20060719Answer.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY RECEIVED
555 SOUTH COLE ROAD. P.O. BOX 7608 . BOISE, IDAHO 83707 . [phone] . FAX: 377
1866 JUL /9 PH 2: 12
IDAHO PUBLIC
UTILITIES COMMISSION
July 19, 2006
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
O. Box 83720
Boise, 1083720-0074
Re:Formal Complaint filed by Ms. Jane Robinson
IPUC CASE NO. INT-06-
Dear Ms. Jewell:
In response to the Formal Complaint filed by Ms. Jane Robinson Service Dated June 30 , 2006
and pursuant to the above referenced Case Number, Intermountain Gas Company respectfully
submits its answer in defense of said Complaint.
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Director
Gas Supply and Regulatory Affairs
MICHAEL P. MCGRATH
INTERMOUNTAIN GAS COMPANY
555 South Cole Road
O. Box 7608
Boise, Idaho 83707
[phone]
Fax: [phone]
Representative for Intermountain Gas Company
RECEIVED
2006 JUL I 9 PH 2: 12
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
JANE ROBINSON
Complainant
vs.
INTERMOUNTAIN GAS COMPANY,
Respondent.
INT -06-Case No.
ANSWER OF INTERMOUNTAIN
GAS COMPANY
Intennountain Gas Company (the "Company" or "Intennountain ) hereby respectfully submits its
Answer in regards to the above referenced Case Number.
Ms. Jane Robinson is disputing the magnitude of her natural gas usage at her residence located at
10225 Hackamore Drive, Boise, Idaho for the period beginning on December 20 2005. Ms. Robinson
remained current with the payment of her natural gas bills prior to this December Date.
Ms. Robinson harbors a belief that her measured natural gas consumption was in error -especially in
light of the fact she had conscientiously and aggressively used her wood burning fireplace during this
past winter period.
As part of an earlier effort to resolve Ms. Robinson s natural gas usage concerns, on February 6 2006
a visual inspection of Ms. Robinson s natural gas meter was perfonned. This visual inspection
concluded that Ms. Robinson s natural gas meter, as well as the accuracy of an earlier Mobile
Automated Meter Read, were both within allowable tolerances. As an added precaution, and as
requested by a member of the IPUC Staff, on March 8, 2006 Intennountain removed the natural gas
meter at Ms. Robinson s residence for testing. The meter was tested and found to be accurate. The
replacement meter installed at the residence had earlier been tested for accuracy and was also shown to
be accurate.
ANSWER OF INTERMOUNTAIN GAS COMPANY -
While Intennountain Gas Company s technicians were on-site to remove Ms. Robinson s meter for
testing, they also perfonned a diagnostic inspection on both her natural gas furnace as well as her
natural gas water heater. Inspection protocol required that the equipment be tested under a range of
high-to-Iow thennostat settings. Unfortunately, Ms. Robinson viewed this procedure as requiring an
unwarranted use of natural gas. Both her furnace, as well as her water heater, were found to be in good
working condition and both met equipment usage specifications. Also as part of Intennountain
equipment inspection, the technician shared with Ms. Robinson his concerns regarding the location of
the fireplace in relation to the location of the natural gas thennostat, the fact that all the heating
registers and interior doors remained closed and that there was no return heating register co-located
with the fireplace. All these factors conspired to lessen the efficiency of not only Ms. Robinson
fireplace but also her natural gas furnace.
As pointed out in Ms. Robinson s Complaint, the index on her replacement meter began at "0492" and
Ms. Robinson had a concern that she would be billed for the total volumes shown on the meter to
include the beginning units. Replacement meters do not have their index reset to zero but, for billing
purposes, the beginning units are documented and used by Intennountain s billing department to
represent a zero "0" unit beginning balance.
Intennountain believes that Ms. Robinson s use of a wood fireplace did indeed lower her consumption
of natural gas. A review perfonned on Ms. Robinson s winter usage showed that her natural gas
consumption this past winter, on a per Heating Degree Day ("HDD") basis, was actually lower per
HDD as compared to previous winters when natural gas was used as the primary heating source.
Intennountain Gas Company apologizes to Ms. Robinson for any disrespect she believes she was
shown or any clouded communication she believes she was given while corresponding with the
Company on this matter.
Ms Robinson s natural gas bill currently stands at $916.67. Of this total balance, $445.69 is for natural
gas consumed after the meter change out and equipment inspection perfonned on March 8th
Wherefore, Intennountain Gas Company respectfully requests that the Complainant, Ms. Jane
Robinson, be required to pay the $916.67 billing deficit presently owed to Intennountain Gas
Company. Intennountain requests that the $445.69 amount representing usage after March 8 th be due
and payable within Ms. Robinson s current billing period. Intennountain would like to make payment
arrangements with Ms. Robinson for the balance that would remain owing, or $470., to be paid over
the length of time this matter remained in dispute, or approximately seven (7) months. Intennountain
requests that the Complaint be dismissed without further action by this Commission.
Dated this 19th day of July, 2006.
Intennountain Gas Company
ANSWER OF INTERMOUNTAIN GAS COMPANY - 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 19th day of July, 2006, I served a copy of the within and
foregoing document upon:
Ms. Jane Robinson
O. Box 190356
Boise , 10 83719
Ms. Jane Robinson
10225 Hackamore Drive
Boise, 10 83709
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
O. Box 83720
Boise , 1083720-0074
Morgan W. Richards
804 East Pennsylvania Lane
Boise, 10 83706
By depositing true copies thereof in the United States Mail, postage prepaid , in envelopes addressed
to said persons at the above addresses.
ANSWER OF INTERMOUNTAIN GAS COMPANY -