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HomeMy WebLinkAbout2000121528578.docBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF INTERMOUNTAIN GAS COMPANY FOR AUTHORITY TO INCREASE ITS RATES FOR SERVICE ) ) ) ) ) ) CASE NO. INT-G-00-2 ORDER NO.  28578 On October 27, 2000, Intermountain Gas Company filed an Application requesting that the Commission authorize new rates that would increase the Company’s annual revenues by approximately $35.8 million (27%). Intermountain Gas supplies natural gas to approximately 200,000 customers in southern Idaho. On November 20, 21, 28, and December 4, 2000, the Commission convened public workshops and hearings in Boise, Caldwell, Twin Falls, Pocatello and Rexburg. After reviewing the public comments, the comments of the parties, and the record in this case, the Commission partially grants and partially denies the Application as set out in greater detail below. BACKGROUND A. The Application Wholesale prices for natural gas have risen dramatically over the last ten (10) months, resulting in higher natural gas costs for gas utilities nationally and in Idaho. Between 1990 and 1999, Intermountain Gas residential customers paid between $0.20 and $0.27 per therm for the gas commodity portion of their rates. Currently market prices are well over $0.60 per therm. As a result of the increased commodity prices that Intermountain Gas had to pay its suppliers during the first half of this year, the Commission approved a 28% rate increase that became effective July 1, 2000. The Company asserts that the wholesale prices for natural gas have continued to rise since the new rates took effect in July. In this Application, the Company now seeks permission to increase its natural gas rates by $0.18434 per therm. More specifically, Intermountain Gas seeks to increase the Company’s Weighted Average Cost of Gas (WACOG), and impose a temporary surcharge for seven months related to deferred gas costs. The proposed increase is in addition to all credits and surcharges relating to the Company’s previous rate case, Case No. INT-G-00-1. The Company’s earnings will not change as a result of the proposed changes in prices and revenues. The proposed rates will only recover the increased cost of natural gas and deferred costs that have happened since the prior case. Intermountain Gas proposes to increase the WACOG by $0.18434 per therm to reflect the higher cost of purchasing gas. The Company also seeks to recover deferred gas costs already accrued in its Purchased Gas Cost Adjustment (“PGA”) balancing account (Account No. 186) from its customers through a temporary price adjustment effective during the seven month period beginning December 1, 2000 and ending June 30, 2001. The PGA is a tracker mechanism that allows the Company to adjust consumer gas prices to reflect its purchase cost (WACOG) and to recover the over- and under-collections that occur. As of November 30, 2000, Intermountain has deferred approximately $9,300,000 of variable gas costs in its PGA Account. Intermountain Gas proposes to collect this amount via a short-term surcharge of $0.04811 per therm. The overall effect of the Company’s proposed changes in this case would be an increase in Idaho revenues of $35,818,646 (26.84%). The net increase is comprised of: WACOG Adjustment $26,476,341 Temporary Deferral Recovery Surcharge $ 9,342,305 Net Adjustment $35,818,646 Intermountain Gas seeks to recover the change in rates from each of its customer classes in accordance with its Purchased Gas Cost Adjustment tariff. To this end, the Company proposes to uniformly raise customer rates by $.18434 per therm. Intermountain Gas recommended the following annualized change in rates per customer class: Customer class Proposed Incremental Revenue Proposed Incremental Increase $ /Therm Proposed Average Increase % Change Proposed Average Price $/Therm RS-1 Residential $ 5,815,945 $ 0.18434 22.61% $0.99968 RS-2 Residential $ 16,678,713 $ 0.18434 26.97% $0.86775 GS-1 General Service $ 12,842,089 $ 0.18434 28.61% $0.82876 LV-1 Firm Service $ 481,899 $ 0.18434 48.70% $0.56286 Total $ 35,818,646 $ 0.18434 26.84% $0.87109 B. Procedural History On November 9, 2000, the Commission issued an Order and Notice of Application suspending the Application for 15 days from the proposed effective date of December 1, 2000. Order No. 28561. This Order also provided that the Commission would proceed under Modified Procedure and hold Public Workshops and Hearings in five cities throughout the Intermountain Gas service area. Additionally, this Order established a December 6, 2000 deadline for written comments and a November 15, 2000 deadline for persons desiring to intervene. Northwest Industrial Gas Users (NWIGU) filed a Petition for Leave to Intervene on November 15, 2000. According to their petition, “NWIGU does not object to Intermountain’s filing and does not intend to present evidence or cross examine witnesses.” The Commission granted NWIGU’s Petition to Intervene on November 20, 2000. THE PUBLIC HEARINGS The Commission convened public hearings in this matter on November 20 in Boise, November 21 in Caldwell, November 28 in Twin Falls and December 4 in Pocatello and Rexburg. Each hearing was preceded by an hour-long workshop, during which the Commission Staff and Intermountain Gas representatives provided information to the public on current natural gas