20230310AWEC to INT 84-95.pdf

AWEC’S FOURTH SET OF
PRODUCTION REQUEST 1 MARCH 10, 2023
TO INTERMOUNTAIN

Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]

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’ FOURTH 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 April 3, 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, 10 9:17AM
IDAHO PUBLIC
UTILITIES COMMISSION

AWEC’S FOURTH SET OF
PRODUCTION REQUEST 2 MARCH 10, 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 FOURTH SET OF
PRODUCTION REQUEST 3 MARCH 10, 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.

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AWEC’S FOURTH SET OF
PRODUCTION REQUEST 4 MARCH 10, 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 FOURTH SET OF
PRODUCTION REQUEST 5 MARCH 10, 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.

/ / /

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/ / /

AWEC’S FOURTH SET OF
PRODUCTION REQUEST 6 MARCH 10, 2023
TO INTERMOUNTAIN

DATA REQUESTS

AWEC PR 084 to INTERMOUNTAIN
Reference Intermountain’s Response to Staff Production Request 93, attachment “RFP 93
2022 CC Detail”, line-item description “NWGS Board of Directors Dinne” in the amount of
$3,780.:
a. Please explain why the referenced transaction was booked as an office supply
expense.
b. Please identify each individual in attendance at the referenced dinner.
c. Please provide a copy of the receipt of invoice for the referenced amount.

AWEC PR 085 to INTERMOUNTAIN
Reference Intermountain’s Response to Staff Production Request 93, attachment “RFP 93
2022 CC Detail”, line-item descriptions “2023 Idaho Governors Cup” in the collective
amount of $2,196: Please explain the business purpose of the referenced transactions.

AWEC PR 086 to INTERMOUNTAIN
Reference Intermountain’s response to Staff Production Request 15:
a. Please provide the fair market value of Intermountain’s pension assets as of the most
recent month available.
b. Please provide the most recent estimate of the value of the pension fund liabilities,
including workpapers used to calculate the value.

AWEC PR 087 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 49: The referenced
response provides the pension contributions, but not the corresponding GAAP pension
expense. To the extent not otherwise already provided in response to another DR (e.g. in
AWEC Set 3), please provide the workpapers used to calculate GAAP pension expenses for
the test period.

AWEC PR 088 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 25: The referenced
response only provides an explanation for items a., c., g., h., j., and k. Please confirm that
the other items are appropriately removed from revenue requirement.

AWEC PR 089 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 53, Attachment “AWEC
PR 53 Adams Exhibit 34.pdf”: Please provide an updated version of the referenced working
capital workpaper with test year revenues and expenses or, in the alternate, provide detail of
the test year revenues and expenses that would correspond to the line items in the referenced
attachment.

AWEC’S FOURTH SET OF
PRODUCTION REQUEST 7 MARCH 10, 2023
TO INTERMOUNTAIN

AWEC PR 090 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 29 regarding Case No.
INT-G-16-02 rate case expenses.
a. Please provide itemized detail of each outside consulting service and other expense
included in the deferral, including a description of the tasks performed by the consultant and
the date that the expense was incurred.
b. Is the deferral subject to a carrying charge or otherwise included in rate base.
c. Please identify any amounts associated with the referenced deferral that have been
previously amortized through the Purchased Gas Adjustment or other proceeding.

AWEC PR 091 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 40, attachment “AWEC
PR 40 2022 IT Allocation Worksheet”: The referenced workpaper file only details the
calculation of allocation factors attributable to Information Technology. Please provide
workpapers used to calculate each and every allocation factor detailed in Intermountain’s
Cost Allocation Manual, including the corporate overhead factor, shared services, customer
service canter allocations, construction serves, and every other factor included in the 2022
Cost Allocation Manual.

AWEC PR 092 to INTERMOUNTAIN
Reference Intermountain’s response to Staff Production 2, Attachment “RFP 2 IGC MDUR
2017-2022,” Tab “MDUR 2022”:
a. Please provide transaction level detail supporting the MDUR expenses identified in
Excel column “C”, titled “Total MDUR Costs”
b. Please itemize the “Total MDUR Costs” and “Total IGC Regulated Costs” by the
allocation factor used to allocate the expense to IGC. For example, include separate
itemized detail for costs allocated using the corporate overhead factor, and any other factor
identified in the 2022 Cost Allocation Manual used to allocate the costs.

AWEC PR 093 to INTERMOUNTAIN
Reference Intermountain’s response to Staff Production Request 2, Attachment “RFP 2 UG
Cross Charges 2017-2022,” Tab “MDUG 2022”:
a. Please provide transaction level detail supporting the Utility Group expenses
identified in Excel column “C”, titled “Utility Group Departments”
b. Please itemize the “Utility Group Departments” and “Total IGC portion” cost by the
allocation factor used to allocate the expense to or from IGC. For example, include separate
itemized detail for costs allocated using the overhead factor, and any other factors identified
in the 2022 Cost Allocation Manual used to allocate the costs.

AWEC PR 094 to INTERMOUNTAIN
Reference Intermountain’s response to AWEC Production Request 57: Please provide an
updated version of the attachment to the referenced request corresponding to
Intermountain’s updated revenue requirement provided in the Supplemental Response to
AWEC Production Request 02.

AWEC’S FOURTH SET OF
PRODUCTION REQUEST 8 MARCH 10, 2023
TO INTERMOUNTAIN

AWEC PR 095 to INTERMOUNTAIN
Please provide itemized detail of all deferred debits and deferred credits included in rate
base.

DATED at Portland, OR, this 10th day of March 2023.

_____________________________
Chad M. Stokes, OSB No. 004007
Cable Huston LLP
1455 SW Broadway, Suite 1500
Portland, OR 9701
Phone: [phone]
Fax: [phone]
[e-mail]

Attorneys for Alliance of Western Energy
Consumers