20210311Reply 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@ givenspurslelz.com
Attorneys for Intermountain Gas Company
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOUNTAIN GAS
COMPAI\TY'S APPLICATION FOR A
DETERMINATION OF 2019
ENERGY EFFICIENCY EXPENSES
AS PRUDENTLY INCURRED
CASE NO. INT-G-20.06
InrnmrourtrAlN GAs Cotuplrw,s
Rnply Couunnrs
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 ').
B.lcxcnouxo
Intermountain filed an application on September 1,2020 for an order designating
$2,803,346 of 2019 Energy Efficiency expenditures as prudently incurred. Application at2. On
December 7,2020, the Company Supplemented its Application ("Amended Application") with
additional information pertinent to the case, including the final report from Intermountain's
Evaluation, Measurement and Verification ("EM&V") study, resulting cost-effectiveness test,
and proposed changes to the Company's Residential Energy Efficiency Program ("EE Program")
resulting from the EM&V study. Amended Application at 2.
On February 25,2021, Staff filed Comments in the case. Pursuant to the Notice of
Modified Procedure issued by the Commission in Order No. 34908, Intermountain submits its
Reply Comments.
INTERMoUNTAI.I GAs CoMpANy's REpLy CoMMENTS - I
Rrrlv To Surp CouuruNrs
Intermountain looks forward to continued discussions related to some of the statements
and suggestions made in the body of Stafls Comments. The comments provide ideas the
Company can consider in consultation with its Energy Efficiency Stakeholder Committee
("EESC") to continue to improve the EE Program. These reply comments are focused on Staff s
recommendations, which the Company understands to be Staff s "action items" informed by the
body of the comments.
Intermountain appreciates Staff s recommendations to approve the Company's 2019 EE
Program expenses of $2,803,346 as prudently incurred, to approve the Company's proposed and
modified measures, and to approve the retirement of the T}Yofireplace rebate.l These
recommendations will all help put the EE Program on a solid foundation which will allow for the
continued growth of the program. StaffComments at 15.
In recommendation 5, Staff recommends that the Commission "direct[] the Company, in
cooperation with its EESC, to continue efforts to improve its avoided cost methodology, address
distribution costs which are avoided through its EE Program, and present those results to the
Commission." Staff Comments at 15. The Company believes that, in cooperation with Staffand
the EESC, it has made good progress in improving the avoided cost methodology. Intermountain
agrees with Staffthat it is important to address distribution costs which are avoided through its
EE Program. The Company anticipates the Integrated Resource Plan ("ilU"';, which is currently
in process, will provide valuable information that can be used in this effort. Once the IRP is filed
in the Fall of 2021, [ntermountain looks forward to reconvening the Avoided Cost Subcommittee
of its EESC to develop a method for including avoided distribution costs.
I These recommendations are labeled 1,2, md 3 respectively
INTERMouttrAtrt Gls Couperrry's REPLY CoN,rl,tsNrs - 2
In recommendation 4, Staff recommends that the Commission "[d]irect[] the Company to
address and document the use of billing analysis when establishing incentive levels,, and in
recommendation 6, Staff recommends that the Commission "[d]irect[] the Company to
implement programs and measure adjustments, as soon as possible and an ongoing basis, using
the best data currently available including, but not limited to, billing analysis and the results of
the EM&V." StaffComments at 15. The Company agrees that billing analysis, when available,
can serve as a useful metric in establishing incentive levels and implementing program and
measure adjustments. However, Intermountain has found through its recent EM&V study that
while billing datacan be an important metric, itmay not always be the best method for
evaluating the therm savings or cost effectiveness of a particular rebate and is not always
industry best practice. Intermountain interprets Staff Recommendations as allowing for the
inclusion of industry best practices in determining the analysis methods to be used to support
setting incentive levels and implementing adjustments. These industry best practices may
include, but are not limited to, billing analysis. If that is the intent of Staff s Recommendation-
and it appears to be--then the Company supports the recommended approach. Intermountain is
committed to work with its EM&V consultant and the EESC to set the parameters and content,
based on industry best practice, that will guide the EM&V studies upon which rebate
recommendations will be based.
Coxcr,usroN
ln summary, Intermountain appreciates the Staff Recommendations to approve the 20lg
Program Expenses as prudently incurred, approve the proposed and modified measures, and
approve the retirement of the 70%ofireplace rebate. The Company is committed to using data
resulting from the IRP process to develop, in cooperation with its EESC, a method to include
avoided distribution costs in its avoided cost methodology. Intermountain is also supportive of
INTERMoUNTATN GAs CoMPANY,s REPLY CoMMTNTs - 3
using the best available data and working with its EM&V consultant and EESC to set the
parameters and content, based on industry best practices, including (but not limited to) billing
analysis, that will guide the EM&V studies upon which rebate incentive levels and adjustments
will be based.
Dated: March ll,202l
GIVENS PURSLEY LLP
.P
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas C ompany
TNTERMOI,NTAN.I GAS COMPANY'S REPLY COMUENTS - 4
CERTIFICATE OF SERVICE
I certi$ that on March 11,2021, a true and correct copy of INTERMOUNTAIN 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 [e-mail]
Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise,lD 83714
Matt.Hunter@puc. idaho. gov
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,lD 83702
botto @idahoconservation.org
dnLBltM
Lori A. Blattner
INTERMoITNTAnT GAs CoMpAl.Iy's REpLy CoMr,GNTs - 5