20180330Staff 1-14 to INT.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r4
IDAHO BAR NO. IOI77
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR AN
ACCOUNTING ORDER REGARDING THE
TREATMENT OF COST ASSOCIATED WITH
CUSTOMER PAYMENT TRANSACTIONS
HANDLED BY WESTERN UNION.
REC EIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. INT.G.T8.Ol
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,
Camille Christen, Deputy Attorney General, request that Intermountain Gas Company
(Intermountain Gas; Company) provide the following documents and information as soon as
possible, or by FRIDAY, APRIL20,2018.
This Production Request is continuing, and the Company 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 and supporting workpapers that provide detail or
are the source of information used in calculations. 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 and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS I MARCH 30,2018
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In the Application, the Company requests, in part, authorization to
defer into a regulatory asset the costs associated with "payment transactions handled by Western
Union" and to recover the regulatory asset through the PGA. Application at 6.
a. List all Western Union transaction types the Company seeks cost recovery for in this
filing.
i. Are Western Union Pay Station transactions included?
ii. Are Western Union Speed Pay transactions included?
b. List all Western Union transaction types the Company does not seek recovery for in
this filing and the associated cost.
REQUEST NO. 2: Please provide the annual volume per year of all Western Union
transactions for the last three calendar years (20 1 6, 2017 , 20 I 8 YTD) by transaction type. Indicate
which transaction type(s) the Company included in this filing for potential recovery.
REQUEST NO. 3: Please provide the cost Western Union is charging Intermountain Gas
for each customer pay station transaction. Please also provide the cost Western Union charges
customers for other transaction types.
REQUEST NO. 4: Please provide a copy of Intermountain Gas' current contract with
Western Union for handling payment transactions.
REQUEST NO. 5: Does the contract with Westem Union cover all MDU customers or just
Intermountain Gas customers?
REQUEST NO. 6: What is the transaction cap for pay station payments?
REQUEST NO. 7: What is the current lag time between when a customer makes a
payment at apay station and (a) when the Company is notified of payment, and (b) when the
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 2 MARCH 30,2018
payment is posted to a customer's account? Additionally, does the Company expect the payment
processing/posting time will increase, decrease, or stay the same as a result of the Company paying
the costs associated with the transactions?
REQUEST NO. 8: Please explain the process that occurs from the time the customer
makes a payment at both an authorized and unauthorized pay station until the payment posts to the
customer's account.
REQUEST NO. 9: After payment is made at an authorizedpay station, are those customers
with a pending disconnection still required to contact the Company with the payment confirmation
number to cancel the disconnection? If so, how can this step be eliminated in order to avoid
disconnecting service for customers who have paid their bills?
REQUEST NO. 10: What types of payments (cash, check, credit or debit card, other) are
accepted at an authorizedpay station?
REQUEST NO. 11: How does the Company propose to notify its customers that the pay
station convenience fee has been eliminated?
REQUEST NO. 12: Are pay station payments utilized by both residential and commercial
customers? Please explain if any additional customer classes utilize the pay station payment
alternative.
REQUEST NO. 13: Please explain whether the Company has had discussions with
Western Union to reduce its convenience fees. If discussions have taken place, please provide a
summary of the discussions, and the implications of the convenience fee cost reduction. If
discussions have not taken place, please explain why not.
REQUEST NO. 14: Based on discussions with the Company, Staff understands that the
Company is still considering whether to implement a fee-free debit/credit card payment program.
FIRST PRODUCTION REQUEST
TO INTERMOUNTAIN GAS 3 MARCH 30,2OI8
Does the Company intend to file an Application to implement such a program in July 2018? If not,
please explain what the Company intends to do with respect to implementing a fee-free program.
Why has the Company chosen to eliminate Western Union payment fees now and other payment
processing fees at a later date?
DATED at Boise,Idaho, ttts {aay of March 2018.
Camille Christen
Deputy Attorney General
Technical Staff: Kevin Keyt (l-2, 13-14)
Curtis Thaden (3-11)
Johan Kalala-Kasanda (l 2)
i:umisc:prodreq/intgl8. lccctjkkk prod reql
FIRST PRODUCTION REQUEST
TO INTERMOI.INTAIN GAS 4 MARCH 30,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF MARCH 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO INTERMOUNTAIN GAS COMPANY, IN CASE
NO. INT-G-l8-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
MICHAEL P MoGRATH
DIR _ REGULATORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
(
Y
CERTIFICATE OF SERVICE