 S Cole Rd.ID 83707
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REQUEST NO.20: Page 86 of ExhibitNo. 5 explains that the evaluators used the
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 the stratification 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.
RESPONSE TO REQUEST NO.20:
a. The REM/Rate outputs for each of the sampled households are provided in
CONFIDENTIAL PR#2-19-REMRate Outputs. The billing data for each home is provided in
CONFIDENTIAL PR#2_l g_Billing Data.
b. The homes were stratified by program year, then by builder. The number of projects from
each builder was calculated by each builder's contribution to the total number of homes. The
total sample required was estimated using the following formula:
Eguotion A-7 Sample Size Formulo
11.645 *.50r2
"=( .ro J =67.65
Where,
1.645 : Z-score for 90Yo confidence with a two-tailed sample
.50 = Coefficient of variation (standard deviation / sample mean)
.10 = Required precision (+10%)
The Evaluator assumed a Coefficient of Variation of .5 (best practice per the
Califomia Standard Practice Manual).
c. Yes, ADM created a Stratified Random Sample to verifu the Whole Homes Program
households.
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d. A summary of the number of homes built by each builder and the number of homes
sampled from each builder is provided in CONFIDENTIAL PR#2 2O_Homes by Builder.
Record Holder:Lori 208-377-6015
Sponsor/Preparer: KathyWold. 208-377-6128
Location:555 S Cole Rd-se ID *7707
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REQUEST NO.21: In Final OrderNo. 34536 (INT-G-19-04), the Commission stated,
"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?
RESPONSE TO REQIIEST NO.21:
The full text of the relevant section of Commission Order No. 34536 states:
"An areo of specific concern is the Whole Home Program. First, the Company's 204
deemed savings value should be reevaluoted as soon os possible. The deemed sovings
value should be based on a comparison of actual billing datafrom similar new homes
constructed which received the rebate and ones that did not receive the rebate. We feel
the Company now has adequate data to accurately update this value. With an updated
deemed savings value, the Company should hove sfficient information to update this
incentive before the EM&Y study is completed. Second, we are unsure if the HERS
threshold of 75 is still a reasonable thresholdfor the Whole Home Program. Arter the
EM&V study is completed, we encourage the Company to consider modifuing the HERS
threshold of 75 for the Whole Home Program." Order No. 34536 at 5.
The Order also states that "within two months of the Order, the Company shall develop a
plan to have an EM&V study completed for its EE Program." Order No. 34536 at 6. The
Company subsequently filed that Plan on March 20,2020.
The Company had already begun the RFP process to select an EM&V vendor prior to
receiving the Commission Order. Rather than quickly change the Whole Home program in
January of 2020 based on a comparison of actual billing data, and then change the program again
based on the outcome of the EM&V study later that same year, the Company proposed in the
Plan to have the EM&V completed in the Springof 2020 and then work with the Stakeholder
Committee to develop proposed changes to the program to be filed Fall of 2020.
In preparing the EM&V study, the evaluator found that in Idaho, impacts for other utility
programs are estimated as "gross" rather than "net". "Gross" impacts are defined as the savings
value compared to either (l) the preexisting equipment or (2) applicable minimum code. For new
construction, (2) is applicable. When incorporating the billing impacts of non-program new
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construction as the program baseline, this may elevate the baseline above minimum code if new
homes are built above code to a minor degree but below EE Program standards.
Conversely,"net" impacts are defined as those which occur from a program that would
not have occurred without the program and take into account market impacts from naturally
occurring adoption. Inclusion of those parameters in an analysis of Intermountain Whole Homes
impacts places an abnormally high standard not applied to other programs or other utilities in
Idaho and therefore applies an unfairly punitive yardstick when assessing the success of this
program relative to programs administered by other Idaho investor-owned utilities.
Traditionally, the Idaho Commission has remained fuel neutral and has not allowed
utilities to use energy efficiency programs as a tool to encourage fuel switching. If other Idaho
utilities base their Whole Home rebate levels on gross savings, while Intermountain is required
to base rebate levels on net savings, the effect will be a much smaller rebate for a gas home that
is built to very similar energy efficiency standards as those required for an electric energy
effrciency rebate. Therefore, the Company believes it is appropriate to adopt ADM's suggested
use of modeled savings, or "gross" impacts.
