20230110AWEC to INT 1-23.pdf

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]
Attorneys for Alliance of Western Energy Consumers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOUNTAIN GAS COMPANY
FOR THE AUTHORITY TO CHANGE ITS
RATES AND CHARGES FOR NATURAL
GAS SERVICE IN THE STATE OF IDAHO
CASE NO. INT-G-22-07
ALLIANCE OF WESTERN ENERGY
CONSUMERS’ FIRST SET OF
PRODUCTION REQUESTS TO
INTERMOUNTAIN
Alliance of Western Energy Consumers, by and through its attorney of record,
requests that Intermountain Gas Company (“Company”) provide the following documents
and information as soon as possible, but no later than the time provided by Idaho Admin.
Code 31.01.01.225, or February 1, 2023.
DEFINITIONS
1.“Company” or “Intermountain” refers to any affiliated company, or any officer,
director or employee of Intermountain Gas Company or any affiliated company.
2.“Documents” refers to all writings and records of every type in your possession,
control, or custody, whether or not claimed to be privileged or otherwise excludable
from discovery, including but not limited to: testimony and exhibits, memoranda,
papers, correspondence, letters, reports (including drafts, preliminary, intermediate,
and final reports), surveys, analyses, studies (including economic and market
studies), summaries, comparisons, tabulations, bills, invoices, statements of services
rendered, charts, books, pamphlets, photographs, maps, bulletins, corporate or other
minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, microfiche,
computer data (including E-mail), computer files, computer tapes, computer inputs,
computer outputs and printouts, vouchers, accounting statements, budgets,
workpapers, engineering diagrams (including “one-line” diagrams), mechanical and
electrical recordings, telephone and telegraphic communications, speeches, and all
other records, written, electrical, mechanical, or otherwise, and drafts of any of the
above.
RECEIVED
Tuesday, January 10, 2023 3:32:00 PM
IDAHO PUBLIC
UTILITIES COMMISSION
AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
“Documents” includes copies of documents, where the originals are not in your
possession, custody or control.

“Documents” includes every copy of a document which contains handwritten or
other notations or which otherwise does not duplicate the original or any other copy.

“Documents” also includes any attachments or appendices to any document.
3. “Identification” and “identify” mean:

When used with respect to a document, stating the nature of the document (e.g.,
letter, memorandum, corporate minutes); the date, if any, appearing thereon; the
date, if known, on which the document was prepared; the title of the document; the
general subject matter of the document; the number of pages comprising the
document; the identity of each person who wrote, dictated, or otherwise participated
in the preparation of the document; the identity of each person who signed or
initiated the document; the identity of each person to whom the document was
addressed; the identity of each person who received the document or reviewed it; the
location of the document; and the identity of each person having possession, custody,
or control of the document.

When used with respect to a person, stating his or her full name; his or her most
recently known home and business addresses and telephone numbers; his or her
present title and position; and his or her present and prior connections or associations
with any participant or party to this proceeding.

4. “Person” refers to, without limiting the generality of its meaning, every natural
person, corporation, partnership, association (whether formally organized or ad hoc),
joint venture, unit operation, cooperative, municipality, commission, governmental
body or agency, or any other group or organization.

5. “Studies” or “study” includes, without limitation, reports, reviews, analyses and
audits.

6. The terms “and” and “or” shall be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any
information or documents which might otherwise be considered to be beyond their
scope.

7. The singular form of a word shall be interpreted as plural, and the plural form of a
word shall be interpreted as singular, whenever appropriate in order to bring within
the scope of this discovery request any information or documents which might
otherwise be considered to be beyond their scope.

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
INSTRUCTIONS

1. These requests call for all information, including information contained in
documents, which relate to the subject matter of the Data Requests and which is
known or available to the Company.

2. Where a Data Request has a number of separate subdivisions or related parts or
portions, a complete response is required to each such subdivision, part or portion.
Any objection to a Data Request should clearly indicate the subdivision, part, or
portion of the Data Request to which it is directed.

3. The time period encompassed by these Data Requests is from 2015 to the present
unless otherwise specified.

4. Each response should be furnished on a separate page. In addition to hard copy,
electronic versions of the document, including studies and analyses, must also be
furnished if available.

