20180309Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
FROM:CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
DATE: MARCH 9,2018
SUBJECT:THE APPLICATION OF INTERMOUNTAIN GAS COMPANY FOR AN
ACCOUNTING ORDER REGARDING THE TREATMENT OF COST
ASSOCIATED WITH CUSTOMER PAYMENT TRANSACTIONS
HANDLED BY WESTERN UNION, CASE NO. INT.G.18.O1.
On February 22,2018, Intermountain Gas Company applied to the Commission for
authority to create a regulatory asset to capture the costs associated with customer payment
transactions handled by Western Union. The Company asks that it be authorized to recover the
regulatory asset in the Company's Purchased Gas Cost Adjustment (PGA) beginning in 2019,
and that it be authorizedto defer costs into the regulatory asset until February 1,2021, or until
the Company files a general rate case, whichever comes first. The Company also requested that
the Application be processed by Modified Procedure.
The Company explains that in Order No. 33805, the Commission directed the
Company to meet with Commission Staff to discuss alternatives to convenience fees.
Application at 3. The Company explains that it has met with Staff on several occasions to
discuss the fees, and specifically the costs associated with customer payment transactions
handled by Western Union. Id. The Company represents that it has agreed with Staff from the
Consumer Assistance section that, effective February 1,2018, the Company will pay the costs
associated with customer payment transactions handled by Western Union, with the intention of
deferring those costs and seeking recovery of them through this Application. Id. at 3-4. The
Company indicates that the costs are estimated to total between $75,000 and $125,000 per year,
depending on the per-transaction fee and the number of transactions. Id. at 4. The Company
proposes that the costs be deferred to a regulatory asset and be recovered in rates through the
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Company's PGA, with recovery to begin with the PGA filed in2019. Id. Finally, the Company
requests that the deferral of the costs "should expire in three (3) years (February 1,2021) or until
such time as the Company files a general rate case, whichever comes ftrst." Id. The Company
refers to Accounting Standards Codification (ASC) 980 - Regulated Operations in support of its
request for the regulatory asset. Id.
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Application and set a
deadline for petitions to intervene of 2l days from the date of the Order. After the intervention
deadline has passed, Staff will confer with parties regarding a schedule for processing the case.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and set a deadline for
petitions to intervene of 2l days from the date of the Order?
Camille Christen
Deputy Attorney General
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2DECISION MEMORANDUM