20220825INT to Staff 1-15.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@gi venspursley.com
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
i,, ;' : I
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY
FOR A DETERMINATION OF 2021
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
CASE NO.INT-G-22.03
RESPONSE OF INTERMOUNTAIN
GAS COMPAI\Y TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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Intermountain Gas Company ("Intermountain", "Company"), in response to the First
Production Request of the Idaho Public Utilities Commission ("Commission") Staff to
Intermountain Gas Company dated August4,2022,submits the information below. The requested
documents will be provided through the Company's secure server under the terms of the
Protective Agreement.
REQUEST NO. 1: Please provide the cost-effectiveness workpapers and calculations for
each energy efficiency program in202l 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.
RESPONSE TO REQUEST NO. 1:
In response to Production Request No. l, please see the file "PR#l_l 2021UCT."
Record Holder Lori Blattner-)0*-777-6015
Kathv Wold 208-177-61)R
Location: 555 S Cole Rd. Boise. ID 83707
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REQUEST NO. 2: Please indicate the evaluation method (i.e., billing analysis or
simulation analysis) used to estimate savings for the Whole Home 1,2, 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
RESPONSE TO REQUEST NO.2:
Following the receipt of Commission Order No. 34980 and Order No. 35313 the
Company studied standard methods of evaluating savings.
The Company's first Evaluation, Measurement and Verification (EM&V) was conducted
by ADM & Associates (ADM, Evaluators). ADM evaluated Whole Home rebate savings by
using two savings evaluation approaches. The energy saving estimate of 274 therms per year for
the retired Whole Home rebate was evaluated using a simulation analysis, also called a deemed
savings approach. ADM also employed a second savings evaluation approach: large-scale
consumption data analysis using billing data (billing analysis). ADM conducted this analysis by
utilizing billing data to estimate savings. The billing analysis revealed a significantly lower
therm saving estimate than the simulation analysis, which was one of the factors considered in
the decision to redesign the Whole Home rebate.
ln a deemed savings approach, savings values are estimates of energy savings of an
installed energy efficiency measure that, one, "has been developed from data sources and
analytical methods that are widely considered acceptable for the measure and purpose," and two,
"is acceptable to the situation being evaluated."l The deemed savings approach is a popular
evaluation approach for several reasons. This is a relatively low-cost approach that also provides
certainty of savings values. Some of this certainty stems from the fact that once agreed upon, it is
"increasingly common to hold the stipulated value constant regardless of what the actual value is
during the term of the evaluation." The agreed-to savings value provides "certainty of savings
values that all parties can rely on for their own purposes."2 The deemed values are "essentially
an agreement between the involved parties," to o'accept a stipulated value or set of assumptions
for use in determining the baseline or reporting period energy consumption."3 SEE Action
1 Energy Efficiency Proeram Impact Evaluation Guide p.4-7
2 lbid. p 4-8
3 tbid. p.4-7
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Energy Efficiency Program Impact Evaluation Guide (SEE) found, the use of deemed savings "is
quite popular for evaluations of energy consumer-funded programs."4 A survey of evaluation
practices in the United States revealed "nearly all states use some type of deemed values in the
evaluation framework."s This is also true for Idaho, as other energy efficiency programs have
relied on resources technical reference manuals for program support. Finally, where the deemed
savings approach relies on stipulated assumptions and algorithms, sources of stipulated values,
such as those found in technical reference manuals, should be based on reliable, traceable and
documented sources of information in any evaluation plan.6
Billing analysis, which is one method to conducting large-scale consumption data
analysis, has its benefits. When a randomized control trial is employed in conjunction with
evaluating billing data, this analysis can achieve more precise results with less bias. In addition,
this approach can also address attribution concerns of free-riders and participant spillover. The
benefit of this analysis comes at a cost, it requires more effort to implement.T For best results,
this approach requires an independent, third-party evaluator to invest in establishing the
treatment and control groups for evaluation. It is also important to employ the proper method for
the evaluation. SEE stated large consumption data analysis methods "are primarily used for
evaluations of residential behavior-based programs, whole house retrofits, and weatherization."s
For this reason, billing analysis may not be the best approach for evaluating savings of a new
construction program. In attempting to determine the proper savings evaluation method, the
Company took into consideration "perhaps the most fundamental evaluation question" according
to SEE:
"How good is good enough? " This question is a short version of asking (l) what level of
certainty is requiredfor energl savings estimates resultingfrom evaluation activities,
and (2) is that level of certainty properly balanced against the amount of effirt (e.9.,
resources, time, money) used to obtoin that level of certainty? "e
a Enerey Efficiency Proeram Impact Evaluation Guide p.4-8
s tbid. p. +-8
6 tbid. p. +-8
7 tbid. p.+-9
8 tbid. p.4-9
s tbid. p. xv
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The Company leveraged the results of both the billing and simulation analysis conducted
by ADM. When the evaluators reported "observable energy savings through billing analysis are
much lower than expected equipment savings," the results of the billing analysis were used to
"identify strong and weak areas of program design," and used to "redesign the program
accordingly."r0 The Whole Home billing analysis was used to redesign the Whole Home rebate.
