20250214INT to Staff 1-7.pdf

RECEIVED
Friday, February 14, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
[phone]
[e-mail]
[e-mail]
18791099.1 [14168.18]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. INT-G-24-05
OF INTERMOUNTAIN GAS COMPANY
FOR A DETERMINATION OF 2023 INTERMOUNTAIN GAS COMPANY'S
ENERGY EFFICIENCY EXPENSES AS RESPONSE TO THE FIRST PRODUCTION
PRUDENTLY INCURRED AND REQUEST OF COMMISSION STAFF
APPROVAL OF RATE SCHEDULE EE-RS
In response to the First Production Request of the Commission Staff to Intermountain Gas
Company("Intermountain Gas" or"Company") dated January 24, 2025, Intermountain Gas
submits the following responses. Confidential responses and documents are subject to the
protective agreement in this case, and are available for download using a password-protected link
that will be provided separately by email. The password will be provided in a separate email.
Dated: February 14, 2025.
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Intermountain Gas Company
RESPONSES TO STAFF's FIRST PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I hereby certify that on February 14, 2025, I caused to be served a true and correct copy of
the foregoing document to the person(s) listed below by the method indicated:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
monica.barriossanchez&puc.idaho.gov
Is/Preston N. Carter
Preston N. Carter
RESPONSES TO STAFF'S FIRST PRODUCTION REQUEST PAGE 2 OF 2

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. I
CONFIDENTIAL RESPONSE AND ATTACHMENT PROVIDED
UNDER SEPARATE COVER

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Lori Blattner
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.
RESPONSE NO. 2:
There were no internal audits of the Intermountain Gas Company("Intermountain" or
"Company") energy efficiency expenses or processes in 2023 or 2024. Immediately after
receiving Order No 36245 that required the Company to "develop and follow a schedule for
regular internal audits,"the Energy Efficiency team worked with the Internal Audit team to have
Intermountain's Energy Efficiency program added to the MDU Resources Group internal audit
schedule. At a meeting held on February 12, 2025, the MDUR Audit Committee approved the
2025 Internal Auditing Plan which includes an audit of the Intermountain Energy Efficiency
Program.
INT-G-24-05
IPUC Staff PR 2
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. 3
CONFIDENTIAL RESPONSE AND ATTACHMENTS PROVIDED
UNDER SEPARATE COVER

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Lori Blattner
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.
RESPONSE NO. 4:
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 is provided in file "INT-G_24_05 PR 4 Monthly FTE."
Job descriptions were updated that included changes in job titles. The title of Conservation
Analyst was updated to Energy Efficiency Analyst. Conservation Support Specialist was updated
to Energy Efficiency Program Specialist. All job descriptions are provided in the Response No. 3.
INT-G-24-05
IPUC Staff PR 4
Page 1 of I

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. 5
CONFIDENTIAL RESPONSE AND ATTACHMENTS PROVIDED
UNDER SEPARATE COVER

INTERMOUNTAIN GAS COMPANY
CASE INT-G-24-05
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kathy Wold/Lori Blattner
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.
RESPONSE NO. 6:
No expenses for rebate app maintenance or operations expenses will be booked to the
rider account. Work on the rebate app is being done using internal resources which are included
in the Company's base rates.
INT-G-24-05
IPUC Staff PR 6
Page 1 of 1

INTERMOUNTAIN GAS COMPANY
CASE No. INT-24-05
RESPONSE TO PRODUCTION REQUEST NO. 7
CONFIDENTIAL RESPONSE AND ATTACHMENT PROVIDED
UNDER SEPARATE COVER

GIVENS PURSLEYLLP
Attorneys and Counselors at Law
601 W.Bannock Street
PO Box 2720
Boise,ID 83701
Main:208-388-1200
www.givenspursley.com
Preston N.Carter
Direct:208-388-1222
[e-mail]
February 14, 2025
Via Email ([e-mail])
Monica Barrios-Sanchez
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
Re: Intermountain Gas Company Case No. INT-G-24-05
Dear Ms. Barrios-Sanchez:
On behalf of Intermountain Gas Company (Intermountain Gas), enclosed for filing are
confidential responses to the First Production Request of Commission Staff.
Pursuant to Idaho PUC Rules of Procedure, IDAPA31.01.01.067, 31.01.01.233, and
31.02.01.005.07 and the protective order signed by the parties in this proceeding, the enclosed
information is confidential,proprietary and trade secret information of Intermountain Gas and is
protected by law from public inspection, examination or copying,pursuant to Idaho Code
Sections 74-106, 107, and 48-801 et seq. Intermountain Gas therefore requests that the enclosed
information be protected from inspection, examination or copying by any person other than the
Commissioners and PUC Staff. The confidential information covered by this letter is available
for download from sharefile link provided in the accompanying email.
Please let me know if you have questions or would like to discuss
Sincerely, �I
Preston N. Carter
cc: Lori Blattner, Intermountain Gas
Jacob Darrington, Intermountain Gas