20231226Staff 25-28 to INT.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[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 )THIRD 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 Attorney General,requests that Intermountain Gas Company
("Company")provide the followingdocuments and information as soon as possible,but no later
than TUESDAY,JANUARY 16,2024.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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
telephonenumber of the record holder.
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l DECEMBER 26,2023
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.25:Please explain if the Company's Conservation Potential
Assessment ("CPA")that is currentlyunderway for the 2023 Integrated Resource Plan will be
providing new annual therm savings estimates for programs without Evaluation,Measurement
and Verification ("EM&V")results.
REQUESTNO.26:In the Company's response to Production Request No.7 -
Confidential Attachment 1,please explain why the Company used the "EESC Agreement 9-16-
2020"rather than the Dunsky Demand &Energy EfficiencyPotential Model ("DunskyDEEP
Model")as the source for the Estimated Useful Life ("EUL")for the Smart Thermostat measure
as the Company did for all other Residential Segment measures.
a.Additionally,please provide copy of the "EESC Agreement 9-16-2020"the
Company used as the EUL source for the Smart Thermostat;and
b.Please explain if the Dunsky DEEP Model provided an annual therm savings
amount.If so,please provide that number.
REQUESTNO.27:In the Company's response to Production Request No.7 -
Confidential Attachment 1,please explain why the Company used the "PreliminaryCPA Figure"
as the Annual Therm Savings source for the Residential Water Heater measure.
a.Please explain if the Dunsky DEEP Model provided an annual therm savings
amount.If so,please provide that number.
REQUESTNO.28:In the Company's response to Production Request No.7 -
Confidential Attachment 1,please explain why the Company used the "Preliminary CPA Figure"
as the Annual Therm Savings and EUL source for the Commercial Boiler Reset Control measure.
a.Please explain if the Dunsky DEEP Model provided an annual therm savings and
EUL amount.If so,please provide those numbers.
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 DECEMBER 26,2023
DATED at Boise,Idaho,this ay of December 2023.
Duval
Deputy AttorneyGeneral
i:umisc:prodreq/INT-G-23-06 PR#3
THIRD PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 DECEMBER 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF DECEMBER 2023,
SERVED THE FOREGOING THIRD 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 82701-0500BOISEID83701-0500 E-MAIL:[e-mail]
E-MAIL:[e-mail]
[e-mail]
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE