20160928Staff 65-102 to INT.pdf

KARL T. KLEIN
SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]/334-0312
IDAHO BAR NOS. 5156/8743
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
R...:C::IVED
2: 51
BEFORE THE IDAHO PUBLIC UTILITIES 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
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission requests that Intermountain Gas
Company (Intermountain Gas; Company) provide the following documents and information as soon
as possible, and no later than WEDNESDAY, OCTOBER 19, 2016.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 1 SEPTEMBER 28, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 65: For each retirement plan available to employees and officers of
Intermountain Gas, please provide:
a) The Summary Plan Description;
b) Amounts included for recovery in the current rate case;
c) All reports provided by third party administrators and/or actuaries for 2014-2016;
d) How 2015 expenses were booked.
REQUEST NO. 66: Please provide copies of all salary and benefit studies performed for
Intermountain Gas/MDU for the years 2012-2016.
REQUEST NO. 67: Please summarize all of the Company's environmental cleanup costs
during 2015. Please show all account numbers and the amount booked to each sub account.
REQUEST NO. 68: Please provide copies of all employee newsletters issued since 2014.
REQUEST NO. 69: Please list all cost-cutting measures undertaken by the Company
during 2014-2016, explain those measures in detail, and quantify the results of those measures.
REQUEST NO. 70: Please provide all expense reports for management personnel for 2015
to 2016 to date. Please show how all expenses were booked.
REQUEST NO. 71: Please provide the amounts the Company spent for injuries and
damages for the years 2010-2016 to date. Please include within your response the description of
each item, the amount for each item, and the account charged.
REQUEST NO. 72: Please provide detail of all advertising expenses recorded above the
line including account and subaccounts where posted, dates posted, vendor names, explanations,
and amounts·posted during 2015 and 2016 to date.
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 2 SEPTEMBER 28, 2016
REQUEST NO. 73: Please provide copies of the ads used during 2015 and 2016 and
correlate the ad copy with the specific detail provided in the Company's response to Request
No. 72.
REQUEST NO. 74: Please provide copies of all billing inserts for 2015 . Please also
provide a schedule showing the amount and account numbers charges for all costs to produce, print,
and distribute inserts.
REQUEST NO. 75: Please provide a list of all leased items in 2015 and 2016 to date.
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
REQUEST NO. 76: Please provide an Excel file showing all capital projects completed or
due to be complete by year from January 1, 2010 through December 31 , 2016. For each project,
please include the following: project name, project number or identifier, cost of service
classification, description of the project, rationale for the project, target start date, actual start date,
target completion date, actual completion date, estimated cost, and actual cost associated with each
project.
REQUEST NO. 77: In Mike McGrath's testimony, he describes the Fixed Cost Collection
Mechanism as reconciling the difference between the Company's actual Fixed Cost Collection
Margin (i.e. -distribution margin) per customer, and the Company's Allowed Fixed Cost Collection
Margin per customer (McGrath's Di, p.2). Please provide an estimate that shows total Allowed
Fixed Cost Collection Margin will not be sufficient to cover the Company's anticipated distribution
costs.
REQUEST NO. 78: Hart Gilchrist references the Company's pipeline integrity
management program in testimony. Please provide the risk model along with a detailed description
of the program (Gilchrist Di, p. 14).
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 SEPTEMBER 28, 2016
REQUEST NO. 79: Hart Gilchrist states in his testimony "In 2015 under the company 's
DIMP, approximately 30,000 feet of plastic pipe was removed and replaced. The Company plans to
remove another 22,000 in 2016 and 25,000 in 2017." Aside from the DIMP, how much additional
plastic pipe requires replacement? When does the Company expect to replace the additional plastic
pipe and at what cost? (Gilchrist Di, p.14).
REQUEST NO. 80: Referencing Exhibit No. 8, please provide a schedule breaking out
each of the revenue and expense categories by FERC Account for each month from January 2013 to
present. Please consider this a continuing request and update as months are finalized.
REQUEST NO. 81: Please provide the general ledger entries for the years 2015 to present
that support the schedule requested in Request No. 80 in an electronic format only. (Excel, comma
separated values, etc.) Please include enough detail on each general ledger to identify individual
transactions. (i.e., invoice number, date, amount, etc.)
REQUEST NO. 82: Please provide the reasoning and all related documentation (including
origination and determination of the amount) associated with the $3 million "Mandatory Spending
Reduction" in the 2015 CapEx budget to actual comparison.
REQUEST NO. 83: Please provide an update as of September 30, 2016, to the 2016
CapEx Budget to Actual comparison.
REQUEST NO. 84: Please provide an Excel file of the 2017 capital expenditure budget by
category (services, revenue mains and the like).
