20210714Application.pdf

A INIERMOUNTAIN'
GAS COMPANY
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JtlJy 14,2020
Lori A. Blatbrer
Director, Regulatory Affairs
Intermountain Gas Company
Enclosure
Mark Chiles
Preston Carter
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Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
RE: Case No. INT-G-21-03
Dear Ms. Noriyuki:
Attached for consideration by this Commission is an electronic submission of Intermountain Gas
Company's Application for a Determination of 2020 Energy Efficiency Expenses as Prudently
lncurred, including the2020 Energy Efficiency Annual Report and Supplement.
If you should have any questions regarding the attached, please don't hesitate to contact me at (208)
377-6015.
Sincerely
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INTERMOTINTAIN GAS COMPAI\"Y
CASE NO.INT-G-21-03
APPLICATION
AND
E)GIIBITS
In the Matter of the Application of INTERMOUNTAIN GAS COMPAI\IY
For a Determination of 2A20 Energ5r Efficiency Expenses as Prudently Incurred
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: [phone]
Attorneys for Intermountain Gas Company
In the Matter of the Application of
INTERMOUNTAIN GAS COMPANY
for a Determination of 2020 Energy
Efficiency Expenses as Prudently
Incurred
BEFORE TI{E IDAHO PUBLIC UTILITIES COMMISSION
Case No.INT-G-21-03
Arpr,rcarroN
Intermountain Gas Company ("Intermountain" or "Comp&y"), a subsidiary of MDU
Resources Group,Inc. with general offices located at 555 South Cole Road, Boise, Idaho, pursuant
to the Rules of Procedure ofthe Idaho Public Utilities Commission ("Commission"), 1) submits its
2020 Energt Effciency Annual Report and 2) makes application to the Commission for an order
designating $3,656,158 of 2020 Energy Efficiency expenditures as prudently incuned.
Please address communications regarding this Application to:
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
prestoncarter@ qivenspursley. com
harmonywri ght@ givenspursley. com
and
Lori A. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608
Boise,lD 83707
lori. blattner@inteas. com
ApplrcauoN - 2
In support of this Application, Intermountain alleges and states as follows.
I.INTRODUCTION
Intermountain is a gas utility, subject to the jurisdiction of the Commission, engaged in the
sale of and distribution of natural gas within the State of Idaho under authority of Commission
Certificate No. 219, issued December 2,1955, as amended and supplemented by Order No. 6564,
dated October 3,1962
Intermountain provides natural gas service to the following ldaho communities and counties
and adjoining areas:
Ada County - Boise, Eagle, Garden City, Kuna, Meridian, and Star;
Bannock County - Arimo, Chubbuck, Inkom, Lava Hot Springs, McCammon, and Pocatello;
Bear Lake County - Georgetown, and Montpelier;
Bingham County - Aberdeen, Basalt, Blackfoot, Firth, Fort Hall, Moreland,/Riverside, and Shelley;
Blaine County - Bellevue, Hailey, Ketchum, and Sun Valley;
Bonneville County - Ammon,Idaho Falls, Iona, and Ucon;
Canyon County - Caldwell, Greenleaf, Middleton, Nampa, Parma, and Wilder;
Caribou County - Bancroft, Grace, and Soda Springs;
Cassia County - Burley, Declo, Malta, and Raft River;
Elmore County - Glenns Ferry, Hammett, and Mountain Home;
Fremont County - Parker, and St. Anthony;
Gem County - Emmett;
Gooding County - Bliss, Gooding, and Wendell;
Jefferson County - Lewisville, Menan, Rigby, and Ririe;
Jerome County - Jerome;
Lincoln County - Shoshone;
Madison County - Rexburg, and Sugar City;
Minidoka County - Heybum, Paul, and Rupert;
Owyhee County - Bruneau, Marsing, and Homedale;
Payette County - Fruitland, New Plymouth, and Payette;
Power County - American Falls;
Twin Falls County - Buhl, Filer, Hansen, Kimberly, Murtaugh, and Twin Falls;
Washington County - Weiser.
Intermountain's properties in these locations consist of transmission pipelines, liquefied
natural gas storage facilities, a compressor station, distribution mains, services, meters and
regulators, and general plant and equipment.
ApplrceuoN - 3
II. BACKGROT]ND
In the Company's General Rate Case No. NT-G-I6-02,Intermountain petitioned the
Commission for authority to begin a residential Energy Efficiency Program ("EE Program"). The
Commission granted the Company's request in Order No. 33757 and found 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. As such, we look forward to seeing the Company's program
develop." Case No. INT-G-I6-02. OrderNo.33757 at37.
Subsequently, in Case No. NT-G-I7-03, the Company requested authority to implement
Rate Schedule EE - Residential Energy Efficiency Rebate Program, which outlined the program
offerings, and Rate Schedule EEC - Energy Efficiency Charge, which established a charge to fund
the program. In Order No. 33888, the Commission approved both rate schedules effective October
1,2017.
In Case No. INT-G-19-04,Intermountain requested that the Commission approve the
Company's 2017-2018 EE Program expenses as prudently incuned. In OrderNo. 34536, the
Commission approved the prudency of the expenses with several conditions attached. Those
conditions were to commission a third-party Evaluation, Measurement and Verification ("EM&V")
study, review and update the avoided cost calculation with the Energy Efficiency Stakeholder
Committee ("EESC"), immediately and continuously monitor, evaluate, and update its EE Program
incentives with the best available data, and discontinue the 80% AFUE condensing fireplace
incentive.
To allow all interested customers to participate in the Residential Energy Efficiency Rebate
Program, and to continue to grow the Program, Intermountain requested authority to revise rate
ApplrcauoN - 4
schedule EEC from $0.00367 to $0.02093 per therm in Case No. INT-G-19-05. The Commission
approved the requested revision in Order No. 34454, efifective October 1,2019.
On January 2&,2020,Intermountain filed a TariffAdvice to cancel the 80% AFUE
condensing fireplace rebate. The effective date for the cancellation was March I,2020.
In Case No. INT-G-20-06,Intermountain requested that the Commission approve the
Company's 2019EE Program expenses as prudently incurred.In OrderNo. 34980, the Commission
approved the prudency ofthe expenses. The Company also requested significant changes to the
progftrm based on its frst ever EM&V study that was filed as part of the case. The Commission
approved the proposed modifications effective April 1,2021. The Commission also ordered the
Company to continue to review its avoided costs and update its avoided cost calculations based on
the review, and to immediately and continuously monitor, evaluate, and update its EE Program
incentives with the best available data.
During program year 2020, the EE Program was available to all residential rate class
customers in the Company's service territory and consisted of nvo main categories of rebates: high-
efficient appliances and new residential construction earning both ENERGY STAR certification and
a Home Energy Rating Score (HERS) of 75 or less.
The Company's 2020 Energt Efficiency Annual Report ("Annual Report") is included as
Attachment 1 to this Application and incorporated by reference. The Annual Report consists of the
main document and a supplement. The main report provides a review of the Company's EE
Program finances, cost-effectiveness, and performance by measure. It also outlines the results of the
EM&V study and actions taken by the Company based on the findings and recommendations of the
study. A review of outreach and educational activities, discussion of the Company's participation in
ArplrcnnoN - 5
a collaborative efi[ort to accelerate market introduction of gas heat pump technologies, and future
plans complete the Annual Report. Annual Report at 4.
Supplement I:2020 Cost-Effectiveness ("Supplement") to the Annual Report outlines the
cost-effectiveness for the EE Program and for each individual rebate offlered. It also includes a
proposed schedule to ensure formal EM&V for each rebate on a regular basis
III. REVENUES
The EE Program expenditures are funded through collections from customers via the
Residential Energy Efficiency Charge ("EEC-RS") of $0.02093 per therm. Total EE Program
revenues for calendar year 2020 were $5,41 6 ,740. The revenue collected in2020 was higher than
expected, likely due in part to customers spending more time at home due to the pandemic, which
resulted in higher consumption. Annual Report at 5.
IV. EXPENDITURES
EE Program expenditures from January 1,2020 through December 31,2020werc
$3,656,158. Of this amount, $2,848,550, or approximately 78Yo, is related to energy efficiency
rebates paid directly to customers. Annual Report at 5.
In addition to the amount spent on energy effrciency rebates, the Company incurred
$807,608 of EE Program expenses for labor, program delivery, special studies, and market
transformation. Arurual Report at 5. These expenditures were a critical factor in the tremendous
success the Company's EE Program has enjoyed in its first three years.
The increase in Labor over the 2019 program year is the result of a full year of the staffing
levels that were instituted in20l9. The Energy Services Representatives ("ESR") that are now
partially underwritten by the EE Program are an essential part of the Company's outreach. This was
ApplrceuoN - 6
especially true in the midst of the 2020 worldwide pandemic when most outreach methods
traditionally employed by the Company were cancelled due to COVID-I9. The ESRS were able to
continue promoting the EE Program with every customer interaction and multiplied the energy
efficiency outreach efforts. Annual Report at 15.
Program Delivery expenses were lower than the levels reported in 2019. This was due to the
many events that were cancelled during 2020 due to COVID-I9. The Company pivoted to engage
with customers via electronic means throughout 2020. While these methods provided an avenue to
continue promotion during the pandemic, Intermountain anticipates an increase in Program Delivery
expenses as COVID-19 protocols are relaxed and a normal schedule of events is possible. Annual
Report at 17.
The $129,568 in Special Studies expense is primarily related to the EM&V study and
follow-on analysis to determine the best structure for the Whole Home rebate going forward.
Intermountain is committed to working to secure an energy efficient future. In 2019
Intermountain joined the North American Natural Gas Heat Purnp Collaborative (Collaborative) to
help advance the adoption of gas heat pump technology. With efficiencies of over 1000 , gas heat
pump technology promises to deliver significant efficiency gains when compared to traditional heat
and water heat technology. The Market Transformation expense of $11,000 represents the
Company's membership in the Collaborative. lntermountain believes the continued investnent in
this collaborative effort will provide our customers with significant energy savings and lower
energy bills in the years to come. Annual Report at 25.
V. DEFERRAL BALANCE
The EE Program began the year with an under-collected defenal balance of $442,385. As
previously noted, the Company received approval to increase the EEC-RS effective October l,
AppuceuoN - 7
2019. That increase coupled with higher than expected volumes and lower than budgeted expenses
due to the pandemic flipped the deferral balance to an over-collected balance of $1,318,197 at
December 31,2021. The Company believes that as the economy returns to normal and as customers
begin taking advantage of the new progftlm offerings that became effective April l, 202l,the
increased participation will begin to erode the defenal balance. Because of this, Intermountain does
not plan to file to adjust the EEC-RS in 2021. However, the Company will continue to closely
monitor fluctuations in its rider balance to avoid excessive over or under collection and file for
adjustments as necessary. Annual Report at 5.
VI. THERM SAVINGS
The2020 program year was one of continued growth in participation. It was also a year that
laid the foundation for many changes to the EE Program. Although the program modifications did
not take eflect urtil2021, they should put the EE Program on a solid foundation for future growth.
The Company's first EM&V study was completed in2020 and was included in Case No.
INT-G-20-06 as Exhibit No. 5. The impact evaluation portion of the study was conducted on the
two most redeemed rebates: the Whole Home rebate and the Furnace rebate. The remaining rebates
were already slated for revisions due to low participation, so they were not included in the study.
ADM Associates, Inc. ("ADM") applied two evaluation approaches to each rebate, a billing
analysis and a simulation analysis. The billing analysis and the simulation analysis yielded disparate
results in the case of both the Whole Home and Furnace rebates. Annual Report at 7. When based
on the Simulation Analysis, EE Program therm savings are 804,820. When based on the Billing
Analysis, EE Program therm savings are258,552. Supplement at 6. Because of the significant
variance in therm savings results depending on analysis method,Intermountain proposed significant
changes to both the Fumace and Whole home rebates. These revisions which took effect April 1,
ApplrcarroN - 8
2021 should better align the results of the analysis methods and help the Company avoid under
reporting or overstating therm savings in the future. Annual Report at 8.
ln2020,Intermountain paid out4,537 rebates to customers, representinga36o/o increase
over 2019. The Fumace rebate was the most redeemed rebate at2,744 for the program year. The
Whole Home rebate also continued to be a popular rebate with 1,536 ENERGY STAR Certified,
HERS rated homes built n2020. Annual Report at l. Intermountain received the ENERGY STAR
Certified Home Market Leader Award for the third year in a row in recognition of the Company's
contributions to energy-efficient new home construction. Annual Report at 21.
The Company is encouraged by the strong growth of the EE Program, and looks forward to
working with customers, the Commission, and other stakeholders to maximize participation in and
the cost-effectiveness of the EE Program going forward.
VII. AVOIDED COSTS
While the Commission found the2017-2018 Program expenses to be prudently incurred in
Case No. INT-G-19-04, Order No. 34536, it also directed "the Company and its Energy Advisory
Group to review the Company's avoided cost calculations concurrently with the EM&V study". Id
at 5.
Intermourtain invited interested members of its EESC to join an Avoided Cost
Subcommittee ("Subcommittee") to address the avoided cost issues raised in Order No. 34536. The
Subcommittee met three times between February and June 2020. The Subcommittee agreed upon a
method for calculating avoided commodity and transportation costs but could not agree on a method
to account for avoided distribution costs. Annual Report at 23.
ApplrcerroN - 9
The Company updates the Gas Transportation Costs included in the avoided cost calculation
with its annual Purchased Gas Cost Adjusfinent ("PGA") filing each year. The updated Avoided
Costs are included as Exhibit No. I and incorporated by reference.
The Commodity Costs will be updated as part of the Integrated Resource Plan ("IRP";
planning cycle. The resulting update of the Avoided Costs will be filed with the IRP. The IRP will
also provide the necessary data to inform the calculation of avoided distribution costs. Following the
filing of the Company's 2021 IRP, lntermountain will reconvene the Subcommittee to determine a
methodology for including avoided distribution costs in the calculation.
VI[. COST-EFFECTIVENESS
Intermountain reports the cost-effectiveness of its EE Program based on two industry
standard metrics: the Utility Cost Test ("UCT") and the Total Resource Cost ("TRC"). The UCT
measures cost-effectiveness from the utility company's perspective and takes into consideration
avoided supply costs, program administration costs, and incentives paid by the utility. The TRC
measures cost-effectiveness from the customer's perspective and focuses on avoided supply costs,
program administration costs and net participant costs. Although both are common industry metrics
for measuring cost-effectiveness, the Company relies more on the UCT because it measures the
cost-effectiveness of items directly under the Company's control.
As previously discussed, the Avoided Cost Subcommittee agreed upon a new avoided cost
methodology for use in Intermountain's Energy Effrciency Program planning and evaluations. The
agreed upon avoided costs, as outlined in Exhibit No. l, have been used in all cost-effectiveness
tests included as part of the Annual Report.
To fully weigh the implication of each method used in the EM&V study, the Company
performed cost-effectiveness testing using the post-analysis savings of both the Simulation Analysis
ApplrcaroN- 10
and the Billing Analysis. The EE Program as an entire portfolio was found to be cost-effective
based on the UCT Simulation Analysis with a benefit to cost ratio of 1.5. Using the Billing
Analysis, the EE Program was not cost-effective with a ratio of 0.5. The Annual Report provides a
detailed analysis of the cost-effectiveness of each rebate, along with explanations and justifications
for revisions made to rebates based on the EM&V results and recommendations. Annual Report at
9. As previously discussed, the significant progrtlm changes that were effective April 1, 2021 should
help resolve the disparity found in the two analysis methods and ensure clear cost-effectiveness for
the EE Program going forward.
