20170418Reply Comments.pdf

WILLIAMS BRADBURY
ATTORNEYSATLAW
April 18,2017
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Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
Re: INT-G-I7-02
Dear Ms. Hanian:
Please find enclosed an original and seven copies of the Reply Comments of
Intermountain Gas Company for filing in the above referenced case.
Thank you for your assistance in this maffer. Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L. Williams
Enclosures
1015 1J7. Hays Street - Boise, ID 83702
Phone: 208-34+6633 - www.williamsbradbury.com
Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise,ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Respondent Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
VIRGINIA ROTHENBURGER,Case No. INT-G-I7-02
Complainant,
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ANSWER OF RESPONDENT
INTERMOUNTAIN GAS
COMPANY
INTERMOUNTAIN GAS COMPANY,
Respondent
COMES NOW Intermountain Gas Company ( "Intermountain" or the "Company"), in
response to the Complaint filed by Ms. Virginia Rothenburger at the Idaho Public Utilities
Commission ("Commission" or o'Idaho PUC") and the Summons issued by the Commission on
March 30,2017, states as follows:
INTRODUCTION
1. Ms. Rothenberger's complaint and Commission Stafls inquiry focuses on
Intermountain's payment options for customers. In particular Ms. Rothenberger and Staff
maintain that it is: 1) unfair that Intermountain not provide customers with the flexibility to
adjust the date that funds are withdrawn from a customer's financial institution when using the
Auto Pay method of payment, arrd2) that customers should not be required to have to pay a
convenience fee of $1.99 when using a debit or credit card to pay their Intermountain gas bill.
)
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgE I
2. Intermountain understands the need to provide a variety of payment methods for
its customers and currently offers six different methods of payment. Intermountain's goal is to
offer cost effective means for customers to pay their bills while, at the same time, keeping the
Company's payment processing costs to a minimum, for the benefit of all customers.
HISTORY
3. Virginia Rothenberger has been a customer at 1846 Harrison St. N. in Twin Falls,
Idaho, since February of 2009. During that time she has paid her monthly bill with regularity
through a variety of sources. Some of Ms. Rothenberger's payments were made through the
mail, while others were paid at one of the Company's authorized walk-in locations.
4. In April of 2016 Ms. Rothenberger called to inquire if she could pick the date that
an automatic payment would withdraw. She was advised at that time that it was not an available
option for her to select the automatic withdrawal date, and that the payment would instead be
withdrawn a set number of days following the generation of her monthly bill. Ms. Rothenberger
was told that the automatic withdrawal from her account would occur around the 28th of each
month. On that same call Ms. Rothenberger also inquired about a level payment plan and was
advised that amount would be $36.00 per month. A few days later, a signed AutoPay
authorization form was received from Ms. Rothenberger.
5. On July 5,2016, Ms. Rothenberger called again and requested her account be put
on Level Pay. She called again on August 2nd informing Intermountain that her bank account
had been "hacked" and that she wanted to confirm if the payment was withdrawn. She asked
that future payments not be withdrawn earlier than the 3'd of each month, but Intermountain
again advised her that was not possible, and that withdrawal date is automatically determined
based on a customer's billing date. Altematively, the Company advised Ms. Rothenberger of
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgEZ
other payment options available to her, including local payment locations and the use of the
Company's website, which Ms. Rothenberger indicated was not an option due to the issues with
her eyesight.
6. On December 2,2016, Ms. Rothenberger called again, asking to speak with a
supervisor. She advised the supervisor she was upset because her payment was taken out of her
bank account on November 28,2016, causing her to incur a bank overdraft fee. Ms.
Rothenberger indicated that her payment was always deducted on the 3'd of each month. The
supervisor went over the dates of each payment with her, also noting that because AutoPay was
first initiated with the May statement, only one draft (May,2016) took place after the 3'd of the
month. The supervisor again advised Ms. Rothenberger that AutoPay is drafted approximately
l0 calendar days following the customer's billing date. Ms. Rothenberger stated she was not
awzre of that and had not been told that AutoPay could not deduct on the 3rd day each month.
The supervisor again explained alternative payment options to Ms. Rothenberger, including
having her bank remit the payment on a specific date each month.
7. On January 24,2017, Ms. Rothenberger called Intermountain asking that her
AutoPay be cancelled. She indicated that someone from an organization helping the blind would
assist her with making monthly payments. Intermountain advised Ms. Rothenberger that the
Company would make a one-time stop for the upcoming payment scheduled to be withdrawn on
January 30s, and that awritten request to completely stop AutoPay would need to be sent to the
Company.
