20230120INT to Staff Nos. 19 26 27 31 38 42 43.pdf

RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 3
Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR NATURAL GAS SERVICE IN
THE STATE OF IDAHO
Case No. INT-G-22-07
INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF
In response to the First Production Request of the Commission Staff to Intermountain
Gas Company dated December 16, 2022, Intermountain Gas Company, (“Intermountain,”
“Applicant,” or “Company”), submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email. Confidential
responses and documents are subject to the protective agreement in this case, and are available
for download using a password-protected link that will be provided separately by email. The
password will be provided in a third email.
DATED: January 20, 2023.
GIVENS PURSLEY LLP
Preston N. Carter
Attorney for Intermountain Gas Company
RECEIVED
Friday, January 20, 2023 4:11:06 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on January 20, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Chad M. Stokes
Cable Huston LLP
1455 SW Broadway, Ste. 1500
Portland, OR 97201
Attorneys for Alliance of Western Energy
Consumers
[e-mail]

Marie Callaway Kellner
710 N. 6th Street
Boise, ID 83702
Attorneys for Idaho Conservation League
[e-mail]

Brad Heusinkveld
Idaho Conservation League, Energy Assoc.
710 N. 6th Street
Boise, ID 83702
[e-mail]

Non-confidential responses only:
Darrell Early
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 3 OF 3

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
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.
RESPONSE NO. 19:
48.1655.17012: Prepaid Insurance; see RFP 19 Prepaid Insurance.xlsm. Any non-direct
invoice is allocated according to the Cost Allocation Manual, which can be found at RFP 3 Cost
Allocation Manual 2022.pdf.
48.1655.17013: AMA Prepaid Gas; see RFP 19 JP_CB Prepayment Tracking 22.xlsx.
During the months of April through October the Company purchases gas that is placed in
underground storage at Jackson Prairie and Clay Basin via Shell’s Asset Management
Agreement. This gas is paid for at the time of injection but will not be used until the heating
season, therefore, accounted for as a prepaid amount. November through March the Company
withdrawals the gas injected and expenses it based on the final injection WACOG multiplied by
number of therms withdrawn each month.
48.1659.17014: Postage Meter; see RFP 19 Prepaid Postage Meter.xlsx. The Company
purchases postage from Pitney Bowes for the IGC postage meter at the Boise General Office
each month. At the end of the month, the Company expenses the amount of postage used.
Anything leftover is considered a prepaid.
INT-G-22-07
IPUC DR 19
Page 1 of 2
48.1659.17017: Prepaid Software Maintenance; see RFP 19 Prepaid Software Mtc.xlsx.
Software costs are managed at a corporate level and allocated according to the Cost Allocation
Manual, which can be found at RFP 3 Cost Allocation Manual 2022.pdf.
48.1659.17018: Prepaid Neopost Postage Meter; see RFP 19 Prepaid Neopost Postage
Meter.xlsx. Neopost/Quadient postage meter. Cascade Natural Gas office staff determine costs
based off usage by employees of Intermountain, MDU, Cascade, etc.
INT-G-22-07
IPUC DR 19
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Allison Waldon/Lori
Blattner
REQUEST NO. 26:
Please provide all Audit Committee meeting minutes for the Company and its affiliates
for 2017 through 2022 to date.
RESPONSE NO. 26:
Intermountain does not have an audit committee. Intermountain objects to this Request to
the extent it seeks information from affiliates that do not relate to Intermountain.
Notwithstanding this objection, Intermountain is willing to work with Staff to provide specific
information needed for purposes of this case.
INT-G-22-07
IPUC DR 26
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Allison Waldon/Lori
Blattner
REQUEST NO. 27:
Please provide access to the Board of Directors' meeting minutes for each meeting in
2017 through 2022 to date. Please provide copies of the Board of Directors' materials distributed
for meetings from 2017 through 2022 to date. Please also include the same for the Compensation
Committee.
RESPONSE NO. 27:
As discussed with Staff, the minutes of the Board of Directors that related to
Intermountain will be provided to Staff for an onsite review. Intermountain is open to providing
materials related to specific meetings identified by Staff. Regarding the request for meeting
minutes and materials, Intermountain does not have a Compensation Committee, and
Intermountain objects to this request insofar as it requests information not related to
Intermountain. Notwithstanding this objection, Intermountain will work with Staff to provide
information needed for purposes of this case.
INT-G-22-07
IPUC DR 27
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cheryl Imlach/Jacob
Darrington
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.
RESPONSE NO. 31:
Please see the Excel file RFP 31 - Advertising Expense. The first tab of the file is a
summary of all advertising expenses. Tabs 48501 through 48573 show the amounts by business
unit and indicate if an attachment of a copy of the related advertising is provided. The
attachments are provided in the RFP 31 Attachments folder with individual folders for each
business unit which corresponds to a tab in the Excel file. Please note that this file includes
actual amounts through November 2022, whereas the Company’s filing included actuals through
September 2022. However, the Company is working on providing an update to its revenue
requirement with actuals through November. Additionally, the Company will provide an update
to both this response and the revenue requirement with actuals through December 2022 once the
information is available.
INT-G-22-07
IPUC DR 31
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad
(Capital), Ted Dedden (Operating)/ Patrick Darras (Capital), Jacob Darrington (Operating)
REQUEST NO. 38:
Please provide copies of the monthly, quarterly, and annual comparison of operating and
capital budget to actual expenditures for 2017 through 2022 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.
RESPONSE NO. 38:
Please see “RFP 38 Capital Budget Variances.xlsx” for a comparison of the capital
budget to actual expenditures for 2017 through November 2022. A separate tab for each year is
included in this file. Within each tab the actual to budget comparison is presented by month and
in total for the year. Explanations for total year variances greater than $1 million have been
provided.
Please see RFP 38 Annual/Monthly/Qtr O&M pdf documents that offer explanations for
material O&M variances compared with Plan for 2017 through 2022 to date.
INT-G-22-07
IPUC DR 38
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick Darras
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.
RESPONSE NO. 42:
Please see “RFP 42 – Capital Projects 2015-2021.xlsx”. Due to the volume of
information, some details are limited to projects, excluding blanket funding projects, greater than
$1 million. Funding projects that were approved in the budget, but that received no charges have
been included at the bottom of the spreadsheet (see explanation in cell Y1218).
INT-G-22-07
IPUC DR 42
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad
REQUEST NO. 43:
Please provide a detailed Excel file of the 2022 capital expenditure budget
including 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 (if started prior to 2022), target completion date, actual completion date (if completed
in 2022), 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.
RESPONSE NO. 43:
Please see “RFP 43 – Capital Expenditures 2022.xlxs”. Due to the volume of
information, some details are limited to projects, excluding blanket funding projects, over $1
million. The data presented includes all budget and non-budget projects to agree to total capital
expenditures through November 2022.
INT-G-22-07
IPUC DR 43
Page 1 of 1