HomeMy WebLinkAbout20231006Application.pdf
October 6, 2023 Ms. Jan Noriyuki Commission Secretary
Idaho Public Utilities Commission P.O. Box 83720 Boise, ID 83720-0074
RE: Case No. INT-G-23-06 Dear Ms. Noriyuki: Attached for consideration by this Commission is an electronic submission of Intermountain Gas
Company’s Application for a Determination of 2022 Energy Efficiency Expenses as Prudently Incurred, including the 2022 Energy Efficiency Annual Report. If you should have any questions regarding the attached, please don’t hesitate to contact me at (208) 377-6015.
Sincerely,
Lori A. Blattner Director, Regulatory Affairs
Intermountain Gas Company
Enclosure cc: Mark Chiles
Preston Carter
RECEIVED
Friday, October 6, 2023 1:05:23 PM
IDAHO PUBLIC
UTILITIES COMMISSION
INTERMOUNTAIN GAS COMPANY
CASE NO. INT-G-23-06
APPLICATION
AND
EXHIBITS
In the Matter of the Application of INTERMOUNTAIN GAS COMPANY
For a Determination of 2022 Energy Efficiency Expenses as Prudently Incurred
APPLICATION - 2
Preston N. Carter, ISB No. 8462 Morgan D. Goodin, ISB No. 11184
Givens Pursley LLP
601 W. Bannock St. Boise, Idaho 83702 Telephone: (208) 388-1200
Attorneys for Intermountain Gas Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
for a Determination of 2022 Energy
Incurred
Case No. INT-G-23-06 APPLICATION
Intermountain Gas Company (“Intermountain” or “Company”), a subsidiary of MDU
Resources Group, Inc. with general offices located at 555 South Cole Road, Boise, Idaho, pursuant
to the Rules of Procedure of the Idaho Public Utilities Commission (“Commission”), 1) submits its
2022 Energy Efficiency Annual Report and 2) makes application to the Commission for an order
designating $3,364,641 of 2022 Energy Efficiency expenditures as prudently incurred.
Please address communications regarding this Application to:
Preston N. Carter Givens Pursley LLP 601 W. Bannock St. Boise, Idaho 83702
prestoncarter@givenspursley.com
morgangoodin@givenspursley.com stephaniew@givenspursley.com
and Lori A. Blattner Director – Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608 Boise, ID 83707 lori.blattner@intgas.com
APPLICATION - 3
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 Idaho 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 - Heyburn, 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, compressor stations, distribution mains, services, meters and
regulators, and general plant and equipment.
APPLICATION - 4
II. BACKGROUND
In the Company’s General Rate Case No. INT-G-16-02, Intermountain petitioned the
Commission for authority to begin a residential Energy Efficiency Program. The Commission
granted the Company’s request in Order No. 33757.
Subsequently, in Case No. INT-G-17-03, the Company requested authority to implement
Rate Schedule EE – Residential Energy Efficiency Rebate Program, which outlined the program
offerings, and Rate Schedule EEC-RS – 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 incurred. In Order No. 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 Energy
Efficiency 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
Schedule EEC-RS (“EEC-RS”) 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, effective October 1, 2019.
In Case No. INT-G-20-06, Intermountain requested that the Commission approve the
Company’s 2019 EE Program expenses as prudently incurred. In Order No. 34980, the Commission
APPLICATION - 5
approved the prudency of the expenses. The Company also requested significant changes to the
program based on its first 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.
In Case No. INT-G-21-03, Intermountain requested that the Commission approve the
Company’s 2020 EE Program expenses as prudently incurred. In Order No. 35313, the Commission
approved the prudency of the expenses. The Commission stated, “We commend the Company for
continuing to adjust its young Energy Efficiency Program to deliver cost effective energy savings to
customers.” The Commission also ordered the Company to continuously monitor, evaluate and
update its Energy Efficiency Program incentives with the best available data using the most accurate
evaluation method to do so. The Commission acknowledged the overfunded rider balance of
$1,318,197 and permitted the Company to carry forward the balance to meet anticipated increased
Program participation, with the understanding the Company will seek adjustment if increased
participation does not materialize.
During program year 2021, the Company retired, modified, or added residential program
incentives as approved in Order No. 34980.
Order No. 34941 in Case No. INT-G-20-04 authorized the Company to implement a
Commercial Energy Efficiency program in Rate Schedule EE-GS and established a funding
mechanism for program costs in Rate Schedule EEC-GS (“EEC-GS”). The Commission directed
the Company to develop an EM&V plan, file an Annual Commercial Energy Efficiency Program
Report, include representatives from the GS-1 rate class in its EESC, and immediately and
APPLICATION - 6
continuously monitor, evaluate, and update its Commercial Energy Efficiency Program incentives
with the best available data. The Company launched its Commercial Energy Efficiency Program on
April 1, 2021, consisting of incentives for commercial space heating and commercial kitchen
equipment.
In case INT-G-22-03, Order No. 35663, the Commission approved the prudency of the 2021
Energy Efficiency Program expenses. The Commission commended the Company for continuing to
adjust its Energy Efficiency Program to deliver cost effective energy savings and the collaborative
effort of the Company, EESC and Staff to maintain a DSM program that has value.
The Commission identified improvements to be made for future DSM prudency filings,
specifically directing the Company to directly assign Energy Efficiency Program costs to either the
appropriate residential or commercial program, when possible, and to provide explanations when
costs are not assignable.
The Commission directed the Company to use a billing analysis to evaluate program
performance for the Furnace and Whole Home measures, and also allowed for the Company to
present argument and evidence to justify other empirical analysis as part of its annual DSM
prudency filing. The Commission directed the Company to submit an RFP for a third-party contract
to conduct an impact evaluation with billing analysis for Whole Home and Furnace measures with
its 2023 prudency filing.
The Commission also approved the Company’s proposal of the following treatment of
avoided costs: to update the transportation component of avoided costs as an exhibit to IRP filing, to
no longer file avoided cost calculations as exhibits to the annual DSM prudency filing, to update all
avoided costs as exhibits to IRP filing, and to base cost-effectiveness testing off the avoided costs in
place at the time of program planning.
APPLICATION - 7
The Company’s 2022 Energy Efficiency Annual Report (“Annual Report”) is included as
Attachment 1 to this Application and incorporated by reference. The Annual Report provides a
review of the Company’s Energy Efficiency Portfolio, which consists of the Residential Program
and the Commercial Program. The report outlines revenues, expenditures, cost-effectiveness, and
performance by measure for each Program. A review of outreach and educational activities,
discussion of the Company’s participation in a collaborative effort to accelerate market introduction
of gas heat pump technologies, and future plans complete the Annual Report. Annual Report at 24.
III. REVENUES
The EE Program expenditures are funded through collections from customers via Energy
Efficiency Charges. The EEC-RS of $0.01564 per therm funds the Residential Program. Total
Residential Program revenues for calendar year 2022 were $5,738,001. Annual Report at 6.
The EEC-GS of $0.00320 funds the Commercial Program. The revenue for 2022 was
$472,346. Annual Report at 17.
