20240222Comments of the Commission Staff.pdf

MICHAEL DUVAL DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074
[phone]IDAHOBARNO.11714
Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83 714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS COMPANY'S APPLICATION FOR A
DETERMINATION OF 2022 ENERGY EFFICIENCY EXPENSES AS PRUDENTLY INCURRED
) ) CASE NO. INT-G-23-06
)
) ) COMMENTS OF THE ) COMMISSION STAFF __________________)
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Michael Duval, Deputy Attorney General, submits the following
comments.
BACKGROUND
On October 6, 2023, Intermountain Gas Company ("Company"), a subsidiary of MDU
Resources Group, Inc., applied to the Idaho Public Utilities Commission ("Commission") for an
order designating $3,364,641 of2022 Energy Efficiency ("EE") expenditures as prudently
incurred ("Application"). The Company filed its 2022 Energy Efficiency Annual Report
concurrently with its Application.
On November 15, 2023, the Commission issued a Notice of Application and Notice of
Intervention Deadline. Order No. 36002. The city of Boise City intervened. Order No. 36032.
STAFF COMMENTS 1 FEBRUARY 22, 2024
STAFF ANALYSIS This is the fifth Demand-Side Management ("DSM") Energy Efficiency prudency filing made by the Company since the EE Program's inception on October 1, 2017. Staff examined the Application, the 2022 Energy Efficiency Annual Report ("Annual Report"), Annual Report Supplements, workpapers, and additional information provided by the Company through discovery. Staff recommends the Commission approve the Company's EE Program expenses of $2,657,836 as prudently incurred. This amount is $706,805 less than the Company's request due to a Staff recommended disallowance. The comments below address the Company's program financials, cost-effectiveness, evaluations, and other topics. Absence of any discussion on additional points should not be construed as Staffs support or endorsement for the Company's position without a full evaluation in the future. Financial Review Staff audited the Company's EE Program, which included a review of the Company's EE incentives, marketing campaign, program administration, and labor expenses. Staff discovered that incentives are paid without proper documentation and Staff has concerns with the Company's internal control processes which will be discussed in greater detail below. The Tariff Rider balance, labor expenses, and calculations are also described in greater detail below. Revenue The EE Program expenditures are funded through collections from customers via Energy Efficiency Charges on Residential Customers ("EEC-RS") and General Service Customers ("EEC-GS"). The EEC-RS of$0.01564 per therm funds the Residential Program. Total Residential Program revenues for calendar year 2022 were $5,738,001. The EEC-GS of $0.00320 funds the Commercial Program. The Commercial Program revenue for 2022 was $472,346. In 2022, customer participation in the Residential Program increased 43% over the previous year with 7,945 rebates paid to customers. The most redeemed rebate was the Smart Thermostat incentive, which makes up approximately 35% of the total residential rebate count. STAFF COMMENTS 2 FEBRUARY 22, 2024
Participation in the Commercial Program also increased, but not at the same pace as the
Residential Program. The Commercial Program had $472,346 in revenue, but only $92,997 in
expenditures. The reasons for so few Commercial rebates were that multiple Commercial
measures may have been installed in 2022 without applications for rebates, the program lacks
offerings for small/light commercial customers, and the Company is still learning about its
commercial customers.
Labor Expenses
Labor expenses increased by 2% over 2021 for a total expenditure of $650,675. The
Company's EE program total labor expenses for 2023 was 19.3% of total program expenses,
which is a higher percentage than the previous four years which were: 15.9% in 2021; 17 .6% in
2020; and 17.8% in 2019. The relatively large labor percentage increase was because total
expenditures for the EE program decreased. In 2022 expenditures were approximately $3 .4
million, but in 2021 they were approximately $4 million.
Additionally, in 2023, the Company developed a new rebate application-expecting to
improve rebate validation and streamline rebate payment processing with internal systems. Staff
believes that the rebate application may help reduce inefficiencies within the EE program and
may help decrease labor expenses. Staff continues to recommend the Company reduce labor
costs wherever possible-which will help increase the cost-effectiveness of the Company's EE
Programs.
