20230223INT to Staff - Response No. 75-85.pdf

RESPONSES TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 3
Preston N. Carter, ISB No. 8462
Morgan D. Goodin, ISB No. 11184
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Intermountain Gas Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR NATURAL GAS SERVICE IN
THE STATE OF IDAHO

Case No. INT-G-22-07

INTERMOUNTAIN GAS COMPANY’S
RESPONSES TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF

Intermountain Gas Company, (“Intermountain,” “Applicant,” or “Company”), in
response to the Fifth Production Request of the Commission Staff to Intermountain Gas
Company dated February 2, 2023, submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email.

DATED: February 23, 2023.

GIVENS PURSLEY LLP

Preston N. Carter
Attorney for Intermountain Gas Company

RECEIVED
Thursday, February 23, 2023 12:20:04 PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 3
CERTIFICATE OF SERVICE
I certify that on February 23, 2023, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

Chad M. Stokes
Cable Huston LLP
1455 SW Broadway, Ste. 1500
Portland, OR 97201
Attorneys for Alliance of Western Energy
Consumers
[e-mail]

Marie Callaway Kellner
710 N. 6th Street
Boise, ID 83702
Attorneys for Idaho Conservation League
[e-mail]

Brad Heusinkveld
Idaho Conservation League, Energy Assoc.
710 N. 6th Street
Boise, ID 83702
[e-mail]

Darrell Early
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

RESPONSES TO FIFTH PRODUCTION REQUEST OF COMMISSION STAFF PAGE 3 OF 3

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]

