20191216Comment.pdf

INT-G-19-04, comments submitted L2176/2079
lntermountain Gas Company's (lGC or Company) Exhibit No. l attached to the Application is the
Company's "Energy Efficiency 2018 Annual Report." On p.6 ofthat Report, the Company
claims that its efficiency program was cost-effective using the Utility Cost Test (UCT) but that it
was not cost-effecting using the Total Resource Cost Test (TRC). Missing from this Report is
any statement that these cost-effectiveness tests were calculated using actual net therm
savings rather than gross therm savings, but it is readily apparent from the the numbers
reported for the Space Heating Program Results (also p.6) that the savings are gross, rather
than actual net. Consequently, the UCT's actual benefit/cost ratio, like the TRC'S, almost
certainly falls well below the 1.0 cost-effectiveness threshold. Notably, this omission of
calculating net savings is consistent with Company witness Allison Spector's Exhibit No. 26 in
tNT-G-16-02.
The Application states that it "...reports the cost effectiveness of its EE Program based on two
industry standard metrics..." (p.6), but it deviates from the standard metrics by failing to adjust
the gross therm savings by the therms saved by efficiency gains that would have occurred in the
absence of its program. Quoting from the National Action Plan for Energy Efficiency's
"Understanding Cost-Effectiveness of Energy Efficiency Programs" Section 4.7, Establishing the
Net-To-Gross Ratio: 'Establishing the NTG is critical to understanding overall program
success...' " For example, a 60% NTG ratio would reduce IGC's UCT cost effectiveness from its
purported 1.23 benefit/cost ratio down to 0.74 B/C. IGC's TRC cost-effectiveness would also
be reduced from its purported 0.6a B/C ratio, but its reduction would not be as significant as
the UCT's reduction.
I urge the Commission to deny the Company's Application for a "Determination of 2017-2018
Energy Efficiency Expenses as Prudently lncurred," because it is, at best, a premature
application. To wit, the Application states that "...lntermountain has not yet had its program
evaluated by a third-party contractor..." but that it intends to do so in the future. (p. 7) Thus,
the Company can reapply for such determination if and when it has a credible third-party
evaluation completed that shows its program was either actually cost-effective based on
National Action Plan for Energy Efficiency metrics or, at the very least, that the Company
planned and managed its program well and had a reasonable expectation that it would be
cost-effective.
Thank you for your consideration,
Lynn Anderson
d la a dvisor@ ya h oo.co m
208-342-63t7
720 Bacon Dr.
Boise, ldaho 83772