Evaluators recommended 1) imposing a more stringent HERS Index requirement, 2) removing
Energy Star certification requirement, and 3) directly targeting natural gas savings by imposing
specific requirements such as furnace efficiency, higher insulation and more stringent air sealing
and duct sealing requirements. Two of the three recommendations were implemented in the re-
design of the Whole Home rebate. A more stringent HERS Index requirement was not
implemented due to the fact a lower HERS Index can be achieved through measures that do not
contribute to therm savings. Instead, specific energy performance targets focused on securing
therm savings were implemented.
For the reasons examined here, the Company evaluated the retired Whole Home rebates
paid in 2021 and the Whole Home Tier I and Whole Home Tier II using savings estimates
established in the simulation analysis (deemed savings) conducted by ADM. In regard to the
deemed savings approach, SEE states, "properly used, stipulation can be very useful for program
planning purposes and can reduce M&V costs, create certainty and simplifu evaluation
procedure."ll This evaluation approach will provide the Program a thorough, cost-conscious
approach that lends stability and continuity to a new and developing program.
Beyond the Whole Home rebate and for savings evaluations as a whole, the Company
will continually evaluate internally and in conjunction with experienced, quality third-party
evaluators, that the most suitable savings evaluation approach is employed for each measure.
Record Lori Blattner-208-377-601s
Sponsor/Preparer:Kathv Wold.208-377-6128
Location 555 S Cole Rd. Boise.ID 83707
10 Energv Efficiencv Program lmpact Evaluation Guide p. 5-4
11 lbid.4-9
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REQUEST NO.3: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 202l.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 identifu 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 REQUEST NO.3:
The list of all expenses charged to the energy efficiency tariff rider during 2021is
Confidential and is labeled *CONFIDENTIAL PR#l_3 2021 Expenses".
When reviewing the annual expenses in January 2022The Company discovered expense
reductions that were mistakenly coded to labor expenses for the Energy Efficiency Program in
December 2021. A correcting journal entry was made in January 2022to remove these expense
deductions. Thus, the correction will flow through to the Company's 2022Prudency application.
Record Holder: Lori Blaffner.208-377-60t5
Sponsor/Preparer: Kathy Wold. 208-377-6128
Location: 555 S Cole tD 83707
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REQUEST NO. 4: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for 202I and2022to 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.
RESPONSE TO REQTTEST NO.4:
No internal audits were conducted on the Company's energy efficiency expenses and
processes for202l and2022, to date.
Record Holder: Lori Blattner.208-377-6015
Sponsor/Preparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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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.
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.
RESPONSE TO REQUEST NO.5:
The requested information for employees that charged time to the energy efficiency tariff
rider in 2021is Confidential and included as "CONFIDENTIAL PR#l_s EMPLOYEE
INFORMATION." This file includes anorganizational chart as of the end of the 2021program
year.
A current organization chart as of July 31,2022, is provided in the file
"CONFIDENTIAL PR#l_s ORG CHART 2022." 1n2022, the Company required additional
assistance in rebate processing to stay current on incoming applications. Because Intermountain
did not require a full new FTE, a partnership with the Cascade Natural Gas Energy Efficiency
team was more cost effective than hiring a new employee. Employee Stephanie Reed reports to
Washington Energy Efficiency Manager Monica Cowlishaw. Only Stephanie's time spent
assisting with the Company's rebate processing is charged to the tariff rider.
