20230327INT to AWEC 63-83.pdf

RESPONSES 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: [phone]
Facsimile: [phone]
[e-mail]
[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 ALLIANCE OF WESTERN
ENERGY CONSUMERS’ THIRD SET OF
PRODUCTION REQUESTS

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Alliance of Western Energy Consumers’ (“AWEC”) Third Set of Production
Requests to Intermountain Gas Company served March 6, 2023, submits the following
responses. Responsive documents are available for download using the link provided in the
accompanying email.
DATED: March 27, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
2023 March, 27 4:27PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO AWEC’S SECOND PRODUCTION REQUESTS PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on March 27, 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]

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
[e-mail]

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 63:
Reference Intermountain’s Supplemental Response to AWEC Production Request 02:
Please explain the drivers for the reduction in income tax expense relative to Intermountain’s
initial filing. If the change was the result of a correlation identified in a Production Request,
please identify the Production Request.
RESPONSE NO. 63:
The two main drivers of the reduction in income tax expense relate to errors in the tax
workpapers/exhibits in the Company’s original filing. The first error was using an incorrect sign
on plant related deferred taxes on Exhibit No. 11. This error was identified while preparing the
Company’s response to AWEC Production Request No. 21. The second error related to
inadvertently excluding the amount of investment tax credit (ITC) generated in 2022 on Exhibit
No. 10. This error was identified while preparing the Company’s response to AWEC Production
Request No. 23.
Please see the Company’s original and supplemental responses to AWEC Production
Requests Nos. 21 and 23 for more information.
INT-G-22-07
AWEC PR 63
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/ Jacob
Darrington
REQUEST NO. 64:
Reference Staff Production Request 10: Please provide credit card statements for
November 2022 and December 2022 in the manner requested in the referenced response.
RESPONSE NO. 64:
Credit card statements for November 2022 were provided in response to IPUC Request
No. 10 as “CONFIDENTIAL RFP 10 Nov-Dec 2022.xlsx”. The credit card statements for
December 2022 were provided in Supplemental Response to IPUC Request No. 10
“CONFIDENTIAL Supplemental RFP 10 Dec 2022- Jan 2023.xlsx”.
INT-G-22-07
AWEC PR 64
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 65:
Please identify the amount of Contributions in Aid f Construction (“CIAC”) received in
2022 by month. If available, please identify both the principal balance as well as the tax gross-up
amount on the CIAC receipts.
RESPONSE NO. 65:
The amount of Contribution in Aid of Construction (“CIAC”) received in 2022 by month
are presented in the table below. All amounts are principal balance. As explained in the
Response to AWEC Production Request No. 67, the Company is only allowed to charge the tax
gross-up on CIACs for RNG projects. One CIAC was accrued for in 2022 for an RNG facility.
However, per the contract the gross-up portion of the payment will be received in 2023.
INT-G-22-07
AWEC PR 65
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 67:
Please provide an explanation of how Intermountain accounts for CIAC and the
associated tax gross-up amounts.
RESPONSE NO. 67:
CIACs are recorded to plant in service as a reduction to the cost of the associated
property, plant and equipment. Under Commission Order No. 21933, Intermountain is not
permitted to gross-up CIACs to cover the additional income tax generated by the CIAC payment.
However, in Order No. 34693 in Case No. INT-G-20-03, the Commission granted a limited
waiver to Order No. 21933 to allow for the collection of a gross-up on CIACs received for the
construction of RNG facilities.
INT-G-22-07
AWEC PR 67
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 68:
Does Intermountain amortize the CIAC rate balances as a reduction to operating
expenses? If yes, please identify where the revenue requirement workpapers those amortization
amounts may be found. If not, please explain how ratepayers get the periodic benefit associated
with CIAC.
RESPONSE NO. 68:
CIACs are recorded as a reduction to the cost of the associated property, plant and
equipment thereby lowering rate base. The CIAC is then depreciated along with the associated
plant and the periodic benefit is embedded in the depreciation expense included in the updated
revenue requirement on Exhibit No. 2, Line 16.
INT-G-22-07
AWEC PR 68
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Kim Ukestad/Jacob
Darrington
REQUEST NO. 69:
Does Intermountain account for the tax-gross up associated with CIAC differently that
the principal amount? If yes, please explain how these two aspects of CIAC receipts are handled
for accounting purposes.
RESPONSE NO. 69:
As explained in the Response to AWEC Production Request No. 67, Intermountain is
only allowed to gross-up CIACs received for RNG facilities. The principal portion of the CIAC
is recorded as a reduction to the cost of the associated property, plant and equipment. The tax
gross-up on the CIAC for an RNG facility is recorded as other revenue on the statement of
operations.
INT-G-22-07
AWEC PR 69
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob Darrington/
Jacob Darrington
REQUEST NO. 70:
Reference Intermountain’s Supplemental Response to AWEC Production Request 02:
Please identify the amount of excess deferred federal income taxes being amortized to rates and
identify where in the revised revenue requirement workpapers that amortization (or benefit) can
be found.
