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HomeMy WebLinkAbout20170915Comments.pdfDAPHNE HUANG DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 IDAHO BAR NO. 8370 IN THE MATTER OF THE APPLICATION OF INTERMOUNTAIN GAS COMPANY TO IMPLEMENT A DEMAND SIDE MANAGEMENT PROGRAM F'UNDING MECHANISM AND CHARGE I ' a', t,1 r A Street Address for Express Mail: 472 W , WASHINGTON BOISE, IDAHO 83702-5918 Attorney for the Commission Staff BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) CASE NO. INT.G.17.O3 COMMENTS OF THE COMMISSION STAFF COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Daphne Huang, Deputy Attorney General, submits the following comments. BACKGROUND On July 27,2017,Intermountain Gas Company asked the Commission for authority to implement a Demand Side Management (DSM) Program Funding Mechanism and DSM Charge. Although the Commission has yet to formally accept a tariff filing from the Company, adraft tariff was submitted as an exhibit during the Company's recent rate case, in which the Commission authorized the Company to implement a residential DSM program. Order No. 33757 at37-38. Intermountain asks that its Application be processed by Modif,red Procedure, and requests an effective date of October 7,2017 , to coincide with the requested effective date for its annual Purchased Gas Cost Adjustment filing. 1 t/n) STAFF COMMENTS SEPTEMBER 15,2017 "DSM" generally refers to utility activities and programs that encourage customers to use less overall energy, either through efficiency programs or peak load control measures. The Commission authorized the Company to implement a DSM program, finding that "DSM, as both a least-cost resource and an important element of promoting energy efficiency, is an important part of any utility's provision of service." OrderNo. 33757 at37; see Applicationat2. The Company seeks "to define and formalize amechanism whereby the Company can recover costs incurred in the administration and delivery of its Rate Schedule DSM Energy Efficiency" and submits a proposed budget for recovery. Application at 3. The Company states that its costs for administering its DSM program may include energy efficiency program rebates; administration ramp-up expenses and incremental staffing; DSM outreach; local support for promotion of tariff-approved DSM measures; and encouraging market transformation through adaptation of energy efficiency technologies. /d The Company reports that all DSM activities are designed for its residential customers. .Id The Company proposes a recovery mechanism in which it submits its "annual budget of anticipated administrative and program costs related to the Company's DSM program." Id. In its annual filing, the Company will request the Commission's ruling that its "expenses are both reasonable and prudent." 1d Also, the Company's budget will include "any surplus or deficit associated with the collection of DSM funds and the incurrence of DSM-related expenses." 1d. Program Budget The Company's proposed2}lT-2Ol8 DSM budget totals $777,000 which includes $600,000 in rebate expenses, $147,000 in personnel expenses, and $30,000 in program delivery and ramp-up expenses. Staff finds the proposed budget to be reasonable for the expenses associated with a new program limited to residential customers. 2STAFF COMMENTS SEPTEMBER 15,2017 STAFF ANALYSIS Staff has reviewed the Company's Application and accompanying exhibits. Based on its review, Staff supports the Company's DSM funding requirements and proposed tariff rider charge. In the comments below, Staff addresses the Company's DSM funding, program structure, accounting methods, reporting requirements, and customer considerations. The Company's proposed DSM tariff rider amount is calculated by dividing the $777,000 budget by Rate Schedule RS 21 1,957,936 normalized 2016 therm sales to arrive at a surcharge of $0.00367 per therm. This is approximately $0.22 per bill for an average customer using approximately 61 therms per month. Staff notes that because the tariff rider rate is calculated based on 20 I 6 normalized therm sales, customer growth that occurr ed in 2017 will likely provide additional revenue over what the Company