8. Upon Ms. Rothenberger's inquiry to the Commission's Consumer Affairs
Section, the Section's assigned investigator (Mr. Hecht) recommended to the Company that Ms.
Ms. Rothenberger's billing due date be adjusted in accordance with Rule 202.02.The Company
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgC 3
accepted that recommendation and extended Ms. Ms. Rothenberger's due date. However,
changing Ms. Rothenberger's due date did not directly address Ms. Rothenberger's request to
have AutoPay draft on a specific date. AutoPay is currently configured in Company's customer
information system to withdraw funds 11 days after the billing date, in accordance with section
4.3 of the Company's Tariff Section A: General Service Provisions, as approved by the
Commission. The due date on the account has no effect on when an AutoPay payment is
withdrawn.
9. Ms. Rothenberger requests that customers should have the flexibility to select the
date of their AutoPay withdrawal. As mentioned, the Company's billing software is not
configured to accommodate this request - to provide customer choice in selecting withdrawal
dates - and is only programmed to withdraw l1 days following the billing date. Intermountain
realizes that this withdrawal date occurs prior to the actual (15 day after billing) due date.
However, AutoPay is an optional program that customers are free to choose, or to decline, and
there are other payment channels available that allow a customer to pay later, at the time closer
to the billing due date.
10. Intermountain has offered AutoPay as a payment option for several years. Up
until very recently, the processing of ACH payments could take several days, depending on the
banking institution the customer used. The earlier AutoPay withdrawal ensured that customers
electing recurring payments were not inadvertently past due as a result of delays in ACH
processing. With recent advancements in the timing of ACH payments, Intermountain has
explored alternatives to programing the customer information system with a withdrawal date
that aligns with the due date. These options will be further pursued when current IT initiatives
are resolved and resources are available to complete any necessary programming. The Company
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgE 4
would like to point out, however, that such a prograrnming option will not be available on a
customer-by-customer basis, but would instead need to be applied concurrently to all customers.
I l. According to the Decision Memo drafted by Commission Staff, Ms. Rothenberger
is also seeking relief from the $ I .99 convenience fee associated with making a payment using a
debit or credit card. However, in the several phone conversations between the Company and
Ms. Rothenberger over the last year, she did not express any objection to this processing fee. In
a phone call with an Intermountain representative on August 2,2016, Ms. Rothenberger
indicated her bank suggested she pay with a pre-paid debit card since her checking account had
been compromised multiple times. When the $l.99 processing fee was mentioned, Ms.
Rothenberger did not object to the fee, but did explain it would cost her nearly $25.00 to take a
cab to apay station.
12. In that August 2,2016, conversation with the Company, the free payment option
on Intermountain's website was offered again to Ms. Rothenberger, but she indicated with her
eyesight that the web option will not work. The subject of Ms. Rothenberger's objection to the
$1.99 convenience fee was never discussed by any Company representative and Ms.
Rothenberger and was not disclosed or discussed by Commission Staff s investigator, Mr.
Hecht, during the investigation of the informal complaint. The first mention of Ms.
Rothenberger requesting this particular relief was in Mr. Hecht's Decision Memorandum
created "in lieu of'Ms. Rothenberger filing a formal complaint in writing.
13. The option of paying by credit or debit card was introduced by the Company
several years ago, in response to a perceived demand from customers wanting this particular
channel to make billing payments. Due to the higher transaction fees and stricter network
security requirements associated with debit and credit card payments, a third-party vendor is
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgE 5
necessary and contracted with, to transact these payments. The convenience fee is charged by
this vendor and passed through at l00oh, with no transaction proceeds received by the
Company. Intermountain has worked with the vendor to ensure the fee is kept reasonably low.
The fee has been as high as $3.95 and was last adjusted in January of 2016, when it was
lowered to $1.99 from the previous fee of $2.75.
RESPONSE
14. Intermountain works diligently with each of its customers to help them find the
best means of paying their bill through a variety of payment options. The Company's goal has
always been to provide safe reliable service at the lowest cost. Having standard operating
procedures and collection methods help keep operating costs low. Variances to operating
procedures and methods increase costs, which are either collected directly from the customer
causing the cost, or are collected from all customers. The Company is also continually pursuing
new payment options or improvements to existing options.
15. In order to benefit all lntermountain customers, the Company is proposing the
following change to its current payment options which should help facilitate a resolution to Ms.