IV. EXPENDITURES
Expenditures for the Residential and Commercial Programs combined for January 1, 2022
through December 31, 2022 were $3,364,641. Of this amount, $2,608,536, or approximately 78%,
is related to energy efficiency rebates paid directly to residential and commercial customers.
Residential rebates accounted for $2,555,389 and Commercial rebates accounted for $53,147 of the
total. Annual Report at 6 and 17.
In addition to the amount spent on energy efficiency rebates, the Company incurred
$756,105 of administrative expenses for labor, program delivery and market transformation. As a
Portfolio, this was approximately 4% more than 2021 expenditures. The Company increased
expenditures in program delivery and market transformation, but did not incur any expenses for
APPLICATION - 8
special studies such as CPA or EM&V. Labor expenses increased by 2% over 2021 for a total
expenditure of $650,675.
To comply with Order No. 35663 to “assign EE costs when possible or provide explanations
as to why costs are not assignable,” the Company directly assigned as many Program expenses as
possible as well as re-examined the allocation that was being used for expenses that could not be
directly assigned.
When possible, expenses are applied directly to the related program. Residential customer
promotions like engagement activities or email campaigns are direct expensed to the residential
program. The Company also developed guidelines to directly apply expenses as they occur,
primarily driven by the audience of the activity. Any expenses related to participation or promotion
in the Building Contractor Association, focused on residential home building, is expensed to the
Residential Program. Commercial customer email campaigns, as well as promotional and
educational activities whose primary audience is engineers and architects, is expensed to the
Commercial Program. Community-wide events are expensed to the residential program because that
is the primary audience.
Labor is the largest Program expense. The Energy Efficiency Portfolio, which includes both
the Residential and Commercial Programs, is delivered and administered by all Energy Efficiency
staff; no team member works exclusively on either the Commercial or Residential program. This is
true for both dedicated energy efficiency department employees and the Energy Services
Representatives (“ESR”). ESRs engage in business development for both the residential and
commercial sector and also promote the relevant energy efficiency program to those customers.
This has allowed the Company to leverage the expertise and flexibility of the team to promote and
APPLICATION - 9
educate about either program as the opportunities arise across the service territory, creating a one-
stop-shop for customers.
Based on Staff recommendations, the Company prioritized re-evaluating the expense
allocation used to assign expenses that did not clearly belong to one Program or the other. The
Company conducted an analysis of service starts recorded in the Company’s Construction Tracking
system. In 2021 there were 11,983 residential service starts and 568 commercial sales starts or a
95% and 5% split between residential and commercial activity. Therm savings also closely reflected
the residential/commercial split witnessed in the analysis of service starts. Total estimated therm
savings for the Energy Efficiency Portfolio were 652,650 therms: 615,806 attributed to the
Residential Program and 36,844 to the Commercial Program, or a 94/6 split between the two
programs. While the split between residential and commercial in both service starts and estimated
therm savings were very close to the same, the 95/5 allocation was used since service starts reflect
actual activity, or labor, which is the largest program expense. Labor costs were assigned based on
this analysis (95% to the residential program and 5% to the Commercial program) through an
automatic standard labor distribution through the Company’s payroll system. Utilizing employees
that work on both the residential and commercial programs is the most cost-effective approach until
the Portfolio grows to a size that can accommodate separate staff for each Program.
Any expense that could not be directly assigned was also allocated 95% to the residential
program and 5% to the Commercial Program. The expenses that could not be directly assigned were
$54,507 of the total.
Intermountain is committed to working to secure an energy efficient future. In 2022
Intermountain renewed its membership in the North American Natural Gas Heat Pump
Collaborative (“Collaborative”) to help advance the adoption of gas heat pump technology. With
APPLICATION - 10
efficiencies of over 100%, gas heat pump technology promises to deliver significant efficiency
gains when compared to traditional heat and water heat technology. The Market Transformation
expense of $25,000 represents the Company’s membership in the Collaborative. Intermountain
believes the continued investment in this collaborative effort will provide our customers with
significant energy savings and lower energy bills in the years to come. Annual Report at 24.
V. DEFERRAL BALANCE
The Residential Program began the year with an over-collected deferral balance of
$2,834,164. By June 2022, the Company had an over-collected balance of $4,893,882. To reduce
the over-collection, the Commission approved the Company’s request in Case No. INT-G-22-05,
Order No. 35539, to transfer $4,850,000 to the Company’s PGA for refund to residential customers.
To more accurately match on-going revenues with expenses, the Company’s filing also decreased
the residential EEC rate. On October 1, 2022 the EEC-RS was reduced from $0.02093 per therm to
$0.01564 per therm. The rider balance was $450,521 at the end of 2022. Annual Report at 6.
The Commercial Program went into effect on April 1, 2021. The Commercial rider balance
started the year with an over-collected balance of $84,589, and remains an over-collected balance of
$463,938 at December 31, 2022. As the Commercial Program continues to gain awareness and
participation with GS-1 customers, the Company will continue to monitor the rider balance to avoid
over or under collection and file for adjustments as necessary. Annual Report at 17.
VI. THERM SAVINGS
The 2022 program year was the first full year of performance after residential Program
modifications were implemented on April 1, 2021. The Residential Program achieved 615,806
therm savings in 2022. Annual Report at 7. In 2022 Intermountain paid out 7,945 rebates to
customers, which represented a 43% increase over the previous year. The furnace rebate and new
APPLICATION - 11
construction rebate were again the two most redeemed rebates, followed by smart thermostats which
where were added to the Residential Program in April 2021.
The new Commercial Program consists of three incentives for space heating and three
commercial cooking equipment incentives. In 2022, the Commercial Program achieved 36,844
estimated therm savings. Annual Report at 17. There were seven high-efficient condensing boiler
rebates redeemed as well as nineteen fryers. The commercial energy savings kit pilot was a success
with 342 kits distributed.
The Company is encouraged by the continued growth of the Energy Efficiency Program,
and looks forward to working with customers, the Commission, and other stakeholders to maximize
participation in and the cost-effectiveness of the Energy Efficiency Program going forward.
VII. AVOIDED COSTS
For this filing, the Company used the Avoided Costs as calculated in the IRP (see
Case No. INT-G-21-06, Exhibit No. 5). In accordance with Order No. 35663, the Company will
update the transportation component of avoided costs as an exhibit to IRP filings. In addition, as
outlined in the Order, the Company will no longer file avoided cost calculations as exhibits to the
annual DSM prudency filing and will instead update all avoided costs as exhibits to IRP filings.
This will allow the Company to base program planning on the most recent IRP filing and to perform
cost-effectiveness testing using the avoided costs in place at the time of program planning.
VIII. COST-EFFECTIVENESS
Intermountain reports the cost-effectiveness of its Portfolio 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
APPLICATION - 12
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. Exhibit No. 1 outlines the cost-
effectiveness for the Programs and for each individual rebate offered. It also includes a proposed
schedule to ensure formal EM&V for each rebate on a regular basis.
