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JOHN R. HAMMOND
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0357
IDAHO BAR NO. 5470
2QQ3 JUN I 3 PM 2: 21
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UTIL r:E2 Cm'lhJSSION
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNT AIN GAS COMPANY FOR
AUTHORITY TO INCREASE ITS RATES FORSERVICE CASE NO. INT-O3-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, John R. Hammond, Deputy Attorney General, and in response to the Notice
of Application, Notice of Public Workshops and Hearings, Notice of Modified Procedure and
Notice of Comment Deadline issued in Order No. 29242 on May 14, 2003, submits the following
comments.
On May 7 2003, Intermountain Gas Company (Intermountain; Company) filed its annual
Purchased Gas Cost Adjustment (PGA) Application with the Idaho Public Utilities Commission
for authority to place into effect new rate schedules that will result in an overall increase of
approximately $61 million (37.76%) in revenues.l The Company has requested an effective date
of July 1 , 2003 for its proposed rate schedules.
I The Company supplies natural gas to approximately 200 000 customers in southern Idaho.
STAFF COMMENTS JUNE 13 2003
STAFF REVIEW AND ANALYSIS
The Company proposes to implement the following permanent adjustments and temporary
surcharges to its tariff rates for natural gas service and sales:
Permanent Adjustments
Elimination of Surcharges and Credits from INT -02-
. W ACOG Adjustment
$10 163,440
$47 034 183
Temporary Surcharges and Credits
Fixed Cost Collection Adjustment
Uncollected Gas Costs in Account 186
Market Segmentation
Miscellaneous Gas Costs & True Ups
217,435
$4,427 982
($2 366 437)
($504 575)
The total incremental revenue requested by Intermountain Gas Company during the
2003-2004 PGA period is $60 972 028 or a 37.76% increase. The following tables represent
Intermountain Gas' proposed changes in rates per customer class.
Proposed Proposed Proposed
Customer Class Revenue Average Average Average PriceIncreaseIncrease %
$/Therm Change $/Therm
RS-1 Residential 384 066 23826 33.44%95075
RS-2 Residential 108 992 880 23129 37.90%84164
GS-1 General Service 025 514 23886 42.49%80100
LV-1 Large Volume 089 088 22058 53.91%62976
1 Tariff price plus the Weighted Average Cost of Gas (WACOG) $0.50305 per therm
WACOG = total commodity cost of gas / total purchase therms
Proposed Proposed Proposed
Transportation Revenue Average Average Average PriceIncreaseIncrease %
$/Therm Change $/Therm
T -1 Transportation 338 014 (0.00421)22%09554
T -2 Transportation 602 291 (0.00024)89%02672
Intermountain Gas proposes to allocate the change in rates to each of its customer classes
in accordance with its Purchased Gas Cost Adjustment tariff and approved cost-of-service
2 In Case No. INT-02-, the Commission authorized certain surcharges and credits to be recovered from and
returned to customers over a period of one year. These surcharges and credits were made up of overcollected gas
costs, changes in the fixed cost collection allocations and other miscellaneous gas items.
STAFF COMMENTS JUNE 13 2003
methodology.3 Staff agrees that this is the proper methodology to use should the Commission
authorize the Company s proposed increase in rates.
1. Staff Audit
Staff has conducted a detailed audit of the Company s gas costs that were incurred during
the previous PGA period. All invoices, contracts and other materials that relate to the gas
purchased during the prior PGA period were reviewed. Staff has verified that there will be no
increase in profit to the Company from this proposed rate increase should the Commission grant
the Company s request. At this time, Staff is also conducting a comprehensive financial audit of
Intermountain Gas. Based on preliminary figures, the Company had net income of $4.2 million
for the year ending September 2002. During the same period, Intermountain earned 5.314% on
its common equity.
During the course of the PGA audit, Staff identified several things the Company has done
in an attempt to reduce the gas price for customers. First, the Company sold a large portion of its
Sumas gas and then purchased a similar quantity of Rockies gas at a lower price. This resulted
in significantly reduced purchased gas costs. The Company plans to continue this practice if it
results in less-expensive gas for customers.
Second, in 2002, the Company entered into financial transactions to fix the price for a
portion of gas purchased for customers. These transactions are used by the Company to protect
customers from significant upward swings in the price of gas on the wholesale market. While
these transactions ended up costing customers an additional $713 354 over what it would have
cost on the spot market, they did provide price stability and reduced risk of market exposure. In
addition, Intermountain Gas states it is constantly reviewing and analyzing the forward markets
to ascertain when it would be prudent to make other forward purchases as the need or
opportunity arises.
