20230123AWEC to INT 24-62.pdf

AWEC’S SECOND SET OF
PRODUCTION REQUEST 1 JANUARY 23, 2013
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 PUBLIC UTILITY COMMISSION

OF IDAHO

INT-G-22-07

In the Matter of

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

ALLIANCE OF WESTERN ENERGY
CONSUMERS’ SECOND 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 13, 2023.

DEFINITIONS

1. “Company” or “Intermountain” or “IGC” 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
RECEIVED
Monday, January 23, 2023 1:25:25 PM
IDAHO PUBLIC
UTILITIES COMMISSION

AWEC’S SECOND SET OF
PRODUCTION REQUEST 2 JANUARY 23, 2013
TO INTERMOUNTAIN

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.

“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

AWEC’S SECOND SET OF
PRODUCTION REQUEST 3 JANUARY 23, 2013
TO INTERMOUNTAIN

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 SECOND SET OF
PRODUCTION REQUEST 4 JANUARY 23, 2013
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

AWEC’S SECOND SET OF
PRODUCTION REQUEST 5 JANUARY 23, 2013
TO INTERMOUNTAIN

preparer; (d) name of each person who received the document; and (e) the reason for
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 SECOND SET OF
PRODUCTION REQUEST 6 JANUARY 23, 2013
TO INTERMOUNTAIN

DATA REQUESTS

AWEC PR 024 to INTERMOUNTAIN
Please provide transaction level detail supporting each operating expense by FERC account
through the most recent month available. If the entirety of 2022 is not yet available, please
update this request once it becomes available. Please provide detail showing all fields stored
in IGC’s accounting system including date, vendor, amount, detailed description,
memorandum, and any other fields stored in IGC’s accounting system.

AWEC PR 025 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 23, “Attachment CONFIDENTIAL
RFP 23 Legal Detail,” Tab “MDUR Cross Charges”: Please explain why the amounts in
the following cells are appropriately allocated to Idaho ratepayers:
a. Q5
b. Q17
c. Q18
d. Q21
e. Q23
f. Q24
g. Q27
h. Q39:Q41
i. Q62
j. Q113
k. Q126

AWEC PR 026 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 23, “Attachment CONFIDENTIAL
RFP 23 Legal Detail,” Tab “MDUR Cross Charges”: Please explain why the amounts in
cells “Q336:Q339” are not partially allocated to any other intercorporate entity.

AWEC PR 027 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “Exhibit 2”: Please provide unadjusted and adjusted operating results for
the 12-months ending September 30, 2022.

AWEC PR 028 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “WP - Industrial Migration”: Please provide a more detailed explanation
for why it was necessary and appropriate to set the amounts in cells “G99” and “I124” to
zero.

AWEC PR 029 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, tab “WP - Deferred GRC Costs”: Please provide a docket and order

AWEC’S SECOND SET OF
PRODUCTION REQUEST 7 JANUARY 23, 2013
TO INTERMOUNTAIN

reference where the Commission approved the deferral of GRC costs from Docket No. INT-
G-16-02.

AWEC PR 030 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 7: Is IGC seeking to defer the rate case
expenses identified in the referenced response, or include them as a test period expense?

AWEC PR 031 to INTERMOUNTAIN
Please provide a corporate entity chart detailing each entity at least 5% owned, directly or
indirectly, by MDU Resources Group, Inc. along with the percentage ownership of each
entity, including ownership percentages for subsidiary entities owned by other subsidiary
entities.

AWEC PR 032 to INTERMOUNTAIN
Please provide financial statements for each entity at least 5% owned, directly or indirectly,
by MDU Resource Group Inc., including a balance sheet, income statement, statement of
cashflows and statement of retained earnings.

AWEC PR 033 to INTERMOUNTAIN
Please identify the number of employees for each entity at least 5% owned, directly or
indirectly, by MDU Resource Group Inc.

AWEC PR 034 to INTERMOUNTAIN
Please identify each intercorporate cross charge or allocation included in IGC revenue
requirement from MDU Resource Group Inc. and provide workpapers supporting the
calculation of the allocated amount.

AWEC PR 035 to INTERMOUNTAIN
Please provide IGC’s GAAP trail balance for calendar years 2020, 2021 and 2022.

AWEC PR 036 to INTERMOUNTAIN
Please provide copies of IGC’s pro forma federal income tax returns for tax years 2018,
2019, 2020 & 2021.

AWEC PR 037 to INTERMOUNTAIN
To the extent not provided in response to Staff Production Request 37, please provide a
schedule showing all dues, contributions and donations included in the utility’s regulatory
expense accounts for the test period period by FERC account. For any MDUR cross charge
items from another utility please separately detail and describe each contribution or donation
and please also describe how the item benefits Idaho ratepayers.

AWEC’S SECOND SET OF
PRODUCTION REQUEST 8 JANUARY 23, 2013
TO INTERMOUNTAIN

AWEC PR 038 to INTERMOUNTAIN
Please identify all lobbying expenses included in revenue requirement and provide an
explanation for how those costs benefit Idaho ratepayers.

AWEC PR 039 to INTERMOUNTAIN
Please identify all officer’s life insurance costs included in revenue requirement and provide
an explanation for how those costs benefit Idaho ratepayers.

AWEC PR 040 to INTERMOUNTAIN
Reference IGC’s response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022”: Please provide workpapers, in Excel format with all formulas
and links intact, used to calculate each of the allocation factors identified in the referenced
cost allocation manual and effective in calendar year 2022.

AWEC PR 041 to INTERMOUNTAIN
Reference IGC’s response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022,” Page 12: Please explain why it is appropriate to consider a
Montana Dakota Customer that receives both gas and electric services as a single customer
in the customer allocation factor.
AWEC PR 042 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 3, Attachment “RFP 3 Cost Allocation
Manual 2022,” Page 12: Does a combination customer of Montana Dakota receive a
separate bill for gas and electric services or are both services invoiced through a single bill.

AWEC PR 043 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 3, Attachment “RFP 3 Cost Allocation
Manual 2022,” Page 12: Does a combination customer of Montana Dakota receive a
separate bill for gas and electric services or are both services invoiced through a single bill.

AWEC PR 044 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 11: Please identify any penalties or
fines included in an MDUR cross charge in the test period and explain how the item was
handled for purposes of calculating revenue requirement.

AWEC PR 045 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)” Tab “WP - Salary Expense Adjustment”: Please reconcile the 2022 amounts
in the referenced tab to the amounts provided in response to Staff Production Request 12.

AWEC PR 046 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)” Tab “WP - Salary Expense Adjustment”: Do the 2022 amounts in the
referenced tab include capitalized labor? Please explain.

AWEC’S SECOND SET OF
PRODUCTION REQUEST 9 JANUARY 23, 2013
TO INTERMOUNTAIN

AWEC PR 047 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)” Tab “WP - Salary Expense Adjustment”: For each category of labor expense
in the referenced tab, please provide detail of the 2022 expenses using the same categories
as provided in response to Staff Production Request 12.

AWEC PR 048 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)” Tab “WP - Salary Expense Adjustment”: Do the 2022 amounts in the
referenced workpaper include labor costs associated with the Boise Campus and customer
service center which are reallocated to other utilities? Please explain how such amounts are
handled in the referenced workpaper.

AWEC PR 049 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 15: Please provide accounting
workpapers detailing the calculation of pension expenses for the test period.

AWEC PR 050 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 18: Are the Plant Held for Future Use
balances identified in the referenced request included in rate base in this proceeding?

AWEC PR 051 to INTERMOUNTAIN
Please provide the gross plant and accumulated depreciation for the Customer Care and
Billing software as of December 31, 2022.

