20220909INT to Staff 16-21.pdf

' -!i
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 lntermountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMII{ISSION
- n'! / 41-' --L{: 1.: ,-' :--J
IN TIIE MATTER OF TIIE APPLICATION
OF INTERMOUNTAIN GAS COMPANY
FOR A DETERMINATION OF 2021
ENERGY Etr'FICIENCY EXPENSES AS
PRUDENTLY INCURRED
CASE NO.INT.G-22.03
RESPONSE OF INTERMOUNTAIN
GAS COMPAI\TY TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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Intermountain Gas Company ("Intermountain", "Company"), in response to the Second
Production Request of the Idaho Public Utilities Commission ("Commission") Staff to
Intermountain Gas Company dated August 19, 2022, submits the information below. The
requested documents will be provided under the terms of the Protective Agreement.
REQUEST NO. 16: Please provide the criteria that will be used to select the proposed
Conservation Potential Assessment ("CPA') study vendor.
RESPONSE TO REQTIEST NO. 16:
For the information requested, please see fiIe "CONFIDENTIAL PR#2_16 IGC Request
for Proposal2023_CPA". This file is the request for proposal (RFP) the Company will distribute
on September 12,2022.The RFP outlines the criteria on which CPA vendor proposals will be
evaluated.
Record Lori Blattner.?,0*-177-6015
Sponsor/Preparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise. D 83707
RsspoNsp oF INTERMoUNTAIN Ges Cotw.c.Ny ro SECoND
PRopucuoN Rneussr oF THE Covnasslott Srerr - Pecn I
REQUEST NO. 17: Please explain how the Company's internal Evaluation,
Measurement, and Verification ("EM&V") will be used in development of the proposed 2023
CPA study as described in the Annual Report at 13.
RESPONSE TO REQTTEST NO. 17:
The Annual Report at 13 describes the database validation portion of the intemal EM&V
study. This consisted of a series of checks that confirm that the data within the program tracking
sheet are consistent with the Company's billing database as well as extemal data sets including
Ada County Assessor parcel records and Home Energy Rating Scores (HERS) provided by
RESNET. Consultants will likely use several of these data sets to evaluate local building trends,
market barriers, and uptake rates, among other important contributing factors to the resulting
CPA model. Additionally, the selected CPA consultant will be provided a copy of the official
2020Bl&.f.&V study conducted by ADM so those findings may be incorporated into the CPA
analysis.
Record Holder: Lori Blattner.208-377-6015
Sponsor/Preparer:Landon Barber. 208-377-6199
Location: 555 S Cole Rd. Boise. ID 83707
RsspoNsp oF INTERMoT.JNTATN Ges CorvpeNy ro SECoND
PRooucrroN RseuEsr oF Tr{E CorrnrarssroN Srerr - Pacp 2
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- qualifying home, incomplete applications. incorrect or
missing information) from Ekotrope applications versus errors in applications from other
avenues.
RESPONSE TO REQUEST NO. 18:
[n2020, the Whole Home rebate required the home to be Energy Star Certified with a
HERS Index score of 75 or lower. The submission process consisted of a using an excel
spreadsheet or the rebate form (paper or pdfl and is referred to as the conventional method.
Ekotrope submission was not an option at this time. In 2020, there were 1,547 Whole Home
rebates paid. Of those,l2%o required follow up due to incomplete information and l% did not
qualify for the rebate.
Program year 2021was a transition year in which the original Whole Home rebate was
retired and the re-designed Whole Home rebate was implemented effective April l,202l.The
Ekotrope submission process was implemented to facilitate submission and verification of the
more detailed rebate requirements. Although the Company removed the HERS Index threshold
of 75, a HERS rating is still required for the rebate because the HERS rating process verifies all
energy performance targets required under the new Whole Home rebate: air change per hour,
insulation rating, duct leakage and space heating equipment efficiencies.
From April 2021 through December 2021, the Company received 263 Whole Home
rebates: 52o/owere submitted viathe conventional method, and4SYo were received via Ekotrope.
From the rebates submitted via conventional methods, 38% required follow up due to errors or
incomplete information, while only 5%o of those submitted through Ekotrope required follow up.