Record Holder: Lori Blattner.208-377-60ts
Sponsor/Preparer:Kathv Wold. 208-377-6128
Location:555 S Cole Rd. B ID RJ7O7
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REQUEST NO. 6: Please provide a timeline of the Company's Full Time Equivalent
('FTE.) positions for 2019 through 2022 to 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.
RESPONSE TO REQUEST NO.6:
The timeline of the Company's FTE positions for 2019 -2022to date is Confidential and
is included as "CONFIDENTIAL PR#l_6 FTE TRACKING."
All labor charges were allocated by 80/20 split between the residential and commercial
programs.
Record Holder: Lori Blattner.208-377-601s
Sponsor/Preparer: Kathy Wold. 208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
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REQUEST NO. 7: Please provide monthly balances for the energy efficiency tariffrider
balance from January 2021through June2022. Please include monthly revenues, expenses, and
any interest calculations.
RESPONSE TO REQUEST NO.7:
Monthly balances for the energy effrciency tariffrider balance from January 2021
through June2022 are confidential and are included as "CONFIDENTIAL PR#l 7 Tariff
Rider."
When reviewing year-end balances The Company discovered expense reductions that had
been coded to Energy Efficiency Program labor in error in the expenses for December 2021. A
correcting journal entry was made in January 2022 to remove these expense reductions. The
adjusted ending balance displayed on page I reflects what the ending rider balances would have
been at year end had the error not occurred.
Record Lori Blattner.208,-777-6015
Sponsor/Preparer:Kathv Wold.208-377-6128
Location 555 S Cole Rd. Boise.lD 83707
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REQIJEST 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
any 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 $24,500 ($ I 9,600 residential,
$4,900 commercial) increased by $13,500 from the previous rate of $l 1,000 in 2019 and
2020.
b. Please explain all actual energy savings obtained by the Company through participation
in the Collaborative by year.
RESPONSE TO REQITEST NO.8:
Market transformation efforts the Company has invested in can best be categorized as
upstream and downstream activities in gas heat pump (GHP) technology for space and water
heating. To begin, the work of the North American Natural Gas Heat Pump Collaborative
(Collaborative) has primarily focused on activities in the upstream market channel
(manufacturers, distributors, retailers, installers, and codes and standards). While raising
awareness about gas heat pumps with customers will be critical to the success of the market
adoption of gas heat pumps, the Company has been cautious to promote gas heat pumps with
customers too early, as residential gas heat pumps are not yet available to purchase. Residential
gas heat pumps are estimated to be market ready in 2023, but it is the work of the Collaborative
that will be essential to making that market launch successful. Without the upstream markets
ready to deliver on gas heat pumps, from manufacturing and delivering the equipment, to having
educated installers in place, to having agreed upon equipment standards, and ensuring gas heat
pump performance in cold climates, exciting the base about a new technology that fails to arrive
may only serve to set customers up for disappointment. Due to the nature of working with
upstream markets, most of the Collaborative's deliverables are more technically focused. For
example, available on the Collaborative website is the "Gas Heat Pump Water Heater Installation
- Considerations for Installation" document that outlines the benefits of gas heat pump water
heating along with many of the installer type considerations for gas heat pump water heaters.
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Some of the early deliverables and resources provided by the Collaborative are more technical
than most residential customers will want to know about gas heat pumps but are an important
step in making sure the supply chain is in place to deliver the gas heat pumps when they are
commercially available.
The Collaborative thoroughly understands the need to raise awareness and education
about gas heat pumps with customers, the downstream market, as well. The Collaborative just
released a "Stakeholder Guide" with officialtalking points outlining gas heat pump benefits for
customers. This confidential document is provided as CONFIDENTIAL PR#l_8 Talking Points
These kinds of resources will position the Company, both the energy efficiency team and
partners like the Energy Services Representatives, to be able to communicate the benefits of gas
heat pumps effectively and readily to customers, and by also leveraging a collaborative effort,
allow the Company to produce the collateral that will be necessary to educate and promote gas
heat pumps much more inexpensively than would be possible on its own.