Tariff Rider
As of December 31, 2022, the Energy Efficiency Charge Rider was over-funded by
$914,459. The EEC-RS was over-funded by $450,521 and EEC-GS was $463,938 over-funded.
Staff will continue to monitor the rider balance trends in the Company's quarterly updates and
recommend adjustments as needed. Tables No. 1 and 2 below show the tariff rider balances as
of December 31, 2022.
In June of 2022, the EEC-RS was over-funded by $4,893,882. The Company states two
primary reasons for the overfunded balance. The first is that therm sales were higher than the
Company had forecasted. The second is that the entire 2019 under-funded balance of $1,097,907
was used to determine the EEC-RS rate as if it was a recurring yearly expense-rather than
STAFF COMMENTS 3 FEBRUARY 22, 2024
amortizing the balance over time. In response to the large over-funded balance, the Company proposed a one-time transfer of the $4,850,000 of the EEC-RS deferral balance to residential customers through the Company's Purchased Gas Adjustment ("PGA") filing. The Commission approved this transfer in Order No. 35552 and approved a decrease in the Energy EEC-RS from $0.02093 per therm to $0.01564 per therm in Order No. 35539 and 35552, effective October 1, 2022. Table No. 1: Residential Tariff Rider Reconciliation Beginning Balance, as of January 1, 2022 (Underfunded) $ 2,834,164 Tariff Rider Revenue $ 5,738,001 Tariff Rider Expenses $ (3,271,644) Staffs Recommended Disallowance $ 706,805 Net expenses $ (2,564,839) Residential Rider Refund to PGA $ (4,850,000) Ending Balance, as of December 31, 2022 (Underfunded) $ 1,157,326 Table No. 2: Commercial Tariff Rider Reconciliation Beginning Balance, as of January 1, 2022 (Underfunded) $ 84,589 Tariff Rider Revenue $ 472,346 Tariff Rider Expenses $ (92,997) Ending Balance, as of December 31, 2022 (Underfunded) $ 463,938 Internal Controls Through discovery and discussion with the Company, Staff believes that the Company could improve process controls. Staff is concerned that the Company has never done an internal audit of its EE program. Internal audits are important to ensure that EE programs are running efficiently and as intended. In its response to Production Request No. 24, the Company stated that it does not have plans to conduct internal audits in the near future. Staff recommends that the Company develop a schedule for regular internal audits of its EE programs to find potential issues and redundancies in the program. Specifically, Staffs audit revealed that the Company does not have specific controls for verifying proof of purchase and installation prior to paying a rebate. Staff understands that the EE team is small but believes it would be in the best interest of the program to audit a percentage of developer rebates to ensure follow through. STAFF COMMENTS 4 FEBRUARY 22, 2024
DSM Cost-Effectiveness
In its 2020 prudence filing, the Company provided an Evaluation, Measurement and
Verification study ("2020 EM& V") Impact evaluation with two distinct types of analysis that
support widely different therm savings estimates of the Company's Whole Home and Furnace
measures. In each of the prudence filings following the 2020 EM&V, the Company has used the
simulation analysis resulting in more favorable cost-effectiveness results than the Billing
Analysis. In the previous prudence filing, the Commission directed the Company to use Billing
Analysis to evaluate the performance of its Whole Home and Furnace measures. Staff believes
that the Company is not in compliance with Commission Order No. 35663 and recommends the
Commission disallow a total of $706,805 associated with the Company's Furnace, Whole Home
Tier I and Whole Home Tier II programs.
Regulatory History
Support for this recommendation began in Case No. INT-G-19-04. In that case, the
Commission ordered the Company to conduct an EM&V of its Whole Home program; in the
ensuing Order, the Commission further specified that "[t]he deemed savings value should be
based on a comparison of actual billing data from similar new homes constructed which
received the rebate and ones that did not receive the rebate." Order No. 34536 at 5. The
Company contracted with ADM Associates ("Evaluator") to conduct its EM&V.
