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Home My WebLink About20230309INT to AWEC 21-23.pdfRESPONSES TO AWEC’S FIRST 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: (208) 388-1200 Facsimile: (208) 388-1300 prestoncarter@givenspursley.com morgangoodin@givenspursley.com blakeringer@givenspursley.com 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’ FIRST SET OF PRODUCTION REQUESTS Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in response to the Alliance of Western Energy Consumers’ (“AWEC”) First Set of Production Requests to Intermountain Gas Company dated January 10, 2023, submits the following supplemental responses. 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 9 2023. GIVENS PURSLEY LLP Preston N. Carter Attorney for Intermountain Gas Company RECEIVED 2023 March, 9 3:41PM IDAHO PUBLIC UTILITIES COMMISSION RESPONSES TO AWEC’S FIRST PRODUCTION REQUESTS PAGE 2 OF 3 CERTIFICATE OF SERVICE I certify that on March 9, 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 jan.noriyuki@puc.idaho.gov Dayn Hardie Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Boise, ID 83714 dayn.hardie@puc.idaho.gov Chad M. Stokes Cable Huston LLP 1455 SW Broadway, Ste. 1500 Portland, OR 97201 Attorneys for Alliance of Western Energy Consumers cstokes@cablehuston.com Marie Callaway Kellner 710 N. 6th Street Boise, ID 83702 Attorneys for Idaho Conservation League mkellner@idahoconservation.org Brad Heusinkveld Idaho Conservation League, Energy Assoc. 710 N. 6th Street Boise, ID 83702 bheusinkveld@idahoconservation.org Darrell Early Ed Jewell Deputy City Attorney Boise City Attorney’s Office 150 N. Capitol Blvd. PO Box 500 Boise, ID 83701-0500 boisecityattorney@cityofboise.org dearly@cityofboise.org ejewell@cityofboise.org RESPONSES TO AWEC’S FIRST 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 wgehl@cityofboise.org Preston N. Carter INTERMOUNTAIN GAS COMPANY CASE INT-G-22-07 FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN ENERGY CONSUMERS Preparer/Sponsoring Witness: Jessica Anderson/Jacob Darrington REQUEST NO. 21: Reference Darrington Exhibit 11, Cell “E28”: Please reconcile the (-)$892,950 in plant related deferred taxes to the approximate (-)$588,524 temporary plant book tax difference in Exhibit 10, Cells “G47:G48,) which tax effected is just (-)123,590. SUPPLEMENTAL RESPONSE NO. 21: In conjunction with its December revenue requirement update provided in the response Supplemental AWEC PR 2, the Company is supplementing this response to provide an update to the deferred income taxes related to plant. As part of its December revenue requirement update, the Company made changes to its tax workpapers and exhibits to make them easier to follow and to correct issues that were identified while preparing responses to previous production requests. Exhibit 11 no longer presents a separate value for plant related deferred taxes, but instead presents total federal deferred income taxes. WP – Deferred Tax provides the breakout of the federal deferred income taxes, including plant related deferred taxes. Please see the table below for the components of plant related deferred taxes. 2022 Plant Timing Difference (see Exhibit 10, Cell G51) (2,086,151) 2022 AFUDC Equity Flowthrough Timing Difference (see Exhibit 10, Cell G50) 217,065 2022 Total Plant/AFUDC Timing Difference (1,869,086) INT-G-22-07 AWEC PR 21 - Supplemental Page 1 of 2 Deferred Tax Expense at Statutory (Plant Timing Difference ($2,085,790) X 21% - 1031 LKE Timing Difference ($361) * 35%) (see Exhibit 10, Cells C51 & E51 for timing differences) 438,142 Amortization of Excess Deferred Income Taxes – Plant ARAM (see AWEC 19) (984,992) Total Deferred Income Tax Expense (Benefit) (see WP-Deferred Tax Cells E58:E59) (546,850) INT-G-22-07 AWEC PR 21 - Supplemental Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-22-07 FIRST PRODUCTION REQUEST OF ALLIANCE OF WESTERN ENERGY CONSUMERS Preparer/Sponsoring Witness: Jessica Anderson/Jacob Darrington REQUEST NO. 23: Reference Darrington Exhibit 11, Line 34: Please explain why the ITC Amortization is an increase to income tax expense. SUPPLEMENTAL RESPONSE NO. 23: In conjunction with its December revenue requirement update provided in the response Supplemental AWEC PR 2, the Company is supplementing this response to explain that the Company changed the presentation on Exhibit 10 to show the calculation of the ITC Amortization more clearly. As the Company stated in its first response to Request No. 23, it inadvertently excluded the amount of investment tax credit (ITC) generated in 2022. This issue has been fixed in the updated presentation of Exhibit 10. INT-G-22-07 AWEC PR 23 - Supplemental Page 1 of 1