20230314INT to Staff - Response to No. 103_106-113.pdf

RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 3
Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[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 EIGHTH PRODUCTION
REQUEST OF THE COMMISSION STAFF

In response to the First Production Request of the Commission Staff to Intermountain
Gas Company dated February 28, 2023, Intermountain Gas Company, (“Intermountain,”
“Applicant,” or “Company”), 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 14, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company
RECEIVED
Tuesday, March 14, 2023 4:01:16 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on March 14, 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]

RESPONSE TO THE EIGHTH 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
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 103:
Referencing the Company’s response to Production Request No. 5, please confirm
whether the following leases will be, or have been, renewed. If so, please also provide the terms,
cost, and dates of the new leases.
a.United Self Storage – Payette Office Shop (Lease ends 7/15/23);
b.JNM Investments – Rexburg Office and warehouse (Lease ends 2/28/23);
c.Communications Associates – Antenna Site at Della Mountain (Lease ended 12/31/22);
d.Communications Associates – Antenna Site at Mt. Harrison (Lease ended 12/31/22)
e.Day Wireless – Tower and Equipment at Wilson Peak (Lease ends 9/30/23);
f.Dan Price – Burley Shop (Lease ended 7/31/22); and
g.SBA Site Management, LLC – Georgetown Tower Site (Lease ended 12/31/22).
RESPONSE NO. 103:
a.United Self Storage – Payette Office Shop (Lease ends 7/15/23);
The Company intends to renew this lease upon its expiration in July. New terms,
costs, and dates are not available at this time.
b.JNM Investments – Rexburg Office and warehouse (Lease ends 2/28/23);
This lease was signed in 2018 with a six-year term. The lease ends on 2/28/2024.
At this time, the Company intends to renew the lease upon its expiration, however
new terms, costs and dates are not available.
c.Communications Associates – Antenna Site at Della Mountain (Lease ended 12/31/22);
INT-G-22-07
IPUC DR 103
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This lease was signed in 2017 with a seven-year term. The lease ends on
12/31/2023. At the end of the term the lease will automatically be renewed for a
one-year renewal term unless, upon written notice, the Company communicates
its desire to terminate the lease. At this time the Company intends to let the lease
auto-renew for the one-year term. Rental rates will increase 2% upon renewal,
which will make the annual rent $4,443.
d.Communications Associates – Antenna Site at Mt. Harrison (Lease ended 12/31/22);
This lease was signed in 2017 with a seven-year term. The lease ends on
12/31/2023. At the end of the term the lease will automatically be renewed for a
one-year renewal term unless, upon written notice, the Company communicates
its desire to terminate the lease. At this time the Company intends to let the lease
auto-renew for the one-year term. Rental rates will increase 2% upon renewal,
which will make the annual rent $7,069.
e.Day Wireless – Tower and Equipment at Wilson Peak (Lease ends 9/30/23);
The Company does not plan to renew this lease after this term expires.
f.Dan Price – Burley Shop (Lease ended 7/31/22); and
This lease changed ownership to Intermountain Properties after the term ended
7/31/22. The lease was renewed with the new owners for a three-year term
beginning 8/1/22. Payments are $900 per month. This is reflected in “RFP 5 –
Lease Listing” line 23 of the Excel file.
g.SBA Site Management, LLC – Georgetown Tower Site (Lease ended 12/31/22).
This lease was renewed for a 1-year term on 1/1/23 with an annual payment of
$10,661.54.
INT-G-22-07
IPUC DR 103
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 106:
Please reconcile the deferred rate case expense from Case No. INT-G-16-02 of $328,019
shown in the current case on Company witness Darrington Exhibit No. 7 and the $319,963 state
and deferred in Commission Order No. 33887.
