20210907INT to Staff 1-11.pdf

GtvENS PunsLEY,,"
Attorneys and Counselors at Law
601 W. Eonnock Strel
POBox2T20
Boise. lD 83701
Telephone: 20&38&1200
Focslmile: 208-38&l 300
www.givenspursley.com
Preslon N. Corler
[e-mail]-Wl222
September 7,2021
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Gory G. Allen
Chodle S. Boser
Chdstophs J. Beeson
Joson J. Blokley
Cllnl R. Bolinder
Jetf w. Bower
Preslon N. Corter
Jeremy C. Chou
Michoel C. Creomer
Amber N. Dino
B.odley J. Dixon
Thomos E. Dvorok
Deboro Kristensen Groshom
Donold Z. Groy
Mon J. Holleron
KeEti H. Kennedy
gizobeih A. Koeckerilz
NeolA. Koskello
Michoel P. Lowrence
Fronklln G. Lee
Dovid R. Lombordi
LoR E. Lundberg
Klmbedy D. Moloney
Kennelh R. Mcclure
Alex P. McLoughlin
Mebdie A. McQuode
Ctvblopher H. Meys
L. Edword Mllletr
Judson B. Montgomery
Deboroh E. Nelson
W. Hugh O'Riqdon, LL.M.
Somuel F. Porry
Rondoll A. Pelermon
Bloke W. Ringer
Michoel O. Roe
Comeron D. Wor
Roberl B. whlte
Mlchoel V. Woodhouse
Williom C. Cole (Of Counsel)
Kenneth L. PuBley (194e2015)
Jomes A. Mcclure {192,t-201 l)
Roymond D. Givens (191 7-2008)
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Re:Intermountain Gas Company
Case No. INT-G-2l-03
Dear Ms. Noriyuki:
ln regard to the above reference Case, enclosed for filing with this Commission are Intermountain
Gas Company's ("Intermountain") Responses to Staffs First Production Requests.
Pursuant to Idaho PUC Rules of Procedure, IDAPA3l.0l.0l.067, 31.01.01.233, and 31.02.01.005.07,
the enclosed information is confidential, proprietary and trade secret information of lntermountain
and is protected by law from public inspection, examination or copying, pursuant to Idaho Code
Sections 74-106, 107, and 48-801 et seq. Intermountain therefore requests that the enclosed
information be protected from inspection, examination or copying by any person other than the
Commissioners and PUC Staff. ln accordance with IPUC Rule 67.02.a, the enclosed information is
marked "Confidential - Trade Secrets" and submitted on yellow paper.
Thank you for your cooperation. If you should have comments or questions regarding this request,
please contact Lori A. Blattner (208-377-6015) or me (208-388-1222).
Sincerely,
I./ * ----:- N 2_ Z**
Preston N. Carter
Givens Pursley LLP
Attorney for Intermountain Gas Company
l,ori A. Blattner
Enclosure
cc:
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@ givenspursley.com
Attomeys for Interrrountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF INTERMOT]NTAIN
GAS COMPAI\IY'S APPLICATION FOR
DETERMINATION OF 2O2O EI\IERGY
EX'I'ICIENCY EXPENSES AS PRUDENTLY
INCURREI)
CASE NO.INT-G.2I.03
RESPONSE OF INTERMOT]NTAIN
GAS COMPAIYY TO FIRST
PRODUCTION REQUEST OF TIIE
COMMISSION STAT'['
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Intermountain Gas Company, in response to the First Production Request of the Idaho
Public Utilities Commission Staffto Intermountain Gas Company dated August 17,2Ozl,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. 1: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2020. Please include date, vendor, amount, a brief description of the expense,
and the account to which the expenses 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 whether 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.
RESPONSE TO REQTTEST NO. 1:
The list of all expenses charged to the energy efficiency tariff rider during 2020 is
Confidential and is included on the Sharepoint site as "CONFIDENTIAL PR#l 2020
Expenses". The Company notes that as it prepared its response to this request it discovered trvo
small amounts totaling $8.01 that were accidentally charged to the energy efficiency tariffrider
RrspoNse oF INTERMoUNTAIN Ges CorrapANy ro Fnsr
PRooucrroN Rneussr oF THE ComarssroN Srenr - P.q,cB I
during the2020 progftrm year. The amounts can be seen on the tab labeled "Acct 5521" of the
file referenced above and are described as "ESR expense to be reversed". The Company is
working with its accounting department to reverse these amounts from the tariff rider during the
2021 program year.