The Supplement provides a proposed EM&V Schedule for all rebates to ensure a regular
update to deemed therm savings based on actual program data. This regular cycle of EM&V will
help to guarantee the cost-efflectiveness of the EE Program going forward. Supplement at 13.
IX. STAKEHOLDER MEETINGS
The Energy Efficiency Stakeholder Committee has been a valuable resource for the
Company as it builds the EE Program. As outlined in the Annual Report,lntermountain hosted three
full EESC meetings, three Avoided Cost Subcommittee meetings, and a Commercial Subcommittee
meeting. The meetings have included good representation from a variety of groups including
representatives from the Commission Staff, the Governor's Office of Energy and Mineral
Resources, and conservation group representatives. Home energy raters representing both sides of
the state attended, as well as builders and fryAC professionals. The Company also recruited
commercial industry experts to provide insight into the development of the Commercial EE
Program that launched April 1,202I.
The minutes from the Avoided Cost Subcommittee meetings were included in Case No.
INT-G-20-06 as Exhibit No. 2. The minutes from the frrll EESC meetings were included in Case
Applrcnuox - I I
No. INT-G-20-06 as ExhibitNo.4. These meetings were important inthe development of the
Company's revisions to its residential rebate offerings.
The Company hosted an EESC Commercial Subcommiuee on July 15,2020. Minutes from
that meeting are included as Exhibit No. 2 and incorporated by reference. The Commercial
Subcommittee provided guidance and expertise regarding the development of the first ever rebate
offering for commercial customers. Annual Report at 23.
X. MODIFIED PROCEDURE
lntermountain requests that this matter be handled under modified procedure pursuant to
Rules 201-204 of the Commission's Rules of Procedure. Intermountain stands ready for immediate
consideration of this matter.
AppncerroN- 12
)ilr. REQIiEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Commission issue an order designating $3,656,158 of 2020 Energy Efficiency
expenditures as pnrdently incurred,
b. That this Application be heard and acted upon without hearing turder moffied procedure,
and
c. For such other relief as this Commission may determine proper herein.
DATED: July 14,2021.
INTERMOUNTAIN GAS COMPANY Givens Pursley LLP
dnkBltE f
By
Lori A. Blattrer
Director - Regulatory Affairs
By
Preston N. Carter
Attorney for Intermountain Gas Company
ApplrcnrroN- [3
E)CIIBIT NO. 1
CASE NO. INT.G.21.O3
INTERMOT]IYTAIN GAS COMPANY
Avoided Cost Calculrtion
(17 pages)
Exhibit No. 1
Case No. INT-G21-03
lntermountain Gas Company
Page'l of 17
Avoided Costs
Overuiew
The avoided cost represents those costs that the Company does not incur as a result of energy
savings generated by its Energy Efficiency Program. The calculation is used both to
economically evaluate the present value of the therms saved over the life span of a measure
and to track the performance of the program as a whole.
Avoided costs are forecasted out 30 years in order to properly assess Energy Efficiency
measures with longer lifespans. This forecast is based on the performance of the Company's
portfolio under expected market conditions.
Costs Incorporated
lntermountain's avoided cost calculation contains the following components:
ACnominot= CC + TC + VDC
Where:
o ACnmrinot = The nomina! avoided cost for a given year
o CC= CommodityCosts
o IC=TransportationCosts
o VDC=Variable Distribution Costs
Thefollowing parameters are also used inthe calculation of the avoided cost:
o The assumed fonarard-looking annual inflation rate is 2.0%.
o The discount rate is derived using lntermountain's tax-effected cost of capital.
o Standard present value and levelized cost methodologies are utilized to develop a
real and nominal levelized avoided cost by year.
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 2 ot 17
Understanding Each Component
Commodity Costs
Commodity costs represent the purchase price of the natural gas molecules that the Company
does not need to buy due to therm savings generated by its Energy Efficiency Program. To
calculate the commodity costs, the Company first utilizes price forecasts included in its lntegrated
Resource Plan (lRP) for three primary basins (AECO, Sumas, and Rockies) then weights these
forecasts based on lntermountain's historical day-gas purchase data. Day-gas purchases
represent the first costs that could be avoided through Energy Efficiency Program savings. To
account for the seasonal nature of energy savings, the weighted price is shaped by normal
monthly weather, measured in heating degree days with a base of 65 degrees. The original basin
price forecasts span through 2036 and then an escalator is applied through the remainder of the
forecast period. The gas price forecasts will be updated in each IRP planning cycle.
Tronsportotion Costs
Transportation costs are the costs the Company incurs to deliver gas to its distribution system.
As the Company's Energy Efficiency Program generates therm savings, the Company can reduce
pipeline capacity needs and monetize any excess capacity to reduce costs for all customers
through credits in the Company's annual Purchased Gas Cost Adjustment (PGA) filing. The
Company calculates the per therm transportation cost as the weighted average of the gas
transportation costs listed on the Company's residential and commercial tariffs. The nominal
value of the transportation cost is increased each year by the model inflation rate of 2.Oo/o. The
inflated nominal value is then discounted back to today's dollars as part of the final step in the
avoided cost calculation. The Company will update the transportation cost each year to reflect
the most current gas transportation cost as filed in its PGA.
Vo rioble Distribution Costs
Variable distribution costs are the avoidable portion of costs incurred by lntermountain to
deliver gas to customers via its distribution system. Lowering gas consumption through the
Company's Energy Efficiency Program allows lntermountain to delay costly capacity
expansion projects and utilize existing pipeline infrastructure more efficiently. While these
cost benefits are intuitively apparent, the Company and its Stakeholder group are
investigating methods to quantify these savings. The Company is currently using a
placeholder value of zero for this component.
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 3 of 17
AVOIDED COST BY YEAR
(1 page)
INTERMOUNTAIN GAS COMPANY
Avoided Cost by Year
Exhibit No. I
Case No. INT-G-2l-03
lntermountain Gas Company
Page 4 ol 17
Avoided Cost
Per Thermtal
Line
No.Year
NominalCost
Per Thermtll
Real Percent
Adjustmentt2l
Real Cost
Per Therm
Present
Valuel3l
(a)(b)(c)(d)(e)(0
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
2019 $
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
0.51
0.52
0.49
0.48
0.49
0.50
0.54
0.56
0.57
0.58
0.60
0.62
0.63
0.64
0.65
0.67
0.68
0.70
0.72
0.74
0.76
0.78
0.80
0.82
0.84
0.87
0.89
0.91
0.94
0.96
-1.72%
-7.65%
-3.53%
-0.02o/o
0.13o/o
6.52o/o
1.030/o
0.160/o
-0.42o/o
0.99%
1.21o/o
0.02%
-0.63%
0.19o/o
0.820/o
0.25o/o
0.64%
0.640/o
0.65%
0.65%
0.65%
0.66%
0.66%
0.66%
0.66%
0.67o/o
0.670/o
0.670/o
0.68%
0.51 $
0.51
0.47
0.45
0,45
0.45
0.48
0.49
0.49
0.48
0.49
0.50
0.50
0.49
0.49
0.50
0.50
0.50
0.50
0.51
0.51
0.51
0.52
0.52
0.52
0.53
0.53
0.54
0.54
0.54
0.49 $
0.95
1.36
1.74
2.09
2.44
2.79
3.12
3.45
3.75
4.05
4.33
4.61
4.87
5.11
5.35
5.58
5.80
6.01
6.22
6.41
6.60
6.78
6.96
7.12
7.28
7.44
7.59
7.73
7.87
0.51
0.51
0.50
0.49
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.49
0.49
0.49
0.49
0.49
0.49
0.49
0.49
0.49
0.49
0.49
$
NOTES
t'l See Exhibit No. 1, Page 6, Column (e).
t2l The year over year percentage change in Column (b), adjusted by the inflation assumption on
Exhibit No. 1, Page 17, Line 4, Column (b).
ttl The cumulative present value of Column (d) is calculated using the real discount rate on
Exhibit No. 1, Page 17, Line 5, Column (b).
tal Levelized avoided cost of Column (e) computed with the real discount rate on Exhibit No. 1,
Page 17, Line 5, Column (b).
Exhibit No. 1
Case No. INT-G-2l-03
lntermountain Gas Company
Page 5 of 17
NOMINAL AVOIDED COST BY YEAR
(1 page)
INTERMOUNTAIN GAS COMPANY
Nominal Avoided Gost by Year
Variable Distribution
cosd3l
Transportation
Costtal
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 6 of 17
Total
Costtsl
Line
No.Year
Commodity
6sstttltzl
(a)(b)(c)(d)(e)
$1
2
3
4
5
o
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
2019 $
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
2041
2042
2043
2044
2045
2046
2047
2048
0.31 $
0.30
0.27
0.26
0.26
0.27
0.31
0.32
0.33
0.33
0.34
0.36
0.36
0.37
0.38
0.39
0.40
0.41
0.42
0.44
0.45
0.46
0.48
0.49
0.51
0.52
0.54
0.56
0.57
0.59
0.21 $
0.21
0.22
0.22
0.23
0.23
0.24
0.24
0.24
0.25
0.25
0.26
0.26
0.27
0.28
0.28
0.29
0.29
0.30
0.30
0.31
0.32
0.32
0.33
0.34
0.34
0.35
0.36
0.36
0.37
0.51
0.52
0.49
0.48
0.49
0.50
0.54
0.56
0.57
0.58
0.60
0.62
0.63
0.64
0.65
0.67
0.68
0.70
0.72
0.74
0.76
0.78
0.80
0.82
0,84
0.87
0.89
0.91
0.94
0.96
NOTES
t'l See Exhibit No. 1, Pages 8-13, Column (f). Divided by 10 to convert units from dekatherms
to therms.
l2l Annual growth after 2036 is tied to yearly percentage change of the prior period.
I3l Placeholder value of zero until a Variable Distribution Cost methodology is developed.
tol See Exhibit No. 1, Page 15, Line 8, Column (d). Annualgrowth is tied to inflation assumption
from Exhibit No. 1, Page 17, Line 4, Column (b).
ttl Sum of Columns (b)-(d).
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
PageT ot 17
COMMODITY COST
(6 pages)
INTERMOUNTAIN GAS COMPANY
Commodity Cost
Weighted Basin HDD
Price Forecasttll Weighll2l
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 8 of 17
Commodity
Cost
Line
No.
Heating
Year Month
HDD
Factol3I
(a)(b)(c)(d)(e)(0
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
2019
2019
2019
2019
2019
2019
2019
2019
2019
2019
2019
2019
2020
2020
2020
2020
2020
2020
2020
2020
2020
2020
2020
2020
2021
2021
2021
2021
2021
2021
2021
2021
202',1
2021
2021
2021
10$
11
12
1
2
3
4
5
6
7
8
o
10
11
12
1
2
3
4
5
6
7
8
I
10
11
12
1
2
3
4
5
6
7
8
I
2.59
2.69
3.27
3.32
3.53
3.01
2.77
2.35
2.38
2.94
3.05
2.64
2.59
2.69
3.27
3.32
3.53
3.01
2.77
2.15
2.16
2.60
2.71
2.29
2.30
2.25
2.82
3.05
3.14
2.65
2.46
1.98
2.01
2.39
2.46
2.28
3%$
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7o/o
3Yo
1o/o
Ao/o
1%
0.09
0.23
0.49
0.67
0.58
0.44
0.28
0.17
0.08
0.03
0.00
0.02 $3.06
3o/o
9%
15o/o
20o/o
16%
14o/o
10o/o
7o/o
3%
1o/o
0o/o
1%
3o/o
9%
15%
20o/o
160/o
14o/o
10o/o
7o/o
3o/o
1o/o
0o/o
1%
0.09
0.23
0.49
0.67
0.58
0.44
0.28
0.15
0.07
0.02
0.00
0.01 $3.03
0.08
0.19
0.42
0.61
0.51
0.38
o.25
0.14
0.07
0.02
0.00
0.01 $
NOTES
t'l See Case No. INT-G-20-06, Confidential Workpaper No. 1, Column (i).
I2l Monthly HDD65 weighting. Based on a normalweather year.
t'l Column (c)times Column (d).
2.70
INTERMOUNTAIN GAS COMPANY
Commodity Cost
Exhibit No. 'l
Case No. INT-G-21-03
lntermountain Gas Company
Page 9 of 17
Commodity
Cost
Line
No.
Heating
Year Month
Weighted Basin
Price Forecastlll
HDD
Weigfrlt2l
HDD
Factol3I
(a)(b)
2022
2022
2022
2022
2022
2022
2022
2022
2022
2022
2022
2022
2023
2023
2023
2023
2023
2023
2023
2023
2023
2023
2023
2023
2024
2024
2024
2024
2024
2024
2024
2024
2024
2024
2024
2024
(d)(e)(c)(0
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
10$
11
12
I
2
3
4
5
o
7
8
I
10
11
12
1
2
3
4
5
6
7
8
I
10
11
12
,|
2
3
4
5
6
7
8
9
2.29
2.33
2.77
2.97
2.87
2.41
2.27
1.93
2.05
2.36
2.41
2.37
2.34
2.44
2.82
3.01
2.94
2.43
2.3'.1
1.97
2.09
2.45
2.49
2.45
2.44
2.55
2.69
2.91
3.13
2.58
2.44
2.13
2.23
2.54
2.57
2.54
3%
9o/o
15o/o
20o/o
160/o
14o/o
10%
7%
3o/o
1o/o
0%
1o/o
3o/o
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7o/o
3o/o
1o/o
0o/o
1o/o
3%
9%
15%
20%
160/o
14%
10o/o
7o/o
3o/o
1o/o
0o/o
1o/o
0.08
0.20
0.41
0.60
0.47
0.35
0.23
0.14
0.07
0.02
0.00
0.01 $2.58
$
0.08
0.21
0.42
0.60
0.48
0.35
0.23
0.14
0.07
0.02
0.00
0.01 $2.63
0.08
0.22
0.40
0.59
0.s1
0.37
0.24
0.15
0.08
0.02
0.00
0.02 $
NOTES
I'l See Case No. INT-G-20-06, Confidential Workpaper No. 1, Column (i).
l2l Monthly HDD65 weighting. Based on a normalweather year.
l'1 Column (c) times Column (d).
2.69
INTERMOUNTAIN GAS COMPANY
Commodity Cost
Weighted Basin HDD
Price Forecasttll Weighlt2l
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 10 of '17
Commodity
Cost
Line
No.
Heating
Year Month
HDD
Factol3l
(a)(b)(c)(d)(e)(f)
1
2
3
4
5
6
7
I
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
2025
2025
2025
2025
2025
2025
2025
2025
2025
2025
2025
2025
2026
2026
2026
2026
2026
2026
2026
2026
2026
2026
2026
2026
2027
2027
2027
2027
2027
2027
2027
2027
2027
2027
2027
2027
10$
11
12
1
2
3
4
5
o
7
I
I
10
11
12
1
2
3
4
5
6
7
8
I
10
11
12
1
2
3
4
5
6
7
8
9
2.61
2.62
3.11
3.33
3.49
3.05
2.92
2.55
2.58
2.92
3.02
2.74
2.74
2.75
3.24
3.45
3.6'1
3.16
3.02
2.67
2.68
3.02
3.13
2.86
2.85
2.86
3.34
3.51
3.66
3.23
3.08
2.74
2.74
3.09
3.20
2.92
3o/o
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7%
3o/o
1o/o
0%
1o/o
3o/o
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7o/o
3o/o
1o/o
0o/o
1o/o
3o/o
9%
15o/o
20o/o
160/o
14o/o
10%
7o/o
3o/o
1o/o
0o/o
1o/o
0.09
0.22
0.46
0.67
0.57
0.44
0.29
0.18
0.09
0.03
0.00
0.02 $3.07
$
0.10
0.24
0.48
0.69
0.59
0.46
0.30
0.19
0.09
0.03
0.00
0.02 $3.19
0.10
0.24
0.50
0.70
0.60
0.47
0.31
0.19
0.09
0.03
0.00
0.02 $
NOTES
ltl See Case No. INT-G-20-06, ConfidentialWorkpaper No. 1, Column (i).
I2l Monthly HDD65 weighting. Based on a normal weather year.
Itl Column (c)times Column (d).
3.26
INTERMOUNTAIN GAS COMPANY
Gommodity Cost
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 11 ol 17
Commodity
Cost
Line Heating
YearNo.Month
HDD
Weighlt2l
HDD
Factol3l
Weighted Basin
Price Forecasttll
(a)(b)
2028
2028
2028
2028
2028
2028
2028
2028
2028
2028
2028
2028
2029
2029
2029
2029
2029
2029
2029
2029
2029
2029
2029
2029
2030
2030
2030
2030
2030
2030
2030
2030
2030
2030
2030
2030
(c)(d)(e)(0
1
2
3
4
5
6
7
8
I
10
11
12
13
'14
15
16
'|.7
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
10$
11
12
1
2
3
4
5
6
7
I
9
10
11
12
1
2
3
4
5
E,
7
II
10
11
12
1
2
3
4
5
6
7
8
I
2.92
2.92
3.39
3.55
3.67
3.29
3.12
2.77
2.79
3.13
3.25
2.99
2.99
3.00
3.46
3.69
3.81
3.44
3.24
2.91
2.91
3.28
3.39
3.13
3.14
3.15
3.61
3.83
3.96
3.57
3.36
3.03
3.04
3.39
3.50
3.26
3%$
9%
15o/o
20%
160/o
14o/o
10%
7o/o
3o/o
1%
0o/o
1o/o
0.10
0.25
0.50
0.71
0.60
0.48
0.31
0.20
0.10
0.03
0.00
0.02 $3.30
3%
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7o/o
3%
1o/o
0o/o
1%
3o/o
9o/o
15o/o
20%
160/o
14%
10%
7o/o
3o/o
1%
0o/o
1o/o
0.10
0.26
0.51
0.74
0.62
0.50
0.32
0.21
0.10
0.03
0.00
0.02 $3.42
0.11
0.27
0.54
0.77
0.65
0.52
0.34
0.22
0.10
0.03
0.00
0.02 $
NOTES
I1l See Case No. INT-G-20-06, ConfidentialWorkpaper No. 1, Column (i)
t2l Monthly HDD65 weighting. Based on a normalweather year.
ttl Column (c) times Column (d).
3.56
INTERMOUNTAIN GAS COMPANY
Commodity Gost
Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 12 ot 17
Commodity
Cost
Line Heating
YearNo.Month
Weighted Basin
Price Forecasttll
HDD
Weiqhtt2]
HDD
Factol3l
(a)(b)(c)(d)(e)
3%$
9o/o
15o/o
20o/o
160/o
14o/o
1Oo/o
7o/o
3%
1o/o
0o/o
1o/o
(0
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
2031
2031
2031
2031
2031
2031
2031
2031
2031
2031
2031
2031
2032
2032
2032
2032
2032
2032
2032
2032
2032
2032
2032
2032
2033
2033
2033
2033
2033
2033
2033
2033
2033
2033
2033
2033
10$
11
12
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
I
10
11
12
1
2
3
4
5
6
7
I
I
3.26
3.28
3.75
3.89
4.02
3.61
3.41
3.08
3.10
3.45
3.54
3.31
3.31
3.33
3.80
3.91
4.04
3.65
3.44
3.10
3.14
3.49
3.57
3.34
3.34
3.37
3.84
4.02
4.15
3.75
3.53
3.20
3.24
3.60
3.67
3.46
0.11
0.28
0.56
0.78
0.66
0.52
0.34
0.22
0.11
0.03
0.00
0.02 $3.64
3%
9o/o
15o/o
20o/o
16%
14o/o
10o/o
7o/o
3%
1o/o
0o/o
1o/o
3o/o
9o/o
15o/o
20o/o
160/o
14o/o
10o/o
7o/o
3o/o
1%
0o/o
1o/o
0.11
0.29
0.56
0.79
0.66
0.53
0.34
0.22
0.11
0.03
0.00
0.02 $3.67
0.12
0.29
o.57
0.81
0.68
0.54
0.3s
0.23
0.11
0.03
0.00
0.02 $
NOTES
ltl See Case No. INT-G-20-06, Confidential Workpaper No. 1, Column (i).
t21 Monthly HDD65 weighting. Based on a normal weather year.
I'l Column (c) times Cotumn (d).
3.75
INTERMOUNTAIN GAS GOMPANY
Gommodity Cost
Exhibit No. 'l
Case No. INT-G-21-03
lntermountain Gas Company
Page'13 of 17
Commodity
Cost
Line Heating
YearNo.Month
HDD
Weig6ltzl
HDD
Factol3l
Weighted Basin
Price Forecasttll
(a)(b)(c)(d)(e)(0
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
'18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
2034
2034
2034
2034
2034
2034
2034
2034
2034
2034
2034
2034
2035
2035
2035
2035
2035
2035
2035
2035
2035
2035
2035
2035
2036
2036
2036
2036
2036
2036
2036
2036
2036
2036
2036
2036
10$
11
12
1
2
3
4
5
6
7
I
9
10
11
12
1
2
3
4
5
6
7
8I
10
11
12
1
2
3
4
5
6
7
8
9
3.45
3.49
3.97
4.15
4.27
3.88
3.67
3.34
3.36
3.72
3.82
3.60
3.60
3.63
4.11
4.21
4.35
3.96
3.76
3.44
3.44
3.79
3.91
3.65
3.66
3.65
4.14
4.37
4.61
4.08
3.94
3.45
3.51
4.00
4.14
3.66
3%$
9%
15o/o
20%
160/o
14%
10o/o
7o/o
3o/o
1o/o
0o/o
1%
0.12
0.30
0.59
0.83
0.70
0.56
0.37
0.24
0.11
0.04
0.00
0.02 $3.88
3%
9o/o
15o/o
20%
16%
14%
10%
7%
3%
1%
0o/o
1o/o
3%
9%
15o/o
20o/o
16%
14o/o
10o/o
7o/o
3o/o
1o/o
0o/o
1o/o
0.12
0.31
0.61
0.85
0.71
0.57
0.38
0.24
0.12
0.04
0.00
0.02 $3.98
0.13
0.31
0.61
0.88
0.75
0.59
0.40
0.25
0.12
0.04
0.00
0.02 $
NOTES
t1l See Case No. INT-G-20-06, Confidential Workpaper No. 1, Column (i).
t2l Monthly HDD65 weighting. Based on a normalweather year.
l'l Column (c) times Column (d).
4.10
Exhibit No. I
Case No. INT-G-2l-03
lntermountain Gas Company
Page 14 ot 17
AVOIDED GAS TRANSPORTATION COST
(1 page)
Exhibit No. 1
Case No. INT-G-2l43
lntermountain Gas Company
Page 15 of 17
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Exhibit No. 1
Case No. INT-G-21-03
lntermountain Gas Company
Page 16 of 17
DISCOUNT RATE
(1 page)
Exhibit No. 1
Case No. INT-G21-03
lntermountain Gas Company
Page 17 ol 17
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EXHIBIT NO.2
CASE NO. INT.G.21.O3
INTERMOT]NTAIN GAS COMPAIYY
Energr Efficiency Stakeholder Committee Meeting Minutes
(3 pages)
Exhibit No.2
Case No. INT-G21{3
lntermountain Gas Gompany
Page 1 of3
lntermountain Gas Energy Efficiency Stakeholder Committee
Com me rcia I Su bcom m ittee
July 15, 2020 at 1:00 PM
Minutes Recorded by Kody Thompson
Attendees:
Brian Bennett -The Energy Auditor
John Chatburn - OEMR
Lori Blattner - IGC
Mark Chiles - IGC
John Fisk - IGC
Kody Thompson - IGC
Kathy Wold - IGC
Jonathan Grove - ATS lnland NW
Jennifer Lightfoot - Ada County
Brad lverson-Long - IPUC
Marissa Warren - OEMR
Mike Morrison - IPUC
Ben Otto - ldaho Conservation League
Ben Seitz - Sunbelt Controls
Katie Pegan - OEMR
Matt Vandermeer - Momentum
Brian Shiroma- ES&R Design & Supply
Kevin Keyt - IPUC
Meeting Facilitator: Kathy Wold
L:00 PM Meeting Convened - Kathy Wold
Kathy Wold gave an overview of the meeting agenda and provided an ice breaker to begin the meeting.
Exhibit No. 2
Case No. INT-G-21-03
lntermountain Gas Company
Page 2 of 3
1:15 PM CPA Final Report - Kathy Wold
Kathy provided a review of the Conservation PotentialAssessment (CPA) as it related to commercial
savings potential. The review included the different levels of potential (technical, economic and
achievable), three potential savings scenarios (low, base and maximum), market characterization,
measure characterization, and recommendations given under the CPA.
The Committee asked about how incentive levels would be set, the rate class to which the commercial
rebate would apply and whether the potential savings could be broken down by percentage of class
consumption.
1:30 PIV Commercial Program Methodology - Kathy Wold
Kathy explained that cost-effectiveness is the primary goal of the commercial program and that the
Company would follow the model of the residential program of starting with a modest initial offering to
better understand the market, energy efficiency goals and needs of commercial customers. The top 10
measures identified in the CPA were discussed, along with the measures that were planned to be
included in the program based on feasibility of administering the program and the savings identified in
the CPA.
A committee member mentioned Rocky Mountain Power did direct replacements with customers on
high efficiency faucets, which also provided good access to begin discussions on the high-efficient
equipment. Other committee members agreed including installation was a good idea.
1:45 PIV Final Commercial Program Draft - Kathy Wold
Kathy explained the initial design of the program offering was based on the CPA base scenario using an
incentive level of 50% of the measure incremental cost. lncentive levels were fine-tuned to either meet or
maxi m ize cost-effectiveness testi ng.
The Committee asked questions about the definition of incremental costs and how incremental costs
were provided. lncrementalcosts are the estimated cost differential between the standard equipment
and the high-efficiency option. lncremental costs for each measure were provided by the CPA.
2:00 PM Feedback Requested
A committee member stated the boiler reset control is a good suggested offering, but also recommended
restricting this measure to space heating only as it is ineffective with boilers for water heating.
A committee member with commercial food service equipment expertise, recommended the Company
explore the energy savings opportunities of a griddle. This is a commonly used piece of equipment and
there is also an ENERGY STAR certified griddle that is considerably more expensive than the standard
equipment.
A committee member commented that outside of the proposed commercial rebates, there is a lot of
90%+ equipment in commercial settings that have not been correctly commissioned, and therefore do
not achieve expected efficiencies. He recommended the Company explore incentivizing testing and
commissioning of existing systems to capture energy savings and make commissioning part of the
application requirement. Education regarding commissioning protocols may also be a necessary step.
Exhibit No. 2
Case No. INT-G21-03
lntermounlain Gas Gompany
Page 3 of 3
Committee members inquired about the timetable for a custom commercial program. The Company is
first focused on establishing the commercial rebate program.
Another committee member commented that commissioning equipment is important for long term
savings and recommended developing relationships with early adopters, which will help grow the
Program. He also recommended exploring incentives for architects & engineers to help advise their
clients in new builds. Committee member questioned if there are opportunities to partner with
organizations who perform HVAC commissioning, possibly offering an incentive to have them report back
savings and help develop relationships.
Committee members commented that combining smaller measures into an Energy Savings Kit is a good
idea. Committee member inquired about how the Energy Kits will be distributed. He recommended
distributing the kits to contractors to perform direct installation. This would help ensure the measures are
installed as intended and opens the door to more conversations with customers.
2:L5 PM Meeting Closed
2020
ANNUAL REPORT
SU PPLEM ENT 1 : 2O2O COST-EFFECTIVENESS
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Energy
Efficiencylobr,,oCn,mttf toSqw'
lntroduction
lntermountain's Energy Efficiency Program (EE Program) offers individual customers a way to lower their
usage and monthly energy bills. lt additionally benefits all customers by ensuring resources are used
efficiently which delays the need for expensive system upgrades and additional supply contracts,
thereby keeping costs low for everyone. Cost-effectiveness testing is vital to ensuring the Company's EE
Program is in fact a least-cost resource, and is integral to the design, implementation and success of the
EE Program.
lntermountain initially launched the EE Program as a modest residential rebate offering. The original
proBram allowed lntermountain to gauge customer interest in installing high-efficiency naturalgas
equipment and served as a starting point to refine and further develop cost-effective, relevant program
offerings.
Following the launch of the EE Program, lntermountain commissioned an independent 3'd party to
conduct a comprehensive Conservation Potential Assessment (CPA) to quantifo energy efficiency
resources available within the Company's service territory, to support both short-term energy efficiency
planning and long-term resource planning activities, and to provide the most up-to-date market data for
both the residential and commercial sectors. This study serves as the basis for modifications to current
rebates that underperformed and was used to design new rebates and programs.
To improve the two most popular rebates, lntermountain also commissioned an Evaluation,
Measurement and Verification (EM&V) study. The EM&V study provided data on actual therm savings
related to the furnace and whole home rebates, as well as insights to be used to further refine and
improve the EE Program.
Cost-Effectiveness and Methodology
Intermountain's objective is for all rebates is to have benefit/cost ratios greater than one for the Utility
Cost Test (UCT). The UCT measures cost-effectiveness from the utility company's perspective and takes
into consideration avoided supply costs, program administration costs and incentives paid by the utility.
Rebates undergo cost tests at several stages: preliminary design, implementation, and an annual review.
For a different perspective, cost-effectiveness of rebates is also evaluated based on the customer's
perspective using avoided supply costs, program administration costs and net participant costs, or the
Total Resource Cost Test (TRC). However, the TRC is not the primary cost test used for decisions
regarding the inclusion or exclusion of rebate offerings. ln calculating the UCT and TRC, lntermountain
1
relies on the calculations outlined in the Colifornia Stondard Proctice Manualand the National Action
Plan for Energy Efficiency's (NAPEE) Understanding Cost Effectiveness of Energy Efficiency Programs:
Best Practices, Technical Methods, ond Emerging lssues for Policy-Mokers.
Rebate characteristics such as estimated useful life, deemed therm savings, and incremental cost used
for cost-effectiveness testing are provided by the CPA study for all rebates, other than the furnace and
whole home rebates. Estimated therm savings for the furnace and whole home rebates are based on
the EM&V impact evaluation. The rebate count used in the cost-effectiveness calculation is the actual
number of rebates paid for the program year.
Cost-effectiveness of EE Program rebates are reviewed annually. The results are reported in the annual
report and reviewed with the Energy Efficiency Stakeholder Committee (EESC). Rebate performance,
cost-effectiveness, market insights, and lessons learned are taken into consideration when deciding
whether to continue, revise or retire a rebate.