Record T.ori Blatfner 208-777-501 5
SponsorlPreparer Kathv Wold. 208-377-6128
Location: 555 S Cole Rd.rD 83707
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REQUEST NO.22: In Section 4.4. I 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
20-point HERS Index range." Given the lack of correlation between this methodology and the
HERS Index, why has the Company chosen to use this same methodology to model energy
savings?
RESPONSE TO REQUEST NO.22:
ADM found that the HERS score itself was not correlated to natural gas savings. This is
because the HERS index is a composite score that combines gas, electric, and water impacts.
However, the simulation output of REM/Rate includes the "Fuel Summary Report" which
specifies impacts by fuel type for a given home. ADM found that the key drivers in therm
savings were not the HERS score itself, rather it was driven by the choices made by the builder
to reach a specified HERS score. This corresponds to ADM's recommendation that
Intermountain have specific gas-savings program requirements as part of its Whole Home
Program rather than relying solely on a HERS score. Savings were found to increase with
specific program requirements such as improved duct sealing, improved envelope/air sealing,
and requirements for effrcient space or water heating equipment. The lack of a relationship
between HERS score and gas savings itself does not directly question the usefulness of
REM/Rate as an analytical tool for gas impacts, but rather the efficacy of a HERS score as the
direct predictor of a single fuel's impact when it is a composite of multiple savings sources.
Record [.ori Blattner )O8,-777-60l 5
Sponsor/Preparer:Kathv Wold. 208-377-6t28
Location: 555 S Cole Rd. Boise. lD 83707
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REQUEST NO.23: According to the Whole Homes billing analysis, the actual average
savings of Energy Star Certified Homes was 57.54 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 Homes program?
RESPONSE TO REQITEST NO.23:
This matter is an extension of RequestNo.21. The 57.54 Therms value compares
Intermountain program homes to non-program homes, which are by and large built by different
builders. As discussed in the Response to Request No. 21, [ntermountain believes it is punitive to
assess the Whole Home program based on net therm savings rather than the gross therm savings
used by other ldaho utility energy efficiency programs. Due to the difference in builders in the
program versus the non-program builder population, it is not readily apparent that non-program
builders are in fact the correct counterfactual for what the specifrc progrom builders would have
done outside of the program. Applying this standard presumes that because one segment of the
home builder market has advanced the efficiency level of their new construction without the
program therefore all builders must have done so. This question is not answerable with current
data, and assuming that the practices of current non-program builders are directly transferrable as
standard practice for program builders (which is what is implicit in the comparison billing
analysis) is potentially damaging to long term efficiency gains in new construction among
builders that would otherwise lag standard practice.
Record Lori B ).08-177-6015
Sponsor/Preparer: KathyWold. 208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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REQUEST 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. 7, page
5). What information will the HERS evaluator provide to the Company, and how does the
Company plan to use this information to evaluate and refine the Whole Home program?
RESPONSE TO REQUEST NO.24:
To address the fact that a lower HERS score does not necessarily correlate with more
therm savings as discussed further in the Response to Request No. 22, the Company proposes
revising the whole home rebate to include specific energy performance requirements identified to
capture therm savings specifically (minimum furnace efficiency, Air Change per Hour (ACH)
limits, duct leakage allowance and ceiling insulation), as outlined in Exhibit No 7.
In order to qualiff for a whole home rebate, however, a HERS certificate must be
provided by a certified HERS rater. A HERS certificate not only provides the HERS score, but
also a oohome feature summary." These features factor in to the final FIERS score. A sample
HERS certificate has been provided for review as CONFIDENTIAL PR#2 24_Sample HERS
Certificate. The specific requirements of the proposed whole home rebate coincide with several
of the home features included on the HERS certificate (the information is highlighted on the
sample certificate): primary heating system, primary water heating, house tightness (ACH), duct
leakage to outside, and ceiling insulation. This will allow the Company to veriff qualification of
a rebate with a single document that is provided by a certified energy rating professional (i.e. the
home energy rater). The Company is not requiring a specific HERS score but is rather using the
HERS documentation as proof by the home energy rater that the home does indeed meet the
energy efficiency targets specified for the whole home rebates.
