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Home My WebLink About20240109INT to Staff 18-21_23-24.pdf INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S SECOND PRODUCTION REQUEST PAGE 1 OF 2 18146557.1) Preston N. Carter, ISB No. 8462 Morgan D. Goodin, ISB No. 11184 Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1300 prestoncarter@givenspursley.com morgangoodin@givenspursley.com Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF INTERMOUNTAIN GAS COMPANY’S APPLICATION FOR A DETERMINATION OF 2022 ENERGY EFFICIENCY EXPENSES AS PRUDENTLY INCURRED Case No. INT-G-23-06 INTERMOUNTAIN GAS COMPANY’S RESPONSES TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Intermountain Gas Company (“Intermountain” or “Company”), in response to the Second Production Request of the Commission Staff to Intermountain Gas Company dated December 19, 2023, submits the following responses. Responsive documents are available for download using the link provided in the accompanying email. Confidential responses and documents are subject to the protective agreement in this case, and are available for download using a password-protected link that will be provided separately by email. The password will be provided in a third email. DATED: January 9, 2024. By:_____________________________ Preston N. Carter Givens Pursley LLP Attorneys for Intermountain Gas Company. RECEIVED Tuesday, January 9, 2024 12:13:55 PM IDAHO PUBLIC UTILITIES COMMISSION INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S SECOND PRODUCTION REQUEST PAGE 2 OF 2 18146557.1) CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT on January 9, 2024 I caused a true and correct copy of the foregoing to be served upon the following parties as indicated below: Monica Barrios-Sanchez Interim Commission Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-0074 monica.barriossanchez@puc.idaho.gov Email U.S. Mail Fax Hand Delivery Ed Jewell Daphne Huang Deputy City Attorneys Boise City Attorney’s Office PO Box 500 Boise, Idaho 83701-0500 ejewell@cityofboise.org dhuang@cityofboise.org boisecityattorney@cityofboise.org Email U.S. Mail Fax Hand Delivery Wil Gehl Energy Program Manager Boise City Department of Public Works PO Box 500 Boise, Idaho 83701-0500 wgehl@cityofboise.org Email U.S. Mail Fax Hand Delivery Preston N. Carter INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold REQUEST NO. 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 no, why not? RESPONSE NO. 18: a.Yes, the Company re-evaluates the expense allocation ratio annually. In December 2023, the Company will review sales starts as reported in Construction Tracking and will base the 2024 allocation on this information. All 2024 expenses that cannot be direct assigned will be allocated between the residential and commercial program based on this allocation ratio. INT-G-23-06 IPUC Staff PR 18 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kody Thompson / Kathy Wold REQUEST NO. 19: Please explain if the Company’s Commercial Energy Saving Kit program tracks customer participation in the Company’s other energy efficiency programs following the delivery of 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 no, why not? RESPONSE NO. 19: The Company did track customer participation in the Commercial Energy Saving Kit program with other energy efficiency program participation. a. An analysis on the Commercial Energy Savings Kit found that, through third quarter 2023, one address that received a kit went on to participate in another rebate offering. There was an additional address that received a fryer rebate in 2021 that received a Commercial Energy Savings Kit in 2022. b.N/A INT-G-23-06 IPUC Staff PR 19 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold REQUEST NO. 20: Please answer the following questions regarding the Company’s participation in the Collaborative. a.Please provide examples of the Collaboratives efforts in the market research, engagement with manufacturers, training tools for installers, supporting product specifications areas; and b.Please list and provide examples of the Collaboratives efforts in traditional market transformation efforts. RESPONSE NO. 20: a.Examples of the Collaborative’s efforts in market research, engagement with manufacturers, installer training tools and product specifications are outlined in PR #15, part c. Collaborative materials have also been provided in file PR#2_20 NAGHP Collaborative Materials. b.Collaborative efforts are outlined in PR#15, part c. The market transformation activities undertaken by the Collaborative are traditional market transformation activities. The Collaborative’s approach is non-traditional only from the sense that the natural gas industry is engaging in these activities now, before GHPs are on the market, rather than waiting for a product and then trying to accelerate adoption. It is estimated that electric heat pumps sat on retailer shelves for 10 years with millions of dollars invested in market transformation efforts before reaching a 10% market share. GHP technology has been proven, is in production and will avoid the delay in INT-G-23-06 IPUC Staff PR 20 Page 1 of 2 adoption by preparing a “landing pad” in the market for GHP technology. Accelerating GHP technologies into the market now, quickly and widely, will ensure that customers have a choice of fuels in their homes and businesses that provide comfort, performance, reliability, and savings. INT-G-23-06 IPUC Staff PR 20 Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold REQUEST NO. 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 quantify the savings. c.Please provide copies of all advertisements paid for by the Company and charged to the Energy Efficiency Tariff Rider during 2022. RESPONSE NO. 21: a.The Company conducted a limited pilot program (350 kits) of the Commercial Energy Savings Kit to raise awareness about the launch of the commercial energy efficiency program. This is the only promotional item the Company claimed estimated savings. No savings are claimed on any other promotional item. b.The Dunsky CPA was the estimated savings source used for the Commercial Energy Savings Kits. c.Samples of all advertisements paid for by the Company and charged to the Energy Efficiency Tariff Rider during 2022 are provided in file “PR2_21 Promotional Materials.” The 2022 Residential Ad was placed in the Building Contractor Association (BCA) Parade of Homes Magazine in the 5 regional BCAs throughout the service territory. There is no active BCA in Wood River Valley so this ad was also placed in the Sun Valley Mountain Express publication. This ad was also placed in the Idaho Statesman Treasure Valley Magazine. INT-G-23-06 IPUC Staff PR 21 Page 1 of 2 The IGC Energy Out West ad was placed in the Energy Out West conference which is an organization devoted to the advancement of knowledge and practice in the field of weatherization. The Idaho BOL ad was placed in the Idaho Business Review year-round publication “Book of Lists.” The Company’s ad was placed in the construction section, targeting general contractors, architects, engineers, and HVAC. INT-G-23-06 IPUC Staff PR 21 Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kellie Erhardt/Kathy Wold REQUEST NO. 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 efficiency expenses including dates of the audit. RESPONSE NO. 23: The Company has not completed any internal audit of the Energy Efficiency Expenses. INT-G-23-06 IPUC Staff PR 23 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-23-06 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Kellie Erhardt/Kathy Wold REQUEST NO. 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. RESPONSE NO. 24: The Company’s Internal Auditing Department is not planning any Energy Efficiency Expense audits for 2024. Annually the Company’s Internal Audit Department prepares an independent, objective, risk-based audit plan. Internal Auditing management: prepares risk assessments (Information Technology and Operating Company) consults with Company management and Audit Committee members, discussing risks and potential risk-related audit projects prepares a proposed audit plan based on estimated resources to be discussed with Company Executive Management to obtain feedback presents the proposed audit plan to the Company’s Audit Committee for approval updates the approved audit plan during the year if changes are warranted (external or internal conditions may change Company objectives and/or risks) VEO-W-23-04 IPUC Staff PR 24 Page 1 of 1