Preston N. Carter

INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dan Tillis/Nicole
Kivisto
REQUEST NO. 75:
Approximately how many customer service representatives (“CSR’s”) are employed by
the Customer Experience Team Center located in Meridian, Idaho?
RESPONSE NO. 75:
The Customer Experience Team (“CXT”) budget for Customer Service Representative
(“CSR”) headcount is 107. The current CSR headcount is approximately 100. In addition to the
CSRs, the CXT budgets for additional personnel that provide direct assistance to customers,
including the following:
13 Customer Support Representatives who reply to emails, chats, provide web portal
support and handle some inbound calls (there are currently 2 vacancies on this team).
16 Schedulers who handle and relay emergency calls and other order types to
Technicians.
INT-G-22-07
IPUC DR 75
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dan Tillis/Nicole
Kivisto
REQUEST NO. 76:
How many CSR’s work in the satellite office in Bismarck, North Dakota?
RESPONSE NO. 76:
Currently the Customer Experience Team (“CXT”) has 9 CSRs reporting into the
Bismarck, North Dakota CXT. In addition to the CSRs, there are also 19 Credit and Collections
employees based out of the Bismarck office that make outbound call attempts to customers to
collect past due payments, schedule payment arrangements, and refer customers for energy
assistance. There are currently 2 vacancies on this team. The Credit & Collections agents also
handle inbound customer calls during periods of high call volume – e.g. Monday, Tuesday after a
holiday, seasonal busy periods, etc.
INT-G-22-07
IPUC DR 76
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dan Tillis/Nicole
Kivisto
REQUEST NO. 77:
Does the Customer Experience Team Center provide customer service for all utilities
owned by MDU Resources Group, Inc.?
RESPONSE NO. 77:
Yes, the Customer Experience Team center provides customer service for all utilities
owned by MDU Resources Group, Inc.
INT-G-22-07
IPUC DR 77
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dan Tillis/Nicole
Kivisto
REQUEST NO. 78:
What are the operating hours of the Customer Experience Team Center?
RESPONSE NO. 78:
The Customer Experience Team core operating hours are Monday – Friday from 6:30
AM – 7:30 PM. The Customer Experience Team is staffed 24 hours a day, 7 days a week, 365
days a year by the Scheduling Team to handle after hours emergency calls.
INT-G-22-07
IPUC DR 78
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Dan Tillis/Nicole
Kivisto
REQUEST NO. 79:
What hours (Mountain Time), does the Customer Experience Team take phone calls from
Idaho customers?
RESPONSE NO. 79:
For normal, non-emergency calls the Customer Experience Team takes inbound phone
calls from Idaho customers from 7:30 AM – 6:30 PM Mountain Time. The Customer Experience
Team is also staffed 24 hours a day, 7 days a week, 365 days a year by the Scheduling Team to
handle after hours emergency calls from Idaho customers.
INT-G-22-07
IPUC DR 79
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Byron L. Pfordte/
Nicole Kivisto
REQUEST NO. 80:
Please explain the efforts put forth by the Company to promote the Project Share, Project
Warmth and Keep Kids Warm programs.
RESPONSE NO. 80:
Project Share is promoted by the Company through customer bill inserts, website links,
and a dedicated webpage at www.intgas.com/customer-service/low-income-assistance-
programs/project-share/.
Project Warmth is promoted by the Company through customer bill inserts, website links,
a dedicated webpage at www.intgas.com/customer-service/low-income-assistance-
programs/project-warmth/, and social media posts.
Keep Kids Warm is promoted by the Company through customer bill inserts, website
links, a dedicated webpage at www.intgas.com/customer-service/low-income-assistance-
programs/keep-kids-warm/, social media posts, press releases, and through our community
partners; Idaho Steelheads and Baird’s Dry Cleaners.
INT-G-22-07
IPUC DR 80
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Byron Pfordte/
Nicole Kivisto
REQUEST NO. 81:
Please describe the types of advertising (radio, tv, bill insert, welcome kit, etc.) that is
conducted in Idaho to inform and educate customers about the following:
a.Energy Assistance and bill payment options;
b.Energy conservation; and
c.Winter Moratorium and the Winter Payment Plan.
In addition, please provide copies of any written brochures or documents sent or
otherwise provided to customers for each defined category listed in this question.
RESPONSE NO. 81:
The types of promotion conducted in Idaho to inform and educate customers is outlined
below. Copies of documents provided to customers in each defined category are included in the
folder “RFP 81 Documents”.
a. Energy Assistance and Bill Payment Options
Energy Assistance
o Paid and organic social media posts in Facebook and Instagram, and organic only
posts in Twitter, and LinkedIn
o Website banners, webpages, and text links promoting and providing bill
assistance information
o Bill inserts eight times a year
INT-G-22-07
IPUC DR 81
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o Bill onserts: once a year to all customers and every month to every past due
customer
o Paid display ad campaigns in October, December, February, and April
o Customer emails to those opted-in to receive Intermountain cost-savings email
notifications
Bill Payment Options
o Social media posts in Facebook, Twitter, LinkedIn, and Instagram
o YouTube videos
o Website buttons, webpages, and text links promoting and providing bill assistance
information
o Bill inserts three times a year
o Bill onserts year-round targeting customers not currently enrolled in any/all
programs
o Customer emails to those opted-in to receive Intermountain cost-savings email
notifications
b. Energy Efficiency
A Residential Energy Efficiency Program Brochure is included with each new
residential customer letter.
