20230228Staff 103-115 to INT.pdf

CLAIRE SHARP coDEPUTYATTORNEYGENERAL
IDAHO PUBLIC UTILITIES COMMISSION 28 p gPOBOX83720
BOISE,IDAHO 83720-0074
[phone] -e ''t
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )COMPANY'S APPLICATION FOR )CASE NO.INT-G-22-07
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR NATURAL GAS SERVICE IN )EIGHTH PRODUCTION
THE STATE OF IDAHO )REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY,MARCH 14,2023.1
This Production Request is to be considered as continuing,and Intermountain Gas
Company is requested to provide,by way of supplementary responses,additional documents that
it,or any person acting on its behalf,may later obtain that will augment the documents or
information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0357.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l FEBRUARY 28,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provideall
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.103:Referencing the Company's response to Production Request No.5,
please confirm whether the followingleases will be,or have been,renewed.If so,please also
provide the terms,cost,and dates of the new leases.
a.United Self Storage -Payette Office Shop (Lease ends 7/15/23);
b.JNM Investments -Rexburg Office and warehouse (Lease ends 2/28/23);
c.Communications Associates -Antenna Site at Della Mountain (Lease ended
12/31/22);
d.Communications Associates -Antenna Site at Mt.Harrison (Lease ended
(12/31/22);
e.Day Wireless -Tower and Equipment at Wilson Peak (Lease ends 9/30/23);
f.Dan Price -Burley Shop (Lease ended 7/31/22);and
g.SBA Site Management,LLC -Georgetown Tower Site (Lease ended 12/31/22).
REQUESTNO.104:Referencing the Company's response to Production Request No.7,
please provide a current update for the amount of external rate case expenses the Company has
incurred.Please supplement your response as additional rate case expenses are incurred.
REQUESTNO.105:In Case No.INT-G-17-05,Intermountain Gas applied to amortize
its rate case expenses throughthe PGA.The Company listed the rate case expense balance as
$699,114.In Order No.33887,the Commission said
we are not at this time approving recovery of the remaining $319,963 in external
rate case expenses,reflecting work by Concentric on the cost of capital study
and rate base consulting and calculations and by Alta Vista on external
computer services.Instead,more investigation and justification of those
expenses is required before we can determine whether they were prudently
incurred.We therefore defer our consideration of those expenses until the
Company's next general rate case.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 FEBRUARY 28,2023
Id.at 5.Please provide the additional justification and documentation related to the purpose and
prudency of the unrecovered expenses.
REQUESTNO.106:Please reconcile the deferred rate case expense from Case
No.INT-G-16-02 of $328,019 shown in the current case on Company witness Darrington
Exhibit No.7 and the $319,963 stated and deferred in Commission Order No.33887.
REQUESTNO.107:Please provide a listing of all transactions charged to the
followingaccounts.Please include date,amount,a brief description of the transaction,and any
additional tracking information.
a.228.2,Accumulated Provisions-Injuries &Damages;
b.29301,Miscellaneous General Expenses;
c.29302,Miscellaneous General Expenses;
d.293074,Miscellaneous General Expenses;
e.293077,Miscellaneous General Expenses;
f.29130,Advertising Expenses;
g.29210,Office Supplies &Expenses;and
h.29250,Injuriesand Damages.
REQUESTNO.108:Please explain if any energy efficiency expenses are included in
this filing.If yes,please provide worksheets detailing the expenses.
REQUESTNO.109:Please provide the account,sub-account,business unit,and
document numbers for any expenses that are part of the energy efficiency rider.
REQUESTNO.110:Please clarify if all advertising expenses listed in Response to
Production Response No.31 are included in the revenue requirement.Please indicate which
expenses,if any,are included in the energy efficiency rider.
EIGHTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 FEBRUARY 28,2023
REQUEST NO. 111: Please provide the amount allocated to Intermountain Gas
Company from its parent company for the following categories:
a.General Counsel;
b.Executive Compensation;
c.Compensation Committee; and
d.Board of Directors and the Board of Directors Meetings.
REQUEST NO. 112: Please provide a schedule of all expenses associated with Case
No. INT-G-22-01.
REQUEST NO. 113: Please provide a schedule ofrate cases for other regulated
subsidiaries of MDUR for the last 5 years. Please include if those rate cases were settled. For
each rate case that was settled with a stated return on equity, please provide that return on equity.
REQUEST NO. 114: Please provide all documents pertaining to employee purchases
using Company credit cards for the selected employees and months included on the attached
Confidential Excel file for year 2022. This should include the logbook, receipts, and any other
auditable paper trail for the entire month requested for each employee.
REQUEST NO. 115: In reference to Production Request No. 9, please provide
documentation and journal entries of bank statements for the sample of transactions included on
the attached Confidential Excel file.
�1.1\
DATED at Boise, Idaho, this 2 � day of February 2023.
i:umisc:prodreq/intg22. 7cslc prod req 8
EIGHTH PRODUCTION REQUEST TO INTERMOUNT AIN GAS COMPANY 4
Claire Sharp · �
Deputy Attorney General
FEBRUARY 28, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF FEBRUARY 2023,SERVED THE FOREGOING EIGHTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOINTERMOUNTAINGASCOMPANY,IN CASENO.INT-G-22-07,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTERDIR-REGULATORY AFFAIRS GIVENS PURSLEY LLPINTERMOUNTAINGASCO601WBANNOCKST
PO BOX 7608 BOISE ID 83702BOISEID83707E-MAIL:[e-mail]-MAIL:[e-mail] [e-mail]
CHAD M STOKES
CABLE HUSTON LLP
1455 SW BROADWAY
STE 1500
PORTLAND OR 97201
E-MAIL:[e-mail]
brmullins mwanalytics.com
SÈCRET Y
CERTIFICATE OF SERVICE