Assumptions
ln calculating cost-effectiveness for each rebate and for the program as a whole, the Company relied
upon several assumptions as well as studies provided by independent third-party sources. The section
below discusses the key inputs used in calculating cost-effectiveness and the assumptions and sources
used.
Energy Savings
Energy savings for each rebate are calculated by multiplying each rebate's gross annual therm savings by
the total number of rebates issued. The energy savings are then valuated based on the Company's
Avoided Cost. The Avoided Cost is used both to economically evaluate the present value of the therms
saved over the life span of the measure and to track the performance of the program as a whole. A
more in-depth discussion of the Avoided Cost calculation and its components can be found in Case No.
INT-G-21-03, Exhibit No. 1.
Rebate Costs
Total rebate costs are calculated by multiplying the value of each rebate by the number of rebates
issued for the year.
2
Equipment & lnstallation Cost
The incremental equipment and installation costs are inputs to the TRC cost test and were provided by
the CPA. These costs represent the incremental purchase and installation costs the participant will pay
between a base case measure and a higher efficient alternative. These costs are not offset by the
amount of the rebate received by the participant.
Progrom Delivery & Administration
Program delivery and administration costs are allocated to each rebate based on the percentage of the
total annual portfolio of therm savings that rebate represents. Any cost incurred solely for a particular
rebate will be directly assigned to that rebate.
Real Discount Rdte
The real discount rate is used to account for the time-value of money and accurately compare costs. The
real discount rate is based on the Company's tax-affected weighted average cost of capital. The
calculation of the real discount rate can be found in Case No. INT-G-21-03, Exhibit No. 1, Page t7.
lnflation Rote
An inflation assumption is used in cost-effectiveness testing to convert nominal, forward-looking costs
into real dollars. The company assumes an inflation rale of 2.0%.
Net-to-Gross
Net-to-gross (NTG) is a ratio that adjusts the therm savings of rebates and/or programs, so they solely
reflect energy efficiency gains that are the direct result of energy efficiency programs. The NTG deducts
therm savings resulting from free-ridership, or savings that would have occurred regardless of the
program. lt also increases therm savings to account for spillover, or savings that occurred but were not
counted by the program, as well as therm savings resulting from market transformation. Unfortunately,
estimates of net savings require making sweeping assumptions to model a theoretical scenario where
the EE Program did not exist. Because of the difficulty in accurately calculating NTG percentages, the
Company used an NTG of t00%for all rebate and program cost-effectiveness analysis. lntermountain
also performs a sensitivity analysis for each rebate that determines the minimum allowable NTG ratio
where the rebate would remain (or become) cost effective under the Utility Cost Test.
3
Results
As stated previously, lntermountain uses the UCT as the primary measure for determining cost-
effectiveness for each rebate offering and for the entire program. The EM&V evaluation was completed
during the 2020 Program year. For the impact evaluation, ADM applied two evaluation methodologies
to the Whole Home rebate and the Furnace rebate, simulation analysis and billing analysis. The two
approaches yielded widely disparate results. For both rebates, the simulation analysis produced post-
analysis therm savings estimates that appeared to be overstated, exceeding even the CPA therm savings
estimate for the measure. On the other hand, the post-analysis savings estimate from the billing analysis
appeared to understate savings, because the billing analysis did not isolate for changes in household
behavior, equipment, or occupancy, and included factors other than the impact of improved equipment
efficiency, resulting in post-analysis therm savings far less than estimated.
To fully evaluate the implications of each method used in the evaluation, the Company performed cost-
effectiveness testing using the post-analysis savings of both the simulation analysis and the billing
analysis. Two UCT ratios, UCT Simulation and UCT Billing, are provided for the portfolio and for each
incentive, as well as TRC Simulation and TRC Billing. Under the simulation analysis, the Program was
found to be cost-effective with a UCT of 1.5, but not cost-effective under the billing analysis evaluation
with a UCT of 0.5. Due to the disparity in the results of these two approaches, the Company significantly
revised the Program offering to more accurately reflect therm savings. lntermountain specifically
implemented evaluation recommendations that would help avoid under reporting or overstating therm
savings. These changes took effect April 1, 2021.
EM&V Schedule
The Company prepared a proposed EM&V schedule through 2O24. The dates on the schedule indicate
the final year of data that will be included in the study. For example, the initial study that was conducted
in 2020 used data through the year ended 2019.
The schedule may be amended depending on the Company's ability to collect enough data over the time
frames listed to generate a study that will provide statistically significant insights. For example, the
Company will review the number of rebates issued and the ability to measure usage over several full
heating seasons for heating equipment as some of the metrics used to determine the actual timing of
EM&V studies. The Company will also consult with the EESC on actual EM&V study timing. ln the
4
interim years between formal, third-party evaluation, the Company will monitor, evaluate, and update
program incentives with the best data available.
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13
2020
ANNUAL REPORT
.-ffirarr s,5
-^O -
INTERMOUNTAIN'
GAS COMPAI.IY,gtrtdruWdqM
l,tt CowltybS.ri'
Energy
EfficiencyAlo
o
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INDEX
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5
6
7
TABLE OF CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION .....
COST.EFFECTIVENESS TESTING METHOD
EM&V IMPACT EVALUATION . . . . .
ENERGY EFFICIENCY REBATES
ENERGY EFFICIENCY PORTFOLIO
FURNACE INCENTIVES
LESSONS & REVISIONS. FURNACE
COMBI RADIANT HEAT SYSTEM INCENTIVES
LESSONS & REVISIONS - RADIANT COMBO INCENTIVES
FIREPLACE INCENTIVES
LESSONS LEARNED - FIREPLACE INCENTIVES
WATER HEATER INCENTIVES
LESSONs & REVISIONS - WATER HEATER INCENTIVES
TANKLESS WATER HEATER INCENTIVES
LESSONS & REVISIONS - TANKLESS WATER HEATER INCENTIVES
WHOLE HOME INCENTIVES . .
LESSONS LEARNED - WHOLE HOME INCENTIVES . .
NEW REBATES
EM&V RECOMMENDATIONS & ACTIONS
IMPACTS OF COVID-19
PROGRAM OUTREACH, AWARENESS & EDUCATION
ENERGY EFFICIENCY TEAM . . .
CUSTOMERS & COMMUNITY .....
CoNTRACTORS .....
HOME BUILDERS. .. .
EM&V PROCESS EVALUATION
ENERGY EFFICIENCY STAKEHOLDERS . . . . . . . . . .
AVOI DED COST SUBCOM MITTEE
ENERGY EFFICIENCY STAKEHOLDER COMMITTEE
EESC-COMMERCIAL .
ENERGY EFFICIENT FUTURE
LOOKING AHEAD
,9
,9
.9
.9
10
'10
10
11
11
1't
11
11
12
12
13
13
14
15
15
't6
't7
18
22
23
23
23
23
25
27
LIST OF TABLES
TABLE 1.2020 RIDER BALANCE
TABLE 2. 2O2O UCT RESULTS
TABLE 3. RESIDENTIAL REBATES GROWTH BY DISTRICT
LIST OF FIGURES
FIGURE 1.5EE ACTION ENERGY EFFICIENCY PROGRAM IMPACT EVALUATION GUIDE, EM&V
FIGURE 2. ENERGY EFFICIENCY FACEBOOK POST . .
FIGURE 3. OCTOBER 2O2O CUSTOMER BILL INSERT
FIGURE 4. ONLINE REBATE TUTORIAL FROM INTERMOUNTAIN GAS YOUTUBE CHANNEL . ,
FIGURE 5. CONTRACTOR EE PROGRAM OUTREACH POSTCARD MAILING
FIGURE 6. OUTDOOR INFORMATION TABLE .
FIGURE 7, ADVERTISEMENT IN PARADE OF HOMES MAGAZINE
FIGURE 8. INFORMATION TABLE IN AN ENERGY STAR CERTIFIED PARADE HOME .
FIGURE 9. RESIDENTIAL HOME BUILDER EE PROGRAM OUTREACH POSTCARD MAILING . .
5
8
15
,7
'16
16
17
18
19
20
20
21
2O2O ANNUAL REPORT
k
EXECUTIVE SUlVI ]VIARY
ln a year where almost everything
changed, the one thing that did not
change was customer interest and
participation in the lntermountain
Gas Energy Efficiency Program
(Program). While everyone spent
more time at home than ever
before, customers continued to
seek ways to save energy and
save money on home energy use.
ln 2020, overall participation in
the Program continued to grow.
The Whole Home and Furnace
incentives led the way for the third
year in a row, while other incentives
were slow to gain momentum
or uptake. While lntermountain
Gas Company (lntermountain,
Company) continually monitors
program performance, based
on cost-effectiveness, rebate
redemption, customer feed back
and guidance from the Energy
Efficiency Stakeholder Com mittee
(EESC), the Program followed
industry best practice and sought
evaluation by an external party.
To assess the performance of the
Program, the Company enlisted ADM
Associates, lnc. (ADM) to conduct
an independent review, formally
called Evaluation, Measurement
and Verification (EM&V). The
EM&V study provided constructive
information regarding therm saving
verification, as well as practical
recommendations to improve
well-established program delivery
procedures. The EM&V study
served as the basis for significant
revisions to the Program offering.
our communities, safe and healthy.
The Energy Services Representatives
(ESR) continued to carry out
business development and energy
efficiency promotion and education
responsibilities while implementing
social distancing, wearing face masks,
and employing limited contact
protocols while serving customers,
builders, developers, and contractors
in the field. The in-office team was
no longer in the office, but instead
transitioned to work from home. ln
early 2020, many of the traditional
outreach and education events,
like trade shows and conferences,
were initially postponed and then
ultimately canceled. When it was
possible, the Energy Efficiency
(EE) team participated in limited
outreach events following strict
safety protocols. With stay at home
orders and limited public contact, the
EE team switched tactics to engage
with customers and contractors
via social media and email.
ln 2020, lntermountain Gas paid
out 4,537 rebates to customers,
a 36% increase over the previous
year. The Furnace rebate was the
most redeemed rebate, at2,744
rebates in 2020, which is also the
most of any Program year. While
many sectors of the economy slowed
down, home building in ldaho
soared, as did uptake of the Whole
Home rebate for energy efficient
new construction. Second to the
Furnace rebate, the Whole Home
rebate continued to be one ofthe
most redeemed rebates with 1,536
ENERGY STAR Certified, HERS rated
(Home Energy Rating System) homes
built in 2020. The Tankless Water
Heater incentive also continued
to grow with a 44% increase over
201 9. The majority of tankless
To continue to deliver safe, clean,
reliable naturalgas in the midst
of the world-wide pandemic, the
Company adopted new safety and
health protocols to do our part to
keep employees, customers, and
\
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2O2O ANNUAL REPORT 3
water heaters were installed in new construction. The
70% Fireplace, Combination Radiant Heat System, and
Water Heater rebates all decreased from 2019 levels.
The EM&V study not only identified areas where the
Program excelled and ways to improve current and
future procedures, but also evaluated the therm
savings of the two most redeemed incentives. ADM
applied t\l/o methodologies to evaluate savings in the
impact study, a simulation-based approach and a billing
analysis approach. Based on the simulation-based
analysis, the Program was found to be cost-effective
(i.e. a ratio exceeding 1.0) with a Utility Cost Test (UCT)
benefit to cost ratio of 1.5, but not cost-effective under
the billing analysis-based evaluation with a UCT of
0.5. The cost-effectiveness of individual measures also
varied from very cost-effective to not cost-effective
depending on the analysis method used. Due to the
disparity in the results of these two approaches, the
Company significantly revised the Program offering. The
revisions focused on implementing requirements that
directly impact therm savings and implementing EM&V
recommendations that will help the Company avoid
potential under reporting or overstating therm savings.
The EE Program is funded by the Energy Efficiency Charge
(EEC) rider, which is a monthly per therm charge paid
by residential customers. The EEC is used to acquire
cost-effective therm savings. Order No. 34454, which
took effect on October 1,2019, implemented an ECC
of $0.02093 per therm. The EEC is based on a 2020
program budget of $3,9M,642. The Program started 2020
under-colleaed by $442,385, and ended the year over-
collected with a balance of $1,31 8,197. The Company
had higher than expected collected revenue likely due to
customers spending more time at home in2020, which
resulted in higher consumption. Program expenses
were lower than expected due to the cancellations
of many activities due to COVID-19. However,
lntermountain had the highest annual total rebate
payout in Program history in 2020, with $2,848,550 paid
directly to customers in the form of incentive rebates.
The Company continued to promote the Program
through various outreach methods to the traditional
audiences: customers, contractors, builders and the
community at large. Most in-person promotional
activities traditionally used by the Company were
canceled due to the pandemic. The cancellations
provided the Program opponunities to re-think energy
efficiency education and outreach approaches.
The EESC continued to play an instrumental role in the
growth and success of the Energy Efficiency Program
in 2020. Meeting three separate times throughout
the Fall, the EESC reviewed the results of the EM&V
and provided thoughtfulfeedback and guidance in
the application of the results to revise the residential
offering. From the EESC, the Company assembled a
subcommittee dedicated to reviewing and updating the
4 EXECUTIVE SUMMARY
Company's avoided costs and calculations, per Order
No. 34536. The subcommittee met three times in early
2020. The Subcommittee agreed on a methodology
for calculating avoided costs related to commodity
and transportation costs and continues to work on
quantitr/ing avoided distribution costs. Many members
of the EESC also participated on the newly formed EESC-
Commercial Subcomittee (EESC-C). Commercial industry
experts were recruited to join the EESc-c to consult
and advise on the development of the Compan/s first
ever commercial energy efficiency rebate program.
All EESC meetings were held virtually, which allowed
members to participate and engage via a short trip to
their computer rather than a 4-hour drive across the
state, an unexpected benefit to working from home.
lntermountain is committed to providing energy efficient
choices today as well as a clean, energy efficient future. A
key component of that energy efficient future is bringing
naturalgas heat pump technologies to market. Natural
gas heat pump technology has the capability to provide
customers with new energy saving opportunities with
efficiencies exceeding '1000/0, as wellas lower operating
costs and costs of ownership. The Company continued
to participate in the North American Gas Heat Pump
Collaborative (Collaborative) after joining as a charter
member in 2019. The Collaborative is a working group
comprised of North American naturalgas utilities
dedicated to accelerating the adoption of natural gas
heat pump technologies. ln concert with the work of the
Collaborative, the Company continues to be a member of
the long-established Emerging Technology Program (ETP),
facilitated by the Gas Technology lnstitute (GTl). ETP is
a member driven committee working to "accelerate the
market introduction and acceptance of new emerging
technologies to feed utility energy efficiency programs."
The Program continues to evolve and grow along with the
energy efficiency industry. The Company is excited for
the 2021 update of the residential offering which retired
under-performing incentives, added new rebates, and
made important adjustments to existing rebates. A re-
designed new construction rebate will focus on capturing
natural gas therm savings while driving energy efficient
design in residential home building. Opportunities to
save money and energy will be extended to commercial
customers with the launch of the first ever commercial
energy efficiency program at lntermountain Gas.
