20250124Staff 1-7 to INT.pdf

RECEIVED
Friday, January 24, 2025 2:28:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )
GAS COMPANY'S APPLICATION FOR ) CASE NO. INT-G-24-05
DETERMINATION OF 2023 ENERGY )
EFFICIENCY EXPENSES AS PRUDENTLY )
INCURRED ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Intermountain Gas Company("Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, FEBRUARY 14, 2025.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 JANUARY 24, 2025

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide a list of all expenses charged to the energy efficiency
tariff rider during 2023. Please include date, vendor, amount, a brief description of the expense,
and the account to which the expenses were booked. Please separate all expenses by program so
that the expenditures provided reconcile with the amounts listed in the Company's Annual
Report. Please also identify whether each expense is an incentive payment, purchased service,
labor/administrative, materials and equipment, or other expense. Please provide the requested
information in Excel format with all formulas intact and enabled.
REQUEST NO. 2: Please provide copies of all internal audit reports referencing any of
the Company's energy efficiency expenses and processes for January 1, 2023 through present. If
no reports were issued,please provide the date and scope of each audit and all internal auditor
workpapers.
REQUEST NO. 3: Please provide a current organizational chart showing all MDU,
Intermountain Gas, and contract employees, identifying each by title and name, who charge time
to the energy efficiency tariff rider.
a. Please include complete job descriptions, required qualifications, salary ranges,bonus
opportunities, and total compensation ranges, including benefits, for all employees
identified in this request.
REQUEST NO. 4: Please provide a timeline of the Company's Full Time Equivalent
("FTE")positions for January 1, 2020 through present, showing a month-by-month comparison
of FTEs that charge time to the energy efficiency tariff rider. Please indicate by employee which
program (residential, commercial, or both)the individual charges their time to.
REQUEST NO. 5: Please provide monthly balances for the energy efficiency tariff rider
balance from January 2023 through June 2024. Please include monthly revenues, expenses, and
any interest calculations. Please include a forecast of the rider balance for the next two years.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 JANUARY 24, 2025

REQUEST NO. 6: Please provide estimated capital and operations and maintenance
costs for the internal rebate processing software application, as mentioned on page 8 of the
Application for the next five years. Please provide supporting workpapers. Additionally, please
explain if these expenses will be booked to the rider account.
REQUEST NO. 7: Please provide the cost-effectiveness workpapers and calculations for
each energy efficiency program in 2023 in Excel format, with all formulas intact and enabled.
a. For each measure,please list the unit therm savings, the source of unit therm savings,
and the number of rebates.
DATED at Boise, Idaho, this 24th day of January 2025.
ayn rdie
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\INT-G-24-05 PR#1.docx
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 JANUARY 24, 2025

CERTIFICATE OF SERVICE
`fA
4
I HEREBY CERTIFY THAT I HAVE THIS� I DAY OF JANUARY 2025,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE NO. INT-G-24-05, BY E-
MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR—REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL: prestoncarter givenspursley.com
E-MAIL: lori.blattnergint ag s.com morgangoodinkgivenspursley.com
igcregulatorygint ag s.com stephaniewk i�pursley.com
4 ATRICIA JO N, SECRETARY
CERTIFICATE OF SERVICE