20230303INT to Staff 93-100.pdf

RESPONSES TO SEVENTH 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 SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Seventh Production Request of the Commission Staff to Intermountain Gas
Company dated February 10, 2023, submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email. Confidential
responses and documents are subject to the protective agreement in this case, and are available
for download using a password-protected link that will be provided separately by email. The
password will be provided in a third email.
DATED: March 3, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
2023 March 3, PM 4:48
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO SEVENTH PRODUCTION REQUEST OF COMMISSION STAFF 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 SEVENTH 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
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 93:
Regarding the Company's response to Production Request No. 10 on providing credit
card transactions, please provide a list of all transactions occurring in 2022 which were booked
above the line and included for recovery in this case.
RESPONSE NO. 93:
Please see RFP 93 2022 CC Detail.xlsx
INT-G-22-07
IPUC DR 93
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 94:
Please provide a list of sub-account codes for purchases that are below the line.
RESPONSE NO. 94:
Purchases with an account number ending in 4261 through 4265 (ex. 48542.5912.4264)
are below the line expenses and have not been included in the Company’s filed case.
INT-G-22-07
IPUC DR 94
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 95:
Please provide a copy of the Company's policy on credit cards issued to employees.
RESPONSE NO. 95:
Refer to document RFP 95 Credit Card Policy – AD 102.PDF
INT-G-22-07
IPUC DR 95
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 96:
Please provide a list of all subsidiaries of MDU Resources that provide services or costs
that are allocated in the 2022 Cost Allocation Manual.
RESPONSE NO. 96:
Please see the listing of subsidiaries of MDU Resources that receive allocated costs
which was excerpted from page 5 of the 2022 Cost Allocation Manual:
INT-G-22-07
IPUC DR 96
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 97:
Please provide a schedule showing all costs allocated to Intermountain Gas that are
included in the Application. Please break this out by cost allocation category as stated in the
2022 Cost Allocation Manual.
RESPONSE NO. 97:
The 2022 Cost Allocation Manual divides MDUR Allocations into two departments,
shared services and administrative and general services. Using the data provided in Response to
Production Request No. 2, part h, the Company broke out the shared services department
expenses using Exhibit IV of the 2022 Cost Allocation Manual. The administrative and general
services department was broken out as discussed on page 4 of the 2022 Cost Allocation Manual.
Please see RFP 97 IGC MDUR 2022 Allocations.xlsx for MDUR costs allocated to the
Company.
Allocations from other Utility Group companies were broken out using Exhibit V of the
2022 Cost Allocation Manual. After categorizing the utility group data provided in Response to
Production Request No. 2, part h, the Company discovered $917.30 in object account 5211-
Subcontract Payments that was not included in the data previously provided. Please see RFP 97
IGC UG 2022 Allocations.xlsx costs allocated to the Company from other Utility Group
companies.
INT-G-22-07
IPUC DR 97
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Hart
Gilchrist
REQUEST NO. 99:
Please provide the expected life of the Maximo system as well as the depreciation rate
applied to it.
RESPONSE NO. 99:
The expected life of the Maximo system is 12 years. The Maximo assets are amortized on
a straight-line basis over the 12 years which is .694% per month or about 8.33% per year.
INT-G-22-07
IPUC DR 99
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Lance Elroy/Hart
Gilchrist
REQUEST NO. 100:
Please provide the expected year the Maximo system will be fully in use.
RESPONSE NO. 100:
Maximo is in use for maintenance. The remaining phases will be completed by the end
of year 2025.
INT-G-22-07
IPUC DR 100
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