20230201INT to AWEC.pdf

RESPONSES TO AWEC’S FIRST PRODUCTION REQUESTS PAGE 1 OF 3
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[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 ALLIANCE OF WESTERN
ENERGY CONSUMERS’ FIRST SET OF
PRODUCTION REQUESTS

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Alliance of Western Energy Consumers’ (“AWEC”) First Set of Production
Requests to Intermountain Gas Company dated January 10, 2023, 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: February 1, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
Wednesday, February 1, 2023 3:40:24 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO AWEC’S FIRST PRODUCTION REQUESTS PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 1, 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]

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]

RESPONSES TO AWEC’S FIRST PRODUCTION REQUESTS 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 ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Patrick Darras
REQUEST NO. 1:
Please describe Cascade’s capitalization policy and provide any documentation
supporting the policy, including capitalization thresholds and other requirements for an
expenditure to be capitalized versus expensed.
RESPONSE NO. 1:
Please see the Company’s capital expenditures and fixed asset policy, AWEC PR 1
Capital Expenditures and Fixed Assets Policy.pdf.
INT-G-22-07
AWEC PR 1
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 2:
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.
RESPONSE NO. 2:
The Company is targeting a late February timeframe for providing an update to the
revenue requirement based on actuals through December 2022.
INT-G-22-07
AWEC PR 2
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington
REQUEST NO. 3:
Pleas provide a copy of the 2021 IRP and all workpapers supporting the IRP.
RESPONSE NO. 3:
Please see the folder AWEC PR 3 for the files related to the 2021 IRP.
INT-G-22-07
AWEC PR 3
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ron Amen/Ron
Amen
REQUEST NO. 4:
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.
RESPONSE NO. 4:
No. Mr. Amen does not contend that there is a 100% probability that each and every firm
large volume customer will be using its full maximum daily firm quantity on a design day.
However, because Intermountain must provide for each LV-1 customer’s full firm contract
volume on any given day, including a design day, it is appropriate that the full contract volume
be considered in the design day calculation. As indicated on p. 16 of Mr. Amen’s testimony, this
is consistent with the treatment of the LV-1 class customers for system planning purposes in
Intermountain’s most recent Integrated Resource Plan.1 Because Intermountain must plan to
serve the full volume of LV-1 load, and must make investments and incur costs to ensure that its
system is capable of delivering the full firm contracted daily quantity on any given day, it is
appropriate to include the full firm contract quantity in the calculation of the design day and to
consider the full contract quantity of LV-1 customers for purposes of cost allocation.
1 Intermountain Gas Company, Integrated Resource Plan 2021- 2026, at p. 126.
INT-G-22-07
AWEC PR 4
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Chris Mickelson/Ron Amen
REQUEST NO. 5:
Please provide the actual peak day volumes for each rate class and rate schedule for each
year over the period 2016 through 2022, inclusive.
RESPONSE NO. 5:
Intermountain doesn’t currently track ‘actual peak day’ for each rate class, especially
core market (Residential and General Service), and will not have these capabilities for all rate
classes until the Company’s Fixed Network System is fully installed. Intermountain does track
‘actual peak day’ for industrial classes which represent Large Volume and Transportation
classes. However, the peak day is set using the system’s peak day, not that of individual rate
classes. The following peak day sendout table below shows the information for 2016 to 2022:
Calendar
Year
Gas
Peak
Day
Degree
Day
Core
Market
(mmbtu)
Large
Volume
(mmbtu)
Transport
Interruptible
(mmbtu)
Transport
Firm
(mmbtu)
Total
System
(mmbtu)
2016
Dec.
18 57 322,013 2,957 18,048 103,726 446,814
2017 Jan. 6 70 371,193 1,018 21,142 102,986 496,339
2018 Dec. 5 47 281,031 2,078 16,508 110,502 410,119
2019 Jan. 1 49 285,386 1,794 13,975 101,488 402,643
2020
Dec.
29 43 282,369 2,200 20,918 97,567 403,054
2021
Dec.
31 52 302,937 2,841 20,773 95,082 421,633
2022
Dec.
22 57 389,726 2,842 25,497 105,711 523,776
INT-G-22-07
AWEC PR 5
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Min Park/Lori Blattner
REQUEST NO. 8:
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.
RESPONSE NO. 8:
Please see the Excel file AWEC PR 8 – Avg Daily Temps for average daily temperatures
for each weather station over the period 2016 through 2022.
INT-G-22-07
AWEC PR 8
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Eric Wood/Jacob Darrington
REQUEST NO. 9:
Please state the last time that Intermountain experience a design day.
RESPONSE NO. 9:
Intermountain established its design day during its Integrated Resource Planning (“IRP”)
process. As outlined in the 2021 IRP, Intermountain engaged the services of Dr. Russell Qualls,
Idaho State Climatologist, to perform a review of the methodology used to calculate design
weather, and to provide suggestions to enhance the design weather planning. Dr. Qualls assisted
Intermountain in developing a method to calculate probability-derived peak HDD values.
Intermountain used Dr. Qualls’ exceedance probability results to select the company-wide 50
year probability event, which is a 78 heating degree day (“HDD”). Intermountain experienced a
system-wide design day in December 1990 of 81 HDD. The Company also experienced a near-
design day in January 2017 with a system-wide 70 HDD.
INT-G-22-07
AWEC PR 9
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Chris Mickelson/Ron Amen
REQUEST NO. 10:
