Featherston_dh.doc

September 1, 1999

Daniel P. Featherston
Attorney at Law
PO Box 1820
Bonners Ferry, ID 83805

Re: Gas Inspections

Dear Mr. Featherston:

Pursuant to our telephone conversation yesterday, I have enclosed for your review the Idaho Public Utilities Commission’s Safety and Accident Reporting Rules for Public Utilities, IDAPA 31.11.01.000 et seq. As I mentioned, natural gas utilities are subject to safety regulations and rules issued by the federal Office of Pipeline Safety (USDOT) and the Commission. The Commission’s Rule 201 lists the federal safety regulations regarding natural gas systems. The federal regulations pertain to systems on the utility’s side of the meter. Pursuant to Rules 202 and 203, this Commission has also adopted applicable provisions of the National Fuel Gas Code and the Uniform Mechanical Code. IDAPA 31.11.01.202 and 203. These rules adopt safety code provisions usually applicable to the customer’s side of the meter.

Although I have not discussed your inquiry with Avista, I did ask representatives of our southern Idaho natural gas utility (Intermountain Gas) about the construction inspection issue. Company representatives advised me that Idaho Code requires that natural gas companies have franchise agreements with municipalities they serve. A provision in their municipality franchise agreements (possibly similar to the one you mentioned to me) provides that the utility performs the inspections for permitting purposes. Your discussions with Avista may reveal similar procedures and mechanisms for accomplishing this function.

I hope you find this information helpful. If I can provide further information, please contact me at [phone].

Sincerely,

Donald L. Howell, II
Deputy Attorney General

vld/L:featherston_dh

Enclosures

cc: Randy Lobb, Engineering
Dave Schunke, Utilities
Daniel P. Featherston
September 1, 1999
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