Record Lori Blattner.),oR-777-6015
Sponsor/Preparer:Kodv Thomoson. 208-377-6120
Location:555 S Cole Rd.rD 81707
RespoNss oF INTERMoUNTATN G.r.s CovrpANy ro Ftnsr
PRoouctroN Rsqursr oF THE CouurssroN Sr.q.rr - PecB 2
REQIIEST NO.2: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for 2020 and202l, to date. If no
reports were issued, please provide the date and scope of each audit and all internal auditor
workpapers.
RESPONSE TO REQUEST NO.2:
No internal audits were conducted on the Company's energy efficiency expenses and
processes for 2020 and202l, to date.
Record Holder: Lori Blattrer. 208-377-6015
Sponsor/Preparer:KodvThompson. 208-377-6120
Location: 555 S Cole Rd. Boise. lD 83707
RrspoNsn oF INTERMoUNTAIN G.c,s CoMpA).Iyro Fnsr
PRonucrroN Raeunsr oF THE Colvnatssloll Srarr'- PecB 3
REQUEST NO.3: Please provide a current organizational chart showing all MDU,
Intermountain Gas, and contract employees by title and name who charge time to the energy
efficiency tariff rider. Please include complete job descriptions, required qualifications, salary
ranges, bonus opportunities, and total compensation ranges, including benefits, for all employees
identified in this request.
RESPONSE TO REQLTEST NO.3:
The requested information for employees that charged time to the energy effrciency tariff
rider in 2020 is Confidential and is included on the Sharepoint site as "CONFIDENTIAL
PR#3 Employee Information". This file includes an organizational chart as of the end of the
2020 program year. A current organizational chart as of August3l,202l is included on the
Sharepoint site as *CONFIDENTIAL PR#3_Current Org Chart."
Record Holder: Lori Blatftrer. 208-377-6015
Crais Pullev- 208-377-6167
Location: 555 S Cole Rd. Boise.lD 83707
RespoNss oF INTERMoLNTATN Gns CoprpANy ro Fmsr
PnooucuoN RseuEsr oF THE ComarssroN Srerr - Pacr 4
REQUEST NO.4: Please provide a timeline of the Company's Full Time Equivalent
("FTE") positions for 2019 through 2021 to date, showing a month-by-month comparison of
FTEs that charge time to the energy efficiency tariff rider.
RESPONSE TO REQUEST NO. 4:
The timeline of the Company's FTE positions for 2019 through202l to date is
Confidential and is included on the Sharepoint site as "CONFIDENTIAL PR#4_FTE
Comparison".
As can be seen on the organizational charts provided in response to Request No. 3, the
number of Energy Services Representatives (ESR) charging time to the energy efficiency tariff
rider has increased by two additional ESRs (from 8 to l0). One of the additional ESR positions
was added in Twin Falls district to help cover the sprawling geographical Twin Falls/Sun Valley
region. The other ESR position was added to the Boise district to accommodate unprecedented
Treasure Valley growth.
The increase in ESR positions was the result of increased demand for business
development services, therefore the increased labor costs are borne by the business development
budget. The Energy Efficiency tariff rider now underwrites2D%o of each ESR position, reduced
from25o/o, to keep the ESR FTE count the same as it was before the positions were added. This
structure ensures that each of the l0 ESRs are still handling Energy Efficiency promotional
responsibilities, but recognizes that the need for the additional employees was not driven by the
Energy Efficiency program.
Record Holder:Lori 208-177-6015
Kathv Wold- 208-377-6128
Location:555 S Cole Rd.se- ID 87707
RsspoNsp oF INTERMoUNTAIN Ges CoupANy ro FtRsr
PnooucrroN Reeunsr oF THE CovvtssloN Srerr-PecE 5
REQUEST NO. 5: Please provide monthly balances for the energy efficiency tariff rider
balance from January 2020 through June 2021. Please include monthly revenues, expenses, and
any interest calculations.
