20230626Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL 35IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )GAS COMPANY'S TARIFF ADVICE NO.23-)CASE NO.INT-G-23-01
02 )
)COMMENTS OF THE
)COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission,by and through its Attorneyof
record,Dayn Hardie,Deputy AttorneyGeneral,submits the followingcomments.
BACKGROUND
On May 5,2023,Intermountain Gas Company ("Company")filed Tariff Advice No.23-
02 ("TariffAdvice")proposing a revision to General Service Provisions,Section C,Sheet 3.
The Company requested the update become effective June 5,2023.The Tariff Advice requested
removing abandonment of gas facilities as an action requiring a charge since the removal or
safeguarding of abandoned facilities is done in a timely manner to protect the Public's safety
rather than an action that is done at the applicant's convenience."Tariff Advice at 1.
At the Commission's May 23,2023,Decision Meeting,the Commission Staff ("Staff')
presented a Decision Memorandum recommending the Commission convert the Tariff Advice
into a case under Case No.INT-G-23-01,issue a Notice of Application,and set public comment
and Company reply deadlines.Staff explained it began reviewing the Company's proposed tariff
STAFF COMMENTS 1 JUNE 26,2023
changes and wanted to propound formal discovery on the proposal before it makes a
recommendation to the Commission.Specifically,Staff wanted the opportunityto review the
financial implications of the proposal.Accordingly,Staff needed more time than is allotted
under the Company's proposed effective date to conduct and review responses to discovery.
Staff noted it consulted with the Company which agreed to the proposed procedural treatment.
On June 15,2023,the Commission issued Order No.35818 granting Staff's request for a
delay to the comment and reply comment deadlines,proposing June 26,2023,and July 7,2023,
respectively.
STAFF ANALYSIS
The Company submitted the Tariff Advice requesting to remove the word
"abandonment"from Section C,Subsection 3.2 of the Company's General Service Provisions for
the Installation and Extension of Natural Gas Mains and Service for Residential and Commercial
Customers.By implementing this change,the Company would not seek reimbursement from a
third party when "abandonment"occurs but would seek recovery of these costs through base
rates from the general body of ratepayers.Staff recommends that the Tariff Advice be changed
by modifying the format of the tariff and by adding meaningful definitions of "abandonment"
and "relocation,"providing the circumstances under which abandonment and relocation would
occur.
The Company differentiates abandonment from relocation based on whether service is
discontinued.See Response to Staff Production Request No.1.Staff agrees with the Company
that "abandonment"should be recovered through its base rates for the followingreasons:
1.The circumstances requiring abandonment make it difficult or impossible to
identify the party responsible for the decision leading to abandonment;
2.There is an absence of incentive to pay for abandonment because the party(s)that
previouslyused the line no longer require service;
3.Tracking and pursuing collections could become costly;and
4.Removing a line that is no longer in service avoids future safety hazards and
potential legal liability.
See Response to Staff Production Request No.6
STAFF COMMENTS 2 JUNE 26,2023
However,Staff believes the proposed tariff language does not provide the necessary
clarity differentiating"abandonment"from "relocation."Staff recommends creating a new
subsection to Section C,specifically addressing abandonment since it is fundamentallyseparate
from conditions that address adding,modifying,or relocating a service line necessary for
continuation of service.Staff also recommends adding definitions for "relocation"and
"abandonment"to Section C,Subsection 8,"Definition of Terms,"to clarify the difference
between the two types of service line removal.
STAFF RECOMMENDATION
Staff recommends the Company submit a compliance filing modifyingthe tariff language
as proposed by Staff within 30 days of a Commission order.
Respectfully submitted this ay of June 2023.
Dayn Hardie
Deputy AttorneyGeneral
Technical Staff:Mike Louis
i:umisc/comments/intg23.ldhml comments
STAFF COMMENTS 3 JUNE 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF JUNE 2023,SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,INCASENO.INT-G-23-01,BY E-MAILING A COPY THEREOF,TO THE
FOLLOWING:
LORI BLATTNER PRESTON N CARTER
DIR -REGULATORY AFFAIRS GIVENS PURSLEY LLPINTERMOUNTAINGASCO601WBANNOCKST
PO BOX 7608 BOISE ID 83702
BOISE ID 83707 E-MAIL:[e-mail]-MAIL:[e-mail] [e-mail]
SECRETARY
CERTIFICATE OF SERVICE