20230126Staff 72-74 to INT.pdf

CLAIRE SHARP O
DEPUTY ATTORNEY GENERAL u i.i eIDAHOPUBLICUTILITIESCOMMISSIONni·i J
PO BOX 83720
BOISE,IDAHO 83720-0074 SON
[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-22-07AUTHORITYTOINCREASEITSRATESAND)CHARGES FOR NATURAL GAS SERVICE IN )FOURTH PRODUCTIONTHESTATEOFIDAHO)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,FEBRUARY 16,2023.
This Production Request is to be considered as continuing,and Intermountain Gas
Company is requested to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FOURTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l JANUARY 26,2023
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.72:Regarding the Company's response to Production Request No.12,
please break down the provided Excel sheet further by includingthe followinginformation
within each category (Admin,Capital,Customer Account,Sales,etc.),broken down by
employee category (i.e.,officer,exempt,non-exempt,and union)through the end of 2022:
a.Paid time-off,
b.Overtime,
c.Bonuses,
d.Incentive pay,
e.Overheads for pension and union,
f.Overheads for benefits union,and
g.Overheads for payroll taxes
REQUESTNO.73:In the Company's response to Production Request No.14,the
Company stated that it eliminated the traditional medical plan option because the plan became
cost prohibitive.Please provide the costs of the medical plan paid by the Company from 2017
through 2022 and any documents provided to employees that explained their medical benefits
between 2017 through 2022.
REQUESTNO.74:In the Company's response to Production Request No.14,the
Company lists "Business Travel"as a benefit to "all regular employees working a minimum of
30 hours per week".Please provide the Company policy documents describing the Business
Travel benefits for employees.
DATED at Boise,Idaho,this day of January 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umise:prodreq/intg22.7csle prod req 4
FOURTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 JANUARY 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF JANUARY 2023,SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOINTERMOUNTAINGASCOMPANY,IN CASENO.INT-G-22-07,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTERDIR-REGULATORYAFFAIRS GIVENS PURSLEY LLPINTERMOUNTAINGASCO601WBANNOCKSTPOBOX7608BOISEID83702BOISEID83707E-MAIL:[e-mail]-MAIL:[e-mail] [e-mail]
CHAD M STOKES
CABLE HUSTON LLP
1455 SW BROADWAY
STE 1500
PORTLANDOR 97201
E-MAIL:[e-mail]
[e-mail]
S RE
CERTIFICATE OF SERVICE