20230224INT to Staff - Response No. 52_86-92.PDF

RESPONSES TO SIXTH 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 SIXTH PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Sixth Production Request of the Commission Staff to Intermountain Gas
Company dated February 3, 2023, submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email. An amended
response to Request No. 52 of the Commission Staff is also attached and responsive documents
are available at the same link.

DATED: February 24, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
2023 February 24, 2:20PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO SIXTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 24, 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 SIXTH 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
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/
REQUEST NO. 52:
Please provide Capital and O&M informational technology expenses for the Company
from 2016-2022 and please provide supporting worksheets.
RESPONSE NO. 52 Amended:
The capital information technology expenses worksheet for 2016-2022 is being amended
to include the funding project associated with each line item to aide in reconciling to Company
responses to requests 42 and 43. Please see “RFP 52 Amended – IT Capital Expenses.xlsx”.
INT-G-22-07
IPUC DR 52 - Amended
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jeremy Hauff/Patrick
Darras
REQUEST NO. 86:
Please answer the following about blanket funding projects:
a.Please provide the Company's policy for how a project is classified as a blanket
funding project.
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 $100,000 annually.
RESPONSE NO. 86:
a.No policy exists to determine blanket funding project classification.
b.Before each budget season, the Company Vice Presidents review all blanket
funding projects available for their departments and provide changes as needed.
c.Blanket funding projects will exceed $100,000 in the normal course of business.
The $100,000 limitation is at the work order level as no work order over $100,000
can utilize a blanket funding project.
d.Per the explanation in (c.) above, blanket funding projects are expected to exceed
$100,000 annually.
INT-G-22-07
IPUC DR 86
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 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.
RESPONSE NO. 87:
Please see response to RFP 86 for clarification of the $100,000 rule for blankets. Through
discussions with Commission Staff to clarify blanket funding projects, it was determined the
Company would provide a listing of the work orders that make up the blanket funding projects
with total charges of greater than $1 million. Please see “RFP 87 – Blanket Funding
Projects.xlsx”. The first tab contains a listing of all blanket funding projects from RFP 42 that
have charges greater than $1 million. The second tab lists the work orders under those blanket
funding projects.
INT-G-22-07
IPUC DR 87
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Hart
Gilchrist
REQUEST NO. 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 intact.
RESPONSE NO. 88:
After a discussion with Staff, the Company is including in its Response to Staff Production
Request 89 a revision of the information that was provided in Response to Staff Production
Request Nos. 42 and 43. The revised information (“RFP 89 Supplement to RFP 42_43 December
2022.xlsx”) combines the data into one document and updates the information through
December 2022. In addition, a revised document is being provided in response to Staff
Production Request No. 52 “RFP 52 Amended – IT Capital Expenses.xlsx” to include funding
project numbers (FPs) to connect the information among the capital project production requests
that has been provided.
The Company’s Direct Testimony of Gilchrist page 7, line 8 references approximately $4.15
million of costs related to the Work Asset Management project (also referred to as Maximo) that
are in-service as of the end of 2022. This can be found in the Company’s Responses to Staff
Production requests as follows:
Request No. 42: In the updated response to Request 42 for amounts through year-end
2022 “RFP 89 Supplement to RFP 42_43 December 2022.xlsx”, funding project “FP-300217”
reflects the capital expenditures incurred for the Work Asset Management Project. The
INT-G-22-07
IPUC DR 88
Page 1 of 2
$4.15 million is included in these amounts but is not distinguishable as these costs also
include those that remain in Construction Work in Progress as there are multiple work
orders under this one funding project.
Request No. 52: In “RFP 52 Amended – IT Capital Expenses.xlsx” the sum of the
following work orders under funding project “FP-300217” equal the amount in-service as
of the end of 2022:
Work Order
Number Work Order Description
Grand
Total
273606
UG Maximo Equip
Calibration IGC 662,448.72
275702
UG Maximo Elect Maintain
Tasks IGC 692,682.70
277898
UG Gas Patrol & Valves
Track IGC 619,166.95
281718
UG Maximo Tracks 4 & 5
IGC 481,540.09
288271 UG Maximo Corrosion IGC 1,693,307.69
Total In-Service 4,149,146.15
Request No. 54: In “RFP 54 – Maximo Budget and Costs Through 2022.xlsx” the
Intermountain Gas Company amounts presented on the “Maximo Plant In-Service” tab
agree to the $4.15 million in the testimony.
The Company’s Direct Testimony of Boese does not reference any amounts that are capitalized,
therefore no reconciliation to Company Responses 42, 52, and 54 is included.
INT-G-22-07
IPUC DR 88
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 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.
RESPONSE NO. 89:
After a discussion with Staff, the Company is including in its response a revision of the
information that was provided to Staff Production Request Nos. 42 and 43. The revised
information combines the data into one document and updates the information through
December 2022. Please see “RFP 89 Supplement to RFP 42_43 December 2022” for the updated
information.
