20161004Staff 103-119 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
RE CEIVED
'l"l\r 'L"('T -4 PM 2: l Q ,.U i.) ,, . .,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE ITS )
RATES AND CHARGES FOR NATURAL GAS )
SERVICE. )
)
)
)
) ___________________ )
CASE NO. INT-G-16-02
FIFTH 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 TUESDAY, OCTOBER 25, 2016.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional docume1:ts 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 ID APA
31.01.01.228.
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 OCTOBER 4, 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. 103: In Response to Production Request No. 23, a detailed spreadsheet of
Advertising Expense was provided. On tab 2 of this spreadsheet, Column "V" provides a
description of customer benefit. Several line items in Column "V" of this spreadsheet are labeled
with a "9" that is not listed in the legend (Column "V" starting on line 191 ). Please provide
customer benefit description for items marked with a "9" on the spreadsheet.
REQUEST NO. 104: Please provide a detailed schedule of actual expenditures to date for
all Administration & General Outside Services included within the Company's filing. Please
include within your response the dates, vendors, explanations, amounts posted, supporting
documentation for those amounts (such as invoices, contracts and other detail supporting the
transactions), and associated customer benefit.
REQUEST NO. 105: Please provide supporting documentation for forecasted A&G
Outside Services for the period 7 /1/16-12/31/16. Please include an explanation of each expenditure
expected, the purpose, the dollar amounts, and supporting documentation for those amounts. If
based on actual expenses for the same period in 2015, please provide a schedule of actual expenses
and include in your response the dates, vendors, explanation, amounts posted, and supporting
documentation for those amounts.
REQUEST NO. 106: Please provide a detailed schedule of actual expenditures to date for
all Miscellaneous or Other Expense accounts included within the Company's filing. Please include
within your response the dates, vendors, explanations, amounts posted, supporting documentation
for those amounts (such as invoices, contracts and other detail supporting the transactions), and
associated customer benefit.
REQUEST NO. 107: Please provide supporting documentation for forecasted
Miscellaneous or Other Expense accounts for the period 7/1/16-12/31/16. If based on actual
expenses for the same period in 2015, please provide schedule of actual expenses and include in
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 OCTOBER 4, 2016
your response the dates, vendors, explanation, amounts posted, supporting documentation for those
amounts.
REQUEST NO. 108: Please provide detailed installation records for all encoder receiver
transmitter (ERT) investments.
REQUEST NO. 109: Please provide the detailed depreciation schedules with depreciation
rates applied for Depreciation Expenses related to ERT-Units (Account 381-G) and ERT
Installation (Account 382-G) for actual and forecasted periods in the 2016 Test Year. Please
provide reconciliation/proof between depreciation expense and accumulated depreciation during
2015 and 2016.
REQUEST NO. 110: On page 13 of her testimony, Ms. Blattner describes a peak day
allocator used to allocate Transmission and Storage plant costs. The Company has also indicated
that its test year peak day occurred on January 1, 2016. Does the Company believe that January 1,
2016, consumption properly represents the way that customer classes cause the Company to incur
costs? Please explain your answer.
REQUEST NO. 111: Please explain how the peak day allocator was computed for each
class, and provide all supporting workpapers and calculations with formulas intact. If MDFQ was
used in computation of this allocator, please describe how it was used.
REQUEST NO. 112: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for each and every customer with a meter capable of measuring daily
demand. Include all workpapers with formulas intact.
REQUEST NO. 113: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for all the Company's existing classes.
REQUEST NO. 114: Please provide monthly coincident and non-coincident peaks
(number of therms and dates) for each of the Company's proposed classes.
FIFTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 OCTOBER 4, 2016
REQUEST NO. 115: In 2008, the Company started using a Square Footage/Average
Therm Matrix to determine annual estimated therms, annual estimated bills, level pay and deposit
amounts, and main extension costs. Has the Company updated the matrix to reflect more recent
consumption data for residential and commercial customers? Please explain.
REQUEST NO. 116: Please provide the Square Footage/Average Therm Matrix currently
used by the Company.
REQUEST NO. 117: The 2008 Square Footage/Average Therm Matrix was integrated
with the previous Customer Information System (CIS). Given the Company's recent transition to a
new CIS, was the most recent Square Footage/Average Therm Matrix incorporated into the new
CIS? If not, please explain how the Company is making each of the calculations identified in
Production Request No. 115.
REQUEST NO. 118: Does the Company use the current matrix to determine new service
line costs as well as main extension costs? If not, how are those costs determined?
REQUEST NO. 119: The Ketchum/Sun Valley Area Hookup Fee (Rate Schedule H-1)
was originally established to be effective until the Ketchum Uprate Project costs were fully
recovered, or until the capacity provided by the project was fully utilized. Have the costs of the
Ketchum Uprate project been fully recovered, or has the capacity provided by the project been fully
utilized? If not, please provide the current level of costs recovered from the hookup fee and the
capacity of the project currently being utilized. Furthermore, please explain if the Company plans
to cancel the Ketchum/Sun Valley Area Hookup Fee and incorporate the remaining project costs
into base rates. Please explain how base rates were adjusted to account for the hook-up fee, and
how the Cost-of-Service study was adjusted to account for these customers' above average usage.
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 4 OCTOBER 4, 2016
DATED at Boise, Idaho, this t(,/1,-day of October 2016.
Sean Costello
Deputy Attorney General
Technical Staff: Barbara Romano/103-109
Michael Morrison/110-114
Johnathan Farley/115-118
Matt Elam/119
i:umisc:prodreq/intgl 6.2kkscbrmmjfme prod reqS
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 5 OCTOBER 4, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF OCTOBER 2016,
SERVED THE FOREGOING FIFTH 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
INTERMOUNTAIN 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]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83 702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
SECRE~Y~
CERTIFICATE OF SERVICE