20231120Staff 1-14 to INT.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL M 59IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SION
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )GAS COMPANY'S APPLICATION FOR A )CASE NO.INT-G-23-06
DETERMINATION OF 2022 ENERGY )EFFICIENCY EXPENSES AS PRUDENTLY )INCURRED )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Intermountain Gas Company
("Company")provide the followingdocuments and information as soon as possible,but no later
than MONDAY,DECEMBER 11,2023.
This Production Request is to be considered as continuing,and the Company 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 identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l November 20,2023
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.
REQUESTNO.1:Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2022.Please include 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 identify 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.
REQUESTNO.2:Please provide copies of all internal audit reports referencing any of
the Company's energy efficiencyexpenses and processes for 2022 and 2023,to date.If no
reports were issued,please provide the date and scope of each audit and all internal auditor
workpapers.
REQUESTNO.3: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,includingbenefits,for all
employees identified in this request.
REQUESTNO.4:Please provide a timeline of the Company's Full Time Equivalent
("FTE")positions for 2019 through 2023 to date,showing a month-by-monthcomparison of
FTEs that charge time to the energy efficiencytariff rider.
a.Please indicate by employeewhich program (residential,commercial,or both)the
individual charges their time to.
REQUESTNO.5:Please provide monthlybalances for the energy efficiencytariff
rider balance from January 2022 through June 2023.Please include monthlyrevenues,expenses,
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 November 20,2023
and any interest calculations.Please include a forecast of the rider balance for the next two
years.
REQUESTNO.6:Please provide the estimated capital and operational and
maintenance costs for the rebate processing application ("rebate app")for the next 5 years.
Please provide supporting workpapers.Additionally,please explain if these expenses will be
booked to the rider account.
REQUESTNO.7:Please provide the cost-effectiveness workpapers and calculations
for each energy efficiencyprogram in 2022 in Excel format,with all formulas intact and enabled.
a.For each measure,please list the source for unit therm savings (e.g.,2019 CPA,
2020 EM&V,2023 CPA,etc.),and,if different,the most recent study completed
for the measure.
REQUESTNO.8:In the Company's 2022 prudence filing,the Commission directed
the Company to use billinganalysis to evaluate the performance of the whole home and furnace
measures.Please describe the changes that the Company has made,or is considering,for these
programs,in the 2023 program year.
REQUESTNO.9:Did the Company conduct a cost-benefit analysis for the rebate app?
If so,please provide it and information including,but not limited to,the expected error
reductions by using the app,any FTE reductions,etc.If the Company did not conduct a cost-
benefit analysis for the rebate app,please explain why not.
REQUESTNO.10:Please explain if any costs associated with the rebate app are
included in this filing.If so,please provide the total amount included.
REQUESTNO.11:In the Annual Report,the Company stated that it utilized the in-
house Enterprise InformationTechnology ("EIT")department for the rebate app development.
a.Please explain how labor from EIT is allocated to the Energy Efficiciencyrider.
Please provide supporting workpapers.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 November 20,2023
REQUESTNO.12:Please explain the driving factors that influenced increased
participation in the Smart Thermostat program.
a.Additionally,please explain how the Company promoted the Smart Thermostat
program in 2022;and
b.Please provide any documentation of promotion or marketing of the program.
REQUESTNO.13:In the Annual Report at 13,Table 5."Rebates Received post
October Customer Engagement"has a total of 3,243 rebates applied for in 2022.The
Application stated the number of rebates paid to residential customers in 2022 was 7,945.
Application at 10.Please explain the discrepancy between the total of rebates applied and paid
for in 2022.
REQUESTNO.14:Please explain the increase of unit "Therm Savings"of 1,036 in
2021 to 1,295 in 2022 for the High-EfficiencyCondensing Boiler.Please provide supporting
workpapers detailing the calculation of program therm savings and individual rebate therm
savmgs.
DATED at Boise,Idaho,this 20th day of November 2023.
MÍchaefDuval
Deputy AttorneyGeneral
i:umisc:prodreq/INT-G-23-06PR#l
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 November 20,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY,IN
CASE NO.INT-G-23-06,BY E-MAILING A COPY THEREOF,TO THE
FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR -REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL:[e-mail]
E-MAIL:[e-mail] [e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE