20240222Comments.pdf

CITY OF BOISE CITY’S COMMENTS - 1

JAYME B. SULLIVAN
BOISE CITY ATTORNEY

Ed Jewell ISB No. 10446
Daphne Huang ISB No. 8370
Deputy City Attorney
BOISE CITY ATTORNEY’S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorneys for Intervenor

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR A
DETERMINATION OF 2022 ENERGY
EFFICIENCY EXPENSES AS PRUDENTLY
INCURRED

Case No. INT-G-23-06

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 2022 energy
efficiency program expenses as prudently incurred. Boise City, 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. 36058, issued by the Commission on January 12, 2024, hereby submits its
formal written comments and states as follows:
SUMMARY
Boise City commends the Company on continuing to develop and implement new energy
efficiency programs and increasing program participation in its existing offerings. Boise City
RECEIVED
Thursday, February 22, 2024 11:00:57 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CITY OF BOISE CITY’S COMMENTS - 2

recognizes the unique and important benefits that energy efficiency 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 program
participation, resulting in a 43% increase in rebates to customers from 2021 to 2022. Application
at 10. Boise City specifically recognizes the Company’s efforts to reach commercial customers
through its energy savings kit pilot program and continued outreach to encourage additional
participation in commercial energy efficiency programs.
BILLING ANALYSIS & IMPACT OF NEW CONSTRUCTION PROJECTS
Boise City looks forward to reviewing the results of the third-party Evaluation,
Measurement and Verification (“EM&V”) study the Commission directed the Company to
complete in compliance with Order No. 35663. It is imperative that accurate savings information
and an evaluation of the modifications the Company made to its Whole Home rebate programs be
completed. While Boise City appreciates the Company’s progress on its EM&V RFP, Boise City
remains concerned that Company has not implemented a billing analysis for the Whole Home and
Furnace measures as directed by Order No. 35663. Accurate savings for the Whole Home and
Furnace measures are particularly critical in determining cost-effectiveness and appropriate
incentive levels as they account for more than 73% of the Company’s claimed residential savings
in 2022.
A comprehensive billing analysis is needed to evaluate the Company’s residential energy
efficiency measures at this time because of the significant impact the underlying assumptions may
have on determining the appropriate therm savings and incentive levels. In 2022, the Company’s
residential energy efficiency offerings are dominated by new construction projects. As reported in
the Company’s 2022 Annual Report, 50% of furnace rebates and 57% of Smart Thermostats were
CITY OF BOISE CITY’S COMMENTS - 3

claimed on new construction homes. Combining the proportion of new construction costs for
furnace rebates and smart thermostats with the Whole Home measures, more than 63% of all UCT
costs in the residential program are attributable to new construction with only 37% of costs
supporting increased energy efficiency in the Company’s existing residential customer base. While
higher natural gas efficiency, regardless of the source, benefits all customers, Boise City believes
the Commission should provide assurance that existing rate payer funds are not over-incentivizing
efficient appliance adoption in new construction. The Commission’s review of the Company’s
residential energy efficiency offerings should ensure rate payer funds are paying for cost-effective
energy efficiency programs that meaningfully impact new construction building practices.
Reasonable savings assumptions can vary and, at this time, without an accurate billing
analysis it is not clear that the savings assigned to Company’s furnace measure, as an example,
appropriately reflect the impact of significant new construction participation on the measure’s
delivered savings. As an example of the range of potential savings, the Northwest Power &
Conservation Council’s analysis of therm savings and baseline construction practices through its
Regional Technical Forum (“RTF”) differ significantly from the Company’s. The RTF’s
Residential Gas Furnace workbook identifies current baseline practice for gas furnaces in Idaho at
an average 90% AFUE gas furnace installation based on the 2019 Idaho Residential Energy Code
Field study conducted by Pacific Northwest National Laboratory. RTF Residential Gas Furnaces
Version 2.1 workbook available at https://nwcouncil.app.box.com/v/resesgasfurnance2-1 (last
visited February 2, 2024). In heating zone 3, the coldest RTF identified heating zone, the RTF
manual estimates a 90% AFUE rated furnace in a single-family home uses 624 therms per year
compared to a 95% AFUE rated furnace using 591 therms, an annual therm savings of 33. The
Company’s identified 87 therm savings for the same measure is significantly higher. Boise City
CITY OF BOISE CITY’S COMMENTS - 4