has forecasted. All DSM funds collected will be allocated to costs incurred in the administration and delivery of its proposed DSM program, and accounting records will be maintained to track actual expenses versus the DSM tariff rider amount collected from residential customers. Any over-collection of DSM funds will be used to offset future expenses or returned to customers. The Company proposes a recovery mechanism in which it submits an annual budget of anticipated administrative and program costs. As part of that filing, the Company will request the Commission's ruling that its expenses are both reasonable and prudent. Also, the Company's budget will include any surplus or deficit associated with the collection of DSM funds and the incurrence of DSM-related expenses. While Staff recognizes the need for periodic filings to review the Company's programs and determine the prudency of program expenses, Staff does not believe that review constitutes advance prudency or expense approval. Staff also does not believe that annual filings are necessary for adjusting the DSM tariff rider rate. Instead of mandated, automatic reviews each year, Staff believes it is reasonable for the Commission to allow the Company to file revisions to its tariff rider at any time deemed necessary and appropriate. Staff recognizes that in its ramp up stages, the tariff rider rate may need to be adjusted more frequently as the Company's programs expand to include additional residential measures, as well as measures for general service and large volume customer classes. Program Structure The Company's supplemental filing in this case included its tariffs which defined the proposed measures and rebate amounts. As shown in Table 1 below, these are the same measures and rebate amounts the Company proposed in its recent rate case, INT-G-16-02. The Company proposes two tiers; Tier One incentives apply when customers install high-efficiency natural gas equipment and Tier Two incentives apply when customers install high-efficiency equipment when they convert to natural gas for water or space heat. The measures in both tiers are identical, but Tier Two incentives are higher than Tier One incentives. Additionally, Tier JSTAFF COMMENTS SEPTEMBER I5,20I7 Two includes an incentive for new-construction Energy Star Homes with natural gas water and space heating. Table 1: Company Proposed Measures/Incentives Staff witness Donohue expressed concern about Tier Two incentives on pages 9 - 12 of her direct testimony in Case No. INT-G-16-02. To summarize,the Company's cost- effectiveness calculations show that except for the higher incentive cost, Tier Two measures have the same measure costs and energy savings as Tier One measures. The Company claims that the higher incentive amount for Tier Two is intended to address the additional cost of fuel conversions, but the cost ofthe fuel conversion is not included in the cost-effectiveness calculations. Staff believes that if the measure costs and energy savings are the same, then the 4 Whole Home Package (for new construction) Description Rebate Amount Energy Star Certified Home Energy Star Verified Home with Natural Gas Space and Water Heat $1200 Stand Alone Measures (new & existing construction) Description Tier One: Energy Efficiency Rebate Tier Two: Direct Use Rebate 95% AFUE Natural Gas 95Yo or Greater Thermal Efficiency Rating $350 $s00 High Efficiency Combination Radiant Heat System 90Yo or Greater Efficiency Condensing Tank-less Combo System for Space and Water Heat $1000 $1200 80% AFUE Natural Gas Fireplace Insert 80% AFUE Rating or Greater $200 $2s0 70%FE Natural Gas Fireplace Insert 70%FE Rating or Greater $100 $200 .67 Natural Gas Water Heater 67 Energy Factor or Greater $50 $7s .91 EF Condensing Tank-less Water Heater .91 Energy Factor or Greater $ls0 $200 STAFF COMMENTS SEPTEMBER 15,2017 incentive amounts should also align. Staff also points out that three of the seven proposed Tier Two measures are not cost-effective due to the higher incentive amount.l Staff acknowledges that Order No. 33757 reads, "Accordingly, we find it reasonable to authorize the Company to implement its proposed DSM program, recognizing that the Company represents that this program will be used as a starting point from which to develop more robust DSM offerings. We look forward to seeing the program develop." Order at37. However, Staff notes that the Commission Order did not discuss or specifically support either the Company or Staff s position on Tier Two incentives. Therefore, Staff respectfully requests that the Commission clarify its direction on Tier Two incentives. As part of its clarification, Staff recommends that the Commission direct the Company to consolidate its incentives into a single tier at the Tier One incentive level and retain the proposed incentive amount for the Energy Star Homes measure. Staff points out that under this proposal, customers who convert to natural gas space or water heat will still be eligible for incentives when they install high-efficiency equipment. Since all of the same customers will still be eligible for incentives, Staff does not believe that consolidating the tiers will have a detrimental impact on the cost, participation, or cost-effectiveness of the DSM program. In addition, Staff is willing to work with the Company to improve its cost-effectiveness calculations so that Staff could potentially support a proposal for Tier Two incentives in the future. Accounting Treatment Staff met with the Company and discussed the accounting treatment used to establish a balancing account for the energy efficiency program expenses and tariffrider revenues. Staff believes that tariff rider revenues should be calculated and booked independently from the Company's normal sales revenue, expenses should be tracked separately from the Company's Operations and Maintenance (O&M) expenses, and a mechanism should exist to separate labor related expenses, promotional expenses, rebates, and other energy efficiency program related expenses. Through discussions, the Company proposes to record all costs to a Business Unit which will be incorporated into Intermountain's Regulatory Department. Detailed cost segregation will I See INT-G-16-02, Spector Exhibit 26. On the table titled "Direct Use Rebate Under Utility Cost Test," the "UCT with Program Admin Costs" column shows that three of the seven proposed measures exceed the cost-effectiveness threshold of $0.53 I 82. 5STAFF COMMENTS SEPTEMBER 15,2017 be facilitated by charging all program expenses to a sub-account of FERC account 908 - Customer Assistance Expense. To facilitate non-labor expense reporting, unique work orders will be used to track rebates, promotional expenses, and other program expenses. Revenues generated from the Energy Efficiency Charge will be deferred to a Regulatory Liability account (FERC 254). Deferred revenue will be reclassified monthly to Retail Revenue and then used to offset the expenses as they are incurred. Staff believes the proposed accounting treatment will accommodate the requirements for maintaining a balancing account for the energy efficiency programs' revenues and expenses. Reporting Requirements and Prudency Determinations Staff discussed reporting with the Company and recommends that the Company provide a quarterly update on the year-to-date status of the balancing account which would include monthly revenues, monthly expenditures, and number of rebates issued by measure. Staff anticipates that this brief update will be emailed to interested stakeholders and would help inform decisions about the need to adjust the tariff rider amount. In addition, Staff recommends that the Company convene interested stakeholders in person twice ayear to provide an opportunity for the Company to answer questions and to solicit feedback. Staff supports the Company's commitment to file an annual DSM report to document program performance. This report should include a summary of cost-effectiveness, expenditures, participation (number of rebates issued), and program implementation methods for each of the incented measures. These annual reports will be used to determine the reasonableness of the Company's expenditures when the Company files for prudency, which Staff anticipates will happen at least every two years. These recommendations are consistent with reporting standards in place for other utilities. However, Staff has deliberately streamlined the reporting requirements so that it does not unduly interfere with the program's start-up phase. Tariff Revisions Staff has worked with the Company to revise the proposed Rate Schedules DSM and DSM Charge submitted as part of the Company's Application. Revisions were made primarily to clarify and simplify these Schedules as shown in Attachment 1. With the exception of Tier Two incentives, it is Staffls understanding that the Company agrees with the proposed changes. 6STAFF COMMENTS SEPTEMBER 15,2017 The first change is to rename the schedules. Staff recommends changing the Company's proposed "Rate Schedule DSM" to "Rate Schedule EE" and the proposed "Rate Schedule DSM Charge" to "Rate Schedule EEC." These changes were made to more clearly reflect the program's focus on energy efficiency. Another change was made to remove the term "standard efficiency" in the program description of the proposed Rate Schedule DSM. The Company's proposed Schedule does not define the term and Staff notes that what is considered "standard efficiency" may change over time. Removing the term "standard efficiency" makes it easier for customers to understand who qualifies for the equipment incentives specified in the Schedule. Staff does not anticipate that this change will impact program savings. Staff recommends the Company maintain detailed records regarding replaced equipment in order to monitor and address any issues that might si gnifi cantly affect pro gram co st- effectivene s s. In addition to revising the two proposed rates schedules submitted as part of the Company's Application, Staff worked with the Company to revise language in its existing Rate Schedule RS to reflect the Company's proposed Rate Schedule DSM Charge. Staff worked with the Company to clarify the existing tariff as well as include language pertaining to the proposed energy efficiency charge. Both Staff and the Company agree that the proposed charge should be included as a line item on customers' bills, which is reflected in Staff s proposed Rate Schedule RS as shown in Attachment2. Attachment Nos. 1 and2 reflect changes to the proposed tariffs filed by the Company in this case. With the exception of Staff s recommended changes to Tier Two incentives, both the Company and Staff have agreed to the revised tariff language shown in the attachments. If the Commission directs the Company to modify its proposed energy efficiency program, Staff recommends the Commission direct the Company to work with Staff to modify the tariffs in compliance with the Commission's order. CUSTOMER NOTICE AND PRESS RELEASE The Company's press release and customer notice were included with its Application. Staff reviewed the documents and determined that they complied with Rule 125 of the Commission's Rules of Procedure. IDAPA 31.01.01.125. The notice was included with bills sent to customers beginning August 1,2017 and ending September 1,2017 . Customers have the 7STAFF COMMENTS SEPTEMBER I5,2017 opportunity to file comments on or before the Commission's comment deadline of September 15, 2017. CUSTOMER COMMENTS As of September 15,2017, the Commission has received five comments that are opposed to the Company's proposed DSM program. CONCLUSION AND RECOMMENDATIONS Staff supports implementation of the Company's cost-effective natural gas DSM program because it reduces resource costs for all customers. Staff recommends approval of the funding amount, funding mechanism, and proposed accounting treatment. However, Staff s support does not constitute an advance recommendation of prudency. Staff will carefully review program expenses, implementation, and cost-effectiveness calculations when the Company files for prudency of those expenses. Specifically, Staff recommends that: l. The Commission approve the Company's proposed charge of $0.00367 per therm for Rate Schedule EEC. 2. The Commission direct the Company to consolidate its incentives into a single tier at the Tier One level and retain the proposed incentive amount for the Energy Star Homes measure. 3. The Commission approve the revised Rate Schedules EE, EEC, and RS and direct the Company to work with Staff to make further revisions as necessary based on the Commission's decision, and that the Company file conforming tariffs. STAFF COMMENTS SEPTEMBER I5,20178 Respectfully submitted this l5*b day of September 2017 Huang Deputy Attorney Technical Staff: Donn English Stacey Donohue Kevin Keyt Johnathan Farley i :umisc:comments/intg I T.3djhdekskjf comments 9STAFF COMMENTS SEPTEMBER 15,2OI7 l.P.U.C. Gas Tariff Rate Schedules Original Sheet No. '16 (Page 1 of 2) Name of Utility lntermountain Gas Company Rate Schedule EE RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM AVAILABILITY: The lntermountain Gas Company Energy Efficiency Rebate Program (EE Program) is available throughout lntermountain's service territory to eligible residential account holders served under the Company's Rate Schedule RS. PROGRAM DESCRIPTION: The purpose of the program is to encourage upgrades to, or use of, high efficiency natural gas equipment. This will be achieved through the use of rebates, offered towards the purchase and installation of qualified energy-efficient natural gas equipment and construction of Energy Star certified homes. ELIGIBILITY: To qualify for incentives, customers must meet the end-use qualifications identified in the Measures/lncentive Table below. To qualify for space heating rebates, a dwelling must use natural gas as the sole heat source upon installation of rebate-qualified equipment. To qualify for water heating rebates, a dwelling must utilize natural gas for water heating upon installation of rebate-qualified equipment. Rebates for furnaces and water heating equipment for new construction may not be combined with the Energy Star whole home package rebates. Attachment I Case No. INT-G-17-3 Staff Comments 09ll5l17 Page I of 7 tssued oy: lntermountain Gas Company By: Michael P. McGrath Title: Director - Regulatory Affairs Effective: September 12, 2016 l.P.U.C. Gas Tariff Rate Schedules Oriqinal Sheet No. 16 (Paqe 2 ol 2) Name of Utility lntermountain Gas Gompany Rate Schedule EE RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM (Continued) MEASURES/INCENTIVES: GENERAL PROVISIONS: All installations of equipment must comply with all codes and permit requirements applicable in the state of ldaho and must be properly inspected, if required, by appropriate agencies. Customers must submit required documentation of purchase and installation to the Company under the terms and instructions of the current rebate form. The Company reserves the right to verify installation prior to the payment of any rebates. Attachment I Case No. INT-G-17-3 StaffComments 09/l5ll7 Page 2 of 7 tssued oy: lntermountain Gas Company By: Michael P. McGrath Title: Director - Regulatory Affairs Effective: September 12, 2416 Whole Home Package (for new construction) Description Rebate Amount Energy Star Certified Home Energy Star Verified Home with Natural Gas Space and Water Heat $1200 Stand Alone Measures (for new & existing construction) Description Energy Efficiency Rebate 95% AFUE Natural Gas Furnace 95o/o or Greater Thermal Efficiency Rating $350 High Efficiency Combination Radiant Heat System 90% or Greater Efficiency Condensing Tank-less Combo System For Space and Water Heat $1 000 B0% AFUE Natural Gas Fireplace lnsert B0% AFUE Rating or Greater $200 70o/o FE Natural Gas Fireplace lnsert 70% FE Rating or Greater $1 00 .67 EF NaturalGas Water Heater 67 Energy Factor or Greater $50 .91 EF Condensing Tank-less Water Heater 91 Energy Factor or Greater $1 50 l.P.U.C. Gas Tariff Rate Schedules Oriqinal Sheet No. 16 (Pase'l of 2) Name of Utility lntermountain Gas Company Rate Schedule !!DSM RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM AVAILABILITY: The lntermountain Gas Company Energy Efficiency Rebate Program (EE Program) is available throughout lntermountain's service territory to quali{ying-g[giblg residential account holders served g_1dg-fen the Company's€esidential flrate $schedule RS upen meeting the re @ien. PROGRAM DESCRIPTION: Theourooseoftheorooramistoencouraoeuooradesto.oruseof.ffi-hioh efficiencv natural etfeetive DSM reseurees in the ferm ef natural gas therm savings. This will be achieved through the use