issues and answered questions. The Commission expresses its gratitude to the public for turnout at the hearings and for the written comments submitted. We found the public input beneficial and it has assisted us in reaching a decision in this case. Thirty-four (34) people testified at these public hearings – all in opposition to the proposed rate increase. Many residents, both retired and employed, feared that they could not pay a higher gas bill. Those who testified expressed particular concern for the health of senior citizens who cannot afford increased heating bills or who will refuse to adequately heat their homes in an effort to avoid the proposed increase. Five Community Action Agency (CAA) representatives described the strain a rate increase would place on their clients and the limited community resources available to meet the needs of households seeking assistance. CAA’s distribute federal funds through Low-Income Home Energy Assistance Programs (LIHEAP). Several witnesses testified that Intermountain Gas should donate money, or at least the equivalent of its advertising budget, to help low-income customers pay their bills. Four business owners expressed concern for the economic viability of their businesses. In particular, these businessmen feared the negative effect the rate increase would have on their customers, who will be forced to pay higher prices for the goods they sell. One business owner and one employee testified that a rate increase would likely result in layoffs in their respective companies. Several witnesses blamed Intermountain Gas for inadequate planning, faulty management, and excessive profit taking in light of the financial hardship their customers face. A sizable number of witnesses felt that it was more equitable for Intermountain Gas and its shareholders to absorb a loss in lieu of the suggested rate increase. WRITTEN COMMENTS Public Comments As of December 6, 2000, the Commission received 299 written comments. All of the comments oppose the proposed rate increase. A few comments indicated that although some increase might be justified, the entire requested increase should not be granted. Many of the early comments erroneously claimed that this rate proposal would represent an additional 60% increase. Some went on to add the 60% to the earlier increase, arriving at a total increase of 90%. Numerous concerns were expressed in the written comments received by the Commission. Several ratepayers thought that Intermountain’s suppliers were engaging in price gouging and that excess profits were being reaped at the expense of Intermountain Gas customers. Other comments stated that Intermountain Gas shareholders should absorb the increase rather than the customers. Many ratepayers expressed outrage that this will be the Company’s second large increase in one year. Still other consumers felt they had been misled by advertisements that promoted switching to gas appliances as a way to save money because natural gas was more cost effective than electricity. Since commodity prices have increased after they switched to natural gas, some customers feel that the advertisements were made in bad faith. Many comments mentioned that their household received only a 3% cost-of-living increase, while being forced to absorb double-digit price hikes in other areas such as gasoline, groceries, health insurance, prescription drugs and other utility rate increases granted this year. Staff Comments Staff recommended that the Commission grant a partial increase. More specifically, the Staff recommended that the Commission authorize the proposed WACOG increase, continue to defer accrued costs in Account No. 186, deny future interest accrual in the deferral account, review the PGA process, and modify the Company’s Level Pay program. These issues are discussed in greater detail below. (1) WACOG Increase Staff supports the proposed WACOG increase in this case. Natural gas commodity prices continue to rise and are currently at a level that is higher than the rate requested by the Company. Staff believes it is important to send a correct “price signal” to customers now so they can adjust their use accordingly. Furthermore, Staff is concerned that if the WACOG increase is not granted, this will merely defer significant increases to next year. According to Staff calculations, if the WACOG is not increased now and gas prices remain at the $6.00/MMBTU level, ratepayers as a whole could face an estimated increase of $90,000,000 in July 2001. (2) Deferral of Current Costs in Account No. 186 Staff next recommends that the Commission require the Company to continue deferring the amounts already accrued in Account No. 186 until the next PGA Tracker. If the Commission decides to continue deferring these costs, the average increase in this case for gas costs to customers will be approximately 20%. By continuing to defer these costs, Staff feels the Commission will still be able to send a price signal to customers with the gas cost increase, but the impact will be smaller at this time. Although it recognizes that the market gas prices have continued to rise to higher levels than those projected by the Company, Staff believes it is reasonable and prudent to delay this portion of the request given the magnitude of the recommended increase and the previously approved increase in July 2000. (3) Interest on Deferrals Staff