20211206Application.pdf

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Lori A. Blattner
Director, Regulatory Affairs
Intermountain Gas Company
Enclosure
Mark Chiles
Preston Carter
RECEIVED
2021 DEC -6 PM 1:46
IDAllo PUBt-tC
IJT I L IT IES COMt\,,,I ISSION
December 6,2021
Ms. Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,lD 83720-0074
RE: CaseNo. INT-G-21-08
Dear Ms. Noriyuki:
Attached for consideration by this Commission is an electronic submission of Intermountain Gas
Company's Application for Authority to Revise lts Electronic Receiver Transmitter Drive Rate
Programming and Verifi cation Process.
If you should have any questions regarding the attached, please don't hesitate to contact me at (208)
377-6015.
Sincerely,
tnLBbM
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INTERMOTINTAIN GAS COMPAIYY
CASE NO.INT.G.21.O8
APPLICATION
In the Matter of the Application of INIERMOT NTAIN GAS COMPANY
X'or Authority to Revise Its Electronic Receiver Transmitter Drive Rate
Programming and Verificetion Process
Preston N. Carter, ISB No. 8462
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
Telephone: (208) 388-l 200
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of
INTERMOUNTAIN GAS COMPANY
for Authority to Revise Its Electronic
Receiver Transmitter Drive Rate
and Verification Process
Intermountain Gas Company ("lntermountain" or "Company"), a subsidiary of MDU
Resources Group,Inc. with general offices located at 555 South Cole Road, Boise,Idaho, pursuant
to the Rules of Procedure of the Idaho Public Utilities Commission ("Commission"), requests
authority to revise the Company's Electronic Receiver Transmitter ("ERT") drive rate programming
and verification process. Currently, Company employees veriff the drive rate programmed in the
ERT matches the meter at the time of meter installation, and if the ERT is newly installed on the
meter, the ERT is programmed at that time. Within 30 days of the meter installation, Company
employees perform an audit to veriff again the drive rate programming in the ERT matches the
installed meter. For reasons described more fully in this Application, the Company believes that the
30-day verification is no longer necessary due to recent procedural changes.
Please address communications regarding this Application to:
Lori A. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608
Boise,Idaho 83707
Lori. B lattner@ intgas.com
and
Case No.INT-G-21-08
APPLICATION
IxtnRraouNranv Gas CorrpANy's ApplrcartoN - 2
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
[e-mail]
harmonywri [e-mail]
In support of this Application, lntermountain alleges and states as follows:
I.INTRODUCTION
Intermountain is a gas utility, subject to the jurisdiction of the Commission, engaged in the
sale of and distribution of natural gas within the State of Idaho under authority of Commission
Certificate No. 219, issued December 2, 1955, as amended and supplemented by Order No. 6564,
dated October 3,1962.
Intermountain provides natural gas service to the following Idaho communities and counties
and adjoining areas:
Ada County - Boise, Eagle, Garden City, Kun4 Meridian, and Star;
Bannock County - Arimo, Chubbuck,Inkom, Lava Hot Springs, McCammon, and Pocatello;
Bear Lake County - Georgetown, and Montpelier;
Bingham County - Aberdeen, Basalt, Blackfoot Firth, Fort Hall, MorelandlRiverside, and Shelley;
Blaine County - Bellevue, Hailey, Ketchum, and Sun Valley;
Bonneville County - Ammon, Idaho Falls, Iona, and Ucon;
Canyon County - Caldwell, Greenleaf Middleton, Nampa, Parma, and Wilder;
Caribou County - Bancroft, Grace, and Soda Springs;
Cassia County - Burley, Declo, Malta, and Raft River;
Elmore County - Glenns Ferry, Hammetl and Mountain Home;
Fremont County - Parker, and St. Anthony;
Gem County - Emmett;
Gooding County - Bliss, Gooding, and Wendell;
Jefferson County - Lewisville, Menan, Rigby, and Ririe;
Jerome County - Jerome;
Lincoln County - Shoshone;
Madison County - Rexburg, and Sugar City;
Minidoka County - Heyburn, Paul, and Rupert;
Owyhee County - Bruneau, Marsing, and Homedale;
Payette County - Fruitland, New Plymouth, and Payette;
Power County - American Falls;
Twin Falls County - Buhl, Filer, Hansen, Kimberly, Murtaugh, and Twin Falls;
Washington County - Weiser.
INTERMoI.INTAIN GAS COIvpETW,S APPTTCAUOU - 3
Intermountain's properties in these locations consist of transmission pipelines, liquefied
natural gas storage facilities, compressor stations, distribution mains, services, meters and
regulators, and general plant and equipment.
II. BACKGROUND
In 2008, the Company worked with the Commission Staffto develop a Memorandum of
Understanding ("MOU") regarding guidelines for inaccurately billed service. In conjunction with
the MOU, although not specifically mentioned in the MOU, the Company instituted a practice of
performing an audit 30 days after meter installation to verifu the drive rate programming in the ERT
matched the installed meter.
