20230202Staff to INT (Fifth Set) 75-85.pdf

CLAIRE SHARP E.O
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION AN ÍÛ 52
PO BOX 83720
BOISE,IDAHO 83720-0074 SDOW(208)334-0357
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-22-07
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR NATURAL GAS SERVICE IN )FIFTH PRODUCTION
THE STATE OF IDAHO )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 23,2023.
This Production Request is to be considered as continuing,and Intermountain Gas
Company is requested to provide,by way of supplementary responses,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
telephonenumber of the record holder.
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 1 FEBRUARY 2,2023
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.75:Approximatelyhow many customer service representatives
("CSR's")are employed by the Customer Experience Team Center located in Meridian,Idaho?
REQUESTNO.76:How many CSR's work in the satellite office in Bismarck,North
Dakota?
REQUESTNO.77:Does the Customer ExperienceTeam Center provide customer
service for all utilities owned by MDU Resources Group,Inc.?
REQUESTNO.78:What are the operating hours of the Customer Experience Team
Center?
REQUESTNO.79:What hours (MountainTime),does the Customer Experience Team
take phone calls from Idaho customers?
REQUESTNO.80:Please explain the efforts put forth by the Company to promote the
Project Share,Project Warmth and Keep Kids Warm programs.
REQUESTNO.81:Please describe the types of advertising (radio,tv,bill insert,
welcome kit,etc.)that is conducted in Idaho to inform and educate customers about the
following:
a.Energy assistance and bill payment options;
b.Energy conservation;and
c.Winter Moratorium and the Winter Payment Plan.
In addition,please provide copies of any written brochures or documents sent or otherwise
provided to customers for each defined category listed in this question.
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY 2,2023
REQUESTNO.82:Please describe in detail the type of standard payment
plans/arrangements the Company offers its customers.
REQUESTNO.83:Please describe in detail the temporary alternative/modified
payment/plan arrangements the Company offered its customers in 2020 and 2021 due to
COVID-19.
REQUESTNO.84:Did the Company make any of the temporary alternative/modified
payment plan/arrangementa permanent offering?If no,please explain.
REQUESTNO.85:For each of the past three years (2020,2021 and 2022),how many
participants were under winter protection each year.Of that amount,how many participants
agreed to be placed on the winter payment plan and how many were unable to meet their
monthlypayment?
DATED at Boise,Idaho,this -day of February 2023.
Claire Sharp
Deputy AttorneyGeneral
i:umisc:prodreq/intg22.7cslc prod req 5
FIFTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 FEBRUARY 2,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2nd DAY OF FEBRUARY 2023,SERVED THE FOREGOING FIFTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOINTERMOUNTAINGASCOMPANY,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 LLPINTERMOUNTAINGASCO601WBANNOCKST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL:[e-mail]-MAIL:[e-mail] [e-mail]
CHAD M STOKES
CABLE HUSTON LLP
1455 SW BROADWAY
STE 1500
PORTLAND OR 97201
E-MAIL:[e-mail]
[e-mail]
CERTIFICATE OF SERVICE