20220819Staff 1-5 to INT.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 8026
Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO REYISE RATE SCHEDULE
EEC-RS.RESIDENTIAL ENERGY EFFICIENCY
CHARGE
CASE NO.INT-G-22-05
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Claire Sharp, Deputy Attorney General, requests that Intermountain Gas Company ("Company")
provide the following documents and information as soon as possible, but no later than
FRTDAY, AUGUST 26, 2022.1
This Production Request is to be considered as continuing, and Intermountain Gas
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 or
information produced.
I Stuff i. requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO TNTERMOUNTAIN GAS COMPANY
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AUGUST 19,2022
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide workbooks detailing forecasted expenditures for
program years2022,2023,and2024 separated by each residential program and measure. Please
provide Company workpapers in Excel format with formulas intact and enabled.
REQUEST NO.2: Please explain if the Company included any forecasted expenses for
programs or measures that are not currently approved by the Commission.
REQUEST NO. 3: Please provide a workbook detailing forecasted expenditures within
the residential promotional and program delivery expenses in the 2023 and2024 program years.
REQUEST NO. 4: Please provide Company workbooks detailing forecasted revenues
for 2023 and2024 with all equations intact and enabled.
REQUEST NO.5: Please provide supporting documentation justifyinga5o/o increase in
both labor and promotion expenses.
DATED at Boise, Idaho, this t?
w
day ofAugust2022
Claire Sharp
Deputy Attorney General
i:umisc:prodreq/intg22.5cslc prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 19,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPAIIY, IN CASE NO.
INT.G-22-05, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
PRESTON N CARTER
MORGAN D. GOODIN
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE TD 83702
E-MAIL: [e-mail]
stephaniew@ qivenspursley.com
morgangoodin@ g ivenspursley.com
J4 /M*,
SECRETARZ
CERTIFICATE OF SERVICE