HomeMy WebLinkAbout20070613Answer.pdfEXECUTIVE OFFICES
INTERMOUNTAIN INDUSTRIES, INC.
555 SOUTH COLE ROAD. P.O. BOX 7608 . BOISE, IDAHO 83707 . (208) 377-6000 . FAX: 377:61)97 'o
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June 12 , 2007
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
PO Box 83720
Boise ID 83720-0074
Re:Formal Complaint filed by Tessa Leseberg, on behalf of Ralph W. and Wanda
H. Leseberg
IPUC CASE NO. INT-G 07-
Dear Ms. Jewell:
In response to the Formal Complaint filed by Tessa Leseberg, dated May 22 2007
and pursuant to the above referenced Case Number, Intermountain Gas Company
respectfully submits its answer in defense of said Complaint.
Sincerely,
Terri Shoen
Director Customer Services
TERRI SHOEN
INTERMOUNTAIN GAS COMPANY
555 South Cole Road
O. Box 7608
Boise, Idaho 83707
(208) 377-6000
Fax: (208) 377-6097
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Representative for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TESSA LESEBERG,
on behalf of RALPH W. and WANDA
H. LESEBERG
Complainant,
vs.
INTERMOUNT AIN GAS COMPANY
Respondent.
Case No.INT-07-
ANSWER OF INTERMOUNTAIN
GAS COMPANY
Intennountain Gas Company (the "Company" or "Intennountain ) hereby respectfully submits its
Answer in regards to the Complaint filed by Tessa Leseberg, daughter of customers Ralph and
Wanda Leseberg.
Ralph and Wanda Leseberg are customers of Intennountain Gas Company and have taken
continuous service at 111 E 2nd N in St. Anthony, Idaho since September 8 , 1999.
Meter Number 435735 was set at this property on July 16 2002. On January 4 2007, the meter
usage appeared on the company s meter read low usage report. Consumption for recent months
had fallen below prior historical usage. As a result, a service order was generated on January 16
2007, requesting the meter be checked by a Company Service Technician. A Company Service
Technician was dispatched to the Leseberg s and found the meter was not registering properly,
rather than being completely inoperative. The meter was progressively slowing down over a
period of time (Exhibit A). Meter was replaced with new Meter Number 488718. Meter Number
435735 was tested in the Company s Meter Shop on April, 2, 2007; a broken wriggler was
discovered. The wriggler is the linkage between the meter and the index and its proper operation
is critical to the accuracy of the meter (Exhibit B). After setting the new meter, a follow up read
was taken on February 1 2007, by the Automated Meter Reading System. We found that the
Lesebergs were using 4.43 CCF of natural gas daily during the period of January 16 2007 and
February 1 2007 , which was 90% higher when compared to the same period of
time for the previous year. When comparing to their 2005 usage, 4.43 CCF daily usage was 40%
more natural gas during that time period.
ANSWER OF INTERMOUNTAIN GAS COMPANY -
As a result, the follow up read demonstrated a considerable increase over historical usage, even
when taking differences of weather into consideration. The adjusted estimated usage was created
based on actual 2005 historical usage, which we believe was consistent with the Leseberg s typical
usage pattern. By using 2005 , as a base year, the calculated adjustment weighed in favor of the
Leseberg s (Exhibit C and D).
On February 2, 2007, a letter and an adjusted billing were sent to Ralph Leseberg, advising him of
the error and a corrected bill showing the adjusted amount of $496.76 (Exhibits C-E & F). On
February 7, 2007, Wanda Leseberg contacted Intermountain requesting to speak to a Supervisor
concerning the adjusted statement. The infonnation was taken by the Call Center Representative
and forwarded to the Idaho Falls District Manager.
On February 13 2007, Lynn Davis, Idaho Falls District Manager, contacted Mrs. Leseberg. After
discussing the adjustment with her, the account was set up with a $63.00 level payment. She also
agreed to pay an additional $41.40 per month on the adjusted amount of $496., until the balance
was paid in full (Exhibit G and H). Later that day, Tessa Leseberg, daughter of Ralph and Wanda
contacted the Idaho Public Utilities Commission Consumer Investigation Department, regarding
the adjusted statement. Tammie Estberg received the complaint. Intennountain Gas Company
Credit Manager, Mike Kingery responded to Tammie Estberg s e-mail on February 14 2007. Mr.
Kingery provided the four year history and adjustment calculations (Exhibits C & D). In regards
to the Staffs communication ofthe customer s billing infonnation to the daughter, it appears that
the Staffs interpretation ofthe IPUC Rules of Procedure (Rule 43 01.04) has been waived
(Exhibit I #2 and Exhibit M). Mr. Kingery conveyed the fact that we are fairly limited in what we
can relay and explain to the daughter regarding payment arrangements without documented
pennission from the customer or a power of attorney.
On March 13 2007, Mr. Kingery, advised the staff investigator, Tammie Estberg, that the results
of the meter test had not yet been completed. Staff then requested a copy of the meter test results
when available.
On March 28, 2007, Staff advised Intennountain that the customer was filing a fonnal complaint
the following week and needed the test results. April 3 , 2007, Intennountain contacted the Staff
Investigator with the results of the meter tests. On April 20, 2007, the Staff Investigator faxed the
fonnal complaint, in addition to, two (2) letters that had been prepared by the Staff Investigator.
These were responses to the fonnal complaint, which Intennountain had not seen nor been part of
preparation (Exhibit J - Pages 1-14). These letters were incorrect and misled the customer into
believing the following:
I. The adjusted billing calculated by Intennountain was incorrect.
2. Intennountain s equipment problem was not a malfunction.
3. The Company may have experienced a broken wriggler when the CT Metering
Software was installed (Refer to #3 below, regarding C.T. Metering Software).
4. That a recalculated billing prepared by a Staff Engineer with the Idaho Public
Utilities Commission was more accurate than that calculated by the Company.
Intermountain respectfully submits the following response:1. We are in compliance with the Idaho Public Utilities Rule 204.01.02.03 - Inaccurately
Billed Service under Correct Tariff Schedule - Failure to Bill for Service. This Rule
enables Intennountain to retroactively bill back to the time period that can be reasonably
detennined (Exhibit K).
ANSWER OF INTERMOUNTAIN GAS COMPANY - 2
2. Given that this situation was a result of a slow meter rather than a broken meter, the length
of time to accurately identify the problem was reasonable.
3. The C.T. Metering Software statement was made in error by the Idaho Public Utilities
Staff Investigator (e-mail dated May 4, 2007), has no bearing on this case. Intennountain
installed the Electronic Remote Transmitter (ER T), during the Company s Automated
Meter Reading Project. Staffs assertion that the bent and ultimately broken wriggler
installed by the Company during the project, might have created the malfunctioning
wriggler is speculative. There is no definitive proof that the wriggler was bent at the time
of the project.
Intennountain s adjusted billing calculation included; reviewing the registered usage between
January 16 2007 and February 1 2007 on the new meter. The daily usage was 90% higher than
during the same time period in 2006. The usage was 40% more than the usage had been in the
2005 same time period (Exhibit D). As a result; the adjusted bill was estimated based on the 2005
historical usage. A secondary calculation was created by an Idaho Public Utilities Staff Engineer
using a binomial equation for predictive thenns to degree days (Exhibit L). While the Company
disagrees with the methodology used to come up with the revised calculation, Intennountain
initially agreed to settle on the revised amount of $415.46, in order to prevent further confusion
for the customer. Intennountain has since developed a calculation combining historical usage with
the customer s cycle specific heating degree days. This calculation was applied to the Lesebergs
account and resulted in a calculation of$499.86. The two (2) thenn increases over
Intennountain s original estimation results in a variance of less than one-half of one percent
(Exhibit L).
