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Home My WebLink About20230329AWEC to INT 96-111.pdf AWEC’S FIFTH SET OF PRODUCTION REQUEST 1 MARCH 29, 2023 TO INTERMOUNTAIN Chad M. Stokes (OSB No. 004007) Cable Huston LLP 1455 SW Broadway Suite 1500 Portland, OR 97201 Telephone: (503) 224-3092 cstokes@cablehuston.com Attorneys for Alliance of Western Energy Consumers BEFORE THE PUBLIC UTILITY COMMISSION OF IDAHO INT-G-22-07 In the Matter of IN THE MATTER OF INTERMOUNTAIN GAS COMPANY FOR THE AUTHORITY TO CHANGE ITS RATES AND CHARGES FOR NATURAL GAS SERVICE IN THE STATE OF IDAHO ALLIANCE OF WESTERN ENERGY CONSUMERS’ FIFTH SET OF PRODUCTION REQUESTS TO INTERMOUNTAIN Alliance of Western Energy Consumers, by and through its attorney of record, requests that Intermountain Gas Company (“Company”) provide the following documents and information as soon as possible, but no later than the time provided by Idaho Admin. Code 31.01.01.225, or April 19, 2023. DEFINITIONS 1. “Company” or “Intermountain” or “IGC” refers to any affiliated company, or any officer, director or employee of Intermountain Gas Company or any affiliated company. 2. “Documents” refers to all writings and records of every type in your possession, control, or custody, whether or not claimed to be privileged or otherwise excludable from discovery, including but not limited to: testimony and exhibits, memoranda, papers, correspondence, letters, reports (including drafts, preliminary, intermediate, and final reports), surveys, analyses, studies (including economic and market studies), summaries, comparisons, tabulations, bills, invoices, statements of services rendered, charts, books, pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, microfiche, RECEIVED Wednesday, March 29, 2023 2:24:05 PM IDAHO PUBLIC UTILITIES COMMISSION AWEC’S FIFTH SET OF PRODUCTION REQUEST 2 MARCH 29, 2023 TO INTERMOUNTAIN computer data (including E-mail), computer files, computer tapes, computer inputs, computer outputs and printouts, vouchers, accounting statements, budgets, workpapers, engineering diagrams (including “one-line” diagrams), mechanical and electrical recordings, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical, or otherwise, and drafts of any of the above. “Documents” includes copies of documents, where the originals are not in your possession, custody or control. “Documents” includes every copy of a document which contains handwritten or other notations or which otherwise does not duplicate the original or any other copy. “Documents” also includes any attachments or appendices to any document. 3. “Identification” and “identify” mean: When used with respect to a document, stating the nature of the document (e.g., letter, memorandum, corporate minutes); the date, if any, appearing thereon; the date, if known, on which the document was prepared; the title of the document; the general subject matter of the document; the number of pages comprising the document; the identity of each person who wrote, dictated, or otherwise participated in the preparation of the document; the identity of each person who signed or initiated the document; the identity of each person to whom the document was addressed; the identity of each person who received the document or reviewed it; the location of the document; and the identity of each person having possession, custody, or control of the document. When used with respect to a person, stating his or her full name; his or her most recently known home and business addresses and telephone numbers; his or her present title and position; and his or her present and prior connections or associations with any participant or party to this proceeding. 4. “Person” refers to, without limiting the generality of its meaning, every natural person, corporation, partnership, association (whether formally organized or ad hoc), joint venture, unit operation, cooperative, municipality, commission, governmental body or agency, or any other group or organization. 5. “Studies” or “study” includes, without limitation, reports, reviews, analyses and audits. 6. The terms “and” and “or” shall be construed either disjunctively or conjunctively whenever appropriate in order to bring within the scope of this discovery any information or documents which might otherwise be considered to be beyond their scope. AWEC’S FIFTH SET OF PRODUCTION REQUEST 3 MARCH 29, 2023 TO INTERMOUNTAIN 7. The singular form of a word shall be interpreted as plural, and the plural form of a word shall be interpreted as singular, whenever appropriate in order to bring within the scope of this discovery request any information or documents which might otherwise be considered to be beyond their scope. / / / / / / AWEC’S FIFTH SET OF PRODUCTION REQUEST 4 MARCH 29, 2023 TO INTERMOUNTAIN INSTRUCTIONS 1. These requests call for all information, including information contained in documents, which relate to the subject matter of the Data Requests and which is known or available to the Company. 2. Where a Data Request has a number of separate subdivisions or related parts or portions, a complete response is required to each such subdivision, part or portion. Any objection to a Data Request should clearly indicate the subdivision, part, or portion of the Data Request to which it is directed. 3. The time period encompassed by these Data Requests is from 2015 to the present unless otherwise specified. 4. Each response should be furnished on a separate page. In addition to hard copy, electronic versions of the document, including studies and analyses, must also be furnished if available. 5. If the Company cannot answer a Data Request in full, after exercising due diligence to secure the information necessary to do so, state the answer to the extent possible, state why the Company cannot answer the Data Request in full, and state what information or knowledge the Company has concerning the unanswered portions. 6. If, in answering any of these Data Requests, the Company feels that any Data Request or definition or instruction applicable thereto is ambiguous, set forth the language the Company feels is ambiguous and the interpretation the Company is using in responding to the Data Request. 