This Energy Efficienry 2020 report provides a review of
the Company's energy efficiency program finances, cost-
effectiveness, and performance for the entire Program
and for each individual incentive. lt also outlines the
results of the EM&V study and the actions taken by the
Company based on the findings and recommendations
ofthe study. A review of Program outreach and
educational activities is included, as well as an update
on the Company's involvement in a collaborative effort
to accelerate market introduction of gas heat pump
technologies, and the future plans for the Program.
2O2O ANNUAL REPORT 5
INTRODUCTION
lntermountain Gas Company, a subsidiary of MDU
Resources Group, is a naturalgas distribution
company serving over 387,000 residential,
commercial, and industrialcustomers in 76
communities across Southern ldaho since 1955.
ln addition to keeping customefs homes warm
and comfortable, the Energy Efficienry Program
strives to provide customers opportunities to save
money and energy. lndividuals benefit from energy
efficiency by reducing enerty use and ultimately
realizing long-term savings through lower monthly
bills. All customers benefit from the efficient use
of natural gas by maximizing toda/s assets and
delaying the need for expensive system upgrades.
The Energy Efficienry Program was approved by the
ldaho Public Utilities Commission (Commission) and
went into effect on October 1,2017. All customers
receiving natural gas through the Company's
residentia! rate schedule were eligible to participate
in the program through 2020. The Program offers
rebates on naturalgas equipment meeting specific
high-efficiency requirements, and can be applied to
replacement equipment, conversion from other fuel
sources and new construction. The Program also
offers rebates for ENERGY STAR Certified residential
new construction with a HERS score of 75 or less.
The EE Program is funded by the Enerry Efficiency
Charge rider, a monthly per therm charge to residential
customers. ln2020, the Company did not seek a change
to the $0.02093 EEC approved by the ldaho Public
Utilities Commission in Order No. 34454. The Program
started 2020 under-collected by $M2,385, and ended
the year over-collected with a balance of $1,318,1 97. The
Company had higher than expected collected revenue,
likely due to customers spending more time at home in
2020, which resulted in higher consumption. Program
expenses were also down due to the cancellations
of many activities due to the pandemic. At the same
time, however, the Company had the highest annual
total rebate payout in Program history in 2020, with
$2,848,550 paid directly to customers in the form of
incentive rebates. EEC balance fluctuations from over to
under-collected, are largely due to the seasonal nature of
natural gas consumption, with higher consumption in the
winter leading to an over collection, and a subsequent
correction during the summer months of lower
consumption. Although the Program ended the year
with an over-collected balance, the Company believes
the balance will turn around as the economy returns to
normaland customers begin taking advantage of the new
program offerings. Consequently, lntermountain is not
planning to file a revision to the EEC in 2021. However,
the Company will continue to closely monitor fluctuations
in its rider balance to avoid excessive over or under
collection balances and make EEC revisions as necessary.
INTERMOUNTAIN GAS COMPANY
Resldentlal Energy Efficlency Program
2020 Rider Balance
Rcvenue 5 s,4t6,74
Program Erp€nses
Resldential Rebates
Labor
Prog.am Dellvery
Speclal Studles
Total Protram Erpenscs
2020 Rlder Deferral
Over/lUnder) Collection
Prior Year Rider Balance
Over/lUnderl collcctlon
Rlder Account Balance
O,ver/lUnder) collectlon
s 2,848,550
642,387
24,653
129,568
11,000
s 3,6s6,1s8
S 1,750,s82
('142,3851
s 1,318,197
roble I 2020 Rrder Bolonce
i^,r i I-l( ll,..11 I lt.] l
COST.EFFECTIVENESS TESTING METHODOLOGY
lntermountain's objective is for all rebates to have
benefit/cost ratios greater than one when measured
by the UCT. The UCT measures cost-effectiveness
from the utility compan/s perspective and takes
into consideration avoided supply costs, program
administration costs and incentives paid by the
utility. Rebates undergo cost tests at several stages:
preliminary design, implementation, annual review
and during EM&V. For a different perspective, the
cost-effectiveness of rebates is also evaluated based
on the customer's perspective using avoided supply
costs, program administration costs and net participant
costs, or the Total Resource Cost Test (TRC). The TRC is
not the primary cost test used for decisions regarding
the inclusion or exclusion of rebate offerings. ln
calculating the UCT and TRC, lntermountain relies on
the calculations outlined in the California Standard
Practice Manual and the NationalAction Plan for Energy
Effici enc/s (NAP EE) U nd e rsta n d i ng Cost-effectiveness
of Energy Efficiency Programs: Best Practices, Technical
Methods, and Emerging lssues for Policy-Makers.
ln this report, 2020 performance, cost-effectiveness,
lessons learned, EM&V recommendations and actions
taken to address recommendations will be covered for
each rebate. Program outreach and promotional activities
by target audience, EM&V recommendations and actions
taken to address the recommendations are also included.
2O2O ANNUAL REPORT 7
EM&V
!IVI PACT EVALUATION
The first ever Conservation Potential Assessment (CPA)
marked a program milestone in 2019, quickly followed
by another program milestone in 2020: Evaluation,
Measurement and Verification. Figure 7 from the SEE
Action Energy Efficiency Program lmpact Evaluation
Guide, December 2012 (SEE Action Guide) illustrates
the critical role of EM&V in energy efficiency program
planning and improvement. As the SEE Action Guide
notes, EM&V has "three primary objectives: document the
benefits of a program, identify ways to improve current
and future programs, and support energy demand
forecasting and resource planning by understanding
the historical and future resource contributions
of energy efficiency as compared to other energy
sources." Evaluations are often a means for applying
retroactive energy savings to a program to demonstrate
prudent investment of customer funds, but beyond the
retroactive view, evaluation plays an important role in
improving programs. Evaluation, according to the SEE
Action Guide, therefore, "both fosters more effective
programs and justifies increased levels of investment in
energy efficiency as a long-term, reliable energy source."
ln January of 2020, the Company sent out a request for
proposal (RFP) to 29 organizations and posted the RFP
on the Association of Energy Services Professional's
website. A total of 13 firms replied to the RFP with
intent to submit a proposal, and 10 firms submitted a
proposal. The Company conducted interviews with 4
finalists before ADM was selected to conduct the EM&V
The evaluation consisted of two major components:
process evaluation and impact evaluation. The process
evaluation examined program operations and results
for the program years 2017-2019. ADM stated this
portion of the evaluation was designed to "identify
potential program improvements that may prospectively
increase program efficiency or effectiveness in terms
of customer participation and satisfaction !evels."
The impact evaluation was conducted on the
two most redeemed rebates:the Whole Home
rebate and the Furnace rebate. Other incentives
in the program offering did not warrant impact
evaluation since the Company already planned to
change these offerings due to low participation.
Figure I SEE Action Energr Efficiencl, Progrom lmpoct Evolttoilon Guide, EM&V
ADM applied two evaluation approaches to each
rebate, a billing analysis and a simulation-based
analysis. Both methods comply with lnternational
Performance Measurement and Verification Protocol
maintained by the Efficienry Valuation Organization.
ln both cases, ADM recommended the Company use
the therm savings found in the simulation based
analysis, as "billing analyses include any changes in
household behavior, equipment, or occupancy, and
therefore may include factors other than the impact of
improved equipment efficienry." The billing analysis and
simulation-based analysis yielded disparate results in
the case of both the Whole Home and Furnace rebates.
The following chart illustrates the impact on cost-
effectiveness based on the therm saving analysis used.
8 EM&V IMPACT EVALUATION
INTERMOUNTAIN GAS COMPANY
Rrrldcntlal Emrty Efllclcncy Pro8nm
2020 IJCT Results
Rebate
Simulation Analysls
ThGm savinas Annu.l Thcrm S.vings UcT 8lncfits UCTCosts UCTR.tio
Eilllng Analysis
ThGms.vlnls AnnualThcmS.vinis UCTBcnefits UCT Costs UCI R.tio
Whol! Horu6;bin"ir.^txEffiil 1.3
0.7
274
76
38
58
65
Furntca
?0,6 Fi.rpl.*
-
0.5
0.5
113
80'6 Fircplae
Watcr Haatar
T.rkhs Wlter Hc.tlr
Progrem Total
INTERMOUNTAIN GAS COMPANY
Rlsuend.l Emrty E fidcrEy Prognm
2020 TRC Results
Rebat
I 5r$r25 S 3,6s5,150 1.5
224
2.2
Simulation Analysis
Th€m Savings Annual Thcrm s.viBs Tnc Bcmfits TRC Costs TRC R.tio
Bllllng Analysis
Thcrm s.vi[s Annu.l Thcrm Savings TRc Ecnrtits
$ l,ml,or3 $ !,555,rs8 o.5
TRc coirs TRc Ratlo
5,523
2,286,N
808
1-O50
106-O37
Wholc Home
Crmbl Radlant Hcat Systcm
Furmccffi,t pl*"--
8016 FiEplae
Watar Hcater
274
38
0.2
0.5
778
56
130 0.4
r,m1,023 $ 8,093,357 G2
Toble 2 2020 U(T Results
Protnm Total
For both rebates, the simulation-based analysis produced post-analysis therm savings estimates that
appeared to be overstated, exceeding even the CPA therm savings estimate for the measure. On the
other hand, the post-analysis therm savings estimate from the billing analysis appeared to understate
savings, because the billing analysis did not isolate for changes in household behavior, equipment, or
occupancy, and included factors other than the impact of improved equipment efficiency, resulting in post-
analysis therm savings far less than expected. The results of the study clearly indicated changes were
needed to both the Whole Home and Furnace rebates to ensure cost-effectiveness in the future.
On September 1 6, 2020, ADM presented the results of the EM&V to the EESC. A follow up meeting was
held October 27,2020 to discuss the proposed actions to address EM&V recommendations. Using
the EM&V results as a starting point, the Company and the EESC carefully considered changes to both
rebates. Significant program revisions focused on implementing requirements that directly impact
therm savings and implementing EM&V recommendations that will help the Company avoid potential
under reporting or overstating of therm savings These changes took effect April 'l ,2021.
s 53e8r2r I 6,093.357 o.7 I
6 S23
957 m
808
1.050
14.845 105.O37 452
2O2O ANNUAL REPORT 9
EN ERGY
EFFICIENCY REBATES
For each rebate, lntermountain has provided an analysis of the 2020 performance, cost-effectiveness, lessons
learned, EM&V recommendations and actions taken to address the recommendations.
To fully weigh the implications of each method used in the EM&V, the Company performed cost-effectiveness testing
using the post-analysis savings of both the simulation-based analysis and the billing analysis. Two UCT ratios, UCT
Simulation and UCT Billing, are provided for the portfolio and for each incentive, as well as TRC Simulation and
TRC Billing. lt is important to note that only the Whole home rebate and the Furnace Rebate were subject to the
impact evaluation. However, cost-effectiveness tests for the billing analysis and the simulation analysis scenarios
are provided for each rebate, including those that were not part of the EM&V. The program administration costs are
allocated to individual rebates according to the percent of therm savings the rebate contributes to total 2020 therm
savings. Because the Furnace and Whole Home are the two most redeemed rebates, the differences in therm savings
for these two rebates resulting from the EM&V, impacts the allocation of program administration costs. The program
administration cost allocation impacts all rebates included in the program. Therefore, cost-effectiveness for both the
billing analysis and simulation analysis is provided for each rebate. Explanation and justification for revisions of each
rebate based on the EM&V results and recommendations are also provided.
ENERGY EFFIC!ENCY PORTFOLIO
The Program, as an entire portfolio, was found to be cost-effective based on the UCT Simulation with a benefit to
cost ratio of 1.5. Using the billing analysis, the Program was not cost-effective with a UCT Billing ratio of 0.5. Similarly,
individual incentives were often cost-effective under the UCT Simulation scenario, and not cost-effective under the
UCT Billing scenario. The water heating incentives were unlike all others in that they were cost-effective under both
the UCT Simulation and UCT Billing scenarios. The TRC Simulation and TRC Billing ratios for the portfolio were 0.7
and 0.2 respectively.
FURNACE INCENTIVES
The Furnace incentive provides customers a $350 rebate for the installation of a high-efficient natural gas furnace
with a minimum rating of 95% AFUE. The Company issued 2,7M rebates during 2020, which is a 33% increase over
the previous program year. Furnace retrofits continued to make up the majority of the rebates issued, while rebates
for new construction accounted for 39% of furnace rebates. This reflects an increase in builder participation as new
construction accounted for only 17% of furnace rebates the previous year.
U nder the UCT Simulation, the Furnace incentive was cost-effective, with a ratio of 1 .7 . Under the UCT Billing Analysis,
the incentive was not cost-effective, with a ratio of 0.7. The TRC Simulation and Billing Analysis ratios were 0.5 and
0.2 respectively.
IESSOruS AND REVIS'OA'S . FURNACE
The Furnace incentive is the only rebate offering that did not change in the 2021 Program revision. lnstead, the EM&V
study recommended the Company require additional information on the Furnace rebate application. The EM&V study
found 72% of customers surveyed indicated that their pre-existing furnace was functional at the time of replacement.
Collecting additional information on the application will provide a more accurate savings picture on future furnace
rebates. The additional data being collected includes: the BTU input of the furnace being replaced, the efficiency of
the furnace being replaced, and the reason for replacement such as replace-on-burnout, early retirement or new
construction. For example, therm saving estimates used for planning and forecastint compare upgrading a furnace
from standard equipment, or an 80% AFUE furnace to a high-efficiency option of 950/o AFUE. lf customers are instead
10 ENERGY EFFICIENCY REBATES
replacing a 900/0 AFU E furnace with a 95Vo AFUE furnace, there are fewer therm savings to capture. lnformation of this
nature will help provide a more accurate savings picture and better explain differences in estimated therm savings
versus verified therm savings. The EM&V study also identified HVAC sizing as an area for contractor training as over-
sizing, a common practice in Climate Zone 5, negatively affects Program savings. The EESC suggested collecting the
size of the equipment being replaced.
The Company implemented collection of the additional information on the rebate application, as recommended
by EM&V, to provide a more accurate savings estimate and to refine future EM&V analysis. As of April 1,2021, the
following information is required on the rebate application: efficienry of the equipment that was replaced, the reason
for the replacement, and the size of the equipment that was replaced. While the previous application requested
the efficienry of the equipment being replaced, few responded. The updated application now specifies allfields are
required for an application to be considered complete. Fields were added to request the reason for replacement and
the size of the equipment that was replaced.
COMBI RADIANT HEAT SYSTEM INCENTIVES
The $1,000 Combi Radiant Heat System (Combi) incentive is a rebate for the installation of a high-efficient condensing
tankless combination system for space and water heat with a minimum efficiency rating of 90%. The Company issued
9 rebates during 2020; an 18% decrease, or two fewer rebates, compared to the prior program year.
Under the UCT Simulation, the Combi incentive was not cost-effective, with a ratio of 0.7. Under the UCT Billing
Analysis, the incentive was not cost-effective, with a ratio of 0.5. The TRC Simulation and Billing Analysis ratios were
both 0.2.
IESSO'VS AND REVIS'O'VS - RADIANT COMBO INCENTIVES
This incentive has continued to have low participation and has been one of the more misunderstood offerings, both
from an equipment standpoint and application standpoint. Customers installed two tankless appliances, negating the
requirement of one appliance serving both space and water heat, or instead installed a boiler, negating the tankless
requirement. To better assist customers and contractors in understanding rebate requirements while the Company
prepared for a Program revision, the Company implemented a pre-qualification step for the incentive. This step was
successful in helping customers and contractors navigate the requirements of the rebate prior to installation.
