20210209Reply Comments.pdf

Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley.com
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Attorney s for Intermountain Gas C ompany
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOUNTAIN GAS
COMPAI\Y'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL ENERGY
EFFICIENCY PROGRAM AI\[D
FUNDING MECHANISM
CASE NO. INT.G-20.04
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Intermountain Gas Company ("Intermountain" or "Company") respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission Staff ("Staff ').
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lntermountain filed an application on August 3,2020 requesting authority to implement a
Commercial Energy Efficiency ("Commercial EE") Program that would be funded by a
$0.00320 per therm surcharge collected from its General Service ("GS-I") customers.
Application at 8.
On January 26,2021, Stafffiled Comments in the case. Pursuant to the Notice of
Modified Procedure issued by the Commission in Order No. 34869, Intermountain submits its
Reply Comments.
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lntermountain appreciates Staff s comments in this case and the ideas outlined that will
INTERMoI,NTAD.I GIS COIUP TVY,S REPLY COMMENTS . I
provide the necessary foundation upon which to build a successful Commercial EE Program. The
Company agrees that reporting is an important component of any energy efficiency program and
is committed to providing an accurate Annual Commercial EE Program report that includes the
rider reconciliation; evaluation plan; Evaluation, Measurement and Verification ("EM&V")
results (CY 2023 report); and the use of EM&V results to adjust program savings and incentive
levels as outlined by Staff.
While Intermountain also agrees that cost effectiveness is an important component of the
Annual Commercial EE Program report, the Company believes the method for determining the
cost effectiveness of a measure should be based on the advice of its EM&V consultant and
discussions with the Energy Efficiency Stakeholder Committee ("EESC") rather than the
prescriptive approach of using "billing data, when available, to measure the cost effectiveness of
each measure" included as Staff Recommendation l.c. Staff Comments at 7.
Intermountain has found through its recent EM&V study on the Residential EE Program
that while using billingdata can be an important metric in measuring cost effectiveness, it may
not be the best method for evaluating the cost effectiveness for a particular rebate and is not
always industry best practice. As the Company's Evaluator stated in its Residential Program
Impact Evaluation, "billing analyses include any changes in household behavior, equipment, or
occupancy and therefore may include factors other than the impact of improved equipment
efficiency". INT-G-20-06 Supplement to Application at 6. While this was an evaluation of
residential rebates, the theory is applicable to commercial appliances as well. The Company
requests that the Commission not prescribe a method of conducting EM&V in its final Order in
this case, but rather allow the Company to work with its EM&V consultant and EESC to
determine the most appropriate method of calculating the cost effectiveness for each individual
INrsnuorxrarN Ges CoupeNy's REpLy CouurNrs - 2
measure based on industry best practice.
The Company agrees with Staffthat there are many unknowns regarding its proposed
Energy Savings Kit ("ESK") measure. Staff s suggestion of operating the ESK as a pilot measure
of 350 kits for the first year is a reasonable approach. The initial 350 kits will provide valuable
information the Company can use to refine the program with Staffand the EESC.
Intermountain also recognizes the importance of including representatives from the GS-l
rate class on the EESC. The residential representatives on Intermountain's current EESC have
been invaluable in providing feedback that has helped improve the current Residential EE
Program. If the Commercial EE Program is approved, the Company plans to recruit individuals
with similar expertise that will be helpful in growing the Commercial EE Program.
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In summary,Intermountain appreciates the reporting framework outlined by Staff and
agrees with the recommendations of implementing the ESK measure as a pilot program and
including GS-l representatives on its EESC. However, the Company requests that the
Commission not prescribe a specific method for determining cost effectiveness, such as the use
of billing data. Instead, the Company believes relying on industry best practices recommended
by its EM&V consultant and consultation with Staffand the EESC will result in a method of
determining cost effectiveness that is most appropriate for each measure.
Dated: February 9,2021
GIVENS PURSLEY LLP
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Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas C ompany
INTERMoUNTAtrI Gls Corraprv's RgpLv CoMMENTS - 3
CERTIFICATE OF SERVICE
I certiff that on February 9,2021, a true and correct copy of INTERMOT NTAIN GAS
COMPANY'S REPLY COMMENTS was served upon all parties of record in this proceeding
via the manner indicated below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,ID 83714
Via Electronic Mail
j an.noriyuki@puc. idaho. gov
John R. Hammond
Deputy Attorney General
Idaho Public Utilities Commission
I1331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,ID 83714
j ohn.hammond@puc. idaho. gov
Idaho Consenation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, lD 83702
[e-mail]
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Lori A. Blattner
INTERMoUNTAIN GAS CoI4PANY,S REPLY CoMMENTS. 4