7. If a document requested is unavailable, identify the document, describe in detail the reasons the document is unavailable, state where the document can be obtained, and specify the number of pages it contains. 8. If the Company asserts that any document has been destroyed, state when and why it was destroyed and identify the person who directed the destruction. If the document was destroyed pursuant to the Company’s document destruction program, identify and produce a copy of the guideline, policy, or company manual describing such document destruction program. 9. If the Company refuses to respond to any Data Request by reason of a claim of privilege, confidentiality, or for any other reason, state in writing the type of privilege claimed and the facts and circumstances the Company relies upon to support the claim of privilege or the reason for refusing to respond. With respect to requests for documents to which the Company refuses to respond, identify each such document, and specify the number of pages it contains. Provide: (a) a brief description of the document; (b) date of document; (c) name of each author or AWEC’S FIFTH SET OF PRODUCTION REQUEST 5 MARCH 29, 2023 TO INTERMOUNTAIN preparer; (d) name of each person who received the document; and (e) the reason for withholding it and a statement of facts constituting the justification and basis for withholding it. 10. Identify the person from whom the information and documents supplied in response to each Data Request were obtained, the person who prepared each response, the person who reviewed each response, and the person who will bear ultimate responsibility for the truth of each response. 11. If no document is responsive to a Data Request that calls for a document, then so state. 12. These requests for documents and responses are continuing in character so as to require the Company to file supplemental answers as soon as possible if the Company obtains further or different information. Any supplemental answer should refer to the date and use the number of the original request or subpart thereof. 13. Whenever these Data Requests specifically request an answer rather than the identification of documents, the answer is required and the production of documents in lieu thereof will not substitute for an answer. / / / / / / / / / / / / AWEC’S FIFTH SET OF PRODUCTION REQUEST 6 MARCH 29, 2023 TO INTERMOUNTAIN DATA REQUESTS AWEC PR 096 to INTERMOUNTAIN Reference Intermountain’s response to Staff Production Request 2, “RFP 2 Cost Allocation Manual 2022,” Page 5: Please identify the rate base and operating expense associated with FutureSource included in test period results. Please also provide workpapers used to allocate the costs to the Idaho jurisdiction. AWEC PR 097 to INTERMOUNTAIN Reference Intermountain’s response to AWEC Data Request 67: Please identify the total balance of CIAC attributable to the construction of RNG facilities and identify the amount of tax gross-up included in those balances. AWEC PR 098 to INTERMOUNTAIN Please provide Intermountain’s most recent long term load forecast, including a forecast of throughput and customer count by rate class. AWEC PR 099 to INTERMOUNTAIN Reference Intermountain’s response to Staff Production Request 36, file “CONFIDENTIAL RFP 36 IGC GL Claims 2017 to current,” claim “P 41329036201”: Please provide a description of the events resulting in the referenced claim. AWEC PR 100 to INTERMOUNTAIN Please detail the total gallons and dollars of LNG sold to non-utility customers from the Nampa facility by year, since the facility was constructed. AWEC PR 101 to INTERMOUNTAIN Please detail the total dth volumes and gallons of LNG delivered to utility customers from the Nampa facility by year, since the facility was constructed. AWEC PR 102 to INTERMOUNTAIN Please state the total test year revenue requirement of the Nampa LNG Facility, including detail of gross plant, accumulated depreciation, accumulated deferred taxes, operating expenses, depreciation expenses, and any other relevant revenue requirement item. AWEC PR 103 to INTERMOUNTAIN Please provide workpapers used to calculate the margin and O&M credits for the Nampa LNG facility included on lines 3 and 4 in Exhibit 11 of the 2022 PGA Application, Case INT-G-22-04. In the workpapers, at a minimum, please identify the total volumes and the rates applied to derive the referenced credit amounts. AWEC PR 104 to INTERMOUNTAIN Reference Intermountain’s response to Staff Production Request 3, workpaper “RFP 3 - IGC Cost of Service 2022:” Please identify the line items from AWEC production request 24 AWEC’S FIFTH SET OF PRODUCTION REQUEST 7 MARCH 29, 2023 TO INTERMOUNTAIN where the cost of service credits identified in the referenced response are included in test period results. AWEC PR 105 to INTERMOUNTAIN What was Intermountain’s property tax rate for 2022? AWEC PR 106 to INTERMOUNTAIN Reference Intermountain’s response to AWEC Production Request 83: Are any of the amounts identified in the referenced response allocated to affiliate entities? If yes, please detail the amount allocated. If no, please explain why not. AWEC PR 107 to INTERMOUNTAIN Please state the amount of R&D Tax credits that intermountain has generated by year over the period 2019 through 2022. AWEC PR 108 to INTERMOUNTAIN Do Intermountain’s unadjusted test period results exclude all incentive compensation? Please explain why an adjustment is necessary to incentive compensation in Darrington Exhibit 9. AWEC PR 109 to INTERMOUNTAIN Please identify the total amount of incentives by FERC account included in the 2021 test period results. AWEC PR 110 to INTERMOUNTAIN Please identify all costs allocated from Intermountain to another MDU subsidiary in the test period by FERC account. AWEC PR 111 to INTERMOUNTAIN Please detail the total number of employees at the customer service center and detail the amount of the employees’ costs allocated to other MDU utilities. DATED at Portland, OR, this 29th day of March 2023. _____________________________ Attorneys for Alliance of Western Energy Consumers