Third, Intermountain Gas continues to actively search for opportunities to market its extra
pipeline capacity. In this regard, Staff questioned IGI Resource s (IGI) bidding practices last
summer. 5 Since that time IGI has consistently either bid out the Company s extra capacity in an
See Case Nos. INT-95-, INT-88-2 and U-l034-137.4 The Company earned 5.897% for the year ending September 2002 when normalized revenues are considered.5 IGI Resources is a wholesale gas marketer that performs gas procurement and management services for
Intermountain Gas Company. At one time, IGI was affiliated with Intermountain Gas, but was sold to BP Energy in
2000 by Intermountain's parent company, Intermountain Industries.
STAFF COMMENTS JUNE 13 2003
appropriate manner or purchased the capacity itself at the highest rate allowed.6 While the
majority of unused transportation capacity is sold for significantly less than the tariff price, the
Company is attempting to maximize revenue rather than leave the capacity unused.
Fourth, during the most recent PGA period, IGI issued three requests for proposals to
meet Intermountain s short-term gas supply needs. The winning bidder in each case was the
least expensive proposal all but once. On that occasion, BP Energy s (BP) proposal was slightly
less expensive but Intermountain determined that it would use up too much of its available credit
with BP if it accepted the bid. Due to its ongoing relationship with IGI and BP, the Company
decided that it might need available credit for unforeseen situations that could arise in the
volatile wholesale gas market. Therefore, the contract was issued to the next bidder at a slightly
higher price.
Fifth, Intermountain s analysis showed that for the month of March 2002, it would
probably be cheaper to sell all of it's gas priced at the first-of-the-month index and repurchase
gas on the daily market. This strategy proved effective as prices fell from the first-of-month
highs to lower levels.
Sixth, the Company chose not to renew a storage contract for some of its Canadian gas
because the supplier wanted a significantly higher price for that storage capacity. After
attempting to renegotiate the contract, Intermountain s analysis showed that it would be cheaper
to simply purchase the gas during the winter than pay significantly more for storage. Even
though this appears to have been the best economic decision at the time, it does not secure the
price of gas through the winter. Prices have also increased significantly since the decision was
made and it is yet to be seen if the Company will pay less for gas during the winter season than it
would have for the storage capacity. The analysis retained by Intermountain for these types of
decisions should also include an evaluation of potential financial hedges to fix the price.
Finally, as required by Commission Order No. 29199, (Case No. INT-Ol-
Intermountain sent a letter notifying IGI that it will terminate its contract for gas management
services effective next year. Intermountain has also solicited proposals from several gas
6 The Federal Energy Regulatory Commission has capped the maximum price allowed for capacity releases.
STAFF COMMENTS JUNE 13 , 2003
marketers to find the most reliable and inexpensive management partner. Stafflooks forward to
reviewing the proposals and the process Intermountain uses to select a provider.
During its audit, Staff found no inconsistencies or irregularities that would cause it to
recommend adjustments to the Company s proposal. However, Staff encourages the Company
to continue to use all reasonable transactions and strategies to reduce the price of gas for
customers. Based on the foregoing, Staff recommends approval of all the temporary credits and
surcharges proposed by the Company including the $4.4 million in uncollected gas costs and the
$10.2 million increase due to the removal of the surcharges and credits from the last PGA case.
2. W ACOG
Intermountain Gas is requesting an average 38% rate increase. The majority of the
request is due to a proposed increase in the weighted average cost of gas (W ACOG) to
50305/therm.8 This is an increase of $. 18305/therm from the current W ACOG of $. 32/therm.
Staff has reviewed Intermountain s transportation and gas procurement contracts, the
Company s gas price forecast, and national market price trends. Unseasonably cold weather in
late winter for the eastern half of the United States has resulted in natural gas storage levels that
are well below normal. Staff believes the low storage levels are causing an unusual increase in
demand during the summer storage-filling season. Demand has also increased due to natural gas
fired electric generation used for meeting the summer cooling peak demand. This increase in
demand has caused natural gas market prices to increase nationwide.