of rebates, offered towards the purchase and installation of qualified energy-efficient natural gas equipment and construction -of EnerqvENERGY Star selt!fleg[homes. @ ELIGIBILITY: To qualify for incentives, customers must meet the end-use qualifications identified in the Measu res/l ncentive Table below. fne purpe€e ef ths pr gffiuipment-Gustemers eurrently using high effieieney natural gas HVAC er water heating equipment Custemers are eligible fer the fellewing tiers ef ineentives; eq{*ipm€nt gas equipment and fer qualified energy effieieney upgrades in the new eenstruetien seeter To qualify for space heating rebates, a dwelling must use natural gas as the sole heat source upon installation of rebate-qualified equipment. To qualify for water heating rebates, a dwelling must utilize natural gas for water heating upon installation of rebate-qualified equipment. Attachment I Case No. INT-G-17-3 staff comments tssued oy: lntermountain Gas Company By: Michael P. McGrath Effective: September 12, 2016 Title: Director - Regulatory Affairs O9ll5ll7 Page 3 of 7 l.P.U.C. Gas Tariff Rate Schedules Oriqinal Sheet No. 16 (Page 2 of 2) Name of Utility lntermountain Gas Company Rebates for furnaces and water heating equipment for new construction mav not be combined with the Energy S+ARSlALwhole home package rebates. STAR heme, Rate Schedule DSM!! RESIDENTIAL ENERGY EFFICIENCY REBATE PROGRAM (Continued) MEASURES/INCENTIVES: GENERAL PROVISIONS: The Cempany will traek all pregrammatie eests; savings; and equipment installatiens asseeiated with this effert and will use this infermatien te refine the pregram en an annual basis, An annual repert sharl be Attachment I No.INT-G-17-3 tssued uy: lntermountain Gas Company StaffComments By: Michael P. McGrath Effective: September 12, 201 6 Whole Home Package (for new construction) Description Rebate Amount Energy Star Certified Home Energy Star Verified Home with Natural Gas Space and Water Heat $1 200 Stand Alone Measures (for new & existing construction) Description Tier One: Energy Efficiency Rebate 95% AFUE NaturalGas Furnace 95% or Greater Thermal Efficiency Rating $350 High Efficiency Combination Radiant Heat System 90% or Greater Efficiency Condensing Tank-less Combo System For Space and Water Heat $1 000 80% AFUE NaturalGas Fireplace lnsert 80% AFUE Rating or Greater $2oo 7O"/"FE NaturalGas Fireplace lnsert 70"/" FE Rating or Greater $1 00 .67 EF Natural Gas Water Heater .67 Energy Factor or Greater $so .91 EF Condensing Tank-less Water Heater .91 Energy Factor or Greater $1 s0 Title: Director - Regulatory Affairs 09/t5/17 Page 4 of7 l.P.U.C. Gas Tariff Rate Schedules Oriqinal Sheet No. 16 (Page 3 of 2) Name of Utilitv lntermountain Gas Company i i@ All installations of equipment must comply with all codes and permit requirements applicable in the state of ldaho and must be properly inspected, if required, by appropriate agencies. Customers must submit required documentation of purchase and installation to the Company under the terms and instructions of the current rebate form. The Company reserves the right to verify installation prior to the payment of any rebates. Affachment I Case No. INT-G-17-3 Staff Comments 09/15117 Page 5 of 7 tssued uy: lntermountaan Gas Company By: Michael P. McGrath Title: Director - Regulatory Affairs Effective: September 12, 2O16 l.P.U.C. Gas Tariff Rate Schedules Original Sheet No. 17 (Page 1 of 1) Name of Utility Intermountain Gas Company Rate Schedule EEC ENERGY EFFICIENCY CHARGE APPLICABILlTY: Applicable to customers taking service under Rate Schedule RS. The Energy Efficiency Charge is designed to fund administrative and program delivery costs incurred by the Company for energy efficiency services provided to customers as outlined in Rate Schedule EE. MONTHLY RATE: The Monthly Rate is equal to the applicable Energy Efficiency Charge multiplied by the monthly billed therms. Schedule Rate Schedule RS Enerqv Eff iciencv Charqe $0.00367 Attachment I Case No. INT-G-17-3 Staff Comments 09l15l17 Page 6 of 7 rssued by: lntermountain Gas Company By: Michael P. McGrath Title: Director - Regulatory Affairs Effective: October 1, 2017 l.P.U.C. Gas Tariff Rate Schedules Original Sheet No. 17 (Page 1 of 1) Name of Utility lntermountain Gas Company Rate Schedule EEC Enerqv EfficiencvDSM Charge PROGRAM FUNBING MEGHANISM APPLICABILITY: Applicable to customers taking service under Rate Schedule RS. Thgis Enerqy EfficiencyDsM Charge is designed to fund administrative and program delivery costs incurred by the Company in-its++evisien eflql energy efficiency services provided to customers as outlined in Rate Schedule EEDSM._-+his Sehedule will be reviewed annually and revised as neeessary te ensure adequate fundin#er the DSM pregram eests, Any ehange t+this Sehedule is subieet te Cemmissien appreval. MONTHLY RATE: The Monthly Rate is equalto the applicable Enerqv EfficiencyDsM Charge +imes-[Ultiplied_bylh9 monthly billed therms. Schedule Rate Schedule RS Enerqv EIf iciencvDSM Charoe $0.00367 Attachment I Case No. INT-G-17-3 Staff Comments 09l15l1'7 PageT of 7 rssued by: lntermountain Gas CompanyBy: Michael P. McGrath Title: Director - Regulatory Affairs Effective: October 1, 2017 l.P.U.C. Gas Tariff Rate Schedules Second Revised Sheet No. 1 (Page 1 of 1) Name of Utility Intermountain Gas Company Rate Schedule RS RESIDENTIAL SERVICE APPLICABILITY: Applicable to any customer using natural gas for residential purposes. RATE: Monthly minimum charge is the Customer Charge. Customer Charge: Per Therm Charge *lncludes the following: Cost of Gas: $5.50 per bill $0.58143. 1) Temporary purchased gas cost adjustment 2) Weighted average cost of gas 3) Gas transportation cost ($o.os3e5) $0.26020 $0.19964 Distribution Cost: EE Charge: $0.17187 $0.00367 PURCHASED GAS COST ADJUSTMENT: This tariff is subject to an adjustment for the cost of purchased gas as provided for in Rate Schedule PGA. This adjustment is incorporated into the calculation of the Cost of Gas stated on customer bills. ENERGY EFFICIENCY CHARGE ADJUSTMENT: This tariff is subject to an adjustment for costs related to the Company's Energy Efficiency program as provided for in Rate Schedule EEC. The Energy Efficiency Charge is separately stated on customer bills. SERVICE CONDIT!ONS: All natural gas service hereunder is subject to the General Service Provisions of the Company's Tariff, of which this rate schedule is a pail. Attachment 2 Case No. INT-G-17-3 staff comments 09ll5l17 Page I of2 rssued by: lntermountain Gas CompanyBy: Michael P. McGrath Title: Director - Regulatory Affairs Effective: October'1, 2017 l.P.U.C. Gas Tariff Rate Schedules Second Revised Sheet No. 1 (Page 1 of 1) Name of Utility lntermountain Gas Company Rate Schedule RS RESIDENTIAL SERVICE APPLICABILITY: Applicable to any customer using natural gas for residential purposes. RATE: Monthly minimum charge is the Customer Charge. Customer Charge: Per Therm Charge: *lncludes the following: Cost of Gas: Distribution Cost: EE Charqe: $5.50 per bill $0.58143. 1) Temporary purchased gas cost adjustment 2)Weighted average cost of gas 3) Gas transporlation cost ($0.053e5) $0.26020 $0.19964 $0.17187 $0.00367 PURCHASED GAS COST ADJUSTMENT: ThistariffissubjecttoanadjustmentforcostofpurchasedgaSaSprovidedforin@ of the Cost of Gas stated on customer bills. ENERGY EFFICIENCY CHARGE ADJUSTMENT: This tariff is subiect to an adiustment for costs related to the Companv's Enerov Efficiency prooram as provided for in Rate Schedule EEC. The Eneroy Efficiencv Charoe is separatelv stated on customer bills. SERVICE CONDITIONS: All natural gas service hereunder is subject to the General Service Provisions of the Company's Tariff, of which this rate schedule is a part. Aftachment 2 Case No. INT-G-17-3 Staff Comments O9ll5l1't Page2 of 2 rssued by: lntermountain Gas CompanyBy: Michael P. McGrath Title: Director - Regulatory Affairs Effective: October 1, 2017 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF SEPTEMBER 2OI7 , SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. INT-G-17-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG: MICHAEL P McGRATH DIR _ REGULATORY AFFAIRS INTERMOUNTAIN GAS CO PO BOX 7608 BOISE ID 83707 E-MAIL: mike.mcgrath@inteas.com RONALD L WILLIAMS WILLIAMS BRADBURY IOI5 W HAYS ST BOISE TD 83702 E-MAIL: ron@williamsbradbury.com CERTIFICATE OF SERVICE ..-l,- ,41,**- SECRETART