acknowledges Intermountain Gas considered many of these factors when revising its rebates
following the EM&V completed by ADM Associates, filed as Exhibit No. 5 INT-G-20-06. As
reported in the Company’s 2019 Annual Report, new construction projects, however, only
accounted for 17% of furnace rebates in 2019 and 7% of furnace rebates in 2018. The therm
savings analysis completed by ADM Associates on program year 2017-2018 and 2019 no longer
reasonably reflects the current program implemented by the Company.
To appropriately reflect the prevalence of new construction projects, Boise City
recommends that the Commission order the Company to revise its EM&V RFP to specifically
separate new construction from replacement, conversion, or early retirement 95% AFUE furnace
rebate in the evaluation. Boise City also recommends the Company be directed to comply with
Order No. 35663’s requirement to “use a billing analysis to evaluate program performance for the
Furnace and Whole Home measures” or justify “other empirical analysis as part of its annual DSM
prudency filing” no later than its 2023 DSM prudency filing. Additionally, if warranted based on
the results of the EM&V or other billing analysis, Boise City recommends the Company revise
rebate costs for the Whole Home and Furnace measures and seek Commission approval for mid-
year program changes, as it did in its 2019 energy efficiency prudency docket.
DEVELOPMENT OF NEW ENERGY EFFICIENCY OFFERINGS
Boise City continues to recommend the Company evaluate and present a targeted,
behavioral energy efficiency program offering to its Energy Efficiency Savings Committee for
future implementation. A behavior-change focused offering could lead to significant savings
without the traditional overhead expenses or customer costs associated with current equipment
replacement rebates. Boise City also looks forward to the Company’s continued evaluation of
CITY OF BOISE CITY’S COMMENTS - 5

weatherization kits or similar easy to install, low-cost measures that could increase customer
awareness of energy efficiency program offerings and deliver relatively low-cost savings.
CONCLUSION
Boise City appreciates the opportunity to provide comments to the Commission on the
Company’s energy efficiency program and continues to support the Company pursuing all cost-
effective increases to its demand side resources. Boise City commends the Company on its energy
efficiency education and outreach to customers and stakeholders, leading to increased program
participation in 2022. Boise City recommends:
1. The Commission direct the company to revise its EM&V RFP to analyze 95% AFUE
rebates paid to residential new construction projects separately from retrofits and
replacement projects.
2. The Commission reiterate its direction to the Company to use a billing analysis to evaluate
the Whole Home and furnace measures, presenting results to the Commission with its 2023
energy efficiency prudency filing.

DATED this day of February 2024.

______________________________
Daphne Huang
Deputy City Attorney

21st
CITY OF BOISE CITY’S COMMENTS - 6
CERTIFICATE OF SERVICE
I hereby certify that I have on this _____ day of February 2024, served the foregoing
documents on all parties of counsel as follows:
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
❑U.S. Mail
❑Personal Delivery
❑Facsimile
❑Electronic Means w/ Consent
❑Other: __________________
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
❑U.S. Mail
❑Personal Delivery
❑Facsimile
❑Electronic Means w/ Consent
❑Other: __________________
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
[e-mail]
[e-mail]
[e-mail]
❑U.S. Mail
❑Personal Delivery
❑Facsimile
❑Electronic Means w/ Consent
❑Other: __________________
Lori Blattner
Intermountain Gas
P.O. Box 7608
Boise, ID 83707
[e-mail]
❑U.S. Mail
❑Personal Delivery
❑Facsimile
❑Electronic Means w/ Consent
❑Other: __________________
________________________________
Michelle Steel
Paralegal, City of Boise
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22nd