In addition, the western Canadian and US Rockies natural gas reserves are no longer
confined to serve only the Northwest US and Canada. In 2000, the Alliance pipeline opened
(See Attachment A). This pipeline allowed the Western Canadian gas-producing fields to serve
the larger Midwestern United States natural gas market. In May 2003, a new pipeline began
service that doubled the Kern River delivery capability of US Rockies gas into southern
California (See Attachment A). Based on these factors Staff believes Idaho customers are now
subject to the national gas market that is experiencing significant price increases and market
volatility.
7 ln this Order, the Commission also required Intermountain Gas to "submit a report detailing the qualifications
service offered, and remuneration required by the bidding parties." Order No. 29l99 at 8 The W ACOG is the Company s anticipated average purchase price for natural gas over the PGA year July 2003-
June 2004.
STAFF COMMENTS JUNE 13 , 2003
The Commission could consider a smaller W ACOG increase. However, current market
estimates exceed the Company s request by approximately 5 cents per therm (See Attachment
B). Thus, even at the Company s requested W ACOG deferred gas costs could be generated.
Purposely generating deferral balances is not necessarily unreasonable particularly if
commodity price are expected to decrease in the next ratemaking cycle. Unfortunately natural
gas prices for the 2004-05 PGA cycle are expected to be approximately $.45 per thermo
Therefore, the forward price projections provide little opportunity for additional deferral
recovery without a rate increase next year. The forward projections also do not take into
consideration unknown external events such as colder than normal winters or warmer than
normal summers. Should either of these events occur natural gas prices will exceed projections
and rate increases will be required even if the proposed W ACOG is approved. Therefore, Staff
does not recommend a W ACOG below that proposed by the Company and believes that
Intermountain s requested W ACOG is reasonable given the current market circumstances.
Staff recommends approval of the Company s W ACOG as requested. Staff also
recommends that the Commission require Intermountain to continue to file its quarterly
W ACOG reports for the current gas year. Staff further recommends that the Commission require
Intermountain to also file W ACOG reports for the projected 2004-2005 gas year to allow Staff to
follow the same data and results the Company should be monitoring.
3. Risk Mana1!ement and Price Stability
Staff has also completed its review of the Company s Risk Management Committee
minutes and other documented activities. Staff notes that the Company has greatly improved
documentation of these activities regarding credit risk and venders' reliability. However
customers' rates clearly remain unprotected from annual market volatility. RS-2 Customers are
still being asked for a 38% increase in rates. In fact RS-2 gas costs will go up 57% over the last
PGA cycle (See Attachment C).
In the Company s 2002 PGA, the Company requested to keep the W ACOG higher than
its market forecasts to create a credit deferral for customers within the PGA. In May 2002, the
Company presented both a 2002-03 W ACOG estimate of $. 32/therm and a 2003-04 W ACOG
estimate of approximately $.35/therm. The Company s 2002-03 W ACOG turned out to be a
very good estimate. The accuracy was improved considerably by a significant amount of
financial hedging that secured the 2002-03 gas prices. Unfortunately for customers, the
Company did not secure the forward prices for the 2003-04 W ACOG in 2002.
STAFF COMMENTS JUNE 13 2003
As part of our investigation of the Company s risk management decision making the
Staff questioned the Company as to why 2003-04 hedges were not secured. The Company
replied "the obligation of the Gas Management Committee is not to project what prices will do
nor is it the Committees objective to 'beat' a projected W ACOG , but rather to ensure
Intermountain s gas supplies are purchased at a prudent price level."
Staff does not disagree with an emphasis on prudent gas purchases, nor does Staff
downplay the importance of the improved documentation implemented by the Company.
However, Staff believes the Company should add an additional element to its risk management
activities that involves consideration for customer rate stability.
While Staff continues to agree with its 2002 comments and the Commission s decision
not to artificially increase rates to build customer deferral reserves, it also believes there are other
methodologies that could provide a more disciplined approach to minimize price volatility for its
gas customers. In this regard, Staff believes the Commission should require Intermountain Gas
to file a more formal risk management policy. By not adequately considering and documenting
the analysis for financial hedges as part of the risk management practice, or by simply stating
that prices are too high with the expectation that prices will come down, the Company is taking a
price view. The Company s decision-making process needs to be documented and included as
part of its formal policy to assure that decisions are made in a rational and reasonable manner.