Wherefore, Intennountain Gas Company respectfully requests that the customer, Ralph and
Wanda Leseberg, be required to pay the adjusted bill of $499.86 presently owed to Intennountain
Gas Company. Intennountain requests that the $499.86 amount, representing usage after January
2007, be due and payable within the Leseberg s current billing period.
Intennountain apologizes to Mr. and Mrs. Leseberg for the inconvenience this has caused. Again
we are more than willing to enter into a payment arrangement on the $499., to be paid over the
next twelve (12) months.
Intennountain requests that the Complaint be dismissed without further action by this
Commission.
Dated this lih day of June, 2007
Intennountain Gas Company
em Shoen
Representative for Intermountain Gas Company
ANSWER OF INTERMOUNTAIN GAS COMPANY - 3
CERTIFICATE OF MAILING
I HEARBY CERTIFY that on this twelfth day of June , two thousand and seven, I served a
copy of the within and foregoing document upon:
Tessa Leseberg
111 E 2nd N
Saint Anthony, ID 83445-1517
Ralph and Wanda Leseberg
111 E 2nd N
Saint Anthony, ID 83445-1517
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
PO Box 83720
Boise, ID 83720-0074
By depositing true copies thereof in the United States Mail , postage prepaid , in envelopes
addressed to said persons at the above addresses.
Director Customer Services
ANSWER OF INTERMOUNTAIN GAS COMPANY - 4
SERVICE ORDER Service Trip
800-548-3679. Boise Area 377-6840. www.intgas.com
AM/PM LL Cycle RouteNo 78902
Intermountain Gas Company
Customer Service.
Premise Number
3012975
Date To Work
1/16/07
Scheduled Activity
Name Leseberg, Ralph W
C/O Name Leseberg, Wanda H
Service Address 111 E 2 N
Ordered by 10635
Contact Home 208-624-7182
Std Cmp Usage Read Comments: Dead meter
Cell
Instructions
Exhibit A
Town
St Anthony
Fee
Work
Narrative
Cross Street Sub
Special Directions
Order 91968740
Taken By 102521/16/072:09
Meter 435735
Meter Loc East
ERT # 0019448128
Size Drive RateAC-250
Meter Bill Pres Cust Del Pres
Last TestSet Date 7/11/02
Service Line 642
Tamper Count Magnetic
Previous Read 2146
GPS Reads:Latitude 43.96861
Completed Activity
Completed By
Ext Relief Valve
Tilt Date
Longitude 111.68081
RemovelReplace ERT Remove/Replace Meter Relight
Appliances
Type No.Activity
Central Heat
Rate RS1
10635 Date 1/16/07 Arrival Time Secure Time Departure Time
ERT Read
ERT Tamper
Index Read
Magnetic
SetlReplace Meter ERT#
Drive Rate
ERT Read
Ext Relief Valve ( YES NO / NA )Drive Rate
Size Meter Bill Pres Cust Del Pres
Pressure Found Lockup Found Pressure Left
Observed Test Hand ( YES NO )( YES NO )Movement
Index Read
Tag Date Appl Reason
Lockup Left
Comments
Customer Signature
Utility Charge
Exhibit A
INVESTIGATION INFORMATION
Gas Odor Inside Gas Odor Outside
Initial Reading:
Line Break Structure Fire
GASLocation Instrument Zeroed:LEL ppm C.
Source:
Comments I Actions Taken:
Results:
Verification Readings:
Meter Spot Test Results: Test Hand Size
LEL GAS ppm C.
Minutes Observed:CFH Usage:
INSPECTION INFORMATION (CIRCLE ONE)
Pressure Test Approved Tagged:YES NO ~psi Test Witnessed:
Clearances Approved:Pipe Size:YES Number of Appliance Outlets:
Pipe Wrapped:YES NO Pipe Fittings Meet Code:
YES
YES Regulators Vented:
YES NO
YES NO
Venting Per Manufacturer's Instructions:Combustion Air:YES
Duct Work Intact:YES Return Air Intact:YES Temporary Heat:YES
Job Approved:YES
Comments I Actions Taken:
Results:
(PLEASE PRIN1)
DEFINITIONS
YES APPROVED NO NOT APPROVED NA NOT APPLICABLE ENTERED BY.
Service Order Details.
!!Not for Line Locates!!
Order Number: CW91968740
Exhibit A
Service Link Order Completion Details (CI7990)
CW91968740 Page
MDD Details
Created: 1/16/2007
Acknowledged:Assigned: 1/16/2007
Dispatched: 1/16/2007
Premise Information
2:09: 15PM
2:09:17PM
2:09:18PM
Enroute: 1/16/2007 2:11:06PMOnsite: 1/16/2007 2: 11: 1 OPM
Completed: 1/16/2007 2:13:25PM
Assigned Tech: 10635 (Bird)
Job Code: Service Trip
Sub-Type Description:
Address: 111 E 2 N
Cross Street:
City: St Anthony
Phone Number:
Cell Phone Number:
Landlord Agreement: No
Premise: 3012975
Appointment Time: 1/16/2007 8:00:00AM
ERT Number: 0019448128
Customer: Leseberg Ralph W
Requested By: 10635
Map Number:
Instructions: Change out dead meter per tech
Directions:
Activity Information
Activity 1: Remove/Replace ERT
Activity 2: Remove/Replace Meter
Activity 3: Relight
Activity 4:
Activity 5:
Service Fee:
Final Comments:
Equipment
Subdivision Name:
Service Location:
Contact Phone Number: 208-624-7182
Work Phone Number: X
Route Code: 78902
Read Cycle: 1
Rate: RS1
Meter Number: 435735
Co-applicant: Leseberg Wanda H
Legal Address:
Activity 6:
Activity 7:
Activity 8:
Activity 9:
Activity 10:
Taken By: srobinson
Latitude: 43.9686
Meter Location: East
Meter Size:
Previous Read Value: 2 146
Billing Pressure: 0.
Tamper Count:
Tilt: 1
External Relief Valve:
Service lineN umber: 642
Longitude: -111,6808
Meter Set date: 7/11/02
Test Date:
Previous Read Date: 1/2/07
Delivery Pressure:
Tamper Date:
Magnetic: 0
Standard Completion Review
Waive Fee: N
Standard Completion Comments:
After Hours: N
Additional Comments:
Standard Completion Usage Read Review:
Usage Read: 2 156
Usage Read Comments:
Dead meter
Drive Rate Found: 1
CW91968740 Page 2 of
Standard Completion ERT Read Review
ERT Read: 0
ERT Read Completion Comments:
Relite space heater.
