20190305_bab1jo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:BEVERLY BARKER
DATE:FEBRUARY 28,2019
SUBJECT:FORMAL COMPLAINT OF RAUL MENDEZ AGAINSTINTERMOUNTAINGASCOMPANY
On January 25,2019,Raul Mendez filed a formal Complaint,Attachment A hereto,
against Intermountain Gas Company (the Company).Mr.Mendez asks the Commission to order
the Company to:
(1)Refund a $14.00 Account Initiation Charge,plus accumulated interest applied tohisaccountinOctober2018;
(2)Pay costs of $72.00 incurred in the drafting of his Complaint;
(3)Bar the Company from charging fees for voluntarily disconnecting service,especially if the reason for requesting disconnection is due to financial hardship;
(4)Warn the Company that they must comply with the Commission's rules;and
(5)Warn the Company "about manipulation of fees to the detriment of Idaho
customers."
See Complaint at 10-11.
Mr.Mendez filed his Complaint after becoming unsatisfied with the outcome of informal
proceedings.His formal Complaint thus asks the Commission for "more accountability and
transparency of the IPUC complaint process and to warn staff of not giving the appearance of
bias."
DECISION MEMORANDUM l FEBRUARY 28,2019
BACKGROUND
Mr.Mendez contacted Commission Staff several times about the Company's rates and
charges and his bills.In this particular instance,Mr.Mendez objects that the Company charged
him an Account Initiation Charge after he tried to save money by having the Company
disconnect his service in the summer and then reconnect service at the same address before
winter.Mr.Mendez questions whether the Account Initiation Charge is "a valid charge on an
already existing account"and whether a customer "can disconnect gas service without incurring
additional fees such as an initiation fee for restarting service."See Complaint at 1.Staff notes
that the Commission has authorized the Company to assess an Account Initiation Charge
whenever an account is opened.See Intermountain Gas'Tariff,Section A,Sheet No.6,Section
9.4,and Attachment B hereto.Mr.Mendez also questions the amounts billed by the Company in
the past during the summer,when he believes no gas was consumed.See Complaint at 1.
Mr.Mendez also alleges that Commission Staff violated his right to due process during
informal proceedings.Specifically,he complains that Staff insufficiently explained the
Commission's rules and the Company's rates and charges.See Complaint at 7,9 and 10.
Finally,Mr.Mendez's Complaint refers to the Fair Debt Collections Practices Act.
However,it is unclear which specific collection practices of the Company he disputes and how
this federal law might apply under the circumstances.See Complaint at 9 and 10.
STAFF RECOMMENDATIONS
Staff recommends that the Commission issue a summons to Intermountain Gas and direct
it to file a response to the Complaint.
Further,given that Mr.Mendez has identified several issues that are more appropriately
addressed by Staff,Staff requests that it also be allowed to respond to the Complaint.
Staff recommends the Commission allow the Company and Staff to file their responses
within 21 days after the Commission issues the summons.
Staff recommends that the Commission then allow Mr.Mendez 14 days after the
response deadline to file a reply.
Finally,Staff recommends that the Commission direct the Company,Staff and Mr.
Mendez to meet within 30 days after Mr.Mendez's reply deadline to explore whether they might
DECISION MEMORANDUM 2 FEBRUARY 28,2019
resolve some or all of the issues.Staff then would update the Commission within 14 days about
settlement efforts in order to allow the Commission to make a decision.
COMMISSION DECISIONS
Does the Commission wish to:
(1)Accept Mr.Mendez's formal Complaint?
(2)Issue a summons to Intermountain Gas,giving the Company 21 days to respond
after the summons issues?
(3)Allow Staff to respond to the Complaint within 21 days after the summons issues?
(4)Allow Mr.Mendez to reply within 14 days of the response deadline?
(5)Direct the Company,Staff and Mr.Mendez to meet and confer within 30 days of
the reply deadline,with Staff to report to the Commission within 14 days on the
outcome of the meeting or with further process recommendations?
Beverly r
Udmemos/Decision Memo Mendez_sckkbbrev
DECISION MEMORANDUM 3 FEBRUARY 28,2019
ATTACHMENT A
Raul Mendez
2712 N.Goldeneye Way
Meridian,ID 83646
PH [phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RAUL MENDEZ,CASE No.
Complainant,
VS CUSTOMER COMPLAINT
INTERMOUNTAIN GAS COMPANY,
Respondent.
NOW COMES RAUL MENDEZ,complainantcharges as follow:
Mr.Mendez complains against the above utility company providing gas for Idaho residents.Mr.Mendez
notes that most of his communications over the past 1.5 years have been with staff at the Idaho Public
Utilities Commission thru the Informal complaint procedure,Rule 402 01;IDAPA 31.21.01.He has
receivedlittle correspondence from Respondent because they indicated that they don't respond to email
even whentheir website indicate that it is one of the means to contact them.Mr.Mendez charges that
the staff with the Idaho Public Utilities Commission violated his Due Process rights and Intermountain
Gas violated his rights under the Fair Debt CollectionsPractices Act (FDCPA).
ISSUES
1)Is an account initiation fee of $14 dollars a valid charge on an already existing account?
2)Should the charges be consistently the same over the summer on an account that shows no use of gas?
3)can a customer disconnect gas service without incurring additional fees such as an initiation fee for
restarting service?
FACTUAL BACKGROUND
On 7/6/2017,Mr.Mendez contacted respondent questioning why he had been charged $7.41 for July
2017 when on July 2016 and over the entire Summer of2016 the charge had been $5.34.Mr.Mendez
indicated that he does not use gas over the summer including heating for water.He questioned why there
was an increase of 2.07 from the previoussummer when it should be identical since there is no gas usage.
Furthermore,he indicated that for many years it had been $5.34 over the summer months when he does
not use gas.
On 7/7/2017,Respondent explained that the difference in the bill from 2016 summer to 2017 summer is
due to the customer charge going from $2.50 to $5.50 as of 5/1/2017.
On 7/25/2017,Mr.Mendez called utility to ask how to disconnect service over the summer since there is
no usage of gas and to save money for the winter.He was told by Sydney in Customer service that there
would be a 14 dollar reconnect fee to restart service in the winter.
On 7/30/2017,Mr.Mendez contacted respondent via email and told customer service that he has not
being able to find on their website anything in regards to a 14-dollarreconnection fee.
On 8/3/2017,Mr.Mendez requested respondent send to him the information where it says that there is a
14 dollar reconnect fee.
On 8/4/2017,Respondent explainedto Mr.Mendez that the $14 fee is not a reconnect fee but initiation
fee for starting service.He was directed the FAQS on the company's website.see exhibit 1.
On 8/4/2017,Mr.Mendez repliedto respondent pointing out that an initiation fee is entirely different than
a reconnect fee.I alreadvhave the service on,thereforethe 14-dollarcharge does not apply.
furthermore,I see that you do indeed charge a reconnect fee only if the service has been disconnected due
to non-payment.The company's website indicate that an initiation fee is charged on each account opened
with Intermountain gas.see exhibit 1.
On 8/9/2017,Mr.Mendez contacted respondent stating that if there is no usage then there should be the
same fee every statement during summer whether it's $5.34 or $7.41.How is it possible that the cost of
gas per terms and the distribution costs varies from July 2017 to August 2017 when there is no gas usage.
see exhibit 1.
On 8/24/2017,Curtis Thaden with the IPUC handled the informal complaint.He indicated that when the
customer places a request to reconnect a $14 'account initiation charge'is assessed to open a new account.
He further indicated that the account numberin the new account will be the same as the closed out
account.He stated that if an account is closed for longerthan 10 days and a request is made to reconnect
service the utilitycompany will consider that person an applicantand not a customer.Mr.Thaden
indicated that thoughyour furnace is not operatingin the summer months Therm usage is being recorded.
More than likely the recorded usage is from a pilot light of the furnace and hot water heater and gas is
being used to heat the water.This explanationwas provided even when Mendezmade it clear that no
gas is being used at all during summer including heating for water and when for many years the per
therms and distribution costs have been the same during summer months when there has been no use.see
exhibit 1.
On 9/12/2017,Mr.Mendez questioned respondent if the fees are being manipulated.It was 4 therms
summer 2016 as well when there was no gas usage.However,it was $2.06 and $7.08 in 2016 when the
customer charge was $2.50.It is still 4 therms summer 2017 but because the customer charge is now
$5.50,it appears that IntermountainGas has loweredthe same 4therms to $1.86 and $0.69.it was $5.34
summer 2016 and it is $8.05 summer 2017.No gas is being used at all during summer.Comparison
between prior years and 2017 summer show a consistent 4 therms but somehow the statements for this
year ends up being 3 dollars more.He got no response.see exhibit 1.
On 4/30/2018,Mr.Mendez contacted respondent again regardinga seasonal shut off over the summer
since he does not use gas during warm weather.He noted in August 2017 that there was no point in
disconnectingservice that late since it would have to be restarted in October but he would plan on the
seasonal disconnect in 2018.
On 5/2/2018,Respondent talked to Mr.Mendezon the phone and providedhim with Order
No2738941026and indicated there would be a $14 initiation fee to restart service.
On 5/4/2018,Mr.Mendez told respondent that the $14 fee is for new accounts but his account has been
open for 15 years.
On 5/4/2018,Respondent told Mr.Mendezthat once your account is closed for 10 days you're no longera
customer.So,the $14 initiation fee for a new account would apply when you start service in the fall.
see exhibit 1.
On 5/12/2018,Mr.Mendez asked respondent to providethe exact location on the policies where it states
that the utilities can charge the 14-dollarinitiation fee on an already existing account.see exhibit 1.
On 5/18/2018,Mr.Mendez told respondent that his account has been opened for 15 years and that they
are trying to charge 14 dollars to restart the service on an existing account which is current and not
stopped due to non-payment.see exhibit 1.
On 6/7/2018,Mr.Mendez contacted Mr.Thaden with the IPUC regardingthe ongoing issues with
respondent.Mr.Mendez told Mr.Thadenthat the IPUC has approveda 14-dollar initiation fee on a new
account but not on existing accounts that have been temporarily disconnected.
On 6/8/2018,Mr.Thaden told Mr.Mendezthat Section 9.4 of the approvedtariff allows intermountain
gas to charge a fee of $14 or $40 whenevera customer requests service,even if the requestor previously
had an active account.If a customer requests disconnection of service,service is disconnected and the
account is closed.The account is no longeractive and the former customer is no longerclassified as a
customer.see exhibit 1.
On 6/14/2018,Mr.Mendez told Mr.Thaden that he had not being able to find anywhere where it
specifically states that an existing account becomes a new account after it has been closed for more than
10 days.
On 6/19/2018,Mr.Thaden told Mr.Mendez that the word existing is causing confusionand that existing
implies that something is current.when a customer closes out their account,the account is no longer an
existing account and that person is no longera customer of the utility.Only active accounts are existing
accounts.A customer is definedby the Utility Customer Relation Rules as someone who is receiving
servicefrom a utility or has receivedservice within the past ten calendar days prior to termination by the
utility,see exhibit 1.
On 7/20/2018,Mr.Mendez told Mr.Thadenthat under section 9.4 of the tariff and under the fee policy
(approvedby the IPUC)there was nothing in the language indicating that "when a customer closes out
their account,the account is no longeran existing account and that person is no longer a customer of the
utility.If he/she,at a later date decides to become a customer again,and requests service be established,
an account is opened."
On 8/2/2018,Mr.Thaden indicated again that if a customer voluntarily disconnect service and then
decides to reconnect service again an account initiation charge is assessed.Often,IG will issue the same
account numberas.previouslyissued as a courtesy to a customer for the purpose of bill pay and automatic
withdrawal from the individuals banking see exhibit 1.
On 8/2/2018,Mr.Mendezreplied to Mr.Thadenthat if the same account number is "issued"for the
purposes of billing,then any reasonable person would conclude that it was an existing customer with an
existing account with an existing billing information that is having the service restarted.In other words,
it is not a new applicant for service.
On 8/3/2018,Mr.Thaden told Mr.Mendez that the customer definition specific to "has receivedservice
within the past 10 calendar days prior to termination by the utility."Terminationby the utility refers to
any condition that broughtabout the terminationof servicewhich includes customer requests.see
exhibit 1.
On 8/15/2018,Mr.Mendez told Mr.Thaden that he could not find anythingon the IPUC rules regarding
to "any condition that broughtabout the termination of service which includes customer requests."
On 10/9/2018,Mr.Mendezcontacted respondent noting that he receivedthe bill for 10/2018 for which 14
dollars had been charged as an initiation fee on an existing account which now showed as being active.
