20230208INT to Staff - Response to No. 48.pdf

RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF 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 THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Second Production Request of the Commission Staff to Intermountain Gas
Company dated December 29, 2022, submits the following supplemental response to Production
Request No. 48.
DATED: February 7, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
Tuesday, February 7, 2023 3:38:36 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO SECOND PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 7, 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]

Non-confidential responses only:
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 SECOND PRODUCTION REQUEST OF COMMISSION STAFF 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
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Lori
Blattner
REQUEST NO. 48:
On page 17 of Company Witness Blattner’s testimony, she explains how the Nampa
Liquefied Natural Gas (“LNG”) facility was out of service for repair due to a leak in the outer
shell LNG tank for most of 2021.
a)Please explain the accounting treatment the Company will use for the repair costs for the
Nampa LNG plant. Please provide Excel worksheets with formulas intact.
b)Please provide a worksheet that details all costs associated with the repair that are
included in this case. If not all costs are being included within this case, please explain
exclusions and accounting treatment that will be applied to them.
c)Please explain how repair costs will be allocated to utility customer classes and off
system sales customers. Please provide the percentage of costs that will be allocated to
each customer class.
SUPPLEMENTAL RESPONSE NO. 48:
Subsequent to filing the response for Request No. 48, the Company discovered that it had
inadvertently omitted an additional work order related to the LNG Tank Repair. Please see “RFP
48 REVISED – Nampa LNG Tank Repair Costs.xlsx”. The revised file contains two tabs. The
first tab contains the work order costs provided with the original response and remains
unchanged. The second tab includes the cost for the work order that was omitted. The majority of
costs associated with the additional work order were recorded to plant in service FERC subplant
account 363 – Measuring and Regulating, and the removal costs were recorded to accumulated
reserve.
INT-G-22-07
IPUC DR 48 - SUPPLEMENTAL
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