Inspection Review
Pressure Test Approved:
Test Witnessed By:
Inspection Comments:
Drive Rate Found: 1
Pressure Test PSI:
Pipe Size Correct:
Clearences OK:
Fittings OK:
Venting Per Mfg Instructions:
Duct Work Intact:
Temporary Heat:
Collection Review
Amount Collected:
Non Pay Reason:
Install ERT Review
Installed ERT ID: 58,462 649
Drive Rate: 1
Install Meter Review
Number of Outlets:
Pipe Wrapped:
Regulators Vented:
Combustion Air:
Return Air Intact:
Job Approved:
Payment Method:
Install Read: 0
Installed Meter Number: 488 718
Install Usage Read: 0
Install Delivery Pressure: 0.
Temp Compensated: N
Pressure Found: 7.
Lockup found: 8.
Observed Test Hand: Yes
External Relief Valve: No
Investigation Review
Secure Time: :
Gas Odor Inside:
Gas Odor Outside:
Location Instrument Zerod:
Initial Gas Reading:
Source:
Verification Gas LEL:
Meter Spot Test Hand Size:
Meter Spot Test Minutes Observed:
Investigation Comments:
Installed Meter Size: AC-250
Install ERT Drive Rate: 1
Install Billing Pressure: 0.
Press Compensated: N
Pressure Left: 7.
Lockup Left: 8.
Movement: No
CO Found:
Line Break:
Structure Fire:
Initial Gas LEL:
Initial CO PPM:
Verification CO PPM:
Verification Gas Reading:
Meter Spot Test CFH Usage:
Investigation Results:
Remove and Replace Review
Install Usage Read: 0
Delivery Pressure: 0,
Temp Compensated: N
Remove Reason
Remove Reason Text: Dead meter and ert.
Remove Reason Desc: Dead Meter
ERT Tamper
Tamper Indicator:
Billing Pressure: 0.
Pressure Compensated: N
Tilt:
Magnetic:
Tamper Comments:
Exhibit A
Red Tag Information
Equip/Comments
Meter Station Condition Check
I ndex Drive:
Relief Set Pressure:
CW91968740 Page 3 of
Tag Reason Tag Date
PSI Left:
Repair Code:
Exhibit A
Clear?
Exhibit B
INTERMOUNT GAS COMPANY
METER SHOP
SPECIAL TEST REPORT
Company #435735
Meter Type AC-250
Account #6725575
ER T Number 19448128
Removed For:Dead
Mfg. # AOO136567 Date 04/02/2007
Set Date 07/16/2002 Remove Date 01/16/2007
Index Read 2037
ERT Read 2156.
Removed By:Lewis Bird.
Customer Name
Customer Address 111 E. 2nd. N. St. Anthony Idaho
Prover Room Temp. Prover Temp.
Test Data Check Test:099.4 Open Test:099.
Meter Drive Rate:1 Ft.ER T Drive Rate: 1 Ft.
Tamper Seals:Yes No
Tested By:Mr. Mark Cirelli Witnessed By:John Atwater
Test Requested By: Mr. Lynn Davis Location:Idaho Falls
Comments :Broken Wriggler. Please Note Meter and ERT Reads.
Retain in Mtr. Shop: lJ8JJ Date:04/02/2007 Return to District: CD Date:
Copies:Original - Meter Shop Second - Requesting Mgr. / Office Third - Credit Mgr.
JOC Fonn # 530
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Exhibit E
CU$tomer Services
Intermountain Gas Company
555 South Cole Road
O. Box 7608 ' Boise, 1083707-1608
www,intgas.com
Ralph W Leseberg
111 E2nd
Saint Anthony. 1083445
February 2, 2007
RE: 111 E 2 N
Dear Mr. Leseberg:
During an audit of your account we discovered your meter has not been registering your
natural gas usage accurately. Further investigation has revealed it has been
malfunctioning since February 2006.
Historical usage in combination with weather data for this time period has enabled us to
evaluate your natural gas consumption for this period.
The usage adjustment for the time frame in question is as follows:
Month Therms Amount
Please see attached
A charge of $496.76 for therms you used but were not billed for will be reflected on your
next billing statement. We value you as a customer and apologize for any inconvenience
this may cause and are happy to make payment arrangements with you.
Please contact our Customer Service Center at 1~800-548-3679 to. make needed
arrangements or to answer any questions you may have. Thank you in advance for your
understanding.
Cordially,
),~~ ~
Billing Technician
Intermountain Gas Co.
Boise / Treasure Valley (208) 377-6840 . Other Areas (800) 548.3679 . FAX (208) 377-6081nt\ ~ '... 7.nn ~ ~ .~..;~ 0:.
~~ '6
Exhibit F
" ..
~~~~~~OUNTAIN GAS COMPANY
Boise. Idaho 83732
www./ntgas.com
(800) 548-3679
Call 7 AM - 7 PM Mon-Fri
SERVICE ADDRESS: 111 E 2 N, Saint Anthony, 10 83445
READING DATES
PAYMENT DUE DATE
Mar , 2007 53852700-001-Level Pay $63.
ACCOUNT NUMBER PAY THIS AMOUNT
Total of Account - Previous Billing
Payments Received
Balance Forward
$231.28 CR
$0.
$231.28 CR
FROM
Feb 01 Mar 01
METER READINGS
FROM TO = 100 CU FT X BILLING FACTOR = THERMS BILLED169 98 0.959
TYPE OF RATE
RS1
THERMS RATE
10287
CHARGE
$103.
$6.
$3.
$496.
BILLING DATE
Mar 06, 2007
I I CURRENT ACTIVITY
Current Usage
Customer Charge
Municipal Franchise Fee
Billing Adjustment
AVERAGE THERMS PER DAY
THIS YEAR LAST YEAR3.4 1.Total Current Activity
Balance Forward
Total of Account
Level Pay Due March 20, 2007
$610.
$231.28 CR
$378.
$63.
Effective February 12, 2007, Intermountain Gas changed credit card payment vendors from SpeedPay to BiliMatrix. To pay by phone
call toll free 1-866-558-2808, or visit our website at www.intgas.com. BiliMatrix charges a $2.75 convenience fee for each payment.
INTERMOUNTAIN GAS COMPANY
.. P,O, Box 64
, Boise. Idaho 83732
www.lntgas.com
PAYMENT DUE DATE
Mar 20, 2007
ACCOUNT NUMBER
53852700-001-
PAY THIS AMOUNTLevel Pay $63.
538527000010000006300
BALANCE FORWARD
$231.28 CR
CURRENT CHARGES
Ralph W Leseberg
Wanda H Leseberg
111 E 2nd N
Saint Anthony, 1083445-1517 $610.
TOTAL OF ACCOUNT
$378.
11..1'1.11..111 1..1'11.11.1"11 111...1'11 11111 1111...AMOUNT ENCLOSED
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Exhibit H
From:
To:
LINDSAY
Date:
Subject:
LYNN DAVIS
FISETTE, MELINDA;IMLACH, CHERYL;SEVERE, PAM;WROBLEWSKI,
2/13/2007 10: 05: 04
Re: Fwd: forward to supervisor about dead meter in St Anthony
Lindsay;
Just talked, , to Mrs. Lesebert. She will call to go back on
level pay after missing the last two payments and agreed to make additional
payments of $41.40 per month to payoff the 496.76. I gave her your name in
case she has any problem getting set up with these arrangements.
Thanks, Lynn
Lynn Davis
District Manager , Idaho Falls
Intermountain Gas Company
(208) 542-6621 phone
Idavis0intgas. com
??? PAM SEVERE 2/7/2007 3: 00 PM ???