5. If the Company cannot answer a Data Request in full, after exercising due diligence
to secure the information necessary to do so, state the answer to the extent possible,
state why the Company cannot answer the Data Request in full, and state what
information or knowledge the Company has concerning the unanswered portions.

6. If, in answering any of these Data Requests, the Company feels that any Data
Request or definition or instruction applicable thereto is ambiguous, set forth the
language the Company feels is ambiguous and the interpretation the Company is
using in responding to the Data Request.

7. If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.

8. If the Company asserts that any document has been destroyed, state when and why it
was destroyed and identify the person who directed the destruction. If the document
was destroyed pursuant to the Company’s document destruction program, identify
and produce a copy of the guideline, policy, or company manual describing such
document destruction program.

9. If the Company refuses to respond to any Data Request by reason of a claim of
privilege, confidentiality, or for any other reason, state in writing the type of
privilege claimed and the facts and circumstances the Company relies upon to
support the claim of privilege or the reason for refusing to respond. With respect to
requests for documents to which the Company refuses to respond, identify each such
document, and specify the number of pages it contains. Provide: (a) a brief
description of the document; (b) date of document; (c) name of each author or
preparer; (d) name of each person who received the document; and (e) the reason for
AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
withholding it and a statement of facts constituting the justification and basis for
withholding it.

10. Identify the person from whom the information and documents supplied in response
to each Data Request were obtained, the person who prepared each response, the
person who reviewed each response, and the person who will bear ultimate
responsibility for the truth of each response.

11. If no document is responsive to a Data Request that calls for a document, then so
state.

12. These requests for documents and responses are continuing in character so as to
require the Company to file supplemental answers as soon as possible if the
Company obtains further or different information. Any supplemental answer should
refer to the date and use the number of the original request or subpart thereof.

13. Whenever these Data Requests specifically request an answer rather than the
identification of documents, the answer is required and the production of documents
in lieu thereof will not substitute for an answer.

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

/ / /

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
PRODUCTION REQUESTS

AWEC PR 001 to INTERMOUNTAIN
Please describe Cascade’s capitalization policy and provide any documentation supporting
the policy, including capitalization thresholds and any other requirements for an expenditure
to be capitalized versus expensed.

AWEC PR 002 to INTERMOUNTAIN
Please provide updated revenue requirement based on actual loads and actual test period
results. To the extent this information is not yet available at the time Intermountain
responds to this request, please state when the information will be available and supplement
the response to this request with the information when it becomes available.
AWEC PR 003 to INTERMOUNTAIN
Please provide a copy of the 2021 IRP and all workpapers supporting the IRP.
AWEC PR 004 to INTERMOUNTAIN
Reference Amen Direct at 14:1-15:4: Does Mr. Amen contend that there is a 100%
probability that each and every firm large volume customers will be using its full maximum
daily firm quantity on a design day? If no, please explain.
AWEC PR 005 to INTERMOUNTAIN
Please provide the actual peak day volumes for each rate class and rate schedule for each
year over the period 2016 through 2022, inclusive.
AWEC PR 006 to INTERMOUNTAIN
Please provide the following information for each large volume customers (e.g. LV-1, T-3,
and T-4), with the customer names obfuscated using a unique identifier, for each year over
the period 2016 through 2022, inclusive.
a. The customer’s rate schedule
b. Monthly throughput
c. Daily throughput
d. Peak day throughput, with the peak day date identified.
e. Maximum Daily Firm Quantity on the Peak Day
f. Weather station area.

AWEC PR 007 to INTERMOUNTAIN
Please provide gas daily market prices for each hub in which intermountain transacts over
the period 2016 through 2022.
AWEC PR 008 to INTERMOUNTAIN
Please provide the average daily temperature for each weather station area that
Intermountain uses in its weather normalization model over the period 2016 through 2022.

