20230213INT to AWEC.pdf

RESPONSES TO AWEC’S SECOND 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’ SECOND SET OF
PRODUCTION REQUESTS

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Alliance of Western Energy Consumers’ (“AWEC”) Second Set of Production
Requests to Intermountain Gas Company dated January 23, 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 13, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
2023 February 13, 2:59PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO AWEC’S SECOND PRODUCTION REQUESTS PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 13, 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 SECOND 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
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 24:
Please provide transaction level detail supporting each operating expense by FERC
account through the most recent month available. If the entirety of 2022 is not yet available,
please update this request once it becomes available. Please provide detail showing all fields
stored in IGC’s accounting system including date, vendor, amount, detailed description,
memorandum, and any other fields stored in IGC’s accounting system
RESPONSE NO. 24:
Please see “AWEC PR 24 2022 Op Exp But Includes All OM.xlsx”. This file includes
the entirety of 2022.
INT-G-22-02
AWEC PR 24
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kirsti Hourigan and
Nathaniel Monk/ Kirsti Hourigan and Nicole Kivisto
REQUEST NO. 25:
Reference IGC response to Staff Production Request 23, “Attachment CONFIDENTIAL
RFP 23 Legal Detail,” Tab “MDUR Cross Charges”: Please explain why the amounts in the
following cells are appropriately allocated to Idaho ratepayers:
a.Q5
b.Q17
c.Q18
d.Q21
e.Q23
f.Q24
g.Q27
h.Q39-Q41
i.Q62
j.Q113
k.Q126
RESPONSE NO. 25:
Items a and h are related to Company retirement plans. Legal fees are incurred when the
plans take certain actions such as making formal amendments, conducting audits, and providing
summary plan descriptions to participants. Outside legal counsel is retained to ensure all of these
actions are done correctly and completely and to ensure the plan does not lose its tax-exempt
INT-G-22-02
AWEC PR 25
Page 1 of 2
status. Legal review protects MDUR and its subsidiaries from costs that may be incurred if any
of these actions were performed incorrectly.
Item c is related to the MDU Resources, Inc (“MDUR”) audit, which is performed by
Deloitte & Touche LLP (“Deloitte”). The cost of the Deloitte audit is allocated across the MDUR
entities as explained in Response to AWEC Request No. 25. The financial audit is important in
ensuring accurate financial records of the Company for Idaho ratepayers.
Items g, j and k are related to enforcing the MDUR trademark. As an administrative cost
of MDUR, it is allocated across the MDUR entities. As a subsidiary of MDUR, Intermountain
(and the Company’s customers) benefits from the economies of scale of being part of a larger
organization. In return for that benefit, however, Intermountain does share in the costs of doing
business that are incurred at the MDUR level.
INT-G-22-02
AWEC PR 25
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington.
REQUEST NO. 27:
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “Exhibit 2”: Please provide unadjusted and adjusted operating results for the
12-months ending September 30, 2022.
RESPONSE NO. 27:
The Company does not have the requested information. For context, the Company does
not report on the 12 months ending September 30, 2022 and has not calculated unadjusted and
adjusted operating results for that time period.
INT-G-22-02
AWEC PR 27
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 29:
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, tab “WP - Deferred GRC Costs”: Please provide a docket and order reference
where the Commission approved the deferral of GRC costs from Docket No. INT-G-16-02.
RESPONSE NO. 29:
The Commission approved the establishment of a regulatory asset to defer external rate
case costs associated with Case No. INT-G-16-02 in Case No. INT-G-15-03, Order No. 33432.
INT-G-22-02
AWEC PR 29
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Nicole Kivisto
REQUEST NO. 33:
Please identify the number of employees for each entity at least 5% owned, directly or
indirectly, by MDU Resource Group Inc.
RESPONSE NO. 33:
In Response to IPUC Staff Request No. 28, Intermountain provided the annual report and
proxy statements for the years 2017-2021. For 2021, the employee count for each entity can be
found on page eight within the annual report. See the employee count table below which was
excerpted from the 2021 annual report:
The 2022 annual report has not been provided as it has not been approved at the time of
submittal. Intermountain will supplement the Response to IPUC Staff Request No. 28 to provide
the 2022 annual report and proxy statement once approved.
INT-G-22-02
AWEC PR 33
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 40:
Reference IGC’s response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022”: Please provide workpapers, in Excel format with all formulas and
links intact, used to calculate each of the allocation factors identified in the referenced cost
allocation manual and effective in calendar year 2022.
RESPONSE NO. 40:
In addition to the workpapers provided in Response to Staff Production Request No. 3,
please see AWEC PR 40 2022 IT Allocation Worksheet.xlsx.
INT-G-22-02
AWEC PR 40
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Nicole
Kivisto
REQUEST NO. 41:
Reference IGC’s response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022,” Page 12: Please explain why it is appropriate to consider a Montana
Dakota Customer that receives both gas and electric services as a single customer in the
customer allocation factor.
