20161012Staff 120-130 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~:CE IVEO
GI& OCT 12 AM 9: 34
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
SIXTH 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, NOVEMBER 2, 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.
SIXTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 1 OCTOBER 12, 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. 120: On page 5 of her testimony, Ms. Blattner explains that she used a test
year using 6 months of actual data and six months of forecasted data. Please provide the
workpapers, assumptions, and supporting data used to create this forecast. Please explain why
forecast, rather than actual weather data was used.
REQUEST NO. 121: Please provide the workpapers, assumptions, and supporting data
used to determine the Company's weather normalized consumption as summarized in Table B.1. of
Ms. Blattner's direct testimony, and used by Company witness Darrington.
REQUEST NO. 122: Please provide the accounting entries and related supporting
documentation associated with the Ketchum/Sun Valley Area Hookup. Please include all
components associated with the Hookup including but not limited to the revenues, costs, and rate
base amounts. Please correlate this information with the decreased tariff and corresponding refunds
approved in Case No. INT-G-09-01 and Tariff Advice No. 09-02. Please identify specifically
where these costs and revenues are within the Cost-of-Service study.
REQUEST NO. 123: Please provide a narrative of the line extension process, a copy of
any policies and procedures related to the process, and a list from 2010 through 2016 to date of line
extensions other than the previously referenced Ketchum /Sun Valley Area hookup. For each line
extension, please identify the costs (including documentation underlying those costs), hookup fee
calculated, hookup fee revenue, advances and/or contributions and any other accounts posted.
Please include within your response specifically how these amounts were included within the Cost­
of-Service study.
REQUEST NO. 124: Please identify how the interruptible snowmelt provisions are
recorded within the accounting records and Cost-of-Service Study. Please include within your
response the amounts and accounts posted, by year, for 2014 through 2016 to date.
SIXTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 OCTOBER 12, 2016
REQUEST NO. 125: Please provide the Zacks Financial and Yahoo Finance! reports that
include the 5-year earnings growth rate estimates for MDU Resources Group.
REQUEST NO. 126: Please provide copies of the SNL Financial reports used to determine
the total assets, operating revenue, and operating income for the group of proxy companies listed in
Exhibit 5, Schedule 3. Please provide a copy of the equivalent report for MDU Resources Group.
REQUEST NO. 127: Please provide the Company's studies and bill impact analyses
supporting the proposal to combine the RS-1 and RS-2 residential classes.
REQUEST NO. 128: Please provide studies and analyses showing the relationship
between load factor and usage for GS-1 customers. Please also provide in executable electronic
format 12 months of consumption data for GS-1 customers having a consecutive 12 months of
billing history.
REQUEST NO. 129: Please provide detailed installation and retirement records for all
Meter investments and Meter Set Installations.
REQUEST NO. 130: Please provide the detailed depreciation schedules with depreciation
rates applied for Depreciation Expenses related to Meters (381-G) and Meter Set Installation
(382-G) for actual and forecasted periods in the 2016 Test Year. Please provide a
reconciliation/proof between depreciation expense and accumulated depreciation for Meters and
Meters Installation during 2015 and 2016.
SIXTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS 3 OCTOBER 12, 2016
DATED at Boise, Idaho, this /J,-rl'-day of October 2016.
Technical Staff: Michael Morrison/120-121
Patricia Harms/122-124
Mark Rogers/125-126
Bentley Erdwurm/127-128
Barb Romano/129-130
i:umisc:prodreq/intgl 6.2kkscmmphmrbe prod req6
SIXTH PRODUCTION REQUEST
TO INTERMOUNT AIN GAS
Sean Costello
Deputy Attorney General
4 OCTOBER 12, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF OCTOBER 2016,
SERVED THE FOREGOING SIXTH 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]
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 83702
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 A VENUE
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: kmiller@snakeri veral I iance.org
CERTIFICATE OF SERVICE