Staff recommends that the Commission direct the Company to formalize its risk
management policy with special emphasis on managing reliability, price, service quality, credit
risk, and customer rate volatility. Staff further recommends that the Commission direct the
Company to file this formal written policy within 90 days. Staff anticipates that the formal
policy would include trigger points or volatility limits that could be used to make hedging
decisions or forward market purchases. Staff also believes that after the initial filing of this
formal policy it could easily be incorporated into the Company s biannual Integrated Resource
Planning (IRP) process in the future. The IRP provides short and medium term market
projections. Thus, it presents a good opportunity to address risk management with respect to
anticipated market volatility and short-term market swings.
9 Intermountain Gas response to Staff audit requests dated 5/20/03.
STAFF COMMENTS JUNE 13 2003
4. Lon1! Term Gas Purchases
One area of Staff concern relates to the Company s recent decision not to seek formal
proposals for its long-term gas needs.lo The Company has solicited such proposals for purchases
less than a year away, and has a documentation process that explains how the winning bid was
chosen. However, for its longer-term gas, the Company has not requested formal proposals and
in response to Staff s inquiry stated:
Today, no long-term producer or supplier who sells to Intermountain is
willing to directly negotiate a fixed price." While price has always been, and
will continue to be, an important component of any of our contracts with
suppliers, the price discovery component of LDC/supplier negotiations has
now been supplanted by the collective outlook on future prices with the
advent of natural gas being traded on the Nymex and the over the counter
derivative markets. Not by coincidence, the Company has found, of recent
that many of our preferred portfolio of producers simply will no longer
respond to RFP's as they view the exercise as price discovery only and much
prefer direct negotiation with the Company.
In addition to the price component of our supply contracts, Intermountain
continues to ensure that our supplies are aligned with secure, reliable, and
reputable credit worthy producers and suppliers who the Company is
comfortable will always provide firm, uninterrupted gas supply for our core
market needs.
Staff has not been able to ascertain the validity or reasonableness of the Company
statement that suppliers will not respond to formal long-term requests for supply because there
have been no formal proposals for Staffto review. Staff believes it is reasonable to ask the
Company to perform at least the same level of due diligence for long-term contracts as it does
when it looks for short-term arrangements. Staff believes that reliability and credit worthiness
should be a part of the formal process documentation for long-term as well as short-term
contracts. Staff recommends that the Company perform a formal Request for Proposals with
closed bids submitted to Intermountain Gas for independent evaluation when searching out new
long-term supply and transportation arrangements.
10 The contract in question is the rust replacement contract for Intermountain s three major natural gas supply
contracts that are scheduled to expire in 2003. The current contracts have ten-year terms and were secured through a
bidding process.
11 Company response to Staff Audit Request #3, May 29, 2003.
STAFF COMMENTS JUNE 13 , 2003
5. Demand Side Mana1!ement
In years past natural gas demand side management (DSM) was not cost effective. In
2000-2001 natural gas prices approached the point where DSM became cost effective. Prices
and rates appear to be at the same point again. Now is the time when the Company s current
activities can be most effective. Staff encourages the Company to continue its current programs
and its mass media and web site activities to promote the efficient use of natural gas. These
media activities provide all customers with valuable conservation information and provide
individuals with ways to reduce their own monthly energy bills. Staff also recommends that the
Company continue to explore new DSM opportunities for its customers.
CONSUMER ANALYSIS
1. Customer Notice
When Intermountain Gas filed its Application on May 7 2003 , both the customer notice
and press release were included in the filing. Customers were notified of the Application by bill
stuffer and had until June 13, 2003 to file comments with the Commission. Staff reviewed the
customer notice and press release and determined both complied with the notice requirements of
IDAP A 31.21.02.102. The customer notice was mailed with cyclical billings beginning May 7
2003 and ending June 4 2003. In addition, Intermountain filed its Application earlier than usual
to allow adequate time for customers to receive notice well before the scheduled public hearings
and workshops.
2. Customer Comments and Public WorkshoDs and Hearin1!s
As of June 11 2003, the Commission had received 181 written comments from
customers. None of those who commented favored the increase. Two of the respondents stated
that if such an increase were warranted, only part of the increase should be granted. They further
recommended that the Commission review wholesale gas prices in six months and if they have
not declined, the Commission could order further rate increases. Three of those commenting
said they did not attend the hearings or workshops because they assumed the Company would
get the increase regardless of objections by the public. One customer, a farmer, said that $8 600
in additional unbudgeted costs that he would incur as a result of one rate case increase "will cut
in a very thin margin, possibly into a loss situation.
The first of three scheduled workshops and hearings were held in Boise at the Idaho
Public Utilities Commission office. One Intermountain Gas customer attended the workshop.
