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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF INTERMOUNTAIN GAS COMPANY FOR )
AUTORITY TO INCREASE ITS RATES )
AND CHAGES FOR NATURL GAS SERVICE)
IN THE STATE OF IDAHO .............)
)
CASE NO. U-1034-88
REQUEST FOR PRODUCTION
OF DOCUMENTS & INFORMTION
COMES NOW the Staff of the Idaho Public Utilities Com-
mission by and through its attorney of record, Mary Ann Johnson,
Deputy Attorney General, and requests that Intermountain Gas
Company furnish the following docuients and data on or before
July 3,1980:
(1) Provide Intermountain Gas Company's proposed
utili ty construction expenditure budget for each of the following
years: 1980, 1981 and 1982.
(2) Provide Intermountain Gas Company iS capi tal con -
struction expenditure for 1978 and 1979.
(3) Provide the monthly balances of short- term borrow-
ing for the test year and for the 12-month prior to the test
year.
(4) Using a calculation comparable to that used in
Company Exhibit No. 102, Schedule 6, page 3, provide the effec-
tive interest cost for each period on the short-term borrowings
referred to above.
(5) What are the Company's specific external financing
proposals for each of the following years: 1980, 1981 and 1982?
Insofar as the financing for utility purposes might differ from
total corporate purposes, indicate the differences.
( 6) In regard to Company Exhibit No .102, Schedule 5,
how is the calculation for reverse flow-through depre~iation made
($500,000) ?
(7) In regard to page 12 of Mr. Worthan' s testimony,
has. the Company forecasted wage and salary increases beyond
June 30, 1980 and included these in the expenses for the adjusted
test year? Are other expenses forecasted beyond June 30, 1980
and included in the adjusted test year?
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(8) What is the appropriate net to gross multiplier
for tax purposes for the utility operations?
(9) What proportion (if any) of the additional income
taxes can be deferred through any inter-period tax allocation?
(The additional taxes would be due to any additional rate increase.)
DATED at Boise, Idaho, thisolD-tay of June, 1980.
1IC
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this~day of June,
1980, served the foregoing document upon all parties of record in
this proceeding by mailing a copy thereof, properly addressed
with postage prepaid, to the following:
Walter H. Smith, Acting President
In termoun tain Gas Company
P.O. Box 7608
Boise, ID 83705
Eugene C. Thomas, Esq.
T. N. Ambrose, Esq.
Moffatt, Thomas, Barrett
& Blanton, Chartered
P.O. Box 829
Boise, ID 83701
Gary Greer
Plant Manager
Beker Indus tries Corp.
P.O. Box 37
Conda, ID 83230
Larry D. Ripley, Esq.
Dan L. Poole, Esq.
Elam, Burke, Jeppesen, Evans & Boyd
P.O. Box 1559
R. Michael Southcombe, Esq.
Clemons, Cosho & Humphrey
1110 Bank of Idaho Bldg.
Boise, ID 83702
James N. Roethe, Esq.
Pillsbury, Madison & Sutro225 Bush St.
San Francisco, CA 94104
N. Randy Smith, Esq.
J. R. Simplot Company
P.O. Box 27
Boise, ID 83707
Melvin D. Alsager
J. R. Simplot Company
P.O. Box 27
Boise, ID 83707
D~w~Oh