In Case No. INT-G-20-06, the Company did not have a completed EM&V at the time of
the original application; however, the Company filed a supplemental application which
included the completed EM&V for the Whole Home and Furnace measures. For the Whole
Home program, the study included a statistically rigorous analysis based on the measurable
savings of customer bills ("Billing Analysis") and an alternative analysis that estimated savings
using Home Energy Rating System models for each project compared to a reference model that
reflected Idaho building code requirements ("Simulation Analysis"). For the Furnace program,
the study included two alternative analyses in addition to a Billing Analysis. This included a
pre-post analysis, that the Evaluator recognizes is potentially subject to greater bias, and an
Equivalent Full Load Hours for Heating analysis that estimates savings using an engineering
equation to calculate average savings. In 2020, the Evaluator prepared a memorandum
updating its Simulation Analysis to account for Idaho adopting an updated version of the
STAFF COMMENTS 5 FEBRUARY 22, 2024
International Energy Conservation Code and affecting the baseline of its simulation.
Additionally, the Evaluator recommended a tiered structure for the Whole Home measure.
Table No. 3: Historical Sources for Therm Savin2s Estimates (therms/unit/vr)
Proeram Measure
Whole Whole 95%AFUE Home Home
Year & Source of the Estimate Furnace (Orimnal) Tier 1
2019 Conservation Potential Assessment 87 185 n/a Estimate
2020 EM&V Matched Control Group Billing 56 58 n/a Analysis
2020 EM&V Pre-Post Analysis 29 n/a n/a
2020 EM& V Simulation Analysis 134 274 n/a
Memo Simulation Analysis n/a n/a 161
Whole Home
Tier2
n/a
n/a
n/a
n/a
128
As part of its supplement, the Company updated its cost-effectiveness calculations with
therm savings estimates using the alternative Simulation Analysis which is based on industry
best practices and reported the programs as cost-effective. In Order No. 34980, the
Commission ordered the Company to "use the most accurate evaluation method and clearly
show why it is the most accurate evaluation method-regardless of 'industry best practice.'
Whatever evaluation method the Company chooses, it should provide a detailed and convincing
defense of the method-particularly if the Company chooses not to use a billing data analysis."
Order No. 34980 at 8 ( emphasis in original).
In Case No. INT-G-21-03, the Company reported cost-effectiveness using both
Simulation and Billing Analysis based therm saving estimates. Because of widespread program
changes approved in Order No. 34980 (that were implemented by the Company in April of
2021 ), Staff deferred the topic to the next prudence filing. Staff stated that it expects the
Company to comply with Order No. 34980 and provide a detailed and convincing defense of its
selected analysis method in the next prudence filing. The Commission also reiterated this
language in Order No. 35313.
In Case No. INT-G-22-03, the Company continued to evaluate the cost-effectiveness of
its Whole Home rebate using therm savings based on a simulation analysis. For the Furnace
program, the Company used the 2019 CPA savings estimate. In response to Order Nos. 34980
and 35313, directing the Company to "provide a detailed and convincing defense of its selected
STAFF COMMENTS 6 FEBRUARY 22, 2024
evaluation method," the Company did not provide its defense until requested by Staff in
Production Request No. 2. In that case, Staff commented that the Company had not provided a
detailed and convincing defense for its evaluation methods. Additionally, to support its use of
the CPA based therm savings for the Furnace program, the Company conducted an internal
analysis of furnace rebate program participants. Staff believed that the Company's analysis was
flawed by not considering a significant portion of rebates. The Commission ordered:
[T]hat the Company use a billing analysis to evaluate program performance forthe Furnace and Whole Home measures. The Company may submit argument
and evidence to justify other empirical analysis as part of its annual DSM
prudency filing.Order No. 35663 at 11.
In the current filing, the Company continued to ignore the Commission's orders and
used favorable therm savings estimates from the Simulation Analysis to evaluate the cost­
effectiveness of its Whole Home and Furnace measures. In response to Production Request No.
7, the Company provided confidential workpapers detailing the cost-effectiveness evaluation of
its 2022 programs. This document lists the source of each unit therm savings input used to
determine the benefits of the offering and to evaluate its cost-effectiveness. For the Whole
Home Tier I and Tier II rebate, the Company lists the 2020 EM&V -ADM New Homes Memo.
This memo is provided as open information in the supplemental application in Case No. INT-G-
20-06. For the Furnace rebate, the Company lists the Dunsky DEEP Model used to inform its
2019 CPA.
Since the Commissions' first order directing the Company to use Billing Analysis in Case
No. INT-G-19-04, the Company has made no reasonable effort to implement the Commission's
orders and has continually attempted to use Simulation Analysis therm savings estimates despite
the availability of and direction to use the results of the Billing Analysis to inform the evaluation
of its Whole Home and Furnace measures. It is Staff's position that, by using Simulation
Analysis therm saving estimates for the Whole Home measure and CPA therm savings estimate
for the Furnace measure, the Company is not using the most accurate evaluation method as
directed. Staff believes that, by continuing to use Simulation Analysis estimates, the Company is
overvaluing the benefits of its rebates, presenting these offerings as cost-effective, and seeking
recovery for expenses incurred beyond the value that the program is actually receiving. It is vital
that the Company's EE offerings are evaluated with data and methods that accurately reflect the
STAFF COMMENTS 7 FEBRUARY 22, 2024
savings that are realized by the Company when this information is available. While this
information is not currently available for all programs, the Billing Analysis from the 2020
EM& V is currently the most up-to-date analysis of actual savings from the Whole Home and
Furnace measures. Staff believes that the record of Staff comments and Commission orders
described above have established clear guidance that the Company should be using Billing
Analysis supported therm savings to evaluate these programs, 1 unless it can present argument
and evidence to justify other empirical analysis.
Basis for Disallowance
Based on the regulatory history described above, Staff believes that $706,805 of the
Company's 2022 expenses for the Furnace and Whole Home measures are not prudently
incurred. Therefore, Staff recommends disallowing that amount.
Staff used the therm savings that the Commission directed the Company to use to
determine this amount. The Billing Analysis therm savings were 56 therms per unit per year for
the Furnace measure and 58 therms per unit per year for the Whole Home measures.
Staff proportionally modified the Whole Home therm savings to account for changes the
Company made to its Whole Home program in 2021. Based on the ratio between the Whole
Home Memo Simulation Analysis and Billing Analysis therm savings estimates, Staff calculated
that the 58-therm savings translated into 67 therms for the Whole Home Tier I program and 53
therms for the Whole Home Tier II program.2 Table No. 4 below compares the therm savings
assumed by the Company to the Billing Analysis values directed by the Commission.
1 Evaluations include cost-effectiveness evaluations impact evaluations, and interim internal evaluations.
2 Simulation results in the 2020 ADM New Homes Memo were 2.4 to 4.7 times higher than the corresponding Billing Analysis results in 2020. Since the same modeling software was used for the memo simulation results, Staff reduced the simulated therm savings by a factor of2.4 to estimate the likely billing savings. Staff believes these results are reasonable in part because the energy efficiency standard for a baseline home was raised in 2021. This more efficient baseline home should diminish the therm savings for all program measures. Therefore, the new billing values for Whole Home Tier I and Whole Home Tier II should be similar or less than the originally measured billing values.
STAFF COMMENTS 8 FEBRUARY 22, 2024
Table No. 4 - Comparison of Therm Savings
Pro2ram Measure Therm Savings (tber11L'ltunit1yr) 95%AFUE Whole Home Whole Home Furnace Tier 1 Tier 2
Values assumed by the Company 87 161 128
Billing values directed by the Commission 56 67 53
Next, Staff calculated the revised benefits for each measure by using the Company's cost­
effectiveness workpapers provided by the Company in its response to Production Request No. 7.
Staff updated the unit therm savings for the three programs in the Company's workpaper
spreadsheet-which automatically calculated the benefits. Table No. 5 compares the benefits
before and after the change for each program.
Table No. 5 -Comparison of Program Measure Benefits
Program Measure 2022 Program Benefits 95%AFUE Whole Home WhoJeHome
Furnace Tier 1 Tier 2
Rebate Count 350 1 1399
Benefit claimed by the Company $ 1,868,195 $1,265 $ 1,407,149
Benefit calculated using the billing values $ 1,202,516 $526 $ 582,647
Last, Staff compared the updated program benefits to each program's cost. The costs are
allocated by the Company and are not affected by the assumed therm savings, so Staff used the
same values declared by the Company. Table No. 6 shows that all three program measures
become cost ineffective; therefore, Staff believes that any expenses beyond the benefits are not
prudent.
Table No. 6 -Revised Analysis of 2022 Cost Effectiveness
Proeram Measure 2022 Cost-Effectiveness 95%AFUE Whole Home Whole Home Fwmce Tier 1 Tier 2 Therm Savings -Billing Data (therms/unit/yr) 56 67 53 Rebate Count 350 1 1399 Program Measure Benefits $ 1,202,516 $ 526 $ 582,647 Program Measure Costs $ 1,385,933 $ 990 $ 1,105,571 Total Deficit
Program Measure Cost Effectiveness ( a negative vakie il NOT cost effective) S (183,417) $ (464) S (S22,924) s (706,805)
STAFF COMMENTS 9 FEBRUARY 22, 2024
Cost-Effectiveness Implications
Based on the Company's worksheets updated with Billing Analysis therm savings
estimates, the Furnace rebate is not cost-effective with a Utility Cost Test ("UCT")3 ratio of 0.8.
The Whole Home and Tier I and Tier II rebates are also not cost-effective with UCT ratios of
0.53. These programs continue to comprise a majority of the Residential sector savings. With
updated values, the Residential sector is not cost-effective with a UCT ratio of 0.8. While the
Whole Home and Furnace measures are not cost-effective when considered with Billing Analysis
values, Staff believes that the Company has the ability to make necessary adjustments to achieve
cost-effective offerings. Staff believes that the Furnace measure will only need minor
adjustments to make the program cost-effective moving forward.
The Whole Home Tier I and II measures will need more significant changes to achieve a
cost-effective offering. Staff believes that the impact evaluation expected in the next prudence
filing will include information that may help the Company implement a cost-effective program.
In its next prudence filing, the Company should provide the completed evaluation, an overview
of each evaluation recommendation, detailed descriptions of the actions the Company will take
to address each item, and an explanation of how those changes will lead to the development of
cost-effective offerings for the Whole Home and Furnace rebate programs that reflect actual
therm savings. If the Company does not believe that it can maintain a cost-effective program, it
should consider sunsetting the Whole Home offering.
Evaluations
Whole Home and Furnace EM& V
In the previous prudence filing, the Commission directed the Company "to submit an
[Request for Proposal ("RFP")] for a third-party contract to conduct an impact evaluation with
Billing Analysis for the Whole Home and Furnace measures to be included in its 2023 prudency
filing." Order No. 35663 at 10. With this filing, the Company submitted a draft of its RFP for
review. Staff believes that by not issuing the RFP (and instead submitting the RFP as part of the
filing for review), the Company is not in compliance with the Commission's directive. However,
Staff does not recommend the Commission take action on this issue at this time. Staff believes 3 The UCT considers cost-effectiveness from the perspective of the utility. The UCT presents as a ratio of the benefits of avoided supply costs to costs incurred by the program administrator. Any ratio above 1 is cost-effective. STAFF COMMENTS FEBRUARY 22, 2024
that the Company delayed submitting the RFP in good faith to receive feedback from the
Commission. In discussions with the Company, Staff clarified the intent to have a study
completed by the time of this filing. The Company was amenable to this suggestion and issued
its RFP for the evaluation of the Whole Home and Furnace measures shortly afterwards. The
Company stated it believes that the evaluation will be completed in time to be included in the
next prudence filing and will be including the Smart Thermostat measure and 2023 program year
data in the evaluation. Because the Whole Home and Furnace measures provide the majority of
savings for the Company's residential sector, it is important that the Company have a completed
EM&V Impact evaluation before filing its next prudence evaluation. Staff recommends that the
Commission direct the Company to delay its next prudence filing until such time as it has a
completed EM&V impact evaluation as directed in Order No. 35663.
