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HomeMy WebLinkAbout20160916INT to Staff 1-24.pdfWILLIAMS · BRADBURY September 16, 2016 Jean D. Jewell Commission Secretary ATTORNEYS A T LAW Idaho Public Utilities Commission 472 W. Washington Street Boise, ID 83 702 RE: IGC Response to First Staff Request -Case No. INT-G-16-02 Dear Ms. Jewell: RE CEIVED 2016 SEP 16 PM I: 35 iU \": uLIC • IT L:~ (' 1M1SSION Enclosed for filing with the Commission are one original and two conformed copies of Intermountain Gas Company's Response to Staff's First Request for Production, and one CD­ ROM that contains the answers and attachments. By separate confidential CD, please find the responses to staff request No. 20. Please direct any questions related to the transmittal of this filing to Mike McGrath at 208- 377-6168. Sincerely, .. 11~ k)~ Ronald L. Williams Attorney at Law RLW 1015 W. Hays Street -Boise, ID 83702 Phone: 208-344-6633 -Fax: 208-344-0077 -www.williamsbradbury.com CERTIFICATE OF MAILING I HEREBY CERTIFY that on this l 6 day of September 2016, I caused to be served for Case No. INT-G-16-02 a true and correct copy of the Respo?s~ ofldaho Intermountain Gas Company to First Production Request of the Comm1ss1on Staff upon the following individuals in the manner indicated below: Northwest Industrial Gas Users c/o Edward A. Finklea Executive Director 545 Grandview Drive Ashland, OR 97520 Phone: (541) 708-6338 Facsimile: (541) 708-6339 efinklea@nwigu.org Chad M. Stokes Tommy A. Brooks Cable Huston LLP 1001 SW Fifth Ave., Suite 2000 Portland, OR 97204-1136 Telephone: (503) 224-3092 Facsimile: (503) 224-3176 cstokes@cablehuston.com tbrooks@cablehuston.com Michael C. Creamer {ISB No.4030) Givens Pursley LLP 601 W. Bannock St. Boise, ID 83 702 Telephone: (208)-388-1200 Facsimile: (208) -388-1 300 mcc@givenspursley.com Karl Klien Deputy Attorneys General Idaho Public Utilities Commission 472 W. Washington Street Boise, ID 83 702 Telephone: (208) 334-0320 Karl.Klein@puc.idaho.gov D Hand Delivery [ll US Mail (postage prepaid) D Facsimile Transmission D Federal Express D Electronic Transmission 0 Hand Delivery ~ US Mail (postage prepaid) D Facsimile Transmission D Federal Express D Electronic Transmission D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission D Federal Express @ Electronic Transmission G!('Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission D Federal Express D Electronic Transmission Ronald L. Williams Attorney for Intermountain Gas Company Ronald L. Williams, ISB No. 3034 Williams Bradbury, P.C. 1015 W. Hays St. Boise, ID 83702 Telephone: (208) 344-6633 Email: ron@williamsbradbury.com Attorneys for Intermountain Gas Company REC EIVED 2016 ~:EP 16 PM I: 34 BEFORE THE IDAHO PUBLIC UTILITES COMMISSION IN THE MATTER OF INTERMOUNTAIN GAS ) COMPANY'S APPLICATION TO CHANGE ) ITS RA TES AND CHARGES FOR NATURAL ) GAS SERVICE ) ) ) _________________ ) Case No. INT-G-16-02 RESPONSE OF IDAHO INTERMOUNT AIN GAS COMP ANY TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF COMES NOW, Intermountain Gas Company, and in response to the First Production Request of the Commission Staff to Intermountain Gas Company dated August 26, 2016, herewith submits the following information: REQUEST NO. 1: Please provide the Company's previous Cost Allocation Manuals from 2010 through the effective date of the 2016 Cost Allocation Manual. RESPONSE TO REQUEST NO. 1: The copy provided to the !PUC as Exhibit JO is lntermountain Gas Company's sole version of the Cost Allocation Manual. There are no manuals that predate that document. Record Holder: Michael McGrath, 208-3 77-6168 Sponsor/Preparer: Ted Dedden. 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 2: Please provide all contracts, agreements and other related and underlying documents that establish the services provided and received, and the costs charged and paid between the affiliated companies for 2010 through 2016 to date. RESPONSE OF JGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page I RESPONSE TO REQUEST NO. 2: PENDING; Extended through 9/23/16 Record Holder: ---=-M=i=c=ha=e"'"I =M=c'-"G=r=at=h"--, 2=-0"'-'8"--3=-7a...a7'----=-6 .::..;16=-=8'--­ Sponsor/Preparer: --------------- Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 3: Please provide copies of any internal or external reviews and reports associated with the allocation of costs between Interrnountain Gas and any affiliated Companies. Please include within your response any reviews, reports and other documents performed or created by or for any other regulatory commissions. RESPONSE TO REQUEST NO. 3: Intercompany allocations receive managerial review on a monthly basis but there has been no formal review of intercompany charges by internal or external auditors. Oregon has performed a review of intercompany charges and proposed adjustments to the Cascade Natural Gas Corporation general rate case filing Docket No. UG 305. Cascade management has responded with additional testimony supporting the charges and methodology used in the allocations. This case is still active and in the process of settlement. Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden. 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 4: Please provide the Administrative and General (A&G) cost study referenced by Witness Madison's Direct Testimony, page 3, line 10. RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 2 RESPONSE TO REQUEST NO. 4: Please see detailed response attached on the CD-File Name PR#4 Record Holder: Michael McGrath, 208-377-6168 --~~~~~~~~~~~~---- Sponsor/Preparer: Concentric Energy Advisors ;508-263-6230 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 5: Please provide spreadsheets, workpapers and any other underlying source information and documentation demonstrating that working capital will be provided by the Company, and not by its customers (through the payment of the new rates to maintain plant, expenses and the like). RESPONSE TO REQUEST NO. 5: Cash working capital (CWC) is the amount of funds required to finance the day-to-day operations of the Company. A CWC requirement represents the amount of cash the Company needs to keep on hand to meet its cash operating expenses. Exhibit 13, page 5 presents the CWC requirement for Intermountain Gas Company employing the Gross Lag methodology. Employing the Gross Lag methodology, the revenue lag was divided by 365 days to arrive at a CWC factor for revenues. That factor was then multiplied by the Company's adjusted revenues. The revenues are adjusted to remove all non-cash items and other revenues which were not available to pay cash expenses. Such offsets included depreciation, return on equity, and uncollectibles. Expense leads were also divided by 365 days to arrive at the CWC factor associated with each expense classification. The factor was multiplied by the appropriate RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 3 expense level. The revenue and expense cash working capital requirements were then summed to determine the overall CWC requirements for the Company. It was important that there be symmetry between the level of cash operating revenues and cash operating expenses reflected under the Gross Lag methodology. The sole purpose of the CWC analysis was to analyze the timing of cash receipts and cash outflows. To get an accurate determination of the Company's CWC requirements, the level of revenues considered in the CWC analysis should be sufficient to reflect the payment of all cash operating expenses. If there was an imbalance between the level of operating revenues and expenses, there would be an artificial imbalance in the resulting level of CWC requirement. The CWC determination was intertwined with lead-lag studies to analyze the lag time between the date customers receive service and the date that customers' payments were available to the Company. This lag was offset by a lead time during which the Company received goods and services, but paid for them at a later date. The "lead" and "lag" were both measured in days. The dollar-weighted lead and lag days were then divided by 365 to determine a daily CWC factor. The CWC factor was then multiplied by the annual test year cash revenues and expenses to determine the amount of CWC required for operations. Concentric performed the lead-lag study by analyzing Intermountain Gas Company's cash transactions and invoices for the twelve months ended December 31, 2015. The developed leads and lags were applied to the test year expense levels as presented in Exhibit 13, page 5. Two broad categories of leads and lags were considered: 1) lags associated with the collection of revenues owed to the Company (revenue lags); and 2) lead times associated with the payments for goods and services received by the Company (expense leads). The revenue lag refers to the elapsed time between the delivery of the Company's product (i.e., gas) and its ability to use RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 4 the funds received as payment for the delivery of the product. The expense lead refers to the elapsed time from when a good or service is provided to the Company to the point in time when the Company paid for the good or service and the funds were no longer available to the Company. The revenues included in the CWC analysis were those that were generated.from regulated rates. Employing the Gross Lag methodology, the revenues were adjusted to eliminate non-cash items. The resulting figure represents the revenues that were available to pay cash operating expenses. Therefore, the expenses included in the CWC analysis reflect only those cash expenses which were paid from the cash operating revenues. The revenue lag and expense leads reflect actual elapsed timing of cash flows during the twelve months ended December 31, 2015. The revenue lag and expense leads were applied to test year revenues and expenses. As calculated in Exhibit 13, page 5 the requested level of CWC included in rate base for Intermountain Gas Company is $1,032,688. The calculation demonstrates that the working capital is being provided by the Company as the cash working capital requirement related to revenues ($29,281,376) exceeds the cash working capital requirement related to expenses ($28,248,688). Thus, the Company is meeting their obligations prior to receiving payment from customers. A copy of the study is included as a response to AR#6. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Concentric Energy Advisors ; 508-263-6230 Location: 555 S Cole Rd. Boise. ID 83707 RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 5 REQUEST NO. 6: Please provide the lead/lag study determining the days of lead/lag for revenue and expense accounts. Reference: Exhibit No. 13, page 5 of 7. RESPONSE TO REQUEST NO. 6: Please see detailed response attached on the CD-File Name PR#6 Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Concentric Energy Advisors ;508-263-6230 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 7: Please provide a schedule showing all employee classifications, standard occupational codes (if known), number of employees in each classification, and the dollar amount of salaries from 2012 through each month of 2016 as it becomes available for each classification. Please break out the salary by basic wages, overtime, bonus wages, and other expenses (such as on-call pay etc.). RESPONSE TO REQUEST NO. 7: Please see detailed response for all JGC employees attached on the CD-File Name P R#7 Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Craig Pulley. 208-377-6163 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 8: Please provide a job description for each employee classification mentioned in your response to the previous production request. RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 6 RESPONSE TO REQUEST NO. 8: Please see detailed response for all JGC job classifications attached on the CD-File Name P R#8 Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Craig Pulley. 208-377-6163 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 9: Please provide a schedule of the Company's "Property Held for Future Use" through 2016. Please consider this an ongoing request and provide updates to this schedule whenever actuals are updated. Please provide worksheets in Excel format with formulas intact. RESPONSE TO REQUEST NO. 9: There is no property listed as "Property Held for Future Use" on Intermountain Gas Company's books. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden. 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 10: Please provide a detailed schedule of the "Advances in Aid of Construction" received by the Company from 2010 through 2016 as available. Please include within your response the names, dates, amounts and accounts posted. Please consider this a continuing request and provide updates to this schedule at the same time actuals are updated. Please provide worksheets in Excel format with formulas intact. RESPONSE TO REQUEST NO. 10: Please see detailed advances schedule attached on the CD-File Name PR#IO. JGC went live with the JD Edwards ERP system in May of 20 I 0. General ledger detail was retained in the RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 7 prior software until that date and converted over the course of several months in lump sum journal entries (January 2010 -April 2010 attached). Detail for specific customers is not available in JDEfor the system conversion period. Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden; 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 11: Please provide a schedule of "Prepaid Items" showing dollar amounts and account numbers where posted, vendors, and related explanations (including allocated amounts) for 2015 and 2016 to date. Please consider this a continuing request and provide updates to this schedule at the same time actuals are updated. RESPONSE TO REQUEST NO. 11: Summary-See details in attachment available on CD-File Name PR#] 1: Vendor Explanation Account Pitney Bowes Postage 1659.17014 IPUC IPUC Fee 1659.17013 Marsh Insurance 1655 AEGIS Insurance 1655 EIM Insurance 1655 Helmsman Insurance 1655 ND Insurance Dept Insurance 1655 balance as of Dec-15 Jul-16 1655 $ 160,431.21 $ 306,918.44 1659.17013 $768,887.38 $ 160,291.41 1659.17014 $ 214,048.91 $96,313.26 Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden; 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 8 REQUEST NO. 12: Please describe the method by which the Company recorded and allocated materials and supplies to its accounting records in 2015 and 2016 to date. Please include within your response the method to record and update the "Materials and Supplies Inventory," as well as expensing and other transactions related to materials and supplies. RESPONSE TO REQUEST NO. 12: Jntermountain Gas Company assigns individual material codes to the majority of inventory. The inventory is recorded in FERC account 154. JGC uses the weighted average cost method to value its inventory. The weighted average cost is recalculated by JD Edwards (JGC 's ERP system) as items are received or issued/returned to and.from inventory at each warehouse. The inventory is either expensed or applied to a capital project at the time it's issued.from the warehouse based on the type of work involved. Jntermountain Gas Company records other inventory expense in FERC account 163. Expenses typically consist of unidentified freight, invoice price variance, inventory adjustments, and small non-coded items. Costs captured in the 163 account are distributed to CWJP and O&M through two separate processes via Materials Overhead. For capital projects the overhead is applied to CWJP inventory issues monthly through our Fixed Asset Accounting System, Power Plan. For operating projects Materials Overhead is applied to O&M inventory issues quarterly based on warehouse issues, per JD Edwards. The loading rate is evaluated on a quarterly basis. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 9 REQUEST NO. 13: Please provide a copy of all adjusting entries for the December 31, 2015 general ledger and the related explanation for each entry. RESPONSE TO REQUEST NO. 13: Summary below-See details in attachment available on CD-File Name PR#J3: Please see the 11st below for the December 2015 adjusting Journal entries. The support and desaiptlon are provided In the attached PDF's and are named according to the "Batch Number.• User ID Document Doaanent Doaanent G/L Date PN Explanation Ledger 1yJ Reverse o Batch Typo Batch Number r 12/14/2015 SHELTONR JE 13560 00048 12 Reclass post-ret. act to payab AA G 1349115 r 12/31/2015 12 JE 12-20 Depreciation AdJust GYLLENSN JE 1358100048 AA G 1349960 GYU.ENSN JE r 13607 00048 12/31/2015 12 48Jel2-99 Conversion entry AA 1352899 GYU£NSN JE 13759 «!048 12/31/20]5 12 JE 12-68 Misc Adjustments AA G 13SSS71 GYU£NSN JE 13760 «!048 12/31/20]5 12 JE 12-20 Misc Plant Adjustment AA G U55S78 GYLLENSN JE 13769 r00048 12/31/20]5 12 JE 12-20 #2 Misc Plant Adj AA G 1355782 DEDDENT JE 13775 «!048 12/31/20l5 12 12-15 ARO Establishment AA G 1356010 r 12/31/2015 12 JE 12-20 Manual overheads Adj AA GYUENSN JE 13793 00048 G 1356196 Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 14: Please provide a copy of all closing entries for the December 31 , 2015 general ledger and the related explanation for each entry. RESPONSE TO REQUEST NO. 14: Per 8/26/2016 teleconference with Ms. Patricia Harms, request should focus on extraordinary or significant acijusting entries. There were no qualifying extraordinary or significant adjusting entries for the December 2015 general ledger. Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 10 REQUEST NO. 15: Please indicate ifthere have been any FERC investigations since 2011. If so, please provide a list with dates, descriptions and outcomes. RESPONSE TO REQUEST NO. 15: Intermountain Gas Co. has not been the subject of any FERC investigations since 2011. Record Holder: Michael McGrath, 208-377-6168 Sponsor: Ted Dedden; 208-377-6149 Location: 555 S Cole Rd. Boise, ID 83707 REQUEST NO. 16: Please provide a list of legal work and cases from 2012 to date including within the response the date(s), status including descriptions, estimates of liability, and possible ramifications to any of the Company's operations. Please also include within your response the cost of the legal work by issue. RESPONSE TO REQUEST NO. 16: PENDING; Extended through 9/23/16 Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Scott Madison; 208-377-6105 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 17: Please provide all reports and letters prepared by the Company's Internal Audit staff that document areas reviewed by them from December l, 2015 to date. RESPONSE TO REQUEST NO. 17: See page 12 RESPONSE OF JGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 11 RESPONSE TO REQUEST NO. 17: Tim! Period Objective Resp O nsib ility Conclusion Follow-U Audit Team Distribution B MDU RESOURCES GRIJIIP Kl December II 2015 lntennoun'lain Gas Co To ensure select key intemal controls relevant to IGC are properly designed and operating effective! to acbi eve the c ' s objective ofreliable financial r · TedDedden Nicole Gyllenskog Niki O . Intema1 Auditing conducted intcmal control testing and walkthroughs on the following processes and concluded that IGC' s controls appear to be properly designed and op crating effectively to achieve the company's objective o freliable financial reporting. No deficiencies were identified. Nmueror Coadailtn Process C.JdnJI Tested PUii Revenue Cycle 7 7 0 Unbilled Revenue Cycle 3 3 0 Extieme Repcxv 1 1 0 To'lal 11 11 0 Sheri B erogan, Manager-(701) 530-1083 Donna Vincent, Intema1 Auditor -(701) 530-1754 Lisa Grabar Lead Internal Auditor -701 530-10 27 Dave Goodin-MDU Resources Dorms chwartz -MDU Resotrces Nathan Ring-MDU Resources Selly Iverson-MDU Resources Rebecca D orwart-MDU Resources Nicole Kivisto -MDU Utilities Group Scott Matison -Imermountain Ou Marlc Chiles -Inleml ountain Ou OmretSenger -Montana-Dakota Utilities Kellie Erhardt-Montana-Dakota Utilities Deloitte & Touche CONFIDENTIAL-FOR INTERNAL USE ONLY These materials are confidential and are designated for inllrnal use ono/. Do not dlstrzbutl without the prior writtln consent of the MDUR Ilre cto r of Intimal Audui/1€. RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 12 Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd. Boise, ID 83707 REQUEST NO. 18: Please provide the Internal Audit schedule of planned audit reviews for 2016 and 2017. Please include within your response a description of each planned audit review and the underlying reason for each one. RESPONSE TO REQUEST NO. 18: Please see response file name PR#18 included within the attached CD. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden. 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 19: Please provide a copy of the 2015 shareholder annual report and proxy statement. RESPONSE TO REQUEST NO. 19: Please see response file name PR# 19 included within the attached CD. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 REQUEST NO. 20: Please provide all Audit Committee meeting minutes for the Company and its affiliates for 2015 and 2016 to date. RESPONSE TO REQUEST NO. 20: Responses to this request involve confidential and proprietary information of Intermountain and are contained on a separate CD identified as such. RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 13 Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd. Boise, ID 83707 REQUEST NO. 21: Please provide copies of any accounting adjustments proposed and recorded during the external audit process during the 2015 audit. Please include within your response the reasoning for the adjustments, the dates, amounts, and accounts posted. RESPONSE TO REQUEST NO. 21: There were no accounting acijustments proposed and recorded during the external audit process during the 2015 audit. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 22: Please provide copies of any accounting issues identified during the 2015 external audit process but that were "passed on" and either not proposed as an adjustment or proposed but not recorded. Please explain why each adjustment or issue was "passed on." RESPONSE TO REQUEST NO. 22: There were no accounting issues identified during the 2015 external audit process that were "passed on" and either not proposed as an acijustment or proposed but not recorded. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden: 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 23: Please provide a schedule with details for all advertising expenses included within the Company's filing. Please include within your response the dates, vendors, RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 14 explanations, amounts posted, copies of the related advertising, and associated customer benefit. Please provide worksheets in Excel format with formulas intact. RESPONSE TO REQUEST NO. 23: Please see worksheets and PDF documents file name PR#23 included within the attached CD listing detailed advertising expenses included within Intermountain Gas Co. 's filing. Note column "V" describes the customer benefit; and column "S" titled ''Attachment Reference" indicates the scanned image title. Record Holder: Michael McGrath. 208-377-6168 Sponsor/Preparer: Ted Dedden. 208-377-6149 Location: 555 S Cole Rd. Boise. ID 83707 REQUEST NO. 24: Please provide a schedule that identifies the components of "Miscellaneous Intangible Plant" that, as of December 31, 2015, had a balance of $38.8 million according to the Company's FERC Form No. 2-Annual Report. Approximately $33 million was added to the balance of "Miscellaneous Intangible Plant" during Calendar Year 2015. Please include within your response the dates, vendors, work order numbers, dollar amounts, underlying nature of each amount posted, and documentation supporting those amounts (such as invoices, contracts and other detail supporting the transactions, including the methodology for determining intangibles and all its inputs if any of the amounts are an allocation). RESPONSE TO REQUEST NO. 24: Please see worksheets included within the attached CD referring to file name P R#24, for Account 303, Miscellaneous Intangible Plant at December 31, 2015 reflecting each asset's balance, dollar amount and associated capital work order number. Assets prior to 2011 were converted from our legacy system and do not have an associated work order number. Please see RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 15 worksheet titled "CC&B at 12-31-2015"(Customer Care and Billing) which supports the $26,377,554.16 capitalized costs as of August 2015. This project started in 2009 as a Utility Group Project between Montana Dakota Utility, Cascade Natural Gas Corp. and Intermountain Gas Company. Principal costs were allocated to JGC from MDU using a weighted meter count formula between all utilities, IGC's proportional rate was 30. 7%. CC&B costs incurred prior to June 2013 were converted in summary from our legacy financial system to our current ERP JD Edwards financial system. Record Holder: Michael McGrath, 208-377-6168 Sponsor/Preparer: Ted Dedden; 208-377-6149 Location: 555 S Cole Rd, Boise, ID 83707 DATED at Boise, Idaho, this I~ day of S rp~'' 'o ,-r , 2016. Respectfully submitted, flA )l.v~ Ronald L. Williams Williams Bradbury, P.C. Attorneys for Intermountain Gas Company RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF, Page 16