The scope of future work includes the following plans:
o manufacturer outreach and engagemento GHP case studieso develop GHP template for technical reference manualso a codes and standards equipment reviewo research and develop partnerships with installers to identify thought leaders
and early adopterso frnalize development of installer support materials
The Collaborative is also in the process of developing a modeling tool to forecast the
potential for gas heat pumps. This tool provides estimates on quantities, savings, emission
reduction and the funding requirements needed to expand incorporate gas heat pumps into
Energy Efficiency program portfolios. The tool will utilize regional data from the US. Energy
Information Agency, Statistics Canada and other publicly available data sources.
a. The annual membership fee for the Collaborative increased by $2,500. The initial
membership fee established at the launch of the Collaborative was $22,000. To provide more
immediate funding to kick-start the Collaborative, membership fees were paid over two program
years. The Company invested $l1,000 in2019, another $l1,000 in2020, and the full amount, of
$24,500 which included a $2,500 increase, was paid in202l.
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b. To date, there have been no energy savings to claim by the Company through
participation in the Collaborative. Traditional market transformation is defined as "participating
in activities to change markets pennanently by making energy efficient equipment and practices
the norm."l2 Although the Collaborative is engaging in these same activities of market
transformation, they are taking a more proactive approach by preparing to "implement
coordinated utility programs when the heat pump products are introduced to the market - which
is different than waiting for a product to appear and then developing a program a few years
later.l3 Several market factors have made clear the need for the natural gas industry to act now,
rather than wait for gas heat pumps to come to market: manufacturer and technology developer's
uncertainty about the gas industry, the role of natural gas in decarbonization, and lessons learned
from the electric heat pump.
The "Gas Heat Pump Technology and Market Roadmap" presented by the Gas
Technology Institute, interviewed manufacturers and technology developers about perceptions
and commitments to GHP technology. Upstream markets found building the business case for
GHP products to be the biggest challenge, especially given the "fear that the 'electrifu
everything' consumer and policy trends will negatively impact the role of natural gas products in
the future.'la Utitity support for gas heat pumps will be critical in sending the message to
manufacturers that there will be a market for the product if they produce it. Finally, the
Collaborative is looking to lessons learned from previous market transformation programs. It is
estimated market transformation efforts for the electric heat pump took l0 years to achieve a
10% market share. The gas industry is looking to "do even beffer and develop gas heat pump
technologies that will be brought to market quickly."ls Bringing advanced gas efficiency and
technology to market in an expeditious manner will be crucial if the gas industry is to save
energy and preserve fuel choice for Intermountain's customers. Through a concentrated,
coordinated effort, the Collaborative is leveraging the energy, resources, and expertise from all
12 https://www.utilitvdive.com/news/market-transformation-movine-bevond-traditional-energv-efficiency-
proerams/557985/
l3 Th" Er"rgence of the North American Gas Heat Pump Collaborative: A Collaborative Approach to lgnite the
Market for Gas Heat Pumps
1a Gas-Heat-Pump-Roadmap-lndustry-White-Paper-Nov20 l9.pdf (eti.enerev) p.24l5 TheEmergenceoftheNorthAmericanGasHeatPumpCollaborative:ACollaborativeApproachtolgnitethe
Market for Gas Heat Pumps
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its members, guided by subject matter expert in market transformation, collaborative
administrator Resource Innovations.
Because gas heat pumps have demonstrated energy efficiency of greater than 100%, they
will be a significant therm saving opportunity for Intermountainos customers in the near future.
lntermountain will continue to explore opportunities for GHP demonstrations and pilot programs
to discuss with its Energy Efficiency Stakeholder Committee.
Record Lori Blattner-208-377-6015
SponsorlPreparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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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.
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
RESPONSE TO REQUEST NO.9:
The Company continues to promote the energy efficiency program with customers
(residential and commercial), contractors, home builders and the community at large.
The Company plans to conduct a Conservation PotentialAssessment (CPA) in2023 for
both the residential and commercial programs. This study will provide insights on under-
performing measures by identifying real or perceived market barriers (equipment availability,
contractor knowledge, awareness) to address the current measures that are not cost-effective and
will explore other energy savings opportunities for residential and commercial customers.
l. Residential -
a. Storage Water Heater UCT:0.9
One known market barrier to the storage water heater is the electrical requirement
for power venting. There is a new high-efficiency water heater on the market that
meets the efficiency requirement and does not require power venting. The
Company has shared this information with the ESR team to help address this
market barrier with customers and contractors. In the April202l program offering
revision, the incentive for the storage water heater was increased from $50 to
$l 15. Since the revision of this rebate (April 2021 through June 2022) the number
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of storage water heater rebates has already matched the number of rebates paid
from January 2018 through March 202l.The Company believes the new
equipment coupled with the increased rebate will make this rebate cost effective
in the next year.
2- Commercial -
The Commercial program remains in an awareness building mode. The Company
continues to promote the new program with commercial customers, contractors,
architects, engineers, and restaurant suppliers. The Company will utilize the
upcoming CPA to evaluate all current offerings and identify opportunities to
redesign or add new measures to the commercial program.
o The Company is working to identiff commercial customers by industry (i.e.
lodging, restaurant, retail) in order to deliver customized communications,
allowing the Company to target the most relevant information to specific
customers (i.e. high-efficiency boilers to schools, and kitchen equipment to
restaurants).
. The ESR team recently communicated that connecting with decision makers and
reaching decision makers at the optimal time of decision is a challenge. Staff on
the customer's site are often not the decision makers for the equipment being
installed. In other instances, equipment decisions have already been made by the
time the customer is discussing starting gas service. The Company will continue
to explore opportunities to reach building architects and engineers, as well as
physical plant and facilities managers to raise awareness with those responsible
for selecting when and what equipment is installed in a facility.
o A customized communication is scheduled to be mailed to all restaurant
customers in the service territory in Fall 2022.These communications will also be
sent to commercial kitchen equipment providers.
a. All measures are not cost effective.
In the case where reasons for slow/no uptake of the rebate or no specific market
barriers have been identified, the Company will plan to use the next CPA study to
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reevaluate the offering, the incentive amount, incentive design or potentially replacing
the rebate with another energy saving measure.
i. Condensing Unit Heater -None
A market barrier has been identified for the condensing unit heater. Unless
the unit is installed outdoors, installation of condensate collection can
present a barrier to adoption or increase installation costs. The Company is
designing a pilot rebate for consideration for a High Temperature High
Ventilation (HTHV) unit heater that meets the current efficiency
requirement but does not require any condensate collection. The Company
plans to present this pilot rebate to the EESC for discussion.
ii. Boiler Reset Control - None
The boiler reset control will be reevaluated in the Company's upcoming
CPA.
iii. High-Efficiency Condensing Boiler UCT:0.8
The high-efficiency condensing boiler will be reevaluated in the
Company's upcoming CPA.
iv. Fryer - UCT:0.3
A recent supply chain newsletter relayed there are significant supply chain
delays for specific brands of restaurant fryers, in some cases as long as one
year. A recent survey revealed restauranters would rather wait for their
fryer than switch brands. This could potentially impact uptake of this
measure.l6
v. Steamer - UCT:0.5
The steamer will be reevaluated in the Company's upcoming CPA.
vi. Griddle - None
16 2022-07-29-TAM-supply-Chain-Update-Vol-3-lssue-7.pdf (enerev-solution.com) p.I
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Record
The griddle will be reevaluated in the Company's upcoming CPA.
Lfnlrlar Tnri Bletfne.r l5
SponsorPreparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
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REQIIEST NO. 10: Please describe all alternatives the Company has explored to
increase uptake of commercial Energy Savings Kits.
RESPONSE TO REQUEST NO. 10:
Since the Energy Savings Kits (ESK) launch on October 1,2021, the Company has
promoted the energy savings kits with commercial customers, commercial industry related
contacts and organizations, and at events with commercial audiences. The Company has always
attempted to highlight that ESKs are a complimentary product to help drive uptake.
Customer emails were sent out two separate times to qualiffing commercial customers
who had'opted in'to receive email communications from the Company. The first email was sent
out on December l,202l,to 9,328 recipients (see PR#l_10 Commercial Customer email
l2.l.2l). This email campaign hada36%o open rate and2.60/o click rate, or2.60/o of recipients
who opened the email, clicked the link to access the ESK application page. The Company
received 38 ESK applications on December l, and I I more applications the following 5 business
days, (Dec 2-8), for a total of 49 applications immediately following the email. The second email
was sent out July 12,2022,to 9,647 recipients and outperformed the previous email campaign
with a 52o/o open rate (see PR#l_10 Commercial email 7.22). The Company received 161
applications on July 12 and an additional 52 over the next 5 days for a total of 213 ESK
applications. In total, the Company sent out 193 Energy Savings kits to qualiffing Commercial
customers. Not only is the energy efficiency program new to commercial customers but
communicating with these customers by email is also new. The increased open rate is an
indication customers are becoming more familiar with receiving communications about energy
effrciency from the Company. Tracking open rates and click thru rates also help the Company to
determine more optimal communication times and messaging that resonates with customers.