To assist with reconciling the projects and costs identified in Company Witness Darras’s
testimony see “RFP 89 – Darras Testimony Reconciliation.xlsx”. Within this file all capital
projects identified in Mr. Darras’s testimony have been listed including the page and line of the
reference. In addition, the funding project number and name, which tie the projects back to “RFP
89 Supplement to RFP 42_43 December 2022” have been included. Any differences between the
above file and the testimony amount have been identified and reconciled.
Project FP-318758 which Mr. Darras’s testimony referenced is a budgeted amount and
has not been reconciled to RFP 42_43; the information was provided in Mr. Darras' testimony
for informational purposes only.
INT-G-22-07
IPUC DR 89
Page 1 of 2
Please note that projects highlighted in yellow in the file “RFP 89 – Darras Testimony
Reconciliation.xlsx” were included in the original revenue requirement, however, these projects
have not yet closed to plant and will not be included in the December revenue requirement
update that will be filed.
INT-G-22-07
IPUC DR 89
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 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.
RESPONSE NO. 90:
Please see “RFP 90 – Darras Project Cost Detail.xlsx” for the details of all costs
associated with capital project detailed in Company Witness Darras’s testimony. Within the file
is a summary page of all projects and their associated costs noted within the testimony. There is
then a tab identified for each work order that relates to the noted projects. If a given project’s
cost details had a line item that exceeded $750,000, an additional tab was provided for the
transactional detail that constitutes that amount. For the budgeted projects that do not have an
associated work order with an in-service date in 2022, those projects will be removed from the
December revenue requirement update that will be filed. The budgeted projects (except for FP-
318758, which was never included in the revenue requirement) were originally included in the
revenue requirement because they were forecasted to be completed and in-service within the test
year period of 2022.
INT-G-22-07
IPUC DR 90
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 91:
Company Witness Darrington's Exhibit No. 13 lists the monthly average Gas Plant in
Service. Please provide the underlying details 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.
RESPONSE NO. 91:
In a discussion with Commission Staff, it was determined that for purposes of this
request, the Company would provide a way to roll forward the activity for the average net plant
in service that supports the increase from the 2016 General Rate Case (GRC) to the 2022 GRC.
Please see “RFP 91 – Plant Rate Base Rollforward.xlsx”. The attached Excel workbook has all
formulas intact and includes all workpapers.
The average net plant in service is calculated using an average of monthly averages
methodology (AMA). The AMA methodology was used in both the 2016 GRC as well as the
2022 GRC. The Company filed a Gas Plant in Service with an original cost of $596,065,559 and
a total accumulated depreciation of $308,450,846 in the 2016 GRC. These values are found in
tab “2016 GRC Order” lines 27 and 28, respectively. These values are comprised of monthly
values that are included in tabs “Exhibit 13, p. 1 – 2016 GRC” (this tab is specific to original
cost of gas plant in service) and “Exhibit 13, p. 2 – 2016 GRC” (this tab is specific to
accumulated depreciation of gas plant in service). The comparable Exhibit 13 pages for the 2022
GRC are also included in the workbook.
INT-G-22-07
IPUC DR 91
Page 1 of 2
The 2016 GRC, as filed, was based on a test year consisting of January through June
2016 actual results and July through December forecasted information. To provide a roll forward
of the gas plant in service, the Company is providing data beginning with December 2015, which
was used as part of the 2016 AMA plant in service calculation.
The validation of the beginning values for December 2015, which was used as the
starting point to calculate the 2016 AMA plant in service is included in the “2015 Summary” tab.
The validation for the June values used in the 2016 AMA plant in service is included in the
“2016 Jan-Jun Summary” tab. The December and June values from the summary tabs are used in
the AMA calculations on Exhibit 13 (p. 1 and p. 2) for the 2016 GRC, lines 1 and 13 for
December and June, respectively.
The roll forward then proceeds for each year, beginning with the remaining 2016,
through 2022. The Summary tabs show the plant in service and the accumulated depreciation
with the calculated net plant in service.
The balances in the “2022 Jan-Sep Summary” tab tie to the September balances used in
the 13-month average plant and reserve calculations as filed in Exhibits 13 and 14 to the 2022
GRC. Actual October through December 2022 data has also been provided to support the
updated rate base information for the remainder of 2022.
Supplemental to this information “RFP 91 – Work Orders Placed in Service 2016-
2022.xlsx” has been provided. This file contains a tab for each year that shows every work order
that was placed in service during that year. The amounts on each year’s tab agree to the
“additions” amounts on the plant in service tabs, “PIS” tabs, in “RFP 91 – Plant Rate Base
Rollforward.xlsx”.
INT-G-22-07
IPUC DR 91
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob
Darrington/Patrick Darras
REQUEST NO. 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 respect to gas plant in service for the test year.
RESPONSE NO. 92:
As shown on “RFP 90 – Darras Project Cost Detail.xlsx”, only the land portion (Work
Order # 286603) of the 12” Cloverdale back feed and Kuna Gate Upgrade projects was placed in
service in 2022. The other portions of the projects were not completed or placed into service in
2022. The 12” Cloverdale back feed and Kuna Gate Upgrade projects were included in the
original revenue requirement, however, only the land portion (Work Order # 286603) mentioned
above will be included in the December revenue requirement update that will be filed.
INT-G-22-07
IPUC DR 92
Page 1 of 1