proposes that the Company accrue no interest on the amounts in the deferral accounts from November 30, 2000 through the next PGA Tracker expected in July 2001. Even though elimination of interest for this period will be a change from current practice, Staff believes it is reasonable as a prospective interim measure until the PGA process can be re-evaluated. Staff is concerned that the Company currently has little incentive under the existing PGA mechanism to assure least-cost acquisition of natural gas. The elimination of interest on the deferral account provides an interim incentive, until a more formal PGA review is undertaken, for Intermountain Gas to explore innovative means to obtain the most cost-effective gas and document these activities. Staff maintains that the Commission is not required to allow this interest accrual and that based on the Company’s projections, the interest foregone will total approximately $314,819 through June 2001. (4) Review of the PGA Process Given the impact on customers of the natural gas market’s current price volatility, decreased supply and increased demand of natural gas, Staff recommended the Commission initiate a formal review of the PGA mechanism. More specifically, Staff feels a review is warranted to evaluate the need for incentives to ensure that the Company secures gas at the lowest possible cost for its customers. Furthermore, a formal review could result in rewards for both the Company and its customers through profit sharing and administrative savings. 5) Level Pay Modifications (Customer Deferral Option) Approximately 20% of the Company’s customers are enrolled in the current Level Pay Program. Staff recommends that an “anniversary date” Level Pay Program be put in place allowing customers the opportunity to join the Level Pay Program and defer, or level out, their natural gas bills over the next 12-month period. Staff recognizes that customers starting a level pay plan at times other than the spring or early summer will not build up a credit balance to carry them through the heating season. Although the Company may experience a change in cash flow, Staff believes the overall annual impact will be minimal and only occurs in the first year. Staff also recommends that special payment options, such as the Level Pay Program and arrangements spreading payments over several months, be offered by the Company when specifically requested by customers. Staff believes the Company should advertise the availability of the special payment options on each customer’s bill with the appropriate customer assistance telephone number. Company Comments Even though the Staff and Company agree that the WACOG should be increased as proposed, Intermountain Gas opposes the Staff recommendations regarding the deferral of Account No. 186 accrued costs, denying future interest accrual in the deferral account, formal reviewing of the PGA process, and modifying the Company’s Level Pay Program. The disputed issues are discussed below. (1) Deferral of Current Costs in Account No. 186 The Company opposes any deferral of the approximately $9.3 million in current costs accrued in Account No. 186. Moreover, the Company argues that if recovery of the deferral is not granted now, significant rate increases will be needed next year. From a consumer perspective, deferring collection of current costs would not send a price signal at a time when customers can change their gas usage. Even once the deferred amount comes due at a later date, the customers that incurred the cost might not pay it. (2) Interest on Deferrals Intermountain views this recommendation as an unwarranted punitive measure, not an “incentive.” The Company denies Staff’s assertion that it has little incentive under the existing PGA mechanism to assure least cost acquisition of natural gas. Intermountain notes that there is no evidence that the Company has not been diligent in the management of its gas supply. Furthermore, millions of dollars in savings have been passed on dollar for dollar, with interest, to Intermountain’s customers as a result of the Company’s gas management policies during varied commodity market conditions. (3) Review of the PGA Process The Company is willing to review the PGA mechanism with Staff, and hopes that this review can be done informally. Intermountain Gas maintains that the existing PGA mechanism serves customers well by insuring that they pay no more or less for natural gas than the costs incurred by the Company to acquire it. The Company also notes that the Staff has had the opportunity to review Intermountain Gas purchase contracts and to verify the appropriateness of those contracts during its annual PGA review. (4) Level Pay Modifications (Customer Deferral Option) In its comments, Intermountain Gas offers to: 1) initiate an anniversary based, 12-month, level pay plan, 2) establish special payment arrangements on a special case-by-case basis, and 3) include language on its customers bills advising them of the level pay and special payment plans. However, the Company insists that it is necessary to charge the customer interest on winter debit balances under the anniversary plan program because it requires the Company to fund the customer’s payment shortfalls during the winter heating season. DISCUSSION AND FINDINGS A. WACOG Increase The Commission greatly appreciates those who testified at the