On 10/18/2018,Mr.Thaden told Mr.Mendez that if you file a formal complaint and the Commissioners
accept the complaint,IG will respond to the Commission.see exhibit 1.
On 10/25/2018,Mr.Mendez attached a link from the Idaho Supreme Court for Mr.Thaden review.The
link is a guide regardingthe IPUC and utilities in Idaho.It asks the question:my utility charged me a
deposit before they turned on my service.Can they do that?Usually,no.However,a utility may
charge a deposit when they turn on your service if you had your seryice terminated for nonpayment at
previousaddress.The link indicated too that IPUC rules appliedto the water utility like Suez.yet.Suez
does not charge am 'initiation'fee for restarting serviceafter temporarydisconnections.Aren't the rules
the same for all three utilities?see exhibit 1.
On 11/6/2018,respondent told Mr.Mendez that the 14-dollar initiation fee as well as the interests on the
past due balance is allowed,and even mandated by our tariff that is approvedby the IPUC.see exhibit
1.
On l 1/6/2018,Mr.Thadentold Mr.Mendez that if the Commissioners were to rule in your favor I am
certain that Intermountain Gas would be ordered to remove the $14 fee and interest charges from your
account.The 14-dollar initiation fee is allowed per each company tariff and is not a violation of any rule.
Also,keep in mind that both IntermountainGas and Idaho Power incur costs when havingto reconnect
service and those costs are not recoveredin rates.see exhibit 1.
On 11/8/2018,Mr.Mendez told Mr.Thaden that basically,the 14-dollarcharge that is in dispute is for
sending someone to turn on service on an existing account.it's just that IG are not saying that it is a fee
connected with sending someone to turn it on;instead they claim it is an initiation fee on a new account.
What about Suez?many people request seasonal disconnects during winter if they are away from home
to avoid frozen pipes.They don'tcharge an initiation fee on existing accounts.aren't the IPUC rules the
same for the utilities?
On 12/4/2018,Mr.Thadentold Mr.Mendezthat when you called IG to start service again an account was
opened;often the company will issue the same account numberas previously used for a customer's
conveniencefor electronic payment purposes.IG assesses a $14 account initiation fee when a request for
serviceto be established is requested.For service to be established an account has to be opened.In
review of the company's tariff under section 9.4,the wording states "on each account opened"not new
account.Suez water does not charge an initiation fee.Each utility company has its own set of
guidelines,business practices,and rate design so policy will vary from utility to utility.I do not believe
the commission will waive a fee that has previously been approvedby the Commission.see exhibit 1.
ARGUMENT
Mr.Mendez has only includedemail correspondence on exhibit I for organizationalpurposes of this
complaint.He refers to some links/attachments in the abovecorrespondence that will be included as
separate exhibits.He will refer to pertinentRules and he will also refer to K.W v.Idaho Department of
IIealth and Welfare,State ofIdaho.Case No 1:12-cv-00022.A US District Courtof Idaho case
involving violations of due process rights.He will refer to the FDCPA.
On 5/18/2018,Mr.Mendez attached a picture for respondent of his IG account showingas the service
being stopped.see exhibit 2.On 10/9/2018,Mr.Mendez attached a picture for respondent of the same
account numberwith the same account name for the same address showingas the service being active.
see exhibit 3.On 10/9/2018,Mr.Mendezalso attached a picture of respondent's website showing the
fees approvedby the Idaho Public Utilities Commission.see exhibit 4.Respondent and Mr.Thaden
frequently refer on the above emails to 9.4 under IG tariff see exhibit 5.On 10/25/2018,Mr.Mendez
attached a link from the Idaho Supreme Court website to help people with questions about utilities.see
exhibit 6.
Rule 5 of IDAPA 31.21.01 defines an applicant as any potential customer who applies for service.
Defines customer as any person who has applied for,has been accepted by the utility and is:receiving
servicefrom a utility or has receivedservice within the past ten days prior to termination by the utility.
defines utility as any public utility providing gas,electric or water service subject by law to the
Commission's jurisdiction.
IDAPA 31.21.01,Rule 101.01 states that no utility shall demand or hold a deposit from any current
residentialcustomer or applicant for residentialservice without proof that the customer or applicant is
likely to be a credit risk or damage to property of the utility.A utility shall not demand or hold a deposit
under this rule as a condition of service from a residential customer or applicantunless one or more of the
following criteria applies:a)the customer or applicant has outstandinga prior residential service account
with the utility that accrued within the last four years and at the time of application for service remains
unpaid and not in dispute.b)the customer's or applicant's service from the utility has been terminated
within the last four years for one or more of the following reasons:i.nonpayment of any undisputed
delinquentbill;ii.misrepresentation of the customer's or applicant's identity for the purpose of obtaining
utility service.d)the applicant did not have service with the utility for a periodof at least 12 consecutiye
months during the last four years and does not pass an objective credit screen.
IDAPA 31.21.01,Rule 104 states that if the utility requires a cash deposit as a condition of providing
service,then it shall immediately provide an explanationto the applicant or customer stating the precise
reasons why a deposit is required.The applicantor customer shall be given an opportunityto rebut those
reasons.
IDAPA 31.21.01,Rule 107.02 states that the utility shall promptly return the deposit (with accrued
interest)by either crediting the existing customer's current account or issuing a refund.Rule 107.03 states
that the utility shall pay interest at the annual rates established in Rule 106 for the entire periodover
which the deposit was held.
IDAPA 31.01.01,Rule 21 states that the Commissionmay provide that informal proceedings may
precede formal proceedings in the considerationof a rulemaking or a case.
Mr.Mendezhas already spent a significant amount of time correspondingwith Mr.Thaden in regards to
his complaint against IntermountainGas.The informal complaint has resulted in a violation of Mr.
Mendez right to Due Process as Mr.Thaden has provided information that conflicts or overshadows the
language of the IPUC rules,or just misrepresented information to Mr.Mendez.Ïn the Federal Case K.W
v.Idaho Department of IIealth and Welfare,State ofIdaho.Case No 1:12-cv-00022;Judge WinmilI
explainedthat the first Notice reducingbeneñts to disabled participants failed to providedue process
because it made it difficult for a participantto determinewhy his budget had been reduced and left him
unable to effectively challenge the reduction.A second proposed notice failed to properly notify
participantsof the reasons for IDHW's actions.Judge Winmill stated that one of those procedural
protections is the establishment of clear ascertainable standards that "insure fairness and ...avoid the risk
of arbitrary decision making."citing Carey v.Quern,588 F.2d230,232 (9th Cir.1978).
The explanations provided by Mr.Thaden thru the informal complaintviolate Due Process because they
make it difficult for people to determine why Respondent/utilitiesunder IPUC Jurisdictionare charging
$14 to restart service and the conflicting information makes it difficult to challenge the charge.Mr.
Thadenexplanationsfailed to properly inform the public why utilities like IG charge an initiation fee on
existing accounts.Judge Winmill ruled against the IDHW in violations of Due process precisely because
the lack of clear ascertainable standards to avoid the risk of arbitrary decision making.
For example:Mr.Thaden stated that the 14-dollar initiation charge is assessed to open a new account
and if the account had been closed for longerthan 10 days and request is made to reconnect that the utility
will consider the person an applicant and not a customer.Mr.Thaden also stated that Section 9.4 of the
tariff allowed IG to charge the 14 dollar whenevera customer requests service even if the requestor
previously had an activeaccount.Mr.Thaden stated that the customer definition specific to "has
receivedservicewithin the past 10 calendar days prior to termination by the utility;terminationby the
utility refers to any condition that broughtabout the termination of service includes customer requests.
Mr.Thaden stated that if the Commissioners were to rule in your favor I Am certain that IG would be
orderedto remove the $14 fee and interest charges.Mr.Thaden stated that Suez does not charge an
initiation fee and each utility company has its own set of guidelines,business practices and rate design so
policy will vary from utility to utility and he also noted on his last email that he now did not believethe
commission will waive a fee that has previously been approved.
IDAPA 31.21.01 Rule 5 defines utility as any public utility providing gas,electric or water service
subject by law to the Commissioner's jurisdiction.The Utility questions under the the Idaho Supreme
Court site to help people show that the IPUC adopts rules that apply to residential customers of
investor-ownedutilities such as Idaho Power,Intermountain Gas and Suez water.Mr.Mendez has seen
nothing in the IPUC rules to indicate that Suez has a different set of rules than other utilities under IPUC
jurisdiction in regards to the 'initiation fee.'
IDAPA 31.21.01,Rule 101.01 clearly state that a utility shall not demand or hold a deposit unless:1)the
customer or applicant has an outstanding prior account with the utility that accrued within the last four
years and at the time of applicationof service remains unpaid and not in dispute,2)the customer's or
applicant's services from the utility has been terminatedwithin the last four years for i.nonpayment of
any undisputeddelinquentbill,ii.misrepresentation for the purpose of obtaining utility service,3)the
applicantdid not have service with the utility for at least 12 consecutive months during the last four years
and does not pass an objective credit screen.It is clear that the 14-dollarinitiation fee on Mr.Mendez
case became a deposit that respondent charged (to restart service)to an existing account that did not met
any of the above criteria under the rule.Respondent would not have been able to assess the 14-dollarfee
if there was no account on file even if the applicant/customerwas delinquentfor four years or if the
applicant did not have service with IG for 12 consecutive months during the last four years.Mr.Mendez
account was already opened and was temporarily disconnected by the customer NOT the utility.
Mr.,Thaden stated that "has receivedservice within the past 10 calendar days prior to terminationby the
utility";termination by the utility refers to any condition that brought about the termination of service
includes customer requests.However,that is not what the rule states.IDAPA 31.21.01 Rule 5 defines
a customer as any person who has applied for,has been accepted by the utility and is:receiving service
from a utilityor has receivedservice within the past ten days prior to terminationby the utility.Due
process requiresthat the rule specifically state that "termination by the utility refers to any condition that
brought about the terminationof service including customer requests."Otherwise,there is no clearly
ascertainable standards.Due process requires that the 9.4 Tariff actually state that Respondent is allowed
to charge the 14 dollar whenevera customer requests service even if the requestor previously had an
active account.Otherwise,there is no clearly ascertainable standards.Due process requires that IPUC
staff don't toy with people when Mr.Thadenfirst,state that "that if the Commissioners were to rule in
your favor I Am certain that IG would be orderedto remove the $14 fee and interest charges,"then later
on he tells people that "I do not believethe commission will waive a fee that has previously been
approved."It gives the appearance of arbitrary decision making and an attempt to discourage/prejudice
people.
The Fair Debt CollectionsPractices Act is a Federal Consumer Protection Law intended to shield the
public from the menace of unscrupulous and dishonest debt collectors.Among other provisions,The
FDCPA makes it illegal to:collect charges not permitted by law (15 U.S.C.1692f(l));falsely represent
the character,amount or legal status of the debt (1692e(2)(A));falsely represent the compensation
lawfully permitted for services (1692e(2)(B));threaten to take any action that cannot legally be taken or
that is not intended to be taken (1692e(5));use false representations or deceptive means to collect or
attempt to collect the debt (1692e(10)),and threaten to take nonjudicial action to effect dispossession of
the property (1692f(6)).
Respondentnever answered Mr.Mendez concerns with the charges being manipulatedsince there is no
gas usage over the summer including no heating for water means that it should be consistently the same
every month over the entire Summer.In fact,Mr.Mendezpointed out that prior to the Summer Of 20 17
it had been a consistent $5.34 every single month of the Summer for years.It was 4 therms summer
2016 as well when there was no gas usage.However,it was $2.06 and $7.08 in 2016 when the customer
charge was $2.50.It is still 4 therms summer 2017 but because the customer charge is now $5.50,it
appears that IntermountainGas has lowered the same 4therms to $1.86 and $0.69.it was $5.34 summer
2016 and it is $8.05 summer 20l7.No gas is being used at all during summer.Comparisonbetween
prior years and 2017 summer show a consistent 4 therms but somehow the statements for 2017 year ends
up being 3 dollars more.While Mr.Mendezgot no response from Respondent;Mr.Thaden told Mr.
Mendez that the differencewas attributedto a "pilot light of the furnaceand hot water heater and gas is
being used to heat the water."NOTE:Mr.Thadenprovidedthis explanation even when told that there is
no gas being used to heat water and when the readings showed a consistent 4 therms during Summer for
many years,precisely because of the no usage.
IDAPA 31.21.01,Rule 104 states that if the utility requires a cash deposit as a condition of providing
service,then it shall immediatelyprovide an explanationto the applicant or customer stating the precise
reasons why a deposit is required.The applicant or customer shall be given an opportunity to rebut those
reasons.The assessing of the 14-dollarinitiation fee to an existing account to restart service is an
example of "collect charges not permitted by law (15 U.S.C.1692f(l))"and since Due process protections
requires the establishment of clear ascertainable standards that "insure fairness and ...avoid the risk of
arbitrary decision making."Carey v.Quern,588 F.2d 230,232 (9th Cir.1978).Having discussed
extensivelyhow the IPUC informal complaint violated Mr.Mendez Due process,then stands to reason
that the same explanations given by respondentare in violation of Law including the aforementioned
FDCPA.
CONCLUSION
1)Mr.Mendez asks the Commission that the 14 dollar "initiation"fee assessed to his existing account in
order to restart service on 10/2018 be refunded along with Interests accrued since 10/2018.
2)Mr.Mendez asks the Commission to Order Respondent to pay costs incurred in the drafting of this
Utility complaint.Mr.Mendez has incurred costs of Gas/mileage in traveling to the Law library to do
research and for printing/copies.His Costs total 72 dollars.
3)Mr.Mendez asks the Commission to issue an Order barringRespondent from chargingcustomer's
fees for voluntarily disconnecting service.Especially if the reasons for disconnect are due to financial
hardship.
4)Mr.Mendez asks the Commission to issue an Orderwarning Respondent that they must comply with
the IPUC Rules.
5)Mr.Mendez asks the Commission to issue an Orderwarning Respondent about manipulationof fees
to the detriment of Idaho customers.
6)Mr.Mendezasks the Commission for more accountability and transparency of the IPUC complaint
process and to warn staff of not giving the appearance of bias.
Dated:January 25,2019
Raul Mendez
l have not being able to find where it says that there is a 14 dollar to reconnectservice.would you please
send me the link where it says that there is a 14 dollar reconnectfee?I asked to havethe service
disconnected during hot weather because I don't use gas at all and I need to save money,but I was told
that there is a reconnectfee.I hope that you're not misleading customers.I might haveto contact the
Idaho Public Utility Commission to explain my situation and Intermountaingas unwillingness to work with
customers when the statements clearly show there is no gas usage and l'm being charged7.41 for
'maintenance'fees.....and please do not ask me to call you because I already did and you did not offer any
solutions.
Raul
[Quoted text hidden]
Raul Mendez <[e-mail]>Thu,Aug 3,2017 at 5:54 PM
To:Customer Service IGC <[e-mail]>
I have not receiveda response and it concerns me that when customers contact you via messaging on
your website that apparently any responses can disappearfrom customer's email.I have these questions:
1)can you please send me the informationwhere it says that there is a 14 dollar reconnectfee?
2)you can go back severalyears and see that there is about 4-5 months out of the year wherethere has
never been gas usage on my account during warm weather.I have paid my bills for no use.Why do you
need to send a technician to disconnect the service (then charge a 14 dollar reconnect fee)when there is
clearly no use of the service during this time of the year?
3)can you just make a note on my account not to be billed during this time of the year when there is no
gas use7 do you need me to sign an agreement so to make sure that I won't use gas during warm weather
and you won't bill me for it?
4)do you need proof of income7 I cannotcontinue to pay for no use during warm weather and when l'Il
need the money during winter to pay bills as high as over 100 dollars.As explainedbefore,I havealready
tried the 'utility assistance'organizationssuch as EIAda,SalvationArmy,St Vincent De Paul,etc but they
all have limited funding giving priority to elderly,disabled and family with many kids.
5)If you need to disconnect service then schedule for next week so that I can unlock the fence for the tech
to access the meter.Call me ahead of time.Even though I believeit to be a waste of time/resourceswhen
I'm not using gas during 5 months of the year.
thank you,
Raul
{Quoted text hidden]
Customer Service IGC <[e-mail]>Fri,Aug 4,2017 at 9:42 AM
To:Raul Mendez <[e-mail]>
Hello Raul,
I have attempted to contact you by phone severaltime to discuss your issues.The $14.00fee is not a
reconnect fee but initiation fee for starting serviceyou can find this information on our website in the
FAQs,https://www.intgas.com/utility-navigation/faqs.If the gas service is on you will be charged a
customer charge each month this is the same for every customer of Intermountain Gas Company.If you
httoc//mnil annala onm/mailln/(1941r=o ("1(L1&Qr10Fruims,--+2,«.anma-n119,-,s...«+L:,4-+L-,,-,3 i n la inni o
wish to have the serviceoff during the summer you will need to contact our CustomerService Centerat
1-800-548--3679,Monday through Friday,7 a.m.to 7 p.m.
Sincerely,
Mary,Customer Support Lead
Intermountain Gas Company
Phone:[phone],M-F,7am-7pm
anowmarsbalow.
CaE befmeyondig
From:Raul Mendez [mailto:[e-mail]]
Sent:Thursday,August 03,2017 5:55 PM
To:Customer Service IGC<[e-mail]>
Subject:Re:acct #XXXXXXXOOO2
**WARNING:EXTERNALSENDER.NEVER click links or open attachments without positive sender
verification of purpose.DO NOT provideyour user ID or password on sites or forms linked from this email.
**
[Quoted text hidden]
Raul Mendez <[e-mail]>Fri,Aug 4,2017 at 6:35 PMTo:Customer Service IGC <[e-mail]>
Hello,
an initiation fee is entirely differentthan a reconnect fee.I already have the serviceon,thereforethe 14
dollar charge does not apply.furthermore,I see that you do indeed charge a reconnect fee ONLY if the
service has been disconnected due to non-payment.Here is what your website states:
Does Intermountain Gas charge any special handlingfees7
Our goal is to keep costs for serviceto our customers as low as possible.In orderto do this we believe
individual customers should bear the cost of any special handling they require instead of having all
Ul11CL11 "1 .ROUL TT AkJkJkJUkJkJkVUU L JL i.agv V VI A 1
customers pay for these services.The Idaho Public Utilities Commission authorizes Intermountainto
recover the following costs:
Interest on Past Due Accounts:Amounts due for your previous month's gas bill,which remain
unpaid at the time of the next billing date,will be assessed interest at the rate of 1%per month.
Participantsin the Level Payment Programwill be exempt from late payment interest charges.
Field Collection Fee $15:If a company representativemust visit your home to collect a past due
payment,a $15 fee will be assessed.If gas service is discontinued,this charge does not apply (see
Reconnection Fee).
Reconnection Fee:A reconnectionfee is assessed when senrice is restored for a customerafter a
non-pay service interruption.This fee is $22 during the hours of 8:00 a.m.to 4:30 p.m.and $44
during the hours of 4:30 p.m.through 7:00 p.m.,Monday through Friday.A reconnectionfee of $50
will be chargedon weekends or Company holidays.
Returned Payment Fee $20:This charge shall apply when a payment (check or electronic)is not
honored and returned by the bank.
Account initiation Fee $14 or $40:Each new account openedwith intermountain8 a.m.to 5 p.m.,
Monday through Friday,will be billed a $14 fee with the first regular bill.A $40 fee will be charged for
all accounts opened after 5 p.m.,Monday through Friday,weekendsor holidays.
I'm troubled by your attempts to be misleading.I don't understandwhy you would not want to work
something out with a customerwith such an excellent payment record.I got laid off by Micron and so l'm
working taking care off my disabled mom but it doesn'tpay well.I don't have a choice but to disconnect
then during warm weather when I don't use gas so to save money for winter.It makes no sense for a tech
to come twice during the year to disconnect then reconnectwhen you havedocumentedstatements over
the years showing that I don't use gas during this time of the year,but whateverif that is what it needs to
be done then fine.I'll probablywait until next year to start disconnectingthe service after cold weather
since it's already august and the tech would haveto come in Octoberto reconnect.......just to be clear
though there is no reconnectfee based on the informationon your website.
Thank you,
Raul Mendez
(Quoted text hidden]
Customer Service IGC <[e-mail]>Mon,Aug 7,2017 at 8:38 AM
To:Raul Mendez <[e-mail]>
Hello Raul,
if you would like to discuss this more you will need to contact our CustomerService Centerat
1-800-548-3679,Monday through Friday,7 a.m.to 7 p.m.We will no correspondwith you by email on
this matter.
Sincerely,
Mary,Customer Support Lead
httnw//mail annale enm/mail/n/09ik=a57046eRd4&view=nt&<:earch=all&nermthidthrend..19/7/901R
yman -im:acet «muuu a rage i ui 11
Intermountain Gas Company
Phone:[phone],M-F,7am-7pm
Know whats below.$8ll befmagend
From:Raul Mendez [mailto:[e-mail]]
Sent:Friday,August 04,2017 6:35 PM
(Quoted text hidden]
[Quoted text hidden)
Raul Mendez <[e-mail]>Wed,Aug 9,2017 at 5:50 PM
To:Customer Service IGC <[e-mail]>
Mary,
you have email and social media availableto customers,presumablyso that customers can contact you.I
already call and talked to Sydney who told me that you would not waive the misleading 14 dollar reconnect
fee.she also told me that you do not haveany kind of customer assistance programfor low-income people
who would qualify for it.It seems like IntermountainGas is the only utility that does not have any customer
assistance program.
If there is no usage then there should be the same fee every statement during summer whetherit's 5.34 or
7.41 becauseapparentlythere is a customer charge of 5.50 that is now fixed.I don't understand then how
the charge for this month is 8.05 as opposed to 7.41 from last month and 7.41 this month plus .07 interest.
The bill should be 14.89.
how is it possible that the cost of gas per terms and the distribution costs varies from last month to this
month when there is no use7 these are all valid questions.If there is no intent to mislead then there is no
reason why the questions would not be answered by anyone either by email,phone,or any other social
media available on your website to customers to reach you.
Thank you,
Raul
[Quoted text hidden]
Raul Mendez <[e-mail]>Fri,Aug 11,2017 at 6:45 PM
To:Customer Service IGC <[e-mail]>
no responsefrom customer service to my valid questions/concerns?well,it isn't like I could just switch
service to another company in Idaho and I wonder if this is the reason why you try to get away with
misleading people.I'm not going to pay a 14 dollar reconnectfee and I'm not going to pay more for the
'cost of gas per terms and distributioncosts'that should be the same every month while service is not
uman -r w:Internountain uas,Kaui Ivienuez,rage 1 01 lu
Raul Mendez <[e-mail]>
FW:Intermountain Gas,Raul Mendez,
5 messages
Curtis Thaden <[e-mail]>Thu,Aug 24,2017 at 4:03 PM
To:"[e-mail]"<[e-mail]>
Hi Mr.Mendez,
Thank you for contacting the Idaho Public Utilities Commission concerningthe issues you outlined in your
email.
Previously,the customer charge was set at a seasonal rate (April -November$2.50,December-March
$6.50).The Commissionapproveda year round rate of $5.50.The year round rate was approved(Case
No.INT-G-16.-02)and went into effect May 1 2017.Having the same customer charge throughoutthe
year is consistent with how the IntermountainGas incurs customer related costs over the year.Costs most
closely tied to specific customers are the capital costs and expenses of metering,meter reading,billing,the
service line,and customer service.IntermountainGas asked for $10.00.Staff recommended$5.50 and
the Commission approved the recommendation.The low usage of terms on your billing indicates possible
usage by a pilot light.This might by why you are seeing 3 to 4 therms of use over the last two billing
periods?In June and July of 2016 term usage was 4 therms per month.
If a customer requests disconnectionof servicethe account is officially closed.Wherithe customer places
a requestto reconnecta $14 "Account Initiation Charge"is assessed to open a now dócount (account
number used will be the same as the closed out accounty.If service is connected after hours the fee is
$40.Any time a customer voluntarilystops serviceand then a request is made to establish serviceagain
an "Account initiation Charge"is assessed.Please note that if the account is closed for longerthan 10-É
days and a request is made to reconnectservice the utility companywill considerthat person an applicant
and not a customer.
If you are disconnectedfrom servicefor non-paymentand then reconnecteda "Reconnection Fee"of $22
is assessed and if outside of regular business hours the charge is $40.00,and $50 on weekendsand
Company holidays.
At this time IntermountainGas nor does any utility in Idahooffer rate assistance to Idaho low income
customers.El-Ada providesenergy assistance grants to help with customer heating costs.The agency
can be reached at [phone].
I will address the issue of your preferredmethod of communicationwith IntermountainGas (email)and why
the Company told you that you have to call them to get an answers.
