20230223INT to Staff - Response No. 71.pdf

RESPONSES TO THIRD 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
RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Third Production Request of the Commission Staff to Intermountain Gas
Company dated January 9, 2023, submits the following supplemental response to Request No.
71. Responsive documents are available for download using the link provided in the
accompanying email.
DATED: February 23, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
Thursday, February 23, 2023 12:20:21 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO THIRD PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 23, 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 THIRD 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
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Josh Sanders/Patrick
Darras
REQUEST NO. 71:
Please provide all documents and reports related to all safety audits performed on the
Company from 2017 to present date.
SUPPLEMENTAL RESPONSE NO. 71:
Please see “RFP 71 Idaho Inspections 2019-2022.xlsx” for a listing of pipeline safety
audits and results.
Please see “RFP 71 Q4 UG Detailed Report 2021 and 2022 – IPUC.pdf” for a list of
OSHA audits and results. As noted on the report, Intermountain has had zero inspections and
zero citations for the two years reported. In addition, a review of the OSHA Establishment
website shows that the Company has not had an OSHA violations since 2009 and the last
reported inspection by OSHA was in 2010.
INT-G-22-07
IPUC DR 71 Supplement
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