IX. STAKEHOLDER MEETINGS
The Energy Efficiency Stakeholder Committee (“EESC”) has been a valuable resource for
the Company as it builds the Energy Efficiency Program. As outlined in the Annual Report,
Intermountain hosted two full EESC meetings to address both the Residential and Commercial
Program. The meetings included good representation from a variety of groups including
representatives from the Commission Staff, the Governor’s Office of Energy and Mineral
Resources, a not-for-profit residential home builder, home energy raters, and city and county
representatives involved in energy efficiency and sustainability with familiarity of both the
residential and commercial sectors. Minutes from the two meetings are included in Exhibit No. 2.
X. EM&V REQUEST FOR PROPOSAL
A draft of the proposed RFP for a third-party contract to conduct an impact evaluation with
billing analysis for the Whole Home and Furnace measures is included as Exhibit No. 3 in
compliance with Order No. 35663.
MODIFIED PROCEDURE
Intermountain 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.
APPLICATION - 13
XI. REQUEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Commission issue an order designating $3,364,641 of 2022 Energy Efficiency
expenditures as prudently incurred,
b. That this Application be heard and acted upon without hearing under modified procedure,
and
c. For such other relief as this Commission may determine just and proper.
DATED: October 6, 2023
EXHIBIT NO. 1
CASE NO. INT-G-23-06
INTERMOUNTAIN GAS COMPANY
Cost Effectiveness
(22 Pages)
Introduction
Intermountain’s Energy Efficiency Program (EE Program) offers individual customers a way to
lower their usage and monthly energy bills. It 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.
Cost-Effectiveness and Methodology
Intermountain’s objective is for all rebates 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. In
calculating the UCT and TRC, Intermountain relies on the calculations outlined in the California
Standard Practice Manual and the National Action Plan for Energy Efficiency’s (NAPEE)
Understanding Cost Effectiveness of Energy Efficiency Programs:
Best Practices, Technical Methods, and Emerging Issues for Policy-Makers.
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, except
for Whole Home rebates. Estimated therm savings for 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.
Exhibit No. 1 Case No. INT-G-23-06 Intermountain Gas Company Page 1 of 22
Assumptions
In 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 EE Program. A more in-depth discussion of the Avoided Cost calculation
and its components can be found in Case No. INT-G-2203, Exhibit No. 1 which was originally
filed as Exhibit No. 5 in Intermountain’s Integrated Resource Plan (Case No. INT-G-21-06).
Rebate Costs
Total rebate costs are calculated by multiplying the value of each rebate by the number of
rebates issued for the year.
Equipment & Installation 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.
Program Delivery & Administration
Program delivery and administration costs are direct assigned to their respective program,
either residential or commercial, when they can be specifically identified. For example, the
expense of a residential builder mailing list is charged to Residential Program delivery and
administration costs. After all direct costs are assigned, the remaining pool of program and
administration costs, are split between the residential program and commercial program based
on a respective 95/5 split. This 95/5 split was developed after re-evaluating the company’s
Exhibit No. 1 Case No. INT-G-23-06 Intermountain Gas Company Page 2 of 22
expense allocation. For 2022, total estimated therm savings for the Energy Efficiency Portfolio
were 648,935 therms: 615,806 attributed to the Residential Program and 33,126 from the
Commercial Program, or a 95/5 split between the two programs. An analysis of service starts
by the ESRs, tracked in Construction Tracking, also very closely followed this split, with 8,901
residential service starts and 496 commercial sales starts or a 96% and 4% split in service starts
in 2022. Therefore, the Company implemented the 95/5 allocation of expenses for all
expenses that were not direct assigned.
Real Discount Rate
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-22-03, Exhibit
No. 1, Page 11. Per Case No. INT-G-22-03, Order No. 35663, the Company will update the
discount rate and inflation rate within the avoided cost filing in the IRP.
Inflation Rate
An inflation assumption is used in cost-effectiveness testing to convert nominal, forward-
looking costs into real dollars. The company assumes an inflation rate 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. It 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 100% for all rebate and program cost-effectiveness analysis. Intermountain 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.
Exhibit No. 1 Case No. INT-G-23-06 Intermountain Gas Company Page 3 of 22
Results
The Company performed cost-effectiveness testing at the program level and the individual
measure level. The Residential Program was found to be cost-effective with a UCT of 1.3. The
Commercial Program remains in an awareness-building mode since its launch on April 1, 2021.
The UCT of the Commercial Program was 2.0.
EM&V Schedule
The Company prepared a revised EM&V schedule through 2024. 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. For measures with limited
participation, the Company was advised to monitor Program participation and to conduct
EM&V impact evaluations when there was sufficient participation to justify an evaluation. The
Company work with a 3rd party evaluator to determine when there is enough data to provide
meaningful evaluation.
The schedule was amended based on the amount of data available for analysis. The impact
evaluation for residential water heating measures was moved to year end 2023 due to the
limited number of both storage and tankless water heater rebates. The Company updated both
the storage and water heater rebates effective April 1, 2021, and uptake has already increased.
The impact evaluation planned for year-end 2022 for commercial kitchen rebates, fryer,
griddle, and steamer, was also postponed. Due to the slow uptake in the Commercial Program,
the Company plans to conduct a process evaluation for all commercial measures for year-end
2023. The Company plans to use a billing analysis to evaluate program performance for the
furnace and Whole Home measures until such time as the Company justifies other empirical
analysis as part of the annual DSM prudency filing.