Customer Ralph Leseberg
III E 2 N in St. Anthony
It appears the customer called the CSC about the adjustment on this dead meterin St. Anthony. I haven t received any notification of an adjustment on this
customer but looking at the statement, I'm assuming that the adjustment was
only for the January usage and no letter or spreadsheet was issued.
From what I see on the statement, the customer actually used 71 feet on the
new meter and we showed usage on the old meter of 62 feet. Again, I'
assuming that the 62 feet is the estimated usage for Jan 02 to Jan 16 was
based on the actual usage which averaged 4.43 feet per day for those days.
There were no notes in the customer or premise log to go by.
Let me know if I'm assuming right and I'll return the call to the customer.
Thanks so much
??? MARGARITA ROMERO 2/7/2007 12: 45: 05 PM ???
Forwarding info to your office. Customer requesting call back on dead meter
computation.
??? DIANA HALE 2/7/2007 12: 31 PM ???
account 53852700 Ralph Leseberg at III E 2 N
and explain how we came up wi th the usage on a
call in am
Wanda wants supervisor to call
dead meter. 624-7182 perfer
From:
To:
Date:
Subject:
LINDSAY WROBLEWSKI
MIKE KINGERY
2/13/2007 11: 48: 57
Re: Fwd: forward to supervisor
Exhibit H
about dead meter in St Anthony
Mike,
Can you please put this customer back on Level Pay and set up the contract per
Lynn s request?
(61 1J200 DcrNOArvf EDS'FwcFRE:Tdaho :jSUC:LESE B URG~RA1.pH-'--"'-~'-"'----'---~" -~~"'".~'""""'-~=~-Pae21'-.., ,,...,"- -' ---~.------------ .. ------.- '-.-.....--. "..,-----..-.._-.",..""""" .._.._...:
Exhibit I
E-mails 1-
To: Tammie Estberg
Subject: Re: Idaho -PUC- LESEBURG, RALPH (!J
Tammie
I have attached the meter read history and the adjustment calculations.
The district manager had spoken with Wanda Lesebert and she indicated she would like to restart Level
Pay and have the adjustment added into that calculation. The last payment received was on 11-10-2006.
We have agreed to set up the account on Level Pay with the debit balance. The calculation came to
$63.00.
We are fairly limited in what we can relay and explain to the daughter regarding payment arrangements
without documented permission from the customers or a power of attorney.
Mike Kingery
Credit & Collection Manager
Intermountain Gas Company
208.377.6069
;:.;:.;:.
TESTBER o:::TESTBER(g)puc.idaho.gov;:. 2/14/20071:35 PM
;:.;:.;:.
IDAHO PUC/208-334-0300 voice/208-334-3762 fax
exec. referral: N inv : TESTBER
service class: RES
reason
pucJd
(j)
: 88664
ress: 1 EAST 2ND NORTH
cust city : ST. ANTHONY
cust state :
cust zip : 83445
cust phone : 2086247182
0:::0:::0:::0:::0:::0:::0:::0:::0:::0::: begin narrative
;:.;:.;:.;:.;:.;:.;:.;:.;:.;:.
Sent: Tuesday, February 13, 2007 11 :58 AM
Subject: Tessa Leseburg, 624-7182; has gas meter issue w/lntermountain Gas.
02/14 Cd Tessa -her parents Ralph and Wanda (senior citizens) recently received billing from company
stating they owed $157.75 that is much higher than their normal level payments. When she called
company to ask what was going on, explanation was that the meter was not working
properly so compahY changed meter and adjusted billings from last february to current which would add
another $496 to customer s bill. Her parents fixed income will not allow them to make these kinds of
payments. Doesn t company have some responsiblity to make sure their equipment is working
correctly? Also company stated that an estamate of 40% consumption was used to figure back billing
increase? Explained to customer that PUC rules do allow for adjusted billing period but company was
required to explain how adjustment was figured and provide same time amount of time to
pay back. Tessa confirmed INTG did mention the pay back could take same number of months but it
would not matter as her parents income would not allow for such high payments.
INTG - Please provide 4 year history and explaination of meter problem with breakout of adjustments.
Read Date Billed Usage Metered Usage Read Num2/1/2007 71
1/16/2007 1/16/2007 62 1/2/2007 19 12/1/2006 11/1/2006 10/2/2006 9/1/2006 8/1/2006 7/3/2006 6/1/2006 5/1/2006 4/3/2006 3/1/2006 35 2/1/2006 65 1/3/2006 118 12112/1/2005 73 11/1/2005 41 10/3/2005 14 9/1/2005 8/1/2005
n1~005 12 W1~005 21 5/2/2005 40 4/1/2005 71 3/1/2005 83 2/1/2005 89 1/3/2005 98 10312/1/2004 64 11/1/2004 28 10/1/2004 16 9/1/2004 8/2/2004 6/30/2004 6/1/2004 27 5/3/2004 35 4/1/2004 46 3/1/2004 81 2/2/2004 97 1/2/2004 79 12/1/2003 85 10/30/2003 27 10/1/2003 15 9/2/2003 8/1/2003 7/1/2003
Exhibit I
E-mails 1-
Days Cnt EquipmenUd Code71 16 488718
4887182208 14 4357352146 32 4357352126 30 4357352116 30 4357352110 31 4357352108 31 4357352107 29 4357352107 32 4357352105 31 4357352100 28 4357352093 33 4357352083 28 4357352047 29 4357351979 33 4357351858 30 4357351781 29 4357351736 32 4357351721 31 4357351712 31 4357351704 30 4357351691 30 4357351668 31 4357351625 31 4357351549 28 4357351463 29 4357351371 33 4357351268 30 4357351200 31 4357351169 30 4357351151 30 4357351141 33 4357351131 28 43573529 43573532 43573531 43573528 43573531 43573532 43573531 43573530 43573529 43573532 43573531 43573529 435735
Read Code
MAMR Read
Manual Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MhMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
MAMR Read
Conversion
Conversion
Conversion
Conversion
Conversion
Conversion
r:1version
Conversion
C6~version
Conversion
Conversion
Conversion
Conversion
Exhibit I
E-mails 1-
Estimate lnd
(3)
Q",dI)1II9rI!LIfM ~~ P~::f ~c!Ji~ ~l9.~~ JL~-:f~~!:! ~Q~~~hEEC~:~:= :
~ ,== ~ ===:~"::-=.==: =:===:=:~::::: ~ ::'
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Exhibit I
E-mails 1-
From:
To:
Date:
Subject:
Attachments:
MIKE KINGERY
LUCINDA MEEDS; MIKE KINGERY
2/15/2007 4:39 PM
Fwd: RE: Idaho -PUC- LESEBURG, RALPH
leseberg.xls
Tammie,
Answers are in bold below:(1)
What was wrong with the meter?
The meter was malfunctioning, but rather than going completely dead, it appears to have been
going progressively slower over a period of time.
Was it completely replaced and if so, what was the date? I see there were therms recorded for usage.
The meter was replaced on 1-16-2007
How did company determine that it was not actual usage?
Consumption for recent months fell well below prior historical usage. A technician was
dispatched to inspect the meter.
How was the increase of 40% calculated?
After setting the new meter on 1-16-2007 a follow up read was completed on 2-2007. The 4.43 ccf
of daily use during that time was higher to the comparable time period a year prior as well as
using 40% more during that time period from two years ago.
What factors were used to figure the new calculated usage if company did not feel the meter was working
correctly?
With the follow up read indicating a considerable increase over historical usage and taking the
weather during that time period into account, estimated consumption was created based on actual
historical usage. This resulted in a calculation to the favor of the customer.
Please provide a four year history for this account.
The four year history was included in the original response. I have attached it again , highlighting
when the meter was changed.
Thanks
Mike
;:.;:.;:. "
Tammie Estberg" oo::::Tammie.Estberg~puc.idaho.gov
Mike
What was wrong with the meter?
Was it completely replaced and if so, what was the date? I see there were therms recorded for usage.
How did company determine that it was not actual usage?
How was the increase of 40% calculated?
What factors were used to figure the new calculated usage if company did not feel the meter was working
correctly?
Please provide a four year history for this account.
Also, I heard Wanda (customer of record) answering the daughter s questions while on the phone to me
so I am sure it will not be difficult to fulfilllNTG's requirements to allow Wanda access to information. Until
which time it can be provided to the company, I will only give information to customer.
Thanks
Tammie
-----
Original Message-----
From: MIKE KINGERY (mailto:MKINGERY~intgas.com)
Sent: Wednesday, February 14 20072:44
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Exhibit I
E-mails 1-
From:
To:
Date:
Subject:
MIKE KINGERY
LUCINDA MEEDS
Fwd: RE: Idaho -PUC- LESEBURG, RALPH
FYI
;:.;:.;:. "
Tammie Estberg" o:::Tammie.Estberg~puc.idaho.gov;:. 2/16/2007 1 :40:50 PM
;:.;:.;:.
Mike
Thanks for the information. Sorry about the usage history. I did not get it when I printed the attachments
the first time. I will be out of the office until next Friday for work. I have not had a chance to review the
information and discuss it with the customer. I will follow up with customer and Company when I return,
Thanks
Tammie
-----
Original Message-----
From: MIKE KINGERY (mailto:MKINGERY~intgas.com)
Sent: Thursday, February 15 20074:32
To: Tammie Estberg
Subject: RE: Idaho -PUC- LESEBURG, RALPH
Tammie
Answers are in bold below:
What was w ng with the meter?
The meter wa alfunctioning, but rather than going completely dead, it a
going progressi slower over a period of time.
Was it completely re ced and if so, what was the date? I see there were erms recorded for usage.
The meter was replace on 1-16-2007
How did company determin hat it was not actual usage?
Consumption for recent mon s fell well below prior historical
dispatched to inspect the mete.
How was the increase of 40% calcul ed?
After setting the new meter on 1-16- 07 a follow up read as completed on 2-2007. The 4.43 ccf
of daily use during that time was highe 0 the compar Ie time period a year prior as well as
using 40% more during that time period f m two ye sago.
What factors were used to figure the new calcu ed u ge if company did not feel the meter was working
correctly?
With the follow up read indicating a consider e ' crease over historical usage and taking the
weather during that time period into accou , estim ed consumption was created based on actual
historical usage. This resulted in a calcu tion to the or of the customer.
Please provide a four year history for this count.
The four year hist ry was included in e original respons . I have attached it again, highlighting
when the meter wa:s changed.
;:.;:.;:. "
Tammie Estberg" Tammie.Estberg~puc.idaho.gov;:. 2/15/2007 3: 11 PM
;:.;:.
Mike
What was wrong th the meter?
Was it com pie y replaced and if so, what was the date? I see there were therms recorde for usage.
How did company determine that it was not actual usage?
How was the increase of 40% calculated?
What factors were used to figure the new calculated usage if company did not feel the meter was working
Thanks
Mike
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Exhibit I
E-mails 1-
From:
To:
MIKE KINGERY
Tammie Estberg
(j)
ubject:RE: Idaho -PUC- LESEBURG , RALPH
I have not yet received the results of the meter test. The meter was initially identified due to its decreased
consumption and upon field inspection, the technician determined the meter was dead.
The historical consumption showed a sharp decline compared to prior years beginning in February 2006,
which was the basis for the estimated calculation. Based on the consumption recorded on the new meter
it is possible the malfuntioning meter was registering slowly for a longer period of time than originally
identified.
Mike
;:.;:.;:. "
Tammie Estberg" ..::Tammie.Estberg~puc.idaho.gov;:.
Hello Mike
In reviewing this complaint I would still like to have a copy of the meter test results and a firm explanation
of the meter malfunction. Define the meter malfunction, it appears to not have been a dying meter as the
original reported usage does not show a steady decline.
Thank you
Tammie
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Exhibit I
E-mails 1-
From:
To:
MIKE KINGERY
Tammie Estberg
(j)
Subject:
Attachments:
RE: Idaho -PUC- LESEBURG, RALPH
MeterT estLeseberg ,doc
Tammie
I have received the meter test and it is attached, The broken wriggler prevented the meter from fully
registering consumption, even though the rest of the meter was fully functional.
Mike
)0)0)0 "Tammie Estberg" -c::Tammie.Estberg~puc,idaho.gov)o (f)Mike
Customer is filing a formal complaint next week on this issue. I have not received the meter test results
please provide them asap.
Thanks
Tammie
-----
Original Message-----
From: MIKE KINGERY (mailto:MKINGERY~intgas,coml
Sent: Tuesday, March 13, 2007 10:23 AM
To: Tammie Estberg
Subject: RE: Idaho -PUC- LESEBURG, RALPH
I have not yet received the results of the meter test. The meter was initially identified due to its decreased
consumption and upon field inspection, the technician determined the meter was dead,
The historical consumption showed a sharp decline compared to prior years beginning in February 2006
which was the basis for the estimated calculation, Based on the consumption recorded on the new meter
it is possible the malfuntioning meter was registering slowly for a longer period of time than originally
identified,
Mike
)0)0)0 "Tammie Estberg" -c::Tammie,Estberg~puc.idaho,gov)o 3/13/2007 8:43:12 AM )0)0)0
Hello Mike
in reviewing this complaint I would still like to have a copy of the meter test results and a firm explanation
of the meter malfunCtion. Define the meter malfunction, it appears to not have been a dying meter as the
original reported usage does not show a steady decline.
Thank you
Tammie
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E-malls 1-
From:
To:
Date:
Subject:
MIKE KINGERY
TERRI SHOEN
4/20/2007 3:06 PM
Fwd: Idaho -PUC- LESEBURG, RALPH
::0::0::0 "Tammie Estberg" oo:::Tammie.Estberg~puc.idaho.gov::o 4/20/200711:07 AM ::0::0::0
Mike
The PUC has received a formal complaint from Mr. Leseburg, a copy of which I will be faxing to your
office. In reviewing the informal complaint I do not have a direct response from the company regarding a
possible adjustment to the rebilling.
The informal complaint was opened during a period of conversations between Intermountain Gas
employees handling the adjusted rebilling and PUC staff. During those conversations, it was stated by the
Company that heating degree day mythology is not used when recalculating adjusted billings. A PUC
staff engineer recalculated the billing for the Leseburg s based on degree day heating. It is unclear whither
or not this information was used as an example during discussion between the Company and staff. I am
sending by fax a copy of the calculated adjustment using heating degree day for this customer.
