20191216Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC I.ITILITIES COMMISSION
PO BOX 83720
BOTSE. IDAHO 837 20-OO7 4
(208) 334-03 l2
BAR NO. 99I7
IN THI' MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION I.'OR
DETERN{INATION OI-' 2OI7.2OI8 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED
RECEIVED
:i)8:11l5 PH 3:26
',; , j',i::l;i\\8sloN
Strcct Address for Express Mail:
I I33I W. CHINDEN BLVD. BLDG 8. SUITE 20I-A
BOISE, IDAHO 837I4
Attorney for the Commission StatT
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. INT.G-19.04
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the ldaho Public Utilities Commission, by and through its
attorney of record, Dayn Hardie, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 34440 on September 17,
2019, in Case No. INT-C-19-04, submits the following comments.
BACKGROUND
On August 9, 2019, Intermountain Gas Company ("Intermountain Gas" or "Company")
applied to the Commission for an onler designating expenses associated wittr its 2017-2018
residential Energy Efficiency Program ("EE Program" or "Program") as prudently incurred. In
Case No. INT-G-17-03, Intermountain Cas received the Commission's authorization to
implement two new rate schedules: l) Rate Schedule EE-Residential Energy Efficiency Rebate
Program, outlining the offerings of the EE Program; and 2) Rate Schedule EEC-Energy
Efficiency Charge ("EE Charge"), establishing a per therm charge to fund the EE Program. See
Order No. 33888; Application at4. Both Schedules became effective October 1,2017. ld. at4.
STAFF COMMENTS DECEMBER I6,20I9I
The initial period for both schedules ran from October 1, 2017 through December 31, 2018
("Initial Period"). Id
In Case No. INT-G-19-05, the Company rcquested to increase its EE Charge from
$0.00367 per therm to $0.02093 per therm. The Company asserted that from the EE Program
inception on October l, 2017 through June 30, 2019 it had collected $1,712,654 from customers
through the EE Charge and incurred S2,810,560 in EE Program expenses. The Commission
approved the Company's requested EE Charge increase in Order No. 34454.
STAFF ANALYSIS
This is the first prudency filing made by the Company since it began its EE Program on
October l, 2017. Staff examined the Company's Application, workpapers, 2018 Energy
Efficiency Annual Report ("Report"), exhibits, Conservation Potential Assessment ("CPA"),'
and additional information provided by the Company through Production Responses. The
Company is seeking approval for EE Program expenses of $ I ,496, 198 for the pcriod of
October 1, 2017 through December 3 I , 2018 as prudently incurred. Based on its review, Staff
recommends the Commission approve the Company's EE Program expenses of $ 1,496, 198 as
prudently incurred.
Staff comments address the Company's EE Program financials, program offerings,
avoided cost, Evaluation, Measurement and Verification C'EM&V"), CPA, and other issues.
Staff notes that the absence of any discussions on other issues should not be construed as StatT
support for the Company's position.
While Staff believes the EE Program expenses of $ 1,496,198 were prudently incurred,
Staffbelieves that some ofthe initial assumptions about measure savings and incentive levels
should be re-evaluated as soon as possible. In particular, Staff recommends that EE Program
savings be evaluated by an independent third party EM&V evaluator and that the Company, with
input from stakeholders, adjust its avoided cost methodology so that it more accurately
represents actual costs avoided through energy efficiency.
I The CPA was submitted in Case No. INT-C-19-07 as Exhibit 4
STAFF COMMENTS DECEMBER I6,2OI9)
Financial Review
Staff audited the Company's EE Program, which includcd reviewing transactions across
all ofthe Company's EE measures. Staff verified that expenses were well documented and that
internal controls were in place to prevent improper payment of incentives and to propcrly rccord
Program expenses. The Tariff Rider balance, Program costs, labor expenses, and avoided cost
methodology and calculations are described in greater detail below.
Turill Rider Balance
Table I shows Tariff Rider activity from Program inception through December 31,2018.
Table l: Tariff Rider Reconciliation
$o
$ l, 185,328
($ 1,496,148)
$0
($310,820)
ln Case No. INT-G- l9-05, the Company reported that the Tariff Rider underfunded
balance had increased from $310,820 at the end of 2018 to $1,097,907 as ofJune 2019. While
Staff has not yet reviewed the prudency of any 2019 expenses, Staff recommended and the
Commission approved the Company's request to increase its EE Charge to reduce its
underfunded Tariff Rider balance. See Order No. 34454.
