20211228Notice_of_Application_Order_No_35275.pdf

NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35275 1
Office of the Secretary
Service Date
December 28, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY’S APPLICATION TO
REVISE ITS ELECTRONIC RECEIVER
TRANSMITTER DRIVE RATE
PROGRAMMING AND VERIFICATION
PROCESS
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CASE NO. INT-G-21-08

NOTICE OF APPLICATION

NOTICE OF
MODIFIED PROCEDURE

ORDER NO. 35275

On December 6, 2021, Intermountain Gas Company (“the Company”) applied to revise
its current electronic receiver transmitter (“ERT”) drive rate and verification process. Currently,
the Company audits each ERT unit within 30 days of installation to verify the programming rate
and ensure that it matches the installed meter. The Company has revised its procedures for
verifying ERT drives and meters and believes the current 30-day audit is no longer necessary.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that the Company is subsidiary company of MDU
Resources Group, Inc. (“MDU”). The Company is a public utility that sells and distributes natural
gas within the State of Idaho.
YOU ARE FURTHER NOTIFIED that in 2008, after receiving two formal complaints
involving billing errors arising from a mismatch between the meter drive rate and drive rate
programmed into the ERT, the Company worked with Staff to develop a Memorandum of
Understanding (“MOU”) regarding guidelines for inaccurately billed service. Based upon the
MOU’s purpose, the Company instituted a 30-day-audit practice after meter installation to verify
the ERT drive rate programming to ensure that the drive rate matched the installed meter.
YOU ARE FURTHER NOTIFIED that the ERT transmits consumption data to the
Company’s billing system. The drive rate represents the amount of gas consumed during one cycle
of the diaphragm within the meter. In the above-mentioned formal complaints, the ERT drives
were programmed with a one-foot drive rate while the meters were constructed with a two-foot
drive rate. 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.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35275 2
YOU ARE FURTHER NOTIFIED that the Company currently verifies and programs
the drive rate programming 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 installation and programming,
the Company audits meters to verify that the drive rate programming in the ERT matches the
installed meter. This process addressed the problems identified in 2006 and 2007.
YOU ARE FURTHER NOTIFIED that the Company represents it has identified a new
process that is accurate, reliable, and renders the 30-day audit unnecessary. The Company states
that the ERT drive rate will be programmed at the meter manufacturer’s facility or in the
Company’s meter shop and then be verified at the time of meter installation. The Company states
that this proposal provides two verifications and makes the 30-day audit unnecessary.
YOU ARE FURTHER NOTIFIED that the Company is working to convert all one-
foot drive meters to two-foot drive meters and states that it is only purchasing new meters with
two-foot drives in order to standardize all residential meters to two-foot drives. For all new ERT’s
programmed in the meter manufacturer’s facility, the Company states that its meter shop performs
a sample audit of the ERTs to check that they are programmed as a two-foot drive. The Company
also asserts that the current one-foot drive meters are reprogrammed in the Company’s meter shop
and then verified at the time of installation. The Company represents that this process provides the
two verifications envisioned in 2008 after entering into the MOU with Staff.
YOU ARE FURTHER NOTIFIED that the Application and Exhibits are available for
public inspection during regular business hours at the Commission’s office. The documents are
also available on the Commission’s website at www.puc.idaho.gov. Click on the “NATURAL
GAS” tab at the top of the home page, then select “Open Cases” and then locate and click on the
case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held
pursuant to the Commission’s jurisdiction under Title 61 of the Idaho Code. The Commission may
enter any final order consistent with its authority under Title 61.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted
pursuant to the Commission’s Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter and will proceed under Modified Procedure
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35275 3
pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission’s Rules of Procedure,
IDAPA 31.01.01.201 through .204. The Commission notes that Modified Procedure and written
comments have proven to be an effective means for obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that persons desiring to state a position on this
Application may file a written comment explaining why the person supports or opposes the
Application. Persons who would like a hearing must specifically request a hearing in their written
comments. Persons must file comments by February 24, 2022. Comments must be filed through
the Commission’s website or by e-mail unless computer access is unavailable. To comment
electronically, please access the Commission’s home page at www.puc.idaho.gov. Click the
“Consumers” tab and then “Case Comment Form” and complete the form using the case number
as it appears on the front of this document. To file by e-mail, the customer must e-mail the
comments to the Commission Secretary and the Company at the e-mail addresses listed below. If
computer access is unavailable, then comments may be mailed to the Commission and Company
at these addresses:
For the Idaho Public Utilities
Commission:

Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

Street Address for Express Mail:

11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, Idaho 83714

For Intermountain Gas:

Lori A. Blattner
Intermountain Gas Company
P.O. Box 7608
Boise, Idaho 83707
[e-mail]

Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
[e-mail]
[e-mail]

YOU ARE FURTHER NOTIFIED that the Company must file any reply comments by
March 2, 2022.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set, the Commission will consider this matter on its merits and enter its order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35275 4
O R D E R
IT IS HEREBY ORDERED that the Company’s Application be processed by Modified
Procedure, Rules 201-204 (IDAPA 31.01.01.201-.204). Persons interested in submitting written
comments must do so by February 24, 2022. The Company must file any reply comments by March
2, 2022.
IT IS FURTHER ORDERED that Parties should continue to comply with Order No.
35058, issued June 3, 2021. All pleadings should be filed with the Commission electronically and
shall be deemed timely filed when received by the Commission Secretary. See Rule 14.02. Service
between Parties should also be accomplished electronically. Voluminous discovery-related
documents may be filed and served on CD-ROM or a USB flash drive.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 28th day
of December 2021.

ERIC ANDERSON, PRESIDENT

KRISTINE RAPER, COMMISSIONER

PAUL KJELLANDER, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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