Exhibit No. 1 Case No. INT-G-23-06 Intermountain Gas Company Page 4 of 22
INTERMOUNTAIN GAS COMPANY
Residential Energy Efficiency Program
2022 UCT Results
Rebate
Therm
Savings Savings UCT Benefits UCT Costs UCT Ratio
615,806 4,122,748 3,272,840 1.3
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Rebate
Therm
Savings Savings UCT Benefits UCT Costs UCT Ratio
36,844 182,771$ 92,092$ 2.0
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 5 of 22
INTERMOUNTAIN GAS COMPANY
Whole Home Tier I - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)161 Utility Cost 1,265$ 990$ 1.3
Lifetime Energy Savings (therms)25 Total Resource Cost 1,265$ 2,207$ 0.6
Present Value of Energy Savings S 1,265$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 900$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 1
Total Rebate Costs R 900$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 2,117$
Total Equipment & Installation Costs I 2,117$
NOTES
Program Delivery & Administration
Overhead Expenses[1]84$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 6$
Total Program Delivery & Administration Costs A 90$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 6 of 22
INTERMOUNTAIN GAS COMPANY
Whole Home Tier II - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)179,072 Utility Cost 1,407,149$ 1,105,571$ 1.3
Lifetime Energy Savings (therms)4,476,800 Total Resource Cost 1,407,149$ 3,087,954$ 0.5
Present Value of Energy Savings S 1,407,149$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 700$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 1,399
Total Rebate Costs R 979,300$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 2,117$
Total Equipment & Installation Costs I 2,961,683$
NOTES
Program Delivery & Administration
Overhead Expenses[1]117,964$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 8,307$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 126,271$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 7 of 22
INTERMOUNTAIN GAS COMPANY
Furnace - 95% AFUE - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)273,876 Utility Cost 1,868,195$ 1,385,933$ 1.3
Lifetime Energy Savings (therms)5,477,520 Total Resource Cost 1,868,195$ 4,398,569$ 0.4
Present Value of Energy Savings S 1,868,195$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 350$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 3,148
Total Rebate Costs R 1,101,800$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 1,307$
Total Equipment & Installation Costs I 4,114,436$
NOTES
Program Delivery & Administration
Overhead Expenses[1]265,439$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 18,693$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 284,133$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 8 of 22
INTERMOUNTAIN GAS COMPANY
Combination Boiler - 95% AFUE - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)930 Utility Cost 6,753$ 5,342$ 1.3
Lifetime Energy Savings (therms)20,460 Total Resource Cost 6,753$ 21,674$ 0.3
Present Value of Energy Savings S 6,753$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 800$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 6
Total Rebate Costs R 4,800$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 3,522$
Total Equipment & Installation Costs I 21,132$
NOTES
Program Delivery & Administration
Overhead Expenses[1]506$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 36$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 542$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 9 of 22
INTERMOUNTAIN GAS COMPANY
Boiler - 95% AFUE - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)795 Utility Cost 6,247$ 4,451$ 1.4
Lifetime Energy Savings (therms)19,875 Total Resource Cost 6,247$ 6,281$ 1.0
Present Value of Energy Savings S 6,247$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 800$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 5
Total Rebate Costs R 4,000$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 1,166$
Total Equipment & Installation Costs I 5,830$
NOTES
Program Delivery & Administration
Overhead Expenses[1]422$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 30$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 451$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 10 of 22
INTERMOUNTAIN GAS COMPANY
Storage Water Heater - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)1,216 Utility Cost 6,036$ 6,568$ 0.9
Lifetime Energy Savings (therms)15,808 Total Resource Cost 6,036$ 15,368$ 0.4
Present Value of Energy Savings S 6,036$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 115$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 32
Total Rebate Costs R 3,680$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 390$
Total Equipment & Installation Costs I 12,480$
NOTES
Program Delivery & Administration
Overhead Expenses[1]2,698$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 190$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 2,888$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 11 of 22
INTERMOUNTAIN GAS COMPANY
Tankless Water Heater Tier I - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)37,050 Utility Cost 291,139$ 236,697$ 1.2
Lifetime Energy Savings (therms)926,250 Total Resource Cost 291,139$ 1,077,447$ 0.3
Present Value of Energy Savings S 291,139$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 325$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 570
Total Rebate Costs R 185,250$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 1,800$
Total Equipment & Installation Costs I 1,026,000$
NOTES
Program Delivery & Administration
Overhead Expenses[1]48,062$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 3,385$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 51,447$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 12 of 22
INTERMOUNTAIN GAS COMPANY
Tankless Water Heater Tier II - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)870 Utility Cost 6,836$ 5,854$ 1.2
Lifetime Energy Savings (therms)21,750 Total Resource Cost 6,836$ 18,634$ 0.4
Present Value of Energy Savings S 6,836$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 300$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 15
Total Rebate Costs R 4,500$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 1,152$
Total Equipment & Installation Costs I 17,280$
NOTES
Program Delivery & Administration
Overhead Expenses[1]1,265$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 89$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A 1,354$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 13 of 22
INTERMOUNTAIN GAS COMPANY
Smart Thermostat - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)121,836 Utility Cost 529,128$ 521,434$ 1.0
Lifetime Energy Savings (therms)1,340,196 Total Resource Cost 529,128$ 825,877$ 0.6
Present Value of Energy Savings S 529,128$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Average Rebated Amount[1]98$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 2,769
Total Rebate Costs R 271,509$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 208$
Total Equipment & Installation Costs I 575,952$
NOTES
Program Delivery & Administration
Overhead Expenses[2]233,482$ [1]Rebates pay the full cost of the individual thermostat up to a maximum of $100.
Direct Costs 16,443$
Total Program Delivery & Administration Costs A 249,925$ [3]Minimum NTG value where rebate remains cost-effective under UCT.
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 14 of 22
INTERMOUNTAIN GAS COMPANY
Condensing Unit Heater - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)- Utility Cost -$ -$
Lifetime Energy Savings (therms)- Total Resource Cost -$ -$
Present Value of Energy Savings S -$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 1,500$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count -
Total Rebate Costs R -$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 2,889$
Total Equipment & Installation Costs I -$
NOTES
Program Delivery & Administration
Overhead Expenses[1]-$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs -$
Total Program Delivery & Administration Costs A -$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 15 of 22
INTERMOUNTAIN GAS COMPANY
Boiler Reset Control - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)- Utility Cost -$ -$
Lifetime Energy Savings (therms)- Total Resource Cost -$ -$
Present Value of Energy Savings S -$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 350$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count -
Total Rebate Costs R -$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 612$
Total Equipment & Installation Costs I -$
NOTES
Program Delivery & Administration
Overhead Expenses[1]-$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs -$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A -$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 16 of 22
INTERMOUNTAIN GAS COMPANY
High Efficiency Condensing Boiler - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)9,064 Utility Cost 71,225$ 18,710$ 3.8
Lifetime Energy Savings (therms)226,600 Total Resource Cost 71,225$ 35,966$ 2.0
Present Value of Energy Savings S 71,225$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Average Rebated Amount[1]2,567$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 7
Total Rebate Costs R 17,969$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 5,032$
Total Equipment & Installation Costs I 35,224$
NOTES
Program Delivery & Administration
Overhead Expenses[2]671$ [1]Rebates are based on the capacity of the unit.
Direct Costs 71$
Total Program Delivery & Administration Costs A 742$ [3]Minimum NTG value where rebate remains cost-effective under UCT.
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 17 of 22
INTERMOUNTAIN GAS COMPANY
Commercial Energy Efficiency Program
Fryer - Energy Star Certified - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)9,652 Utility Cost 44,949$ 17,214$ 2.6
Lifetime Energy Savings (therms)115,824 Total Resource Cost 44,949$ 2,964$ 15.2
Present Value of Energy Savings S 44,949$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 800$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count 19
Total Rebate Costs R 15,200$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 50$
Total Equipment & Installation Costs I 950$
NOTES
Program Delivery & Administration
Overhead Expenses[1]1,820$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs 193$
Total Program Delivery & Administration Costs A 2,014$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 18 of 22
INTERMOUNTAIN GAS COMPANY
Steamer - Energy Star Certified - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)- Utility Cost -$ -$
Lifetime Energy Savings (therms)- Total Resource Cost -$ -$
Present Value of Energy Savings S -$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 1,100$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count -
Total Rebate Costs R -$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 635$
Total Equipment & Installation Costs I -$
NOTES
Program Delivery & Administration
Overhead Expenses[1]-$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs -$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A -$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 19 of 22
INTERMOUNTAIN GAS COMPANY
Griddle - Energy Star Certified - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)- Utility Cost -$ -$
Lifetime Energy Savings (therms)- Total Resource Cost -$ -$
Present Value of Energy Savings S -$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Rebate Amount 200$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Rebate Count -
Total Rebate Costs R -$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 360$
Total Equipment & Installation Costs I -$
NOTES
Program Delivery & Administration
Overhead Expenses[1]-$ [1]Allocated based on percentage of portfolio rebate count.