RESPONSE NO. 41:
The customer service center is equipped to handle both electric and gas customers, so
there is no incremental cost associated with assisting a combination customer. Therefore, each
customer is only counted once in the customer allocation factor calculation.
INT-G-22-02
AWEC PR 41
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Bradley Davidson/Nicole Kivisto
REQUEST NO. 42:
Reference IGC response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022,” Page 12: Does a combination customer of Montana Dakota receive a
separate bill for gas and electric services or are both services invoiced through a single bill.
RESPONSE NO. 42:
Combination customers at Montana Dakota receive a single bill showing their gas and
electric charges.
INT-G-22-02
AWEC PR 42
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Bradley Davidson/Nicole Kivisto
REQUEST NO. 43:
Reference IGC response to Staff Production Request 3, Attachment “RFP 3 Cost
Allocation Manual 2022,” Page 12: Does a combination customer of Montana Dakota receive a
separate bill for gas and electric services or are both services invoiced through a single bill.
RESPONSE NO. 43:
Combination customers at Montana Dakota receive a single bill showing their gas and
electric charges.
INT-G-22-02
AWEC PR 43
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 44:
Reference IGC response to Staff Production Request 11: Please identify any penalties or
fines included in an MDUR cross charge in the test period and explain how the item was handled
for purposes of calculating revenue requirement.
RESPONSE NO. 44:
There were no penalties or fines cross charged to the business units from MDUR in 2022.
INT-G-22-02
AWEC PR 44
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Craig Pulley/Kirsti
Hourigan
REQUEST NO. 49:
Reference IGC response to Staff Production Request 15: Please provide accounting
workpapers detailing the calculation of pension expenses for the test period.
RESPONSE NO. 49:
Accounting work papers are provided as requested. Included are the hours compensated
along with amounts paid to the Idaho Pipe Trades Trust during 2022.
INT-G-22-02
AWEC PR 49
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 50:
Reference IGC response to Staff Production Request 18: Are the Plant Held for Future
Use balances identified in the referenced request included in rate base in this proceeding?
RESPONSE NO. 50:
The Plant Held for Future Use balances are not included in rate base.
INT-G-22-02
AWEC PR 50
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 51:
Please provide the gross plant and accumulated depreciation for the Customer Care and
Billing software as of December 31, 2022.
RESPONSE NO. 51:
Please see “AWEC PR 51 – CCB NBV.xlsx” for the gross plant and accumulated
depreciation for the Customer Care and Billing software as of December 31, 2022.
INT-G-22-02
AWEC PR 51
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Russ Nishikawa/Lori
Blattner
REQUEST NO. 52:
Reference IGC response to Staff Production Request 33: Please provide additional
information regarding the activity at the Nampa LNG Facility in 2022, including the following:
a.Root cause analyses for the leak and 2021 outage.
b.Total O&M expense booked for repairs.
c.Initial capital project justification and budget documentation
d.All work-orders and work-order changes associated with the project.
e.Line item detail of the final project costs.
f.A description for how the expenditures are split between ratepayers and shareholders.
RESPONSE NO. 52:
a.The root causes of the 2021 LNG tank outage were due to a corrosion leak on the tank’s
outer shell and the beginning failure of the aluminum to stainless steel transition joint.
b.Total O&M expense booked for repairs is $14,888. Please note that this amount was
originally capitalized, but will be reclassified in the January 2023 general ledger from
plant in service to operation and maintenance expense in FERC 843.3 - maintenance of
gas holders.
c.A portion of the tank outage project was justified as capital expense due to the
replacement of existing equipment and the addition of new equipment. All replacements
and additions could only have been completed while the tank was out of service.
INT-G-22-02
AWEC PR 52
Page 1 of 3
d.Associated work orders are 288255 and 285448. Change Order (“CO”) files attached are
as follows. CO numbers not included below represent potential work that was
contemplated but that the Company decided not to pursue.
i.AWEC PR 52 - CO #1 - WO 285448: Procure 8” Transition Joint; estimated at
$19,437.75
ii.AWEC PR 52 - CO #1 - WO 288255: Servo Gauge and Temp Probe Addition
(related to ENRAF); estimated at $179,763
iii.AWEC PR 52 - CO #2 - WO 288255: Addition of OSHA Compliant Catwalk
Across Top of Tank; estimated at $255,300
iv.AWEC PR 52 - CO #4 - WO 288255: Upgrade LNG Tank Valves; estimated at
$177,577
v.AWEC PR 52 - CO #5 - WO 288255: Upgrade LNG Tank PSV’s; estimated at
$58,061
vi.AWEC PR 52 - CO #6 - WO 288255: LNG Inner Tank Inspection; estimated at
$75,000
vii.AWEC PR 52 - CO #7 - WO 288255: LNG Tank Cooldown Nozzle and Vent;
estimated at $138,649
viii.AWEC PR 52 - CO #10 - WO 288255: Perlite Top Off; estimated at $635,055
e.Please see the files AWEC PR 52 WO 285448 - Nampa LNG Tank Repair Capital Costs
and AWEC PR 52 WO 288255 - Nampa LNG Tank Repair Capital Costs for the final
project costs.
