20220804Staff 1-15 to INT.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR A
DETERMINATION OF 2O2I ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
CASE NO.INT-G-22-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
STAFF of the Idaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Chris Burdin, Deputy Attorney General, hereby requests that Intermountain Gas Company
("Company" or "Intermountain Gas") provide the following documents and information as soon
as possible, but no later than THURSDAY, AUGUST 25,2022.
This Production Request is continuing, and Intermountain Gas 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 or information produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; and the name, job title, and telephone number of
the person preparing the documents. Please also identift the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO INTERMOLINTAIN GAS COMPANY
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I AUGUST 4,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide the cost-effectiveness workpapers and calculations for
each energy efficiency program in 2021 in Excel format, with all formulas intact and enabled.
Where applicable, please provide cost-effectiveness calculations before and after program updates
were implemented in spring 2021.
REQUEST NO. 2: Please indicate the evaluation method (i.e., billing analysis or
simulation analysis) used to estimate savings forthe Whole Home 7,2,and the retired Whole
Home program. In the response, please provide detailed support and reasoning for choosing this
evaluation method as directed in Commission Order No. 34980 at7-8, and Order No. 35313 at 5.
REQUEST NO. 3: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2021. Please include the 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.
REQUEST NO. 4: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for 2021 and 2022 to date. If an audit
report was not issued, please provide the date and scope of any audit that may have occurred, and
all internal auditor workpapers.
REQUEST NO. 5: 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.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 4,2022
a. Please include complete job descriptions, required qualifications, salary ranges, bonus
opportunities, and total compensation ranges, including benefits, for all employees
identified in this request.
REQUEST NO. 6: Please provide a timeline of the Company's Full Time Equivalent
("FTE") positions for2019 through 2022to date, showing a month-by-month comparison of FTEs
that charge time to the energy efficiency tariff rider.
a. Please indicate by employee which program residential, commercial, or both the
individual charges their time to. If both, please indicate if charges were allocated by
direct assignment,80120 split, or another method.
REQUEST NO. 7: Please provide monthly balances for the energy efficiency tariff rider
balance from January 2021through June 2022. Please include monthly revenues, expenses, and
any interest calculations.
REQUEST NO. 8: Please describe how the Company is using 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 imy examples of projects,
demonstrations, energy efficiency programs, or collaborations of work or future planned work not
described in the annual report since the Company has joined the Collaborative in 2019.
a. Please explain why the market transformation expense of $24,500 ($19,600 residential,
$4,900 commercial) increased by $13,500 from the previous rate of Sll,000 in2019
and2020.
b. Please explain all actual energy savings obtained by the Company through participation
in the Collaborative by year.
REQUEST NO. 9: Please explain what the Company is doing to address cost
ineffectiveness for the following measures.
l. Residential -
a. Storage Water Heater UCT: 0.9
2. Commercial -
a. All measures are not cost effective.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY J AUGUST 4,2022
i. Condensing Unit Heater - None
ii. Boiler Reset Control - None
iii. High-Efficiency Condensing Boiler UCT :0.8
iv. Fryer - UCT: 0.3
v. Steamer - UCT: 0.5
vi. Griddle - None
REQUEST NO. 10: Please describe all alternatives the Company has explored to increase
uptake of commercial Energy Savings Kits.
REQUEST NO. I l: In the Annual Report, the Company describes a number of marketing
campaigns. Please describe the costs, including the account number(s) and where expenses are
booked, and benefits for each of the following campaigns:
a. Valley Regional Transit ads
b. Launch into Spring Sweepstakes
c. Fall Smoker Sweepstakes
d. Parade of Homes
REQUEST NO. 12: In the Annual Report, the Company describes the addition of a
savings calculator to its energy efficiency website. Please provide the number of times the savings
calculator was accessed, and the number of rebates initiated from customer interaction with the
savings calculator by month since implementation of the savings calculator.
REQUEST NO. 13: In the Annual Report, the Company describes the addition of
webpages for the Commercial Program. Please provide the number of times the new webpages
were accessed by month from implementation through June2022.
REQUEST NO. 14: Application at l0-11 describes how the Company calculates avoided
cost. Please answer the following:
a. Please describe the Company's current practice for updating the avoided cost used for
the Company's Demand Side Management ("DSM") programs.
FIRST PRODUCTION REQUEST
TO INTERMOLTNTAIN GAS COMPANY 4 AUGUST 4,2022
b. Has the Company considered changing how they file updated DSM avoided cost with
the Commission? If so, please describe the new process, or any changes to the current
process, the Company is considering.
REQUEST NO. 15: Please provide a copy of Excel file; IGC_CPA_App F.xlsx which is
listed in Appendix F., Titled: UCT Results by Measure, on page F-l of the Intermountain Gas
Company Conservation Potential Assessment Final Report dated July 2019, as filed in Exhibit 4
of Case No. INT-G-19-07.
DATED at Boise,Idaho, this tltl4 day of August2022
aJU-
Chris Burdin
Deputy Attomey General
i:umisc:prodreq/intg22.3cbiit prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 5 AUGUST 4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPAI{Y, IN CASE NO
INT-G-22.03, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOI.]NTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
stephaniew@ g ivenspursley.com
J, /%.,
SECRETARY //
CERTIFICATE OF SERVICE