Effective April 1 ,2021 the incentive was updated to instead require a combination boiler. The combination boiler is a
single unit designed to provide both space and water heat. The updated rebate is an $800 incentive with a minimum
required efficiency of 95% AFUE.
FIREPLACE INCENTIVES
The Fireplace incentive provides customers a $100 rebate for the installation of a high-efficient fireplace insert, with
a minimum efficienry of 70% FE. The Company issued 1 3 rebates during 2020, a 7% decrease, or one fewer rebate,
compared to the prior program year.
The Fireplace incentive was not cost-effective under the UCT Simulation or UCT Billing with cost-effectiveness ratios
of 0.6 and 0.5. The Fireplace incentive was also not cost-effective under the TRC Simulation and Billing Analysis with
ratios of 0.5, and 0.4 respectively.
The lack of availability of the 80% AFUE fireplace and complications of retrofitting this equipment proved to
be a significant barrier to adoption. ln accordance with Order No. 34536, the 8070 AFUE fireplace was retired
March 1,2020.
2O2O ANNUAL REPORT 11
IESSO'VS LEARNED - FIREPLACE INCENTIVES
The 70% FE Fireplace rebate had very low participation over the life of the offering, with 13 and 14 units installed in
2018 and 2019, respectively. While some customers may use a fireplace insert as a substitute heat source, fireplace
inserts are designed to be a decorative feature and are not normally rated for energy efficiency. lf a unit is rated,
there is not a standard efficiency rating currently applied to al! fireplace inserts. Based on the findings of the CPA,
estimated annual therm savings were reduced from 56 therms to 10 therms. To be cost-effective, only a minimal
incentive could be offered, making this an ineffective offering. The rebate was retired effective April1,2021 .
WATER HEATER INCENTIVES
The Water Heater incentive provides customers a $50 rebate for the installation of a high-efficient storage water
heater with a minimum efficiency of 0.67 EF. Intermountain issued 6 rebates during 2O2O; a 25% decrease, or two
fewer rebates, than the prior Program year.
Under the UCT Simulation, the Water Heater incentive was cost-effective, with a ratio of 2.0. Under the UCT Billing
Analysis, the incentive was cost-effective, with a ratio of 1.0. The incentive was not cost-effective based on the TRC
Simulation and Billing Analysis with ratios of 0.4 and 0.3 respectively.
I,ESSONS AND REVIS'OruS - WATER HEATER INCENTIVES
The 2019 CPA estimate of annual therm savings for storage water heaters was higher than original estimates when
the Program was developed. Annual therm savings estimates increased from22 therms to 38 therms, while the
estimated useful life (EUL) decreased from 16 years to 13 years. The Company increased the 0.68 UEF, previously 0.67
EF, water heater rebate from $50 to $115 and anticipates that this increase will encourage more participation from
the 2019 level of 8 rebates.
The Department of Energy updated the standard for measuring efficiency in water heaters after the Company began
offering incentives. The efficiency rating was updated on April 1,2021 from Energy Factor (EF) to Uniform Energy
Factor (UEF) on all water heating incentives to be consistent with the current standard in place. The new UEF rating
subjected appliances to new testing procedures that resulted in consistent standards for measuring energy efficiency
performance, a better reflection of real-world results that impact energy efficiency ratings, and an apples-to-apples
comparison of water heaters that simplified the water heater selection process.
TANKLESS WATER HEATER INCENTIVES
The Tankless Water Heater incentive provides customers a $150 rebate for the installation of a high-efficient
condensing tankless water heater, with a minimum efficiency of 0.91 EF. The Company issued 229 rebates during
2020, a 44% increase over the prior program year.
Under the UCT Simulation, the Tankless Water Heater incentive was cost-effective, with a ratio of 2.2. Under the UCT
Billing Analysis, the incentive was cost-effective, with a ratio of 1.3. The incentive was not cost-effective with a TRC
ratio of 0.2 under both the Simulation and Billing Analysis respectively.
I,ES5OruS AND REVIS'ONS - TANKLESS WATER HEATER INCENTIVES
The Company increased the Tankless Water Heater incentive, now called Tankless Water Heater Tier l, from $150 to
$325. This was based on an increase in the estimated annual therm savings from 58 to 65 therms and an increased
EUL, from 18 years to 25 years, identified in the CPA. The efficiency rating was updated to the new standard rating of
UEF, maintaining an efficiency rating of 0.91 .
12 ENERGY EFFICIENCY REBATES
The EM&V study recommended the Company explore providing customers with another high-efficient water heating
option at a slightly lower incremental cost than that of a 0.91 UEF tankless water heater. The Company implemented
this recommendation and added a new offering, Tankless Water Heater Tier ll. This tankless water heater incentive
provides a rebate of $300 and requires a minimum efficiency of 0.87 UEF.
WHOLE HOME INCENTIVES
The Whole Home incentive provides customers, primarily residentia! home builders, a $1,200 rebate for new
construction homes that are ENERGY STAR Certified and achieve a HERS score of 75 or less. The Company issued
1,536 rebates in 2020, a 42% increase over the prior program year.
Under the UCT Simulation, the Whole Home incentive was cost-effective, with a ratio of 1.3. The incentive was not
cost-effective under the UCT Billing Analysis with a ratio of 0.3. The Whole Home incentive was not cost-effective
under the TRC Simulation or Billing Analysis with ratios of 0.8 and 0.2 respectively.
IESSONS LEARNED - WHOLE HOME INCENTIVES
The Whole Home incentive was the most revised rebate offering as of the April 1 ,2021 Program update. Restructuring
of the rebate was based on EM&V recommendations to increase efficienry requirements to keep up with code
improvements and to attempt to specifically isolate therm saving features in new construction. The Company also
considered the following in restructuring the rebate: the therm saving opportunities identified in the 2019 ldaho
Residential Energy Code Field Study, the energy code requirements that became effective January 2021, and feedback
from the EESC.
Additionally, the Company commissioned a follow-up study with ADM to identify potentia! therm savings based on
a variety of requirements. One of the more significant changes to the rebate is the retirement of the ENERGY STAR
Certification. The EM&V study recommended removing the ENERGY STAR Certification requirement as it seemed "to
be a barrier to builder participation."
The updated Whole Home incentive offers a tiered incentive based on specific energy performance targets. Both tiers
of the rebate will require the home to be HERS scored, but no specific HERS score threshold is required. The EM&V
evaluation found a lower HERS score did not correlate with more therm savings. Additionally, lower HERS scores could
be achieved by implementing non-energy saving measures. While the HERS score threshold is not related to exact
therm savings, requiring that the home be HERS scored is important. The HERS score is a way for builders to quantifiT
and certify a home's energy performance, and it is a simple, transparent way for consumers to easily compare homes
based on energy efficienry performance, much like comparing cars based on a miles-per-gallon formula.
Having a home HERS scored, one indication of energy efficient home building, is not yet a common building practice
in ldaho. According to RESNET, in 2019 only 1496 of all ldaho new home starts received a HERS score. The Company
believes the requirement to have the home HERS scored will help to educate both customers and builders on energy
efficient building.
Continuing to require a HERS certificate will also provide an efficient and reliable process for the Company to veriff
compliance with the program requirements that affect therm savings. A HERS score can only be obtained by a
certified home energy rater, who is subject to certification, quality control, and quality assurance by the governing
body RESNET. The specific requirements added to the Whole Home incentive are all components of a HERS score and
do not require either additional testing to be conducted, or additional documentation to be provided, to verify the
rebate requirements have been met.
2O2O ANNUAL REPORT 13
The updated Whole Home incentive requirements effective April 1 ,2021 are as follows:
Whole Home Tier l - $900
. HERS Rated
. Air sealing at or below 3 ACH at 50 Pa
. Ceiling insulation at or above R49
. Ducts and air handler located inside conditioned
space or duct leakage to outside of less than
4 CFM25t',t00 ft2 CFA
. Minimum furnace efficienry of 97% AFUE
Whole Home Tier ll - $700
. HERS Rated
. Air sealing at or below 4 ACH at 50 Pa
. Ducts and air handler located inside conditioned
space or duct leakage to outside of less than
4CFM25(100 ft2 CFA
. Minimum furnace efficienry of 95% AFUE
This two-tiered approach will provide two rebate options for new construction of energy efficient homes. The
Whole Home Tier I rebate has an estimated annual therm savings of 161 therms, while Tier ll has savings of 128
therms as calculated by ADM.
To allow builders to maximize both energy savings and rebate dollars the offering was updated to allow builders
to layer on rebates for Smart Thermostat and/or Water Heater incentives in addition to the Whole Home rebate.
NEW REBATES
The Company continued to receive feedback from contractors that homes with radiator systems cannot install a
single unit to supply both space and water heat, and therefore could not utilize the combination boiler rebate. Based
on this feedback, a high-efficiency boiler incentive was added during the Program revision. The new rebate provides
an $800 incentive for the installation of a 95% AFUE boiler.
Smart Thermostats have been the most frequently recommended appliance rebate by HVAC contractors, customers,
and members of the EESC. The EM&V study also recommended that a smart thermostat incentive be added. A
smart thermostat rebate was added for Wi-Fi enabled and ENERGY STAR Certified thermostats and provides a $100
incentive.
EM&V RECOMMENDATIONS & ACTIONS
The EM&V recommended that the Company standardize the tracking database categorization for rebate status and
rejection reasoning. The Company tracked rebate status and recorded rebate rejection reasoning within the tracking
database. However, the evaluators recommended using standardized notations for easier filtering and analysis of
the data.
The Company created short code designations for the rebate status and reasons for denial of a rebate. The rebate
status codes provide a quick look into the current status of a rebate. The short codes the Company developed for
rebates that were denied standardized the reasons for denial and can be referenced easily and quickly, eliminating
the need to search through detailed comments to find the reason.
The EM&V study surveyed Program participants regarding satisfaction with the Company and the Program.
Participants experienced high satisfaction with the Company overall, as well as with the appliance rebates. They
expressed high satisfaction with interactions with Program staff, amount of time to receive the rebate, and overall
quality of the contractofs work. They also stated they received their rebate in a prompt and timely manner. Overall,
Whole Home participants were satisfied with the Program. Respondents were either satisfied or very satisfied with
the energy efficienry measures in their homes, and ninety percent of respondents indicated they were either satisfied
or very satisfied with lntermountain as their gas service provider.
14 ENERGY EFFICIENCY REBATES
IMPACTS OF COVID-19
The Company strives to embrace efficiency in all aspects of the Program including rebate processing. The Company
was working toward a near paperless rebate process when in March 2020, the worldwide pandemic and transition
to work-from-home created an immediate need to adapt to a paperless process. Paper rebate applications that are
submitted are now scanned and turned into a digital file and stored in an internal company database while awaiting
processing. Rebate applications submitted to the Company as pdf files via email are also moved to the storage
database. These rebate applications are organized by postmark date and processed on a first in, first out basis.
Digital processes are now utilized for all approvals and check requests. This more efficient process will remain
in place as a standard procedure and will help to ensure we are utilizing our labor as efficiently as possible in
administering the program.
To better communicate the receipt of rebate applications, the Company added an automated response to its
department email, [e-mail]. The automated response serves as a confirmation receipt and informs
the customer of the expected time frame for rebate processing. The message was customized to fit the evolving
conditions during the COVID-19 pandemic. The Company plans to continue providing an automated response
and will remove references to COVID-19 related delays when appropriate.
The Company will continue to seek ways to optimize efficiencies and resources. Ensuring efficient program
administration is an important step in maintaining cost-effectiveness for the Program as it grows.
I
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;
,
*
2O2O ANNUAL REPORT 15
PROGRAM OUTREACH,
AWAREN ESS AN D EDUCATION
ENERGY EFFICIENCY TEAM
ESRs are an essential part of the EE team in regular
day-to-day operations, but even more so in the
midst of the 2020 worldwide pandemic. Most event
driven outreach methods traditionally employed by
the Program were canceled due to COVID-19. Only
the ESRs continued to carry out energy efficiency
promotion and education responsibilities while
implementing strict safety protocols such as social
distancing, wearing face masks, and employing
limited contact protocols while serving customers,
builders, developers, and contractors in the field.
The ESRs promoted energy efficiency with every
customer interaction and multiplied the enerty efficiency
outreach efforts. The connections established by ESRs
are a major key to the success of the Program. ESRs are
representatives of lntermountain in their respective
communities, and traditionally participate in building
contractor associations, cha m bers of commerce
events, civic groups and industry related trade shows.
Their local participation in these groups allows ESRs
to identifi/ energy efficienry outreach and educational
opportunities with residential builders, HVAC contractors,
and at community events. ESRs are an immediately
accessible EE resource in their communities and are
often face-to-face with customers which eliminates
the need for customers to make multiple calls to
different departments within the Company. ESRs are
also the "ears" on the ground as they provide first-hand
customer and contractor feedback about the Program.
The success of the partnership with the ESRs is evident
in the growth by district. While the Treasure Valley,
including both Boise and Nampa districts, grew as
a whole, the number of rebates grew by the largest
percentage specifically in the Nampa district, with a
groMh rate of 124% over 201 9. Most of this growth
was due to increased participation in the Whole Home
rebate by Canyon County residential builders. The
opposite was true in the ldaho Falls district where
appliance rebates contributed the most to the overall
'19% growth of rebates in that district. The Boise and
Pocatello districts also grew over 2019 participation by
24% and 14% respectively, and in both cases appliance
rebates contributed more to the totalgroMh than Whole
Home rebates. Rebate participation trew in all regions
with the exception of the Twin Falls/Hailey region. More
analysis is needed to fully understand why adoption lags
in this region. lnitial assumptions include lack of ENERGY
STAR Certified HVAC contractors and current energy
efficiency practices. The Whole Home rebate required
the home to meet ENERGY STAR Certification, which
required ENERGY STAR Certified HVAC professionals.
The lack of ENERGY STAR Certified HVAC contractors
in this region, appears to be one market barrier to
Whole Home participation in the Magic Valley. As of
Apri! 1 ,2021, ENERGY STAR Certification is no longer a
requirement of the Whole Home rebate, so the Company
is optimistic it will see increased uptake in that region.
The Program will continue to build on successful
outreach strategies and research and address areas
where participation may be lagging. As a first step, the
Company will explore more targeted promotions and
seek to better understand energy efficiency attitudes and
practices in the regions where Program adoption !ags.
Residential Rebates Growth By District
3m0
2500
2m0
1500
1000
s00
0 -Ir
Twin Falls &
Hailey
Boise Nampa Pocatello
.2018 .2079 .2020
il I rII
ldaho Falls
Toble 3 Residential Rebates Growth By District
16 PROGRAM OUTREACH, AWARENESS AND EDUCATION
CUSTOMERS AND COMMUNITY
Consistent with the outreach strategy employed in
previous years, in 2020 the Program focused on three
primary groups for outreach and education efforts:
customers and the community at large, contractors,
and home builders. Due to the challenges posed
by 2020 health and safety restrictions, almost all
in-person outreach opportunities were canceled.
The Program was required to pivot to alternate
methods of outreach to promote energy efficiency.
