20221216Staff 1-47 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
ili':i'f'IVED
,l;l flt[ l6 P]t l2r ll+
, r, ..in ltlEiLlC
' , r ,'CCY^*,1,-fiSStCtl
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOI]NTAIN GAS
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES AI\D
CHARGES FOR NATURAL GAS SERVICE IN
THE STATE OF IDAHO
CASE NO.INT.G.22-07
FIRST PRODUCTION
REQUEST Of,'THE
COMMISSION STAFF
TO INTERMOUNTAIN GAS
COMPAI\'Y
The Staffof the Idaho Public Utilities Commission, by and through its attomey of record,
Claire Sharp, Deputy Attomey General, requests that Intermountain Gas Company ("Company")
provide the following documents and information as soon as possible, but no later than
FRTDAY, JANUARY 6, 2023.
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.
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.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY
)
)
)
)
)
)
)
)
)
I DECEMBER 16,2022
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 a copy of the Company's Chart of Accounts.
REQUEST NO. 2: Please provide the total amount that the Company spent on the
following activities for 2017 through 2022 to date, and show how the Company allocated the
amounts between its operating division and the rest of the Company and its subsidiaries:
a. The Company's annual report;
b. Rating agencies;
c. All software or information system-related issues;
d. Board of Directors compensation, travel expenses, and meeting expenses;
e. Travel and training for all shared executives of Intermountain Gas Company and
affiliates;
f. Insurance coverage;
g. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
h. All other allocated or shared expenses.
REQUEST NO. 3: 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 2017 through 2022 to date.
REQUEST NO. 4: Please provide copies of any internal or external reviews and reports
associated with the allocation of costs between Intermountain Gas and any affiliated companies.
In your response, please include any reviews, reports and other documents performed or created
by or for any other regulatory commissions.
REQUEST NO. 5: Please provide a list of all leased items in 2017 through2022 to date
Please separate capital leases from operating leases and show the dates, terms, amounts, and
accounts used for each lease.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 DECEMBER 16,2022
REQUEST NO. 6: Please provide a list of all property that the Company leases to
others. Please provide copies of all lease contracts.
REQUEST NO. 7: Please provide an estimate of the rate case expenses the Company
expects to incur. Please supplement your response as additional information becomes available.
REQUEST NO. 8: Please provide a copy of the Company's property tax bills for 2017
through 2022 to date.
REQUEST NO. 9: Please provide access to all Company bank statements for 2017
through 2022 to date.
REQUEST NO. 10: Please provide statements for any Company credit cards that
include spending during 2017 through2022 to date.
REQUEST NO. 1l: Please summarize all of the Company's penalties or fines paid for
the period of January 1,2016, through 2022to date. Please show all account numbers and the
amount booked to each by occurrence and date.
REQUEST NO. 12: Please provide the following direct labor related information as
recorded for December 31, 2017 , through 2022 to date. Information, where applicable, should
be listed by O&M expense, other expense, construction, and other account groups (listed by
functional categories, i.e., storage, transmission, distribution, customer, A&G, etc.). Please
provide the information on a system-wide basis. The response should include wages and salaries
for each employee category (officer, exempt, non-exempt, and union), paid time-off, overtime,
bonuses, incentive pay, and overheads for pension, benefits, and payroll taxes. Please also
include average and year-end number of employees by employee category. lnclude part-time
and temporary employees as full-time equivalents.
FIRST PRODUCTION REQUEST
TO INTERMOTINTAIN GAS COMPANY J DECEMBER 16,2022
REQUEST NO. 13: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide a summary of any additional
workforce reduction programs planned for 2022 and2023.
REQUEST NO. 14: Please summarize all benefit and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO. 15: Please provide copies of the Company's pension and actuarial
reports for the years 2017 through 2022 to date. Also, please provide any actuarial calculations
and documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO. 16: Please provide access to copies of all studies used to determine
employee compensation, including executive compensation, and explanations of how the
Company applied them in the years 2017 through2022 to date.
REQUEST NO. 17: Please provide the yearly percentage pay rate increase by employee
and position since the last general rate case. Please provide in Excel spreadsheet with formulas
intact.
REQUEST NO. 18: Please provide a schedule of the Company's "Property Held for
Future Use" through2022. 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.
REQUEST NO. 19: Please provide a schedule of "Prepaid Items" for 2020,2021 and
2022 to date, showing dollar amounts and account numbers where posted, vendors, and related
explanations (including allocated amounts). Please supplement your response as additional
information becomes available.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 4 DECEMBER16,2022
REQUEST NO. 20: Please describe the method by which the Company recorded and
allocated materials and supplies to its accounting records in202l and2022 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.
REQUEST NO. 2l: Please provide a copy of all adjusting, or closing, entries for 2017
through 2022 to date in the general ledger, and the related explanation for each entry.
REQUEST NO.22: Please indicate if there have been any FERC investigations since
2016. If so, please provide a list with dates, descriptions, and outcomes.
REQUEST NO.23: Please provide a list in Excel format of all external attorneys who
performed services for the Company or who were paid by the Company for services from 2017
through 2022to date. Please list the amounts paid, accounts charged, and date of payment.
Please also provide a brief summary of the services performed. If services were performed in
support of a docketed federal/state court or regulatory action, please identify the case name, case
number, and jurisdiction.
REQUEST NO.24: Please provide the Intemal Audit schedule of planned audit reviews
for 2023 and2024. Please include within your response a description of each planned audit
review and the underlying reason for each one.