A residential energy efficiency topic and the Energy Efficiency Program is promoted
each month through social media (Facebook, Instagram, Twitter, and LinkedIn).
The Residential Energy Efficiency Program is advertised in the Parade of Homes
magazine in 5 regional Building Contractor Associations throughout the
Intermountain service territory.
INT-G-22-07
IPUC DR 81
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A Residential Energy Efficiency Campaign is conducted each Fall which includes:
o A bill insert (provided both by paper for those receiving a paper bill, or
digitally for on-line bill pay),
o An email sent to customers that opt in to receiving energy efficiency topics
o A customer engagement activity. This is typically a sweepstakes opportunity
in conjunction with energy efficiency education.
Commercial Energy Efficiency Program
o The Commercial Energy Efficiency Program brochure is sent as a bill insert to
commercial customers.
o Emails are sent to commercial customers at least twice a year.
o Energy Efficiency is promoted to commercial customers at least once a year
via a bill onsert, which is a promotional message that is printed on the bill.
o The Commercial Energy Efficiency Program is advertised in the construction
section of the Idaho Business Review “Book of Lists,” a statewide publication
that is available year-round.
c. Winter Moratorium and Winter Payment Plan
Customer bill inserts are included with all past due bills
Customer Service Representatives present the Winter Moratorium and Payment Plan
options to customers on the phone when applicable
INT-G-22-07
IPUC DR 81
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Teri Sovak/Nicole
Kivisto
REQUEST NO. 82:
Please describe in detail the type of standard payment plans/arrangements the Company
offers its customers.
RESPONSE NO. 82:
The Company offers the following standard payment plans/arrangements:
1.Basic Pay Plan and Payment Arrangement options.
a.Pay Plans are short term arrangements. Customers must make contact prior to
disconnection of service for non-payment, agree to reasonable payment
installments and not have a recent history of broken pay plans. During the course
of the pay plan, customers are typically asked to cover the arrears prior to the next
bill’s due date if possible. Pay Plans are set up based on each customer’s unique
circumstances. Pay Plans do not remove the balance included in the arrangement
from the amount due on the customer’s bill; however, the arrangement does
shelter the debt from all collection activity. Customers can review their Pay Plan
schedule by logging into their online account or contacting a Customer Service
Representative.
b.Payment arrangements are arrangements which allow for longer payback terms.
Payment arrangements temporarily exclude the debt included in the arrangement
from showing in the amount due on the customer’s future bills. Statements reflect
only the bill from the current month’s usage plus the monthly installment owing
INT-G-22-07
IPUC DR 82
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to the payment arrangement as the amount due. No interest is assessed on the
amount unbilled in the payment arrangement. Prior to March 2020, Payment
arrangements were used primarily for dead meter or billing error situations.
Terms were established based on the severity of the billing correction and the
customer’s ability to pay. The Company continues to make long-term payment
arrangements available to customers as described in Response to Production
Request No. 84.
INT-G-22-07
IPUC DR 82
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Teri Sovak/Nicole
Kivisto
REQUEST NO. 83:
Please describe in detail the temporary alternative/modified payment/plan arrangements
the Company offered its customers in 2020 and 2021 due to COVID-19.
RESPONSE NO. 83:
1)Extended Pay Plans
a)Beginning in March of 2020, Intermountain began offering extended pay plans of
up to two additional billing cycles. Unpaid balances were allowed to be carried
forward onto the next bill as a total amount due, along with new usage charges,
while remaining sheltered from collection activity. Customers continued to
review their payment plan schedule by logging into their online account or
contacting a Customer Service Representative.
2)Long-Term Payment Arrangements
a)Additionally, longer-term payment arrangements were offered outside of dead
meter and billing error situations for customers requiring longer arrangements on
past due debt. Terms were flexible but were typically made for up to 12 months
for residential customers and up to 6 months for non-residential customers based
on account balance, prior history of kept or broken arrangements and the
customer’s ability to pay.
INT-G-22-07
IPUC DR 83
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Teri Sovak/Nicole
Kivisto
REQUEST NO. 84:
Did the Company make any of the temporary alternative/modified payment
plan/arrangement a permanent offering? If no, please explain.
RESPONSE NO. 84:
Yes. Long-term payment arrangements continue to be available as established during the
pandemic to customers requiring additional time to pay on past due debt.
INT-G-22-07
IPUC DR 84
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INTERMOUNTAIN GAS COMPANY
CASE INT-G-22-07
FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Carmen
Goicoechea/Nicole Kivisto
REQUEST NO. 85:
For each of the past three years (2020, 2021 and 2022), how many participants were
under winter protection each year. Of that amount, how many participants agreed to be placed on
the winter payment plan and how many were unable to meet their monthly payment?
RESPONSE NO. 85:
In response to Request No. 85, please see the chart below:
2020 2021 2022
IGC - Winter Protection 1,855 1,286 1,318
Winter Budget Payment Plan
Created 2 5 4
Winter Payment Plan Broken 1 3 0
INT-G-22-07
IPUC DR 85
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