L.abor Expenses
As the Company developed and expanded its EE Program, new staff was hired and
additional time for existing employees was charged to the program. The Company has three
employees fully allocated and two employees partially allocated to the EE Program. The
Company also allocates the equivalent of two Energy Service Representatives to the EE
Program.
The total labor expense from inception of the program through December 3 I , 201 8 was
$189,962, which represents l2.l7o of total Program expenses. The Company did not rcport any
labor expenses fbr the EE Program until the start of20l8. Staff believes that labor expenses are
prudently incurred and tue similar to those incurred by other utility EE programs in Idaho. Staff
will monitor any increase in labor expense in future prudency cases.
STAFF COMMENTS DECEMBER I6,20I9
Beginning Balance as of October 1,2017
Funding
Reponed Expenses
Adjustments
Balance as of December 31, 2018 (Underfunded)
3
DSM Program Assessment
The Company's first year repofted savings of 283,067 therms, is well above its initial
target of 65,000 therms and stretch goal of97,825 therms. Report at 1. The Company also
stated that the program was cost-effective, and achieved a UCT ratio of 1.23 as illustrated in
Table 2 below. Repofi at l. These measures are available to all ofthe Company's customers
who receive service under the Residentizrl Rate Schedule.
Table 2: DSM Measure Savings, Throughput, and Cost-Effectiveness:
Measure
Rebate
Amount
Measures
Installed
Annual
Therm
Savings per
Measure2
Total
Therm
Savings
by
Measure UCT TRC
Whole Home Program $ 1,200 619 204 126,216 1.13 t.t7
95olc AFUE Furnace $3so 1,334 |2 r49.408 1.36 0.44
907o High E Combo
System
$ 1,000 3 451 1,35 3 1.94 0.95
80o/c Fircplacc Insert $200 76
707c Fireplace Insert $ r00 l3 56 728 2.t]0.70
.67 EF Water Heater $s0 9 22 r98 1.57
.91 Condensing Tank-
less Water Heater
$ 150 88 58 5,104 1.56 o.23
Totals 2,066 283,067 1.23 o.64
Whole Home Program
The Company offers a Whole Home Program rebate of $1,200 for a new home with
natural gas space and water heating. This program provides incentives to builders for
constructing energy efficient homes. Builders must be Energy Star certified to participate in the
program. In order to qualify for a rebate, the home must bc evaluated by a RESNET certified
third parly evaluator, and receive a Home Energy Rating System C'HERS") threshold index
score ol 75 or less, as determined by the Company. Currently, the Company uses a deemed
savings of 204 therms per home per year to e\timate program cosl-e fleet iveness. Staflbelieves
I Annual Thcrm Savings lines l,l-20, Exhibit No. 26, Case No. INT-G-16-02.
STAFF COMMENTS DECEMBER 16,20I94
0.30
Whole Home Program Participant
HERS Scores
100
-809--EbU
r40*20
0 J r Frequency
ll
.\r oo <r o (o N co <r o (o.{ 00 <t o ro N 00r-{ N.{.il rn <t l^.^(o\o N@aoo1 ah
Bin
Figure ESl: Distribution of Whole Home Program Panicipant Scores Average HERS Score is 61. Sample
Size = 619
-5STAFF COMMENTS
that the 204 therm deemed savings estimate may not accurately reflect natural gas savings
re:rlized by the program, and recommends that both the 204 Therm deemed savings value and the
75 threshold index score be reevaluated by a third party EM&V evaluator, and by comparing the
billed consumption of a sample of new homes that received a Whole Home Program rebate to a
sample of similu homes that did not.
According to literature provided by RESNET, homes built to the 2006 Intemational
Energy Conservation Code C'IECC") are awarded a HERS index score of 100 (Reference
Home). A home's HERS score provides a measure of its energy efficiency relative to the
reference home. For example, a home with a HERS score of 130 uses 309o more energy than the
reference home, and a home with a HERS score of70 uses 307o less energy than the reference
home. According to RESNET, the typical HERS score of a resale home is 130.
Staffs analysis of HERS scores from pnrticipating and non-participating homes was not
consistent with the information provided by RESNET. Using information provided by the
Company (Production Request Nos. 27 and,28), Staff found that the average HERS score for
non-participants was 64, instead of the 100 HERS score used by the RESNET reference home.
