20221014INT to Staff 22-26.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: (208) 388-l 200
Facsimile: (208) 388-l 300
[e-mail]
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPAIIY
FOR A DETERMINATION OF 2021
ENERGY EFFICIENCY EXPENSES AS
PRUDENTLY INCURRED
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Attorneys for [ntermountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.INT-G.22.03
RESPONSE OF INTERMOUNTAIN
GAS COMPAI\IY TO THIRI)
PRODUCTION REQUEST OF THE
COMMISSION STAFF
Intermountain Gas Company ("lntermountain", "Company"), in response to the Third
Production Request of the Idaho Public Utilities Commission ("Commission") Staff to
Intermountain Gas Company dated September 30, 2022, submits the information below. The
requested documents will be provided under the terms of the Protective Agreement.
REQUEST NO.22: Please provide examples of how all employees, who charge time to
the energy efficiency tariffrider, track and record their time charged to the rider.
RESPONSE TO REQUEST NO.22:
There are two ways employees who charge time to the energy efficiency tariff rider track
and record their time charged to the rider:
l. Standard Labor Distribution ("SLD") - this does not require time tracking by the
employee. For employees charging time to the energy efficiency rider on a regular or
permanent basis, the SLD is determined by the Energy Efficiency Program manager
and submitted to Human Resources. All subsequent labor and non-labor expenses
related to that employee are automatically calculated based on the SLD.
2. E-serve - timesheet entry. Employees that provide services for energy efficiency on a
project-by-project, or non-regular basis record hours worked for energy efficiency
and charge this time to account number 48526-51l0-29080.
RrspoNsp oF INTERMoLTNTAIN Gas CoupeNy ro rHrRD
PRooucrroN REeUESToF THE CovlIsstoN Srepn-Pace I
Record [.nri Sllqftnp-r )-0*-177-6015
Sponsor/Preparor: Kathy \Mold. 208-3.77-6128
Location: 555 S Cole Rd- Boise.ID 83707
RSSPO}ISr oF INTERMoI,NTIN Ges CoIpeNy To TIIIRD
PnooucnoN Reqursr oF Tr{E CoMMrssroN $1ap-pagp f,
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 2021 and 2022, to date." Please provide an audit schedule for when the Company will
conduct internal audits ofenergy efficiency expenses and processes.
RESPONSE TO REQUEST NO.23:
The department of Internal Audit does not have energy efficiency on the 2022 audit
schedule. The in-house Enterprise lnformation Technology department is in the process of
developing a rebate app to streamline rebate processing. This will be implemented in 2023.The
Company is planning an internal audit of energy efficiency expenses and processes in 2024 to
avoid an audit during implementation and to audit the new rebate process once implemented.
Record Lori Blattner-208-377-601s
Sponsor/Preparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise. ID 83707
RsspoNsr oF INTERMoUNTAIN Ges CotwaNv ro rHIRD
Pnooucuou RreuBsr oF THE ComatsstoN Srerr - Pacp 3
REQUEST NO.24: Please clarifo 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 Institute ("GTI").
RESPONSE TO REQUEST NO.24:
Research and development is the main difference between the North American Gas Heat
Pump Collaborative ("Collaborative") and the Gas Technology Institute (*GTI'). The following
diagram (originally provided by GTI and edited to add references to UTD and the Collaborative),
illustrates the life cycle of research and development being conducted by GTI, from the idea
generation stage to implementation. The steps in the process guided by the member driven GTI
committees Utilization Technology Development ("UTD") and Emerging Technology Program
(ETP) are represented by steps I through 8 in the graphic below. The yellow star represents
where the Collaborative fits in this cycle, which is to say it isn't part of the GTI cycle. The
Collaborative is leveraging the existing research, field demonstrations and equipment testing by
other industry experts, essentially picking up the gas heat pump baton from implementation to
get gas heat pump technology to a stage of accelerated market adoption. The focus of the
Collaborative is making sure that all the research and development work done by GTI and others,
on specifically gas heat pump technology, results in successful and rapid adoption by consumers.