"Noisy" marketing times like December may have contributed to lower open rates than July,
along with the newness of the Program. The Company also used bill onserts to promote the free
ESKs. A special QR code and message was included on the bill for the month of October (see
PR#l_10 Commercial bill onsert).
The Company will continue to explore additional ways to promote the Program and
ESKs. The Company is in the process of creating a customized, targeted mailing to restaurants
within the Company's service territory. A list of over 2300 restaurants was purchased in order to
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send a customized mailer to commercial restaurant customers to promote the Program and free
Energy Savings Kits. The pre-spray valve and faucet aerators are especially relevant to restaurant
customers. To be able to further segment commercial customers by sector, the Company is
working to categorize commercial customers by Standard Industrial Class (SIC Code), a four-
digit govemmental numerical code used to identifu the primary business use or classification of
the establishment, such as schools, hospitals, hotels, and office space.
The Company has also reached out to groups and organizations adjacent to commercial
customers to promote ESKs like Idaho Lodging and Restaurant Association, FARE Idaho and
restaurant equipment providers. Kits are featured at the Company's information table at events
with commercial customers such as the ASHRAE (American Society of Refrigerating Engineers)
annual conference and ASHRAE golf tournament. ESKs will continue to be promoted
organically as well. To contribute to this promotion, the Company's Energy Service
Representatives are encouraged to promote the Energy Savings Kits in their daily work. Lastly,
the link to the ESK application page is located on the Commercial Energy Efficiency website,
allowing commercial customers to access the ESK application from the commercial home page.
Record [.ori Blattner-208-777-6015
Sponsor/Preparer:Kathv Wold.208-377-6t28Location: 555 S Cole Rd. Boise. ID 83707
RpspoNsp oF INTERMoLINTAIN Ges CoupaNy ro FrRsr
PRooucnoN REeUEST oF THE CovnarssroN Srarp - Pncs 19
REQUEST NO. 11: 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.
RESPONSE TO REQUEST NO. 11:
a. The Valley Regional Transit (VRT) advertising campaign and Launch into Spring
Sweepstakes were launched and ran simultaneously at the end of March through the start
of May.). Metrics provided by VRT estimated 300,000 impressions per month and the
four buses traveled around Treasure Valley for 9 months resulting in an estimated l0
million impressions. Low participation in the Launch into Spring Sweepstakes provided
valuable lessons in designing customer engagement activities. Low participation was
attributed to requiring too many steps to participate. For future engagement activities the
Company made a concerted effort make participation as simple and easy as possible.
Costs:
velley Regionel Transit ads s +ggs.m 54o.p9gg
Laundr into Spring Sweepstakes $ UZ.U 57O.29080 .
b. The Company ran the Fall Smoker Sweepstakes from October I't through October 31st,
2021. This campaign resulted in2,166 entries and the combined savings calculator and
sweepstake entry page received over 9,000 visits. This surge in traffic on the sweepstakes
entry page also rolled over to increases in traffic on all other energy efficiency pages.
This is reflected in the Responses to Production Requests No. l2 and No. 13. The
Company attributes the high levels of customer participation to the lessons learned during
the Launch into Spring Sweepstakes. For the Fall Smoker Sweepstakes, the Company
emailed over 290,000 customers who subscribe to Company email communications. This
email campaign had an open rate of 42o/o and a click through rate of 35o/o. The click
through rate is a measure of the percentage of customers that not only opened the email,
but also clicked on the link to the savings calculator/sweepstakes entry page.