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
AWEC PR 009 to INTERMOUNTAIN
Please state the last time that Intermountain experienced a design day.
AWEC PR 010 to INTERMOUNTAIN
Reference Amen Direct at 15:2-4: Mr. Amen states “The average daily usage for the T-2 3
customers was 113,762 therms for the test year twelve-month period ending December 31, 3
2022.” Please explain how this value was calculated and provide an explanation of why the
calculation produces a reasonable result.
AWEC PR 011 to INTERMOUNTAIN
Reference Amen Direct at 14:1-15:4: Please explain why it would not be reasonable to use
average daily throughput as the peak day requirements for the T-4 rate class, in contrast to
the full maximum daily firm quantity.
AWEC PR 012 to INTERMOUNTAIN
Reference Amen Direct at 27:16-21: Do transportation customers have an ability to call on
the referenced storage facilities to deliver gas to serve their requirements during periods of
high prices or peak demands? If no, please explain why a peak day allocation of storage
plant to transportation customers is reasonable.
AWEC PR 013 to INTERMOUNTAIN
Please provide Intermountain’s annual GAAP financial statements, including income
statement, statement of cashflows, balance sheet, and statement of retained earnings for
2016, 2017, 2018, 2019, 2020, 2021, and 2022.
AWEC PR 014 to INTERMOUNTAIN
Reference Nygard, Exhibit 1 Page 3: Please provide an updated version of the referenced
table with the actual cost of the forecast 2022 issuances.
AWEC PR 015 to INTERMOUNTAIN
Reference Nygard, Exhibit 1: Please provide detail of date and amount of each dividend
paid from intermountain and each equity infusion received by Intermountain over the period
2019 through 2022.
AWEC PR 016 to INTERMOUNTAIN
Reference Darrington Exhibit 2: Is Intermountain requesting a working capital allowance?
If yes, please state the line item where the working capital balances may be found.
AWEC PR 017 to INTERMOUNTAIN
Reference Darrington Exhibit 3: Please provide actual results of operations for calendar
year 2021.
AWEC PR 018 to INTERMOUNTAIN
Reference Darrington Exhibit 17, Column (e): Please state the monthly balance of
unamortized excess deferred federal income taxes, and explain how such balances are
considered in the calculation of ADIT.

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
AWEC PR 019 to INTERMOUNTAIN
Reference Darrington Exhibit 11, Line 18: Please state the amount of ARAM reversals
included as an offset to income tax expense for the test period.
AWEC PR 020 to INTERMOUNTAIN
Reference Darrington Exhibit 11, Line 18: Please explain why the line titled “Non-Plant
Excess deferred taxes” is considered a deferred tax item increasing tax expense, rather than a
permanent reduction to tax expenses.
AWEC PR 021 to INTERMOUNTAIN
Reference Darrington Exhibit 11, Cell “E28”: Please reconcile the (-)$892,950 in plant
related deferred taxes to the approximate (-)$588,524 temporary plant book tax difference
in Exhibit 10, Cells “G47:G48,” which tax effected is just (-)$123,590.
AWEC PR 022 to INTERMOUNTAIN
Reference Darrington Workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req
Model (Darrington)”, Tab “WP - Deferred Tax”, Cells “C111:C115”: Please provide
workpapers used to calculate the hardcoded values in the referenced cells.
AWEC PR 023 to INTERMOUNTAIN
Reference Darrington Exhibit 11, Line 34: Please explain why the ITC Amortization is an
increase to income tax expense.

AWEC’S FIRST SET OF
PRODUCTION REQUESTS 7 JANUARY 9, 2023
TO INTERMOUNTAIN
DATED at Portland, OR, this 9th day of January 2023.
_____________________________
Chad M. Stokes, OSB No. 004007
Attorneys At Law
1455 SW Broadway, Suite 1500
Portland, OR 9701
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Alliance of Western Energy
Consumers
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9'" DAY OF JANUARY 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF AWEC 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 - REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702 BOISE, ID 83702
BOISE ID 83707 EMAIL: [e-mail]
E-MAIL: [e-mail] [e-mail]
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ATTORNEY FOR IDAHO IDAHO CONSERVATION LEAGUE,
CONSERVATION LEAGUE ENERGY ASSOC.
710 N. 6TH ST. BOISE, ID 83702 710 N. 6TH ST
EMAIL: [e-mail] BOISE, ID 83702
EMAIL: [e-mail]
_________________________
Chad M. Stokes
Attorneys At Law
1455 SW Broadway, Suite 1500
Portland, OR 97201
Phone: [phone]
Fax: [phone]
[e-mail]

Attorneys for Alliance of Western Energy
Consumers