RESPONSE NO. 70:
Please see the Company’s Supplemental Response to AWEC Production Request No.19
with regard to plant related excess deferred federal income taxes. Excess deferred federal
income taxes related to Advances in Aid of Construction, Uniform Capitalization, and
Investment Tax Credit are found on WP-Deferred Tax, rows 67-69 and are reflected on Exhibit
No. 11, Cell E23 of the Company’s updated revenue requirement model provided in the
Supplemental Response to AWEC Production Request No. 2.
INT-G-22-07
AWEC PR 70
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/ Kirsti
Hourigan
REQUEST NO. 71:
Please identify Intermountain’s pension expense included in the 2022 Test Period. Please
provide separate detail for any pension expense amounts allocated from, or to, another MDUR
entity.
RESPONSE NO. 71:
Please see tab ‘Total Pension Expense’ in AWEC PR 71 Pension Exp.xlsx for pension
expense included in the 2022 Test Period. Please see tab ‘Allocated Pension Expense’ in AWEC
RFP 71 Pension Exp.xlsx for all pension expense amounts allocated from MDU Resources
(Business Unit 48516) and MDU (Business Unit 48595).
INT-G-22-07
AWEC PR 71
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Craig Pulley/ Kirsti
Hourigan
REQUEST NO. 72:
Please provide the actuarial reports and associated accounting workpapers used to
calculate pension expenses for 2022.
RESPONSE NO. 72:
Please reference IPUC Production Request No. 15 for information and actuarial reports
regarding pension expenses. In addition, the Company’s response to AWEC Production Request
No. 49 includes calculations for 2022 pension expenses. During 2022, the rate contributed was
$4.97 for each eligible hour worked. The Company does not contribute additional funds to help
offset any plan expenses.
INT-G-22-07
AWEC PR 72
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Craig Pulley/ Kirsti
Hourigan
REQUEST NO. 75:
If not already provided in response to the prior requests, please provide the most recent
actuarial reports for pension expense and OPEB expense.
RESPONSE NO. 75:
The information requested has been provided in prior responses. See the Company’s
response to AWEC Request Nos. 72, 73, and 74.
INT-G-22-07
AWEC PR 75
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 76:
Reference Intermountain’s Supplemental Response to AWEC Production Request 24,
Attachment “AWEC PR 24 2022 Op Exp But Includes All OM”: Please reconcile the O&M
amounts included in the referenced attachment to the amount the amounts included in the
Supplemental Response to AWEC Data Request 02, tab “WP – O&M FERC, columns “J:K.”
The differences between the two files appears to be related to the treatment of pension expenses,
although it is not apparent from the workpapers.
RESPONSE NO. 76:
Please see Excel file AWEC PR 76 Reconcile OM Minus Gas Costs which shows the
reconciliation in total between the attachment provided in AWEC PR 24 and the sum of columns
“J:K” on tab “WP – O&M FERC” of the updated revenue requirement model. The total
difference is due to gas costs which are not considered as O&M in the revenue requirement
model and are removed on Exhibit No. 6. The Company notes that there are differences of
categorization between the attachment provided in AWEC PR 24 and tab “WP – O&M FERC”
due to the way the Pivot Table in the attachment to AWEC PR 24 was set up. The Pivot Table
was based on the FERC Minor columns “C:D” on tab “2022 ALL OM” in the attachment to
AWEC PR 24. However, tab “WP – O&M FERC” of the updated revenue requirement model
was based on column “N” on tab “2022 ALL OM” in the attachment to AWEC PR 24. The
Pivot Table in the attachment to AWEC PR 24 should have been based on column “N” on tab
INT-G-22-07
AWEC PR 76
Page 1 of 2
“2022 ALL OM” because the Company uses the information in column “N” to prepare its FERC
Form 2. The Company apologizes for the confusion.
INT-G-22-07
AWEC PR 76
Page 2 of 2
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 77:
Reference Intermountain’s Response to AWEC Production Request 24, FERC Account
913: Please provide an explanation for the $10,000 charge to EAST IDAHO HOCKEY INC, and
provide copies or details of the advertisements purchased.
RESPONSE NO. 77:
The $10,000 payment to East Idaho Hockey Inc was for advertising expense related to a
print advertisement and a video board advertisement at Mountain America Center. The
advertising promoted damage prevention (i.e. call 811 before you dig) as well as the Company’s
Energy Efficiency Program Energy Star® certified homes and appliance rebates. Please see the
following documents for support for this expense:
Invoice - AWEC PR 77 EAST IDAHO HOCKEY INC inv 111918.pdf
Print Ad - AWEC PR 77 IGC_Spud Kings Hockey Sponsorship Ad.pdf
Video Ad - AWEC PR 77 Video Board Ad.pdf
INT-G-22-07
AWEC PR 77
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 78:
Please identify each sports-team or arena sponsorships, or event tickets that
Intermountain purchased in the 2022 Test Period. Please identify the sports team, the arena, the
test period expense, and the FERC account. Please also identify whether the sponsorship entitles
Intermountain to event tickets, a club tickets, or other similar benefits.