Gmail -FW:Intermountain Gas,Raul Mendez,Page 2 of 10
Thankyou for sharing your thoughts on disconnection of services due to financialhardships,assistanceprograms,and consistent utility statement fees.
Sincerely,
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
------Original Message ---
Subject:IntermountainGas
From:Raul Mendez <[e-mail]
To:Beverly Barker
CC:
Good Afternoon,
I have concerns and issues with this utility company.I don't know if I haveto fill out the form on the Idaho
Public Utility Commission website or if you can route my concerns to the right personnel.
I'm low income and I don't use gas during warm weather.I contacted intermountaingas via their email
address around 7/5/2017wonderingwhy the fee has gone up from 5.34 to 7.41 every month during
summer when for many years it had been 5.34.Uwas told that I had to submit any questions/concernsvia
their internal messaging system on the customers account.IG has social media,email,and phone as
means for customer's to contact them.
So,I asked them via their internal messaging system on my customer's account why the fee had gone up
from 5.34 to 7.41 when there is no use during summer and when for many years it was 5.34 during this
time of the year.In addition,I asked them what to do in order to disconnect serviceduring warm weather
in order to save money for non-used service.
I was told via their internal messaging that the fee increased had been approvedby the Public Utilities
Commission and that the difference was due to the fact that IG had decided that it would be a flat 5.50
customer fee every month as opposed to a changingcustornerfee thru the year.I was also told that there
would be a 14 dollar reconnectfee if I decided to disconnectserviceduring warm weather.
A copy of the internal message and the company responseare forwardedto the customers email address.
However,I noticed that after a few days the company responses disappearedfrom the copy that had been
forwardedto my email address.only the customers inquiry show up now.
On 7/25/17 I talked to customers service over the phone.Again,I asked them aboutthe disconnecting of
service during summer when i don't use gas in order to save money.I was told that there would be a 14
dollar reconnect fee that would not be waived.I was also told there was no assistance program for low-
income customer's.
I asked IG for a copy of the policy stating that there is a 14 dollar reconnectfee.
On 8/4/2017 a supervisor send me a link of the special fees stating that the 14 dollaris an "initiation"fee
for starting service.This is what the sites state:
Does IntermountainGas charge any special handling fees7
Gmail -FW:InternountainGas,Raul Mendez,rage a or w
Our goal is to keep costs for serviceto our customers as low as possible.In order to do this we believe
individual customers should bear the cost of any special handlingthey require instead of having all
customers pay for these services.The Idaho Public Utilities Commission authorizes Intermountainto
recover the following costs:
Interest on Past Due Accounts:Amounts due for your previousmonth'sgas biff,which remain
unpaidat the time of the next billing date,will be assessed interest at the rate of 1%per month.
Participantsin the Level Payment Programwill be exempt from late payment interest charges.
Field Collection Fee $15:If a company representativemust visit your home to collect a past due
payment,a $15 fee will be assessed.If gas service is discontinued,this charge does not apply (see
ReconnectionFee).
Reconnection Fee:A reconnectionfee is assessed when service is restored for a customer after a
non-pay serviceinterruption.This fee is $22 during the hours of 8:00 a.m.to 4:30 p.m.and $44
during the hours of 4:30 p.m.through 7:00 p.m.,Monday through Friday.A reconnection fee of $50
will be chargedon weekends or Companyholidays.
Returned Payment Fee $20:This charge shall apply when a payment (check or electronic)is not
honored and returnedby the bank.
Account Initiation Fee $14 or $40:Each new account openedwith Intermountain8 a.m.to 5 p.m.,
Monday through Friday,will be billed a $14 fee with the first regularbill.A $40 fee will be charged for
all accounts opened after 5 p.m.,Monday through Friday,weekendsor holidays.
i pointed out to the supervisorthat IG is misleading customers.An initiation fee is when an account is
being opened and there is a reconnectfee only after sentice has been shut downdue to non-payment.
I received the latest statementshowing an increase in the per terms and distributioncosts even when there
is no use.it should be the same uv¢ty month when there is no gas usage,and in factprior statements
during this time of the yéar show exactly the same fee when there has been no use in years past.
Intermountaingas stated that they would no longer answers my questions via email and I had to call them;
which concems me since I already talked to them over the phone and told me that 1)there is a reconnect
fee of 14 dollars that is not being waived,2)there is no assistance programfor low-income/poorpeople.I
believe that there is an intent to mislead customers.
I believe that customer should be able to disconneptààivícesif they are not usirig then in particularif the
reason for disconnectingit is due to financial hardship.I believe that utlities should have some sort of
assistance programfor low-incomecustomers,and i bâtievet6at thÑ fiÍitý átáÑtnáriÛees should be the
same every month if the service is not being used (assuming there is no late chargeslinterests)and in fact
prior years show that the statements have been the same every month when servicehas not being used.
Lastly,I believethat utilities should not be allowedto abuse and mislead customers.Unfortunately,IG is
the only gas providerand so it's not like customers can just switch service provider's.
Sincerely,
Raul Mendez
Raul Mendez <[e-mail]>Mon,Aug 26,2017at 11:03 PM
To:[e-mail]
Mr.thaden,
See my responses below.
See my responses below.
---Forwarded message ----
From:Curtis Thaden <[e-mail]>
Date:Thu,Aug 24,2017 at 4:03 PM
...----,---2 2,-2-,Page 4 of 10
Subject:FW:IntermountainGas,Raul Mendez,To:"[e-mail]"<[e-mail]>
Hi Mr.Mendez,
Thank you for contacting the Idaho Public Utilities Commission concerningthe issues you outlined in youremail.
Previously,the customer charge was set at a seasonal rate (April -November$2.50,December-March$6.50).The Commission approveda year round rate of $5.50.The year round rate was approved(Case
No.INT-G-16.-02)and went into effect May 1'2017.Having the same customer charge throughouttheyearisconsistentwithhowtheIntermountainGasincurscustomerrelatedcostsovertheyear.Costs mostcloselytiedtospecificcustomersarethecapitalcostsandexpensesofmetering,meter reading,billing,theserviceline,and customerservice.IntermountainGas asked for $10.00.Staff recommended $5.50 andtheCommissionapprovedtherecommendation.The low usage of terms on your billing indicates possibleusagebyapilotlight.This might by why you are seeing 3 to 4 therms of use over the last two billingperiods7inJuneandJulyof2016termusagewas4thermspermonth,I understand that intermountainGasdecidedtomakeitaflatfeeof5.50 year round.However,it does notexplain vihy the per therms andgdistributioncostchangedinthemonthswhentherehasbeennousageofgasANDwhenformanyyearsithasnotreflectedachangeintheperthermsanddistributioncosts.it should be the same when there isnousageofservicelikeithasbeeninprioryears
If a customer requestsdisconnection of service the account is officially closed.When the customer places
a request to reconnect a $14 "Account initiation Charge"is assessed to open a new account (accountnumberusedwillbethesameastheclosedoutaccount).If service is connected after hours the fee is$40.Any time a customervoluntarily stops service and then a request is made to establish service againan"Account Initiation Charge"is assessed.Please note that if the account is closed for longer than 10-days and a request is made to reconnect service the utility company will consider that person an applicantandnotacustomer.I have read the entire policy of Intermountaingas and that is not what it states.Ihighlightedinblueonmypreviousmessagewhatthepolicydefinesasan"initiation fee"and "Reconnectionfee"as approved by the Idaho Public Utilities Commissíon.Reconnection Fee:Areconnectionfeeisassessedwhenserviceisrestoredforacustomerafteranon-pay serviceinterruption.Account Initiation Fee $14 or $40:Each new account opened with Intermountain.I'll like to know howyoucameupwithsuchinformationbecauseitisabundantlyclearwhatthefeesare,furthermore,why is itthattheotherutilitiesinIdahohavenoproblemsdisponnectingunusedserviceandnötõ6argîngfeesforre<:onnectingservice for the same account/customer?afen't you the ones regulating the utííties7 how isthatfairacrosstheboardforallutilitiesandmoreimportantlyhowisthatprotectingthepublicinterest?I'massumingthatotherutlitiescansuetheIPUCforallowingIntermountaingastomakethechargesthatyoucameupwith.
If you are disconnectedfrom servicefor non-payment.andthen reconnected a "Reconnection Fee"of $22
is assessed and if outside of regularbusiness hours the charge is $40.00,and $50 on weekendsandCompanyholidays.
At this time IntermountainGas nor does any utility in Idaho offer rate assistance to Idaho low incomecustomers.El-Ada provides energy assistance grants to help with customer heating costs.The agency
can be reached at [phone].There is a misconception that all these "assistance agencies"such as
EIADA,St Vincent de Paul,SalvationArmy,Ada County Itidigent Services,etc will pay for everyonethat
Grnail -FW:Intermountain Gas,Raul Mendez,Page 5 of 10
walks thru their doors.Unfortunately,I called around and all of them haveno funding even if you do
qualify.they have limited funding thru the year,rely on volunteers,¾give partîcularpreferenceto elderly,
disabled or large families with children.It is imperative then to question why intermountaingas is being ,
allowed to mislead customers trying to charge fees that are not applicableand not accordingto policy
I will address the issue of your preferredmethod of communicationwith IntermountainGas (email)and why
the Company told you that you haveto call them to get an answers.You did not address the initial portion
of my message which raises questions as to why if you contact them thru the internal messaging on the
customer's account that the company responses can be later deleted.they instructed me to contact them
on their internal messaging but the responses were erased,later I was told on the phone that there was a ,
14 dollar for reconnectingthe fee.Lastly,they told me they would not respondto me vía email even
though it is one of the means availablefor customer's to contactthern.A supervisornamed Mary did not
return my last phonecall.so what do I do7 it is clear to me they are misleading customer's
Thank you for sharing your thoughts on disconnectionof services due to financial hardships,assistance
programs,and consistent utility statement fees.
Unfortunately,I'm not at all surprised to find out that the IdahoPublic Utilities Commission is now claiming
that IntermountainGas can charge bogus fees not in accordanceto what has been approvedby you.
while other utilities don't charge reconnectfees and you can disconnect serviceíf you choose to.The
State of Idaho has a nefarious history of violating the law and constitutional rights of the same people that
put food on your table and that allow you to have excellent benefits/retirement.Just take a look at this
links;
https://www.acluidaho.org/en/news/federal-coud-rules-against-idaho-department-health-and-welfare-
medicaid-class-action
https://www.acluidaho.org/en/news/idaho-supreme-court-rules-favor-aciu-public-defense-case
The common theme of course being how much the State of tdaho despises poor people.I'm not surprised
to see that you're allowing Intermountaingas to chargefraudulentfees for someone that want to
disconnect due to harship given that the IDHWwithdrew benefitsfrom disabled people or that poor people
cannot get proper legal representationin Criminal cases.
i'll just disconnect unused service next year during warm weather and if intermountaingas wants to charge
me a reconnect fee then l'Il sue them.
[Quoted text hidden]
Raul Mendez <[e-mail]>Mon,Aug 28,2017 at 11:04 PM
To:[e-mail]
[Quoted text hidden]
Curtis Thaden <[e-mail]>Thu,Aug 31,2017 at 2:50 PM
To:"[e-mail]"<[e-mail]>
Hi Raul,
Gmail -FW:Intermountain Gas,Raul Mendez,Page /01 10
the Commission approvedthe recommendation.The low usage of terms on your billing indicates possible
usage by a pilot light This might by why you are seeing 3 to 4 therms of use over the last two billing
periods?In June and July of 2016 term usage was 4 therms per month.I understandthat intermountain
Gas decided to make it a flat fee of 5.50 year round.However,it does not explain why the per therms and
distributioncost changedin the months when there has been no usage of gas AND when for many years it
has not reflected a change in the per therms and distribution costs.it should be the same when there is
no usage of service like it has been in prior years
[lf I understandyou correctly you are stating that you understandthe customercharge has been raised to
$5.50 year round but your billing dollar amount should be the same every month when there has been no
usage of service?
I reviewedyou usage history dating back to July 2014 and usage has been recordedevery month and
billed accordingly,I comparedthe past 3 months of billing (June,July August)to the same months in 2016
-see below.Though your fumace is not operating in the summer months Therm usagejs being recorded.
More than likely the recordedusage is fromthe pilotlight of the furnace and hot water heatér and gas is
being used to heat the water.Last year your billing for June,July,and August was $5.34 each month
because the recordedTherm usage was the same each month.This year the Thermusage has been
different each month for June,July,and August,therefore the billing amount each month will not be the
same.
