20070817Staff to INT 1-8.pdf

DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
O BOX 83720
BOISE, IDAHO 83720-0074
PHONE: [phone]
FAX: [phone]
IDAHO BAR NO. 5921
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEIVED
ZOfil AUG III P 2:
!d,.l\,J ;);,J'3LIC
UTILITIES COiVi1.iISSJON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TESSA LESEBERG, ON BEHALF OF
RALPH W. AND WANDA H. LESEBERG
Complainants
INTERMOUNT AIN GAS COMPANY
Respondent.
CASE NO. INT-07-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donovan E. Walker, Deputy Attorney General, requests that Intermountain Gas Company
(Intermountain Gas; Company) provide the following documents and information as soon as
possible, but no later than FRIDAY, SEPTEMBER 14 2007. IDAP A 31.01.01.225.
The Company is reminded that responses pursuant to Commission Rules of Procedure must
include the name and phone number of the person preparing the document, and the name, location
and phone number of the record holder. Reference IDAP A 31.01.01.228.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS AUGUST 17 2007
This Production Request is to be considered as continuing, and Intermountain Gas is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearing.
REQUEST NO.1: For FY 2000 through 2006 and year to date 2007 , please provide by
year and rate schedule the total number of rebillings prepared due to equipment malfunctions or
failures and/or data entry mistakes/problems.
REQUEST NO.2: For FY 2000 through 2006 and year to date 2007, please provide by
year and rate schedule: a) the total number oftherms and dollar amount rebilled; b) the mean and
mode of the number of months covered by each rebilling; c) the incidence of rebilling by what
alerted the Company to a possible problem (e., low usage, zero usage); and d) the incidence of
rebilling by type of equipment malfunction or failure (e., bent wriggler).
REQUEST NO.3: In the Company Answer regarding the Complaint filed by Tessa
Leseberg, it is stated on page 3 that
, "
Intermountain has since developed a calculation combining
historical consumption with the customer s cycle specific heating degree days. This calculation was
applied to the Lesebergs' account and resulted in a calculation of $499.86." Please explain in detail
the method used to calculate the rebilling amount of $499.86. Provide all workpapers with
calculations in executable format (e.g. Excel).
REQUEST NO.4: In regard to the response to Request No., does the Company propose
to use this methodology for future estimated rebillings? Ifnot, why?
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS AUGUST 17 2007
REQUEST NO.5: To the extent that Request Nos. 3 and 4 do not provide a full answer, what does
the Company propose as a methodology for estimated rebillings when:
a. there is historic consumption data available for the account prior to the rebilled dates;
b. there is no historic consumption data available prior to the rebilled dates, but there is
valid consumption data available for a period after the meter malfunction is
discovered and corrected; and
c. there is no consumption data prior or subsequent to the meter malfunction being
discovered and corrected?
REQUEST NO.6: With regard to the response to Request No., what is the margin of
error associated with the three scenarios?
REQUEST NO.7: For the following accounts, please indicate: a) therms rebilled;
b) dollar amount rebilled; c) therms calculated under Company s proposed estimation method;
d) dollar amount calculated under Company s proposed method; e) exact time period covered by
rebillings; f) city account is located in:
1. 78085707 -422-
2. 49233500-001-
3. 13706900-001-
4. 67421700-714-
5. 31368800-001-
6. 40853600-084-
REQUEST NO.8: For the accounts listed in Request No., please provide monthly
historical consumption for the last 5 years to the current period if available.
DATED at Boise, Idaho, this !7f~day of August 2007.
Deputy Attorney General
Technical Staff: Marilyn Parker
Bryan Lanspery
i:umisc:prodreqlintgO7. 1 dwmpbl prod reg l.doc
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS AUGUST 17, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF AUGUST 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY IN CASE
NO. INT-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TESSA LESEBERG
RALPH & WANDA LESEBERG
111 EAST 2ND NORTH
ST ANTHONY ID 83445
TERRI SHOEN
INTERMOUNTAIN GAS COMPANY
PO BOX 7608
BOISE ID 83707
CERTIFICATE OF SERVICE