RTSPONSE OF INTERMOLNTATN GAS COIT,PANY TO FIRST
PnooucuoN REeUEST oF THE CouurssroN SrAFF - Pacp 20
Cost Account Number
Costs:
Fall SmokerSweepstakes S 7v.o7 57tr0.zxr80
c. The Company participated in Parade of Homes in every district across the service
territory. A full-page ad was placed in 6 different Parade of Home magazines (one
Builder Contractor Association hosts two parades). All parade magazines are available in
digital and print versions that are heavily distributed throughout their territory. The full-
page ad contained information on the EE Programs and a QR code that linked readers
directly to the Energy Efficiency web page when it was scanned with a smart device.
Parade of Homes are signature events for the building contractor associations and receive
a lot of foot traffic from the people who live in the region. Below are estimates from
Builder Contractor Association representatives regarding the number of visitors to their
parade homes:
a. Builder Contractor Association Southwest Idaho: 15,000 + visitors
b. Snake River Valley Builder Contractor Association: 2500 t visitors
c. Magic Valley Builder Association: 3,000 - 5,000 visitors
d. Builder Contractor Association of Southeast Idaho: 5300 + visitors
e. Eastern Idaho Homebuilder Association: 9,000 + visitors.
Advertising in the parade of home magazines is an avenue to raise awareness about the
Program and home energy efficiency with home builders, potential home buyers and anyone
interested in viewing new homes. When available, EE staff have hosted an information booth in
the garage of a parade home, allowing them to field questions about the Program and hand out
informational materials. The levels of participation varied from title sponsorships which
promoted the EE Program on all Parade marketing material to in person participation.
Costs:
Pgrade of !9m9s
Parale of Homes Travel
Parade of Homes Lodglng
RrspoNsg oF INTERMOUNTAIN GaS COUPENY TO FrRSr
PRooucrroN Rseuesr oF THE CouutsstoN Srapr-Pacp 2l
I
9
s
8,6Ut.00
47.31
379.:15
574/,,.DM
5521.29080
a
Cost Account NumberCampaign
Account NumberCampaignCost
5522.29(E0
Record Lori Blatfner 2,0*,-771-6015
Sponsor/Preparer:Kathv Wold.208-377-6128
Location:555 S Cole Rd. Boise. ID 83707
RespoNsr oF INTERMoT.JNTAIN Gas CorpeNy ro FrRsr
PnopucnoN RBeussr oF TrrE ComvussroN Srnrr-Peop 22
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.
RESPONSE TO REQUEST NO. t2:
The Company launched the Savings Calculator on October lst of 2021 in conjunction
with the Fall Smoker Sweepstakes. For the month of October, the Savings Calculator and Fall
Smoker sweepstakes entry were combined on one webpage. At the end of the sweepstakes the
calculator was available on a permanent webpage. Web analytics for the savings calculator
specifically can be found in the "PR#l_12 (fall smoker sweepstake)". Web analytics for the time
frame of October 2021 - July 2022 can be found in PR#l_12 October 2021- July 2022. During
the I 0 months that the savings calculator has been operational it has amass ed 9,344 views with
page visitors spending an average of 1.9 minutes on the page. Unfortunately, due to current
technological limitations, the Company has no way of tracking the number of rebates initiated
following customer interaction with the savings calculator. The table below shows the number of
pageviews categorized by month since the calculator's launch in October of 2021. The Fall
Sweepstakes engagement activity was instrumental in driving traffic to the savings calculator,
with the greatest number of pageviews in October.
Pageviews
| _oct-zr sral
Nov-21
Dec-21
lan-22
FebZ2
Mar-22
ler4?
v?Y'4t\n-4
lul-22
RpspoNsp oF INTERMoUNTAIN Gas CorvrpaNy ro Fnsr
PRooucuoN RpeupsroF THE CouulssroN SrAFF-Pacp 23
3l
19
3J
ry_4\l
u
2:!
17 I
RecordHolder: Lori Blather. 208-377-6015
SponsorPreparer:Kathv Wold-208i171-612*
Location:555 S Cole Rd. Boise. ID 83707
RrSpOr*Su OF INTERMOI,JNTAIN GES Colpeuy TOFIRST
Pnooucnou Rneuesr or rlm CorvtrvflssroN SrAFF -PtcE 24
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.
RESPONSE TO REQUEST NO. 13:
Pageviews for the commercial program webpages are listed below. The commercial
program home page was active at the launch of the commercial program April I ,202l.The
energy savings kit application page was launched October 1,2021. The spike in web traffic in
October and December correlates with the promotional onsert in October and the promotional
email sent to customers in December.
