20230303INT to AWEC 28 & 30 Supplemental Resp.pdf

RESPONSES TO AWEC’S SECOND PRODUCTION REQUESTS 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 ALLIANCE OF WESTERN
ENERGY CONSUMERS’ SECOND SET OF
PRODUCTION REQUESTS

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Alliance of Western Energy Consumers’ (“AWEC”) Second Set of Production
Requests to Intermountain Gas Company dated January 23, 2023, submits the following
supplemental responses.
DATED: March 3, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
2023 March 3, PM 3:12
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO AWEC’S SECOND PRODUCTION REQUESTS PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on March 3, 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 AWEC’S SECOND PRODUCTION REQUESTS 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
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 28:
Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model
(Darrington)”, Tab “WP - Industrial Migration”: Please provide a more detailed explanation for
why it was necessary and appropriate to set the amounts in cells “G99” and “I124” to zero.
SUPPLEMENTAL RESPONSE NO. 28:
For the migrations in question, the switch from the GS-1 to LV-1 rate class became
effective June 1, 2022 and August 1, 2022, respectively. The GS-1 customer class has 20
different billing cycles, while the LV-1 customer class has only one at the end of each month.
This means that LV-1 revenues, both volumetric and demand, for these two customers were
collected through the general ledger in June or August 2022 for June or August usage. However,
there were also GS-1 revenues for these customers collected in June or August (i.e. final GS-1
bills for the usage before the effective date of the migration to the LV-1 rate class). Therefore,
the Company removed the GS-1 revenues for June or August, respectively, and re-priced those
volumes at the LV-1 rates. However, since the LV-1 customer’s demand charge was effective
on June 1 or August 1, respectively, no adjustment to the MDFQ in cells G99 and I124 was
necessary since the Company would have already received the demand charge revenue through
its general ledger.
INT-G-22-07
AWEC PR 28 - Supplement
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 30:
Reference IGC response to Staff Production Request 7: Is IGC seeking to defer the rate
case expenses identified in the referenced response, or include them as a test period expense?
SUPPLEMENTAL RESPONSE NO. 30:
The Company is proposing to include the rate case costs identified in the response to
Staff Production Request 7 as a test period expense. The Company recognizes that rate case
expenses are generally amortized over a multi-year period. However, since the Company
continues to incur rate case expenses in 2023, which are not included in test year expense, the
Company feels that including the amount of rate cases costs incurred in 2022 as a test year
expense is reasonable and achieves a multi-year amortization.
INT-G-22-07
AWEC PR 30 - Supplement
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