20230526Staff 1-6 to INT.pdf

CHRIS BURDIN
DEPUTYATTORNEY GENERAL pg 7:()2IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-ABOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )COMPANY'S TARIFF ADVICE NO.23-02 )CASE NO.INT-G-23-01
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Intermountain Gas Company ("Company")
provide the followingdocuments and informationas soon as possible,but no later than
FRIDAY,JUNE 2,2023.1
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
informationproduced.
'Staff is requesting an expedited response.If responding by this date will be problematic,please call Staffsattorneyat(208)334-0314.
FIRST PRODUCTIONREQUEST
TO INTERMOUNTAIN GAS COMPANY l MAY 26,2023
Please provide answers to each question,supporting workpapers that provide detail or are
the source of informationused in calculations,and the name,job title,and telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as responses to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Please explain why the Company included abandonment cost in the
current tariff.
REQUESTNO.2:Please explain the operational process or steps required to abandon a
service line.Please also explain the costs.
REQUESTNO.3:If abandoning a line as part of a relocation of a service line,does the
Company include the cost of abandoning the old line in the relocation cost?Please explain.
REQUESTNO.4:As explained in the filing,abandoninga service line is done for
safety purposes.Please explain whether the Company always removes a service line regardless
of whether the customer requests it.
REQUESTNO.5:If these costs are not paid by the customer requesting the service line
to be removed,will the Company request recovery in rates so that the cost is borne by other
ratepayers?
REQUESTNO.6:Please provide a comprehensive list and a description of the different
circumstances that cause a line to be abandoned.Also,please answer the following:
a.For each circumstance,please identify the party (customer,developer,other)
triggering the need for abandonment;and
b.If the party that causes the need is the developer,please explain why the
developer shouldn'tbe required to remove the service line before new service
lines are installed.
FIRST PRODUCTIONREQUEST
TO INTERMOUNTAIN GAS COMPANY 2 MAY 26,2023
DATED at Boise,Idaho,this ѢC day of May 2023.
Chris Burdin
Deputy Attorney General
i:umise:prodreq/intg23.ldhml prod req l
FIRST PRODUCTIONREQUEST
TO INTERMOUNTAIN GAS COMPANY 3 MAY 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF MAY 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOINTERMOUNTAINGASCOMPANY,IN CASE NO.INT-G-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LORI BLATTNER PRESTON N CARTERDIR-REGULATORYAFFAIRS GIVENS PURSLEYLLPINTERMOUNTAINGASCO601WBANNOCKSTPOBOX7608BOISEID83702BOISEID83707E-MAIL:[e-mail]-MAIL:[e-mail] [e-mail]
SECI AÁ
CERTIFICATEOF SERVICE