Direct Costs -$ [2]Minimum NTG value where rebate remains cost-effective under UCT.
Total Program Delivery & Administration Costs A -$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 20 of 22
INTERMOUNTAIN GAS COMPANY
Energy Saving Kit - 2022 Cost-Effectiveness Results
Benefits Cost-Effectiveness Tests
Annual Energy Savings (therms)18,128 Utility Cost 66,597$ 56,168$ 1.2
Lifetime Energy Savings (therms)163,149 Total Resource Cost 66,597$ 61,556$ 1.1
Present Value of Energy Savings S 66,597$
Costs Equations & Assumptions
Utility Cost Test = S x NTG ÷ (R + A)
Average Kit Cost 58$ Total Resource Cost Test = S x NTG ÷ (I x NTG + A)
Kit Count 342
Total Kit Costs R 19,920$ Real Discount Rate 4.68%
Inflation Rate 2.00%
Equipment & Installation Costs Net-to-Gross (NTG)100%
Incremental Cost Per Unit 74$
Total Equipment & Installation Costs I 25,308$
NOTES
Program Delivery & Administration
Overhead Expenses[1]32,768$ [1]Allocated based on percentage of portfolio annual therm savings.
Direct Costs 3,480$
Total Program Delivery & Administration Costs A 36,248$
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 21 of 22
Energy Efficiency Program 2024 2023 2022 2021 2020 2019 2018
Residential Measures:
Whole Home I/P
Whole Home Tier I P I
Whole Home Tier II P I
Fireplace 70% FE P
Fireplace 80% AFUE P
Combination Boiler for Space and Water Heat I/P P
Furnace I/P I/P
Boiler I/P
Storage Water Heater I/P P
Tankless Water Heater Tier I I/P P
Tankless Water Heater Tier II I/P
Smart Thermostat P I
Commercial Measures:
Condensing Unit Heater P
Boiler Reset Control P
High-Efficiency Condensing Boiler P
Fryer P
Steamer P
Griddle P
Pilot: Energy Savings Kit O
Evaluation Type: I=Impact, P=Process, O= Other
Program not yet in existence
Measure offering modified
Measure Offering retired
ENERGY EFFICIENCY PROPOSED EM&V SCHEDULE 2018-2024
For Rebates Issued Through the Year Ended
Exhibit No. 1 Case No. INT-G-23-06
Intermountain Gas Company Page 22 of 22
EXHIBIT NO. 2
CASE NO. INT-G-23-06
INTERMOUNTAIN GAS COMPANY
Energy Efficiency Stakeholder Committee
Meeting Minutes
(6 pages)
Intermountain Gas Energy Efficiency Stakeholder Committee
Meeting
May 5, 2022 at 9:00 am
Attendees:
Lori Blattner – Intermountain Gas Company
Jacob Darrington - Intermountain Gas Company
Landon Barber – Intermountain Gas Company
Kathy Wold – Intermountain Gas Company
John Fisk - Intermountain Gas Company
Kody Thompson – Intermountain Gas Company
Alexa Sakolsky-Basquill – Office of Energy and
Mineral Resources
Brian Bennett – The Energy Auditor
Donn English – Idaho Public Utilities
Commission
Kevin Keyt – Idaho Public Utilities Commission
Laura Conilogue – Idaho Public Utilities
Commission
Selena O’Neal - Energy Specialist with Ada
County
Taylor Thomas – Idaho Public Utilities
Commission
Will Gehl – City of Boise
Guests and Presenters:
Kathy Wold – Intermountain Gas Company
John Fisk – Intermountain Gas Company
Kody Thompson – Intermountain Gas Company
Landon Barber – Intermountain Gas Company
Meeting Facilitator: Kathy Wold
9:00 am – Meeting Convened
Kody presented on Residential Program rebate activity in 2021 and presented the cost-effectiveness
testing for each measure. Kody also provided an overview of the method by which applications are
received, citing specifically the increase in online rebate submissions.
Taylor Thomas asked about why no uptake on the Tier 1 Whole Home. Kody thought it might be because
of stricter air change requirements. Brian Bennett said that it more had to do with 97% AFUE furnaces
being unavailable due to supply chain, with wait times up to 5-8 months (what used to be 3-4 weeks).
John presented on the EE Team activities/outreach for the Residential Program. To leverage employees
promoting the EE program, the Company conducted an employee EE awareness campaign.
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 1 of 6
John provided an overview of the Spring campaign which involved full bus wraps on Valley Ride busses.
The bus routes with the highest visibility were chosen for maximum impressions.
John also covered traditional outreach methods like the new customer letter, social media posts, the
annual bill insert/customer engagement activity, and builder and contractor outreach. John also
represented the IGC EE Program at a code board meeting in Ammon, ID, leveraging an existing,
mandatory meeting for area builders and contractors.
Committee questions following John’s presentation:
•The Committee asked if the raffle prize for the employee incentive program was paid for out of
the EE rider budget. Employee energy efficiency engagement prize was paid from the EE
budget.
•Were the buses CNG powered buses? Yes.
•Were you able to correlate impressions with uptake? The Company was not able to correlate
impressions with rebate uptake.
•Do you know how many customers receive e-bill vs. paper bill? Lori responded back in chat that
42.1% receive e-bill.
Kathy presented on Commercial Program observations and insights. The Company is working on a
project to assign SIC codes to better customize outreach efforts by industry. Overall, the Commercial
Program is still very much in a growth and awareness building mode.
Kody presented on Commercial Program rebate activity in 2021, cost-effectiveness results by measure
and lessons learned.
Committee questions:
•Any plan to measure the actual savings being achieved on the measures that were installed (to
compare to what the CPA said those measures would save)? Kathy postponed until the EM&V
discussion.
John presented on the EE Team activities/outreach for the Commercial Program. John provided an
overview of the development of Commercial outreach collateral: web pages, brochures, commercial
customer mailings, the commercial kitchen savings calculator, and the ESK (energy savings kit) pilot
program.
Landon presented on an internal EM&V type analysis to examine CPA therm saving estimate against
billing data. This analysis focused on customer bills for a sample of Program participants who replaced
baseline efficiency furnace with a rebated high-efficiency furnace. This analysis resulted in a therm
savings of approximately 81.1 therms per year, which seemed to align with the results from the CPA
savings estimate of 87 therms.
Landon also presented on the relationship between the HERS score and gas usage. This analysis found
there is a 99.9% significance level that the HERS Index score is a fantastic predictor of how much gas
customers would use.
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 2 of 6
The final project was a database validation analysis. This analysis was a validation of data being collected
by the Program (address names, square footage and zip codes) against other sources like the Ada county
assessor site, and the Company’s billing database. Continuity here will be important for joining
information for future studies like EM&V.
