20240207INT to Staff 29.pdf

INTERMOUNTAIN GAS COMPANY’S RESPONSE TO STAFF’S FOURTH PRODUCTION REQUEST PAGE 1 OF 2
18205034.1)
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
RESPONSE TO FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF
Intermountain Gas Company (“Intermountain” or “Company”), submits the following
response to the Fourth Production Request of the Commission Staff to Intermountain Gas
Company dated January 17, 2024.
DATED: February 7, 2024.

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

RECEIVED
Wednesday, February 7, 2024 2:49:45 PM
IDAHO PUBLIC
UTILITIES COMMISSION
INTERMOUNTAIN GAS COMPANY’S RESPONSE TO STAFF’S FOURTH PRODUCTION REQUEST PAGE 2 OF 2
18205034.1)
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT on February 7, 2024 I caused a true and correct copy of the
foregoing to be served upon the following parties as indicated below:

Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]

Email
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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]

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Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-23-06
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Kathy Wold
REQUEST NO. 29:
In its response to Production Request No. 8, the Company describes conversations with
the University of Idaho’s Integrated Design Lab (“IDL”) exploring small-scale evaluation and
verification studies. Please answer the following questions.
a.Please describe the anticipated Scope of Work for the IDLs evaluation and
verification studies and how it differs from a formal Evaluation Measurement &
Verification (“EM&V”) study;
b.Please describe the anticipated duration of the IDLs involvement in conducting
evaluation and verification studies;
c.Please explain how the Company will verify that these small-scale evaluation and
verification studies are the least cost opportunity;
d.Please describe the incremental value that IDL evaluation and verifications studies
will provide relative to the Company’s in-house capabilities;
e.Please explain if the Company would still conduct EM&V studies on programs
reviewed by IDL and if the Company would change the frequency at which they
conduct EM&V studies; and
f.If the Company were to proceed with IDL small-scale evaluation and verification
study, please provide and explain a proposed timeline for when the Company would
implement, how long the studies would take to conduct, and when the Company
would consult the Company’s EEAG.
INT-G-23-06
IPUC Staff PR 29
Page 1 of 3
RESPONSE NO. 29:
a.In PR#1_8 the Company stated, “The Company has had initial conversations with the
University of Idaho Integrated Design Lab (IDL), who has expressed an interest in and
expertise to conduct small-scale evaluation and verification studies.” The extent of this
exploration was only one conversation. Upon discovering the existence of IDL, the
Company also learned of their expertise and interest in assisting with energy efficiency
evaluation and measurement, especially for the residential sector.
At this time, the Company has not developed, nor anticipated developing, any
kind of scope of work for EM&V with IDL. IDL has stated they are not in the business of
competing with for-profit entities for EM&V business, and the Company has no intention
of replacing formal EM&V with small scale evaluation projects through IDL. Any small-
scale projects were only thought to be supplemental to formal EM&V.
b.There is no anticipated duration of IDL involvement in conducting EM&V studies.
c.The Company did not have a plan on how to verify these small-scale evaluation studies
would be the least cost opportunity, but merely anticipated a small-scale study conducted
by a local subject matter expert would be the least cost opportunity, compared to the
typical scope and breadth of formal EM&V.
d.The Company is a small but mighty team of 3.25 FTE. While team members are well
equipped to conduct a desk review there is no in-house expertise in verifying equipment
through site visits or examining home construction implementation of energy efficiency
measures and building science. This is the incremental value that IDL could provide to
in-house capabilities.
INT-G-23-06
IPUC Staff PR 29
Page 2 of 3
e.The Company will still conduct EM&V studies on all programs, and does not intend to
change the frequency of formal EM&V.
f.The Company will be conducting formal EM&V in 2024, there will be no need to pursue
any small scale studies with IDL at this time, so there is no proposed timeline to
implement, or estimated study duration, or any proposal to bring to the Energy Efficiency
Stakeholder Committee (EESC).
INT-G-23-06
IPUC Staff PR 29
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