June 2017 9 Therms -total gas charges $11.23
July 2017 3 Therms -total gas charges$7.41
August 2017 4 Terms -total gas charges$8.05
Note:the total gas charge each month is different because the recoded Therm usage was a
different amount each month.
June 2016 4 Therms--total gas charges $5.34
July 2016 4 Therms -total gas charges $5.34
August 2016 4 Therms --total gas charges $5.34
Note:the total gas charge each month was the same because the recorded Therm usage (4
Therms)was the same,
Further Review:
August 2016 billing total gas charge -$5.34,of that amount $2.50 is the customer charge.All charges
associated with 4 Therms of usage was billed out at $2.84
August 2017 billing total gas charges -$8.12,of that amount$5.50 is the customer charge.All charges
associated with 4 Therms of usage was billed out at $2.62
Please note the DistributionCost ($0.017187)is lower this summer than it was last summer ($0.196)]
In summary,the billing dollaramount for your recordedTherm usage this summer is lower than it was last
summer.Therm usage has varied month-to-monthwhich is the cause of a differentbilled amounteach
month.
If you believethere should be no recordedusage at your residenceduring the summer months then there
might be a gas leak and IntermountainGas should be contacted.
If a customer requests disconnectionof servicethe account is officially closed.When the customer places
a request to reconnect a $14 "Account initiation Charge"is assessed to open a new account (account
number used will be the same as the closed out account).If service is connected after hours the fee is
$40.Any time a customer voluntarilystops service and then a request is made to establish service again
an "Account initiation Charge"is assessed.Please note that if the account is closed for longer than 10-
days and a request is utade to reconnect service the utility company will consider that person an applicant
and not a customer I have read the entire policy of intermountaingas and that is not what it states.I
highlighted in blue on my previousmessage what the policy definesas an "initiation fee"and "Reconnectionfee"as approvedby the Idaho Public Utilities Commission.Reconnection Fee:Areconnectionfeeisassessedwhenserviceisrestoredforacustomerafteranon-pay service interruption.Account Initiation Fee $14 or $40:Each new account opened with Intermountain.I'll like to know howyoucameupwithsuchinformationbecauseitisabundantlyclearwhatthefeesare.furthermore,why is itthattheotherutilitiesinIdahohavenoproblemsdisconnectingunusedserviceandnotchargingfeesforre-connectingservice for the same account/customer7 aren't you the ones regulating the utlities?how isthatfairacrosstheboardforallutilitiesandmoreimportantlyhowisthatprotectingthepublicinterest?I'm
assuming that other utlities can sue the IPUC for allowing Intermountaingas to make the charges that youcameupwith.
(When an individualrequests servicefrom IntermountainGas the Companywill charge either a $14 or $40AccountInitiationfeedependingonthetimeofdayanddayoftheweekserviceisconnected.If an existingcustomerdecidestodisconnectservicetheCompanywilldisconnectservicewithoutcharge.If the sameindividualdecidestoreconnectserviceIntermountainGaswillagainchargeanAccountInitiationfee.Asanexample,if a customer requests disconnection of service in April and then requests reconnection ofserviceinOctoberIntermountainGaswillchargeanotherAccountInitiationFee,Furthermore once acustomerisdisconnectedfromserviceformorethan104aysdhe/she is no longer classified as a customerbutratheranapplicant.You asked how I came up with this information?TheAccount Initiation Fee is ,containedin IntermountainGas Company'stariff on file with the Commission.In the Company'sTariff the -
fee is called Account Initiation Charge.
9.4 An "Account Initiation Charge"in the amount of $14.00 during regular business hours and $40.00outsideofregularbusinesshourswillbeassessedoneachaccountopenedwiththeCompanyandwill be
billed with the first regular bill.This charge will not apply to landlord temporary service wherea landlord has
signed a ContinuousService Agreementor to code compliance inspections mandated by the Idaho Public
Utilities Commission.
Idaho Powercharges a fee anytime a request is made to establish service.If an existing customervoluntarilyrequestsdisconnectionfromserviceandthenasksforareconnectionatalaterdatetheCompanywillchargeaServiceEstablishmentChargeof$20.00.Suez Water does not charge a fee when
a request is made to establish service,only when a reconnectionis requested when service is terminated
for non-paymentor a request made to temporarilyturn service off due to a repair.
All the fees mentionedabove have been approved by the Idaho Public Utilities Commission and are valid
fees.In summary,anytime a request is made to establish service(IntermountainGas and Idaho Power),after service was voluntarily requested to be disconnected,a fee will be assessed to establish service.The
fee was approved by the Idaho Public Utilities Commission].
At this time IntermountainGas nor does any utility in Idahooffer rate assistance to Idaho low income
customers.El-Ada provides energy assistance grants to help with customer heating costs.The agency
can be reached at [phone].There is a misconception that all these "assistance agencies"such as
EIADA,St Vincent de Paul,SalvationArmy,Ada County Iridigent Services,etc will pay for everyonethat
walks thru their doors.Unfortunately,I called aroundand all of them have no funding even if you do
qualify.they have limited funding thru the year,rely on volunteers,or give particular preferenceto elderly,
disabled or large families with children.It is imperativethen to question why Intermountain gas is being
allowed to mislead customers trying to charge fees that are not applicableand not according to policy
[You are correct.Not everyonewho applies for energy assistance will get approvedand there are times
during the year when the agencies funding has been depleted.The fees that Intermountain Gas
communicatedto you are validand were approved by the Commission]
I will addressthe issue of your preferredmethod of communicationwith IntermountainGas (email)and why
the Company told you that you have to call them to get an answers.You did not address the initial portion
of my message which raises questions as to why if you contact them thru the internal messaging on the
customer's account that the company responses can be later deleted.they instructed me to contact them
httos://mail.coogle.com/mail/u/0?ik=a57046c8d9&view-ot&search=all&oermthid=thread-...12/5/2018
From:Raul Mendez [mailto:[e-mail]]Sent:Saturday,September09,2017 7:40 PM
(Quoted text hidden]
[Quoted text hidden]
Raul Mendez <[e-mail]>Tue,Sep 12,2017 at 5:16 PMTo:Customer Service IGC <[e-mail]>
Hi,
This is what works best for me and the Commission assured me there was no reason why I couldcommunicateviaemailsincethisisoneofthemanyoptionsyouhaveavailableforcustomers.Here is the
thing:
it was 4 therms last summer as well when there was no qas usage.However,it was $2.06and $0.78 lastyearwhenthecustomerchargewas$2.50.It is still 4 therms this summer but because the customerchargeisnow$5.50,it appears that IG has lowered the same 4 therms to $186 and $0.69.It was 5.34
last year now is 8.05.
Does that make sense?I don't use gas during warm weather including no usage of hot water.It appearsobviousthatthefeesarebeingmanipulated.It wouldn't make much differenceto people who have adecentincomebutforthoseofuswhoarestrugglingeverypennycounts.I was told that all theseassistanceagenciesgetfederalfundsforheatingfromNovembertoMarchandl'Il see what kind of help I
can get.the IPUC regulates nothing and they sleep with the utility companies.What a bizarre world weliveinwherepeopleslaveawaytosupportthecorruptionofpublicofficials.Just take a look at these:
https://www.cheatsheet.com/business/10-states-with-the-most-minimum-wage-workers.htmll?a=viewall
http://boisestatepublicradio.org/topiclbottom-rung-living-low-wages-idaho
http://www.idahopress.com/news/statelshame-idaho-ranks-poorly-in-many-key-areaslarticle_69e564a4-3f3f-11e1-a84c-0019bb2963f4.html
Earningscan affect everythingas shown on poorly Idaho ranks top or near top on many areas.PublicofficialsareresponsibleforthisbutitshouldnotbeasurprisegiventhenefarioushistoryoftheStateofIdahoasshownhere:
https://www.acluidaho.org/en/news/federal-coud-rules-against-idaho-department-health-and-welfare-medicaid-class-action
https://www.acluidaho.orglen/newslidaho-supreme-court-rules-favor-aclu-public-defense-case
It is not surprisingto see that the IPUC allows IG to charge bogus fees given how the above information
points to not only a disconnectwith the peopleof Idaho but how public officials despise poor peopleas awhole.
In short,I don't use gas during summer AT ALL,comparison betweenprior years and this stimmershow aconsistent4thermsbutsomehowthestatementsforthisyearendsupbeing3dollarsmore.I guess therereallyisn't a solution to it,is there?
Raul
(Quoted text hidden]
Raul Mendez <[e-mail]>Mon,Sep 18,2017 at 11:31 PMTo:CustomerService IGC <[e-mail]>
httos://mail.cooale.com/mail/u/0?ik=a57046eRr10&view=nt&mar h=anRm-mthir1=+¾-,1 lo lolom o
nnau -Im:acet «AAAAAAAuuu z fage 11 o1 11
Mary,
you did not respondto the last email on 9/12/2017.you requested the following:If you would like to speak
about your billing exactly we ask if you could please log into your online accountand use the contact us so
we could correspondsecurely on our side and when we reply it will come to you through email.
I tried to see:
Preferred Contact Me had i n
Your system does not allow me to contact you and I need to have a response to my issue as to why
Intermountain gas is manipulatingthe fees so that starting this summer l'm being charged 3 dollars more
for the same 4 therms that have billed on prior years.it might be difficult to see how charges are
manipulated during cold weatherwhen people use lot of gas.is this going to be fixed or not7 I should pay
exactly as it has been prior years and i'm not going to pay more even if I get some heating assistance
during winter.
I might have to do some research to see whose the Federalagency overseeingthe utlities maybe they are
more responsible than the IPUC.Otherwise,the difference betweenthis year and prior years would stay
forever on my account because i'm not paying it.
than you,
Raul
(Quoted text hidden]
//*1 1 I 'll //%f3't F /\A/.AftO '.._..10.......1.--110---------41 33-1....-]1 %/MI?%ftin
Gmail -Contact Inquiry age of 13
Good Morning,
I called customer service on 5/2 to disconnect the service over the summer.I spoke with Michelle who gave me confirmation Itumber 2738941026.I ,
requested to speak to a manager since she told me that there wouldbe a 14 dollar reconnect fee during winter,despilethefactthat itold her that Vm to
income and you have proof that ELAda has made a couple of big payments to avoldthe service being disconnected.the wholepoint of saving me 25 dollars
until cold weather Is to have the money whenI actually use gas and bills are much higher.In addition,this is what your policy is regarding reconnect fee:
la there a charge for reconnection?
A reconnection fee is assessed whenservice is restored for a customer after a non-pay service Interruption.This fee is $22 during the hours of 8:00
a.m.to 4:30 p.m.and 544 during the hours of 4:30 p.m.through 7:00 p.m.,Monday through Friday.A reconnection fee of $50 will be charged on
weekends or company holidays.
It is clear that a reconnect fee applies only whenthe service is reatored after nonpayment service Interruption.Thereisa 14 dollar initiation fee for new
accounts.however,my account has been open for 15years and this is just a temporary atop of service to save money.I have been disconnecting service
temporarily for other utilities as we11tosave money and they have not charged a reconnect fee.I wouldIlke to be able to work things out with Intemlountain
gas so that there is no reconnect fee contrary to your policy.I figure that maybe Michelle was mistaken.
Thankyou,
Raul
[oooted text ninden]
Customer Service IGC <[e-mail]>Frl,May 4,2018 at 11:36 AM
To:Raul Mendez<[e-mail]>
Good moming Raul,
Thank you for your emait Unfortunately,once your account is closed for 10 days your are no longera customer.So,the $14.00 Initiation fee for a new
account would apply whenyou start your service in the fall.
If fulther assistance is needed please feel free to email,or call Customer Service at 1-800-548-3679,Monday-Friday,7 AM to 7 PM.
Thank you,
Kat,Customer Support
Intermountain Gas Company
Phone:[phone],M-F,7am-7pm
08 BW
Sunewmaarsbekm
CaEbeforarondre.
From:Raul Mendez[mallto:[e-mail]]
Sent:Friday,May 04,2018 11:21 AM
To:Customer Service IGC<[e-mail]>
Subject:Re:Contact inquiry
(Quoted text hidden|
Raul Mendez<[e-mail]>Fri,May 4,2018 at 11:42 AM
To:Customer Service IGC <[e-mail]>
Hi,
Would you please send me the link to this particular Information?I could not find it in your policies.My concem is that none of the other utilities charge a
reconnect fee whena customer disconnects seasonally or due to hardship.Once you reconnect with other utilities,you still have the same existing information
on their system.