From January 2022 through lune2022, the Company has receivedTll Whole Home rebates: 5%o
via conventional methods, and95%o via Ekotrope. Less than l% submitted through the Ekotrope
process required any kind of follow up, while 8l% of rebates submitted through conventional
methods required follow up action. Similarly, after accounting for duplicate submissions, less
RrspoNss oF INTERMoLNTAIN Gns CovrpaNv ro SECoND
PRooucroN REeUEST oF THE CovnatsstoN Srarr - Pacp 3
tban lo/o of Ekotope zubmissions did not quafiry @NQ) for the rebate, comparod to a 6% DNQ
rate for those submitted via conventional methods.
R€cord Holder: Lori Blatfirer.208-3774015
Kathv Wold.208-377-6128
Location:555 S Cole Rd,ID 83707
Rrspor.rsE oF INTERMoI NTATN Gls Cowaxy ro sEcoND
PnooucuoN Rneussr or rrr ColrfivtrssroN Srnm - Pecg 4
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).
RESPONSE TO REQUEST NO. 19:
The table below contains data found in the "Cost Engine" tab of "PR#l_l2021
UCT.xlsx". The majority of therm saving metrics are from the2019 CPA conducted by Dunsky
Energy Consultants ("Dunsky"). Dunsky compiled a comprehensive list of potential program
measures along with therm saving values and other underlying assumptions that they tailored to
the Company's service territory. Some of the CPA figures came from the initial measure
characterization file which are listed as Preliminary CPA Figure and the rest were extracted from
the final model and are marked Dunslcy DEEP Model. The Whole Home measure therm savings
come from the EM&V study and supplemental report produced for the Company by ADM
Energy Consultants in2020. The Commercial High-Effrciency Condensing Boiler uses data from
the DEEP Model that is then weighted based on the business types of the actual rebate recipients
in the program
Record Holder: Lori Blattner.208-377-601s
Sponsor/Preparer:Landon Barber. 208-377-6199
Location: 555 S Cole Rd. Boise. tD 83707
RpspoNsp oF INTERMoUNTAIN Gas ColpeNy ro SECoND
PRooucrroN RreuBsr oF THE CovrussloN Srerp - Pecp 5
REBAIE NAME SEGMET{T
A'INUALTHERM
SAVINGSPERUNIT ANNUALIHERM SAVIilGS SOURCE
Whole Home Resldential 274 n20EM&V - ADM ImooctEvoluotion
Combi Radiant Heat Svstem Residential 113 PreliminoN CPA Fioute
7096 Flreplace Residential 10 Dunskv DEEP Model
Water Heater Residential 38 Preliminory CPA Fioure
Residential 55 Dunskv DEEP ModelTankless water Heater
Whole Home I Residential 161 nnEM&V - ADM New llomes Memo
whole Home ll Residential tu nnEM&V - ADM New Homes Memo
Fumace Residentlal 87 Dunskv DEEP Model
Combi boiler Residential 155 Dunskv DEEP Model
Boiler Residential 159 Dunslcy DEEP Model
Residential 38 Preliminorv CPA FioureWater Heater
Tankless I Residential 55 Dunskv DEEP Model
Tankless ll Residential 58 Dunskv DEEP Model
SmartThermostat Residential 44 Dunskv DEEP Model
Condensinc Unit Heater Commercial ffi Dunskv DEEP Model
Commercial t.2t2 Prelimindru CPA FlourcBoiler Reset Control
Hlsh-Eff iciencv Condensi nr Boller Commercial 1.Gt6 Dunskv DEEP Model - Welohted Avo
Frver Commercial $8 Dunskv DEEP Model
Steamer Commerdal 1,03r Dunskv DEEP Model
CommercialGriddle 76 Dunsl<y DEEP Model
Commercial 53 Dunskv DEEP Model - Weidhted AvdESK
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 .l
therms) is relative to a baseline 80%o AFUE fumace. 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 fgp!4g[ furnaces for 2021rebate
customers.
Please explain why the value of 87 therms is used for all the 2021 cost-
effectiveness calculations
RESPONSE TO REQITEST NO.20:
a) Please see the file "PR#2_20 Internal EM&V - Furnace Impact Eval.xlsx".
b) The following table shows the efficiencies of all the replaced furnaces for
program year202l.
