20230314INT to Staff - Response to No. 3_5_18_19_21_28_31_33_34_37_38_46.pdf

SUPPLEMENTAL RESPONSE TO FIRST 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 FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF

In response to the First Production Request of the Commission Staff to Intermountain
Gas Company dated December 16, 2022, Intermountain Gas Company, (“Intermountain,”
“Applicant,” or “Company”), submits the following supplemental 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 3:59:02 PM
IDAHO PUBLIC
UTILITIES COMMISSION
SUPPLEMENTAL RESPONSE TO FIRST 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]

SUPPLEMENTAL RESPONSE TO FIRST 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
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Nicole Kivisto
REQUEST NO. 3:
Please provide all contracts, agreements and other related and underlying documents that
establish the services provided and received, and the costs charged and paid between the
affiliated companies for 2017 through 2022 to date.
Supplemental RESPONSE NO. 3:
The additional December 2022 costs charged and paid between the affiliated companies
are provided as a Supplement to the original Response to IPUC Request No. 3. Please see
Supplemental RFP 3 Affiliate Transactions.xlsx.
INT-G-22-07
IPUC DR 3 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/ Patrick
Darras
REQUEST NO. 5:
Please provide a list of all leased items in 2017 through 2022 to date. Please separate
capital leases from operating leases and show the dates, terms, amounts, and accounts used for
each lease.
Supplemental RESPONSE NO. 5:
Please see “Supplemental RFP 5 – Lease Listing.xlsx” for a listing of the Company’s
leases from 2017 through December 2022. Updates from the previously provided listing are
noted in yellow.
INT-G-22-07
IPUC DR 5 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 18:
Please provide a schedule of the Company's "Property Held for Future Use" through
2022. Please consider this an ongoing request and provide updates to this schedule whenever
actuals are updated. Please provide worksheets in Excel format with formulas intact.
Supplemental RESPONSE NO. 18:
The Company’s “Property Held for Future Use” consists of a portion of the land and
building at its Customer Service Center in Meridian, Idaho. Please see attached
“Supplemental RFP 18 Plant Held for Future Use.xlsx” which has been updated to reflect the net
book value as of December 31, 2022.
INT-G-22-07
IPUC DR 18 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 19:
Please provide a schedule of "Prepaid Items" for 2020, 2021 and 2022 to date, showing
dollar amounts and account numbers where posted, vendors, and related explanations (including
allocated amounts). Please supplement your response as additional information becomes
available.
Supplemental RESPONSE NO. 19:
The prepaid schedules for December 2022 are provided as a Supplement to the original
Response to IPUC Request No. 19. Please see Supplemental RFP 19 JP_CB Prepayment Tracking
22.xlsx and Supplemental RFP 19 Other Prepaid.xlsx.
INT-G-22-07
IPUC DR 19 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 21:
Please provide a copy of all adjusting, or closing, entries for 2017 through 2022 to date in
the general ledger, and the related explanation for each entry.
Supplemental RESPONSE NO. 21:
The closing journal entries for December 2022 are provided as a Supplement to the
original Response to IPUC Request No. 21. Please see supporting documentation in folder
Supplemental RFP 21 Closing Entries 2022.
INT-G-22-07
IPUC DR 21 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted
Dedden/Nicole Kivisto
REQUEST NO. 28:
Please provide a copy of the 2017 through 2022 shareholder annual report and proxy
statement.
Supplemental RESPONSE NO. 28:
The 2022 annual report is provided as a Supplement to the original Response to IPUC
Request No. 28. Please see Supplemental RFP 28 2022-Annual-Report-10-K-2023-Proxy.pdf.
INT-G-22-07
IPUC DR 28 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cheryl Imlach/Jacob
Darrington
REQUEST NO. 31:
Please provide a schedule with details for all advertising expenses included within the
Company's filing. Please include within your response the dates, vendors, explanations, amounts
posted, copies of the related advertising, and associated customer benefit. Please provide
worksheets in Excel format with formulas intact.
SUPPLEMENTAL RESPONSE NO. 31:
In its previous response, the Company provided information through November 2022.
Please see the Excel file Supplemental RFP 31 - Advertising Expense showing information for
December 2022. The December information and the tabs that changed from the original file are
highlighted in yellow. Additional attachments not previously provided are included and
organized in folders in the Supplemental RFP 31 Attachments folder and match a corresponding
tab in the Excel file.
INT-G-22-07
IPUC DR 31 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 33:
Please provide a schedule and journal entries of all additions and retirements to Plant in
Service since the beginning of 2017, including installation date, account, installed cost, and
estimated depreciable life.
Supplemental RESPONSE NO. 33:
Please see “Supplemental RFP 33 – Plant in Service Transactions.xlsx” for schedules of
the Company’s additions and retirements, as well as the transactional information. The 2022
information has been updated to reflect all activity through December 2022. The Excel file
contains four tabs reflecting the requested information as follows:
1.“Additions” Tab – This table reflects all additions to Plant in Service, by year, since the
beginning of 2017 through December 2022. Also reflected in this table are the estimated
depreciable lives of each FERC utility account.
2.“Retirements” Tab – This table reflects all retirements from Plant in Service, by year,
since the beginning of 2017 through December 2022.
3.“Additions Transactions” Tab – This is a data dump of all the additions transactions since
the beginning of 2017 through December 2022. Columns that contain the requested
information including installation date (eng_in_service_year), account (utility_account),
and installed cost (activity_cost) are highlighted in green.
4.“Retirement Transactions” Tab – This is a data dump of all the retirement transactions
since the beginning of 2017 through December 2022. Columns that contain the requested
INT-G-22-07
IPUC DR 33 - Supplemental
Page 1 of 2
information including installation date (eng_in_service_year), account (utility_account),
and installed cost (activity_cost) are highlighted in green.
INT-G-22-07
IPUC DR 33 - Supplemental
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad/Patrick
Darras
REQUEST NO. 34:
Please provide an analysis of any sales of land and/or plant for the years 2017 through
2022 to date, if any. Please show gains, losses, and supporting documentation including
accounting entries for removal of items from rate base.
Supplemental RESPONSE NO. 34:
Please see “Supplemental RFP 34 – Salvage_GL.xlsx” for an analysis of the Company’s
sales of land and plant for the years 2017 through December 2022. The first tab within the file
“Req 34” is a summary of the sale or trade transactions that resulted in the Company receiving
salvage or recording a gain/loss. The second tab “Transactions” is a transactional data dump
showing the recording of the retirement of the assets, the recognition of any salvage received,
and any gain/loss on the transaction.
The majority of the salvage the company receives is for its vehicles and work equipment
upon sale or trade-in. When retirements are recorded the company credits plant and debits
reserve, thereby removing this amount from rate base. When salvage is received it is recorded as
a credit to reserve which in turn reduces the net book value or the Company’s plant assets as well
as its rate base.
Some of the Company’s general plant assets are set to auto-retire at the end of their
estimated depreciable life. In the summary there are three lines in which salvage was recorded
for assets that auto retire. Therefore, no specific retirement transaction is noted for these salvage
amounts as the asset would have retired from plant at a different time.
INT-G-22-07
IPUC DR 34 - Supplemental
Page 1 of 2
The gain/loss transaction noted in 2017 for FERC 385 did not truly result in the
recognition of a gain or loss. During the processing of this retirement, an incorrect transaction
code was selected resulting in PowerPlan, the Company’s fixed asset accounting software,
recognizing the gain/loss on that transaction. This was subsequently corrected through an entry
in the depreciation module to reverse the gain/loss and record the retirement of the full asset to
reserve.
The gain/loss recorded in 2018 for FERC 389 also did not result in the Company
recognizing a gain or loss. This system recognized gain/loss that resulted from the recording of
salvage received for the sale of land was subsequently reversed and recorded to the reserve
account of 390 Structures.
INT-G-22-07
IPUC DR 34 - Supplemental
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 37:
Please provide a listing of all organizations the Company participates in and the costs of
participating in those organizations (e.g. GRI, etc.). Please identify any costs that are allocated
between utility and non-utility operations.
Supplemental RESPONSE NO. 37:
The December 2022 activity is provided as a Supplement to the original Response to
IPUC Request No. 37. Please see the file Supplemental RFP 37 Organizations Dec 2022.xlsx for
amounts charged to accounts 5912 – Company Organizational Dues and 5811 –
Professional/Organization Dues in December 2022. Please note that any costs 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 37 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Kim Ukestad
(Capital), Ted Dedden (Operating)/ Patrick Darras (Capital), Jacob Darrington (Operating)
REQUEST NO. 38:
Please provide copies of the monthly, quarterly, and annual comparison of operating and
capital budget to actual expenditures for 2017 through 2022 to date. Please include within your
response a narrative explanation for budget variations. This should include, but not be limited to,
written operating and capital budget variance reports and explanations used by Company officers
and managers to monitor and control budgets under their responsibility. Please supplement your
response as additional information becomes available.
Supplemental RESPONSE NO. 38:
Please see “Supplemental RFP 38 Capital Budget Variances.xlsx” for a comparison of
the capital budget to actual expenditures for 2017 through 2022. The 2022 Actuals vs Plan tab
has been updated to reflect all capital expenditures through December 2022.
A separate tab for each year is included in this file. Within each tab the actual to budget
comparison is presented by month and in total for the year. Explanations for total year variances
greater than $1 million have been provided.
Please see Supplemental RFP 38 2022 O&M.pdf documents that offer explanations for
material O&M variances compared with Plan for 2017 through 2022 to date.
INT-G-22-07
IPUC DR 38 - Supplemental
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob Darrington
REQUEST NO. 46:
Please provide a detailed schedule of the "Advances in Aid of Construction" received by
the Company from 2017 through 2022 to date. Please include within your response the names,
dates, amounts and accounts posted. Please consider this a continuing request and provide
updates to this schedule at the same time actuals are updated. Please provide worksheets in Excel
format with formulas intact.
Supplemental RESPONSE NO. 46:
The December 2022 schedule is provided as a Supplement to the original Response to
IPUC Request No. 46. Please see Supplemental RFP 46 ADVANCES RECON 2022-
Updated.xlsx
INT-G-22-07
IPUC DR 46 - Supplemental
Page 1 of 1