Thank you,
Raul
[Quoted text hidden)
LIIIluli -LUIILuct Illquiry rage J 01 13
Customer Service IGC <[e-mail]>Mon,May 7,2018 at 3:55 PM
To:Raul Mendez <[e-mail]>
Hello Raul,
We were unable to reach you by phone to discuss your concems with the account Initiation fee.We understand that that other utillties may have different fees
when it comes to stopping service,even for a few months We are also aware how important It Is to keep the costs low for those that wlli utillze the service.
A brief explanatlon of the account initiation fee is found at our website in the area for Frequently Asked Questions.A more detailed verslon can be found In
our tariffs at the Idaho Pubilc Utilities website http://www puc idaho.gov/fileroom/tariffigas/approved.html.
If you have any further questions regarding the fee,we are happy to speak with you to better asslst you.Please contact our oftlce at 800-548-3679,Monday
through Friday,7 AM to 7 PM.
Thank you,
Allison,Customer Support
Intermountain Gas Company
Phone:[phone],M-F,7am-7pm
Callbefalevourg
From:Raul Mendez[mailto:[e-mail]]
Sent:Friday,May 04,2016 11:42 AM
To:Customer Service IGC <[e-mail]>
Subject:Re:Contact Inquiry
fouoted text ruddeni
Raul Mendez <raulmendez2002ggmail.com>Sat,Nayn2,2018at3:03 PM
To:Customer Service IGC <[e-mail]>
I did not get the Ilnk on your website in regards to the 14 dollar initiation fee on existing accounts after disconnect.I did get a linkto the tariff for the IPUC.
Would you be so kind to point me directly to whereit specifically states that you can charge the 14 dollarinitiation fae on an already existing account?Here is
what i found on your website regarding fees:
Ourgoal Is to keep costs for service to our customers as low as possible.In order to do this we believe Individual customers should bear the cost of any special
handling they require Instead of having all customers pay for these services.The Idaho Public Utllities Commission authorizes intermountain to recover the
following costs:
Interest on Past Due Accounta:Amounts due for your prevlous month's gas bill,which remain
unpaid at the time of the next billing date,wlll be assessed interest at the rate of 1%per month
Participants in the Level Payment Program will be exempt from late payment interest charges.
Field Collection Fee $15:If a company representative must visit your home to collect a past due
payment,a 515 fee will be assessed.If gas service is discontinued,this charge does not apply (see
Reconnection Fee).
Reconnection Fee:A reconnection fee is assessed when servlce is restored for a customer after a
non-pay service Interruption.This fee is $22 during the hours of 6:00 a.m.to 4:30 p.m.and $44 during
the hours of 4:30 p.m.through 7:00 p.m.,Monday through Friday.A reconnection fee of $50 will be
charged on weekends or Company holidays.
Returned Payment Fee $20:This charge shall apply when a payment (check or electronic)is not
honored and retumed by the bank.
Account initiation Fee $14 or $40:Each new account opened with Intermountain 6 a.m.to 5 p.m.,
Monday through Friday,will be billed a $14 fee with the first regular bill.A $40 fee will be charged for
all accounts opened after 5 p.m.,Monday through Friday,weekends or holidays.
1....II...-:1 --.......1.,---/--11l.,IAO:1---C'7AA£-O..lAD..,L.,-..+9.es .ek---119,-a...w+L.A-+L.anA 1 /"7/10
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My account shows as being currently stopped.I have not being able to find anything in regards to an initiatton fee appfylity to an account after it has been
stopped for 10 days.It seems to me that this is just a case of greed on the ¢art of IG believing that you can mislead people.It la my understanding that legallyyoucannotleavepeoplewithoutgasduringwintereveniftheyarebehindonpayments.would you deny me staiting the service during winter due to the 14dollarsonanexistingaccount7Iwillpaythecurrentbalancewhichapparentlyyouhavenowchangeditfrom36.65 to 37.02 due to a customer charge for non-
service?
Raul
(Ouoted text hidden|
Customer Service IGC <[e-mail]>Mon,May 14,2018 at 12:57 PM
To:Raul Mendez<[e-mail]>
The link Is:https://www.intgas.com/retes-services/rates-tariffs This is under frequently asked questions.
Account initiation Fee $14 or $40:Each new account openedwith intertnountain 8 a.m.to 5 p.m.,Monday through Friday,will be billed a $14 fee
with the first regularbill.A $40 fee wlli be charged for all accounts opened after 5 p.m.,Monday through Friday,weekends or holidays.
If further assistance Is needed,please call Customer Service at 1-800-548-3679,Monday-Friday,7 AM to 7 PM.
Thankyou,
Daniela,Customer Support
Intermountain Gas Company
Phone:[phone],M-F,7am-7pm
Omri W
0 anewstiersbelomCSilbeforegoudig
From:Raul Mendez[mallto:[e-mail]]
Sent:Saturday,May 12,2018 3:04 PM
(Quoted text niddenj
[Quoted text Nddenj
Raul Mendez<[e-mail]>Fri,Mey38,2018 at 11:48 AM
To:Customer Service IGC <[e-mail]>
yes,I can read and I see that on the fees approved by the IPUC you can charge a 14 dollar initiation fee for a NEW ACCOUNT.My account has been
openedfor 15 years and it is currently stopped to save me money;look:
INTERMOUNTAIN orm rail-i-li-in
MANE A PAYMENT
Tids acouunt to en elms
o
you're trying to charge 14 dollata to restart the servloe on an existing account which is current andnot stopped due to flon-payment.to the contrary,you have
record that EIAda has made a couple of pledges to make payments on my account therefore the reason to save money for winterwhen the service Is used
and billing is much higher.so,whatif I the service was stopped and then transfer to another residence?you don't charge an initiation fee for transfera as far
as what the IPUC has approved.you don't charge a fee for your technician going to homes to change the meters,so why are you trying to charge a 14 dollar
foe just because the technician has to go to a customer's home to restatt service on an existing and current account?
han//mnil amanla no.w/,wn:1/2,/OO:1r-n<"IAAKnOAGP.,,:-,,,---+9,en.ak--119...--+L:A-+L.-,,A 1 lolon10
U111st11 -IU r CCb fligt 1 01 /3
M Gmail Raul Mendez <[e-mail]>
IG Fees
25 messages
Raul Mender raulmen 002@gmail com hu,Ju 7,2018 at 9 PM
To:[e-mail]
Hello Mr.Thaden,
I don't know if you remember me from last year about my complaint against Intermountain Gas charging 14 dollars initlation fee.Here is a
refresher and the last of my contacts with the company:
you're trying to charge 14 dollars to restart the service on an existing account which is current and not stopped due to non-payment.to the contrary,you
have record that EIAda has made a couple of pledges to make payments on my account therefore the reason to save money for winterwhen the service
is used and billing is much higher,so,what if I the service was stopped and then transfer to another residence?you don't charge an initiation fee for
transfers as far as what the IPUC has approved.you don't chargea fee for your technician going to homes to change the meters,so why are you trying
to charge a 14 dollar fee just because the technician has to go to a customer's home to restart service on an existing and current account7
you have not responded to my question In regards to whetheryou'il refuse to restart the service during winterwithout paying the initiation fee on an
existing account?it is my bellef that you cannot leave peoplewithout heating during winter.
Basically,you told me that the IPUC has approved such a fee but you did not provide me the link to the specifics of such approval nor Is it stated
anywhere on IG policies.The policies state that a 14 initiation fee applies for NEW ACCOUNTS.furthermore,I did contact the FTC regarding the
matter who advise me that 1)the state public utility commissions have a formal complaint procedure in place to address such matters 2)the
heating companies cannot leave customers without gas during certain portions of winter.
I could not find such formal complaint procedures on your site.I will have to look up the Administrative rules since most agencies do have some
kind of hearing with administrative judges whereby they issue rulings,which then can be appealed to the head of the agency,which then can be
appealed to the Idaho Supreme Court.How does your process works7
Can IG refuse to restart my service during winter without paying the 14 dollar initiation fee on an existing account?My account is current and I
have received some assistance with paying my bills.
It is currently disconnected to save no more than 25 dollars during summer.In addition IG does not charge customers a fee for going to their
homes to do maintenance such as changing meterslequipment,or charge a fee for transferring service to another place because such fees are not
approved by the IPUC.The (PUC has approved a 14 dollar Initiation fee on a new account but noton existing accounts that have been seasonally
disconnected to save people's money and the need to rely on others to pay the high costs of gas duringwinter months.
Sincerely,
Raul Mendez
Curtis Thaden <[e-mail]>Fri,Jun 8,2018 at 2:53 PM
To:"[e-mail]"<[e-mail]>
Hello Mr.Mender,
Thank you for the email.Yes,I rememberyou.
Below is the link to Intermountain Gas Company's approved tariff on file with the Idaho Public Utilities Commission.Contained in the approved tariff is Section
9 (Discontinuance and Reconnection of Service).Number 9.4 allows IntermountainGasto charge a fee of $14 or $49,whenevera customer requests service,
even if the requestorpreviously had an active account.If a customer requesttdiscotinection of service,service is disconnected and the account is closed.The
account is no longer activeand the former customer is no longer classified as a customer in summary,the fee is allowed to be charged regardless of having a
previous account or not.
IntermountainGas refuse to restart your service If your closed account has been paid in full.The payment of the "account initiation charge"g
requiredto paid priorto service being established,but rather the fee is added to your first billing.
http://www.puc.ldaho.gov/fileroom/tarifflgas/Intermountaingas.pdf
9.4 An "Account Initiation Charge"in the amount of $14.00 during regular business hours and $40.00 outside of regular business houm will be
assessed on each account opened with the Company and will be billed with the first regular bill.This charge will not apply to landlord temporary
service where a landlord has signed a Continuous Service Agreement or to code compliance inspections mandated by the Idaho Public Utilities
Commission.
Sincerely,
Curtis Thaden
Idaho Public UtilitiesCommission
208-334-0322
From:Raul Mendez [mailto:[e-mail]]
Sent:Thursday,June 7,2018 1:29 PM
To:Curtis Thaden <[e-mail]>
Subject:IG Fees
[Quoted text Ndden)
Raul Mendez <[e-mail]>Thus Jun 14,2018 at 8:26 PM
To:Curtis Thaden <[e-mail]>
Hi,
This long document is hard to read.Would you be able to specifically scan the portion where it says that?all I know is what Intermountain Gas has
under the fees approved by the IPUC.the fees specifically state that the 'initiation'fee is for NEW ACCOUNTS.I have not being able to find
anywhere where it specifically states that an existing account becomes a new accountgfier it has been closedfor more than 10 days.I'm confused
so you're saying IG can charge an initiation fee on an existing account?but you don't approve them to charge a fee for transfers to a new
residence?so,does the IPUC have due process procedure whereby people can have thelr cases heard by a hearing officer just as the other
agencies do?i find it hard to believe that this is it?Just contact you to be told the fees are approved by the IPUCT what if people want to dispute
it?
Sincerely,
Raul
[Quoted text hidden)
Curtis Thaden <[e-mail]>Tue,Jun 19,2018 at 2:13 PM
To:"[e-mail]"<[e-mail]>
Hi Raul,
Thank you for the email reply.I have attached a scan of the section in the Intermountain Gas Company tariff that you requested concerning
"account Initiationcharge."
I believe that the use of the word "existing"is causing some confusion?Existing implies that something is current.When a customer closes out
their account,the account is no longer an existing account and that person is no longer a customer of the othity.If he/she,at a later date,
decidesto become a customer again,and requests service be established,an account is opened,and a service technician is dispatched to the
residence.An "account initiation charge"is assessed anytime service is established.The wording in Section 9.4 of Intermountain Gas Company'
tariff states that the charge "will be assessed on each account opened with the Company and will be billed with the first regular bill."Only active
accounts are existing accounts,
t.astly,a customer is defined by the Utility Customer Relation Rules as someone who is receiving service from a utility;or haneceived service
within the past ten (10)calendar days prior to termination by the utility;or has resumed responsibility for payment of service provided to
another or others.
Does my explanation help with understanding why an account initiation charge will be assessed when you request service in the fall,and that a
closed account is not an existing account?Let me know and we can proceed from there.
Sincerely,
httos://mail.coogle.com/mail/u/0?ik=a57046c8d9&view-ot&search=all&oermthid-thread-...12/7/2018
As previously stated,if a customer decides to voluntarily disconnect service and then decides to reconnect service again an "account initiation
charge"is assessed.If an individual is no longer receiving Service from Intermountain Gas (not using the company's services)he/she is no longer
a customer of the utility and the account is no longer an active account.When service is requested again an account is opened and an order is
placed to reconnect service.Often,intermountain Gas will issue the same account number as previously issued as a courtesy to a customer for
the purpose of bill pay and automatic withdrawal from the individuals banking/che¢king account.