Rothenberger's concerns:
a. The Company can change the Payment Due date for AutoPay
customers to the Date Due as listed on the customer bill. Intermountain has been
evaluating a change in the AutoPay process in recent years due to ongoing changes
in the banking industry. Currently, per Intermountain's approved gas tariff section
4.3, all payments are due within 15 days from the date of rendition. However,
when the customer is paying through AutoPay the billing is be due and payable
within 1l days from the date of rendition. The practice of deducting the payment
ANSWER OF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgE 6
on an accelerated basis dates back to when there was a significant time delay
between when the payment was initiated and when the payment was actually
transferred to the Company. Efficiencies in banking practices have shortened the
timeframe between initiation and receipt to where it is now essentially same day or
next day. Based on these efficiencies the Company believes it would be fair to all
of Intermountain's customers to change the payment deduct date for AutoPay
customers to the Date Due. This change will also eliminate the confusion between
the Date Due and Payment Due dates as listed on the customer bill.
b. Specific to Ms. Rothenberger's complaint; should Ms.
Rothenberger elect to move back to paying through the AutoPay method this
change will result in her payment date consistently being due no earlier than the
third of the month based on her current billing cycle. Per a review of Ms.
Rothenberger's bills from August of 2016 through January of 2017, the earliest
due date for her bill would be the 3'd day of the month.
16. With respect to item #2 of Ms. Rothenberger's requested relief; in
Intermountain's recent General Rate Case, Case No. INT-G-16-02, Commission Staff proposed
that lntermountain eliminate the convenience fees associated with credit and debit card payments
and the Pay Station fee associated with Western Union payments. This is essentially the exact
same issue as framed by Staff s Decision Memo on behalf of Ms. Rothenberger. Case No. INT-
G-16-02 is currently in deliberation and Staff, Intermountain and the other parties in that case are
currently waiting for the Commission's ruling.
17. Specific to Ms. Rothenberger's complaint with respect to credit card transaction
fees, it is highly likely that the Commission's decision in Case No. INT-G-16-02 will provide
ANSWEROF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgET
further guidance to the Company with respect to Ms. Rothenberger's and other customer's
obligation to pay credit or debit card transaction fees, and Western Union transaction fees, or
whether the Company will pay such fees at the time of the transaction and collect such fees from
the general body of ratepayers through the Company's rates. In essence, the Company believes
that the Commission's decision in Case No. NT-G-16-02 will fully dispose of this second issue
of Ms. Rothenberger's complaint.
CONCLUSION
18. Intermountain believes it has followed all of the current rules in place while
working with Ms. Rothenberger on her payment options. The Company also understands and is
sensitive to the hardships of her personal circumstances. Finally, Intermountain is committed to
offering payment alternatives that benefit all customers, that are efficient and cost effective, and
that by necessity, will evolve over time.
19. Intermountain believes that the changes proposed above to the AutoPay dates
satisff the requested relief in Case No. INT-G-I7-02. Furthermore, the Company believe that the
Commission's pending decision in Case No. INT-G-16-02 will resolve the credit/debit card fee
issues. These changes benefit all Intermountain customers using these payment options and
should have a minimal impact on other customer's bills. These changes also avoid the burden on
the Company of custom - or customer specific - programs or services, which results in higher
overall costs to Intermountain and eventually, to its customers.
20. Intermountain remains committed to providing safe, reliable service to all
customers at the lowest possible rates and maintaining standard operating procedures and
payment methodologies will allow Intermountain to continue to offer the best service at the
lowest possible rates.
ANSWEROF RESPONDENTINTERMOUNTAIN GAS COMPANY, PAgC 8
Dated this ll day of April,20l7.
Re spectfully submitted,
flaL
Ronald L. Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise [D,83702
Telephone: [phone]
ron@williamsbradbury. com
Attorneys for Intermountain Gas Company
CERTIFICATE OF DELIVERY
I hereby certify that on this $tay of April, 2017,I caused to be served a true and correct
copy of the Answer of Intermountain Gas Company upon the following individuals in the manner
indicated below:
Hand Deliverv: (original & 7 copies)
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise,lD 83720
Mail Delivery:
Virginia Rothenberger
1846 Harrison St. North
Twin Falls, ID 83301
i?e t uiltL
Ronald L. Williams
ANSWEROF RESPONDENT INTERMOUNTAIN GAS COMPANY, PAgE 9