Evaluation Schedule
In the previous prudence filing, Case No. INT-G-22-03, Staff recommended that the
Company carefully consider EM& V impact evaluations for programs that do not have
participation rates sufficient to justify the cost of an evaluation. In the current filing, the
Company provided an evaluation schedule for each of its programs-which shows that the
Company has not made adjustments in response to Staff's recommendation. Specifically, the
Combination Boiler, Boiler, and Tankless Water Heater Tier II rebates continue to experience low
participation. Further, in its reply comments in Case No. INT-G-22-03, the Company "agree[ d]
with the Staff recommendation to postpone formal evaluation of the boiler, combination boiler
and water heating measures until there is enough participation to justify the cost of an impact
evaluation." Reply Comments at 9. Staff continues to recommend that the Company monitor the
participation of its programs and conduct EM& V impact evaluations when there is sufficient
participation to justify an evaluation.
IDL Evaluations
In its response to Production Request No. 8, the Company describes a conversation with
the University of Idaho Integrated Design Lab ("IDL"), exploring the potential of small-scale
EM&V studies. In its response to Production Request No. 29, the Company clarified that it is in
the early stages of discovery and is still exploring the potential of small-scale EM&Vs. Staff
sees the potential for incremental value to the Company but also has several concerns. Staff
STAFF COMMENTS 11 FEBRUARY 22, 2024
recommends that the Company continue to engage its EESC as more information becomes
available.
Market Transformation
In the "Securing an Energy Efficient Future" section of its 2022 Annual Report, the
Company describes several efforts to develop and implement energy efficient technologies,
specifically natural gas heat pumps ("GHP"). In its response to Production Request No. 15, the
Company clarified that of the three efforts described, North American Natural Gas Heat Pump
Collaborative ("Collaborative"), Gas Technology Institute Emerging Technology Program, and
the Energy Solutions Center, only the Collaborative is funded through the EE rider. The
Company describes that the Collaborative is most directly related to a traditional market
transformation effort; however, the Collaborative is different by preparing coordinated efforts to
develop GHP incentive programs before the product is introduced into the market. The
Company states that there are no commercially available residential GHPs ( only one distributor
of commercial GHPs that does not keep them in stock) and that there is no baseline adoption to
estimate until a product is available. Staff is concerned that without an existing product and
market baseline, the Company does not have a way to quantify impacts or benefits of a market
transformation effort. Staff recommends the Company co-develop criteria with the input of Staff
and other stakeholders that will demonstrate benefits to Idaho ratepayers for the Company's
market transformation efforts. This should include, but not be limited to, the ability to estimate a
market baseline for an available product and conduct research ( or gain access to credible
research) that shows a benefit to Idaho ratepayers through the market transformation efforts
affecting the baseline market.
Smart Thermostats
In 2022, the Company had a total of2,769 rebates for the residential Smart Thermostat
measure-an increase of 465% from the total rebates issued in 2021. The Company promoted
the Smart Thermostat measure through bill inserts, emails, brochures, the Company's website,
and social media. See Company's response to Production Request No. 12. Rebates for this
measure are limited to one per heating zone. Additionally, builders are able to "stack-on" Smart
Thermostat rebates to qualifying Whole Home rebates. The Company estimated a total of
121,836 annual therm savings from the Smart Thermostats installed.