On a side note,Idaho Power will also chargean individual a fee for reconnecting service if he/she voluntary asked for service to be
disconnected.As an example,let's say a customer requests service be disconnected because they will be out-of town for a few months.When
the customer returns and requests service be reconnected Idaho Power will chargethe customer a fee too.
The Commission does not have an administrative hearing officer.When a complaint is filed against a utility Company,the Commission forwards
the complaint to the Utility in an attempt to resolve the issue.An individual has the option of requesting what is called a formal complaint,but
that can only be done after an informal complaint process is utilized.
Sincerely,
Curtis
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
From:Raul Mendez [mailto:[e-mail]]
Sent:Friday,July 20,2018 4:34 PM
[Quoted text hidden)
[Quoted text hidden)
82K
Raul Mendez <[e-mail]>Thu,Aug 2,2018 at 7:38 PM
To:Curtis Thaden <[e-mail]>
Hi,
I don't mean to sound like a problematlc customer/person.I'm only disputing the "initiation'fee because my financial situation it's not great as the
ELAda contributions prove;therefore the reason to save money.I wouldn't mind paying it even when it's clear that the attached policy states that
such a fee applies only after the utility company has disconnected the service to customers because it was their decision.See this:has received
service within the past ten (10)calendar days prior to termination by the utility Usually because issues with non-payment.
Ym guessing then that a formal complaint can be established once the company charges the 14 dollars?
are these the Applicable rules?https://adminrules.idaho.gov/rules/current/31/310101.pdfhttps://adminrules.idaho.govirules/current/31/312101.pdf
There is bunch of stuff:
httos://mail.google.com/mail/u/0?ik=a57046c8d9&view-ot&search=all&oermthid=thread-...12/7/2018
DII1t111 -10 1 I sigC .)U1 I J
Pubik Utilities Commission ou it comnasion
y Lontact
Phone:(208)3)¾300
agency website
IDAPA 31 Administrative Rules ."?
What else applies to a formal complaint?there is actually two IDAPA 31.21.01,the one on the website is 25 pages long and the one you attach is
49 pages but it doesn't say when or if it's updated.
Thank you,
Raul
Quoted texthtdden]
R Men raulmemiez2002@grnail com>Aug ,018 at 7:42 PM
To:Curtis Thaden <[e-mail]>
Intermountain Gas will issue the same account number as previously issued as a courtesy to a customer for the purpose of bill pay and automatic
withdrawal from the individuals banking/checking account.
So,any reasonable person would infer that it was an existing customer with an existing agogunt with an existing billing information that is having
the service restarted?In other words it is not a new applicant for service.
Raul
(Quoted text hidden]
Curtis Thaden <[e-mail]>Frl,Aug 3,2018 at 3:52 PM
To:Raul Mendez <[e-mail]>
Hi Raul,
I do not perceive you as being problematic.I work with many of the CAP agencies and know firsthand from my position at the Commission that
many people are struggling to pay their utility bills.
You are correct,the link below is the Rules of Procedure for the Idaho Public Utilities Commission.When you imitate service again.
Intermountain Gas will charge you the $14 Initiation fee.The fee will appear on your first billing.If you still object to the fee you can file an
informal complaint by calling the IPUC front desk at 208-334-0300 or online at http://www.puc.idaho.gov/forms/consumerassistance.aspx
If the issue is still unresolved you can then elect to file a formal complaint by following the requirements (Rule 54)contained in the Rules of
a wt Procedure for the Idaho Public Utilities Commission.The formal complaint must be in writing,state the facts and specify how you would like the
tiss'problem to be resolved.Unlike an informal complaint,which is handled by the commission's Staff,the Commissioners must consider a formal
complaint.The Commissioners will decide whether it is appropriate to accept the formal complaint.If it is accepted,a formal legal proceeding
will be started,if the Commission does not accept the formal complaint,then nothing further will be done.
L+~.//--Il annala nam/maillo/O941,=a«"1AAAnfAO£rview=ntRromarch=allkrnarmthirl=thrmarL 19/'7/9(312
-«-2e 2 =raget
If you decide to file a formal complaint,you are required to submit to the Commission,in writing,the following information:
The utility or person the complaint is against
Fully state the facts constituting the acts or omissions of the utility or person agalnst whom the complaint is filed and the dates when the actsoromissionsoccurred.
Refer to the specliic provision of statute,rule,order,notice,tariff or other controlling law that the utility or person has violated.
State what action or outcome should be taken to resolve the complaint.
The address to send the formal complaint to the Commission is:
Idaho Public Utilities Commission
PO Box 83720
Boise,ID 83720-0074
Thecustomer definition specific to "Has received service within the past (10)calendar days prior to termination by the utility."Termination by
the utility refers to any condition that brought about the termination of service which includes customer requests.
Lastly,one thing to consider.Even though the $14 service charge will be assessed,you will still have a net savings for the timeframe of when
service was disconnected.
Sincerely,
Curtis
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
httnc//mail ananlo enm/mailln/O911r=nO70McRrlORrsriasur=nt2re44,·ch=o112,sar+L A-+LeanA 1 /9/1/310
mail -IG Fees Page 7 of 73
From:Raul Mendez [mailto:raulmendez2002@gmaitcom]
Sent:Thursday,August 2,2018 7:39 PM
[QuotedtextNudenj
[Quotedtext Ndden]
Raul Mendez <[e-mail]>W 18 atÃ44 PM
To:Cudis Thaden <Curtis,[e-mail]>
1 work with many of the CAP agencies and know firsthand from my position at the Commission that many people are struggling to pay their utility
bills.
Which agencies have you worked with7 what kind of work does the IPUC do with such agencies7 I can tell you right now from pemonal
experience and from accounts by others that it is extremely difficult to get "assistance"from these agencies because they always tell people that
they do not have funds no matter what time of the year you ask.If you call 211 with IDHWthen they seem to believe that by giving you a list with
numbers from these agencies that somehow they will provide people with help.
I know that these are federal funds given to the IDHWwho then apparently hands out the money to the 'agencles'but somehow they never have
money to help out people7 has anybody In the State of Idaho ever bothered to do an audit on such agencies7 because it seems rather strange
that they alway6 tell people they don't have funds but somehow they keep expanding with different locations and paid staff.They might get
donations and additional funding from elsewhere to support their organizations,but that only helps to further scrutinize why they never seem to
have help for utility assistance.EIAda is the only agency that I know that at least they pay a utility bill once a year.Ada County Indigent Services
do pay your utilities bill but they ask people to repay the county later on.......see,they get money twice from the IDHW and from the people repaying
the county for the utility assistance,do you see something wrong with that?it is federal money given to the county preclsely to assist people!
So,the IPUC knows that many people are struggling to pay their utility bills but somehow are allowing the utility companies to charge fees for which
they are not entitled and not previously approved by the IPUC although it appears that you're now twisting the meaning of the policles to favor the
utility company.
If you still object to the fee you can file an informal complaint by calling the IPUC front desk at 208-334-0300 or online
athttp://www.puc.idaho.gov/forms/consumerassistance.aspx
I thought that this informal going back and forth email conversation was an informal complaint which haslit will obviously not resolve anything.
If the issue is still unresolved you can then elect to file a formal complaint by following the requirements (Rule 54)contained in the Rules of
Procedure for the Idaho Public Utilities Commission........If the Commission does not accept the formal complaint,then nothing further will be
done.
There is no rule 54 under the idaho administrative rules for the IPUC.There are
these:https://adminrules.idaho.gov/rules/current/31/310101.pdf.https://adminrules.idaho.gov/rules/current/31/312101.pdf
Which make mention to a rule 54 but none exist.what are the reasons for which the cornmission does not accept the formal complaint?and in
the process deny people adequate procedural due process protections provided by the 95 cpnstitution?I'm assuming such denial will state that
it can be appealed to the Idaho Supreme court?see:https://www.isc.idaho.gov/iar14
termination by the utility refers to any condition that brought about the termination of service which includes customer requests.
Lastly,one thing to consider.Even though the $14 service charge will be assessed,you will still have a net savings for the timeframe of when
service was disconnected
I could find nothing on the rules regarding to "ggy condition that brought about the termination of service which includes customer requests".
the key being termination by customer therefore a 14 dollar initiationfee is charged.There is most certainly no such specific definition on IG
website.In fact,they initially told me it was a reconnection fee,then they changed their story to an initiation fee.
How much do you think that I'll be saving myself after the 14 charge?no more than 12 dollars and how much do you think people pay monthly
during winter for gas?If you know firsthand how much people are struggling to pay their bill then you would know that people are struggling
because of the high fees during cold season therefore the reasonto save money now when fees are low for later on.
I guess that l'Il be filing the Informal complaint which would then become a formal complaint since it appearsthe informal proceedings solve
nothing.
Raul
a
jouoted textnoen)
rage um
From:Raul Mendez (mailto:[e-mail]]
Sent:Friday,September 21,2018 1:21 PM
(Quoted text hidden)
(Quoted text hidden]
(Quoted text hidden]
[Quoted text hiddenj
(Quoted text hidden|
(Quoted text hidden)
[Quoted text hidden)
[Quoted text hidden]
[Quoted text hidden]
What else applies to a formal complaint?there is actually two IDAPA 31.21.01.the one on the website is 25 pages long and the one youattachIs49pagesbutitdoesn't say when or if it's updated.
Thank you,
Raul
[Quoted text hidden]
Raul Mendez <[e-mail]>Tue,Oct 9,2018 at 3:28 PMTo:Curtis Thaden <[e-mail]>
so,I received the statement for this month which is due on 10/22/2016.it is my understanding that the 14 dollar Initiation fee being disputed doesnothavetobepaidpendingtheoutcomeoftheformalcomplaintthereforenointerestsshouldbechargedtothe14dollars.It will take me some
time to prepare the formal complaint since such complaint might end up for review in front of the Idaho Supreme Court,I haven't had the chance toreadtheentirerulesbutnonnallyIGhastogivethelrsideornot7doyouordoIhavetonotifythemthatl¶be filing a formal complaint disputingthe14dollars7
Raul Mendez
[Quoted text hidden)
Curtis Thaden <[e-mail]>Thu,Oct 18,2018 at 3:56 PM
To:Raul Mendez <[e-mail]>
Hi Raul,
if you only pay your monthly usage amount in full and not the $14.00,the payment will apply to any past due amount first,therefore you will
never be up for a disconnection.Your account will always show $14 past balance plus a 1%late fee added each month (14 cents the first
month).In summary,as long as you pay for your usage you will not receive a disconnection notice;therefore you can take as long or as much
time as you want to file a formal complaint.
If you file a formal complaint and the Commissioners accept the complaint,Intermountain Gas will respond to the Commission.
Sincerely,
httne//mail onnele enm/mailln/0911r=as70McMO&view=nthemoreh=o11An4emthirl--+hroo,1 lonnut o
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Raul Mendez <[e-mail]>Sat,Nov 3,2010 at 2:08 PM
To:Customer Service IGC <[e-mail]>
I have been Informed by ELAda that a pledge for 123 dollars would appear on my IG account sometime in the middle of November.I received the latest
statement showlng .14 cents Interest on the disputed 14 dollar Initiation fee.Please do not utlllze the 123 to pay the disputed charges as I'm still working on
how to put togetherthe formal complaint in front of the IPUC commissioners which if they refuse will be appealed to the Idaho Supreme Court.I will reiterate
ageln do not use the 123 dollars from ELAda to pay the 14 plust interest.
Thankyou,
Raul Mendez
tavotedtext meden)
Customer Service IGC <[e-mail]>Tue,Nov6,2018 at4:47 PM
To:Raul Mendez<[e-mail]>
Good Aftemoon Raul,
Thank you for your correspondence.Unfortunately,when a payment is received in our office,no matter the source,it appiles towardthe most dellnquent
portion of the bill first.Our system does not allow for us to make exceptions and disregardportions of the balance when crediting an account.
If the LlHEAP pledgeof $123.00 Is received In our office,it will pay the entire balance.It will most Ilkely result In a credit on the account that will be applied
toward future charges as weit
The $14.00 account initiation fee as well as the Interest on the past due balance is allowed,and even mandated,by our Tariff that is approved by the idaho
Public Utilities Commission.
Please click the Ilnks below to reference the applicable rules:
http://puc.idaho.gov/laws/Utility%20Customer%20Relations%2ORules_2010.pdf
202.DUE DATE OF BILLS-DELINQUENTBILLS (Rule 202).
