960626.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE APPLICATION OF)
INTERMOUNTAIN GAS COMPANY FOR)CASE  NO.  INT-G-96-4
AUTHORITY TO PLACE INTO EFFECT A NEW   )
DEMAND SIDE MANAGEMENT PROGRAM,  )FIRST PRODUCTION
THE ATTENDANT ACCOUNTING PROCEDURES)REQUEST OF THE
TO BE USED IN CONNECTION WITH THE NEW )COMMISSION STAFF
PROGRAM, AND TO MODIFY AN EXISTING   )TO INTERMOUNTAIN
DEMAND SIDE MANAGEMENT PROGRAM,)GAS COMPANY
ALL TO BE EFFECTIVE AUGUST 1, 1996.)
_____________________________________________)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests that Intermountain Gas Company provide the following documents and information on or before WEDNESDAY, JULY 10, 1996.
This Production Request is to be considered as continuing, and Intermountain Gas 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 produced.
Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
REQUEST NO.  1:Please provide copies of any and all contracts and correspondence between Intermountain Gas Company and the Niagara Conservation Corporation.
REQUEST NO. 2:What method or criteria will be used in selecting the initial 10,000 customers for program participation?
REQUEST NO. 3:Please explain how it was estimated that 2,000 customers of the 10,000 contacted will choose to receive the DSM kit.
REQUEST NO. 4:On Page 4 of the application it is stated that Intermountain will expand the proposed DSM program to the “entire pre-1992 residential water heating customer base if customer acceptance of the program is significant and therm conservation reaches the desired levels.”
(a)How does Intermountain know which dwellings were completed prior to 1992?
(b)What is Intermountain’s estimate of the percentage of pre-1992 homes that already have low-flow showerheads?
(c)What is the definition of “significant” customer acceptance?
(d)What is the “desired level” of conservation?
REQUEST NO. 5:
(a)What is the projected cost of the pilot program?  Please provide as much breakout of costs as possible.
(b)What is the expected effect of the pilot program on gas rates and customer bills?
(c)And if the program is expanded, what is the expected effect on gas rates and bills?
(In answering (b) and (c), provide the proposed accounting treatment as well as analysis of costs and benefits to non-participants as well as participants.)
REQUEST NO. 6:
(a)Please provide the Company’s assessment of its Residential Water Heater Rebate Program.
(b)Please explain identified market changes which affect the program?
(c)Please explain why the program should be continued?
DATED at Boise, Idaho, this              day of June 1996.
______________________________________
Scott Woodbury
Deputy Attorney General
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