The MOU and the 30-day audit were prompted by two formal customer complaints
involving billing enors arising from a mismatch between the meter drive rate and the drive rate
programmed into the ERT (see Case Nos. INT-G-06-01 and INT-G-07-02). The drive rate
represents the amount of gas consumed during one cycle of the diaphragm within the meter. For
example, a two-foot drive rate represents two cubic feet of gas consumed with each cycle of the
diaphragm. In both formal complaints mentioned above, the ERT was programmed with a one-foot
drive rate while the meter itself was constructed with a two-foot drive rate. Because the ERT is
responsible for wirelessly transmitting the consumption data to the Company's billing system, this
mismatch in drive rates caused the gas consumption used for billing purposes to be exactly one half
of the actual amount of gas consumed.
Currently, Company employees veriff the drive rate programming in the ERT matches
the drive rate of the meter at the time of meter installation, and if the ERT is newly installed on
the meter, the ERT is programmed at that time. Within 30 days of the meter installation,
Company employees perform an audit to verify again that the drive rate programming in the
INTERMOT]NTAIN Ges CoupeNY'S APPLICATIoN - 4
ERT matches the installed meter. The current process provides two verifications that the drive
rate programming in the ERT matches the installed meter. While the current process addressed
the problems identified in 2006 and2007, the Company has identified a new process, explained
below, that is accurate, reliable, and renders unnecessary the 30-day audit.
III. PROPOSAL
Because of changes in Intermountain's procedures, the Company proposes to revise its ERT
drive rate programming and verification process. The ERT drive rate will be programed at the
meter manufacturer's facility or in the Company's Meter Shop and the ERT drive rate programming
will be verified at the time of meter installation. This proposal provides two verifications and
makes the 30day audit an unnecessary third verification. For the reasons outlined below, the
Company believes this proposalwill continue to allow the Company to reduce and quickly catch
mismatches in the drive rate between the ERT and installed meter while avoiding the expenses
associated with the 30-day audit.
The Company is currently working towards a two-foot drive standard for all its residential
meters by converting all one-foot drive meters to two-foot drive meters and only purchasing new
meters with two-foot drives. Standardizing all residential meters to two-foot drives will eliminate
variability that could cause a mismatch between the meter and ERT drive rates.
Intermountain notes that all new residential meters purchased with ERTs will be
prograrnmed at the meter manufacturer's facility with a two-foot drive rate. These ERTs are
programmed in batches at the facility reducing the potential for human error which may occur if
each individual ERT is programmed by a Company employee at the time of meter installation. For
one-foot drive meters converted to two-foot drives, the Meter Shop reprograms the ERT to a two-
foot drive rate.
INTERMoI.,NT TN Gas COMPANY'SAPPLICATION - 5
For all new ERTs programmed in the meter manufacturer's facility, the Meter Shop
performs a sample audit of the ERTs to check that they are programmed as a two-foot drive. At the
time of installation, Company employees veriff the ERT drive rate matches the installed meter. For
one-foot drive meters converted to two-foot drives, the ERTs are reprogrammed in the Meter Shop
and verified at the time of installation. The new process of programming the ERT before
installation and then verifying the ERT at the time of installation provides the two verifications that
were envisioned under the procedure that has been in place since 2008.
Intermountain implemented the changes described above in June and continued to perform
the 30-day audit. Since implementing the changes, the Company has only had one drive rate error
caught by the 30-day audit as seen in the table below. The ERT involved in this error was
programmed correctly at the meter manufacturer's facility, however, the employee mis-
programmed the ERT at the time of installation. Employees have received additional ffaining to not
program ERTs at the time of installation unless the programming is incorrect.
Date
lnstall
Meter
Audits
!nstal!
Drive Rate
lncorrect
30-Day
Meter
Audits
30-Day
Drive Rate
lncorrect
lun2O2L
lul202L
Aug 2021
Sep 2021
Oct 2021
Total
L,758
2,327
L,92L
1,805
L,562
1,986
L,882
2,O]L
L,645
2,L22
1
9,373 9,646 L
Rate o.o00%o.oLo%
Based on the processes explained above and the data presented in this table, the Company
believes that it is no longer necessary to perform an additional 30-day audit to verifu the drive rate
INTBnvouuTAhT GAS CoMPANY'S APPLICATIoN - 6
programming in the ERT matches the installed meter. The Company believes ttut renroving this
unnecessary step will reduce costs and sfieamline the process for installing meters.
IV. MODIFIED PR(rcEDURE
Intermountain rquests th* this matter be handled under modified proce&rc pursuant to
Rules }AIAM of the Commission's Rules of hooedurc. Intermountoin stands ready for immediate
consideration of this matter.
INTERII,ToUNTAIhI Gas COUPaNY,S APPUCATION - 7
v. REQTTEST FOR RELIEF
Intermountain respectfully petitions the Idaho Public Utilities Commission as follows:
a. That the Company be granted authority to revise its ERT drive rate programming and
verification process as explained above,
b. That this Application be heard and acted upon without hearing under modified procedure,
c. For such other relief as this Commission may determine proper.
DATED: December 6, 2021.
INTERMOI.'NTAIN GAS COMPANY GIVENS PURSLEY LLP
and
flnLBbM 94/ -=rJ- p- a-- t-- "By
Lori A. Blattrrer
Director - Regulatory Affairs
By
Preston N. Carter
Attorney for Intermountain Gas Company
INrnRMoLrNTAnt GAs ColvfpANy's AppLIcATIott - 8