The Company strives to maintain a digital presence on
social media. This was never more important than in
2020 when the only safe way to engage with customers
was virtually.ln 2020, posts focused on raising awareness
about rebates, energy efficiency tips for the home,
benefits of an ENERGY STAR Certified Home, and also
leveraged events like ENERGY STAR Day, Earth Day and
Efficiency Day. Three posts promoted the availability of
rebates outright, as seen in Figure 2. Five posts provided
general energy efficiency tips for the home, such as air
sealing and replacing furnace filters. Other posts were
timed for the season such as a September post "lt's
Fall, Ya'll..." about preparing the home for winter. Three
WE OFFE REBATES
posts highlighted special days dedicated to efficiency
such as ENERGY STAR Day. Social media was also used
to promote ENERGY STAR Certified Homes in the virtual
parade of homes, a partnership the Company has
relied on to promote energy efficient home building.
An EE brochure is included with all new customer
letters. These letters are sent to both customers
signing up for service for the first time, and customers
who stop and start service when relocating. ln 2020,
36,642 EE brochures were sent with customer letters.
ln 2020 the Company conducted the Soups on Savings
on Sweepstakes, a sweepstakes contest designed to
encourage customers to learn more about the rebates
offered coordinated with an EE Program customer
bill insert. The Company aimed to educate customers
on the "alphabet soup" of efficiency ratings like AFUE,
UEF and HERS. The bill insert provided answers to the
questions: "How efficient is your furnace? What is the
UEF of my water heater? What is a HERS score?" See
Figure 3. From October 5,2020 through November 9,
2020 the Company provided customers an opportunity
to enter the contest via an entry page on the EE website
Customers entered the contest using either the QR
(quick response) code or via a link on the bill insert.
A link to the contest entry page was also promoted
on the Company home page and on Facebook.
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2O2O ANNUAL REPORT 17
Metrics gathered from Google Analytics showed
social media and the QR Code accounted for 94%
of the total page-views on the entry page site. The
other 5% came from traditional search engines.
Customers from every region of the service territory
entered the contest, for a total of 390 entries in
the Soups on Savings on Sweepstakes. One winner
was selected at random for the prize package.
The Company was unable to engage with the community
in the typical community events like trade shows and
conferences because of cancellations due to COVID-19.
lntermountain looks forward to resuming these
promotional activities in the future as they are a vital
toolto Program outreach and education efforts.
CONTRACTORS
During the world-wide pandemic customers sought
the safety of their homes, either by choice or by
mandate. While cities shut down, work stoppage
wasn't an option for essential services like natural gas
delivery and the related building and HVAC service
experts. Contractors and inspectors discovered ways
to meet the needs of the customer while employing
new safety protocols. Perhaps more time at home,
and consequently higher energy consumption
spurred customers to seek out ways to save money
and energy. ln a year where a downturn in Program
participation might be expected, the Program instead
paid out more rebates than ever before. Contractors
remain a vital partner in energy efficiency efforts.
Since its start, the Program viewed ease of use and
accessibility as a key point in contractor and customer
participation. ln September 2019 the Company launched
an on-line rebate submission form, as requested by
contractors. ln the first full year of offering the on-line
form, 1 5% of all appliance rebate submissions were
returned using the on-line form. ln conjunction with
the on-line form the Company created the Contractor
portal. This password-protected contractor section of
the website contained contractor resources such as
quick links to the rebate forms and industry related
news items that were updated each month. News
items contained timely topics pertinent to contractors
and energy efficiency, such as indoor air quality and
preventing COVID-19 exposure, the importance of
blower door tests, and promotion of training events.
ln an effort to promote the use of the online rebate
application and get contractors to convert from
paper rebate forms to the on-line form, the Company
developed a contractor specific sweepstakes. The
Contractor Bonus Bucks Sweepstakes, offered
five gift cards, awarded to one random winner in
each of the Company's five districts. Every on-line
application received was considered a contest entry
for the contractor identified on the application.
Figure 4 Online rebote tutoriol from lntermountorn Gos YouTube Chonnel.
Sweepstakes entries were accepted for the entire
month of October and winners were notified on
November 5th. To promote the Contractor Bonus
Bucks Sweepstakes the Program utilized an extensive
contact list of over 200 contractors and the contest
was promoted through three separate notifications.
The online form was designed with quality assurance
checks built in that prohibit form submission without
complete information. This greatly reduces the need
for call-backs, clarifications, or additional information
requests, and streamlines general rebate processing.
The goal of the contest was to incentivize contractors to
convert from the paper application to the on-line rebate
application. ln orderto assist contractors in converting,
and since no in-person training could be hosted, the
Company created a step-by-step online rebate application
training video. The eight-minute long video walked the
viewer through each step of filling out the online form,
from locating it in the contractor portalto clicking submit.
The Program unveiled this new educationaltool during
the Contractor Bonus Bucks Sweepstakes and links to
the training video were provided in the promotional
emails. ln addition to promoting the Contractor Bonus
Bucks Sweepstakes, the training video is as relevant
today as when originally published. The Company
18 PROGRAM OUTREACH, AWARENESS AND EDUCATION
posted the video on the lntermountain Gas public
YouTube page and in the contractor portal on both
the home page and the rebate application sections.
The Contractor Bonus Bucks Sweepstakes resulted in
lower than expected participation with a total of 32
entries from four districts across the Program service
territory. While the rebate application training video
remains an instructional asset for the Program, the
overall number of video views was also low. Although
the instructional video was easily accessible, 8 minutes
may be too long for busy schedules, or perhaps video
tutorial is not the preferred method to learn about
new procedures. The Company will use the results of
this promotion and discussions with contractors to
determine other creative ways to incentivize contractor
participation in future programs. lntermountain will also
consider alternative ways to promote the on-line form,
explore whether contractors indeed value the benefits
of the on-line form, and contemplate if promoting the
on-line form with customers directly is a better option.
The most frequent customer response on the rebate
application to the question, "How did you hear about
the program," is "Dealer/Contractor." The number of
contractors promoting the Program continues to grow. ln
comparison with 2019, the total number of contractors
promoting the Program increased from 151 to 170. Of
the 1 70 contractors , 410/o were contractors new to the
Program, 5970 were retained from the previous year,
and 38% participating in 2019 did not return in 2020.
Contractors continue to be vital partners in
promoting energy efficiency. One ESR reported,
'While l'm speoking with the homeowner, I olways osk
them if they spoke with their heoting controctor obout
the installotion of high efficienq gas equipment. l* a
pretty good mix of answers from "l dont know. He just
told me how much a new furnoce would cost " to '\res,
they told me I should consider getting the best equipment
possible ond they recommended a high efficienqr system."
They rely on HVAC controctors to guide them. lf the
HVAC contractor doesnT know obout the EE progroms,
chances ore the homeowner wonT either. They expect
the experts (deolers) to know whot they should do."
To continue to increase Program awareness with
contractors, the Company obtained a list of contractors
from the Division of Building Safety. Postcards
featuring Program information, helpful tips, and
contact information were mailed to 325 contractors
identified as never having been listed as an installing
contractor on a rebate application . See Figure 5.
The Company will continue to raise awareness of the
Program with contractors, explore ways to engage
contractors in the Program, and provide the resources
and tools necessary to make enerSy efficiency easy and
accessible. Prior to 2020, the Company experienced
success in leveraging partnerships with organizations
like ldaho Division of Building Safety to promote
the Program and partner on in-person training
opportunities. The Company will look to resume these
kinds of activities as circumstances allow and explore
additional partnership and educational opportunities.
Figure 5 Cantroctor EE Progrom outreoch postcord moilrng
The lntermountain
Gas Energy Efflclency
Program Can Help You:
. Sell more high efficient natural
gas equipment,
. Get your customers GASH BACX with a
$35O rebate on qualifying equipment.
. Promote high efficienry equipmenr to
lower heating bills, save energy and
maximize comfort.
@3lo:ax.,
5
at
t
To learn about
all available
reba tes
use your
sma rtphone
ca mera to
scan the QRcode below:
HOME BUILDERS
Along with ldaho's population groMh, participation in the
Program's new construction rebate, Whole Home, grew
as well. The number of builders earning the Whole Home
rebate increased, as did the total number of homes
rebated. The Company continued to reach out to builders
through existing memberships in Building Contractor
Associations (BCA), and used BCA community events
like Parade of Homes to continue to raise awareness
about home energy efficiency. Home energy raters
continue to be valued partners in energy efficienry as
experts in both construction-speak and home energy
efficiency performance. With the major overhaulof the
new construction rebate in 2021, the Company will seek
ways to harness the successful momentum of the initial
program and channelthat into the new Program offering.
2O2O ANNUAL REPORT 19
The Company continued to raise awareness about
energy efficiency and Program offerings through
participation in the five BCAs in the Compan/s service
territory. Attendance at BCA general membership
meetings and participation on specific committees
allowed the Company to network with both builders
and home building adjacent industry leaders like
home lenders, HVAC and plumbing contractors, and
realtors, as well as BCA leadership. ln one instance,
the Company was invited to participate in a first-
time event, "Breakfast with a Builder" event.
ln an effort to increase networking opportunities, one
of the BCAs introduced a new invitation-only monthly
event, which featured a small breakfast meeting for
one homebuilder and five to seven associate BCA
members. This smaller, informalsetting provided a
one-on-one opportunity for builders to network with
home building associates and facilitated more in-depth
conversations than the typical limited networking
conversations of a 1So-person luncheon. Association
networking and participation by the EE team led
to more access and inclusion in builder events.
Although opportunities were limited in2020, one of the
most effective builder and community outreach activities
continues to be active golf hole sponsorship at BCA
and community golf tournaments. lmplementing strict
safety protocols, such as face masks, social distancing
and implementing no contact protocols (no handouts,
no handshakes), the Company hosted active golf holes
at seven different golf tournaments throughout the
Program's service territory. The Company used these
sponsorships to promote Program offerings through
brief, one-on-one conversations with all tournament
participants, including builders, as each team progressed
through the golf course. The informal setting, and
efficiency-themed golf games, provided a natural
segue to marketing the Program offerings, or if they
were already participating in the Program, provided
an opportunity for feedback about the Program.
The cancellation of many events in 2020 due to COVID-19
added more importance to the golf tournament
sponsorships. These were one of the few opportunities
that the Company had to interact in person with
Program participants and potential participants. The
Company's commitment to safety, along with specific
safety protocols provided by tournament hosts, led to a
safe and productive tournament sponsorship season.
Annual Parade of Homes (Parade) hosted by each
BCA across the Compan/s service territory have
traditionally been an integral promotional opportunity
for the Program to interact with builders, contractors,
and the community at large. Although 2020 was not
a traditiona! year, these events were still able to go
on in a new, virtualcapacity. The safety protocols
that were put in place due to COVID-19 required the
Company to completely revamp the outreach approach,
as in-person information tables and distribution of
brochures were no longer an option. The virtual parade
of homes eliminated the opportunity for visitors to
tour model homes in person. Each BCA created a
virtual parade of homes by enlisting professional
photographers to create virtual tours of each home,
allowing the viewer to tour the home by clicking through
photos that showcased every aspect ofthe home.
The Company tailored outreach efforts to accommodate
viftual parade of homes by designing a parade of
homes ad with a QR code that directed viewers to
"see" an ENERGY STAR Certified home, with a list of
builders and their respective ENERGY STAR Certified
homes featured in the parade. The Company reached
out to all Parade builders with this opportunity to
earn additional promotion for their Parade home and
raise awareness about the Whole Home rebate. The
advertisement in the BCA virtua! Parade magazine
promoted ENERGY STAR Certified homes in the Parade
and energy efficient builders. Over the course of the
2020 program year, thirteen different builders who
were participating in four different Parade of Homes
across the Compan/s service territory participated in
the Compan/s promotional offering. Overall, visits to
the webpage via the QR code provided in the ad was
low. While it was the perfect opportunity to attempt
to pivot to a digital marketing option, the Company
had severaltake-aways: Customers are still learningF6ure 6. Outdaor informotion toble
20 PROGRAM OUTREACH, AWARENESS AND EDUCATION
to use the QR code, customers are required to take an
additional step (visit the website) vs. visiting or seeing
an information table as they enter a Parade home,
and overall traffic to the virtual parade was low.
Once safety protocols were developed and incorporated
into public events, which included limiting the number of
visitors at one time, supplying face masks and sanitizer
at each home, one BCA hosted a traditional in-person
Parade event. Historically, this Parade consistently
experienced high attendance and 2020 continued this
trend with an estimated 9,000 visitors. This BCA offered
members the opportunity to purchase space in the
garage of the Parade homes to set up informational
booths. The Company seized the opportunity to partner
with three Parade builders and supplied two builders
with Program marketing materials. ln the third home,
the ENERGY STAR Certified home, the Company used the
garage space to host an informational table as visitors
exited the home. This was an excellent opportunity for
the Company to provide attendees with information
about an ENERGY STAR home while physically standing
in an ENERGY STAR Certified home. Sponsoring garage
space in Parade homes provided an opportunity to
promote the EE Program both passively, and actively.
ln addition to reaching out to builders in the BCAs,
the Company also promoted the Program to all
residential building contractors in the service territory.
A postcard was mailed to '1,245 residential building
contractors. The postcard promoted the Whole Home
rebate as well as the benefits of higher sales prices
and faster home sales for enerty efficient homes.
ln 2020, the Company paid out 1,535 Whole Home
rebates, an increase from 1,079 in 2019. Thirty-six
home builders accounted for those rebates requiring
ENERGY STAR Certification and a HERS score of
75 or lower (lower is more efficient), compared to
twenty-four builders in 2019. Sixteen new builders
participated in 2020, while three builders from 2019
did not continue to participate in 2020. Most of the
ENERGY STAR Certified homes were in Boise, followed
by Nampa and ldaho Falls. There were no Whole Home
rebates in Pocatello or the Twin Falls/Hailey region.
lncorporating enerty efficient measures during the
build process is the easiest point in the home building
process to install energy savings measures like air
sealing, duct sealing and insulation. For builders who
may not be ready to build to ENERGY STAR Certified
standards, the Company also incentivizes builders to
Warmth & comfort
the ahole familywill love.
Dancirg ftrFy com€s standard on all homes
feahrrint erierry efficient natural 96.
sft dd Ei&lG and&l w lh.t b hdlnt the w.yb r
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tigure 7 Adverttsentent in Porode of Homes mogoztne
Figure 8 lnt'orntotion tctble ir) on Fl,,lFRG) SIAR certrfied Pctrode Honte
2O2O ANNUAL REPORT 21
install energy efficient furnaces and water heaters as
a stepping-stone to higher efficient homes. Builder
participation in appliance rebates grew from 29
builders in 2019 to 32 builders in 2020, which included
13 new appliance builders and 10 builders that did
not return to the Program in 2020. Furnace rebates
for new construction accounted f or 390h of all furnace
rebates, an increase from 17% in the previous year.
lntermountain received the 2021 ENERGY STAR
Certified Home Market Leader Award, for "outstanding
commitment to energy-efficient new homes," from
the Environmental Protection Agency (EPA). This is the
third year in a row in as many program years that EPA
recognized the Program for important contributions
to energy-efficient construction and envi ronmenta I
protection. According to the annual statistical report,
'Trends in HERS Rated Homes" provided by RESNET,
there were 2,121 HERS rated homes in ldaho in 2019. ln
2020, the number of HERS rated homes grew to 2,414.
