HomeMy WebLinkAbout20230328INT to Staff - Response to No. 118_119_121.pdfRESPONSE TO THE TENTH 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: (208) 388-1200
Facsimile: (208) 388-1300
prestoncarter@givenspursley.com
blakeringer@givenspursley.com
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 TENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF
In response to the Tenth Production Request of the Commission Staff to Intermountain
Gas Company dated March 15, 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 28, 2023.
GIVENS PURSLEY LLP
Preston N. Carter
Attorney for Intermountain Gas Company
RECEIVED
2023 March, 28 4:39PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSE TO THE TENTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on March 28, 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
jan.noriyuki@puc.idaho.gov
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
dayn.hardie@puc.idaho.gov
Chad M. Stokes
Cable Huston LLP
1455 SW Broadway, Ste. 1500
Portland, OR 97201
Attorneys for Alliance of Western Energy
Consumers
cstokes@cablehuston.com
Marie Callaway Kellner
710 N. 6th Street
Boise, ID 83702
Attorneys for Idaho Conservation League
mkellner@idahoconservation.org
Brad Heusinkveld
Idaho Conservation League, Energy Assoc.
710 N. 6th Street
Boise, ID 83702
bheusinkveld@idahoconservation.org
Darrell Early
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
boisecityattorney@cityofboise.org
dearly@cityofboise.org
ejewell@cityofboise.org
RESPONSE TO THE TENTH 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
wgehl@cityofboise.org
Preston N. Carter
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 118:
Regarding the Company’s response to Production Request No. 93, please explain what
the following terms/acronyms mean in transaction descriptions: Boise GO, BSE Alliance
Meeting, Mentoring Program, MVBA, NCEL, SIEO, SSIP, SWIB, TSRA, Western Operating
Group, WEWI, and WROG.
RESPONSE NO. 118:
The following terms/acronyms in the transaction descriptions requested are as follows:
Boise GO – Boise General Office located at 555 S. Cole Road; Boise ID
BSE Alliance Meeting – BSE is Border States which provides materials
procurement services for Intermountain Gas Company.
Mentoring Program – Internal mentoring program to allows employees additional
opportunities to gain experience and knowledge from within the MDU Resources
regulated group that will help make them more effective in their current roles and
to help prepare them to compete for other opportunities in the organization. This
is accomplished through mentoring, administered by Human Resources, which is
intended to help employees establish a one-on-one relationship with a mentor that
will provide learning opportunities and enhance motivation to pursue long-range
career goals.
MVBA - Magic Valley Builders Association
NCEL - North Central Electric League
INT-G-22-07
IPUC DR 118
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SIEO - Southern Idaho Eastern Oregon Underground Corrosion Committee
SSIP - System Safety and Integrity Projects
SWIB - Montana State Workforce Innovation Board
TSRA - Montana Treasure State Resources Association
Western Operating Group - Round table meeting of directors and VP’s from
western utilities (IGC/Avista/Northwest Natural/Dominion West/Southwest
Gas/Cascade) to discuss operational challenges/opportunities/best practices.The
group was created 20 years ago to spend a shorter amount of time and money (no
“conference registration fees”) to bring leaders together. The host company
rotates. By hosting, a company provides a meeting facility and provides two
lunches and a dinner. Typical attendance runs around 15-20 people.
WEWI – This was a typo on the expense report, it should have been WEI –
Western Energy Institute.
WROG - Western Region Operations Group
INT-G-22-07
IPUC DR 118
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Ted Dedden/Jacob
Darrington
REQUEST NO. 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.
RESPONSE NO. 119:
Regarding the Company’s response to Production Request No. 93, the following non-
employee travel expenses were included in the case and charged to FERC account 921:
Hart Gilchrist’s June 2022 expense report included $279.85 spouse’s airfare to attend the
Idaho Governor’s Cup event.
Hart Gilchrist’s September 2022 expense report included two charges for $70.00 related
to spouse’s checked baggage fees to attend the Idaho Governor’s Cup event.
The Company does not permit Company-paid first-class travel. If an employee wishes to travel
first-class, the employee must personally pay the difference to upgrade. Please see RFP 119
Travel Policy.pdf for a copy of the Company’s travel policy for employees.
INT-G-22-07
IPUC DR 119
Page 1 of 1
INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Carmen Goicoechea/Jacob Darrington
REQUEST NO. 121:
Please provide a list of all expenses associated with Western Union or SpeedPay
customer payments.
RESPONSE NO. 121:
Please see RFP 121 Western Union.xlsx for transactions associated with Western Union
customer payments. The total for Western Union transactions is $68,990.20. Total deferred
Western Union payment processing fees in ‘WP- Western Union Fees’ in the Company’s
updated revenue requirement model provided in the Supplemental Response to AWEC
Production Request No. 2. is $68,976.65. The $13.55 difference relates to handling, redeposit, or
return fees which are directly expensed and not deferred.
For SpeedPay, customers pay the $1.99 transaction fee for payments. There are no fees
related to SpeedPay that Intermountain pays.
INT-G-22-07
IPUC DR 121
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