RESPONSE NO. 78:
Intermountain does not sponsor any sports teams but does purchase event tickets. The
teams Intermountain purchased event tickets for in the 2022 Test Period are:
Idaho Steelheads Hockey
Boise Hawks Baseball
Boise State Bronco Football
Boise State Bronco Basketball
2022 Famous Idaho Potato Bowl
The FERC account used to record the purchase of event tickets is 921. Please see AWEC PR 78
Sports Event Tickets.xlsx for a listing of the 2022 Test Period expenses and the sports team
associated with each.
INT-G-22-07
AWEC PR 78
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Jacob
Darrington/Jacob Darrington
REQUEST NO. 79:
Reference Intermountain’s Response to AWEC Production Request 24, FERC Account
913: Please copies of all advertisements in “SNAKE RIVER VALLEY BCA” purchased in the
test period.
RESPONSE NO. 79:
The advertisements purchased from Snake River Valley BCA consisted of three invoices.
Two invoices related to Parade of Homes print advertisements, one for spring and one for fall.
Please see the following support for those advertisements:
Spring invoice- AWEC PR 79 Snake River Valley inv 473.pdf
Fall invoice- AWEC PR 79 Snake River Valley inv 1457.pdf
Print Ad for both invoices- AWEC PR 79 Parade_of_homes_ad FINAL.pdf
The third invoice relates to an advertisement booth at an event for Snake River Valley BCA (see
AWEC PR 79 Snake River Valley BCA inv 1124.pdf). Representatives from Intermountain
promoted the efficient use of natural gas by educating builders attending the event about the
energy efficiency program at Intermountain and the benefits of energy efficiency to the end user
and to all Intermountain customers. Please see the following support for this advertisement:
Invoice- AWEC PR 79 Snake River Valley BCA inv 1124.pdf
Booth advertisement- AWEC PR 79 Scholarship Promotion Activity.pdf
INT-G-22-07
AWEC PR 79
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 80:
Reference Intermountain’s Response to AWEC Production Request 24, FERC Account
912: Please provide an explanation of the service performed by Bannock Development Corp and
explain how those activities benefit ratepayers.
RESPONSE NO. 80:
Bannock Development Corporation is a not-for-profit economic development company
that focuses on the economic well-being and quality of life for the Company’s customers in
Southeast Idaho. They are instrumental in attracting and retaining businesses to the area. Strong
communities benefit ratepayers by providing safe and desirable places to live and to build
businesses. This in turn promotes economic growth and spreads the costs of natural gas service
over a larger customer base. A region with a healthy economy also attracts people to the area to
work, improving the talent pool to draw from to ensure Intermountain has top employees to
perform the functions that keep existing and future infrastructure safe and reliable. Supporting
Bannock Development Corporation also allows Intermountain an opportunity to participate in
site selection inquiries for new businesses allowing the promotion of more cost-effective
opportunities for those businesses to consider as a potential new customer. Finally, involvement
with the Bannock Development Corp provides the Company with insight into potential growth
areas which is helpful in the Company’s Integrated Resource Planning activities.
INT-G-22-07
AWEC PR 80
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 81:
Reference Intermountain’s Response to AWEC Production Request 24, FERC Account
930: Please provide an explanation for the $21,000 charge to “MCCLATCHY COMPANY
LLC,” including any invoices and or receipts associated with that payment. Please also explain
how the payment benefits ratepayers.
RESPONSE NO. 81:
The charge of $21,000 to MCCLATHCY COMPANY LLC is for Intermountain’s
participation in Together Treasure Valley which is a collaboration of area businesses who seek
and fund economic development projects that will have a lasting, meaningful impact in
communities throughout the Treasure Valley. Strong communities benefit ratepayers by
providing safe and desirable places to live and to build businesses. This in turn promotes
economic growth and spreads the costs of natural gas service over a larger customer base. Please
see AWEC PR 81 MCCLATCHY COMPANY LLC inv TTV22-IMG-01.pdf for a copy of the
invoice related to this charge.
INT-G-22-07
AWEC PR 81
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Lori Blattner/ Nicole
Kivisto
REQUEST NO. 82:
Is Intermountain planning to sponsor the Governor’s Cup in 2023 and 2024?
RESPONSE NO. 82:
The Company has not yet committed to a sponsorship for the Governor’s Cup in 2023 or
2024.
INT-G-22-07
AWEC PR 82
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
THIRD PRODUCTION REQUEST OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 83:
Reference Intermountain’s Response to AWEC Production Request 24, FERC Account
923: Please provide an explanation for the $204315 in fees paid to “RICOH USA INC” and the
type of service received.
RESPONSE NO. 83:
Intermountain uses RICOH USA INC for office, printing, and mail room services for the
Boise General and District Offices. The $204,315 in fees paid relate to labor, mileage, and
tracking fees.
INT-G-22-07
AWEC PR 83
Page 1 of 1