20161117CAPAI 1-21 to INT.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Cell)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
PECEIVED
20 1', r'.OV 17 PM 3: 27
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMP ANY'S
APPLICATION TO CHANGE ITS RATES
AND CHARGES FOR NATURAL GAS
IN THE STATE OF IDAHO
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CASE NOS. INT-G-16-02
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S FIRST
PRODUCTION REQUESTS
TO INTERMOUNT AIN GAS
The Community Action Partnership Association of Idaho (CAP AI), by and through its
attorney ofrecord, Brad M. Purdy, requests that Intennountain Gas Company ("Company")
provide the following doctunents and information pursuant to the Commission's Rules of
Procedure 222-240, IDAPA 31.01.01.222-240 as well as the Commission's scheduling order
previously issued in this case.
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 ntunber of the record holder. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing in nature, and the Company is
respectfully 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.
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.
CAPAI'S FIRST SET OF DISCOVERY TO INTERMOUNTAIN GAS
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Please provide a response to the following ~iscovery on or before December 8, 2016.
REQUEST NO. 1: Does the Company have an in~emal criterion, or set of criteria, for
identifying which of its customers are "low income" and, if so, please define and explain the
aforementioned criterion or set of criteria.
REQUEST NO. 2: If your response to the preceding Request is in the affirmative, please state
the percentage of low income customers, using the Cpmpany's definition, compared to all
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residential customers for each of the past five (5) years.
REQUEST NO. 3: Does the Company track or otherwise have knowledge of the percentage
of its residential customers who received income that is equal to or less than 150% of the Federal
Poverty Level (hereinafter, "FPL") and, if so, please $tate the percentage of the those customers
in relation to all residential customers for each ofthe 1past five (5) years?
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REQUEST NO. 4: Does the Company track or otherwise have knowledge as to the
percentage of its residential customers who are LIHEAP recipients and, if so, what is that
percentage, of all residential customers, for each of the past five (5) years?
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REQUEST NO. 5: Please state the actual number, as opposed to percentage, of the
Company's residential customers receiving LIHEAP and/or who fall at or below 150% of the
FPL as a percentage of customers who do not for each of the past five (5) years.
REQUEST NO. 6: How much federal LIHEAP funding was received by the Company in
each of the past five (5) years and how many customers were served in each year by this
funding?
CAPAI'S FIRST SET OF DISCOVERY TO INTERMOUNTAIN GAS 2
REQUEST NO. 7: Please state the average level f consumption and average monthly bills
for residential customers for each month during the p st five (5) years. In responding to this
request, please break said consumption and bills out r to those residential customers who: 1)
receive LIHEAP and/or receive income that is at orb low 150% of the FPL and; 2) those who do
not fall into the foregoing category.
REQUEST NO. 8: What percentage of the Comp , y's residential customers utilize gas as
their primary heat source?
REQUEST NO. 9: Please break out customers utili ing gas and those using a different primary
heat source into customers who: 1) either receive LI AP and/or receive income that is 150%of
the FPL and; 2) those who do not fall into the forego·
REQUEST NO. 10: What is the expected impact o1 residential customers' monthly bills
attributable to the Company's proposed increase in thb customer charge in this case? In
responding to this Request, please break out your res!nse between the two categories of
residential customers who receive LIHEAP and/or rec ive income at or below 150% of the FPL,
and those residential customers who do not.
REQUEST NO. 11: How many residential custome s were disconnected for non-payment in
each of the past five (5) years and how many of those ustomers were reconnected? In
responding to this Request, please break out said disc ections/reconnections between l)
LIHEAP recipients and/or customers receiving incom sat or below 150% of the FPL and 2) all
other residential customers.
CAPAI'S FIRST SET OF DISCOVERY TO INTE OUNTAIN GAS 3
REQUEST NO. 12: Of all those residential custo ers with unpaid debt in each of the past five
(5) years, please state the percentage who received L HEAP and/or whose received incomes at or
below 150%ofthe FPL.
REQUEST NO. 13: If a customer is disconnected for non-payment and has unpaid debt, please
explain the process by which the Company attempts o recover that debt including whether
outside collection agencies are utilized.
REQUEST N0.14: If the Company utilizes outsid collection agencies, please explain how
the costs paid to such agencies are recovered from ra payers.
REQUEST NO. 15: If a customer is disconnected D r non-payment and seeks reconnection,
what are the Company's policies for recovery of unp ·d debt and associated collection and other
costs attributable to the non-payment owed by that cu tomer and explain what happens in the
event that unpaid debt has already been written off as expense to ultimately be passed on to
and recovered from other customers.
REQUEST NO. 16: How much unpaid debt attribut ble to residential customers did the
Company write-off as bad debt expense and recover f om ratepayers during each of the past five
(5) years and how much is attributable to: 1) LIHEAP recipients/customers falling at 150%
below the FPL, and; 2) all other residential customers.
REQUEST NO. 17: On average, of all disconnectio s resulting in unpaid debt, how much of
that debt was effectively recovered by reconnection ch ges and payment of said unpaid debt
over the past five ( 5) years?
CAPAI'S FIRST SET OF DISCOVERY TO INTE OUNTAIN GAS 4
REQUEST N0.18: On average, how many residential customers have disconnected their
service voluntarily during the Company's summer raL season and subsequently chose to
reconnect during the non-summer rate season over thl past five (5) years? In answering this,
please break out your response between 1) customer receiving LIHEAP and/or who received
income at or below 150% of the FPL, and; 2) all othe residential customers.
REQUEST NO. 19: With respect to the Company' existing DSM progran1s, please identify
the process by which such programs were conceived f and implemented including any criteria
utilized by the Company to approve, adopt and imple ent such programs.
REQUEST NO. 19: Please identify and explain the ethodology utilized by the Company to
calculate the energy savings from its existing DSM p ograms.
REQUEST NO. 20: Has the Company ever implem nted a DSM program specifically
targeting low income customers under any definition , f the term "low income" and, if so, please
provide the following:
A. The definition of "low income" used b the Company, and;
B. A brief description of the program and, if it is no longer functioning, the reason
for its termination.
REQUEST NO. 21: Please state the total costs of copection efforts and amounts recovered by
collection agencies for each of the past five (5) years Js well as the amounts of said costs passed
on to ratepayers.
DATED, this 17th day ofNovember, 2016.
Brad M. Purdy ~
Attorney for Community Action
Partnership Asso , . of Idaho
CAPAI'S FIRST SET OF DISCOVERY TO INTE OUNTAIN GAS 5