20220224Comments.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208\ 334-0320
IDAHO BAR NO. 11542
IN TIIE MATTER OF INTERMOT]NTAIN
GAS COMPAAIY'S APPLICATION TO
REVISE ITS ELECTRONIC RECETVER
TRANSMITTER DRTVE RATE
PROGRAMMING AND VERIFICATION
PROCESS
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Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. INT.G-21.08
COMMENTS OF THE
COMMISSION STAFF
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COMES NOW the Staffof the Idatro Public Utilities Commission, (*StafP') by and
through its Attorney of record, Taylor Brooks, Deputy Attomey General, and submits the
following comments:
BACKGROT]ND
On December 6,202l,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 thfuty (30) days of installation to verifr the
programming rate and ensure that it matches the installed meter. The Company has revised its
procedures for veriffing ERT drives and meters and believes the current 30-day audit is no
longer necessary.
In 2008, after receiving two formal complaints involving billing erors arising from a
mismatch between the meter drive rate and drive rate programmed into the ERT, the Company
ISTAFF COMMENTS FEBRUARY 24,2022
worked with Staffto 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 veriff the ERT drive rate programming to ensure
that the drive rate matched the installed meter.l
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 constucted 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.
STAFF ANALYSIS
Staffreviewed the Company's Application,the2}OT MOU, and responses to production
requests. The Company is proposing a modified ERT programming and verification process in
which the ERT drive rate is set at either the meter manufacturer's facility or at the Company's
meter shop. Additionally, at time of installation, the ERT drive rate programming will be
verified. The Company states that this proposal provides two verifications and makes a third
verification, the 30-day audit, unnecessary. Application at 5. In addition, Staffbelieves the
Company's proposed process modifications and discontinuance of 30-day post installation meter
audits are within the Company's purview to provide service that complies with Customer Service
Rule 203.2
Currently, the Company verifies the drive rate atthe 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 prograrrrming, the Company audits meters to veriff that the drive rate
programming in the ERT matches the installed meter. In Staff s first Production Request, Staff
asked for data regarding the number of 30-day meter audits conducted and the number of
incorrectdriveratesfound. TheCompanyrespondedbyprovidingdatafromJune20l9through
Jlune202l, which showed an incorrect drive rate of 0.141 percent. Staffbelieves that the
Company's proposal to eliminate the 30-day audit is reasonable based on the low number of
incorrect drive rates found in the audit process.
I Case Nos. INT-G-06-01 and INT-G-07-02.
2 https://adminrules. idaho. qov/rules/cunent/3 I /3 I 2 I 0 I .pdf
2STAFF COMMENTS FEBRUARY 24,2022
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. tn Staff s second Production Request, Staffquestioned the
number of one-foot drive rate meters in service and when they will be converted or replaced by
two-foot drive rate meters. The Company responded with an estimate that it will convert 4,000
one-foot meters to two-foot and retire an additional 1,500 one-foot meters annually.
For all new ERT's prograrnmed 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
reprograrnmed 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.
Staff analyzed the Company's 30-day audit records to determine if there was evidence
that the new process was lowering the incidents where a meter was calibrated incorrectly.
Though the information was limited to the seven months since the new process was
implemented, the process appears to prevent erors. Since the new process was implemented,
there has only been one incidence where the 30-day audit caught a drive rate error, for a 0.008%
error rate. During the previous two years the error rate was 0.160%. Staffbelieves the new
process has reduced the number of drive rate errors.
Staffalso reviewed documentation the Company maintains for each meter to ensure the
ERT programming and verification process steps are recorded. The Company records meter
information, meter test results, and programming verification information for each meter at the
time of installation, serving as a checklist for the installer to ensure that the meter drive rate and
drive rate programmed into the ERT match. The data will also allow the Company to track and
identifu other issues with meters that can lead to billing erors.
cusroMER CoMMENTS, NOTTCE, AND PRESS RELEASE
Staff reviewed the August 2007 MOU and believes the document remains applicable and
should remain in force. Rebilling as described in the MOU is in alignment with the
Commission's Utility Customer Relations Rules (UCRR),IDAPA 3l-21-01, Rule 203. The
Company has also revised both its billing audit process to quickly identifu when customer usage
3STAFF COMMENTS FEBRUARY 24,2022
indicates a problem with the meters, including the ERTs; and its process to estimate usage in the
event of meter failure utilizing previous usage when available, estimated usage, if necessary, in
addition to local historical Heating Degree Days (HDD) in an Excel spreadsheet.
Staff has identified eleven rebilling complaints received by the Commission over the past
seven years. The complaints reviewed were the result of meter failure and not the result of
incorrect programing of drive rates.
The verification process and its proposed modification to remove a final field audit does
not affect rates and does not require customer notification as called for under the Commission's
Rules of Procedure 31.01.01.
STAFF RECOMMENDATIONS
After examining the Company's Application and responses to Production Requests, Staff
recommends the Commission approve the Company's proposed revisions to its Electronic
Receiver Transmiffer Drive Rate Programming and Verification Process eliminating the 30-day
drive rate audit.
Respecttully submitted this e'{ # day of Febru ary 2022.
General
Technical Staff: Kevin Keyt
Michael Eldred
Chris Hecht
Joseph Terry
i :umisc/commentyintg2 1 . Stbkkmechjt comments
4STAFF COMMENTS FEBRUARY 24,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF FEBRUARY 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. INT-G.2I-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
LORI BLATTNER
DIR _ REGULATORY AFFAIRS
INTERMOI-INTAIN GAS CO
PO BOX 7608
BOISE TD 83707
E-MAIL: [e-mail]
PRESTON N CARTER
GTVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
harmonywri ght@ givenspursley. com
CERTIFICATE OF SERVICE