For those same years, lntermountain rebated 1,079 of
the 2,121 HERS rated homes, accounting for 51% of all
ldaho HERS rated homes. ln 2020, that percentage grew
to6496, as 1,536 of all2,414ldaho HERS rated homes
were lntermountain rebated homes. ln2020, the ldaho
Business Review reported on two ldaho companies
recognized bythe EPA as ENERGY STAR Partner of
the Year - Sustained Excellence awards: Building
Energy, a certified home energy rating company, and
residential builder Brighton Homes. Both organizations
participate in the Company/s energy efficiency program
When asked to comment, Brighton responded,
"Brighton has also partnered with lntermountain Gas
Company in a public education outreach program
on why consumers should choose ENERGY STAR
Certified homes, equipment and appliances." Brighton
Homes was the first builder to partner with the
Company in a Parade of Homes promotion to raise
awareness about ENERGY STAR Certified homes. The
Company intends to expand on proven successful
outreach strategies, like builder partnerships, to
continue the momentum of builder participation
established in the first three years of the Program.
Figure 9 Regdentiol home builder FE Progom autreoctt postrord matling
lntermountain Gas
Energy Efficiency
Program
Don't leavc monclr on thc table!
. Enerty rated homes are sold for. on average,
2.796 more than unrated homes.
. While havinS a home enerty score can in(rease
the home sale prte, a b€tler score also means
more money! More enerry efricient homes sell
for 3-5% more than less efficient homes.
. You could ealn a 11,200/per home rebate when
you qualify for the lntermountain Gas Energy
Efficiency WHOLE HOMt rebare
A Energyl) emci-ncy
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22 PROGRAM OUTREACH, AWARENESS AND EDUCATION
EM&V PROCESS EVALUATION
The EM&V impact study focused on the evaluation of
two measures, while the process evaluation assessed
Progra m o perati ons, overa I I P rogra m effective ness,
and identified areas for Program improvements. ADM
reviewed Program materials and tracking methods,
collected data from Company staff and contractors,
and surveyed both participants and non-participants.
Evaluators found the Program performed well
during the first two years, and the Program used a
broad range of efforts for Program marketing and
community outreach. For the Whole Home rebate,
evaluators stated builder participation increased due
to Program recruitment efforts. Builders cited market
differentiation and the financial incentive as the main
drivers of Program participation. Contractors familiar
with other energy efficiency programs indicated they
were largely satisfied with the design and participation
process of the Compan/s program. Evaluators also
affirmed contractors have a crucial role in promoting
high-efficienry equipment and general Program
awareness with customers. Since the Program is still
in a phase of raising awareness, it was not surprising
several study conclusions indicated non-participant
builders were generally aware of energy efficienry
measures, but not the Whole Home rebate, and similarly,
pafticipants broadly understood Program requirements,
but would benefit from further explanations.
Evaluators recommendations !argely focused on
increasi ng communications, providing marketing
materials, and providing educational materials. For
builders and the Whole Home rebate, evaluators
recommended the Company continue to recruit
builders through community events and generate
awareness about the Whole Home rebate. The
Company should develop educational materials that
increase knowledge of the benefits of owning an energy
efficient home, as well as engage builders with specific
cost-savings estimates to use with homebuyers, and
provide builders with additional marketing materials
to promote the Whole Home measure. Regarding
contractors, the study found opportunities to increase
communications with contractors to raise awareness
about tools like the on-line form, provide more training
opportunities, offer a way for contractors to track the
status of rebates, and for the Company to consider
establishing a contractor network. For customers, ADM
recommended the Company explore incorporating
new measures in the Program offering, develop new
educational materials like on-line instructiona! videos
or educational materials, and continue community
outreach to increase customer knowledge and
general understanding of enerty efficiency.
The Company has been actively working to address
the recommendations resulting from the EM&V
study. The revised Program offering effective April
1, 2021, addressed several recommendations.
The revised Program offering also provides the Company
the perfect opportunity to refresh and update the
recommended marketing and educational materials for
builders and contractors. New educational materials
about the HERS score will also serve to raise awareness
about home energy efficienry, the Whole Home
rebate, and the cost savings of energy efficient homes,
which is applicable to both builders and homeowners.
These materials will be incorporated into the builder
promotional package for Parade of Homes builder
partnerships. The Company is exploring interactive,
on-line educational tools for the energy efficiency
website, such as an energy savings estimator to compare
standard equipment to high-efficienry equipment. The
calculator should help to increase customer knowledge
and general understanding of energy efficiency.
The Company is dedicated to continuous
Program improvement and embraced most of the
recommendations from the evaluation. lmplementation
of some recommendations will require more significant
consideration by the Company, especially in regard
to the potential impact to Program cost-effectiveness.
Although offering contractors and customers a way to
track the status of rebates would provide an exceptional
level of customer service, such a feature would
require a significant investment in Program software.
Likewise, the idea of a contractor network, or trade
ally, is not new to the Company, and has been given
considerable deliberation. The Company will continue
to explore implementing a contractor network with
regard to resource requirements for administering
such a program and optimizing the timing of launching
such a program. Currently, the open invitation to
contractors to participate in the Program has helped
the Program to gain momentum in raising awareness
and participation. The benefits of a contractor network
will continue to be weighted against the potential
impacts on the Program, both positive and negative.
2O2O ANNUAL REPORT 23
EN ERGY EFFICIENCY
STAKEHOLDERS
The role of the Energy Efficiency Stakeholder Committee is an important one, providing information, guidance, and
expertise on the process and development of the Program. As the Program grows, so does the role and the focus of
the EESC. Since the Program was initially available only to residential customers, the original EESC focused solely on
the residential Program .ln 2020, the EESC was instrumental in reviewing and interpreting recommendations from
the EM&V study and implementing revisions to the residential program offering. From the EESC a subcommittee was
formed, specifically to review the Program's avoided costs and avoided cost calculations. Then, stakeholders with
natural gas commercial expertise were added to the committee to form the EESC-Commercial subcommittee. This
subcommittee advised on the development of the Company's first ever commercial energy efficiency program.
AVOIDED COST SUBCOMM ITTEE
lntermountain invited interested members of its EESC to join an Avoided Cost Subcommittee (AC) that would address
the avoided cost issues raised in Order No. 34536. The Subcommittee met three times between February and June
2020. The AC agreed upon a method for calculating avoided commodity and transportation costs but could not agree
on a method to account for avoided distribution costs. The Compan/s Avoided Cost Calculation includes avoided
commodity and transportation costs and leaves a placeholder for potential inclusion of distribution costs in the
future. The AC agreed to continue to discuss options for addressing avoided distribution costs.
The Company will update the Gas Transportation Costs included in the avoided cost calculation annually with its PGA
Adjustment filing. The Commodity Costs will be updated as part of the IRP planning rycle, and an updated avoided
cost calculation will be filed as an exhibit in the lRP.
ENERGY EFFICIENCY STAKEHOLDER COM MITTEE
lntermountain hosted three EESC meetints to share the EM&V study and discuss resulting program changes. The first
meeting on August 5,2020 was held to review the material that would be included in the 201 9 Annual Report that was
filed as part of the Original Application in Case No. INT-G-20-06.
At the second meeting on September 16,2020, ADM presented the findings of the EM&V study and lntermountain
presented proposed Residential EE Program revisions. The EESC had concerns with several of the changes
lntermountain proposed to the Whole Home rebate. As a result of the discussions, lntermountain commissioned a
follow-up study from ADM to explore the best options to improve therm savings while encouraging additional builder
Participation. The Company also reviewed information from the 2019 ldaho Residential Energy Code Field Study and
the ldaho Code Collaborative.
On October 27,2020 the EESC met again to review proposed EE Program revisions. The EESC was supportive of the
proposal. A question was raised regarding the appropriate duct leakage requirement to include in the revised Whole
Home rebate. The Company agreed to further review that requirement before proposing a final rebate.
EESC. COMMERCIAL
The Company recruited commercial industry experts to join the EESC to form a Commercial subcommittee. The
EESC-C provided guidance and expertise regarding the development of the first ever energy efficiency rebate
offering for commercial customers. A building control representative who specialized in products to reduce energy
use and operational costs, and a representative from a commercial kitchen design and equipment provider, joined
the EESC-C. Both had prior experience participating in energy efficiency rebate programs. The inaugural meeting
of the EESC-C was in July 2020. The Company presented the proposed program offering based on the CPA study by
24
Dunsky Energy Consulting. The Company reiterated that
like the residential program, the primary goal of the
commercial program is to secure cost-effective savings.
The Compan/s strategy to launch a commercial program
mimicked the strategy of the residential program: design
a modest initial offering with room to grow. The EESC-C
discussed the proposed offering including how rebates
were selected based on cost-effectiveness, therm savings,
administrative feasibility, and assu mptions and estimates
used in forecasting.
The Company proposed the use of an Energy Saving
Kit (ESK) with a combination of smaller energy saving
applications like faucet aerators and pre-rinse spray
valves. The EESC-C provided helpful insights on the
benefits of combining smaller measures into an ESK.
The committee suggested partnering with contractors
on the distribution of the ESKs. The EESC-C believed the
ESKs would help the Company build relationships with
contractors and initiate conversations with commercial
customers. Additionally, distributing the ESKs through
contractors would ensure equipment is installed and
installed properly.
Other ideas from the committee included restricting
the boiler reset control measure to space heating
only, as this type of measure is ineffective in water
heating. Commercial kitchen griddles were not on
the original list of proposed measures, however, an
EESC-C member recommended the Company explore
this option as there are high-efficiency, ENERGY STAR
Certified griddles available in the market. Upon further
research, the Company found the appliance to be cost-
effective and added it to the commercial kitchen offering.
Several committee members expressed an interest
in the possibility of a custom project and the role of
commissioning equipment to capture long-term savings.
The Company is interested in pursuing a custom offering
but will first focus on establishing the initial commercial
rebate offering. The Company will continue to recruit
members with industry expertise to guide and consult on
the Program.
."jf,
ENERGY EFFICIENT
FUTU RE
lntermountain is committed to
helping customers save energy and
money today, while also working to
secure an energy efficient future.
The rebate program is a traditional resource
acquisition program focused on capturing savings
quickly. The long game to energy savings is based
on an understanding of how the market works, the
market actors, the baseline market, and how to create
lasting change by strategically intervening in the
market. As paft of lntermountain's efforts to secure
an energy efficient future, the Company participated
with two organizations that focus on accelerating the
adoption of natural gas heat pump technolory.
lntermountain has long been a member of the Gas
Technology lnstitute (GTl). GTI is the leading research,
development and traini ng orga nization addressing
enerry and environmental challenges to enable a secure,
abundant and affordable energy future. Intermountain
participates in GTI's Operations Technology Development
(OTD) and Utilization Technology Development (UTD)
collaborative member groups which are focused
on different aspects of the value chain. OTD is a
member-controlled partnership to develop, test, and
implement new technologies related to the safe and
reliable operation of the natural gas infrastructure.
UTD, also a member-controlled partnership, conducts
near-term applied research to develop, test, and
deploy energy-efficient end-use tech n ologies.
I nterm o u nta i n's Energy Efficiency Progra m pa rtici pates
specifically in UTD's Emerging Technology Program (ETP),
which is a member-driven collaborative to acceterate
the introduction and acceptance of new emerging
technologies for energy efficiency protrams. ETP picks
up at the final stages of UTD's research process and
focuses on "identiffing and addressing data or market
barriers, including the development of new measures,
impacts of disruptive technologies, awareness and
education." ETP also provides technology snapshots,
project summary reports, case studies, white papers,
and other resources for training and outreach.
lntermountain participated in both the Spring and
Winter membership meetings in 2020. The meetings
are an opportunity to discuss high potential focus
technologies, active projects and connect with GTI's
subject matter experts. Residential HVAC, water heating,
and commercialfood service are examples of a few of
the steering committees under the ETP umbrella of work.
lntermountain partnered with GTI and 15 utility
sponsors in the gas heat pump roadmap and a follow
up ResidentialThermal Heat Pump Combi-System
Field Demonstration (Demonstration). The goals
of the Demonstration are to monitor performance
for longevity, operatio ns, ma i ntena nce, del ivered
comfort, and to evaluate installation efforts to support
commercialization of gas heat pump technology.
As gas heat pump technologr nears commercialization,
the Company is also committed to identifiTing market
barriers and impediments to market acceptance
of gas heat pump technology. The North American
Natural Gas Heat Pump Collaborative (Collaborative) is
poised to address these issues. lntermountain joined
the Collaborative in 2019 as a charter member and
continued its membership in 2020. The Compan/s
investment in the Collaborative will secure an enerry
efficient future for customers by accelerating the
production, availability, and adoption of high efficient
natural gas heat pump equipment. The Company
contributed the membership fee and participated
on the operations committee, the gas heat pump
water heater committee, and the residentialgas heat
pump combination committee, allowing the Company
to offer input and feedback regarding the direction
and objectives of the committees. The Collaborative
continues to make excellent progress as a newly formed
North American effort advancing the adoption of gas
heat pump technology. The gas heat pump water heater
committee completed market conditioning phase 1,
including a market characterization study and identified
strategies beyond the typica! go-to-market strategies to
achieve greenhouse gas reduction and therm savings.
The residential heat pump combination committee
prepared to conduct market conditioning tasks such
as market characterization research and a supply
chain development plan. A recruitment committee and
communications committee were both established in
the last year. As a charter member of the Collaborative,
the Company received access to all meeting discussions,
information, and study results of the various
projects in which the Collaborative is engaged,
The Company will continue to explore opportunities
to promote gas heat pump technologies. One
such opportunity would be participating in a field
demonstration of gas heat pump equipment. A
demonstration would allow the Program to raise
awareness about the near-term availability of heat
pump technologies with home builders, suppliers,
distributers, and contractors. Not only will there be a
need to raise awareness about this new technology,
but contractor education regarding installation is also
a potential hurdle. A field demonstration provides
a hands-on opportunity to address both, while
substantiating the enerry saving capabilities of gas
heat pump applications in cold climates. A project of
this magnitude will require significant consideration
and planning but is an actionable step towards
delivering new energy savings, lower energy bills, and
preserving fuel choice for customers into the future.
LOOKING AFI EAt)
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ln order No.34980, issued in Case No. INT-G-20-06,
the ldaho Public Utilities Commission deemed the
2019 Program expenses as prudently incurred.
Additionally, the Commission acknowledged the
Company has made substantial progress on updating
its avoided cost methodology and advised the
Company to continue to review and update avoided
cost calculations. Modifications to the residential
offering were approved by the Commission and went
into effect April 1 ,2021. Lastly, it was ordered the
Company continuously monitor, evaluate, and update
Program incentives with the best available data.
The Company looks forward to leveraging the
revised residential rebate offering to build on the
momentum started by the initial program offering
launched three short years ago. lncorporating
additional incentives into the offering, creating tiered
incentives to increase participation, and increasing
incentive amounts where cost-effective, will provide
customers more opportunities to save money and
save energy. In addition to providing money and
energy saving opportunities to residential customers,
lntermountain looks forward to engaging commercial
customers in the new commercial rebate program.
Committed to continuous improvement to help
customers save money and energy, the Company
will continue to collaborate with the Energy Efficiency
Stakeholder Committee and the various sub-
committees, such as the avoided cost subcommittee
and commercial subcommittee, on Program progress
and developments. The Company embraces the
enthusiasm customers have demonstrated for
energy efficient solutions and will continue to put
the best solutions forward to meet those needs.
{
INTERMOUNTAIN
A Subsdn4, al MDI I Rpsou res GtoLI-) lfic
ln the Community to Serve
lntermountain Gas Company
555 S Cole Road
Boise, lD 83709
Tel: [phone]
Fax: [phone]
trEl@trtr
CAs COMPANYA