20230315Staff 118-121 to INT.pdf

CLAIRE SHARP El
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 5 PM 2:53
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )COMPANY'S APPLICATION FOR )CASE NO.INT-G-22-07
AUTHORITY TO INCREASE ITS RATES AND )CHARGES FOR NATURAL GAS SERVICE IN )TENTH PRODUCTION
THE STATE OF IDAHO )REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy Attorney General,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,MARCH 22,2023.1
This Production Request is to be considered as continuing,and Intermountain Gas
Company is requested to provide,by way of supplementaryresponses,additional documents that
it,or any person acting on its behalf,may later obtain that will augment the documents or
information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephone number of
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
TENTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l MARCH 15,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.118:Regarding the Company's response to Production Request No.93,
please explain what the followingterms/acronyms mean in transaction descriptions:Boise GO,
BSE Alliance Meeting,Mentoring Program,MVBA,NCEL,SIEO,SSIP,SWIB,TSRA,
Western Operating Group,WEWI,and WROG
REQUESTNO.119:Regarding the Company's response to Production Request No.93,
please list any airfare expenses in which non-employees'travel expenses were included in this
case,such as:spouses,children,family,friends,etc.Please also provide any instances where the
Company paid for First Class/Business Class seating for travelers and provide a copy of the
Company's travel policy for employees.
REQUESTNO.120:Regarding the Company's response to Production Request No.93,
please provide additional detail regarding the purpose and customer benefit of the transactions
included in the attached confidential sample.
REQUESTNO.121:Please provide a list of all expenses associated with Western
Union or SpeedPay customer payments.
DATED at Boise,Idaho,this day of March 2023.
Claire Sharp *
Deputy AttorneyGeneral
i:urnisc:prodreq/intg22.7cs1c prod req 10
TENTH PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 MARCH 15,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15*DAY OF MARCH 2023,
SERVED THE FOREGOING TENTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY,IN CASE
NO.INT-G-22-07,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR -REGULATORY AFFAIRS GIVENS PURSLEY LLP
INTERMOUNTAIN GAS CO 601 W BANNOCK ST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL:[e-mail]
E-MAIL:[e-mail] [e-mail]
CHAD M STOKES
CABLE HUSTON LLP
1455 SW BROADWAY
STE 1500
PORTLAND OR 97201
E-MAIL:[e-mail]
brmullins mwanalvtics.com
SECRE ARY
CERTIFICATE OF SERVICE