Committee responded this was good information and asked the following:
• Please describe how you did the billing analysis? Landon explained the more technical aspects
of how the study was conducted.
• Was the data adjusted for weather? Yes, it was weather normalized.
Kathy provided an overview on the Program’s involvement in the North American Gas Heat Pump
Collaborative.
Lori presented on some restructuring (and cost saving) changes coming to EE for IGG through the
creation of a West Energy Efficiency team. Lori will be leading the group that will combine Idaho,
Oregon and Washington energy efficiency departments.
Kathy presented on new projects on the horizon:
• The Company will go out for RFP for CPA in the fall.
• The Company is working with the internal IT department to develop a rebate processing app to
streamline rebate processing.
• Upcoming tariff filing to clean up the smart thermostat rebate offering from wi-fi enabled to
Energy Star certified.
• Kathy walked through the EM&V schedule and noted much of the determination for evaluation
will be the level of participation, if there is enough to evaluate given the expense of EM&V
studies.
• The residential rider balance is over-collected. The Company is exploring options to correct that
balance: customer refund and the possibility of a residential energy saving kit program with items
focused on weatherization.
Question from the Committee:
• Does IGC has an app for e-bills. Kathy – no we don’t. And she clarified what she meant by an
EE rebate application app.
• Weatherization kits are not unprecedented in the state of Idaho (something like this was done
during the oil embargo days in the 70s or 80s). Recommended to investigate how that was
managed.
• Any supply chain issues and how much will each kit cost? Kathy wasn’t sure about supply chain,
but the estimate we got was about $29.
• Would this be cost-effective? Kathy presented the preliminary cost-effectiveness.
• How would customers get these kits? Kathy – we would use an application process to have
customers request these kits.
• How much would this program cost in totality? Kathy would need to run some additional
analysis.
• Given the over-collected balance Committee thinks that the rider would still need to be adjusted
even if residential energy savings kits are pursued.
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 3 of 6
•Comment: The weatherization kit is a great program to explore. Interested to see what uptake
would be and cautioned that it can be challenging to have kits installed. Northwest Power
Council Regional Technical Forum might be a resource.
•When will the CPA go to RFP and how long it will take to be completed? RFP to be issued in the
fall, hopefully complete right after the first of the year.
•Have increased commodity prices increased interest in EE? Kathy has not heard anything about
that, but she has heard a lot about supply chain issues. Lori mentioned customers haven’t seen
any IGC rate changes yet, but maybe they will after the PGA in the fall.
•Please provide the slides and for the next meeting can you provide the slides beforehand to allow
participants to better prepare with questions?
Meeting adjourned at 10:40 am.
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 4 of 6
Intermountain Gas Energy Efficiency Stakeholder Committee
Meeting
November 16, 20 22 at 1:00 pm
Attendees:
Kathy Wold – Intermountain Gas Company
John Fisk – Intermountain Gas Company
Kody Thompson – Intermountain Gas Company
Alexa Bouvier - OEMR
Kevin Keyt – IPUC
Selena O’Neal – Ada County
Taylor Thomas – IPUC
Will Gehl – City of Boise
Guests and Presenters:
Kathy Wold – Intermountain Gas Company
John Fisk – Intermountain Gas Company
Kody Thompson – Intermountain Gas Company
Meeting Facilitator: Kathy Wold
1:00 PM – Meeting Convened
Kathy welcomed everyone to the meeting and presented the agenda for the meeting.
John presented the Safety Moment: Winter Vehicle Prep.
Members of the stakeholder committee introduced themselves.
A request was made that the slide deck be provided to committee members prior to the meeting so
they may prepare.
1:15 PM – Rebates & Updates
Kody Thompson provided an update on rebate performance through Quarter 3 of 2022, including the
total number of rebates and by measure for both the Residential and Commercial Programs.
Kody also provided an update on an internal project to create a rebate app that would help streamline
rebate processing. Committee asked for clarification on what exactly would be automated, and if the
Company anticipated the app would reduce FTE. Every rebate will still be verified and approved, but
payment processing post approval would be automated (vendor list creation), and the Company expects
some efficiency gains in processing, but impacts are unknown at this time.
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 5 of 6
Residential Program Outreach and Education
John Fisk presented updates on the results on the residential customer engagement activity, “Grocery
Card Giveaway,” Parade of Homes outreach partnering with builders and the home buying community,
and an IGC Employee engagement activity.
1: PM – Commercial Program Outreach
John discussed a customized marketing outreach with restaurants to promote foodservice equipment
rebates. He also cited advice from the Energy Services Representatives that we promote the Commercial
Program with engineers and architects to get energy efficiency implemented in the design process,
rather than just the retrofit market and provided examples of targeted promotions with design
organizations such as ads and active sponsorship at golf tournaments with ASHRAE and AIA. He also
presented an update on a commercial contractor and design outreach effort to promote a GHP
Workshop hosted by the Energy Solutions Center. He also provided an update on the Commercial ESK
Program. The Committee asked how many of the 250 kits we have remaining. The Company responded
143, with another email campaign to take place before the end of the year.
Committee asked about the Company’s thoughts on the difference in the “click through” rate between
the two customer engagement campaigns (35% vs. 10%).
The Company did not have a exact explanation for the difference in the open rates, but suspected it was
driven by the engagement activity, people saw it, didn’t want to take a quiz, or saw it and took the
energy efficiency quiz to enter for a chance to win a grocery card. Despite the lower click thru rate, the
activity still resulted in more customer responses than any other engagement activity.
1:20 PM – What’s Next?
Kathy relayed the Company is in the very early stages of exploring the possibilities of a custom program
for the Commercial EE Program.
2:05 PM – Meeting Adjourned
Exhibit No. 2 Case No. INT-G-23-06 Intermountain Gas Company Page 6 of 6
EXHIBIT NO. 3
CASE NO. INT-G-23-06
INTERMOUNTAIN GAS COMPANY
Draft EM&V Request for Proposal
(9 pages)
Request for Proposal
Energy Efficiency
Impact Evaluation
Issued: To Be Determined
Responses Due: Two Weeks after Issue Date
Contact: Kathy Wold, Manager Energy Efficiency
Email: Kathy.wold@intgas.com
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 1 of 9
Page 1
Request for Proposal
I e f s
II. Introduction..........................................................................................................................................2
A. Project...............................................................................................................................................2
B. Company Background......................................................................................................................3
C. Key Objectives and Deliverables......................................................................................................4
D. Scope of Work ..................................................................................................................................4
III. PROCESS INFORMATION..................................................................................................................6
A. Schedule............................................................................................................................................6
B. Contact Information.........................................................................................................................6
C. Intent to Bid......................................................................................................................................6
D. Proposal Content..............................................................................................................................7
E. Proprietary Information – Confidentiality.......................................................................................7
F. No Contract Formation ....................................................................................................................8
IV. RFP EVALUATION PROCESS..............................................................................................................8
A. RFP Evaluation Team........................................................................................................................8
B. RFP Evaluation Criteria.....................................................................................................................8
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 2 of 9
Page 2
Request for Proposal
I n
t
Intermountain Gas Company (“IGC”) is seeking proposals from qualified organizations or individuals
(“Respondent”) interested in providing impact evaluations with billing analysis of two specific IGC
residential energy efficiency measures. Impact evaluations would provide analysis of energy savings, by
measure, for the program years April 2021 through December 2022 for the energy efficiency program.
