20230203Staff 86-92 to INT.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 8 ON
[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-22-07
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR NATURAL GAS SERVICE IN )SIXTH 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 Attorney General,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,FEBRUARY 24,2023.
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.
SIXTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l FEBRUARY 3,2023
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.86:Please answer the followingabout blanket funding projects:
a.Please provide the Company's policy for how a project is classified as a blanket
fundingproject.
b.If the Company does not have a policy,how does it determine which project will
be considered blanket funding?
c.Please explain the Company's policy for handling blanket funding projects that
exceed $100,000 in a given year.
d.Please explain the Company's policy for handling blanket funding projects that
consistently exceed $100,000annually.
REQUESTNO.87:In Witness Darras testimony,he explains that blanket funding
projects are typically used for projects under $100,000.Darras Direct at 10.Please reconcile all
blanket funding projects that are over $100,000 with the Company's Response to Staff
Production Request No.42.Please provide supporting Excel worksheets with formulas intact.
REQUESTNO.88:Please reconcile all the capital IT projects provided in Company
Responses to Staff Production Request Nos.42,52,and 54 and in the Company's Direct
Testimony of Boese and Gilchrist.Please provide supporting Excel worksheets with formulas
mtact.
REQUESTNO.89:Staff is unable to reconcile the Company's responses to Production
Requests Nos.42 and 43 with the projects and final project costs identified in Company Witness
Darras's testimony.Please reconcile or provide amended responses to the Production Requests
that can be correlated with the testimony and the Gas Plant in Service.
SIXTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY 3,2023
REQUESTNO.90:For each of the capital projects detailed by Company Witness
Darras in his testimony,please provide a worksheet that details all costs associated with each
project similar to the Company's response to Production Request No.48,part b.For any ledger
line item in those worksheets that exceed $750,000,please provide the itemized details that
comprise that line item.
REQUESTNO.91:Company Witness Darrington's Exhibit No.13 lists the monthly
average Gas Plant in Service.Please provide the underlyingdetails for the December 2022 Gas
Plant in Service.Please reconcile that with the capital projects detailed by Company Witness
Darras in his testimony.Please provide supporting worksheets.
REQUESTNO.92:On page 34 of his testimony,Company Witness Darras states that
work on the 12"Cloverdale back feed and Kuna Gate Upgrade project is "forecasted to be
completed in late 2022."Please provide accounting details on how these projects (or its
constituent parts)has been recorded with res ect to gas plant in service for the test year.
DATED at Boise,Idaho,this day of February 2023.
Cla a
Deputy AttorneyGeneral
i:umisc:prodreq/intg22.7csle prod req 6
SIXTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 FEBRUARY 3,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF FEBRUARY 2023,
SERVED THE FOREGOING SIXTH PRODUCTION REQUESTOF THE
COMMISSION STAFF 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 83707 E-MAIL:[e-mail]
E-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]
SECRETARY
CERTIFICATE OF SERVICE