20060630Don Howell letters to Ms. Robinson.pdf

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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
May 18, 2006
Ms. Jane Robinson
10225 Hackamore Drive
Boise, ID 83709
RE:Your Formal PUC Complaint
Dear Ms. Robinson:
Given our inability to reach each other by telephone, I am writing this letter to address your questions and
provide you with some additional information. I understand from your conversation with my secretary
last Monday, that you requested some additional information and possibly needed more time before
finalizing" your complaint against Intermountain Gas Company. In particular, you asked for your
monthly gas usage and other billing data back to December 1999. I also understand that you would like
an organizational chart for Intermountain Gas.
Let me first address your request for usage history back to December 1999. Without addressing the
relevancy of such data, refunds for alleged over-charges or other complaints are limited to three years
from the date of your initial complaint. Idaho Code 9 61-642; Utility Customer-Relations -Rule-204
(IDAP A 31.21.01.204). While the billing information may be useful, the Idaho Public Utilities Laws
restrict utility refunds to three years. I wanted you to know about the length of the refund period before
researching data more than three years ago.
Putting aside the three-year refund, the Commission s Rules of Procedure allow you to conduct
discovery'" to obtain evidence you think is relevant to the merits of your complaint. See Procedural
Rules 221 through 225, IDAPA 31.01.01.221-225. Thus, your request for information in this case should
be directed to Mr. Mike McGrath of Intermountain Gas. His address is: PO Box 7608, Boise , Idaho
83707.
Weare anxious to serve your complaint upon Intermountain Gas. Please call me and let me know
whether your complaint is sufficient to serve on the Company or what additional information is necessary.
I look forward to talking to you next week.
Deputy Attorney General
cc:Jean D. Jewell
Mike McGrath
bls/L:Robinson dh2
Contracts & Administrative Law Division, Idaho Public Utilities Commission
O. Box 83720, Boise, Idaho 83720-0074, Telephone: [phone], FAX: [phone], E-mail: IpucCQipuc.state.id.Located at 472 West Washington St., Boise, Idaho 83702
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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
June 1 , 2006
Ms. Jane Robinson
10225 Hackamore Drive
Boise, ID 83709
RE:Your Formal PUC Complaint Against Intermountain Gas Company
Dear Ms. Robinson:
On April 13, 2006, the Idaho Public Utilities Commission received your formal complaint
against Intermountain Gas Company. The Commission has not served your complaint upon
Intermountain Gas because you wanted to supplement or include additional information with
your complaint.
It has now been seven weeks since your complaint was received. In an effort to move things
along, the Commission Secretary intends to serve a copy of your complaint upon Intermountain
Gas no later than June 9, 2006. Consequently, any additional material to supplement your
complaint must be received by the Commission Secretary before June 9, 2006.
As I explained in my previous letter dated May 3, Intermountain Gas will have 21 days to
respond to your complaint. After the Company has responded, you will be afforded an
opportunity to file a reply. Then the matter will be placed before the Commission for its
decision.
Please call me at 334-0312 if you have any questions.
~/~
Donald L. Howell, II
Deputy Attorney General
cc:Jean D. Jewell
Mike McGrath
bls/L:Robinson dh3
Contracts & Administrative Law Division, Idaho Public Utilities Commission
O. Box 83720, Boise, Idaho 83720-0074, Telephone: [phone], FAX: [phone], E-mail: IpucCQipuc.state.id.
Located at 472 West Washington St., Boise, Idaho 83702
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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
June 6, 2006
Ms. Jane Robinson
10225 Hackamore Drive
Boise, ID 83709
RE:Your Formal PUC Complaint Against Intermountain Gas Company
Dear Ms. Robinson:
During our first telephone conversation today, you requested a three-week extension from June 9, 2006 to finish
preparing the supplemental material to your complaint. We finally agreed that any and all supplemental material to
your complaint must be received by the Commission Secretary no later than the close of business on June 23 , 2006.