IGC Energy Efficiency Program
Intermountain Gas was granted authority by the Idaho Public Utilities Commission to implement an
energy efficiency program effective October 1, 2017. The residential energy efficiency program was
designed to acquire cost-effective demand side management (DSM) resources in the form of natural gas
therm savings. The program includes rebates for residential customers that purchase and install
qualifying high-efficiency natural gas equipment.
IGC commissioned their first Conservation Potential Assessment in 2018 to support both short-term
energy efficiency planning and long-term resource planning activities. Three levels of savings potential
were assessed: technical, economic and achievable.
A 2020 impact evaluation resulted in several recommendations for the Whole Home and furnace
measures. It was recommended by evaluators that IGC remove the ENERGY STAR certification
requirement and implement a more stringent requirement on HERS Index scores be implemented in
light of the 2018 IECC residential code adoption. Evaluators also recommended implementing specific
requirements such as high-efficient equipment, more stringent air sealing and duct sealing requirements
to directly target natural gas savings. The Whole Home rebate was restructured as a two-tiered rebate
and went into effect on April 1, 2021.
Whole Home Rebate
The Whole Home rebate provides an incentive to residential customers in IGC service territory for the
construction of single-family homes incorporating energy efficient design. Initiated in April 1st of 2021,
the objective of the measure is to acquire energy savings by encouraging customers to build homes
incorporating energy efficient design well above most homes on the market today.
There are two tiers to the Whole Home rebate. To qualify for the Whole Home rebate, a home must
comply with the following requirements.:
TIER I:
x Home must be HERS rated
x Air sealing at or below 3 ACH at 50 pa
x Ceiling insulation at or below R-49
x Ducts and air handler located inside conditioned space or duct leakage to outside of less than 4
CFM25/100 ft2 CFA.
x Furnace efficiency at or above 97% AFUE
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 3 of 9
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Request for Proposal
TIER II:
x Home must be HERS rated
x Air sealing at or below 4 ACH at 50 pa
x Ducts and air handler located inside conditioned space or duct leakage to outside of less than 4
CFM25/100 ft2 CFA.
x Furnace efficiency at or above 95% AFUE
Whole Home incentives also include a “stack on” option. Water heating incentives and the smart
thermostat incentive can we “stacked on” to both the Whole Home Tier I and Tier II incentives.
95% AFUE Natural Gas Furnace
The 95% AFUE natural gas furnace rebate provides an incentive to residential customers in IGC service
territory for the installation of a high-efficient natural gas furnace in single family home using natural gas
exclusively for space heating. Participants must be served on the residential rate. The previous furnace
rebate requiring conversion to natural gas from an alternate fuel, was retired at the launch of this
rebate offering. The objective of the measure is to acquire energy savings by encouraging customers to
choose energy efficient options for space heating.
To qualify for the high-efficient natural gas furnace rebate, a participant must use natural gas exclusively
for space heating and be served on the residential rate. The furnace must meet a minimum efficiency of
95% AFUE or higher. New construction, replacement on burnout, conversion and early retirement are all
eligible for the rebate. The natural gas furnace rebate cannot be combined with the Whole Home
rebate.
IGC requires all equipment must be installed according to current code and approved by local or state
inspection with the signed, approved permit. All equipment must be installed, and work completed, by a
licensed and bonded contractor. The company does allow self-installations with additional supporting
documentation: copy of the purchase receipt of the equipment and a picture of the equipment sticker
displaying the brand, model number and serial number.
Based on the 2020 impact evaluation recommendations, Intermountain revised the rebate application
to capture more data points to allow for more robust evaluation of the measure in the future.
For more information regarding these offerings, please refer to the 2022 Annual Report, found at the
following link: Intermountain Gas Energy Efficiency Program - Intermountain Gas Company (intgas.com)
B y d
IGC is the sole distributor of natural gas in Southern Idaho. Its service area extends across the entire
breadth of Southern Idaho, an area of 50,000 square miles, with a population of approximately
1,409,000. At the end of 2022, IGC served 410,005 customers in 74 communities through a system of
over 12,800 miles of transmission, distribution, and service lines.
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 4 of 9
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Request for Proposal
C y s d s
The key objectives of the impact evaluation include:
x Estimate energy savings by comparing energy consumption of participants to the consumption
that would have occurred without the incentive for the timeframe April 2021 through December
2022, and corrected for weather:
o For the Whole Home incentive evaluation will compare billed consumption of program
participants to the consumption of similar new home non-participants
o For the 95% AFUE natural gas furnace incentive the evaluation should either:
Compare consumption of participants to non-participants, or
Compare the consumption of the same participants before and after installing
the measure.
x Provide confidence levels of 90 percent as well precision levels of 10 percent and program
measure ex-post realization rates attributed to the Whole Home rebate measure and the 95%
AFUE natural gas furnace measure.
Report findings and observations of future ex-ante savings analysis and the accurate and transparent
reporting of program savings.
D. Scope f k
IGC anticipates the selected Respondent will be required to undertake the following tasks in addressing
the key objectives and deliverables. Proposals should address these tasks in detail:
1.Scope of Work Meeting. The Respondent will meet with IGC staff within two weeks of contract
signing and present proposed evaluation methodologies, data collection plan, analysis, report
preparation and delivery, and any other tasks Respondent and IGC feel pertinent to the
evaluation. A final Statement of Work will be developed based on outcomes from this meeting.
This Statement of Work will become part of the contract and will become the basis for this
evaluation.
2.Work Plan. The Respondent will develop a detailed work plan based on the Statement of Work
that details how the Key Objectives and Deliverables will be addressed.
3.Site Visits and Participant Interviews. Where appropriate, the Respondent will verify
installation of energy efficiency measures and associated energy impacts, by conducting site
visits to program participant locations. Respondent should recommend and propose the
appropriate number of site visits based on their experience and expertise with similar
evaluations.
It is necessary that the Respondent coordinate efforts with IGC regarding customer contact and
conduct research in such a manner as to minimize the time impact on IGC customers
participating in this evaluation. Information provided by program participants will be considered
confidential in terms of attribution and shall not be share with any other party.
4. Data Sources.Respondent should recommend and propose the appropriate number of site
visits based on their experience and expertise with similar evaluations. The Respondent will
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 5 of 9
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Request for Proposal
conduct customer interviews/surveys, analyze program data to a set confidence level of at least
90%, and review rebate documentation where appropriate. The Respondent will verify a subset
of EE measure installations and associated energy impacts by conducting a number of site visits
and interviews of program participants needed to collect missing information and achieve data
confidence.
