20231219Staff 15-24 to INT.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 '
.N
[phone]
IDAHO BAR NO.l1714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor 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 )SECOND 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 TUESDAY,JANUARY 9,2024.
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 informationproduced.
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
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l DECEMBER 19,2023
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.15:In the "Securing an Energy Efficient Future"section of the annual
report,the Company describes three market transformation groups ("Groups"):the Emerging
Technology Program,the North American Gas Heat Pump Collaborative ("Collaborative"),and
the Energy Solutions Center.Please answer the followingquestions regarding these Groups:
a.Please describe how the Company's participation in each Group will produce
natural gas savings for the Company's Idaho customers.If appropriate,please
provide an estimated timeline to realizing those savings;
b.Please describe market barriers the Groups have identified for natural gas heat
pumps;
c.Please explain the different stages of bringing new energy-savingproducts to
market that each Group targets;
d.Please describe the efforts each Group takes to address these market barriers;
e.Please identify any areas of potential overlap between the Group's offerings;
f.Please describe the metrics that each Group uses to track the success of its market
transformation efforts;
g.Please describe the methodology each Group uses to estimate the baseline
adoption of Natural gas heat pumps;
h.Please provide a list of manufacturers and distributors with commercially
available gas heat pumps ("GHPs")in the Company's service territory by target
sector.(e.g.,residential or commercial);
i.Please provide a list of GHP products in development,the estimated timeline to
becoming commercially available,explain how the Groups efforts are
accelerating those timelines;and
j.Please explain how the expenses for each of the Groups are allocated within the
Idaho Rider.
REQUESTNO.16:Please provide workpapers for the minimum allowable net-to-gross
sensitivityanalysis described in Exhibit No.1 at 3.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 DECEMBER 19,2023
REQUESTNO.17:Please provide the analysis performed by the Company to
determine the 95/5 expense allocation ratio.Please provide all supporting workpapers in Excel
format with formulas enabled and intact.
REQUESTNO.18:Please explain if the Company has considered a schedule or
timeline to periodically re-evaluate its expense allocation ratio.
a.If yes,please provide the reasoning and consideration used to determine the
timeline.
b.If not,why not?
REQUESTNO.19:Please explain if the Company's Commercial Energy Saving Kit
program tracks customer participation in the Company's other energy efficiency programs
followingthe deliveryof a kit.
a.If yes,please provide the number of customers that went on to participate in
another offering after receiving a kit.
b.If not,why not?
REQUESTNO.20:Please answer the followingquestions regarding the Company's
participation in the Collaborative.
a.Please provide examples of the Collaboratives efforts in the market research,
engagement with manufacturers,trainingtools for installers,supporting product
specifications areas;and
b.Please list and provide examples of the Collaboratives efforts in traditional market
transformation efforts.
REQUESTNO.21:For all promotional and marketing items in 2022,please answer the
following:
a.Please identify any items which the Company claims energy efficiency savings.
b.Please provide the sources used to quantifythe savings.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 DECEMBER 19,2023
c.Please provide copies of all advertisements paid for by the Company and charged
to the Energy EfficiencyTariff Rider during 2022.
REQUESTNO.22:Please provide copies of all invoices and other supporting
documentation,such as contracts,incentive requests,approvals,and calculations for the
expenses charged to the Energy EfficiencyTariff Rider listed on Confidential Attachment A.
REQUESTNO.23:In reference to the Company's response to Production Request No.
2,please explain how often internal audits are conducted on the Company's energy efficiency
expenses.Please also provide a schedule of any internal audits completed on the Company's
energy efficiencyexpenses includingdates of the audit.
REQUESTNO.24:Please identify if the Company has any internal audits planned for
its Energy Efficiency expenses.Please also identify any criteria used by the Company to
determine if an internal audit should be conducted on a specific department.
DATED at Boise,Idaho,this /day of December 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/INT-G-23-06 PR#2
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 DECEMBER 19,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF DECEMBER 2023,
SERVED THE FOREGOING SECOND 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]
ED JEWELL WIL GEHL
DAPHNE HUANG ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEYS BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE PO BOX 500
PO BOX 500 BOISE ID 82701-0500
BOISE ID 83701-0500 E-MAIL:weehl citvofboise.org
E-MAIL:[e-mail]
eiewell citvofboise.org
dearly cityofboise.org
Ida Elmasian
CERTIFICATE OF SERVICE
INT-G-23-06
Confidential Attachment A
Redacted