Based on the customer s dispute of the rebilling calculated by the Company and supported by PUC staffs
calculation using heating degree day, is the Company willing to compromise on the rebilling to accept the
21% lower bill reflected in the heating degree day calculations? Is the Company willing to make any
adjustments to its calculated rebilling for this customer?
Thank you
Tammie Estberg
Utilities Compliance Investigator
Exhibit J
Pages 1-
Sv
~\\UT/ES
:s:FAX Correspondence
To: Intermountain Gas Co. Attn: Mike Kingery
Fax: 208-37.7-B:t:rO (('(('
;:/
Date & Time: April 20 , 2007 (11 :13 AM)
From: Tammie Estberg - Compliance InvestigatorRe: Leseburg Complaint
This transmission /~aQe(s) includina the cover sheet.
Feel free to contact me at Tammie. Estberg(ID.puc.idaho.ov or by calling 208-334-0380.
Sincerely,
Formal complaint from Leseburg
Heating Degree Day Calculations
Tammie Estberg
Utilities Compliance Investigator
P. O. Box 83720, Boise, Idaho 83720-0074
Telephone: (208)334-0300 Facsimile: (208)334-3762
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Exhibit J
Page 3
Leseberg Re-Billing Analysis
Historical Use, Prior to Meter Error Period
Therms
calculated
Using
month year Actual Binomial
xxyy Therms Used Hdd'Equation
705
604 137
805
704 6.44
804 124 8.43
605 303 14.48
905 348 16.
904 354 16.
505 469 21.
1004 672 33.
405 721 36,
1005 654 31.
1104 1007 56.
1005 1270 80.42
106 1271 80.
305 1059 61.
1105 1041 59.
205 1201 73.
1204 1222 75.
5012 118 1403 93.
Page 3 of 5 789.
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Exhibit J
Page 5
Leseberg Re-Billing Analysis
Calculated Therms
Therms ActuallyR
Rebilled Billed
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
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Nav
Dee
Jan-115 113
530.569
21%high
Page 5 of 5
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Exhibit J
Page 6
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April 13 , 2007 .
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Idaho Public Utilities Commission
472 West Washington Street
Boise, Id. 83702
RE: Formal Complaint against Intermountain Gas Company
Dear Commissioners
Upon receipt of the February 2007 payment statement, my mother called Intermountain
Gas Company to inquire about the current charge of$157.) which was much higher
than it had been ITom the previous month. She was told that there was an outstanding
bill in the amount of$496.76 (which was not listed on the February billing) and that a
letter would be sent explaining the reason and charges. He indicated that they would
estimate the monthly charges to compensate for a malfunctioning meter. In mid January
someone ITom Intermountain Gas Company came and replaced the gas meter stating that
it was malfunctioning.
We received the letter apprmclmately February 12th to 14th (see enclosed copies).
February 14th I contacted the Idaho Public Utilities Commission and Tammie Estberg
called me back. I wanted to know ifIntermountain Gas Company could actually
retroactively bill for a malfunctioning meter. Tammie Estberg told me she would
investigate and get back to me. When Tammie Estberg called back she indicated' that theCompany is allowed to correct billing errors.
However, everything should be done in a timely period, Their failure to react quickly is
irresponsible and unacceptable. Its incomprehensive to allow anyone 12 months) notonly to discover a malfunction, but then to be able to eStimate and bill for it. How is it
possible for them to know if the home was occupied every single day of every month and
how much they used the furnace during that entire 12 month period. Instead the used
the same Therm calculations from the revious ear and heatin degree data see
enc osed copies).
To further complicate the whole issue) now it seems that Interro.ountaio Gas Company did
ft
Exhibit J
Page 7
not have a malfunctioning meter but instead it was broken wrigglers when the CT
metering software was installed on the meters (see enclosed copies).
Therefore, I submit that the CT metering software company should absorb the cost since
they provided faulty equipment and Intermountain Gas Company should collect the
disputed bill from them. The responsibility needs to be assumed by the above two parties
and not the consumer who can only trust that they are being billed with accurate
equipment and timely maintenance.
Sincerely,
.-lM '-
~.. ~ /.
Tessa Lese
;~"""'-
For Ralph W. Leseberg
Wanda H. Leseberg
111 E. 2nd North
St. Anthony, Id 83445
f~ ~
Exhibit J
Page 8
Customer Services
Intermountain Gas Company
555 South Cole Road
O. Box 7608 ' Boise, 1083707-1608
www,intgas.com
Ralph W Leseberg
111 E 2nd N
Saint Anthony. 10 83445
February 2, 2007
RE: 111 E 2 N
Dear Mr. leseberg:
During an audit of your account we discovered your meter has not been registering your
natural gas usage accurately. Further investigation has revealed it has been
malfunctioning since February 2006.
Historical usage in combination with weather data for this time period has enabled us to
evaluate your natural gas consumption for this period.
The usage adjustment for the time frame in question is as follows:
Month Therms Amount
Please see attached
A charge of $496.76 for therms you used but were not billed for will be reflected on your
next billing statement. We value you as a customer and apologize for any inconvenience
this may cause and are happy to make payment arrangements with you.
Please contact our Customer Service Center at 1~800-548-3679 to, make needed
arrangements or to answer any questions you may have. Thank you in advance for your
understanding.
Cordially,
\. '
Billing T~chnician
Intermountain Gas Co.
Boise Treasure Valley (208) 377-6840 . Other Areas (800) 648.3679 . FAX (2.08) 377-6081
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Exhibit J
Page 10
IDAHO
PUBLIC UTiliTIES
COm'mlSSIOn
Dine Kernpthome. Governor
O. Box ,83720, Boise, Idaho 83120-0074
Paul Kjellander, President
Marsha H. Smith, Commissioner
Dennis S. Hansen, Commissioner
March 29,2007
Tessa Leseburg
Ralph Leseburg
111 East 2nd North
St. Anthony, 10 83445
R E' lI1tl':tlTIQI.l11ta.1n G;:t..~ adjusted biBing
Dear Tessa
J have researched your complaint questioning the accuracy of Intermountain Gas Company s re-
billing of this account. The Company states that the meter was not working properly resulting in
the account being billed for a portion of the actual usage. The Company is allowed to COITect a
billing error under Utility Customer Relations Rules (UCRR) 204. I have enclosed the Company
proved spreadsheet showing the billed amount and the adjusted bi1ljng. UCRR 313 requires a
utility to accept payment an-angements extending for the same duration oftime covered in the
adju5ted billing. Intermountain Gas states it has addressed payment arrangements with you.
During our phone conversation, you indicated that you would like information on filing a Formal
Complaint. It is not necessary to have an attorney to file a Fonnal Complaint. Enclosed are
instructions on filing a Fonnal Complaint with the PUC, copies of the UCRR that address back
billing and payments of the amounts adjusted, copies of the information provided from
Intermountain Gas for this account, and a calculated fe-billing done by PUC Staff engineer. The
example PUC re-bi1ling, used an industry standard formula that includes heating degree day.
method. Heating degree day method is not used by Intermountain Gas. I am unable to explain
the company s method any further than what they have already provided. Our office is still
waiting foT the results of the meter testing from the Company which should show why and
what percentage the meter may have been misreading.
If you have further questions, please f~el free ~o contact me again.