AWEC PR 052 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 33: Please provide additional
information regarding the activity at the Nampa LNG Facility in 2022, including the
following:
a. Root cause analyses for the leak and 2021 outage.
b. Total O&M expense booked for repairs.
c. Initial capital project justification and budget documentation
d. All work-orders and work-order changes associated with the project.
e. Line item detailed of the final project costs.
f. A description for how the expenditures are split between ratepayers and
shareholders.

AWEC PR 053 to INTERMOUNTAIN
Reference IGC’s response to Staff Production Request 44: Please provide IGC’s most
recent lead lag study.

AWEC PR 054 to INTERMOUNTAIN
Please provide a roll-forward of accumulated depreciation balances by FERC account for
each year 2018 through 2022. Please detail the beginning balance, all incremental

AWEC’S SECOND SET OF
PRODUCTION REQUEST 10 JANUARY 23, 2013
TO INTERMOUNTAIN

depreciation expenses, retirements, transfers, and other adjustments that impacted the
depreciation reserves balance in for each of the referenced years.

AWEC PR 055 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 10: Please identify the FERC account
that the referenced credit card charges are assigned.

AWEC PR 056 to INTERMOUNTAIN
Reference IGC response to Staff Production Request 10: Please provide a receipt or any
other available accounting documentation for the following transaction reference numbers:
a. 24692162063100169237131
b. 24692162063100169245324
c. 24692162063100169236984
d. 24717052075130758179212
e. 74798262285400156898509
f. 24733092235036818536981
g. 74798262285400156898681
h. 24733092263036818714203
i. 74798262285400156898764
j. 24692162314104338302278
k. 24137462288200209309290
l. 24692162335100390132814
m. 24445002167300419993326
n. 24692162161100629234083
o. 24692162178100421648754
p. 24492152223852021799563

AWEC PR 057 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “WP - Depreciation – Forecast”: Please provide workpapers, including
detail of the plant balances and depreciation percentages, used to calculate deprecation
expenses in the referenced workpaper.

AWEC PR 058 to INTERMOUNTAIN
Please provide IGC’s most recently approved deprecation study, along with a summary table
in Excel format detailing all the approved depreciation parameters and associated plant
balances.

AWEC PR 059 to INTERMOUNTAIN
Please provide detail of IGC’s actual month depreciation expense for the test period,
including detail of the plant balances and the associated deprecation percentages used.

AWEC’S SECOND SET OF
PRODUCTION REQUEST 11 JANUARY 23, 2013
TO INTERMOUNTAIN

AWEC PR 060 to INTERMOUNTAIN
Please provide monthly unbilled revenues balances over the period December 1, 2021
through December 31, 2022 and explain how unbilled revenues are handled in the
calculation of revenue requirement.

AWEC PR 061 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “WP - Income Statement”, Cell “N11”: Please reconcile the
$224,699,659 of retail revenue in the referenced cell with retail revenues of $225,199,717
calculated in Tab “WP - Revenue Detail”

AWEC PR 062 to INTERMOUNTAIN
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “Exhibit 3”, Cell “C12”: Please reconcile the Total Operating Revenues
of $218,567,793 in the referenced tab to Total Operating Revenues of WP - Income
Statement $218,252,536 in Tab “WP - Income Statement,” cell “N21.”

DATED at Portland, OR, this 23rd 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 23rd 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]

DARRELL EARLY WIL GEHL
ED JEWELL ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEY BOISE CITY DEPT. OF PUBLIC WRKS
BOISE CITY ATTORNEY’S OFFICE 150 N. CAPITOL BLVD
150N. CAPITOL BLVD P.O. BOX 500
P.O. BOX 500 BOISE, IDAHO 83701
BOISE, IDAHO 83701-0500 EMAIL: [e-mail]
EMAIL: [e-mail]
[e-mail]
[e-mail]

__________________________
Chad M. Stokes
Attorneys At Law
1455 SW Broadway, Suite 1500
Portland, OR 9701
Phone: [phone]
Fax: [phone]
[e-mail]

Attorneys for Alliance of Western Energy
Consumers