Staff compared HERS scores of Whole Home Program participants with the HERS scores of
non-participants, and found very little difference between the HERS scores ofthe two groups
(Figures ES I and ES2). The average HERS score of 6l used for program participants, was only
slightly less than the average HERS score of64, received by non-panicipating homes.
DECEMBER 16,2019
Non-Participant H ERS Scores
100
90
80
70
E603sorg40
30
20
10
0 r.{ F. m ot rn ..r l-. .n crlt+t-rNmm<t$
Ijt,..,"*,(^.rNmOl!,)-rl.-1,1 lO(o F. NcOOtOl
tn
The vast majority of non-participating homes in Staffs evaluation received HERS scores
at or below the Company's 75 HERS threshold (94.7Vo), suggesting that many energy efficient
homes would have been built without any incentive from the Company. However, Staffcautions
against overextrapolation from the 1,035 homes used in its analysis to the general population of
new homes in the Company's service territory. Participation in HERS evaluation is voluntary,
making it possible that non-participant homes receiving HERS evaluation differ from the
majority of homes being built in the Company's service teffitory. Because HERS participants are
self-selected, and do not represent the larger population of new housing stock, Staff does not
believe that HERS scores, by themselves, provide an adequate basis for evaluating cost
effectiveness.
Staff notes that HERS index scores include savings from electrical efficiency measures,
and therefore may not accurately reflect natural gas savings. Further, HERS scores may not
necessarily reflect standard homebuilding practices because the IECC has been updated four
times since RESNET's 2006 base year, and Idaho building standards cumently require builders to
comply with the 2015 IECC. Although Staff believes the Company's HERS threshold index
score of 75 was a reasonable starting point for the Whole Home Program, Staff believes that the
STAFF COMMENTS
B
6
r Frequency
Figure ES2: Distribution of Whole Homc Non-Panicipant HERS Scores Average HERS Score is 64.
Sample Size = 1,035.
J
DECEMBER I6.20I9
Company has acquired sufficient program data to determine its own rebate criteria in order to
incent energy efficient building practices at the lowest program cost.
Staff is also concerned with the 204 Therm savings value that the Company used to
determine cost effectiveness. In its response to Staffs Production Request No. 33, the Company
did not provide workpapers supporting the annual therm savings values used to determine the
Whole Home program's benefits. Instead, the Company provided hard coded values obtained
from a CPA model developed for another company-Cascade Natural Gas-by Nexant. Staff
notes that this is the same value proposed by the Program in the Company's last rate case
(rNT-G-r6-02).
Staff found no evidence supporting the Company's 204 therm value. Staff compared
average annual consumption of homes receiving Whole Home rebates with the average
consumption ofhomes determined in Case No. INT-G-16-02. Staff discovered that annual
consumption by Whole Home Program participants was slightly higher (771 Therms) than
average consumption for all space and water heater equipped homes in the Company's service
teritory (755 Therms). It is possible that homes receiving Whole Home Program rebates are
larger, or have more gas appliances than other homes in the Company's service territory;
however, workpapers provided by the Company do not support either of these possibilities.
Staff believes that the Whole Home program's actual therm savings should be determined
from a billing analysis comparing actual billed consumption of a sample of homes receiving a
Whole Home Program rebate to the actual billed consumption of a sample of similar new homes
that did not receive a rebate. Currently, the Company collects information about home size
(square feet) and the types ofgas appliances installed in all new homes in the course of its
lines/mains extension application process, so the necessary information is readily available to the
Company. Staff believes that it is important for the Company to update energy savings values
and incentive levels as soon as possible, and that this analysis should be performed by a third
party EM&V evaluator. Until a third party EM&V evaluation is completed, Staff believes that
the Company should perform a bill consumption evaluation and update its savings and incentive
levels accordingly.
STAFF COMMENTS DECEMBER I6.20I97
Spar;e Heating Measures
The Company offers two space heating measures. The first measure is a $350 rebate for
installation of a959c Annual Fuel Utilization Energy ("AFUE") or greater natural gas furnace.
The second measure is $ | ,000 rebate for installation of a 907o or greater efficiency condensing
tankless combination system for space and water heating. The Company reported that 1,334
959o AFUE furnaces were installed with therm savings of 149,408 resulting in a UCT of 1.36
and a TRC of 0.44. Report at 6. In Stafls avoided cost analysis, the UCT for a 957o AFUE
furnace with the current incentive is 0.98. Similar to the Whole Home Program, Staff believes
that energy savings and incentive levels should be re-evaluated as soon as possible. The
Company reported that three 907c AFUE combination systems were installed with therm savings
of 1,353 resulting in a UCT of 1.94 and a TRC of 0.95.