5.Impact Analysis with Billing analysis. The Respondent will analyze the data collected from
previous tasks to develop estimates of energy impacts at the measure level. The Respondent will
provide these estimates by comparing deemed values to the source, data collected from site
visits, desk reviews, and customer interviews. The Respondent will provide an estimation of
realization rates to assist in determining ex-ante net energy savings.
Data collected by IGC, and to be made available to Respondent for analysis, includes billed
consumption, brand, model, and efficiency levels of all furnaces rebated under the 95% AFUE
furnace rebate. For the Whole Home rebate, available data includes billed consumption, and
HERS Index score, furnace efficiency, ACH, Air Sealing, and duct leakage values provided by
certified home raters.
6.Interim Reporting. The Respondent will be required to provide to IGC monthly status reports
detailing progress toward completion and any obstacles encountered. These status reports will
be due by the 15th of each month and will include an updated schedule of future activities.
7.Draft and Final Report. The Respondent will be required to provide to IGC bi-weekly status
reports detailing progress toward completion and any obstacles encountered. These status
reports will be due by the 1st and 15th of each month and will include an updated schedule of
future activities.
The Respondent will provide a draft final report to Intermountain upon completion of all tasks.
This draft will be reviewed by Intermountain, and comments will be provided to the Respondent
for clarification as necessary. The Respondent will provide to Intermountain the final version of
the report. Graphs and/or tables are recommended for information not easily conveyed in
narrative form. The draft and final report is required to contain, at a minimum, sections
containing, an executive summary, evaluation methodologies and findings and conclusions. The
Respondent will document methods and preserve workpapers to be evaluated by the public
utilities commissions and interested parties.
8.Presentation of Results. The Respondent will be required to present the results of this analysis
to interested parties at an IGC Energy Efficiency Advisory Group meeting to be held in Boise,
Idaho as well as an option to attend virtually.
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 6 of 9
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Request for Proposal
I S N
e
The project schedule will be determined by the selected Respondent with the following key milestones
included: Draft report of impact evaluation provided to IGC by TBD. Impact Evaluation final report
provided to IGC by No later than 4/1/2024.
Date Event
TBD Intent to Bid submission due
One week after (above) Last day for Respondents to submit questions
2 weeks after(above) RFP Proposals Due by 5:00 p.m. MDT
1 week after(above) Complete review and evaluation of proposals
4 day period starting(above)Begin Finalist interviews
17 days after(above) Kick-off meeting
11 weeks after(above) Impact Evaluation Draft Report Due
2 weeks after(above) no later than 4/1/2024 Final report due – Impact Evaluation
B. Contact n
If you have any questions regarding this invitation to bid process, please contact Kathy Wold at 208-377-
6128. Your proposal may be submitted via email, mail, or FedEx and must be received by COB TBD.
Address for mailed or FedEx responses:
Intermountain Gas Company
Attn: Kathy Wold
P.O. Box 7608
555 South Cole Road
Boise, ID 83707
Email address: Kathy.Wold@intgas.com
This invitation to submit a formal proposal expires at the close of business TBD. Thank you in advance
for the time and effort put forth in preparing your proposal and your prompt response to our inquiry.
C. Intent o d
All “Intent to Bid” forms (see Appendix A) must be received no later than the COB TBD.
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 7 of 9
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Request for Proposal
D.P l
Respondents submitting a proposal shall use the following outline and criteria:
1. A description of the firm’s qualifications to conduct IGC’s energy efficiency impact evaluation
with billing analysis. The preferred bidder will have experience working with natural gas utilities,
as well as a strong understanding of engineering, market, and building science principles as
applied to demand side management planning.
2. Evaluators should have familiarity with the Idaho Building Code.
3. A technical proposal not to exceed 15 pages.
4. A management plan and proposed schedule of deliverables including a kickoff meeting
scheduled within two weeks of contract signing.
5. Response to each item listed in Section II.C., Key Objectives and Deliverables and Section II.D.,
Scope of Work.
6. A detailed budget broken out by task, number of hours, and by individual performing the work.
Key individuals should be identified by name along with billing rates for each individual. Budget
should also include any additional ancillary services provided such as site visits. Budget should
include time and materials on a not to exceed basis. Budget should include a rate schedule for
support after submission of the final report to respond to any questions about the evaluation
from the public utilities commission or other interested parties.
7. Resumes of key staff and subcontractor qualifications.
8. Three references from previous energy efficiency impact evaluation clients.
9. Example of previous energy efficiency impact evaluation reports.
E. Proprietary n –y
Respondent agrees that all information obtained or produced in relation to this RFP is the sole property
of Intermountain Gas Company and shall not be released or disclosed to any person or entity for any
purpose nor used for any purpose other than providing a proposal to IGC, without the express written
consent of IGC.
Respondent agrees not to make any public comments or disclosures, including statements made for
advertising purposes, regarding the Request for Proposals to the media or any other party without the
prior written consent of IGC. In the event the Respondent receives any inquiries regarding the RFP from
the media or any other party, said inquiries shall be forwarded to IGC.
Respondent shall specifically designate and clearly label as “Confidential” any and all material(s) or
portions of their response that they deem to contain proprietary information.
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 8 of 9
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Request for Proposal
F o t n
This request does not constitute a contract or an offer or acceptance of an offer to enter into a contract.
Further, this correspondence may not be used to modify, supplement, novate, or waive any rights with
respect to an existing contract or other binding terms.
IV. RFP N S
P n m
An IGC evaluation team will determine the proposal that best meets the requirements of this RFP and
provides the best overall value for IGC. Proposals will be evaluated in accordance with the requirements
set forth in this RFP, any addenda that are issued, and any other factor IGC deems appropriate. Based
upon the RFP response evaluation and scoring, references and any subsequent activities identified
during the evaluation process (clarifications, answers to questions, etc. that may be required), IGC may
identify the top candidate(s) for further clarifications and/or a Respondent presentation.
Those Respondents whose proposals have not been selected will be notified via an email or a written
letter at the address provided in their proposal.
B. RFP n a
At a minimum, proposals will be evaluated based on the response to this RFP, which may include, but
not be limited to the following criteria:
x Ability to meet RFP requirements.
x Financial stability of the company.
x Total project cost.
x Reputation for thoroughness, credibility, and client responsiveness as demonstrated through
references.
x Technical approach and demonstrated understanding of the issues surrounding the
administration and evaluation of natural gas utility energy efficiency measure impact evaluation.
x Experience and qualifications of proposed staff and management team. No changes in key
personnel should be made without written agreement from IGC.
x The experience of the firm, with interest in evaluation of, and experience with, natural gas utility
energy efficiency impact evaluations.
x The merits of the proposed evaluation methodologies.
x Responses to each item in Sections II.C (Key Objectives and Deliverables) and II.D. (Scope of
Work).
x Proposed itemized budget. The proposal should be bid on a time and materials, not to exceed
basis.
x Any other factors deemed appropriate by IGC.
Exhibit No. 3 Case No. INT-G-23-06 Intermountain Gas Company Page 9 of 9