20180702final_order_no_34099.pdf

Office of the Secretary
Service Date
July 2,2018
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.INT-G-18-01
OF INTERMOUNTAIN GAS COMPANY )FOR AN ACCOUNTING ORDER )REGARDING THE TREATMENT OF COSTS )ORDER NO.34099
ASSOCIATED WITH CUSTOMER )PAYMENT TRANSACTIONS HANDLED BY )WESTERN UNION )
On February 22,2018,Intermountain Gas Company applied to the Commission for
authority to create a regulatory asset to capture the costs associated with certain customer payment
transactions handled by Western Union.The Company asked that it be authorized to defer costs
into the regulatory asset for recovery in the Company's Purchased Gas Cost Adjustment (PGA)
until February 1,2021,or until the Company files a general rate case,whichever is first.The
Commission issued a Notice of Application and set a deadline for petitions to intervene.Order
No.34009.No petitions to intervene were received.The Commission then issued a Notice of
Modified Procedure setting comment and reply deadlines.Order No.34029.Commission Staff
and one member of the public submitted timely comments.
THE APPLICATION
The Company stated that Order No.33805 directed it to meet with Staff to discuss
alternatives to convenience fees.Application at 3.The Company met with Staff several times to
discuss these fees,and specifically the fees associated with customers paying the Company
through Western Union.Id
The Company represented that it agreed with the Commission's Consumer Assistance Staff
that,effective February 1,2018,the Company would pay the in-person transaction fees for
customers to pay their bills through Western Union,and apply to defer the associated costs to a
regulatory asset for later recovery through rates.Id.at 3-4.The Company estimates the costs total
between $75,000 and $125,000 per year,depending on the per-transaction fee and the number of
transactions.Id.at 4.
With this Application,the Company proposes to defer the costs to a regulatory asset for
recovery in its PGA starting in 2019.Id.The Company requests that the deferral of the costs
"expire in three (3)years (February 1,2021)"or when the Company files a general rate case,
ORDER NO.34099 1
whichever comes first."Id The Cornpany referred to Accounting Standards Codification (ASC)
980 -Regulated Operations to support its request for the regulatory asset,and asserts that the
request is just,fair,and reasonable.Id
THE COMMENTS
1.Staff
Staff noted that as of February 22,2018,as per its informal agreement with the Company,
the $1.00 fee charged to customers using in-person Western Union Pay Stations has ended.
However,customers using Western Union Speedpay service(s)to make payments by phone or on-
line using a credit/debit card or electronic check still pay a convenience fee.Id.at 2.
At base,Staff does not believe that deferral treatment is necessary for these Western Union
transaction fees because they do not cause significant financial burden to the Company.But
because of the Company's indications of good faith and cooperativeness with Staff in moving to
eliminate all transaction fees,Staff believes creating a regulatory asset now for later recovery is a
fair compromise.Id.at 6.Staff does not,however,believe the Company must wait to implement
a comprehensive fee-free payment program until the Company has analyzed another year's worth
of data from Avista's Fee-Free Payment Program,as suggested by the Company.Staff believes
the Company should immediately implement a fee-free program that covers all transaction fees.
Id.at 4-5.
Staff thus recommends that the Commission allow the Company to set up a regulatory asset
account into which the Company defers its costs for the in-person Western Union pay station
transaction fees through January 31,2021 (three years).Id.While Staff would generally prefer to
see only those costs related to the purchase of gas in the Company's annual PGA,Staff recognized
that the Commission has allowed the Company to recover other types of expenses,such as deferred
rate case expenses,in the PGA.Staff thus supports,with one caveat,allowing the Company to
recover in-person Western Union pay station deferred transaction costs through the PGA.Id.
Because the PGA allows nearly immediate recovery,Staff recommended that a carrying charge
not be allowed.Id.at 7.Staff further recommended that the Company file quarterly reports with
the Commission detailing the number of Western Union pay station transactions and associated
costs.Id.
ORDER NO.34099
2.Public Comment
One member of the public commented that convenience fees from some customers'
transactions should not be borne by all customers through a rate increase.Rather,the customers
who cause the pay station related costs should pay for them.
COMMISSION DECISION
The Commission has jurisdiction over this matter under Idaho Code §§61-502 and 61-
503.The Commission has the express statutory authority to investigate rates,charges,rules,
regulations,practices,and contracts of public utilities and to determine whether they are just,
reasonable,preferential,discriminatory,or in violation of any provision of law,and may fix the
same by order.Idaho Code §§61-502 and 61-503.
Having reviewed the Application and comments,the Commission now approves the
creation of a regulatory asset to capture the costs associated with in-person customer pay station
transactions handled by Western Union.The Commission also authorizes Intermountain to seek
recovery of those costs in the Company's PGA beginning in 2019 until February 1,2021,or until
the Company files a general rate case,whichever comes first.We encourage the Company and
Staff to continue to collaborate on how to best address transaction fees.
The Commission declines to require the Company to file a report with the Commission
every three months detailing fees incurred and the number of transactions at authorized payment
stations.Instead,the Company shall retain this information for audit review.Finally,due to the
relatively immediate recovery that will occur in the PGA because of the regulatory asset,we
decline to allow the Company to recover a carrying charge.The Commission acknowledges and
appreciates this first step toward fee-free transactions for Intermountain's customers.
ORDER
IT IS HEREBY ORDERED that the Company is authorized to create a regulatory asset to
capture the costs associated with in-person customer pay station transactions handled by Western
Union.The Company may seek to recover those costs in its PGA beginning in 2019 and until
February 1,2021,or until the Company files a general rate case,whichever comes first.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order with regard to any
matter decided in this Order.Within seven (7)days after any person has petitioned for
ORDER NO.34099 3
reconsideration,any other person may cross-petition for reconsideration.See Idaho Code §61-
626.
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this 2
day of July2018.
PAl L KJPELANDER.PRESIDENT
KR STINE RAPER,COMMISSIONER
ERIC ANDERSON,COMMISSIONER
ATTEST:
Diane M.Hanian
Commission Secretary
1:\Legal\GAS\lNT-G-18-0IiOrdersdNTGIKol final sedoex
ORDER NO.34099 4