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Home My WebLink About20211130Comments.pdf.:li: " !.-'\. ltu-l,1,..'iLilh*r, :ili rJ$'{ 30 Bil 3: tr? .:;,.'.l'i t.::.:-;- .'; .; :: .llll;:,iiS31Oi{ JAYME B. SULLIVAN BOISE CITY ATTORNEY Ed Jewell ISB No. 10446 Deputy City Attorney BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise,ID 83701-0500 Telephone: (208) 608-7950 Facsimile: (208) 3 84 -44 5 4 Email: eiewell@cityofboise.ore boca@citvofboise.ore Attomey for lntervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. INT-G-21-03IN THE MATTER OF INTERMOUNTAIN GAS COMPANY'S APPLICATION FOR DETERMINATION OF 2O2O ENERGY EFFICIENCY EXPENSES AS PRUDENTLY INCURRED CITY OF BOISE CITY'S COMMENTS The city of Boise City ("Boise City") submits these formal comments on the application submitted by Intermountain Gas Company ("Company") for a determination of 2020 energy efficiency program expenses as prudently incurred. Boise City submits these formal comments pursuant to Rule 203 of the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of Modified Procedure, Order No. 35143, issued by the Commission on August 20, 202r. 1. Boise City commends the Company on continuing to develop and implement new energy efficiency programs, particularly with the challenges faced during the COVID-I9 pandemic. Boise City recognizes the unique and important benefits that energy efliciency CITY OF BOTSE CITY'S COMMENTS - 1 delivers to all customers and supports the continuation of robust, accessible, and cost- effective energy efficiency measures. Boise City is encouraged by the Company's efforts to expand energy efficiency participation, resulting n a 36% increase in participation in 2020 compared to 2019. Application at 9. 2. Increased customer participation across the Company's rebate programs led to significant increased savings from the Company's simulation analysis compared to 2019. Additionally, both the simulation analysis and bill savings analysis show savings achieved in 2020 exceeded the estimated demand side management savings opportunity in the Company's Integrated Resource Plan. Boise City is concerned, however, about the significant discrepancy between the therm savings reported in the Company's simulation analysis and bill savings analysis. While the Company has implemented significant changes to the Whole Home rebate program in202l to improve cost-effectiveness, Boise City recommends the Commission continue to comprehensively evaluate the portfolio- wide and individual measure savings and provide the Company with clear direction on how to incorporate results from bill savings and simulation savings analyses going forward. 3. Boise City recommends the Company take a measured approach with its stated planned increase in program delivery expenses. See Application at 8. With the success of the Company's energy efficiency programs in2020, affracting their highest participation level since inception, Boise City recommends the Company continue the digital marketing and targeted customer outreach that was effective and less costly than more traditional forms of in-person outreach. Additionally, Boise City recommends the Company begin assigning specific direct program costs to individual rebate programs now that many of the rebates CITY OF BOISE CITY'S COMMENTS - 2 are more established to further facilitate evaluation of cost-effectiveness and targeted program outreach. 4. With the relatively low price of natural gas compared to other fuel costs, Boise City recommends the Company evaluate and present a targeted, behavioral energy efficiency program offering to its Energy Efficiency Savings Committee for implementation in2022. With the demonstrated success of programs like Idaho Power and Avista's Home Energy Reports, there appears to be a significant savings opportunity for the Company, without the traditional overhead expenses or customer costs associated with current equipment replacement rebates. 5. In addition to new program offerings, Boise City recommends the Company evaluate and incorporate a risk premium in the avoided cost model. A specific value reflecting the risks of price volatility and uncertainty in the future pricing of wholesale energy would more comprehensively value the role that only energy efficiency can deliver in reducing the Company's and customers' exposure to rapidly changing market conditions. In INT-G-21- 04, the Company's 2020 purchased gas cost adjustment case, the Commission approved the Company's application to update its rates to reflect the additional$24.2 million needed to cover the variable costs of purchased gas. Order No. 35182. Price volatility is a risk that should be more comprehensively valued in the Company's avoided cost methodology. The American Council for an Energy Efficient Economy report "Sustaining Utility Natural Gas Effrciency Programs [n a Time of Low Gas Prices" outlines different methodologies in use by natural gas utilities to accurately incorporate a risk premium. MeRrrN Kusulen & Perue WHrrE, AusRIceN ColrNcn- FoR AN ENencv ErRrctexr EcoNouy, SusrarNmc UTLITY NATURAL GAS EFFTCTENCY PROGRAMS rN A TrME OF LOW GAS PruCeS p. 19 available CITY OF BOISE CITY'S COMMENTS - 3 at https://www.aceee.ore/siteVdefaulVfiles/pdfs/sustainine utilitv_natural_eas_efficiency p rosrams.pdf (last visited November 29,2021). 6. Boise City recommends the Commission find the Company's 2020 energy efficiency expenses prudent and, as in Order No. 34980 regarding the Company's 2019 energy efficiency expenses, order the Company to continuously monitor, evaluate, and update its energy efliciency program incentives with the best available data. DATED this 30th day of Noverber 2021 P&*Ll EdJed6l) Deputy City Attorney CITY OF BOISE CITY'S COMMENTS - 4 CERTIFICATE OF SERYICE I hereby certiff that I have on this 30th day of November 2021, served the foregoing documents on all parties of counsel as follows: Jan Noriyuki Commission Secretary Idaho Public Utilities Commission I l33l W. Chinden Blvd., Bldg. No. 8, Suite 201-A PO Box 83720 Boise, lD 83720-0074 i an.norivuki@puc. idaho. eov Preston N. Carter Givens Pursley LLP 601 W. Bannock St. Boise,Idaho 83702 prestoncarter(E qivenspursl ev. com harmonywri eht@ sivenspursl ey. com Lori Blattner Director - Regulatory Affairs Intermountain Gas Company P.O. Box 7608 Boise, ID 83707 lori. blattner(@inteas. com Dayn Hardie Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. No. 8, Suite 201-A PO Box 83720 Boise, lD 83720-0074 Dayn.hardie(dpuc. idaho. eov tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: tr U.S. MailO Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: Michelle Steel Paralegal, City of Boise CITY OF BOISE CITY'S COMMENTS - 5