five public hearings and submitted written comments regarding the proposed rate increase. It appears that a significant rate increase may be a hardship to many Idahoans. Although the Commission is mindful of this burden, it would not be prudent to put off a rate increase now in lieu of a larger increase next year. Since Intermountain’s Application was filed, wholesale gas costs continue to surge in excess of the proposed WACOG amount ($0.42296 per therm). For example, on December 5, 2000, the Wall Street Journal reported that natural gas prices reached an all-time high on the New York Mercantile Exchange of $7.433 per MMBTU (or $0.7433 per therm) for January 2001 delivered gas. One reason is due to the tightening of supply available to meet the growing demand for gas. This will result in additional amounts accruing in the deferral account for a future PGA case. According to Idaho law, utilities cannot increase their rates for service without a finding by the Commission that the increase is justified. Idaho Code § 61-622. Based on the Application and Staff comments, we find that gas prices have dramatically increased and the gas rates previously authorized in Order No. 28426 are not adequate to compensate Intermountain Gas for the prices it pays its suppliers. Consequently, we find the rate previously authorized by that Order are no longer “just and reasonable” as required by Idaho Code § 61-502. After reviewing the utility’s Application to increase rates, the Commission is required to establish “just and reasonable” rates. Id. Keeping the current commodity market and the best interests of Idaho ratepayers in mind, the Commission finds it reasonable to grant the proposed $0.13623 WACOG increase. This results in an authorized WACOG of $0.42296 per therm. Unfortunately the increase of natural gas commodity prices has coincided with the arrival of winter in Idaho. Thus far in December, natural gas prices have reached new all-time highs nationwide. The Commission is concerned that if it does not grant a rate increase now and commodity prices remain high, Idaho ratepayers will be forced to bear a staggering rate increase at the next PGA tracker (anticipated in the summer of 2001). Consequently, we find it is important to send a correct “price signal” to customers now so they can adjust their use accordingly. As of early December, the natural gas spot prices from Intermountain Gas’s three major suppliers were more than $10/MMBTU, $8/MMBTU, and $34/MMBTU from the AECO, Rockies, and Sumas trading hubs, respectively. Given these current commodity prices, it is unlikely that the $4.23/MMBTU rate approved by this Order will be adequate to prevent another rate increase next year. However, the WACOG increase approved in this Order will mitigate the size of a rate increase that may be needed next year. The rate increase approved in this Order shall become effective on January 15, 2001. The Commission believes this delay will allow Intermountain Gas time to adjust its billing policies and file new tariffs prior to implementing the new rate. Idaho Code § 61-618. Furthermore, this delay will allow ratepayers time to adjust their natural gas consumption after receiving their first full winter month bill under the previously approved increases. Moreover, the delay will give qualifying customers more time to access the various consumer assistance programs. It is the Commission’s hope that this delay will minimize rate shock, as well as afford ratepayers an opportunity to meet other year-end obligations prior to implementing this rate increase. By delaying implementation of the rate increase from December 1, 2000 to January 15, 2001, customers will delay payment of approximately $10.5 million. B. Deferral of Current Costs in Account No. 186 Although none of those who testified at the public hearings or submitted written comments endorsed a rate increase, many asked that the Commission approve a rate less than the 27% proposed by Intermountain Gas. In light of the 28% increase granted in July 2000, and the increase to the Company’s WACOG authorized by this Order, the Commission finds it appropriate to continue deferring the costs accumulated in Account No. 186. This account was estimated to contain $9,348,974 as of November 30, 2000. By continuing to defer these costs, the average increase for customers will be approximately 20%. The net effect will be to send an effective “price signal” to ratepayers through the WACOG increase, yet lessen the full impact of recovering the amounts already owed to Intermountain Gas. The Company correctly points out in its reply comments that deferring these costs could only add to the size of next year’s rate increase. This $9.3 million in uncollected costs will not simply disappear with time. While the Commission and the Company hope commodity prices will decline next year, the Commission cannot guarantee this will occur. The bottom line is that deferring these costs is a calculated risk. With the information available at this time, granting the WACOG increase but deferring collection of Account No. 186 appears to be the best way to reasonably balance the hardship to ratepayers while allowing the Company to recover its unprecedented commodity costs. Therefore, the Commission is willing to take this risk. C. Interest on Deferrals The Commission finds that Intermountain Gas should be allowed to collect interest on the amounts in the deferral accounts through the next PGA tracker (anticipated in July 2001). However, the Commission is concerned that the PGA may not sufficiently encourage the Company to acquire natural gas at the lowest cost available – particularly in a volatile commodity market. The Commission’s practice thus far has been to allow interest recovery in Intermountain Gas’s PGA. Although this interest recovery is by no means guaranteed in the future, it will continue until a formal review of the PGA is undertaken. D. Review of the PGA Process The Commission finds that it is appropriate to conduct a formal review of the PGA mechanism in light of current market conditions. Although the PGA passes the savings through to customers when Intermountain Gas buys gas more inexpensively than projected, it also passes on the additional cost of gas purchased in excess of the projected price. While there is no evidence to suggest that the costs passed through to the ratepayers have not been just and reasonable, we question why some prices were not locked in to hedge against the current market volatility. A formal review could result in rewards for both the customers and the Company through profit sharing and administrative savings. We find that attributes (such as benchmarking or sharing) included in other utility PGA mechanisms could potentially benefit Intermountain’s customers if they were incorporated in Intermountain’s PGA mechanism. In light of the current volatile market conditions, it is imperative that the Commission and Intermountain’s customers are assured that the PGA mechanism is equitable and that natural gas is secured at the most reasonable price possible. A review at this time would provide such assurance and is in the public interest. A PGA review will also facilitate examination of the Company’s gas purchasing policies, alternative gas suppliers, and management fees it pays to IGI Resources as required by Order No. 28109 (Case No. INT-G-99-1). To assist with this PGA review, Intermountain Gas is directed to prepare and submit an analysis of its gas purchasing policies and gas supplies. E. Level Pay Modification The existing Level Pay Program provides customers the opportunity to average their payments for natural gas over a 12-month period beginning in April. Approximately 20% of the Company’s customers are enrolled in the current Level Pay Program. Customers participating in the program build a credit balance during the summer and deplete that balance throughout the more expensive winter heating season. Anyone who starts the program after April currently pays a calculated level payment for the remaining months of the level pay year until April, when there is a true up for over- and under-payment amounts. The level pay year then begins again. In other words, the level pay plan runs from April to April. In their comments, Staff recommended and Intermountain Gas agreed to implement an “anniversary date” Level Pay Program. This payment plan would allow customers to begin level pay at any time. For some, this would defer their current winter natural gas bill as they pay a level amount calculated to cover the winter heating season over the next 12-month period. The Commission finds this additional payment option can benefit Idaho ratepayers and thus orders its implementation. Even though customers who access this program this winter (2000-2001) have not accumulated a credit balance to carry them through the heating season, the Commission does not authorize the Company to charge interest on the debit amount. Since customers will accumulate both credit and debit balances over the course of a year, the interest owed to and owing by customers will approximately cancel each other out. Furthermore, the administrative burden created by making such interest calculations is too great in proportion to the relatively insignificant sums to be collected or returned. Participation in the program will be limited to those residential and small commercial customers taking service year round. Customers who connect and disconnect on a seasonal basis are not eligible to participate. Customers desiring to participate in this program or any other special payment arrangement are required to call Intermountain Gas to make the arrangements. It is the Company’s obligation to work closely with customers to assist them in managing these rate increases. To promote awareness of payment options, the Company shall include language on bills advising customers of the availability of level pay and special payment plans along with information on how to sign up. Because it is necessary to authorize a rate increase of approximately 20%, the Commission is concerned for the health and safety of ratepayers who struggle to pay their winter heating bills. We encourage ratepayers to contact Intermountain Gas, which offers special payment arrangements to help customers manage their utility payment in extraordinary circumstances. Special payment arrangements can be tailored to the unique needs of a particular customer and can include spreading payments over several months. To make special arrangements or invoke the winter shut-off moratorium, customers should contact Intermountain Gas’s Customer Service Department at 1-800-548-3679. Low-income Intermountain Gas customers may also be eligible to receive financial assistance