20230825Staff 1-8 to INT.pdf

CLAIRE SHARP bl
DEPUTY ATTORNEY GENERAL gy a-::,
IDAHO PUBLIC UTILITIES COMMISSION
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 THE APPLICATION )OF INTERMOUNTAIN GAS COMPANY FOR )CASE NO.INT-G-23-04
AUTHORITY TO CHANGE ITS PRICES )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO INTERMOUNTAIN GAS
)COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy Attorney General,requests that Intermountain Gas ("Company")provide
the followingdocuments and information as soon as possible,but no later than WEDNESDAY
SEPTEMBER 6,2023.1
This Production Request is to be considered as continuing,and the 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 telephonenumber of
I Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY l AUGUST 25,2023
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.1:Please provide a copy of any changes made to the Company's risk
management policy dated July 2021.
REQUESTNO.2:Please provide a copy of any changes made to the policies or
procedures used to identify the amount of capacity reservations maintained by the Company
since the 2022 PGA.
REQUESTNO.3:Please provide the natural gas purchase invoices for November 2022
throughJune 2023,reconciled to the PGA deferrals in the quarterly reports.
REQUESTNO.4:Please provide Lost and Unaccounted for Gas amounts by year
reported to Pipeline and Hazardous Material Safety Administration (PHMSA)for the five-year
period of 2019 through 2023.Include the Company's Lost and Unaccounted for Gas amounts
reported in 2019 through 2023 PGAs and explain any differences between the two.
REQUESTNO.5:Please provide supporting documentation for the calculation of
interest expense included for recovery in this case,includingbut not limited to:
a.Monthlybalances of the debt as well as the interest accrued by month;and
b.Loan agreements with stated interest rates for the debt facility.
REQUESTNO.6:Please provide supporting documentation for the In Person Payment
fees included in this application.
REQUESTNO.7:Please provide the details of the capacity releases detailed in Work
Paper No.5.
REQUESTNO.8:Please provide the contracts for the Upstream Agreements.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 2 AUGUST 25,2023
DATED at Boise,Idaho,this day of August 2023.
.aire Sh
Deputy At orney General
i:umisc:prodreq/intg23.4 prod req l
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS COMPANY 3 AUGUST 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST,IN CASE NO.INT-G-
23-04,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:prestoncarter@,givenspursley.com
E-MAIL:[e-mail] [e-mail]
SECRETARY
CERTIFICATE OF SERVICE