f.All costs associated with the Nampa LNG plant are included in rate base. The Nampa
LNG plant is important for system reliability as a supply resource in the event of very
INT-G-22-02
AWEC PR 52
Page 2 of 3
cold weather or extraordinary system issues. The testimony of Company Witness Lori
Blattner discusses in greater detail the benefits ratepayers derive from the Nampa LNG
plant. Nampa LNG plant costs were allocated among ratepayers according to Company
Witness Ron Amen’s Exhibit 2, Schedule 1, lines 12-14. The allocation percentages can
be found in Ron Amen’s Exhibit 2, Schedule 2 under the PDAY_F Demand Factor.
INT-G-22-02
AWEC PR 52
Page 3 of 3
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Lori Blattner/Lori
Blattner
REQUEST NO. 53:
Reference IGC’s response to Staff Production Request 44: Please provide IGC’s most
recent lead lag study.
RESPONSE NO. 53:
As noted in the Response to IPUC Staff Request No. 44, Intermountain is not requesting
working capital in the rate base in this case. The Company has not contracted for or conducted its
own lead lag study since the last general rate case in INT-G-16-02. In that case, the results of the
study were included as Adams Exhibit No. 34 and are attached here as “AWEC PR 53 Adams
Exhibit 34.pdf”.
INT-G-22-02
AWEC PR 53
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 54:
Please provide a roll-forward of accumulated depreciation balances by FERC account for
each year 2018 through 2022. Please detail the beginning balance, all incremental depreciation
expenses, retirements, transfers, and other adjustments that impacted the depreciation reserves
balance in for each of the referenced years.
RESPONSE NO. 54:
Please see “AWEC PR 54 – 2018-2022 Reserve Rollforward.xlsx” for a roll-forward of
the company’s reserve balances by FERC account. Each of the years requested are presented on
a separate tab.
INT-G-22-02
AWEC PR 54
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 55:
Reference IGC response to Staff Production Request 10: Please identify the FERC
account that the referenced credit card charges are assigned.
RESPONSE NO. 55:
Total credit card charges are charged to a clearing account 48.1844.1 - Credit
Card/Expense Report Clearing. The offsetting actual charges are coded to various FERC O&M
and Capital accounts as appropriate.
INT-G-22-02
AWEC PR 55
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 57:
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “WP - Depreciation – Forecast”: Please provide workpapers, including detail
of the plant balances and depreciation percentages, used to calculate deprecation expenses in the
referenced workpaper.
RESPONSE NO. 57:
The forecasted depreciation amounts come from the company’s PowerPlan forecast
module based on a forecast run in late August. Plant balances for the estimated depreciation
expense were based on July actual plant balances plus estimated additions and retirements for
each subsequent month. The company’s monthly depreciation expense is based on the prior
month’s ending plant balances.
AWEC PR 57 – Depreciation Forecast.xlsx presents the monthly plant balances and
depreciation percentages used to calculate the resulting forecasted depreciation.
INT-G-22-02
AWEC PR 57
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 58:
Please provide IGC’s most recently approved deprecation study, along with a summary
table in Excel format detailing all the approved depreciation parameters and associated plant
balances.
RESPONSE NO. 58:
Please see the files “AWEC 58 INT-G-21-01 Depreciation and Amortization Study” and
“AWEC 58 INT-G-21-01 Settlement Exhibit No. 1 – Summary of Depreciation and
Amortization Rates”. Both files were provided in Intermountain’s most recent depreciation case,
Case No. INT-G-21-01.
INT-G-22-02
AWEC PR 58
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 59:
Please provide detail of IGC’s actual month depreciation expense for the test period,
including detail of the plant balances and the associated deprecation percentages used.
RESPONSE NO. 59:
Please see “AWEC PR 59 – 2022 Monthly Depreciation Expense.xlsx” for the actual
month depreciation expense for 2022. The information presented includes the plant balances and
depreciation percentages. The company’s depreciation expense is calculated on the prior month’s
ending plant balance.
INT-G-22-02
AWEC PR 59
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 60:
Please provide monthly unbilled revenues balances over the period December 1, 2021
through December 31, 2022 and explain how unbilled revenues are handled in the calculation of
revenue requirement.
RESPONSE NO. 60:
Unbilled revenues are removed from the calculation of revenue requirement as part of the
adjustments made to test year operating revenues in Exhibit No. 5, Column (b), Line 3 of the
IGC Revenue Requirement Model. For more information on the removal of unbilled revenues
see Page 12 of Company Witness Jacob Darrington’s testimony. Please see Excel document
PR2 AWEC 60 Unbilled Rev Balances.xlsx for the monthly unbilled revenues balances over the
period December 1, 2021 through December 31, 2022.
INT-G-22-02
AWEC PR 60
Page 1 of 1