RESPONSE TO REQUEST NO. 5:
The monthly revenues, expenses and energy effrciency tariffrider balance are
Confidential and are included in the file on Sharepoint labeled "CONFIDENTIAL PR#s_Taritr
Rider Balance Jan2020 to June 2021". The Company notes that it is not authorized to calculate
interest on the tariffrider balance.
Record T.ori Rlattner 208-777-5015
Sponsor/Preparer: Kody Thompson. 208-377-6120
Location: 555 S Cole Rd. Boise.ID 83707
Rsspol'tsp oF INTERMoUNTATN Ges CorrpAI.Iy ro Fmsr
PRooucrroN ReeuEsr oF THE CouurssroN Sre,rr-P,qcr 6
REQIIEST NO. 6: The Company stated in its Application that it will address avoided
distribution costs following the filing of the 2021 IRP. When does the Company expect to
reconvene the Avoided Cost Subcommittee and address the distribution component of its
avoided cost calculation?
RESPONSE TO REQUEST NO. 6:
The Company believes the IRP will provide the necessary data to inform the calculation
of avoided distribution costs. Intermountain plans to file the IRP in late Fall of 2021. After the
IRP is filed, the Company will reconvene the Avoided Cost Subcommittee to continue the
discussion on the best method for incorporating distribution costs into the calculation.
Record Holder Lori Blattn er - 208-377 -60'1 5
S Kathv Wold 208-777-617*
Location: 555 S Cole Rd. Boise.lD 83707
RrspoNss oF INTERMoUNTATN Ges CorwANy ro FrRsr
PnonucuoN Rneuesr oF THE ComrarssroN Srerr - Pacr 7
REQTIEST NO. 7: Please provide the cost-effectiveness workpapers and calculations
for each energy elficiency prograrn and measure n2020 in Excel format, with formulas intact
and enabled. Please include the workpapers and calculations for both the Simulation Analysis
and the Billing Analysis.
RESPONSE TO REQITEST NO.7:
The cost-effectiveness workpapers and calculatiorur are included inthe file on Sharepoint
labeled *PR#7 2020 UCT & Scenarios".
Record Holder: Lori Blattrer.208-377-60rs
I.andon Rarher-20*,-177-61q9
Location: 555 S Cole Rd" Boise.ID 83707
Rr,spoNse or INrnR[aotnlrArN Gas CoupaNyro FRsr
PnopucrroNReeuesr oF TrrE ComalssroN SrArr-P^q,ce 8
REQUEST NO. 8: On page 6 of Supplement I :2020 Cost-Effectiveness, please explain
why the cost for the Utility Cost Test ("UCT") is different between the Simulation Analysis and
Billing Analysis for each measure. Please provide a reconciliation of the UCT cost between the
Simulation Analysis and Billing Analysis for the Whole Home and Tankless Water heater
measures
RESPONSE TO REQUEST NO. 8:
UCT costs are composed of rebate costs and program delivery and administration costs.
In the UCT model, the program delivery and administration costs are labeled "Allocable
Overhead". Only the allocable overhead expenses vary between the Simulation and Billing
Analyses. The Company allocates its overhead expenses based on the percentage of therm
savings of each rebate to the total therm savings of the portfolio. As described in the Company's
Application, ADM Associates, [nc. (ADM) applied two evaluation approaches to the Whole
Home and Furnace rebates, a Simulation Analysis and Billing Analysis. The two approaches
resulted in different therm saving estimates for these two rebates. As a result, the therm savings
percentages, and thus the allocated overhead expenses, for all rebates are different between the
Simulation Analysis and the Billing Analysis.
For a reconciliation of the UCT costs between the Simulation Analysis and Billing
Analysis for all rebates, please see the calculation of the allocated overhead expenses in the Cost
Calculations section of the "Cost Engine - Simulation" and "Cost Engine - Billing" tabs of the
file "PR#7 2020UCT & Scenarios".
Record Holder: Lori Blattrer.208-377-6015
Landon Barber-208-377-6199
Location: 555 S Cole tD 83707
RsspoNsr oF INTERMoUNTATN Ges CoupANy ro Ftnsr
PRooucttoN Requesr oF THE CotvturssroN Srerr - Pace 9
REQT EST NO. 9: Please describe how the Company is leveraging the market
transformation work of the North American Natural Gas Heat Pump Collaborative
("Collaborative") to promote energy efficiency in the Company's service territory. Please include
examples of projects, demonstrations, energy efficiency progftrms, or collaborations of work or
future planned work since the Company has joined the Collaborative n20I9.
