20220930Staff 22-26 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
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUTTE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES 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
THIRD 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 oolntermountain Gas") provide the following documents and information as soon
as possible, but no later than FRIDAY, OCTOBER 14, 2022.r
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
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO TNTERMOUNTAIN GAS COMPANY
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I SEPTEMBER 30,2022
the person preparing the documents. Please also identit, the name, job title, location, and
telephone number of the record holder.
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.22: Please provide examples of how all employees, who charge time to
the energy efficiency tariff rider, track and record their time charged to the rider.
REQUEST NO. 23: In its response to Production Request No. 4, the Company stated;
"No internal audits were conducted on the Company's energy efficiency expenses and processes
for 2021and2022, to date." Please provide an audit schedule for when the Company will
conduct internal audits ofenergy effrciency expenses and processes.
REQUEST NO. 24: Please clariff and list the similarities and differences between the
research and development activities associated with the North American Natural Gas Heat Pump
Collaborative, and the Gas Technology lnstitute ("GTI").
REQUEST NO. 25: In response to Production Request No. 12, the Company stated;
"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." Please
describe the technical limitations that prevent the Company from tracking energy efficiency
website interactions and activities and improvements planned for website analytics.
REQUEST NO.26: Please provide copies of all bids received in response tothe2023
Conservation Potential Assessment ("CPA") Request for Proposal ("RFP"). Please include any
accompanying workbooks or attachments
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 SEPTEMBER 30,2022
DATED at Boise, Idaho, U, TNLday of Se, temb er ZA22.
I
Chris Burdin
Deputy Attorney General
Technical Staff: Kevin KerllQ2-25)
Jason Talford (26)
i:umiscpredro{in@22.3cbjlt prod rcq 3
THIRD PRODUCTION REQIIEST
TO INTERMOI.INTAIN GAS COMPA}.IY 3 SEPTEMBER30,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQTIEST OX' TIIE
COMMISSION STAFF TO INTERMOUNTAIN 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
601 W BANNOCK ST
BOISE ID 83702
E-MAIL : [e-mail]
stephaniew@ g ivenspursley. com
SECRETARY
CERTIFICATE OF SERVICE