STAFF COMMENTS JUNE 13, 2003
No customers testified at the hearing. Additional workshops and hearings were held on June 4
in Idaho Falls and June 5 , in Twin Falls. Two customers attended the Idaho Falls workshop.
One customer testified at the hearing. In Twin Falls, no customers were in attendance at either
the workshop or hearing. Television and newspapers covered all three meetings and hearings.
3. Customer Service
Between the effective date of the last PGA, July 2002 and June 12 2003 , the IPUC
Consumer Assistance Staff received 83 complaints and inquiries regarding credit and collection
issues of which 81 concerned disconnection of service. This was a significant decrease over the
corresponding 2001-2002 time period when Staff received 154 complaints and inquiries
regarding credit and collection issues of which 145 concerned disconnection of service.
In the past year, during which time rates declined, there was a substantial decrease in the
number of complaints and inquiries related specifically to Intermountain s rates. Since the
effective date of the last PGA, 17 complaints or inquiries regarding rates have been received
while during the same time period the previous year there were 52.
The proposed rates, if approved, will increase prices to levels similar to those in effect
during the 2001-2002 heating season. Based on its past experience, Staff anticipates complaints
and inquiries regarding Intermountain will increase significantly if the Commission approves a
substantial rate increase. Similarly, Intermountain will see an increase in the number of
customers that contact the Company directly. One reason for increased call volumes is because
credit and collection efforts increase as more customers are unable to pay their bills in full.
When customers receive notices threatening disconnection of service for nonpayment, they are
asked to call into the Company to make payment arrangements. During the 2001-2002 heating
season, customers had a difficult time getting through on the Intermountain Gas Customer
Service telephone line. After reviewing Intermountain s Service Levels and Abandoned Call
data, Staff is concerned about Intermountain s ability to handle an increased volume of incoming
telephone traffic that might be expected following another major rate increase.
Service Level" at Intermountain refers to the percent of the total number of incoming
calls that are answered within 30 seconds or less. An established industry standard for utilities is
to answer 80% of incoming customer service calls within 20 seconds. However, Staff does not
take issue with Intermountain using 30 seconds instead of20 seconds. During fiscal year 2002
(October 2001 - September 30, 2002) when Intermountain prices were at their highest, the
Service Level for the year averaged 39.4%. In fiscal year 2001 (October 2000 - September
STAFF COMMENTS JUNE 13, 2003
2001), the average Service Level was 61.6%. In fiscal year 2000 (October 1999-
September 30 2000), the Service Level averaged 83.4%. Clearly, Intermountain has been
unable to meet its own standard for answering incoming calls as call volume has increased.
Another Consumer Assistance Staff concern is how many customer telephone calls
placed to the Company are abandoned per month. "Abandoned Calls" are the number of
customers' telephone calls that reach the Company s telephone line, but are not actually
connected to a Company representative. Typically, these customers hang up after waiting on
hold for longer than he or she deems acceptable. In fiscal year 2002, the average number of
phone calls abandoned per month was 3 534. In fiscal year 2001 , 1 659 calls were abandoned
per month. In fiscal year 2000, the average number of abandoned calls per month was 533.
These figures point to a downward trend in Intermountain s ability to answer incoming calls
within acceptable time frames when prices trend upward.
Intermountain states it has taken several steps this year that will allow them to handle the
additional incoming calls generated as a result of the proposed price increase. Since 2002, three
additional full-time Customer Service Representatives have been hired and two full-time
temporary positions were created. Also , three representatives in outlying local offices have been
identified as remote agents who can step in and answer calls during peak times if needed.
Customers can also communicate with the Company through the Intermountain Web Site at
www.intgas.com. Intermountain states their e-mail response time is within 24 hours.
Staff suggests an additional avenue for Intermountain to explore might be to encourage
the use of facsimile messages for customers unable to reach Intermountain by telephone during
peak times. This method could be employed when call volumes reach unacceptable levels by
playing a message while customers are waiting on hold giving them the option of sending a fax.
This would be in addition to reminding customers of Intermountain s Web Site where questions
and requests may also be sent to the Company.