REQUEST NO. 85: Please provide a detailed Excel file of the 2017 capital expenditure
budget including project names, project numbers or identifiers, cost of service classification,
description, reason, location, target start date, actual start date (if project began before 2017), target
completion date, dollar amounts for each project.
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 4 SEPTEMBER 28, 2016
REQUEST NO. 86: Please provide accounting and underlying supporting documentation
for the $12 million adjustments that increased Gas Distribution -Services (3 80) during 2015
according to the 2015 plant schedule. Please include within your response the underlying reason for
the adjustments, accounting entries, dates, amounts and any other accounts affected.
REQUEST NO. 87: Please provide accounting and underlying supporting documentation
for the $5 million adjustments that increased Gas Distribution -Mains (376) during 2015 according
to the 2015 plant schedule. Please include within your response the underlying reason for the
adjustments, accounting entries, dates, amounts and any other accounts affected.
REQUEST NO. 88: Please provide accounting and underlying supporting documentation
for the $661,000 adjustments that increased Gas Transmission-Mains (367) during 2015 according
to the 2015 plant schedule. Please include within your response the underlying reason for the
adjustments,'accounting entries, dates, amounts and any other accounts affected.
REQUEST NO. 89: Please provide a schedule for depreciation expense during 2015 that
includes plant in service to which the depreciation rates are applied, the depreciation rates that are
applied, any other related information affecting depreciation expense and the resulting depreciation
expense.
REQUEST NO. 90: Please provide a reconciliation/proof between depreciation expense
and accumulated depreciation during 2015. If the depreciation expense entries do not match the
entries to accumulated depreciation, please specifically identify the reasons for the differences,
including the related accounting entries.
REQUEST NO. 91: Please provide a schedule with the monthly balances for materials and
supplies by subaccounts for 2014, 2015 and 2016 to date .
REQUEST NO. 92: Please provide detail documentation including accounting entries and
retirement documents for the almost $10 million in meter ( account 3 81) retirements and $1.5
million in meter installations ( account 3 82) during 2015 according to the 2015 plant schedule.
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 5 SEPTEMBER 28, 2016
Please include within your response any plant in service added as a result of the retirements. Please
include within your response any related plant in service added that resulted in the retirements. If
none, please so state.
REQUEST NO. 93: Please provide detail documentation including accounting entries and
retirement documents for the almost $1.8 million in office furniture and equipment (account 3910)
retirements during 2015 according to the 2015 plant schedule. Please include within your response
any related plant in service added that resulted in the retirements. If none, please so state.
REQUEST NO. 94: Please provide detail documentation including accounting entries and
retirement documents for the almost $1 million in power operated equipment (account 3960)
retirements during 2014 and $0.5 million retirements according to the 2014 and 2015 plant
schedules, respectively. Please include within your response any related plant in service added that
resulted in the retirements. If none, please so state.
REQUEST NO. 95: Please provide documentation including accounting entries and
underlying reasoning for the $1 million negative amount in additions in Mains ( account 367) during
2015 according to the 2015 plant schedule.
REQUEST NO. 96: Please identify all overhead loadings that are capitalized and/or
expensed and their composition. Please include within your response how these overheads are
calculated and applied. Please include within your response the percentages applied by month
during 2014, 2015 and 2016 to date.
REQUEST NO. 97: Please provide workpapers showing how peak day allocators were
determined in the Company's Cost of Service Model.
REQUEST NO. 98: Please provide the workpapers used to determine Demand, Customer,
and Commodity allocators used in the Company's Cost of Service Models.
FOURTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 6 SEPTEMBER 28, 2016
REQUEST NO. 99: In the Company's Mains Study worksheet "mains-steel (eq data)",
what criteria were used to exclude data from the model?
REQUEST NO. 100: Please provide the following data for work orders that were used in
the Mains Study:
a. Work Order Number;
b. Year;
c. Pipe type (plastic/steel);
d. Pipe Length;
e. Total Cost.
REQUEST NO. 101: Currently, the Company's line and mains extension charges (Tariff
Section C) are computed using a 12.5% Rate of Return. Please provide updated tariff sheets that
reflect the Company's proposed Rate of Return. Please provide work papers supporting these
changes.
REQUEST NO. 102: Please provide any workpapers showing the Company's cost
allocation methodology for its interruptible snow melt schedules, IS-Rand IS-C.
,l"I-
DA TED at Boise, Idaho, this 2~ day of September 2016.
Technical Staff: Donn English/65-75
Kevin Keyt/76-79
Joe Terry/80-81
Patricia Harms/82-96
Michael Morrison/97-102
i :umisc:prodreq/intg l 6.2kkscdekskjtphmm prod req4
FOURTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS
Sean Costello
Deputy Attorney General
7 SEPTEMBER 28, 2016
e
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR-REGULATORY AFFAIRS
INTERMOUNT AIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL : [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE