20231023INT to Staff 1-2_Confidential Letter.pdf

601 W. Bannock Street
PO Box 2720
Boise, ID 83701
Main: 208-388-1200 www.givenspursley.com
Preston N. Carter
Direct: 208-388-1222 [e-mail]

October 23, 2023

Via Email
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

Re: Intermountain Gas Company
INT-G-23-05

Dear Ms. Noriyuki:

In regard to the above reference Case, enclosed for filing with this Commission are
Intermountain Gas Company’s (“Intermountain”) Responses to the First Production Request of
the Commission Staff.

Pursuant to the confidentiality agreement signed by the parties in this case and Idaho
PUC Rules of Procedure, IDAPA31.01.01.067, 31.01.01.233, and 31.02.01.005.07, the enclosed
information is confidential, proprietary and trade secret information of Intermountain and is
protected by law from public inspection, examination or copying, pursuant to Idaho Code
Sections 74-106, 107, and 48-801 et seq. In accordance with the protective agreement and IPUC
Rule 67.02.a, the confidential information is marked “Confidential” and/or submitted on yellow
paper.

Thank you for your cooperation. If you should have comments or questions regarding
this request, please contact Lori A. Blattner (208-377-6015) or me (208-388-1222).

Sincerely,

Preston N. Carter

Enclosures
18039008.1

RECEIVED
2023 OCTOBER 23, 2023 11:15AM
IDAHO PUBLIC
UTILITIES COMMISSION

RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorneys for Intermountain Gas Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY’S
APPLICATION FOR AUTHORITY TO FILE
ITS COMPOSITE DEPRECIATION AND
AMORTIZATION RATES EVERY FIVE
YEARS INSTEAD OF EVERY THREE YEARS

Case No. INT-G-23-05

INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF

In response to the First Production Request of the Commission Staff to Intermountain
Gas Company dated October 11, 2023, Intermountain Gas Company, (“Intermountain,”
“Applicant,” or “Company”), submits the following responses. Confidential responses and
documents are subject to the protective agreement in this case.
DATED: October 23, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company
RECEIVED
2023 OCTOBER 23, 2023 11:15AM
IDAHO PUBLIC
UTILITIES COMMISSION

RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE
I certify that on October 23, 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]

Preston N. Carter