STAFF COMMENTS 12 FEBRUARY 22, 2024
For the Smart Thermostat measure, the Company used the Estimated Useful Life ("EUL") of 11 years-which is from an Energy Efficiency Stakeholder Committee Agreement. However, the 2019 CPA conducted for the Smart Thermostat measure stated the EUL was 8 years,4 and the CPA referenced the Mid-Atlantic Technical Reference Manual that estimated an EUL of 7 .5 years. 5 Staff is concerned the Company may be overestimating the EUL of Smart Thermostats, which may overstate the utility benefits of this measure. Staff will review the EUL in the next EM& V study within the next EE prudency filing. Commercial Kits In its Annual Report, the Company describes a Commercial Energy Saving Kit ("CES Kits") offering that it ran in 2022 to increase awareness of its new commercial energy efficiency offerings. While the Company reports the CES Kits as cost-effective, Staff believes that the CES Kits did not succeed in increasing awareness of the commercial programs. In response to Production Request No. 19, the Company stated that it tracked recipients of the CES Kits and their participation in other Commercial EE offerings. The Company reports that only one customer that received a CES Kit went on to participate in another of the Company's offerings. Staff believes that CES Kits were not effective as a marketing strategy. Staff notes that commercial projects are often large scale and can have significant lead times. Staff recommends that the Company continue to monitor its Commercial programs for a delayed response but encourages the Company to explore alternative marketing strategies for its Commercial programs. STAFF RECOMMENDATIONS Based on its analysis of the Company's Application, supporting material, and discovery requests, Staff recommends the Commission issue an order: 1.Approving $2,657,836 of the Company's 2022 EE Program expenses as prudentlyincurred;2.Disallowing the recovery of $706,805 associated with the Company's Furnace, WholeHome Tier I and Whole Home Tier II programs;4 See Company's response to Production Request No. 26. 5 Mid-Atlantic Technical Reference Manual Version 8. https://regulations.delaware.gov/ Adm:inCode/title7/2000/Mid-Atlantic%20TRM%20May%202018.pdf (last visited February 5, 2024). STAFF COMMENTS 13 FEBRUARY 22, 2024
3.Directing the Company to develop a schedule for internal audits of its EE programs;
4.Directing the Company to delay its next prudence filing until such time as it can provide
a completed evaluation the Whole Horne and Furnace measures with additional details as
described above;
5.Directing the Company to monitor the participation of its programs and conduct EM&V
impact evaluations when there is sufficient participation to justify an evaluation;
6.Directing the Company to co-develop criteria-with the input of Staff and other
stakeholders-that will demonstrate benefits to Idaho ratepayers from the Company's
market transformation efforts.
Respectfully submitted this 22nd day of February 2024.
Technical Staff: Jason Talford
Kimberly Loskot
Laura Conilogue Matt Suess
I:\Utility\UMISC\COMMENTS\INT-G-23-06 Comrnents.docx
STAFF COMMENTS
Michael Duval Deputy Attorney General
14 FEBRUARY 22, 2024
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF FEBRUARY 2024, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-23-06, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER DIR-REGULATORY AFFAIRS INTERMOUNTAIN GAS CO PO BOX7608
BOISE ID 83707
E-MAIL: [e-mail]
ED JEWELL
DAPHNE HUANG DEPUTY CITY ATTORNEYS BOISE CITY ATTORNEY'S OFFICE PO BOX500
BOISE ID 83701-0500
E-MAIL: [e-mail]@ci tyo fboise.org [e-mail]
PRESTON N CARTER GIVENS PURSLEY LLP 601 W BANNOCK ST BOISE ID 83702 E-MAIL: [e-mail]@gi venspursley .com
WIL GEHL ENERGY PROGRAM MANAGER BOISE CITY DEPT OF PUBLIC WORKS PO BOX500
BOISE ID 82701-0500 E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE