20180420INT to Staff 1-14.pdf

EXECUTIVE OFFICES
I rureRruouNTArn Ges Coruparuv
555 SOUTH COLE ROAD . p.O. BOX 7608 . BO|SE, TDAHO 83707 . [phone] o FAX: [phone]
RECEIVED
28lB fiPn 20 plt 3: tZ
April20,20l8
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
P.O. Box 83720
Boise, lD 83720-0074
RE: First Production Request of the Commission Staff to Intermountain Gas Company
Case No. INT-G-18-01
Dear Ms. Hanian:
In regard to the above references case, enclosed for filing with this Commission are the original
and seven (7) copies of Intermountain Gas Company's response to the First Production Request
of the Commission Staff.
Please acknowledge receipt of this filing by stamping and returning a copy of this Application
cover letter to us.
Should you have any questions regarding the attached, please contact me at [phone].
Very truly yours,
CN
U
}U
Director,Affairs
Intermountain Gas Company
Enclosure
cc: Mark Chiles
GtvBNS PunsLEY,.,."
Attorneys and Counselors at Law
601 W. Bonnock Sheel
PO Box272O
Boise, lD 83701
Telephone: 20&38&1200
Focsimile: 208-38&1 300
www.givenspureley.com
Preslon N. Corler
[e-mail]
20u388.t222
Gory G. Allen
Chrisiopher J. Beeson
Joson J. Blokley
Clint R. Bolinder
Jeff W. Bower
Preston N. Corler
Jeremy C. Chou
Williom C. Cole
Michoel C. Creomer
Amber N. Dino
Brodley J. Dixon
Thomos E. Dvorok
Jeftrey C. Feredoy
Morlin C. Hendrickson
Brion J. Holleron
Kersti H. Kennedy
Neol A. Koskello
Deboro K. Krislensen
Michoel P. Lowrence
Fronklin G. Lee
Dovid R. Lombordi
Kimberly D. Moloney
Kennelh R. McClure
Kelly Greene Mcconnell
Alex P. McLoughlin
Melodie A. McQuode
Chrislopher H. Meyer
L. Edword Miller
Potrick J. Miller
Judson B. Monlgomery
Emily G. Mueller
Deboroh E. Nelson
W. Hugh O'Riordon, LL.M.
Rondoll A. Pelermon
Jock w. Relf
Michoel O. Roe
Jomie Coplon Smilh
P. Mork Thompson
Jeffrey A. wor
Robert B. White
Kenneth L. Pursley (1940-2015)
Jomes A. Mcclure 0924-2011)
Roymond D. Givens 11917-20c€)
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April20,20l8
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Intermountain Gas Company
Case No. INT-G-18-01
Dear Ms. Hanian
Enclosed for filing with the Commission is Intermountain Gas Company's ("Intermountain")
response to Request No. 4 of the Commission Staff s First Production Request in connection
with the above referenced case.
Pursuant to Idaho PUC Rules of Procedure, IDAPA3l.0l.0l .067,31.01.01 .233, and
31.02.01.005.07, the enclosed information is confidential, proprietary and trade secret
information of Intermountain and is protected by law from public inspection, examination or
copying, pursuant to Idaho Code Sections 74- I 06, I 07, and 48-801 et seq. Intermountain
therefore requests that the enclosed information be protected from inspection, examination or
copying by any person other than the Commissioners and PUC Staff. In accordance with IPUC
Rule 67.02.a, the enclosed information is marked "Confidential - Trade Secrets" and submitted
on yellow paper.
Thank you for your cooperation. If you should have comments or questions regarding this
request, please contact Michael P. McGrath (208-377-6168) or me (208-388-1222).
Sincerely,
/
Preston N. Carter
e/b
Lisa Denmark
April 17,2018
Page2
Givens Pursley LLP
Attorneys for Intermountain Gas Company
cc: Michael P. McGrath
Enclosure
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
Post Office Box2720, Boise, ID 83701
601 W Bannock St
Boise, ID 83702
Telephone : [phone]
Emai I : prestoncarter.@,givenspursley. com
Attorney fbr Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMTSSION
,q [C EIYE D
?tjgi i:ii 20 PH 3: I2
t_ii l^- r_r..iU,. .1;,iissi0N
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.
CASE NO. INT-G.I8-OI
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
INTERMOUNTAIN GAS
COMPANY
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COMES NOW, Intermountain Gas Company, and in response to the First Production
Request of the Commission Staff dated March 30,2018, herewith submits the following
information:
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 Westem Union Pay Station transactions included?
ii. Are Westem 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.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page I
RESPONSE TO REQUEST NO. 1:
a. i. Western Union Pay Station transactions fees are included in this filing.
ii. Ll/estern Union Speed Pay transaction fees are not included in this filing.
b. The company is not seeking recovery for Speed Pay payments which include credit, debit,
ATM, and ACH payments. Each Speed Pay payment has a conveniencefee of $1.99 per transaction
which is assed directly to the customer.
Record Holder: Mike McGrath20S-377-6000
Western Union
Speed Pay
Record Holder:
Location:
Sponsor/Preparer:
5S Col e Rd ise. ID 8370755
Mike Kineery 208-898-7 169
REQUEST NO. 2: Please provide the annual volume per year of all Western Union
transactions for the last three calendar years (201 6,2017 ,2018 YTD) by transaction type. Indicate
which transaction type(s) the Company included in this filing for potential recovery.
RESPONSE TO REQUEST NO. 2:
2016 2017
81,408
146,534
2018 YTD (March)
76,494
108,773
21,240
43,442
Mike McGrath2}8-377 -6000
555 S Cole Rd" Boise. ID 83707
Mike Kinserv 208-898:7 1 69
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.
RESPONSE TO REQUEST NO. 3:
Western Union charges the Company a lransactionfee o.f $0.85 per payment made at a
Convenience P ay location.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 2
Location:
Sponsor/Preparer:
Western Union is also our vendor.fbr credit, debit, ATM, and ACH payments through Speed
Pay. Each Speed Pay payment has a convenience fee of $ 1.99 which is assessed directly to the
customer,
REQUEST NO. 4: Please provide a copy of Intermountain Gas' current contract with
Western Union for handling payment transactions.
A copy oJ-the curuent contract is filed under separate cover exempt from public inspection.
Record Holder: Mike McGrath203-377-6000
Location 555 S Cole Rd. Boise. ID 83707
Sponsor/Preparer:Mike Kbeerv 208-898:7 I 69
REQUEST NO. 5: Does the contract with Western Union cover all MDU customers or just
Intermountain Gas customers?
RESPONSE TO REQUEST NO. 5:
Western Union is our walk-in poyment vendor for all MDU utility brands. The controct is
consolidated ond incorporates all MDU service territories.
Record Holder: Mike McGrath20S-377-6000
Record Holder:
Location:
Sponsor/Preparer:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208 -37 7-6000
555 S Cole Rd, Boise. ID 83707
Mike Kineery 208-898-7 169
Mike Kineerv 208-898-7 169
Mike McGrath 208 -37 7-6000
Mike Kineery 208-898-7 1 69
REQUEST NO. 6: What is the transaction cap for pay station payments?
RESPONSE TO REQUEST NO. 6:
The maximum amounl that an Intermountain Gas customer may pay through a convenience
pay location is 52,500
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 3
555 S Cole Rd. Boise. ID 83707
555 S Cole Rd. Boise. ID 83707
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
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?
RESPONSE TO REQUEST NO. 7:
Western Union creates ct payment file the business day following the customer's payment.
The payment is posted to the Customer Information System the same day it is received from Western
(Jnion. The posting process will remain unchanged with the move to the Company covering the
transaction costs.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377 -6000
555 S Cole Rd. Boise. ID 83707
Mikcllnecrv 208 -89 8 -7 \ 69
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.
RESPONSE TO REQUEST NO. 8:
The customer makes a payment at a Convenience Pay location, providing their bill stub or
account number. A daily file with customer information is provided to Western Union. This allows
for a check of the entered occount number, confirming it is a valid Intermountain Gas account.
Following the payment, the customer is provided o receipt.
The next business day afile of the previous day's payments is receivedfrom Western Union
along with a deposit covering the total payment amounts. That file is then run, and payments are
processed and posted to the respective customer accounts in our Customer Information System later
the same day.
ICC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 4
Location:
Sponsor/Preparer
Payments from unauthorized pay stations follow many dffirent paths and post in various
timelines. Most notably, unauthorized payment locations do not have means to verify the utility
account number they are noting is valid or entered coruectly. Upon receiving the payment, the
unauthorized agent may have a relationship with one of our electronic payment portners. In these
cases, the payment may come through CheckFree, iPay, Metavante, etc. and post to the account
between one to /ive days. Payments that come through with an invalid accounl number may take
longer to post or in some cases the intended account may never be determined, eventually resulting
in escheatment. I/'the unaulhorized location does nol have an electronic relationship, they may
create a paper check and mail the payment through our remittance process.
Record Holder: Mike McGruth208-377-6000
555 S Cole Rd. Boise. ID 83707
Mike Kineerv 208-898-7 1 69
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?
RESPOSNE TO REQUEST NO. 9:
The daily /ile that is sent to l4/estern Union includes a/lag that indicates if the customer has
a pending non-pay disconnect order. If a payment is received on an account with this flag active,
Western Union sends an email to the utility indicating payment confirmation. These emails are
received in recurring lime increments and reviewed periodically throughout the day. Even though
the email is senl as confirmation, it is recommendedthat customers atriskof disconnect call
following their payment to ensure the amount was sfficient qnd make arrqngements on any follow-
up pqyments that may be necessary.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 5
Record Holder:
Location:
Sponsor/Preparer:
Record Holder:
Location:
Sponsor/Preparer:
Mike McG rath 208-37 7-6000
Mike Kinserv 208-898-7 1 69
REQUEST NO. 10: What types of payments (cash, check, credit or debit card, other) are
accepted at an authorizedpay station?
RESPONSE TO REQUEST NO. 10:
Western Union Convenience Pay locations accept cash, check, and money orders. Some
customers with a history of returned payments may be blockedfrom using check as a payment
method.
Mike McGrath 208 -37 7-6000
555 S Cole Rd R se. ID 83707
Mike Kineerv 208-898-7 I 69
REQUEST NO. l1: How does the Company propose to notify its customers that the pay
station convenience fee has been eliminated?
RESPONSE TO REQUEST NO. 11:
The website lists the various poyment options available and outlines that payments at
authorized Western Union locations are free of charge. A bill insert outlining payment options was
sent to all customers in March. It outlined that there is no charge to make a Convenience Pay
transaction.
Record Holder:
Location:
Sponsor/Preparer
Mike McGrath 208-37 7-6000
555 S Cole Rd, Boise, ID 83707
Mike Kineerv 208-898-7 I 69
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.
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 6
555 S Cole Rd. Boise. ID 83707
Location:
Sponsor/Preparer
RESPONSE TO REQUEST NO. 12:
Pay stations are availablefor any class of customer choosing to make the cash or check
payment as long as the amount is below the capped threshold of 52,500.
RecordHolder: MikeMcGrath20S-377-6000
555 S Cole Rd.Boise. ID 83707
Mike Kinserv 208-898-7 I 69
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.
RESPONSE TO REQUEST NO. 13:
The Company has frequent interactions with Western Union regarding the payment options
availqble to customers. These discussions have qlso included negotiations on the costs associated
with various payment types. Intermountain's relationship with Western Union as a partner for
walk-in paymenls as well as uedit and debit payments have affirded the opportunity to negotiate
transaction rates that are low while still providing amenities and new features to improve the user
experience.
In 2018, the Convenience Pay transactionfee was negotiated to a lower rate of 50.85
compared to lhe previous rate at $1.00.
In 2016, Intermountain and the other MDU utilities negotiated a rate with Western Union to
lower the customer convenience fee on credit, debit, ATM, and ACH payments made through Speed
Poy down to $ 1.99. Prior to that time Intermountqin cuslomers were paying 52.75 per transaction.
RecordHolder: MikeMcGrath20S-377-6000
Location 555 S Cole Rd, Boise. ID 83707
Sponsor/Preparer:Mike Kinserv 208-898-7 169
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 7
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.
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?
RESPONSE TO REQUEST NO. 14:
The Company was directed in Case No. INT-G-17-02, Order No. 33805 to meet with IPUC
staff to discuss alternatives to convenience.fees. During 2017, Company personnel met with IPUC
staffto discuss the issue o.f convenience.fees including both the LVestern Union "walk-in" fees and
the Speed Pay credit and debit cardfees. The Company chose at that time to eliminate the Western
Union.fee as a charge to customers basedonthe general demographics of customers usingthat
pqyment program. The Company declined to implement a "fee-free" Speed Pay program due to the
signfficantly higher costs involved and the lack of data available to properly assess the magnitude
of the program. The Company committed to review the credit/debit card fee issue in July 2018 and,
once another year of data is available/br analysis, will assess the data and make a determination
on whether to proceed in implementing a "fee free " program for credit and debit card payments.
Record Holder:
Location:
Sponsor/Preparer:
Mike McGrath 208-377-6000
Mark Chile s 208-37 7 -6124
IGC RESPONSE TO FIRST REQUEST FOR PRODUCTION Page 8
555 S Cole Rd. Boise. ID 83707