RESPONSE TO REQUEST NO. 9:
The Confidential file on the Sharepoint site labeled "CONFIDENTIAL PR#g_NGHP
Collaborative Achievements UpdateJntermountain Gas 2021" summarizes the recent key
accomplishments of the Collaborative. The market transformation initiatives of the Gas Heat
Purnp Water Heater Committee and the Residential Combi System Committee are outlined along
with the ways Intermountain will be able to utilize this work to promote energy efficiency in the
Company's service territory.
Record I.ori Blattner- 208-377 -601 5
SponsorlPreparer Kathy Wold. 208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
Rrspousn oF INTERMoUNTATN Gls CovrpANy ro Fmsr
PRonucrroN Rrqunsr oF THE CouurssroN Srerr - PncB l0
REQUEST NO. 10: Of the 229 tarkJess water heater rebates administeredin}020,
please provide a breakdown of the rebates administered between new construction, non-
operational equipment replacements, and operational equipment replacements.
RESPONSE TO REQUEST NO. 10:
Intermountain did not collect data on tankless water heater rebates that were new
construction, non-operational equipment replacements, or operational equipment replacements in
2020. The EM&V study performed in 2020 included recommendations to collect this data. The
Company began collection of this data on April l, 2021to coincide with the effective date of the
Energy Efficiency Program update which was approved by the Commission in Case No. INT-G-
20-06, OrderNo.34980.
Although it did not specifically collect this data in2020, the Company estimates that97
of the 229 ta*Jess water heater rebates administered can be attributed to new construction as
these rebates were issued to home builders directly.
Record Holder: Lori Blattner. 208-377-6015
Knrlrr 2 09,-?77-61)O
Location: 555 S Cole Rd. Boise. lD 83707
RrspoNsp oF INTERMoUNTATN Ges CoupANy ro FrRsr
PRooucuoN RseuEsr oF THE CoutvttsstoN Srerr - Pncs 1 I
REQUEST NO. 11: Of the 2,744 furnace rebates administeredin2020,please provide a
breakdown of the rebates administered between new construction, non-operational equipment
replacements, and operational equipment replacements.
RESPONSE TO REQUEST NO. 11:
Intermountain did not collect data on furnace rebates that were new construction, non-
operational equipment replacements, or operational equipment replacements in 2020. The
EM&V study performed in 2020 included recommendations to collect this data. The Company
began collection of this data on April l, 2021to coincide with the effective date of the Energy
Efficiency Program update which was approved by the Commission in Case No. INT-G-20-06,
Order No. 34980.
Although it did not specifically collect this data in2020, the Company estimates that
1,066 of the 2,744 furnace rebates administered can be attributed to new construction as these
rebates were issued to home builders directly.
Record I nri Blqffncr )0*,-777-6015
Sponsor/Preparer: Kody Thompson. 208-377-6120
Location: 555 S Cole Rd. Boise. lD 83707
RrspoNss oF INTERMoUNTATN Ges CoupANy ro Fnsr
PRonucrroN RseuEsr oF THE CouurssroN Srerr-Pace 12
DATED: Scptembcr 7, 2021
GIVENS PI.'RSLEY LLP
/sA. a=d
PrestouN. Carter
Attomcys for Intermormtain Gas Coryany
Rpspor.Er or INreRMorJlmAD.I Gls Coruperwro Fnsr
PnooucmoN RseuFJt oF Trm Comas$oN $16pp-paan 13
CERTTX'ICATE OF SERVICE
I certiff that on September 7,2021, a true and correct copy of INTERMOUNTAIN GAS
COMPAI.IY'S RESPONSE TO FIRST 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
Idatro Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,ID 83714
Dayn Hardie
Deputy Attorney General
Idatro Public Utilities Commission
ll33l W. ChindenBlvd., Bldg.8, Suite 201-A
Boise,ID 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
Dayn.Hardie@puc. idaho. gov
Jacob Darrington
RrspoNsn oF INTERMoUNTATN Ges CorvpANy ro Fmsr
PRooucrrorl Rcqursr oF THE ComarssroN Srerr-P^lcp 14