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Home My WebLink About20230302AWEC 63-83 to INT.pdf AWEC’S THIRD SET OF PRODUCTION REQUEST 1 MARCH 2, 2023 TO INTERMOUNTAIN Chad M. Stokes (OSB No. 004007) Cable Huston LLP 1455 SW Broadway Suite 1500 Portland, OR 97201 Telephone: (503) 224-3092 cstokes@cablehuston.com Attorneys for Alliance of Western Energy Consumers BEFORE THE PUBLIC UTILITY COMMISSION OF IDAHO INT-G-22-07 In the Matter of IN THE MATTER OF INTERMOUNTAIN GAS COMPANY FOR THE AUTHORITY TO CHANGE ITS RATES AND CHARGES FOR NATURAL GAS SERVICE IN THE STATE OF IDAHO ALLIANCE OF WESTERN ENERGY CONSUMERS’ THIRD SET OF PRODUCTION REQUESTS TO INTERMOUNTAIN Alliance of Western Energy Consumers, by and through its attorney of record, requests that Intermountain Gas Company (“Company”) provide the following documents and information as soon as possible, but no later than the time provided by Idaho Admin. Code 31.01.01.225, or March 24, 2023. DEFINITIONS 1. “Company” or “Intermountain” or “IGC” refers to any affiliated company, or any officer, director or employee of Intermountain Gas Company or any affiliated company. 2. “Documents” refers to all writings and records of every type in your possession, control, or custody, whether or not claimed to be privileged or otherwise excludable from discovery, including but not limited to: testimony and exhibits, memoranda, papers, correspondence, letters, reports (including drafts, preliminary, intermediate, and final reports), surveys, analyses, studies (including economic and market studies), summaries, comparisons, tabulations, bills, invoices, statements of services rendered, charts, books, pamphlets, photographs, maps, bulletins, corporate or other RECEIVED 2023 March 2, PM 12:45 IDAHO PUBLIC UTILITIES COMMISSION AWEC’S THIRD SET OF PRODUCTION REQUEST 2 MARCH 2, 2023 TO INTERMOUNTAIN minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, microfiche, computer data (including E-mail), computer files, computer tapes, computer inputs, computer outputs and printouts, vouchers, accounting statements, budgets, workpapers, engineering diagrams (including “one-line” diagrams), mechanical and electrical recordings, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical, or otherwise, and drafts of any of the above. “Documents” includes copies of documents, where the originals are not in your possession, custody or control. “Documents” includes every copy of a document which contains handwritten or other notations or which otherwise does not duplicate the original or any other copy. “Documents” also includes any attachments or appendices to any document. 3. “Identification” and “identify” mean: When used with respect to a document, stating the nature of the document (e.g., letter, memorandum, corporate minutes); the date, if any, appearing thereon; the date, if known, on which the document was prepared; the title of the document; the general subject matter of the document; the number of pages comprising the document; the identity of each person who wrote, dictated, or otherwise participated in the preparation of the document; the identity of each person who signed or initiated the document; the identity of each person to whom the document was addressed; the identity of each person who received the document or reviewed it; the location of the document; and the identity of each person having possession, custody, or control of the document. When used with respect to a person, stating his or her full name; his or her most recently known home and business addresses and telephone numbers; his or her present title and position; and his or her present and prior connections or associations with any participant or party to this proceeding. 4. “Person” refers to, without limiting the generality of its meaning, every natural person, corporation, partnership, association (whether formally organized or ad hoc), joint venture, unit operation, cooperative, municipality, commission, governmental body or agency, or any other group or organization. 5. “Studies” or “study” includes, without limitation, reports, reviews, analyses and audits. 6. The terms “and” and “or” shall be construed either disjunctively or conjunctively whenever appropriate in order to bring within the scope of this discovery any AWEC’S THIRD SET OF PRODUCTION REQUEST 3 MARCH 2, 2023 TO INTERMOUNTAIN information or documents which might otherwise be considered to be beyond their scope. 7. The singular form of a word shall be interpreted as plural, and the plural form of a word shall be interpreted as singular, whenever appropriate in order to bring within the scope of this discovery request any information or documents which might otherwise be considered to be beyond their scope. / / / / / / AWEC’S THIRD SET OF PRODUCTION REQUEST 4 MARCH 2, 2023 TO INTERMOUNTAIN INSTRUCTIONS 1. These requests call for all information, including information contained in documents, which relate to the subject matter of the Data Requests and which is known or available to the Company. 