20230217INT to Staff Resp to RFP 72-74.pdf

RESPONSES TO FOURTH 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 FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF
Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Fourth Production Request of the Commission Staff to Intermountain Gas
Company dated January 26, 2023, submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email.
DATED: February 16, 2023.
GIVENS PURSLEY LLP
Preston N. Carter
Attorney for Intermountain Gas Company
RECEIVED
2023 FEB – 16 PM 2:20
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO FOURTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 16, 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 FOURTH 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
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/ Kirsti
Hourigan
REQUEST NO. 72:
Regarding the Company’s response to Production Request No. 12, please break down the
provided Excel sheet further by including the following information within each category
(Admin, Capital, Customer Account, Sales, etc.) broken down by employee category (i.e.,
officer, exempt, non-exempt, and union) through the end of 2022:
a.Paid time-off,
b.Overtime,
c.Bonuses,
d.Incentive pay,
e.Overheads for pension and union,
f.Overheads for benefits union, and
g.Overheads for payroll taxes
RESPONSE NO. 72:
The Company has updated the information provided in Production Request No. 12 through
the end of 2022 broken down as follows:
a.Paid time-off – The Company does not track actual Paid time-off.
b.Overtime - See Excel document RFP 72 Benefits Breakdown
c.Bonuses - See Excel document RFP 72 Benefits Breakdown. The Company considers Bonuses
and Incentives as the same expense item.
d.Incentive pay - See Excel document RFP 72 Benefits Breakdown. The Company considers
Bonuses and Incentives as the same expense item.
INT-G-22-07
PUC DR 72
Page 1 of 2
e.Overheads for pension and union – The Company does not utilize an overhead rate for its union
pension plan.
f.Overheads for benefits union - The Company does not utilize an overhead rate for union benefits.
g.Overheads for payroll taxes – The Company does not utilize an overhead rate for payroll taxes.
INT-G-22-07
PUC DR 72
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Craig Pulley/ Kirsti
Hourigan
REQUEST NO. 73:
In the Company’s response to Production Request No. 14, the Company stated that it
eliminated the traditional medical plan option because the plan became cost prohibitive. Please
provide the costs of the medical plan paid by the Company from 2017 through 2022 and any
documents provided to employees that explained their medical benefits between 2017 through
2022.
RESPONSE NO. 73
Included below are the employer contributions to the medical plan premium for plan
years 2017 through 2022. The Intermountain Gas Company (“IGC”) employer contributions in
the table below represent the costs of the medical plan paid by the Company. There are
additional fees to the Company such as administrative plan fees that are not included in the costs
below.
2017 2018 2019 2020 2021 2022
IGC's Employer
Medical
Contributions $2,497,907 $2,480,455 $2,781,663 $2,678,055 $2,990,355 $2,885,171
Included with this response are the Open Enrollment Guides for plan years 2017 through
2022 which provide summaries of the medical plan along with other benefits offered to
employees by the Company. The Open Enrollment Guides were provided to employees to
explain their health benefits.
INT-G-22-07
PUC DR 73
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Craig Pulley/Kirsti Hourigan
REQUEST NO. 74:
In the Company’s response to Production request No. 14, the Company lists “Business
Travel” as a benefit to “all regular employees working a minimum of 30 hours per week”. Please
provide the Company policy documents describing the Business Travel benefits for employees.
RESPONSE NO. 74:
The “Business Travel” referenced in Production Request No. 14 is travel insurance. The
Company provides Business Travel Accident Coverage to provide 24-hour accident protection
while employees are traveling on Company business. Attached is the 2022 Summary Plan
Description.
INT-G-22-07
PUC DR 74
Page 1 of 1