Record [.ori Blattner-208-377-6015
Sponsor/Preparer: Kathy Wold. 208-377-6128
Location:555 S Cole Rd.ID R3707
RgspoNse oF INTERMOLINTAIN GES COTWANY TO FIRST
PRooucrroN RseuEsr oF THE Covnalsslol{ Srarp - Pecs 25
132Apr-21
53May-21
6lun-21
Jul-21 57
ArE-2t 62
224
65
trt
Scp2l
Oct-21
ilov-21 5?l5
226 162Dc(-21
L^-22 50 l1
Fcb-22 36 2
Mar-22 50 6
59 7A9r-22
73 l3May-22
74 7Jun-22
Comnrercial Inergy lff iciency Homepdge Inergy Saving Kit Application PageMonth
REQUEST NO. 14: Application at l0-l I 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 S ide Management("DSM ") programs.
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.
RESPONSE TO REQUEST NO. 14:
a. The Company currently updates avoided costs as outlined in Exhibit I of Case No. tNT-
G-21-03:
. The commodity cost component of the avoided cost is updated during Integrated
Resource Planning ("IRP"; years.
o The transportation cost component of the avoided cost is updated annually to
reflect the latest Purchased Gas Adjustment ("PGA") filing.
o Avoided costs are currently filed as exhibits in both IRP filings and annual
prudency fi1ings.
b. The Company has considered making several improvements to the current update
schedule:
o The Company proposes changing the transportation cost from an annual update
schedule to only being updated during IRP years. These updates would reflect the
costs outlined in the most recent regular cycle PGA prior to the IRP planning
year.
o The Company proposes continuing to file all updated avoided cost calculations as
exhibits in each IRP filing. The Company proposes no longer filing avoided cost
calculations as exhibits in annual DSM prudency filings.
o The Company proposes that program planning be completed based on the avoided
costs included in the most recently filed IRP. The cost-effectiveness testing in the
Company's prudency filings would be based on the avoided costs that were in
place at the time of program planning. So, for example, any changes to the
program in calendar year 2023 would be based on avoided costs from the IRP that
RrspoNsp oF INTERMoUNTATN Gas CoupaNy ro Frnsr
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Record
was filed in November of 2021. Cost-effectiveness in the prudency filing for the
2023 progam year would also be based on the avoided costs from the November
2021 IRP filing. The Company will file its next IRP in the fall of 2023, so
program changes in calendar year 2024 would be based on the IRP filing in2023.
The cost-effectiveness in the prudency filing for the2024 program year would be
based on the avoided costs from the fall2023 tRP filing.
[-ori Blattner-208-377-601s
Sponsor/Preparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RsspoNsp oF INTERMOI.JNTAIN GAS COIvlpATW TO FIRST
PRooucttoN Rseupsr oF THE CotrnralsstoN Srerr-Pacs,Z7
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.
RESPONSE TO REQUEST NO. 15:
In response to Production RequestNo. 15, please see the fiIe "CONFIDENTIAL
PR#l_15 2018 CPA Appendix F UCT.'
Record Holder: Lori Blattner.208-377-601s
SponsorlPreparer:Kathv Wold-208-377-6t28
Location: 555 S Cole Rd. Boise.ID 83707
RsspoNss oF INTERMoUNTATN Ges CorrpeNy ro FrRST
PRooucrroN RseuEsr oF THE Corwrrssrou Srarr - PecE 28
DATED: August 25,2022
GIVENS PI.JRSLEY LLP
,,/Lr'-?*>
Preston N. Carter
Attorneys for Intennountain Gas Company
Rnspolusn oF INTERMoI,NTAIN GAS COUNEUV TO FIP.ST
PnooucnoN RseuEsr or rHE CoMMISSIoN Srem - Plce 29
CERTIFICATE OF SERVICE
I certi$ that on August 25,2022, a true and correct copy of INTERMOLTNTAIN GAS
COMPANY'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
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,lD 83714
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,ID 83714
Via Electronic Mail
[e-mail]
chris.burdin@puc. idaho. gov
Jacob Darrington
REspoNsp oF INTERMoUNTATN Ges Cotvrerw ro FrRST
PRooucrroN RreuBsr oF TlrE CourarssroN Srerr - Pecp 30