20240116INT to Staff 25-26.pdf

INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S THIRD PRODUCTION REQUEST PAGE 1 OF 2
18171136.1)
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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 THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF
Intermountain Gas Company (“Intermountain” or “Company”), in response to the Third
Production Request of the Commission Staff to Intermountain Gas Company dated December
26, 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 16, 2024.

By:_____________________________
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company

RECEIVED
Tuesday, January 16, 2024 4:24PM
IDAHO PUBLIC
UTILITIES COMMISSION

INTERMOUNTAIN GAS COMPANY’S RESPONSES TO STAFF’S THIRD PRODUCTION REQUEST PAGE 2 OF 2
18171136.1)
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on January 16, 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
[e-mail]

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
[e-mail]
[e-mail]
[e-mail]

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
[e-mail]

Email
U.S. Mail
Fax
Hand Delivery

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-06
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 25:
Please explain if the Company’s Conservation Potential Assessment (“CPA”) that is
currently underway for the 2023 Integrated Resource Plan will be providing new annual therm
savings estimates from programs without Evaluation, Measurement and Verification (“EM&V”)
results.
RESPONSE NO. 25:
The Company will not be updating annual therm savings estimates for measures that do
not have EM&V results. The CPA is an estimate that is helpful in establishing a measure. Once
the measure is established and has enough history to allow for EM&V, the Company believes it is
more appropriate to use EM&V results to update the therm savings estimates.
The Company prepared a flow chart to help better explain the planning, implementation,
evaluation cycle it is using for energy efficiency. The flow chart is provided in file, PR#3_25
Evaluation Flow Chart.
INT-G-23-06
IPUC Staff PR 25
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-06
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 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 Efficiency Potential Model (“Dunsky DEEP 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 the annual therm savings
amount. If so, please provide that number.
RESPONSE NO. 26:
a.The meeting notes from the September 16, 2020, Stakeholder Committee meeting are
found in the file “PR#3_26_09.16.2020 Stakeholder Committee Meeting Notes.” The
Estimated Useful Life (EUL) provided by Dunsky was 8 years. With this input, the
measure was not cost effective in preliminary program planning cost tests. ADM
recommended using an EUL of 11 years as they had never seen an EUL as low as 8
years for the smart thermostat. There were no objections to this recommendation from
the Committee.
b.The annual therms savings used for cost effectiveness testing for the smart thermostat
was 44 therms per unit and was provided by Dunsky DEEP model.
INT-G-23-06
IPUC Staff PR 26
Page 1 of 1