RsspoNse oF INTERMoUNTATN Ges CotvpeNy ro SECoND
PRooucrrou Rrquesr oF THE CourarssloN Srnrr -Pnop 6
c
Prior Efficiency
50% AFUE
50% AFUE
55% AFUE
68% AFUE
7Oo/o AFUE
75% AFUE
78Yo AFUE
80% AFUE
85% AFUE
87% AFUE
88% AFUE
89% AFUE
90% AFUE
91% AFUE
92% AFUE
92.L% AFUE
93% AFUE
95% AFUE
96% AFUE
95.5% AFUE
97% AFUE
98% AFUE
99% AFUE
Coal
Electric
oil
New Construction
(Blank)
RsspoNss oF INTERMoT.TNTAIN Gas Cotwexv ro SECoND
PtooucrroN Rpeuesr oF Trm Coutr,ttsstoN Srarr - Pacp 7
Program Year 2021 Fumace Count
2
5
5
I
9
2
4
438
4
3
2
1
346
7
32
1
6
32
53
1
3
3
32
1
2t
1
933
76t
Total 2,704
The Company notes that a significant amount of prior furnace efficiency data has
been unavailable due to the field being left blank on the rebate forms when they
are submitted. In April of 2021the Company enacted several changes
recommended by the 2020BM&V study that made the form more intuitive for
applicants. As a result, blank responses in this field drastically reduced, as
illustrated in the following graph. Accurate data on prior fumace effrciency will
allow for more robust results in future baseline studies.
2021 BLANK RESPONSE RATE
EXCLUDING NEW CONSTRUCTION
70.0%
60.0%
s0.0%
40.0%
30.0%
20.0%
10.0%
0.o%
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
PROGRAM MONTH
c) The annual savings per fumace estimate of 87 therms comes from the 2019 CPA
study conducted for IGC by Dunsky. For all the measures examined in the CPA,
Dunsky tailored the underlying measure assumptions to the IGC service territory
based on factors including building code standards and regional climate. The
Company's initial EM&V on the furnace rebate found widely disparate therm
savings based on the method selected. In response, the Company implemented
revisions to the furnace rebate based on recommendations from the EM&V in an
effort to secure the therm saving forecast in the CPA. The baseline saving
estimate of 8 I . I therms calculated in the 2021 interim EM&V provides strong
evidence to support the continued use of the CPA figure. The Company will re-
examine the fumace therm savings in the upcoming2D24 EM&V.
I nri Elloffnar ?o*,-?17-60.15
Sponsor/Preparer: Landon Barber. 208-377-6199
Location:555 S Cole Rd Boi rD 83707
RpspoNss oF INTERMoUNTATN Gas ColraNy ro SECoND
PRooucrroN REqursr oF THE CovnarssroN Srerr - Pecp 8
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Record Ho
REQUEST NO.21: Annual Report at 3 discusses the Company's plans in the fall of
2022 to "post a Request For Proposal (RFP) for a CPA study, to update estimated therm
savings and 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.
RESPONSE TO REQTIEST NO.21:
The Company will post an RFP for a CPA study on September 12,2022. See file
*CONFIDENTIAL PR#2_l6IGC Request for Proposal2023_CPA" which includes a timeline
for RFP issuance, receipt of proposals, determination of shortlist, award of final bid, and
completion of study.
Record Lori Blattner-208-777-6015
Sponsor/Preparer: Kathy Wold. 208-377-6128
Location: 555 S Cole Rd. Boise.ID 83707
RrspoNsr oF INTERMoLTNTAIN Gas Cotwarsv ro SECoND
Pnooucflor{ Rreussr oF TT{E ColvmnsstoN Srerr - PeoB 9
DATED: S€ptember 9,2W2
GIVENS PI'RSLEY LLP
3?A/''b
Pres0onN. Car,ter
Atlomeys for Intermountaln Gas Company
RrspONSr OF INTERMoI}NTAIN Gns Colpervy To SECoND
PnooucnoN Rnqunsr or rr{E CoMlassroN Srarr - Plcn l0
CERTIFICATE OF SERVICE
I certi$ that on September 9,2022, a true and correct copy of INTERMOTINTAIN GAS
COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF TFIE 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,ID 83714
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-4
Boise,lD 83714
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attomey's Office
150 N. Capitol Blvd
Boise,ID 83701-0500
Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise,ID 83701-0500
Via Electronic Mail
j an.noriyuki@puc. idaho.gov
[e-mail]
ej [e-mail]
bo i sec ityatto mey @city ofbo i se. org
wgehl@cityofboise. org
dnkBllM
Lori Blattner
RpspoNss or INrpRuoLrNTArN Gas Colreuv ro SECoND
PRooucuoN Rrqursr oF THE CoMMrssroN Srerr - PacE I I