Fi re place Inse rt Measure s
The Company offers two fireplace insert measures. The first measure is a $200 rebate for
installation ofan 807o AFUE or greater natural gas fireplace insert. The second measure is $100
rebate for installation of a7O9o or greater Fireplace Efficiency ("FE") natural gas fireplace insefi.
The Company reported that thirteen'l Oo/o FE inserts were installed with a savings of 728 therms
resulting in a UCT of 2.17 and a TRC of 0.70. Staff believes that energy savings and incentive
levels for this measure should be re-evaluated as soon as possible.
The Company reported that zero 807o AFUE condensing fireplace insefts were installed
and no therm savings were achieved. The Company would like to discontinue the 80% AFUE
fireplace insert measure because no customers have used the incentive and installation of
condensing technology is cost prohibitive from a customer's perspective. Staff suppo(s
discontinuing the 80% AFUE measure.
Water Heating Measures
The Company off'ers two measures in its Water Heater Program. The first measure is a
$50 rebate for installation of a 0.67 Energy Factor (EF) or greater natural gas water heater. The
second measure is $ 150 rebate for installation of a 0.91 EF or greater condensing tankless water
heater. The Company reported that nine 0.67 EF water heaters were installed resulting in 198
annual therm savings and a UCT of I .57 and a TRC of 0.30. Given the relatively modest savings
8 DECEMBER I6,20I9STAFF COMMENTS
the 0.67 EF water heaters, 22 therms, Staff believes that the $50 rebate should be re-evaluated as
part of the Company's EM&V evaluation.
The Company reported that 88 condensing tankless water heaters with 0.91 AFUE were
installed with savings of 5,104 therms resulting in and a UCT of l.56andaTRCof 0.23. Staff
believes that energy savings and incentive levels lor this measure should be re-evaluated as soon
as possible.
Avoided Cost
Staff has several concerns with the Company's avoided cost calculations. In its review,
Staff found that the Company included base rate embedded distribution costs in its avoided cost
computations. Production Request Nos. l0 and 33. Staff does not believe this is appropriate
because costs that are already incurred and embedded in rates cannot be avoided. Staff also
believes that the Company's forecast of avoided commodity costs is unreasonably high and
appears to exceed costs the Company could actually avoid. Staff recommends that the Company
conduct an avoided cost review in order to accurately determine the value of future capacity
costs that might be avoided by the Company's EE Programs.
DSM avoided costs are those costs that the Company avoids by implementing a DSM
measure or program. For example, a measure that incents customers to replace a low efhciency
furnace with a high efficiency furnace allows the Company to avoid the cost of gas saved by the
high efficiency fumace, as well as some of the costs of transporting that gas from the producer to
the Company's distribution system; however, no energy efficiency measure can affect fixed costs
that are already embedded in the Company's base rate.
After excluding embedded distribution costs, Staff recomputed UCT ratios for each of the
seven measures offered by the Company and found that the Whole Home Program and the High
Efficiency Natural Gas Furnace program are not cost-effective at current incentive levels.
ISTAFF COMMENTS DECEMBER I6.20I9
Nleasure Rehate Staff UCT
Whole Home Program S I 200 I 13 0.78
HE Combination Radiant Heat System $ r ,000 L95 1.39
95% AFUE Furnace $350 l -'tt)0.9ti
HE'loc/c AFUE Insert s 100 2. 18 1.56
.6'1 EFI .68 UEF Water Heater $s0 r.58 l. l5
.91 EFI .92 UEF Tankless Water Hcater $ ls0 ).57 l. 13
Table 3: Recomputed UCT rvithout Embedded Costs
Notes: The 807a AFUE lnscrt was not includcd hecause no rcbates have been issued. Company avoided costs and
thcrm savings used in calculations are based on initial calculations included in case INT-C-16-02.
ln its avoided cost calculations, the Company used the present value of forecasted Fixed
Transportation Costs (TCF), Variable Transportation Costs (TCV), Commodity Costs (CC), ard
Embedded Distribution Costs (DSC) in its calculation of nominal Avoided Costs (ACnu',inar).