Continual evaluation and refinement of the whole home rebate will be based on EM&V
and a regular cycle of design-implement-evaluate. The Company has just completed the first full
cycle of EM&V which was: design the current whole home rebate, implement the rebate,
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evaluate the rebate, and use evaluation results to revise the rebate. The Company plans to repeat
this process in order to veriff savings and continually refine and improve the offerings to secure
cost effective therm savings.
Record Lori Blattner- 208-177-501 5
SponsorlPreparer:Kathv Wold. 208-377-6128
Location: 555 S Cole Rd. Boise.lD 83707
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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 efficacy 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.
RESPONSE TO REQUEST NO.25:
Of the current offerings included in Intermountain's program, only fireplaces and water
heaters were not evaluated in the EM&V study. Fireplaces had very low participation resulting in
insufficient data to support a reliable evaluation, per guidance from ADM. Because of the low
participation, Intermountain is proposing that this rebate be discontinued, so there will be no
need to evaluate this rebate in the future.
Based on guidance from ADM, water heaters will be evaluable when there are a
minimum of 300 rebates processed with at least one year of post-retrofit billing data (specifically
comprising summer months). Summer months present a smaller subset of gas loads (water
heating, kitchen equipment) which allows for a better evaluation of water heating savings.
The Company plans to establish a formal schedule of evaluating the rebate offerings
listed in Exhibit No 7. The furnace rebate is the only rebate that remains unchanged. Since all
other rebate offerings are either new or have been revised, the Company will follow the guidance
provided by ADM regarding evaluating water heaters and determine the timing of the initial
evaluation for each rebate based on having sufficient data including both the number of rebates
issued and post-retrofit billing data. Once the initial evaluation is established, the Company plans
to evaluate rebates that remain in the program on a regular 4 to 5-year evaluation cycle.
Record Holder: Lori Blattner. 208-377-6015
SponsorlPreparer: KathyWold. 208-377-6128Location: 555 S Cole Rd-rD 83707
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REQUEST 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'
RESPONSE TO REQUEST NO.26:
Please see PR#2 26_Residential2019 Cost-Effectiveness for the workpapers used to
prepare the tables in Exhibit No. 6.
Record Ho Rlattner-77-6015
Sponsor/Preparer:Barber-77-6199
Location:555 S Cole Rd- B ID 8?707
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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 include
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.
RESPONSE TO REQIIEST NO.27:
Please see PR#2_27f,.esidential202l Plan Cost-Effectiveness for the workpapers used
to prepare the table on Page 9 of Exhibit No. 7. The source for the Annual Therm Savings in
Column (e) can be found on the tab labeled "Planning". The assumptions behind the Forecasted
Rebates in Column (d) are discussed in the text of Exhibit No. 7. The Company used information
from the CPA and EM&V studies as a starting point for the Proposed Incentive in Column (g),
and then used the model provided in this Response to refine the Proposed Incentive until it was
cost-effective.
Record Ho I nd Fllqffner )08,-777-6015
Sponsor/Preparer: LandonBarber. 208-377-6199Location: 555 S Cole Rd. Boise.ID 83707
RnspoNsp oF INTERMoUNTATN Ges CorrapaNy ro SECoND
PRopucuoN REeuesr oF THE CorrrvrssroN Srerr - PacE 19
DATED: January 13,2021
GIVENS PURSLEY LLP
f
Preston N. Carter
Attorneys for Intermountain Gas Company
RBspoNsB oF INTERMoUNTAIN Gas COIcaNY TO SECOND
PnopucnoN Rpeupsr oF TI{E Corrrrr,ttssroN Srarr - PacE 20
CERTIFICATE OF SERVICE
I certiff that on January 13,202I, 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
I1331 W. Chinden Blvd., Bldg. 8, Suite 201-4.
Boise,lD 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, tD 83714
matt.hunter@puc. idaho. gov
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,ID 83702
[e-mail]
dnABbM
Lori A. Blattner
RpspoNsp op INTBRUoLINTAIN Gas Collpauv ro SECoND
PRopucuorq Rpeussr oF THE Comnsslorq Srarp - Pecp 21