20161208INT to CAPAI 1-21.pdf

WILLIAMS · BRADBURY
ATT OR N E YS AT LAW nEC EIVE D
November 8, 2016
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Response to CAP AI First Request for Production
Case No. INT-G-16-02
Dear Ms. Jewell:
. i ~·.L:f~ __ :: , ·,;,11ss10 ~
Enclosed for filing with the Commission are one original and three conformed copies of
Intermountain Gas Company's Response to Community Action Partnership Association of
Idaho (CAP Al) First Request for Production.
Please direct any questions related to the transmittal of this filing to Mike McGrath at
208-377-6168.
Sincerely,
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83 702
Telephone: [phone]
Email: ron@williarns brad bury. corn
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
)
_________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO FIRST
PRODUCTION REQUEST OF
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF
IDAHO
COMES NOW, Intermountain Gas Company, and in response to the First Production
Request of Community Action Partnership Association of Idaho (CAP AI) dated November 17,
2016, herewith submits the following information:
REQUEST NO. 1: Does the Company have an internal 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.
RESPONSE TO REQUEST NO. 1:
Jntermountain Gas Company does not collect or track any personal information
regarding a customer 's low income status.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page I
REQUEST NO. 2: If your response to the preceding Request is in the affirmative,
please state the percentage oflow income customers, using the Company's definition, compared
to all residential customers for each of the past five (5) years.
RESPONSE TO REQUEST NO. 2:
The company 's response to request number one was not in the affirmative.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
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 state the percentage of the those
customers in relation to all residential customers for each of the past five (5) years?
RESPONSE TO REQUEST NO. 3:
Intermountain Gas Company does not identify low-income status or maintain information
regarding the customers ' annual income.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
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?
RESPONSE OF JGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 2
RESPONSE TO REQUEST NO. 4:
Heating Season
2011-2012
2012-2013
2013-2014
2014-2015
2015-2016
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
LIHEAP Percentage
3.98%
4.03%
3.94%
2.44%
1.96%
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
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.
RESPONSE TO REQUEST NO. 5:
Heating Season
2011-2012
2012-2013
2013-2014
2014-2015
2015-2016
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
LIHEAP Count
11,328
11,602 -11,645
7,353
6,002 -
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
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?
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 3
RESPONSE TO REQUEST NO. 6:
Heating Season
2011-2012
2012-2013
2013-2014
2014-2015
2015-2016
Record Holder:
Location:
Preparer:
Sponsor:
LIHEAP Dollars
$1,140,308
$804,180
$807,748
$549,313
$1,002,727
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 7: Please state the average level of consumption and average monthly
bills for residential customers for each month during the past five (5) years. In responding to this
request, please break said consumption and bills out into those residential customers who: 1)
receive LIHEAP and/or receive income that is at or below 150% of the FPL and; 2) those who do
not fall into the foregoing category.
RESPONSE TO REQUEST NO. 7:
Please see CD file labeled CAP Al PR #7 for the average usage and billing information
for 2011-2014. The data shown is for all residential customers including LIHEAP Customers.
For the 2015 year, please reference the Company's response to CAPAI PR#I 0, which includes
the requested LIHEAP breakout.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page4
REQUEST NO. 8: What percentage of the Company's residential customers utilize
gas as their primary heat source?
RESPONSE TO REQUEST NO. 8:
While some customers may use natural gas as a secondary heating source to supplement
a wood stove or other primary heat, data is not available to identify the relatively few customers
that would fall in to this category.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 9: Please break out customers utilizing gas and those using a different
primary heat source into customers who: 1) either receive LIHEAP and/or receive income that is
150%ofthe FPL and; 2) those who do not fall into the foregoing category.
RESPONSE TO REQUEST NO. 9:
Please see response to Request to No.8.
Record Holder:
Location:
Preparer:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 10: What is the expected impact on residential customers' monthly
bills attributable to the Company's proposed increase in the customer charge in this case? In
responding to this Request, please break out your response between the two categories of
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 5
residential customers who receive LIHEAP and/or receive income at or below 150% of the FPL,
and those residential customers who do not.
RESPONSE TO REQUEST NO. 10:
Please see the file labeled "CAPAI PR#-1 O" which provides the requested data for all
Rate Class RS-I and Rate Class RS-2 customers and separately for LIHEAP recipient customers
in these two rate classes.
The following table describes the data and analysis that is provided on the CD file
labeled "CAPAI PR#IOAttachment ":
Analysis Table
Average Therms Monthly consumption data is the 2015 calendar year average
monthly usage of all customers with 12 monthly bills
Average Bill, Current Rates Monthly bills are calculated using current base rates and PGA rates
of $0.55589 per therm for Rate Schedule RS-1 and $0.5159 per
therm for Rate Schedule RS-2.
Average Bill, Proposed Monthly bills are calculated using proposed base rates and PGA
Rates rates of $0.52196 per therm for Rate Schedule RS.
Change in Bill Calculated differences between monthly bill at current and
proposed rates; the Change in Bill is the change related to the
customer charge, plus the change related to all other charges.
Related to Customer Calculated differences between proposed and current customer
Charge charges.
Related to Other Calculated differences for volumetric portion of monthly bills
Charges using average monthly therms and proposed and current
volumetric charges.
% Change in Bill Calculated; the difference between monthly bills at proposed and
current rates, divided by the total monthly bill at current rates.
Related to Customer Calculated; the difference between monthly customer charges at
Charge proposed and current rates, divided by the total monthly bill at
current rates.
Related to Other Calculated; the difference between monthly volumetric charges at
Charges proposed and current rates, divided by the total monthly bill at
current rates.
Record Holder: Mike McGrath, 208-377-600
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner, 208-377-6000
RESPONSE OF JGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 6
REQUEST NO. 11: How many residential customers were disconnected for non­
payment in each of the past five (5) years and how many of those customers were reconnected?
In responding to this Request, please break out said disconnections/reconnections between 1)
LIHEAP recipients and/or customers receiving incomes at or below 150% of the FPL and 2) all
other residential customers.
RESPONSE TO REQUEST NO. 11:
The table below reflects customers that were disconnected for non-payment for each
calendar year. The number of reconnects includes customers that were disconnected for non­
payment and had service reconnected within IO days of the original non-pay disconnect.
Customers that request a reconnect beyond the I 0-day window are considered a new applicant
and are not included in the numbers below.
The LIHEAP counts reflect customers who received a LIHEAP assistance payment in the
same calendar year the disconnect took place.
2016 data reflects information through the month of November.
Year Non-Pay Reconnects DNP Reconnect
2011
2012
2013
r--
2014
2015
2016
Record Holder:
Location:
Preparer:
Sponsor:
Disconnects w/LIHEAP w/LIHEAP
10,649 6,027 1,469
10,657 6,320 1,058
11,148 6,679 774
8,652 4,810 988
5,006 2,558 325
6,723 2,049 197
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
757
588
456
509
157
54
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 7
--------------
REQUEST NO. 12: Of all those residential customers with unpaid debt in each of the
past five (5) years, please state the percentage who received LIHEAP and/or whose received
incomes at or below 150%of the FPL.
RESPONSE TO REQUEST NO. 12:
Write-off figures are not specifically available for customers that received LIHEAP
assistance.
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 13: If a customer is disconnected for non-payment and has unpaid
debt, please explain the process by which the Company attempts to recover that debt including
whether outside collection agencies are utilized.
RESPONSE TO REQUEST NO. 13:
Customers requesting to be reconnected following a disruption of service due to non­
payment are required to pay the past due amount that initiated the disconnect as well as at least
one-third of the calculated deposit if one is not already on file.
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 14: If the Company utilizes outside collection agencies, please explain
how the costs paid to such agencies are recovered from ratepayers.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 8
RESPONSE TO REQUEST NO. 14:
Collection agencies are paid a percentage of the total dollar amount that they recover
from written off debt. Agencies remit the recovered dollars in full and the agency commission is
returned through a remitted invoice. These collection agency costs are part of our contracted
services expenses in our O&M budget.
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 15: If a customer is disconnected for non-payment and seeks
reconnection, what are the Company's policies for recovery of unpaid debt and associated
collection and other costs attributable to the non-payment owed by that customer and explain
what happens in the event that unpaid debt has already been written off as an expense to
ultimately be passed on to and recovered from other customers.
RESPONSE TO REQUEST NO. 15:
Customers requesting to be reconnecting following a disruption of service due to non­
payment are required to pay the past due amount that resulted in the disconnect as well as at
least one-third of the calculated deposit if one is not already on file.
If an applicant has an unpaid debt at the time they request new service, payment of the
full balance is required as well as one-third of the calculated deposit prior to establishing new
service. This payment is required even if the debt has been written off unless the debt is from
service provided more thanfour years prior in accordance with Rule 310.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 9
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 16: How much unpaid debt attributable to residential customers did the
Company write-off as bad debt expense and recover from 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?
RESPONSE TO REQUEST NO. 16:
The Company does not track bad debt expense by rate class. Additionally, the Company
does not track the amount of bad debt expense it recovers from its customers through its base
rates. Please see the Company 's response to !PUC Staff Request No. 138, which shows
historical bad debt expense for the period 2010-2015.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Mark Chiles, 208-377-6000
REQUEST NO. 17: On average, of all disconnections resulting in unpaid debt, how
much of that debt was effectively recovered by reconnection charges and payment of said unpaid
debt over the past five (5) years?
RESPONSE TO REQUEST NO. 17:
Jntermountain Gas Company charges $22. 00 for customer reconnections during normal
business hours. This reconnection fee is not sufficient to recover the labor and overhead costs
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 10
.------------------------------------------
expended when sending a technician out to a customer 's home to reconnect service. Therefore,
there is "nothing left " to apply towards any unpaid debt.
The below table shows the overall percent of write-off recoveries:
2012 41.23%
2013 41.24%
2014 36.81%
2015 38.76%
Record Holder: Mike McGrath, 208-377-600
Location: 555 S Cole Rd, Boise, ID 83707
Preparer: Del Herner, 208-377-6000
Sponsor: Mark Chiles, 208-377-6000
REQUEST NO. 18: On average, how many residential customers have disconnected
their service voluntarily during the Company's summer rate season and subsequently chose to
reconnect during the non-summer rate season over the past five (5) years? In answering this,
please break out your response between 1) customers receiving LIHEAP and/or who received
income at or below 150% of the FPL, and; 2) all other residential customers.
RESPONSE TO REQUEST NO. 18:
The data for this request is not available for prior years. With the conversion to our new
CIS system in August 2015, figures are available for the most recent summer rate season. In
2016, 241 customers ended service between the dates of May 1 and July 1 and also reestablished
service at that address later in the calendar year. Of those 241 customers, 17 received a LIHEAP
benefit in the 2015-2016 heating season.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page I I
Record Holder:
Location:
Preparer:
Sponsor:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Del Herner, 208-377-6000
Mark Chiles, 208-377-6000
REQUEST NO. 19: With respect to the Company's existing DSM programs, please
identify the process by which such programs were conceived of and implemented including any
criteria utilized by the Company to approve, adopt and implement such programs.
RESPONSE TO REQUEST NO. 19:
The Company's Tariff "Residential Space Heating Equipment Rebate" is currently the
only means in place to incent customers to upgrade to more efficient equipment. (Exhibit 20-1)
This tariff is not a traditional DSM Program that quantifies and measures energy savings as they
relate to the cost of the rebate.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Cheryl Imlach, 208-377-6000
REQUEST NO. 20: Please identify and explain the methodology utilized by the
Company to calculate the energy savings from its existing DSM programs.
RESPONSE TO REQUEST NO. 20:
As outlined in the Company's response to Request No. 19, the Company has no existing
DSM programs. Although the Company has no methodology in place to calculate the energy
therm savings from the tariff mentioned in the response to Request No. 19, the Company believes
the overall average therm savings between a 78% and 90%AFUEfurnace is approximately 82
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 12
therms per year. Intermountain has issued 1,438 rebates since 2009, which would therefore
equate to approximately 117,916 therm savings for this time period.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-6000
555 S Cole Rd, Boise, ID 83707
Cheryl Imlach, 208-377-6000
REQUEST NO. 21: Has the Company ever implemented a DSM program specifically
targeting low income customers under any definition of the term "low income" and, if so, please
provide the following:
A. The definition of "low income" used by the Company, and;
B. A brief description of the program and, if it is no longer functioning, the reason
for its termination.
RESPONSE TO REQUEST NO. 21:
The Company has not implemented a DSM program specifically targeting low income
customers.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath, 208-377-600
555 S Cole Rd, Boise, ID 83707
Cheryl Imlach, 208-377-6000
REQUEST NO. 22: Please state the total costs of collection efforts and amounts
recovered by collection agencies for each of the past five (5) years as well as the amounts of said
costs passed on to ratepayers.
RESPONSE OF IGC TO FIRST PRODUCTION REQUEST OF CAPAI Page 13
RESPONSE TO REQU ESTN0.22:
The table below s hows collection agency fees for the past five years:
Year Amount
2011 $182,47 5
2012 $166,48 1
2013 $140,95 1
2014 $179,10 3
2015 $86,927
The Company im
enabled Jntermountain to
!J)lemented a new Customer Information System in August of 2015 which
track recoveries separate from write-offs in its general ledger. The
amount of recoveries fro m August 1, 2015 to September 30, 2016 was $413,939.
The amount of co llection agency fee expenses the Company is seeking recovery for is
$127,927. This number i s based on actual expenses through June 3 0, 2016 and forecast expense
for July -December 201 6
Record Holder:
Location:
Preparer:
Sponsor:
Mi ke McGrath, 208-377-600
55 5 S Cole Rd, Boise, ID 83 707
l Herner, 208-377-6000 De
Te d Dedden, 208-377-6000
DATED at Boise, Idaho, this 8th day of November, 2016.
RESPONSE OF JGC TO FIR
Respectfully submitted~
;{~ l [J,Mt-
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for Intermountain Gas Company
ST PRODUCTION REQUEST OF CAP AI Page 14
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 8th day of December, 2016, I caused to be served a true
and correct copy of the Response of Intermountain Gas Company to First Production Request of
CAP AI upon the following individuals in the manner indicated below:
Hand Delivery: (original and 3 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83707
E-Mail: [e-mail]
Brad M. Purdy
2019N. 17th Street
Boise, ID 83 702
E-Mail: [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 gth Avenue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery D US Mail (postage prepaid)
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Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: [e-mail]
[e-mail]
Attorneys for NWIGU
Electronic service only:
Michael C. Creamer
Givens Pursley LLP
E-Mail: [e-mail]
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 709
E-Mail: [e-mail]
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
Company LLC
Electronic service only:
Dr. Don Reading
E-Mail: [e-mail]
The Amalgamated Sugar Company LLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
2
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-------------------------------
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. J emigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
E-Mail: [e-mail]
Lanny .zieman. [e-mail]
N [e-mail]
[e-mail]
Ebony. payton. [e-mail]
Attorneys for Federal Executive Agencies
(FEA)
3
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Ronald L. Williams