RESPONSE NO. 106:
In Case No. INT-G-17-05, the Company requested to include $699,114 of rate cases
expenses to be amortized and recovered over a four-year period. Instead, the Commission
authorized the Company to amortize and collect over a five-year period $378,614 of deferred
rate case expenses. This leaves $320,500 of deferred rate case costs remaining ($699,114 -
$378,614 = $320,500), however, Order No. 33887 incorrectly stated the remaining amount as
$319,963. In addition, legal fees of $7,519 were invoiced to the Company after Intermountain
had submitted Case No. INT-G-17-05. Therefore, the total remaining amount of deferred
general rate cases costs on Darrington Exhibit No. 7 is $328,019 ($320,500 + $7,519 =
$328,019).
INT-G-22-07
IPUC DR 106
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 107:
Please provide a listing of all transactions charged to the following accounts. Please
include date, amount, a brief description of the transaction, and any additional tracking
information.
a.228.2, Accumulated Provisions-Injuries & Damages;
b.29301, Miscellaneous General Expenses;
c.29302, Miscellaneous General Expenses;
d.293074, Miscellaneous General Expenses;
e.293077, Miscellaneous General Expenses;
f.29130, Advertising Expenses;
g.29210, Office Supplies & Expenses; and
h.29250, Injuries and Damages.
RESPONSE NO. 107:
Please see Excel file “RFP 107 Selected Acct Detail 2022.xlsx” for the detail requested.
Please also see Excel file “RP 107 Injuries and Damages Reconciliation.xlsx” for additional
information regarding account 29250.
INT-G-22-07
IPUC DR 107
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Niki Ogami/Jacob
Darrington
REQUEST NO. 108:
Please explain if any energy efficiency expenses are included in this filing. If yes, please
provide worksheets detailing the expenses.
RESPONSE NO. 108:
Energy efficiency expenses have been removed from the calculation of revenue
requirement in this filing. These expenses are removed as part of the “Remove Non-Distribution
Revenues and Expenses” adjustment on Exhibit No. 5, Column (b).
INT-G-22-07
IPUC DR 108
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Niki Ogami/Jacob
Darrington
REQUEST NO. 109:
Please provide the account, sub-account, business unit, and document numbers for any
expenses that are part of the energy efficiency rider.
RESPONSE NO. 109:
Energy efficiency expenses are coded to the appropriate object account and sub-account
based on the type of expense. The business unit number is the unique identifier for energy
efficiency expenses, which is 48526. When looking at the Company’s account coding, the first
part of the account string is the business unit number. Please see the example below.
As explained in the response to Request No. 108, all Energy Efficiency expenses have
been removed from the calculation of revenue requirement in this filing.
INT-G-22-07
IPUC DR 109
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 110:
Please clarify if all advertising expenses listed in Response to Production Response No.
31 are included in the revenue requirement. Please indicate which expenses, if any, are included
in the energy efficiency rider.
RESPONSE NO. 110:
All the advertising expenses included in the Response to Production Request No. 31 are
included in the revenue requirement and none of these expenses are included in the energy
efficiency rider. Some of the items included in the Response to Production Request No. 31 may
have been shared with the energy efficiency department (business unit 48526) because the item
promoted the energy efficiency program, however, the advertising expenses listed in the
Response to Production Request No. 31 did not include the amount that was shared with the
energy efficiency program and included in the energy efficiency rider.
INT-G-22-07
IPUC DR 110
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Nicole
Kivisto
REQUEST NO. 111:
Please provide the amount allocated to Intermountain Gas Company from its parent
company for the following categories:
a.General Counsel;
b.Executive Compensation;
c.Compensation Committee; and
d.Board of Directors and the Board of Directors Meetings.
RESPONSE NO. 111:
Please see the following for support of the items listed above:
a.Legal fees allocated to Intermountain from MDUR were $16,233.14.
b.Please see RFP 111 2022 MDUR Exec Comp.xlsx for executive compensation
allocated to Intermountain from MDUR.
c.The Compensation Committee expenses are included in the Board of Directors fees
and meeting expenses provided in part (d) below.
d.Please see RFP 2 Expense Summary.xlsx, item D, provided in the Response to IPUC
Request No. 2 for the amounts allocated to Intermountain from MDUR related to the
Board of Directors fees and meetings expenses.