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.
RESPONSE NO. 10:
The average daily usage value of 113,762 therms was calculated by taking the twelve-
month test-year period normalized therms for the T-3 rate class of 41,523,144 therms and
dividing by 365 days in the test year. The test year therms, which summed to 41,523,144 therms
for the T-3 rate class, were based on 9 months of actuals through September 2022 and 3 months
of forecast data from October through December 2022. As mentioned within Mr. Darrington’s
testimony, all forecast information within the Company’s rate case will be updated with actuals
for October through December 2022, once the Company’s 2022 books are closed.
The Company notes that the quotation in the Request above appears to have some
extraneous characters. The actual quote from Amen Direct at 17:2-4 is “The average daily usage
for the T-3 customers was 113,762 therms for the test year twelve-month period ending
December 31, 2022.”
INT-G-22-07
AWEC PR 10
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ron Amen/Ron
Amen
REQUEST NO. 11:
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.
RESPONSE NO. 11:
Similar to Mr. Amen’s previous response to Request No. 4, the full maximum daily firm
quantity should be used to determine the peak day requirements for the T-4 rate class because
Intermountain must plan to serve the full firm contractual volume of the T-4 load, and must
make investments and incur costs to ensure that its system is capable of delivering the full firm
contracted daily quantity on any given day, including a design day. As indicated on p. 16 of Mr.
Amen’s testimony, this is consistent with the treatment of the T-4 class customers for system
planning purposes in Intermountain’s most recent Integrated Resource Plan. For these reasons, it
would not be reasonable to use the average daily throughput as the peak day requirement for the
T-4 rate class.
INT-G-22-07
AWEC PR 11
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ron Amen/Ron
Amen
REQUEST NO. 12:
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.
RESPONSE NO. 12:
No. Transportation customers cannot call on the referenced storage facilities to deliver
gas to serve their requirements during periods of high prices or peak demands. However, the
storage facilities do provide important indirect benefits to T-4 customers. Storage is an integral
component of Intermountain’s gas system to ensure that there is sufficient gas to supply firm
customers and to preserve sufficient capacity and deliverability integrity of the system. Sufficient
pressure on the system, provided in peak demand situations by storage resources, ensures that the
transportation customers’ gas deliveries to the Company’s city gates can be delivered to the
customers’ facilities. T-4 customers benefit from storage as a means to preserve system integrity
and reliability in peak demand situations; therefore, it is appropriate that T-4 customers receive
an allocation of costs to maintain and make ready to deploy system storage.
INT-G-22-07
AWEC PR 12
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 14:
Reference Nygard, Exhibit 1 Page 3: Please provide an updated version of the referenced
table with the actual cost of the forecast 2022 issuances.
RESPONSE NO. 14:
Please see AWEC PR 14 Long-Term Debt Capital.xlsx.
INT-G-22-07
AWEC PR 14
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 15:
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.
RESPONSE NO. 15:
Please see AWEC PR 15-Dividends.pdf and AWEC PR 15-Equity Infusions.pdf.
INT-G-22-07
AWEC PR 15
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington
REQUEST NO. 16:
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.
RESPONSE NO. 16:
Intermountain is not requesting a working capital allowance in this case.
INT-G-22-07
AWEC PR 16
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington
REQUEST NO. 17:
Reference Darrington Exhibit 3: Please provide actual results of operations for calendar
year 2021.
RESPONSE NO. 17:
Please see the response to AWEC Request No. 13 for a copy of the Company’s 2021
income statement.
INT-G-22-07
AWEC PR 17
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jessica
Anderson/Jacob Darrington
REQUEST NO. 20:
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.
RESPONSE NO. 20:
Darrington Exhibit 11, Line 18 represents the Company’s non-plant excess deferred
income taxes which are being amortized over a 10-year period. The non-plant excess deferred
taxes were calculated and approved in Case No. GNR-U-18-01, Order No. 34073.
These excess deferred income taxes originated from the deferred tax balances associated
with customer advances and uniform capitalization. These excess deferred income taxes
originated from deferred tax assets, as opposed to plant-related excess deferred income taxes
which originated from deferred tax liabilities.
The amortization of excess deferred income taxes, originating from deferred tax assets
result in tax expense (increasing tax expense), whereas the amortization of excess deferred
income taxes originating from deferred tax liabilities result in tax benefit (decreasing tax
expense).
INT-G-22-07
AWEC PR 20
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jessica
Anderson/Jacob Darrington
REQUEST NO. 23:
Reference Darrington Exhibit 11, Line 34: Please explain why the ITC Amortization is an
increase to income tax expense.
RESPONSE NO. 23:
While preparing its response to this data request, the Company found that it inadvertently
forgot to include the estimated amount of investment tax credit (ITC) generated in 2022 on
Darrington Exhibit 10, Line 50. To comply with IRS normalization rules, the ITC generated in
2022 should be netted with the amount on Darrington Exhibit 11, Line 22 (or cell C34 in the
Excel version) to produce a reduction to income tax expense. This correction will be made, and
an updated yearend value will be provided, when the Company files an update to its revenue
requirement model in late February 2022.
INT-G-22-07
AWEC PR 23
Page 1 of 1