01.Ordinary Due Date.The utility may require that bills for service be paid within a specified time alter the billing date.The minimum
specified time after the billing date is fifteen (15)days (or twelve (12)days after mailing or delivery,if bills are mailed or delivered more
than three (3)days after the billing date.)Upon the expiration of this time without payment,the bill may be considered delinquent.(7-1-93)
http //puc.idaho.gov/fileroom/tarifflgas/Intermountalngas.pdf
9,4 An "Account initiation Charge"in the amount of $14.00 during regular business
hours and $40.00 outside of regularbusiness hours will be assessed on each
account opened with the Company and will be bllied with the first regular bill.
This charge will not apply to landlord temporary service where a landlord has
signed a Continuous Service Agreementor to code compilance Inspections
mandated by the Idaho Public Ut|Ilties Commission
4 3 AII billings renderedshall be net and each monthly bill shall be due and payable
within 15 days from the date of rendition,except as provided for in the Idaho
Public Ut|Ilties Commission's ("lPUC")Utility Customer Relations Rules.When
the customer account is participating in the electronic transfer of funds,the
bitilngs shall be due and payable within 11 days from the date of rendition.
Smail -IG Fees Page 13 of 73
Curtis
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
From:Raul Mendez [mailto:[e-mail]]
Sent:Tuesday,October 9,2018 3:28 PM
[Quoted text hidden)
[Quoted text hídden)
Raul Mendez <[e-mail]>Thu,Oct25,2018 at 4:31 PM
To:Curtis Thaden <[e-mail]>
Ok.My next question then is if I prevall on the appeal of the 14 dollar initiation fee then the 14 dollar plus Interest will be erased from my account?
plus I will reguest IG from charging improper fees in the future to customers.Does the IPUC regulates water,heating,and electricity?I see that
the Idaho Supreme court website has a place for court help in which they mention that you do (see link).In addition,it appears that according to
such link they have the following infomistion regarding deposit/fee prior to starting service:
My utility charged me a deposit before they tumed on my service.Can they do that?Usually,no.However,a utility may charge a deposit when
they tum on your service if you had your service terminated for nonpayment at previous address
So,it seerns Ilke the IG website Is accurate in that they can charge a fee only after non-payment.In addition,don't the rules are the same for all
three utilities?
Sincerely,
Raul
https://courtselfhelp.ldaho.govlbrochures/H-7.pdf
[QuotedtextNdden]
Curtis Thaden <[e-mail],gov>Tue,Nov 6,2018 at 1:14 PM
To:Raul Mendez <[e-mail]>
Hi Raul,
If the Commissioners were to rule in your favor I am certain that Intermountain Gas would be ordered to remove the $14fee and interest
charges from your account.
The Commission regulates investor-owned or privately owned utilities that provide gas,water,electricity or some telephone services for profit.
We do not regulate services provided by Co-Ops'or municipalities.The UCRR (Utility Customer Relation Rules)apply to electric,gas and water
utilities.The TCRR (Telephone Customer Relation Rules pertain to telephone companies.
Keep in mind that anytime a customer cancels service and then requests service to be reconnected,intermountain Gas will charge the $14 fee.
Idaho Power will do the same though the fee is $20.This is allowed per the each CompanyTariff on file with the Commission and is not in
violation of any rule.Also,keep in mind that both Intermountain Gas and idaho I½wer incur costs when having to reconnectservice and those
costs are not recovered in rates.
Curtis
ma11-10Fees ragezioli3
i do hope your situation improves.
As previously discussed,in review of the IJtility Customer Relations Rules a "customer"is classified as someone who is receiving service from a
utility.When a customer requests service to be disconnected,the individual is no longer receiving service and therefore is no longer a customer
of the utility.The account is closed out and a final billing is generated;therefore the individualis no longer a customer of the utility.Whenyou
called IntermountainGas to start service again an account was opened;often the Company wll!Issue the same account number as previously
used for a customer's donvenience for electronic payment purposes.Intermórmtaln Gas asses$ei a icâúht fatlân fe "when a request
for service to be established is requested.For serviced to established anaccount has to be openect in review of the Coropany's tariff,under
Section 9.4,the wording states *on eachaccount opened",not new äccount.
Suez Water does not charge an account initiation or service establishment charge.Each utility has its own set of guldelines,business practices,
and rate design so policy will very from utilityto utility.
Though I understand your position,I do not believe the Commission will waive a fee that has previously been approved by the commission,but
you can certainly file a formal complaint if that is what you chooseto do.
Curtis Thaden
Idaho Public UtilitiesCommission
208-334-0322
From:Raul Mendez [mallto:[e-mail]]
Sent:Thursday,November 8,2018 3:07 PM
To:Curtis Thaden <[e-mail].g v>
Subject:Re:IG Fees
Curtis,
It might sound redundant but what the policy says is that an "IÑitiation fee"ap 's for new accounts.A reconnect fee applies when the utility
company disconnects service usually for non-payment.There is usually a associated with the utility sending a tech to reconnect service for
reasons such as non-payment and fraud.there is no tech fee associated h sending someone to tum on the service after a seasonal shut off.
Basically,the 14 dollars charge that is in dispute is for sending someon turn on the service on an existing account.It's just that they are not
saying that it is a fee connected with sending someone to turn it on Iny ad they claim it is an initiation fee on an new account.
What about Suez?I was told that a lot of people requests seasÓnal shk offs during winter if they are away from home to avoid frozen pipes.they
don't charge an initiation fee on existing accounts.aren't thekules the s e?It makes no sense to charge Initiation fees on existing accounts and
the only reason people in my position temporarily shut off service is to sa money since you already know that public utility assistance is almost
non-existent in Idaho.Basically,it appeara that the IPUC position is that pie in Idaho cannot shut off their services because it looses money to
the utility companies7 I hope my situation will improvejíext year but I still b leve It's worth to dispute the charge since taken in the context of how
much they are charging for initiation fees to other pepple,then you realize thål they are making a lot of money on the questionable practice of
charging 14 dollars on exlsting accounts,I'm still doing research so it might b a while because I want to give myself the best chance in case it
ends up being appealed to the Idaho Supreme Cpúrt.
Sincerely,
Raul
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Does Intermountain Gas charge any special handling fees?
Our goal is to keep costs for service to our customers as low as possib!e in order to do this we believe individual
customers should bear the cost of any special handling they requireinstead of having all customers pay for
these services.The idahoPublic Utilties Commission authorizes Intermountain to recover the following costs:
Interest on Past Due Accounts:Amounts due for your previous month's gas bill,which remain unpa:d at
the time of the next billing date.will be assessed interest a:the rate oil%per month.Participants in the
Level Payment Programwill be exempt from fate payment interest charges.
Field Collection Fee $15:if a company representative must visit your home to collect a past duepayment,a
515 fee wilt be assessed.if gas service is discontinued.this charge does not apply (see Reconnection Fee).
Reconnection Fee:A reconnection fee is assessed when service is restored for a customer after a non-pay
service interruption.This fee is $22 during the hours of 8:00 a.m.to 4:30 p.rrt and $44 during the hours of
4:30 p.m through 700 p.m,,Monday througn Friaay.A reconnection fee of 550 will be charged on weekends
or Company haldays
Returned Payment Fee $20:This charge shall apply when a payment (check or electronic)is not honored
and returned by the bank
Account initiation Fee $14or $40:Each new account opened whh mtermountain 8 a m.to 5 p.m..Monday
through Fridäy,will be billed a 514 fee with the first requiar b;D.A $40 fee will be chargedfor al accounts
opened after 5 p.rn.Monday through Fúday.weekendsor holidays.
O How does the Level Pay program work?
O How does the AutoPay program work?
O How can 1 switch to paperless billing statements?
O Do you have a third-party notification program7
O Where can I get more information about energy assistance7
Typeheretosearc $Cþ ri
IDAHO PUBLIC UTILITIES COMMISSIONI.P.U.C.Gas Tad Approved EffectiveSEl
t
RAevised
Sheet No.8 May 19,2014 May 26,2014JeanD.Jewell SecretaryL*y Intermountain Gas Company
9.DISCONTINUANCEAND RECONNECTIONOF SERVICE
9.1 When a customer desires to discontinue service he shall give notice to theCompanyatleasttwobusinessdaysinadvanceandshallberesponsibleforallgasconsumedforthetwodaysafterdateofsuchnotice.
9.2 The Company may discontinue service for any of the reasons set forth in theIPUC's Utility Customer Relations Rules.Service cannot be disconnected onlegalholidaysrecognizedbythestateofIdahooranydayswheretheCompanyisnotopenforbusiness.
9.3 Whenever service has been discontinued by the Company for any reasonspecifiedintheIPUC's Utility Customer Relations Rules,a charge to recoverthereconnectionshallbecollectedbytheCompanybeforeserviceisrestored.Service shall be reconnected as soon as possible,but no later than twenty-four(24)hours after the customer has made satisfactory payment arrangementswiththeCompany.The charge for reconnection shall be:
$22.00,provided satisfactory arrangements for payment of all proper chargeshavebeenmadeduringthehoursof8:00 a.m.through 4:30 p.m.MondaythroughFrlday,except Company holldays;or
$44.00 if such arrangementa are made during the hours of 4:30 p.m.through7:00 p.m.Monday through Friday,except Company holidays.
If such arrangements are made during hours other than the above,thereconnectionshallbecompletedonthefollowingdayexceptformedicalemergenciesorwhereacustomerhasbeendisconnectedinerror.AreconnectioncompletedonaweekendorCompanyholldaywillbecharged$50.00.
Reconnections required for medical emergencies or where a customer hasbeendisconnectedinerrorwillbecompletedthesameday,including Companyholldaysandweekends.
9.4 An "Account initiation Charge"In the amount of $14.00 during regularbusinesshoursand$40.00 outside of regular business hours will be assessed on eachaccountopenedwiththeCompanyandwillbebilledwiththefirstregularbill.This charge will not apply to landlord temporary service where a landlord hassignedaContinuousServiceAgreementortocodecomplianceinspectionsmandatedbytheIdahoPublicUtilitiesCommission.
Issued by:Intermountain Gas CompanyBy:Michael P.McGrath Title:Director-Regulatory AffairsEffective:May 26,2014
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te
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my
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me
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c
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fo
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th
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p
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t
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.
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U
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T
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M
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M
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]
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t
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D
D
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]
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C
C
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#]
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l
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f
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e
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fo
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of
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·
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ATTACHMENT B
IDAHO PUBLIC UTILITIES COMMISSIONI.P.U.C.Gas Tariff Approved EffectiveSectionAMay19,2014 May 26,2014EighthRevisedSheetNo.6 Jean D.Jewell SecretaryuigIntermountainGasCompany
9.DISCONTINUANCE AND RECONNECTION OF SERVICE
9.1 When a customer desires to discontinue service he shall give notice to the
Company at least two business days in advance and shall be responsible for all
gas consumed for the two days after date of such notice.
9.2 The Company may discontinue service for any of the reasons set forth in the
IPUC's Utility Customer Relations Rules.Service cannot be disconnected on
legal holidays recognized by the state of Idaho or any days where the Company
is not open for business.
9.3 Whenever service has been discontinued by the Company for any reason
specified in the IPUC's Utility Customer Relations Rules,a charge to recover
the reconnection shall be collected by the Company before service is restored.
Service shall be reconnected as soon as possible,but no later than twenty-four
(24)hours after the customer has made satisfactory payment arrangements
with the Company.The charge for reconnection shall be:
$22.00,provided satisfactory arrangements for payment of all proper charges
have been made during the hours of 8:00 a.m.through 4:30 p.m.Monday
through Friday,except Company holidays;or
$44.00 if such arrangements are made during the hours of 4:30 p.m.through
7:00 p.m.Monday through Friday,except Company holidays.
If such arrangements are made during hours other than the above,the
reconnection shall be completed on the following day except for medical
emergencies or where a customer has been disconnected in error.A
reconnection completed on a weekend or Company holiday will be charged
$50.00.
Reconnections required for medical emergencies or where a customer has
been disconnected in error will be completed the same day,including Company
holidays and weekends.
9.4 An "Account Initiation Charge"in the amount of $14.00 during regular business
hours and $40.00 outside of regular business hours will be assessed on each
account opened with the Company and will be billed with the first regular bill.
This charge will not apply to landlord temporary service where a landlord has
signed a Continuous Service Agreement or to code compliance inspections
mandated by the Idaho Public Utilities Commission.
Issued by:InÍGrmOuntain Gas Company
By:Michael P.McGrath Title:Director -RegulatoryAffairs
Effective:May 26,2014