INT-G-22-07
IPUC DR 111
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Lori Blattner/ Lori
Blattner
REQUEST NO. 112:
Please provide a schedule of all expenses associated with Case No. INT-G-22-01.
RESPONSE NO. 112:
In Response to Staff Request No. 23, the Company provided the file “RFP 23 Legal
Detail.xls” which outlined external legal fees. As shown on tab “GP-Bill and Payment Report”,
line 274, the total legal fees related to Case No. INT-G-22-01 were $8,571. There were no other
expenses paid in relation to this case.
INT-G-22-07
IPUC DR 112
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Zach Harris/ Tammy
Nygard
REQUEST NO. 113:
Please provide a schedule of rates for cases for other regulated subsidiaries of MDUR for
the last 5 years. Please include if those rate cases were settled. For each rate case that was settled
with a stated return on equity, please provide that return on equity.
RESPONSE NO. 113:
Commission Staff clarified for purposes of this production request the Company should
provide rate cases for other regulated subsidiaries of MDUR for the last five years that resulted
in a settlement with a specified return on equity (ROE). See below for a breakdown by MDUR
natural gas subsidiary:
Intermountain Gas Company (Idaho) –
o INT-G-16-02. Not Applicable.
Settlement did not occur.
Cascade Natural Gas Corporation (Oregon) –
o Docket No. UG-390 (Effective January 21, 2021). Not Applicable.
Application and Settlement included same ROE.
o Docket No. UG 347 (2018). Not Applicable.
Application and Settlement included same ROE.
Cascade Natural Gas Corporation (Washington) –
o Docket No. UG-210755 (2021). Not Applicable.
Application and Settlement included same ROE
o Docket No. 200568. (2020). Not Applicable.
Settlement did not occur
o Docket No. 190210
Application filed March 29, 2019. Requested 10.3% ROE.
Final Order 05 – Effective September 20, 2019, approved settlement with
proposed 9.4% ROE.
o Docket No. 170929 (2017)
N/A. Black box settlement with no specified ROE.
INT-G-22-07
IPUC DR 113
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Great Plains Natural Gas Company (Minnesota) –
o Docket No. G-004/GR-19-511 (Effective April 2021). Not Applicable.
Settlement did not occur.
Great Plains Natural Gas Company (North Dakota) –
o Combined with MDU ND Gas in Case No. PU-20-379 (Effective June 2021)
Initial filing on 08/26/2020 requested 10.20% ROE
Commission issued an order on May 24, 2021, approving the settlement.
Settlement includes 9.30% ROE
o Case No. PU-17-075
Initial filing on 02/03/2017 requested 9.50% ROE.
Commission issued order on 01/09/2019 approving settlement. Settlement
includes 9.40% ROE.
Montana-Dakota Utilities Company (North Dakota) –
o Case No. PU-20-379 (Effective June 2021)
See Great Plans above. Initial Filing requested 10.20% ROE, Settlement
included 9.30% ROE
Montana-Dakota Utilities Company (South Dakota) – Not Applicable.
o Prior to five-year timeline.
Montana-Dakota Utilities Company (Montana) –
o Docket No. 2020.06.076 (Effective April 2021). Not Applicable.
Commission order approved a black box settlement amount, but no
specified ROE.
o Docket No. 2018.09.060. Not Applicable
Commission order approved a black box settlement amount, but no
specified ROE.
o Docket No. D2017.9.79
Application filed 09/25/2017 with proposed 9.50% ROE
Final Order No. 7573f issued on 06/16/2018 approved settlement.
Settlement included 9.40% ROE.
Montana-Dakota Utilities Company (Wyoming) –
o Docket No. 30013-351-GR-19 (Record No. 15261)
Filed 05/23/2019 with proposed 10.30% ROE
Commission issued Memorandum Opinion, Findings, and Order
Approving Stipulation on March 17, 2020, approving Settlement.
Settlement included 9.35% ROE.
o Docket No. 30013-344-GR-18 (Record No. 15142). Not Applicable
Tax Plan Accounting for Tax Cuts and Jobs Act of 2017
INT-G-22-07
IPUC DR 113
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