The Company expressed this relationship as:
Using this method, the Company estimated an avoided cost of 50.4759 per therm. Staff
notes that this value nearly equals the entire $0.49'12 residcntial rate.r This is noteworthy
because avoided costs are usually less than the retail rate since they are intended to reflect only
those costs that can be avoided, not all costs.
In addition to including embedded distribution costs, Staff believes the inclusion of
natural gas commodity costs in the avoided cost calculation are unreasonably high. Staff found
that the commodity costs used in the Company's avoided cost calculation are even higher than
those included in retail rates. For example, the Company used an avoided commodity cost of
$0.3163 per therm in its 2019 avoided cost rate, whereas the cost of gas currently in residential
retail rates is $0.1533 per therm.4 Company Responses to Staffs Production Request Nos. 10
and 33. It appears that the Company used an Integrated Resource Plan ("IRP") forecast to
I Does not include $0.0209-1 pcr thcrm energy efficicncy charge.
r Rate Schcdule RS Weighted Averagc Cost of Gas ($0.20904) less thc T(rmporary purchased gas cost adjustmenl
($0.05s73).
l0 DECEMBER I6.20I9
Company UCT
AC*,,,i,"r = TCF + TCV + CC + DSC
STAFF COMMENTS
determine its avoided commodity costs, but instead of using a single forecast to calculate thc
avoided cost, the Company seems to have used the highest of three forecasts in each month to
determine the avoided commodity costs. Staff was also unable to reconcile discrepancies in the
transportation costs (TCF and TCV) used by the Company.
The Company included a distribution cost of $0.1624 in its avoided cost calculations.
These were calculated using a weighted average of Residential and General Service distriburion
rates from the Company's current tariff. Because the Company's current DSM program only
includes Residential customers, Staff believes that it was inappropriate for the Company to use
the distribution rate from its General Service tariff in its calculations. Further, Staff does not
believe that the distribution costs already embedded in the Company's base rates can be avoided,
and, thus, disagrees with the Company's inclusion of this term in its avoided cost calculations.
In order to calculate the UCT values in Table 2, Staff used a value of $0.3342 per therm
as a proxy for avoided costs. This value includes the $0.20904 weighted average cost ofgas
($0.05573) temporary purchased gas cost adjustment, and $0. 18087 Gas Transportation Cost
included in the Company's 2019 residential tariff.
Staff notes that it is possible for energy efficiency measures to enable the Company to
avoid future capacity costs that have not yet been embedded in rates. Energy efficiency
measures might decrease load growlh sufficiently to allow the Company to delay capacity
upgrades, or to use smaller pipes when extending new service; however, the Company provided
no evidence that it takes its EE Program into account when planning or designing its distribution
system. Staff notes that the Company's line and main extension policies do not distinguish
between homes with and without Energy Star ratings, or between homes constructed using
energy efficiency measures incented by the Company.
Further, the Company has stated in previous cases that it does not consider the effects of
capacity expansion in its DSM cosGeffectiveness assessment. As noted in Order No. 33314
at 7-8, "in reply, the Company explains that avoided costs from avoided capacity expansions do
not affect the Company's DSM cost-effectiveness assessment because the expansions are driven
by rapid customer growth and system integrity issues that DSM programs cannot address. " In
the current case, StafT fbund no evidence that the Company has begun considering the effects of
energy efficiency programs when planning new construction or upgrades to cxisting distribution
plant.
STAFF COMMENTS t1 DECEMBER 16,20I9
Staffbelieves it's likely that an updated review of the Company's avoided costs would
identify and quantify capacity contributions for some ofthe Companyrs energy efficiency
lneasures, and recommends that the Company conduct an avoided cost review in cooperation
with its Energy Advisory Group.
EM&V
The Company stated, in its report, that it will be issuing a request for proposal ("RFP')
for an EM&V study in 2019 "to assess the performance of energy efficiency activities and assure
the certainty and effectiveness of future activities." Report at 23. EM&V studies are necessary
to assess the performance of a Company's EE Programs and to establish whether Programs and
measures are generating the level of savings they were created to deliver.s
Because the Company's DSM program has been underway for two years, and there are
concerns about the amount of savings associated with its fastest growing and highest incented
program-Whole Home Program; Staff believes it is time for the Company to conduct an
evaluation to confirm the savings achieved by its programs and measures. Staff recommends
that the Company develop a plan for completing an EM&V study within two months of a
Commission order in this case. Staff recommends that this plan outline when an RFP will be
submitted, how and when a contractor will be selected, and how the Company will use the
findings to evaluate and update their EE Program.