Sincerely,
-' .. ,
:-:7
"- ---.., ,(;';'~~--,--,
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Tammie Estberg
Utilities Compliance Investigator
800-432-0369
Located at 472 West Washington Street , Boise , Idaho 83702
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Exhibit J
Page 11. ,p;,\.;
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Read Date Billed Usage IMetered Usage Read Num
21-1/2007 71
1116/2007
1/16/2007 62
1/212007 19 12/1/2006
11/1/2006 10/212006 . 9/1/2006
8/1/2006
7/3/2006
6/1/2006
5/112006 4/3/2006 ' 9 1 03/1/2006 35 2/1/2006 65 1/312006 118 121
12/1/2005 73
11/1/2005 41 1013/2005 14 9/1/2005
8/1/2005
7/1/2005 12 6/1/2005 21
5/212005 40
4/1/2005 71
3/1/2005 83
2/1/2005 89 1/3/2005 98 10312/1/2004 64 11/1/2004 28
10/1/2004 16 9/1/2004 8/2/2004 9 .6/30/2004 6/1/2004 27
5/312004 35 4/1/2004 46 3/1/2004 81 2/212004 97 1/2/2004 79 12/1/2003 85 10/30/2003 27 29
10/1/2003 15 9/2/2003 8/1/2003
7/1(2003
Days Cnt EquipmenUd Cbde ,Read Code71 16 488718;MAMR Read
468718: Manu~1 Read2208 14 435735i2146 32 43573S;MAMR Read2126 30 43573S:MAMR Read2116 30 435735~ MAMR Read2110 31 435735: MAMR Read2108 31 435735: MAMR Read2107 29 435735! MAMR Read2107 32 43573S! MAMR Read2105 31 435735 MAMR Read2100 28 435735: MAMR Re8d2093 33 435735 , MAMR Read~O83 28 435~~Ii MAMR Read2047 29 4357~f MAMR Read1979 33 435735: MAMR Read1858 30 435735' MAMR Read1781 29 435735~ MAMR Read1736 32 435735 MAMR Read1721 31 435735 MAMR Read1712 ,31 435735 MAMR Read1704 30 435735 MAMR Read1691 30 435735 MAMR Read1668 31 435735 MAMR Read1625 31 435735 I ~R Read1549 28 435735i MAMR Read1463 29 435735; MAMR, Read1371 33 435735: MAMR Read1268 30 435735i MAMR Read1200 31 4357351 MAMR Read1169 30 435735j MAMR Re~d1151 30 435735 ,MAMR Read, 1141 33 435735 MAMRRe.ad1131 28 435735 Conversion29 435735 Cohversion32 42573-5 Conversion31 435735 J Conversion28 435735 Conversion31 435735 Colwersion32 4357351 Conversion31 435735 i Conversion30 435735! Conversion29 435735! Conversion32 435735 i Conversion31 435735 Conversion29 4357aS. Conversion
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Exhibit J
Page 12
fo C~Y""faJlI\(~alculated Therms Re-
Therms Rebilled Billed
115
530.
, 75
1 i
113
569
21 % high
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Exhibit J
Page 13
IDAHO
PUBLIC UTiliTIES
COmmiSSiOn
Dirk Kempthome, Governor
O. Box 83720, Boise, Idaho 83720-0074
Paul KjelJander, President
Marsha H. Smith, Commissioner
Dennis $. Hansen, Commissioner
April 3,2007
Tessa Leseburg
Ralph Leseburg
111 East 2ad North
S1. Anthony, ID 83445
RE: Intermountain Gas Meter
Dear Tessa
Attached is the meter test results supplied by IntennountaiJJ Gas for the meter at your address.
Intermountain Gas now states that the problem was not a malfunctionin meter but rather a
bTOken wriQ:g A wriggler is involved in the recording consumption information used by
e Company to detennine the billing.
The Company may have experienced a number of broken wrigglers when the CT Metering
software was installed on meters, CT Meters enable the Company to, collect coDsumption
readings by remote receivers-
Please let me know if you have further questions.
Sincerely,
----
" r
--"
L.--~~ _.
~ :~;\---
Tammie Estberg "
Compliance Investigator
208-334-0369
Located at 472 West Washington Street, Boise, IdaJ:'lo 83702
._--.__._-~-,---,-........-........
Exhibit J
Page 14
INTERMOUNTAI~ GAS COMPANYMETER SHOP
SPECIAL TEST REPORT
Company #435735
Meter Type AC-250
Account #6725575
ERTNumber 19448128
Removed For:Dead
Mfg. #AOO 136567 Date 04/02/2007
Set Date 07/16/2002 Remove Date 01/16/2007
Index Read 2037
ER TRead 2156.
Removed By:Lewis Bird.
Customer Name
Customer Address 111 E. 2nd . N. St. Anthony Idaho
Prover Room Temp. Prover Temp.
Test Data Check Test:099.4 Open Test:099.
Meter Drive Rate:1 Ft.ER T Drive Rate: 1 Ft.
Tamper Seals:Yes D No
Tested By:Mr. Mark Cirelli Witnessed By:John Atwater
Test Requested By: Mr. Lynn Davis Location:Idaho Falls
Comments :Broken Wriggler. Please Note Meter and ERT Reads.
Retain in Mtr. Shop: Date:04/02/2007 Return to Dis1rict: (OJ Date:
Copies:Original - Meter Shop Second - Requesting Mgr. / Office Third - Credit Mgr.
IOC Form # 530
Cf7
Exhibit K
UTILITY CUSTOMER RELATIONS RULES IDAP A 31.21.01
underbilled shall be given the opportunity to make payment arrangements under Rule 313 on the
amount due. At the customer s option, the term of the payment arrangement may extend for the
length oftime that the underbilling accrued. The utility shall promptly refund amounts overpaid by
the customer unless the customer consents to a credit against future bills, except overbillings not
exceeding $15 may be credited to future bills. (7-93)
(Adopted as Rule 8., O.N. 17744; amended and recodified, G.O. 177.
Statutory Reference: Idaho Code ~ 61-642.
Cross-Reference: Rules 005, 200, 204.
204. INACCURATELY BILLED SERVICE UNDER CORRECT TARIFF SCHEDULE-
FAILURE TO BILL FOR SERVICE (Rule 204).
01. Errors in Preparation - Malfunctions - Failure to Bill. Whenever the billing for
utility service was not accurately determined because a meter malfunctioned or failed, bills were
estimated, or bills were inaccurately prepared, the utility shall prepare a corrected billing. If the
utility has fail~d to bill a customer for service, the utility shall prepare a bill for the period during
which no bill was provided. (7-93)
02. Corrections. Ifthe time when the malfunction or error began or the time when the
utility began to fail to bill for service cannot be reasonably determined to have occurred within a
specific billing period, the corrected billings shall not exceed the most recent six months before the
discovery of the malfunction or error or failure to bill. Ifthe time when the malfunction or error or
failure to bill began can be reasonably determined, the corrected billings shall go back to that time,
but not to exceed the time provided by Section 61-642, Idaho Code, (three (3) years). (7-93)
03. Refunds and Additional Payments. The utility shall prepare a corrected billing
indicating the refund due to the customer or the amount due the utility. A customer who has been
underbilled or who has not been billed shall be given the opportunity to make payment arrangements
under Rule 313 on the amount due. At the cl,lstomer s option, the term ofthe payment arrangement
may extend for the length of time that the underbilling accrued or the customer was not billed. The
utility shall pr,()mptly refund amounts overpaid by the customer unless the customer consents to a
credit against future bills, except overbillings not exceeding $15 may be credited to future bills.