from energy programs like LIHEAP, Project Share, and Project Warmth. Interested customers should contact the Commission Consumer Assistance Staff at 1-800-432-0369 for more information on programs in their vicinity. Several Community Action Agency representatives testified at the public hearings that their agencies did not have adequate funding to meet the needs of households seeking assistance. We note that LIHEAP is a federally funded program that many states match with state funds. However, Idaho does not. This is an area that should be explored by our utilities and those agencies which assist income eligible customers. We also encourage natural gas customers to conserve energy in an effort to keep winter heating bills affordable. The Department of Energy offers conservation tips on its website located at http://www.eren.doe.gov/buildings/documents/high_heating_bills.html O R D E R IT IS HEREBY ORDERED that the Northwest Industrial Gas Users’ Petition for Leave to Intervene is granted. IT IS FURTHER ORDERED that Intermountain Gas’s Application is partially granted. The Company shall file tariffs in conformance with an incremental rate increase of $0.13623 per therm to achieve a WACOG of $0.42296 per therm. The new tariff rates shall be effective on January 15, 2001. IT IS FURTHER ORDERED that the current costs in Account No. 186 be deferred until the next PGA tracker case. IT IS FURTHER ORDERED that the Commission shall initiate a formal review of the PGA mechanism to ensure that it adequately protects ratepayers from swings in commodity prices. IT IS FURTHER ORDERED that Intermountain Gas analyze the cost-effectiveness of its relationship with its gas suppliers and gas purchasing policies, and file results of that analysis with the Commission to facilitate review of the PGA. IT IS FURTHER ORDERED that Intermountain Gas initiate and maintain an anniversary-based level pay program, as set out in the body of this Order. IT IS FURTHER ORDERED that Intermountain Gas notify its customers of the rate changes approved in this Order. The Company shall also advise its customers of the anniversary-based level pay program and how to obtain state and local natural gas customer assistance programs. THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally decided by this Order) or in interlocutory Orders previously issued in this Case No. INTG00-2 may petition for reconsideration within twenty-one (21) days of the service date of this Order with regard to any matter decided in this order or in interlocutory Orders previously issued in this Case No. INT-G-00-2. For purposes of filing a petition for reconsideration, this order shall become effective as of the service date. Idaho Code § 61-626. Within seven (7) days after any person has petitioned for reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-626. DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this day of December 2000. DENNIS S. HANSEN, PRESIDENT MARSHA H. SMITH, COMMISSIONER PAUL KJELLANDER, COMMISSIONER ATTEST: Jean D. Jewell Commission Secretary O:INTG002_ln2 A “therm” is a commercial unit of heat energy and comprises approximately 100 cubic feet of natural gas. A therm is equivalent to 100,000 BTUs (British Thermal Units). Case No. INT-G-00-1. Order No. 28426. According to its petition, Northwest Industrial Gas Users (NWIGU) is a nonprofit corporation comprised of 31 industrial users of natural gas with major facilities located in Idaho, Washington and Oregon. Its Idaho members include J.R. Simplot Co., Basic American Foods, and Lamb-Weston, Inc. Petition for Leave to Intervene, p. 3. This account was estimated to contain $9,348,974 as of November 30, 2000. Customers participating in the Level Pay Program build a credit balance during the summer and deplete that balance throughout the heating season. Anyone who starts the program after April pays a calculated level payment for the remaining months of the level pay year until April, when there is a true up for over- and under-payment amounts. The level pay year then begins again. INT-G-00-1. A “BTU” (British Thermal Unit) is the heat needed to raise one pound of water by one degree Fahrenheit. A “MMBTU” (million BTUs) is equal to 10 therms. AECO (Alberta Energy Company) is a pipeline hub located in southeastern Alberta, Canada. The Rockies pipeline distributes natural gas from the Rocky Mountain region of the United States. Sumas, Washington is a hub on the Sumas International Pipeline near the Canadian border. The WACOG that the Company proposed, and is approved by this Order, is $0.42296 per therm. This amount is equivalent to approximately $4.23 per MMBTU. The interest on deferred accounts from November 30, 2000 through June 2001 will be approximately $314,819. No electric or gas utility may terminate or threaten to terminate service during the months of December through February to any residential customer who declares that he or she is unable to pay in full for utility service and whose household includes children (under age 18), elderly (age 62 or older), or infirm persons. Rule No. 306, Termination of Residential Gas and Electric Service-Winter Payment Plan (IDAPA 31.21.01.306.01). However, for the families that use this protection, the full amount not paid during the moratorium period becomes due after March 1. ORDER NO. 28578 1 Office of the Secretary Service Date December 15, 2000