Intermountain has many mechanisms in place to assist customers in paying bills when
they are unable to pay in full. The Level Pay program is by far the most popular budgeting tool
used by Intermountain residential customers. It helps nearly 20% oflntermountain s customers
spread their payments into 12 equal installments. Of the 20% on Level Pay, 5% are RS-
customers and 14% are RS-2 customers. In April or May of each year, the Company reviews
each customer s Level Pay and adjusts the monthly amount for the next 12 months. This year
anticipating an increase in prices, Intermountain held off adjusting Level Pay amounts. Instead
STAFF COMMENTS JUNE 13 2003
Intermountain will make the necessary adjustments this year by August to avoid making multiple
changes in Level Pay amounts that could cause customer frustration and confusion.
Programs available to customers who have trouble paying their gas bills include LIHEAP
(Low Income Home Energy Assistance Program), Project Share, and Project Warmth. Project
Share and Project Warmth serve different geographic areas and do not overlap. Customers
dire need are often able to get assistance from two programs: LIHEAP and Project Share or
Project Warmth. In some situations, a customer may make a salary slightly higher than the
levels needed to qualify for LIHEAP funds. However, these customers still may qualify for
Project Share funds or Project Warmth funds because their requirements are more lenient.
Intermountain this year has implemented a new program where customers can sign up to
donate funds on a regular basis to a fuel fund. A specified amount will be added automatically to
the customer s monthly Intermountain Gas bill. Intermountain sends those funds to Project
Share in Southwestern Idaho and Project Warmth in Southeastern Idaho.
During the months of December through February, no electric or gas utility may
terminate service or threaten to terminate service to a residential customer who declares that he
or she is unable to pay in full for service and whose household includes children (under the age
of 18), elderly (age 62 or older), or infirm persons. During the winter protection period
customers are encouraged to make payments or sign-up for a program called the Winter Payment
Plan. The Winter Payment Plan is especially appropriate for customers who make too much
money to qualify for any of the fuel funds but still have difficulty making ends meet. The
Winter Payment Plan offers relief from high winter bills by allowing customers, for up to 5
months (November through March), to pay one-half of the customer s regular Level Pay amount.
Upon making the March payment, the customer would be expected to call into the Company and
establish a payment plan, usually a regular Level Pay amount, with the balance still owing after
the winter months rolled into a new Level Pay amount. Consumer Assistance Staff suggests an
additional Level Pay promotion be offered in September of this year. A Level Pay promotion
just before the winter would encourage customers to sign-up for Level Pay in the fall and
average their projected higher usage winter bills over a longer period of time. Consumer
Assistance Staff believes this would help to address approximately one third of the comments
from customers on fixed incomes who worried that they could not afford a 38% increase in
winter heating costs.
STAFF COMMENTS JUNE 13, 2003
STAFF RECOMMENDATIONS
Based on the foregoing comments, Staff recommends that:
1. The Company s proposed WACOG of$.50305 be approved.
2. The proposed temporary surcharges and credits be approved.
3. The Company seek formal or informal proposals for long-term gas supplies as well as
short-term supplies.
4. The Company continue to increase its documentation regarding its purchase and other
decisions.
5. Intermountain continue to file its quarterly W ACOG reports for the current gas year
and also begin filing W ACOG projections for the subsequent gas year as well.
6. The Commission direct the Company to formalize its risk management policy with
special emphasis on managing reliability, price, service quality, credit risk, and
customer rate volatility and file this formalized written policy within 90 days.
7. The Company allow customers to ask questions and seek service through facsimiles
as well as over the phone and through the internet.
8. Intermountain perform an additional Level Pay promotion in September to allow
customers the opportunity to sign up before the winter heating season. Customers
would be encouraged to sign-up for Level Pay in the fall and average their projected
higher usage winter bills over a longer period oftime.
Respectfully submitted this
~y
of June 2003.
John . ammond
Deput~ Attorney General
Technical Staff: Alden Holm
Michael Fuss
Marilyn Parker
JH:i :/urnisc/cornrnents/intgO3 .llnahrnfussrnp
STAFF COMMENTS JUNE 13 2003
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CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JUNE 2003
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. INT-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
MICHAEL E HUNTINGTON MORGAN W. RICHARDS JR
VP- MARKETING & EXTERNAL AFFAIRS MOFFATT THOMAS ET AL
INTERMOUNTAIN GAS COMPANY PO BOX 829PO BOX 7608 BOISE ID 83701-0829
BOISE ID 83707-1608
JEFFREY C BROOKS
ADVANCED ENERGY STRATEGIES INC
1027 E CAYMAN DR
MERIDIAN ID 83642
SE REpy
CERTIFICATE OF SERVICE