REQUEST NO.25: Please provide all reports and letters prepared by the Company's
Internal Audit staff that document areas reviewed by them from December 1,2020 throtgh2022
to date.
REQUEST NO. 26: Please provide all Audit Committee meeting minutes for the
Company and its affiliates for 2017 through 2022 to date.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 5 DECEMBER 16,2022
REQUEST NO. 27: Please provide access to the Board of Directors'meeting minutes
for each meeting in20l7 through 2022to date. Please provide copies of the Board of Directors'
materials distributed for meetings from 2017 through2022 to date. Please also include the same
for the Compensation Committee.
REQUEST NO. 28: Please provide a copy of the 2017 through2022 shareholder annual
report and proxy statement.
REQUEST NO. 29: Please provide copies of any accounting issues identified during the
last external audit 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 o'passed on."
REQUEST NO.30: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the yearc2017 through 2022 to date.
REQUEST NO. 31: Please provide a schedule with details for all advertising expenses
included within the Company's filing. Please include within your response the dates, vendors,
explanations, amounts posted, copies of the related advertising, and associated customer benefit.
Please provide worksheets in Excel format with formulas intact.
REQUEST NO. 32: Please provide copies of all billing inserts for 2017 through 2022 to
date and indicate the date they were sent. Please also provide a schedule showing the amount
and account numbers charged for all costs to produce, print, and distribute the inserts.
REQUEST NO.33: Please provide a schedule and journal entries of all additions and
retirements to Plant in Service since the beginning of 2017, including installation date, account,
installed cost, and estimated depreciable life.
REQUEST NO. 34: Please provide an analysis of any sales of land and/or plant for the
years 2017 through 2022 to date, if any. Please show gains, losses, and supporting
documentation including accounting entries for removal of items from rate base.
FIRST PRODUCTTON REQUEST
TO INTERMOUNTAIN GAS COMPANY 6 DECEMBER 16,2022
REQUEST NO. 35: Please provide details of any planned sales of land and/or plant for
the remainder of 2022. Please include within your response the estimated date of these sales and
planned accounting treatment.
REQUEST NO.36: Please provide a schedule showing injuries and damages claims for
the years 2017 through2022 to date. Please include within your response the description of each
item, the amount for each item, and the account charged.
REQUEST NO.37: Please provide a listing of all organizations the Company
participates in and the costs of participating in those organizations (e.g. GRI, etc.). Please
identify any costs that are allocated between utility and non-utility operations.
REQUEST NO.38: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actual expenditures for 2017 through2022 to date.
Please include within your response a narrative explanation for budget variations. This should
include, but not be limited to, written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility. Please supplement your response as additional information becomes available.
REQUEST NO.39: Please list all the Company's long-term debt issuances. Please
include the following: dates of issuance and expiration, amounts, premiums or discounts, interest
rates, dates of pre-payment, and payment schedules for each issuance.
REQUEST NO. 40: Please describe the Company's methodology for developing,
managing, executing, and completing Capital Projects in a least cost manner. Please provide a
copy of all Company policies and procedures documenting the process.
REQUEST NO. 41: Please summarize all of the Company's environmental cleanup
costs for the period of January 1,2016, through 2022 to date. Please show all account numbers
and the amount booked to each sub account by occurrence and date.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 7 DECEMBER 16,2022
REQUEST NO. 42: Please provide an Excel file with formulas enabled showing all
capital projects completed by year from January 1,2015, through December 31,2021. For each
project, please include the following: name or title, number or identifier, in-service date, cost of
service classification, description, rationale analysis or business need, target start date, actual
start date, target completion date, actual completion date, estimated cost, budgeted cost, actual
cost, if a cost benefit analysis was performed, if the work was primarily completed by employees
or contractors, and if a request-for-proposal was performed.
REQUEST NO.43: Please provide a detailed Excel file of the 2022 capital expenditure
budget including n.rme or title, number or identifier, in-service date, cost of service
classification, description, rationale analysis or business need, target start date, acfual start date
(if started prior to 2022), target completion date, actual completion date (if completedin2022),
estimated cost, budgeted cost, actual cost, if a cost benefit analysis was performed, if the work
was primarily completed by employees or contractors, and if a request-for-proposal was
performed.
REQUEST NO.44: 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,
and similar expenses).
REQUEST NO. 45: For the period January 1,2015, through December 31,2021, please
provide a breakdown of Capital Expenditures by existing rate classes in FERC accounts 380,
381,382, 383, 384, and 385.
REQUEST NO. 46: Please provide a detailed schedule of the'oAdvances in Aid of
Construction" received by the Company from20l7 through 2022to date. 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.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 8 DECEMBER T6,2022
REQUEST NO. 47: Please provide a matrix identifuing the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division, and
company. Please include within your response the dollar level at which the individual capital
expenditures require approval by the Board of Directors. Please include the following in your
response: cost/benefit analysis, intemal rates of return, or similar analysis for each capital
project.
, , t{44
\Q2 4", of Decemb er2o22.DATED at Boise,Idaho, this
i:umisc:prodreq/intg22.7cslc prod req I
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY
Claire Sharp
Deputy Attorney General
q^4J
9 DECEMBER16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF DECEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO INTERMOUNTAIN GAS COMPAI{Y, IN CASE
NO. INT.G-22-07, 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
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
stephaniew@ givenspursley.com
SECRET
CERTIFICATE OF SERVICE