20220330Final_Order_No_35359.pdf

ORDER NO. 35359 1

Office of the Secretary
Service Date
March 30, 2022

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

ORDER NO. 35359

On December 6, 2021, Intermountain Gas Company (“Company”) applied to the Idaho
Public Utilities Commission (“Commission”) to revise its current electronic receiver transmitter
(“ERT”) drive rate and verification process. Application at 1. Currently, the Company audits each
newly installed ERT unit within 30 days of installation to verify that the programming rate matches
the meter. Id. The Company revised its procedures for verifying each ERT drive and meter and
believed the 30-day audit is no longer necessary. Id.
On December 28, 2021, the Commission issued a Notice of Application and Notice of
Modified Procedure setting comment deadlines for the public and the Company’s reply. See Order
No. 35275. Staff filed comments to which the Company did not reply.
Now, the Commission issues this final Order granting the Company’s Application,
allowing it to revise its current ERT drive rate and verification process by eliminating the 30-day
audit.
BACKGROUND
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. Staff Comments at 1-2. Based upon the MOU, the Company instituted
a 30-day audit practice after installation to verify the ERT drive rate programming matched the
installed meter drive rate.1 Id. at 2.
The drive rate represents the amount of gas consumed during one cycle of the
diaphragm within the meter. Id. In the previous formal complaints, the ERT drives were

1 Case Nos. INT-G-06-01 and INT-G-07-02.

ORDER NO. 35359 2
programmed with a one-foot drive rate while the meters were constructed with a two-foot drive
rate. Id. This mismatch in drive rates caused the gas consumed for billing purposes to be exactly
one half of the actual amount of gas consumed. Id.
THE APPLICATION
The Company is working toward a two-foot ERT drive standard for all residential
meters believing that doing so will eliminate variability that could otherwise cause a mismatch
between the meter and ERT drive rates. Application at 5. All new residential meters purchased
with ERT’s will be programmed at the meter manufacturer’s facility with a two-foot drive rate. Id.
For one-foot drive meters that are converted to two-foot drive meters, the Company stated that the
meter shop will reprogram the ERT to a two-foot drive rate. Id. The Company stated that all ERTs
programmed or re-programmed at the manufacturer’s facility were audited to verify that the ERTs
were programmed with two-foot drive rates. Id. at 6. The Company believed the new process of
programming the ERT before installation and then verifying the ERT at the time of installation
provided the two-step verification process envisioned under the MOU. Id. The Company
represented that only one error has occurred during the new process and it was due to operator-
error. Id. Accordingly, the Company believes the current 30-day audit process is no longer
necessary. Id. at 7.
STAFF COMMENTS
Staff recommended the Commission approve the Company’s Application as filed. Staff
Comments at 2. Staff believed the Company’s proposed modification and discontinuance of a 30-
day post installation audit were within the Company’s discretion. Id. Staff believed the Company’s
proposal complied with Customer Service Rule 203, IDAPA 31.21.01.203. Id. The Company
provided data to Staff which showed an incorrect drive rate of 0.141 percent. Staff Comments at 2.
Staff believed the Company’s proposal was reasonable given this low rate of error. Id.
Staff verified that two-foot drive meters, when calibrated correctly, are more likely to
prevent errors. Id. at 3. Staff also verified the Company’s documentation process and verified that
the Company records meter information, meter test results, and programming verification
information for each meter at the time of installation. Id. Staff represented that this process serves
as a checklist for the installer to ensure that the meter drive rate matches the drive rate programmed
into the ERT. Id. Staff also represented that the data would allow the Company to track and identify
issues with meters to correct if necessary. Id.

ORDER NO. 35359 3
Staff stated that the Company revised its billing audit process to better identify when
customer usage indicates a problem with the meters, including the ERTs and stated that the
verification process as proposed in the Application would not affect rates or require customer
notification, Id. at 4.
COMMISSION FINDINGS AND DECISION
The Company is a gas corporation and public utility as defined in Idaho Code §§ 61-
117 and -129. The Commission has jurisdiction over the Company and the issues in this case under
Title 61 of the Idaho Code, including Idaho Code §§ 61-501 and -503. The Commission is
empowered to investigate and modify Company rules and regulations. Idaho Code § 61-503. We
find the Company’s proposed revision to eliminate the 30-day drive rate audit in its ERT drive rate
programming and verification process established in the MOU is reasonable given the evidence of
the Company’s low rate of error and the plans to audit the installation process. The Commission
encourages the Company to continue training employees to verify that ERT drive-rates are
programmed and matched correctly with the installed or constructed meter rate.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application is granted. The Company
may revise its ERT drive rate programming and verification process to eliminate the 30-day drive
rate audit.
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
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-
626.
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ORDER NO. 35359 4
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 30th day
of March 2022.

ERIC ANDERSON, PRESIDENT

JOHN CHATBURN, COMMISSIONER

JOHN R. HAMMOND JR., COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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