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Home My WebLink About20230309INT to AWEC 37_47-48.pdfRESPONSES 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: (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’ 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 responses. Responsive documents are available for download using the link provided in the accompanying email. DATED: March 9, 2023. GIVENS PURSLEY LLP Preston N. Carter Attorney for Intermountain Gas Company RECEIVED 2023 March, 9 3:48PM IDAHO PUBLIC UTILITIES COMMISSION RESPONSES TO AWEC’S SECOND 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 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 wgehl@cityofboise.org 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. 37: To the extent not provided in response to Staff Production Request 37, please provide a schedule showing all dues, contributions and donations included in the utility’s regulatory expense accounts for the test period by FERC account. For any MDUR cross charge items from another utility please separately detail and describe each contribution or donation and please also describe how the item benefits Idaho ratepayers. RESPONSE NO. 37: The Company’s contribution or donation account is object 5981 and all but two charges for 2022 were below the line. Any costs with an account number ending in 4261 through 4265 (ex. 48501.5981.4261) are below the line expenses and have not been included in the Company’s revenue requirement. The following two charges were coded to donations and were included in the December revenue requirement update provided in response to Supplemental AWEC PR 2. The FERC account for these two charges are 921: Upon further inspection, the ATI conference charge should have been recorded to seminars registration and advertising. The College of Western Idaho Foundation donation should have been recorded as a below the line expense. INT-G-22-07 AWEC PR 37 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-22-07 SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN ENERGY CONSUMERS Preparer/Sponsoring Witness: Zach Harris/Jacob Darrington REQUEST NO. 45: Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model (Darrington)” Tab “WP - Salary Expense Adjustment”: Please reconcile the 2022 amounts in the referenced tab to the amounts provided in response to Staff Production Request 12. RESPONSE NO. 45: The referenced workpaper for the salary expense adjustment has a total eligible allocated salary of $25,756,103. This amount is derived by summing the salaries under the column titled “Eligible Allocated Salary.” The salary expense adjustment removes capitalized labor, temporary labor, and labor associated with Energy Efficiency employees. In addition, the salary expense adjustment is specific to salaries and excludes payroll taxes, insurance (medical, dental, life, etc.) and pension/401k costs. The adjustment also excludes any bonus or incentive amounts employees may have received during the year. Finally, the second component of the adjustment is a pro-forma adjustment to account for salary or wage increases that will occur in 2023. However, to be eligible for a salary or wage increase, an employee must have been hired prior to September 30, 2022. Therefore, the salary expense adjustment workpaper also removes employees hired after September 30, 2022. In contrast, the amounts provided in response to Staff Production Request 12 specific to 2022 include all labor costs (i.e. salary, payroll taxes, insurance, etc.) for all Company employees through November 2022. An updated response regarding labor costs through December 2022 has been provided in Staff Production Request 72. Additionally, the December revenue requirement INT-G-22-07 AWEC PR 45 Page 1 of 2 update provided in Supplemental AWEC Production Request No. 2, changed the total eligible allocated salary to $25,845,490 due to an adjustment of the allocated MDUR salary amount. INT-G-22-07 AWEC PR 45 Page 2 of 2 INTERMOUNTAIN GAS COMPANY CASE INT-G-22-07 SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN ENERGY CONSUMERS Preparer/Sponsoring Witness: Zach Harris/Jacob Darrington REQUEST NO. 47: Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model (Darrington)” Tab “WP - Salary Expense Adjustment”: For each category of labor expense in the referenced tab, please provide detail of the 2022 expenses using the same categories as provided in response to Staff Production Request 12. RESPONSE NO. 47: As explained in the Company’s response to AWEC Production Request No. 45, the salary expense adjustment only includes salary and wages and excludes other labor expenses. Nonetheless, the Company has provided the salary and wage amounts broken down by functional category as provided in response to Staff Production Request 12. See “AWEC PR 47 – Functional Salary Category” for the requested information. INT-G-22-07 AWEC PR 47 Page 1 of 1 INTERMOUNTAIN GAS COMPANY CASE INT-G-22-07 SECOND PRODUCTION REQUEST OF ALLIANCE OF WESTERN ENERGY CONSUMERS Preparer/Sponsoring Witness: Zach Harris/Jacob Darrington REQUEST NO. 48: Reference workpaper “16524523_2_CONFIDENTIAL Ex. 1-19 - IGC Rev Req Model (Darrington)” Tab “WP - Salary Expense Adjustment”: Do the 2022 amounts in the referenced workpaper include labor costs associated with the Boise Campus and customer service center which are reallocated to other utilities? Please explain how such amounts are handled in the referenced workpaper. RESPONSE NO. 48: The salaries and wages in the referenced workpaper only include amounts allocated to Intermountain and excludes amounts allocated to other utilities. INT-G-22-07 AWEC PR 48 Page 1 of 1