2. Where a Data Request has a number of separate subdivisions or related parts or portions, a complete response is required to each such subdivision, part or portion. Any objection to a Data Request should clearly indicate the subdivision, part, or portion of the Data Request to which it is directed. 3. The time period encompassed by these Data Requests is from 2015 to the present unless otherwise specified. 4. Each response should be furnished on a separate page. In addition to hard copy, electronic versions of the document, including studies and analyses, must also be furnished if available. 5. If the Company cannot answer a Data Request in full, after exercising due diligence to secure the information necessary to do so, state the answer to the extent possible, state why the Company cannot answer the Data Request in full, and state what information or knowledge the Company has concerning the unanswered portions. 6. If, in answering any of these Data Requests, the Company feels that any Data Request or definition or instruction applicable thereto is ambiguous, set forth the language the Company feels is ambiguous and the interpretation the Company is using in responding to the Data Request. 7. If a document requested is unavailable, identify the document, describe in detail the reasons the document is unavailable, state where the document can be obtained, and specify the number of pages it contains. 8. If the Company asserts that any document has been destroyed, state when and why it was destroyed and identify the person who directed the destruction. If the document was destroyed pursuant to the Company’s document destruction program, identify and produce a copy of the guideline, policy, or company manual describing such document destruction program. 9. If the Company refuses to respond to any Data Request by reason of a claim of privilege, confidentiality, or for any other reason, state in writing the type of privilege claimed and the facts and circumstances the Company relies upon to support the claim of privilege or the reason for refusing to respond. With respect to requests for documents to which the Company refuses to respond, identify each such document, and specify the number of pages it contains. Provide: (a) a brief description of the document; (b) date of document; (c) name of each author or AWEC’S THIRD SET OF PRODUCTION REQUEST 5 MARCH 2, 2023 TO INTERMOUNTAIN preparer; (d) name of each person who received the document; and (e) the reason for withholding it and a statement of facts constituting the justification and basis for withholding it. 10. Identify the person from whom the information and documents supplied in response to each Data Request were obtained, the person who prepared each response, the person who reviewed each response, and the person who will bear ultimate responsibility for the truth of each response. 11. If no document is responsive to a Data Request that calls for a document, then so state. 12. These requests for documents and responses are continuing in character so as to require the Company to file supplemental answers as soon as possible if the Company obtains further or different information. Any supplemental answer should refer to the date and use the number of the original request or subpart thereof. 13. Whenever these Data Requests specifically request an answer rather than the identification of documents, the answer is required and the production of documents in lieu thereof will not substitute for an answer. / / / / / / / / / / / / AWEC’S THIRD SET OF PRODUCTION REQUEST 6 MARCH 2, 2023 TO INTERMOUNTAIN DATA REQUESTS AWEC PR 063 to INTERMOUNTAIN Reference Intermountain’s Supplemental Response to AWEC Production Request 02: Please explain the drivers for the reduction in income tax expense relative to Intermountain’s initial filing. If the change was the result of a correction identified in a Production Request, please identify the Production Request. AWEC PR 064 to INTERMOUNTAIN Reference Staff Production Request 10: Please provide credit card statements for November 2022 and December 2022 in the manner requested in the referenced response. AWEC PR 065 to INTERMOUNTAIN Please identify the amount of Contributions in Aid of Construction (“CIAC”) received in 2022 by month. If available, please identify both the principal balance as well as the tax gross-up amount on the CIAC receipts. AWEC PR 066 to INTERMOUNTAIN Reference Intermountain’s Supplemental Response to AWEC Production Request 02, workpaper “CONFIDENTIAL Supplemental AWEC PR 2 - Ex. 1-19 - IGC Rev Req Model-Dec Update,” Tab “WP - Deferred Tax”, Excel Rows “62:63” Please provide workpapers supporting the periodic deferred taxes associated CIAC Capitalized and CIAC Incurred. AWEC PR 067 to INTERMOUNTAIN Please provide an explanation of how Intermountain accounts for CIAC and the associated tax gross-up amounts. AWEC PR 068 to INTERMOUNTAIN Does Intermountain amortize the CIAC rate base balances as a reduction to operating expenses? If yes, please identify where in the revenue requirement workpapers those amortization amounts may be found. If not, please explain how ratepayers get the periodic benefit associated with CIAC. AWEC PR 069 to INTERMOUNTAIN Does Intermountain account for the tax-gross up associated with CIAC differently that the principal amount? If yes, please explain how these two aspects of CIAC receipts are handled for accounting purposes. AWEC PR 070 to INTERMOUNTAIN Reference Intermountain’s Supplemental Response to AWEC Production Request 02: Please identify the amount of excess deferred federal income taxes being amortized to rates and identify where in the revised revenue requirement workpapers that amortization (or benefit) can be found. AWEC’S THIRD SET OF PRODUCTION REQUEST 7 MARCH 2, 2023 TO INTERMOUNTAIN AWEC PR 071 to INTERMOUNTAIN Please identify Intermountain’s pension expense included the 2022 Test Period. Please provide separate detail for any pension expense amounts allocated from, or to, another MDUR entity. AWEC PR 072 to INTERMOUNTAIN Please provide the actuarial reports and associated accounting workpapers used to calculate pension expenses for 2022. AWEC PR 073 to INTERMOUNTAIN Please provide Intermountain’s other post-employment benefits (“OPEB”) expense for the 2022 Test Period. Please provide separate detail for any OPEB expense amounts allocated from, or to, another MDUR entity. AWEC PR 074 to INTERMOUNTAIN Please provide the actuarial reports and associated accounting workpapers used to calculate OPEB expenses for 2022. AWEC PR 075 to INTERMOUNTAIN If not already provided in response to the prior requests, please provide the most recent actuarial reports for pension expense and OPEB expense. AWEC PR 076 to INTERMOUNTAIN Reference Intermountain’s Supplemental Response to AWEC Production Request 24, Attachment “AWEC PR 24 2022 Op Exp But Includes All OM”: Please reconcile the O&M amounts included in the referenced attachment to the amount the amounts included in the Supplemental Response to AWEC Data Request 02, tab “WP - O&M FERC, columns “J:K.” The differences between the two files appears to be related to the treatment of pension expenses, although it is not apparent from the workpapers AWEC PR 077 to INTERMOUNTAIN Reference Intermountain’s Response to AWEC Production Request 24, FERC Account 913: Please provide an explanation for the $10,000 charge to EAST IDAHO HOCKEY INC, and provide copies or details of the advertisements purchased. AWEC PR 078 to INTERMOUNTAIN Please identify each sports-team or arena sponsorships, or event tickets that Intermountain purchased in the 2022 Test Period. Please identify the sports team, the arena, the test period expense, and the FERC account. Please also identify whether the sponsorship entitles Intermountain to event tickets, a club tickets, or other similar benefits. AWEC PR 079 to INTERMOUNTAIN Reference Intermountain’s Response to AWEC Production Request 24, FERC Account 913: Please copies of all advertisements in “SNAKE RIVER VALLEY BCA” purchased in the test period. AWEC’S THIRD SET OF PRODUCTION REQUEST 8 MARCH 2, 2023 TO INTERMOUNTAIN AWEC PR 080 to INTERMOUNTAIN Reference Intermountain’s Response to AWEC Production Request 24, FERC Account 912: Please provide an explanation of the service performed by Bannock Development Corp and explain how those activities benefit ratepayers. AWEC PR 081 to INTERMOUNTAIN Reference Intermountain’s Response to AWEC Production Request 24, FERC Account 930: Please provide an explanation for the $21,000 charge to “MCCLATCHY COMPANY LLC,” including any invoices and or receipts associated with that payment. Please also explain how the payment benefits ratepayers . AWEC PR 082 to INTERMOUNTAIN Is Intermountain planning to sponsor the Governor’s Cup in 2023 and 2024 AWEC PR 083 to INTERMOUNTAIN Reference Intermountain’s Response to AWEC Production Request 24, FERC Account 923: Please provide an explanation for the $204,315 in fees paid to “RICOH USA INC” and the type of service received. DATED at Portland, OR, this 2nd day of March 2023. _____________________________ Chad M. Stokes, OSB No. 004007 Attorneys At Law 1455 SW Broadway, Suite 1500 Portland, OR 9701 Phone: 503-224-3092 Fax: 503-224-3716 cstokes@cablehuston.com Attorneys for Alliance of Western Energy Consumers