Once the Commission has served your complete written complaint upon Intermountain Gas, it will have 21 days to
file an answer. After the Company has responded, you will be afforded an opportunity to file a reply no later than
14 days after the Company files its answer. The matter will then be ready for the Commission to decide.
You also asked for a copy of a Petition for Reconsideration. I have enclosed per your request two recent Petitions
for Reconsideration. As I mentioned during our conversation, there is no "sample form" for a Petition for
Reconsideration under the Commission s Procedural Rule 331 , IDAPA 31.01.01.331. The Commission granted
reconsideration in the IPC-05-22 case. I make no representations regarding the sufficiency of these Petitions.You may review other petitions by searching the Commission s website under "File Room" or by visiting the
Commission s Records Room located at 472 W. Washington Street in Boise.
During our second telephone conversation of today, you asked for a list of the rate increases and decreases that the
Commission has authorized Intermountain Gas from 1999. Enclosed for your information is a chart showing the
increases and decreases in Intermountain Gas s WACOG (weighted average cost of gas) back to 1994 for
residential space-heating only (RS-1) customers. I have also included a copy of the September 2005 press release
when the WACOG increased an average of27.6% (from 55.5 cents to 73.2 cents). Finally, I have included a chart
showing the average residential (RS-2) rates back to 1995. RS-2 is space and water heating.
I hope you find this information helpful. We look forward to receiving your supplemental information on or before
June 23 , 2006.
nrelY,
/tJ. _ltlf ~well, II
Deputy Attorney General
cc:Jean D. Jewell
Mike McGrath
bls/L:Robinson dh4
Contracts & Administrative Law Division, Idaho Public Utilities Commission
O. Box 83720, Boise, Idaho 83720-0074, Telephone: [phone], FAX: [phone], E-mail: IpucCQipuc.state.id.
Located at 472 West Washington St., Boise, Idaho 83702
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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
June 15 2006
Ms. Jane Robinson
10225 Hackamore Drive
Boise, ID 83709
RE:Your Formal PUC Complaint Against Intermountain Gas Company
Dear Ms. Robinson:
I am sending you this letter as a follow up of our telephone conversation yesterday because I was unable to reach
you by phone and your telephone voice mailbox was "full." Yesterday you asked me to provide you with several
documents. Please find enclosed a copy of Idaho Code ~~ 61-641 and 61-642. These Code sections address the
Idaho Public Utilities Commission s authority to investigate overcharges. In addition Idaho Code ~ 61-642
requires that all complaints regarding overcharges be filed with the Commission within three years of the
overcharge. I have also included a copy of the Commission s Utility Customer Relations Rule 204.
During our telephone conversation of June 6, we agreed that you would submit the supplemental material to
accompany your complaint no later than June 23 , 2006. Yesterday you inquired whether the deadline for
submitting your supplemental material to the Commission Secretary could be extended to July 15, 2006.
As you know the Commission Secretary did not immediately serve your April 13 complaint upon Intermountain
Gas because you indicated that you would shortly submit additional information to support your complaint. It has
now been nine weeks since your complaint was received and you have not yet submitted your supplemental
information. The timely processing of your complaint is intended to secure a just, speedy and economical
determination of the issues included in the complaint. Granting a delay until July 15 would not serve these goals.
However, to provide you with a little more time to prepare your additional material, the Commission Secretary will
not serve your complaint on Intermountain Gas until June 30 , 2006. Consequently, your additional materials must
be received by the Commission Secretary before June 30.
We look forward to receiving your supplemental information. Given the formal nature of the Commission
process, you may also wish to consult with an attorney about your complaint.
~~~
Donald L l!en. II
Deputy Attorney General
Enclosures
cc:Jean D. Jewell
Mike McGrath
bls/L:Robinson dh5
Contracts & Administrative Law Division, Idaho Public Utilities Commission
O. Box 83720, Boise, Idaho 83720-0074, Telephone: [phone], FAX: [phone], E-mail: IpucCQipuc.state.id.
Located at 472 West Washington St., Boise, Idaho 83702