(7-93)
(Adopted as Rule 8.2 and 8.3, O.N. 17744; amended and recodified, G.O. 177.
Statutory Reference: Idaho Code 9 61-642.
Cross-Reference: Rules 005 203,313.
205.(RESERVED).
13-
Exhibit L
Ralph Leseberg
53852700
111 E 2nd N., 5t Anthony
167 158 182,235,600 569 664,21,732.
Therms:
Charge:
MFF:
Total:
411
482.
14.
$ 496.
Usage dropped significantly Feb 2006. Rebilled Feb - Jan at previous year's usage. Found customer currently using 40% more than Feb 2005 and 90% more than Feb 2006.
Ralph Leseberg
53852700
111 E 2nd N., 5t Anthony
167 158 182,235,561 531 585,18.650.
Therms:
Charge:
MFF:
Total:
373
403.
12.
$ 415.
PUC Calculation using binomial equation for predictive therms to degree days
AS BILLED
MONTH FACTOR Rate
CCF THERM
FetrO6 963 14245
Mar-978 14245
Apr-943 25501
May-921 25501
Jun-899 1.25501
Jul-878 25501
Aug-O6 865 25501
Sep-06 879 25501
Ocl-907 2 rate chang,
Nov-928 1.21543
Dec-944 10287
Jan-969 10287
Ralph W Leseberg
53852700
111 E 2nd N., 5t Anthony
FACTOR
SHOULD HAVE BEEN BILLEDRATE
167 158 182,235,
THERM Char e
963 14245 99,109.
978 14245 105,114.
943 25501 96,102.
921 25501 42.46.
899 25501 23,27.
878 1.25501 11,14.
865 25501 10.
879 25501 10.12.
907 14 rate chang,17.20.
928 1.21543 60.77 65.
944 10287 72,81.
969 109 10287 120,130.
602 571 667,21,735.
Therms:
Charge:
MFF:
Total:
413
485.
14.
$ 499.
Calculation using historical usage and Degree Day variance with consideration for baseload
Exhibit M
IPUC RULES OF PROCEDURE IDAPA 31.01.01
Cross Reference: Rules 15,, 113, 123 202.
040.(RESERVED).
RULES 41 THROUGH 50 - REPRESENTATIVES OF PARTIES
041. INITIAL PLEADING BY PARTY - LISTING OF REPRESENTATIVES (Rule
41).
01. Designation of Representative Required. The initial pleading of each party to a
proceeding (be it an application, petition, complaint, motion, or answer) must name the party
representative(s) for service and state each representative s mailing and electronic (if available)
address for purposes of receipt of all official documents. Service of documents on the named
representative(s) by mail or by electronic mail is valid service upon the party for all purposes in
that proceeding. If no person is explicitly named as a party's representative, the person signing
the pleading will be considered the party's representative. (3-16-04)
02. Number Of Representatives. No more than two persons may be designated as a
party's representatives for purposes of service or receipt of official documents unless otherwise
authorized by order. The Commission may condition such an order upon reasonable terms
concerning payment of copying costs and mailing costs to additional representatives. (7-93)
(Adopted, G.O. 163; amended, G.O. 202; amended, 31-0101-0301.)
Court Rule Reference: I.R.P. 10(a)(1), II(a)(I).
Cross Reference: Rules IS, 16, 31, 43, 44, 49, 51, 61, 62 , 64, 65, 72, 323, 332.
042. TAKING OF APPEARANCES (Rule 42).
The presiding officer at hearing or prehearing conference will take appearances to identify the
representatives of all parties at the hearing. Parties whose pleadings have not been received by or
distributed to all, other parties may be required to state their interests at the hearing. (7 -93)
(Adopted, G.O. 155; amended, G.O. 163.
Cross Reference: Rules 41 , 43.
043. REPRESENTATION OF PARTIES AT PROCEEDINGS (Rule 43).
Recognizing that proceedings before the Commission are sometimes administrative in nature or
quasi-judicial in nature, appearances and representation of parties at hearing shall be as follows:
(3-16-04)
01. Natural Person. A natural person must represent
represented by a duly authorized employee, or an attorney.
02. Partnership. A partnership must be represented by
employee, or an attorney.
himself or herself or be
(3-16-04)
a partner, duly authorized
(7-93)
03. Corporation. A corporation must be represented by an officer, duly authorized
employee, or an; attorney. (7-93)
Exhibit M
IPUC RULES OF PROCEDURE IDAPA 31.01.01
04. Other Entity. A municipal corporation, state, federal, tribal, or local government
agency, or entity, incorporated association, or non-profit organization must be represented by an
officer, a duly authorized employee or an attorney. (7-93)
05. At~orney Representation. Only an active member of the Idaho State Bar may
represent a party as an attorney except as provided by Idaho Bar Commission Rule 222 (Limited
Admission/Pro Hac Vice). The Commission adopts by incorporation Bar Rule 222 as modifiedbelow. (3-16-04)
a. Given the administrative nature of many proceedings, limited admission by out-of-
state attorneys will not be necessary in conjunction with administrative filings such as tariff
schedules, tariff advices, price lists, certificates to provide local exchange service, and
interconnection agreements. Out-of-state attorneys representing the same party in one (1) or
more quasi-judicial cases (such as fonnal complaints, motions, petitions, and applications that
request modified procedure or an evidentiary hearing), must request limited admission at least
one (1) time per calendar year. (3-16-04)
b. An attorney applying for limited admission to appear before the Commission in a
representative capacity shall file a written motion with the Commission Secretary and serve a
copy on all parties. The motion shall be substantially in the fonn set out in Bar Rule 222(1) with
references to the Commission instead of the court. (3-16-04)
c. A eopy of the written motion shall be submitted to the Idaho State Bar accompanied
by the fee prescribed by Bar Rule 2220). (3-16-04)
(Adopted, G.O. 155; amended, O.N. 15503; amended, O.N. 17001; amended, G.O. 163; amended, 31-0101-0301.)
Statutory Reference: Idaho Code ~ 61-619.
Case Reference: Idaho State Bar Association v, Idaho Public Utilities Commission 1021daho 672 637 P,2d 1168 (1981).
Bar Rule Reference: Idaho Bar Commission Rule 222.
Cross Reference: Rules 19 257.
044. SERVICE ON REPRESENTATIVES OF PARTIES AND OTHER PERSONS
(Rule 44).
From the time a party files its initial pleading in a proceeding, that party must serve and all other
parties must serve all future documents listed in Rule 51 upon all other parties' representatives
designated pursuant to Rule 41, unless otherwise directed by order or notice or by the presiding
officer on the record. The Commission may order parties to serve past documents filed in the
case upon those representatives. The Commission may order parties to serve past or future
documents filed 'in the case upon persons not parties to the proceedings before the Commission.
(Adopted, G.O. 155; amended, G.O. 163; amended, G.O. 182; amended, 31-0101-0301.)
Cross Reference: Rules 6, 41, 51 , 62, 229, 255, 312.
(3-16-04)
10-