RrspoNsp oF INTERMoITNTAIN G,cs CotvpaNy ro rHrRD
PRooucroN REeUEST oF THE CourvtssroN Srerr - Pecp 4
UTD Mirsion; to "ldentify, sclect, fund, and
oycrsec rescarch projects rcsulting in innovativr
customcr solutlons wtrich maximizc tha
.nvironmcnt!l pcrformancc, rffordrbility,
cfficiency.nd s.lcty of cqulpmcnt and proccrses
usc natural glr lnd rcncwablc Gncrgy tesourccs,"
ETP UTD
ETP activities are "beyond development" stage:
Field Testing, Demonstration, Pilot Programs, and
Deployment - a focused efiort to ensure market
acceptance of next-generation emerging bchnologies
Record [.nri Rlqffner )0*,-777-6015
Kqfhw Wnl.l )0*,-777-61)R
Location 555 S Cole Rd- Boi tD 83707
RrspoNsp oF INTERMoLTNTATN Ges ColeeNy ro rHrRD
PRooucuoN RreuBsr oF THE CorwussroN Srarp - Pecs 5
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REQUEST NO. 25: [n 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.
RESPONSE TO REQTIEST NO.25:
The intent of the savings calculator was to provide an educational tool enabling
customers to estimate the potential savings from installing high-efficiency equipment. In order to
make it as easy to use as possible, and to avoid collecting personally identifiable information
("PfI") for data security reasons, customers were not required to provide information such as
name, phone number, or account number in order to use the calculator. Therefore, in response to
Production Request No. 12, there was not a way to retroactively tie rebates to interactions with
the savings calculator.
Although we were unable to directly tie savings calculator use to rebates, the Company
did see an increase in the number of rebate applicants that cited the bill insert, social media, and
website, all of which promoted the savings calculator, in the month during and months after the
promotion.
2021 "How did you hear about the Program?" Responses
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Pnopucttorq Rseupsr oF THE Cour,ussroN Srerp - Pacs 6
Dec
Record I.rni Blatfner 208-377-6015
Sponsor/Preparer: Kathy Wold. 208-377.6128
Location:555 S Cole Rd^rD 83707
Rrspousr oF INTERMoLTNTAIN Ges Colw.trtv ro rI{rRD
PnooucnoN Rreuesr or fiD Colvfi/trssloN Srarr - Pecs 7
REQUEST NO.26: Please provide copies of all bids received in response to the
2023 Conservation Potential Assessment ("CPA") Request for Proposal ("RFP").
Please include any accompanying workbooks or attachments.
RESPONSE TO REQUEST NO.26:
The RFP for the CPA study was posted on the o'RFPs, RFQs, and RFIs" Community page
of the Association of Energy Services Professionals ("AESP") website. The majority of
responses to previous RFPs were attributed to the AESP community page and for that reason
AESP was again used to reach potential vendors. The RFP was also emailed to l6 vendors
identified as conducting conservation potential assessment studies. One vendor responded they
are "not best placed to assist the firm in the study of conservation potential." Another vendor
submitted an intent to bid, only to later withdraw their intent to bid, citing, "We are simply too
resource constrained - both to prepare the proposal and to perform the work over the coming few
months." Follow up emails sent to two vendors who had worked with the Company in the past
did not elicit additional responses. One vendor has requested a deadline extension to prepare a
proposal. This is due October 14,2022.
Record Ho Lori Blattner-208-777-6015
Sponsor/Preparer:Kathv Wold.208-377-6128
Location: 555 S Cole Rd. Boise.lD 83707
RpspoNsp oF INTERMoLTNTATN Ges CovrpeNy ro rHrRD
PRooucrroN REquEsr oF THE CovurssroN Srlpr - PacE 8
DATED: October 14,2022
GIVENS PI.JRSLEY LLP
,AF&;>
hestonN. Carter
Attorneys for Intermountain Gas Company
RsspoNsp oF INTBRMoUNTATN Gas Colwexv ro rI{IRD
PRooucrroN Rreussr or rHE Cor\ffvrrssroN SrAFF - Pecs 9
CERTIHCATE OF SERVICE
I certifu that on October 14,2022, a true and correct copy of INTERMOUNTAIN GAS
COMPANY'S RESPONSE TO THIRD PRODUCTION REQI"'EST 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,ID 83714
Chris Burdin
Deputy Attomey General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, lD 83714
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney's Offrce
150 N. Capitol Blvd
Boise,ID 83701-0500
Via Electronic Mail
j [e-mail]. gov
chri s.burdin@puc. idaho. gov
ej [e-mail]
boisecityattorney@c ityofboise.org
wgeh l@cityofbo i se.orgWil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise,ID 83701-0500
Jacob Darrington
RrspoNsp oF INTERMoT.TNTAIN Ges CotrlpeNy ro rHrRD
PRooucrrox Rseupsr oF rHE ComurssroN Srarp - Pecp l0