20221229Staff 48-57 to INT.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )COMPANY'S APPLICATION FOR )CASE NO. INT-G-22-07
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR NATURAL GAS SERVICE IN )SECOND PRODUCTION
THE STATE OF IDAHO )REQUESTOF 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 AttorneyGeneral,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and information as soon as possible, but no later than
THURSDAY,JANUARY 19, 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 identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l DECEMBER 29, 2022
RECEIVED
Thursday, December 29, 2022 2:04:08 PM
IDAHO PUBLIC
UTILITIES COMMISSION
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.48:On page 17 of Company Witness Blattner's testimony,she explains
how the Nampa Liquefied Natural Gas ("LNG")facility was out of service for repair due to a
leak in the outer shell LNG tank for most of 2021.
a.Please explain the accounting treatment the Company will use for the repair costs
for the Nampa LNG plant.Please provide Excel worksheets with formulas intact.
b.Please provide a worksheet that details all costs associated with the repair that are
included in this case.If not all costs are being included within this case,please
explain exclusions and accounting treatment that will be applied to them.
c.Please explain how repair costs will be allocated to utility customer classes and
off system sales customers.Please provide the percentage of costs that will be
allocated to each customer class.
REQUESTNO.49:Please describe both the expected service and depreciation life of
the repaired Nampa LNG plant.Please provide workpapers detailing the expected depreciation
expense.
REQUESTNO.50:Please describe the selection process/methods used for information
technology upgrades,enhancements,and projects for the period of 2016 through 2022.
a.Please describe how the Company addressed least risk and least cost
considerations in selection of projects.
b.Please provide any cost benefit analyses conducted for each project.
REQUESTNO.51:Please provide Capital and Operations &Maintenance ("O&M")
informational technology expenses for MDU Resources Group Inc.("MDU")from 2016-2022
allocated to Intermountain Gas.Please explain how MDU allocates Capital and O&M
informational technology expenses to their subsidiaries and please provide supporting
worksheets.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 DECEMBER 29,2022
REQUESTNO.52:Please provide Capital and O&M informational technology
expenses for the Company from 2016-2022 and please provide supporting worksheets.
REQUESTNO.53:Please describe the Company's current progress of its Aldyl-A
replacement program.
a.Based on the Company's assessments,how many miles of Aldyl-A pipe require
replacement in 2023 and beyond?
b.Please provide the expected timeline and annual costs for Aldyl-A replacement.
c.Please provide a workpaper that details the number of miles and costs of Aldyl-A
replacement for each year since the last general rate case.
d.Please provide the accounting treatment for all Aldyl-Acost included in this rate
case.
REQUESTNO.54:Please provide the supporting worksheets for the $35 million Work
and Asset Managementproject referenced in Company Witness Gilchrist Direct Testimony at 7.
REQUESTNO.55:Please provide the Company's latest Distribution Integrity
ManagementProgram ("DIMP")plan and annual report.
REQUESTNO.56:Please provide Company Witness Bulkley's workpapers and
exhibits in Excel format with all formulas intact.
REQUESTNO.57:Please provide any studies the Company has in its possession,or
any studies the Company has reviewed on the gas consumption of low-income customers.
SECOND PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 DECEMBER 29,2022
DATED at Boise,Idaho,this day of December 2022.
Claire Sharp
Deputy AttorneyGeneral
i umise prodreq/inig22.7csic prod req 2
SECOND PRODUCTIONREQUEST
TO INTERMOUNTAIN GAS COMPANY 4 DECEMBER 29,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF DECEMBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY,IN CASE
NO.INT-G-22-07,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR-REGULATORYAFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL:prestoncarter civenspursley.com
E-MAIL:lori.blattner [ntgas.com stephaniew(älaivenspursley.com
CHAD M STOKES
CABLE HUSTON LLP
1455 SW BROADWAY
STE 1500
PORTLAND OR 97201
E-MAIL:estokesacablehuston.com
brmullinsra3mwanalvtics.com
S RETA Y
CERTIFICATEOF SERVICE