20220819Staff 16-21 to INT.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY F'OR A
DETERMINATION OF 2O2I ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
CASE NO.INT-G-22.03
SECOND 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 FRIDAY, SEPTEMBER 9, 2022.
This Production Request is continuing, and lntermountain 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 identi$, the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY
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I AUGUST 19,2022
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. 16: Please provide the criteria that will be used to select the proposed
Conservation Potential Assessment ("CPA") study vendor.
REQUEST NO. 17: Please explain how the Company's internal Evaluation,
Measurement, and Verification ("EM&V") will be used in development ofthe proposed 2023 CPA
study as described in the Annual Report at 13.
REQUEST NO. 18: Please indicate how many whole home incentive applications were
initiated through the Ekotrope software compared to standard rebate applications. How many of
these applications were successfully completed for the 2020 and 2021 program years?
Additionally, please provide a comparison between the number application errors (i.e., non-
qualifuing home, incomplete applications, incorrect or missing information) from Ekotrope
applications versus errors in applications from other avenues.
REQUEST NO. 19: Supplement I at 5 lists the estimated therm savings for each rebate
measure. Please provide the derivation and basis for each value (the therm savings per rebate).
REQUEST NO.20: Annual Report at 12 discusses the Company's estimated therm
savings for the 95% AFUE furnace rebate. The report states that this result (81.I therms) is
relative to a baseline 80% AFUE furnace. Please provide the following:
a. Please provide the underlying data, analysis, and reasoning for the 8l.l therm
savings.
b. Please provide the efficiencies of all the replaced furnaces for 2021 rebate customers.
c. Please explain why the value of 87 therms is used for all the 2021 cost-effectiveness
calculations.
REQUEST NO.21: Annual Report at 3 discusses the Company's plans in the fall of 2022
to o'post a Request For Proposal (RIP) for a CPA study, to update estimated therm savings and
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 19,2022
explore additional energy saving opportunities." Please provide confirmation that the RFP will be
issued and provide a timeline for RFP issuance, receipt of proposals, determination of shortlist,
award of final bid, and completion of study.
DATED at Boise, Idaho, this l9s day of August2022.
(lr^- f\,,rlh
Chris Burdin
Deputy Attomey General
i:umisc:prodreq/intg22.3cbjit prod req 2
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY J AUGUST 19,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF AUGUST 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQT]EST OF THE
COMMISSION STAFF TO INTERMOT,NTAIN GAS COMPAI\IY, IN CASE NO.
INT-G.22-03, 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
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL : prestoncarter@ givenspursley.com
stephaniew@ givenspursley. com
SECRETAR
CERTIFICATE OF SERVICE