CPA
The purpose of a CPA is to estimate the amount of energy savings in a utility's service
territory that is possible to acquire. The Company sent a RFP to thirty companies in April 2018.
Six companies retumed proposals and the Company conducted interviews with three of them.
The Company selected Dunsky Energy Consultants to complete its CPA. Dunsky Energy is a
respected energy research group with staff that have advanced degrees and certifications in
energy-related fields. StafT notes the CPA expenditure was greater than other Idaho companies
with mature energy efficiency programs; however, Staff believes the cost to be justified for a
new program such as that being implemented by Intermountain Gas. The Company's CPA was
submitted with its 2019IRP in Case No. INT-G- l9-07. Staff looks tbrward to the Company
5 httDs://www.enerIv.sov/sites/Dr od/liles/20 l4/05/l'l 6/whal is emv.ndf
STAFF COMMENTS t2 DECEMBER I6,2019
using the results of the CPA to include EE as a resource in its IRP and develop the annual
savings goals of the EE programs.
Marketing and Outreach
Staff believes the Company demonstrated innovative and cost-conscious marketing
strategies. The Company used its membership in the Building Contractors Association to create
awareness and promote the Whole Home Program. The Company used regional Parade of Home
promotions and sponsored "efficiency" holes at golf tournaments to engage with local builders
and discuss energy efticiency offerings. The Company also participated in ajoint meeting with
Rocky Mountain Power's EE Program for HVAC contractors. Application at 20.
The Company's marketing, education, and outreach efforts were focused on customers,
contraclors, and home builders. The Company published multiple electronic and paper bill
inserts, created an energy cfficiency program section and a dedicated web address on the
Company's website, and used digital and social media to promote the EE Program. However,
some information was not clearly related to the Company's energy efficiency programs. Staff
sees an opportunity for the Company to rehne its energy efficiency marketing to focus on
available programs and incentives. Staff believes the Company can improve its marketing as it
develops its understanding of the target population and tailors its message to specific customer
segments.
SUMMARY
Based on its review, Staff believes the Company's EE Program expenses of $1,496,198
are prudent.
Staff confirmed that the Company's EE program is based on assumptions, therm savings,
and avoided costs described in Case No. INT-G-16-02 and that the Company has taken critical
steps in developing its EE Program such as establishing an Energy Advisory Group, completing
a CPA, hiring program staff, and creating customer awareness of its EE Programs. Staff
encourages the Company to continue refining and enhancing its programs and processes, which
Staff believes should include using the recently completed CPA to make program adjustments.
Staff also recommends the Company complete :rn EM&V study and an avoided cost review and
use that information to implement additional program and process modifications as necess,uy.
STAFF COMMENTS DECEMBER I6.2OI9t3
STAFF RECOMMENDATIONS
Based on Stafls audit and analysis, Staff recommends the Commission:
l. Find that the Company prudently incured $1,496,198 in 2Ol7 - 2018 EE Program
expenses.
2. Direct the Company, in cooperation with its Energy Advisory Group, to review its
avoided cost calculation and develop a plan to establish an avoided cost methodology
that represents actual Company costs, which are avoided through its energy efficiency
program, and present those results in its next DSM Annual Report.
3. Direct the Company to develop a plan within two months of a Commission order in
this case for completing an EM&V study. Staff recommends that this plan outline
when an RFP will be submitted, how, and when a contractor will be selected, and
how the Company will use the findings to evaluate and update their EE Program.
4. Direct the Company to implement program and measure changes, including incentive
level adjustments, as soon as possible and on an on-going basis, using the best data
curently available, such as the analysis of the recently completed CPA.
day of December 2019
n Hardie
Deputy Attorney General
Technical Staff: Cassie Koerner
Donn English
Kevin Keyt
Brad Iverson-Long
Mike Monison
t4 DECEMBER I6,2019
1b+L-Respectfully submittcd this
STAFF COMMENTS
CERTIFICATE OF StrRVICE
I HEREBY CERTIFY TIIAT I HAVE THIS I6TII DAY OF DECEMBER 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASt, NO. INT-G.19.04, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSi,EY LLP
60I WBANNOCKST
BOISE ID 83702
E-MAIL: prestoncafter@gi vcnsDursley.crln.)
kendrah,.0 givcnspursley.con.r
SECRETARY
CERTIFICATE OF SERVICE
- L, ,//tZtr,-Y(