Additional IGC Comments.pdf

EXECUTIVE OFFICES RECEIVED II)
INTERMOUNTAIN GAS COMPANY FILED
555 SOUTH COLE ROAD. P.O. BOX 7608. BOISE,IDAHO 83707. (208) 377-0Zbutftif~9~t1 9:~5
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November 25, 2002
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Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
O. Box 83720
Boise , ID 83720-0074
Re:IN THE MATTER OF THE APPLICATION TO IMPLEMENT A TWO-YEAR PILOT WINTERPROTECTION PROGRAM THAT ESTABLISHES MINIMUM MONTHLY PAYMENTS
DURING THE WINTER MORATORIUM, AND A WAIVER OF WINTER MORATORIUM
RULE 306, IDAPA 31.21.01.306.
IPUC CASE NO. GNR-02-
Dear Ms. Jewell:
In response to Comments of the Commission Staff, dated November 21 , 2002, pursuant to theabove referenced Case, Intermountain Gas Company respectfully requests that the Commissionalso include in its consideration of the Pilot Winter Protection Program the additional pointscontained in this letter.
Intermountain Gas is appreciative of the Commission Staff's comments and the level of agreementthere appears to be with us on many key points. While there are concerns regarding the startingdate for a pilot program and the extent to which a customer "safety net" should be provided, thereappears to be consensus regarding the following:
The four goals of the Moratorium Policy should include preserving the public health and safety by
limiting termination circumstances, encouraging good payment habits by customers, providingsome relief from impossible financial obligations, and facilitating collection of problem accounts;
The eligibility criteria for the existing moratorium program does not provide an objective criteriafor distinguishing between those who are truly unable to pay and those who are simply unwilling
to pay;
When customers decide not to pay at all, charging interest has not been a sufficient incentive for
payment;
There is less incentive for heating-only customers to pay their gas bills and reconnect ascompared to electric customers;
The Winter Payment Plan has failed to be an incentive for payment with no Intermountaincustomers participating;
Application to Implement 2 Yr. Pilot Program
Page 2 November 25, 2002
The proposed Pilot Program , which uses income criteria for LlHEAP as a proxy for customerswho are unable to pay, is a reasonable, objective screening criteria to use;
Customers who can pay either in full or in part should be required to pay; and
A two-year pilot program is the appropriate time frame for gathering information to aid in program
evaluation.
On November 8-, 2002 , Intermountain Gas mailed notice of the Application in the abovereferenced Case and a description of the proposed Winter Protection Program to 100% of ourresidential customers. Additionally, should the Pilot be approved , customers who call seekingmoratorium protection this winter will have the Winter Protection Program fully explained to thempersonally by one of our Customer Contact Representatives. Intermountain Gas will continue toprovide customers who do not meet the moratorium eligibility criteria with level pay plans, special
payment arrangements and counseling on where to seek other assistance.
During the comment period , Intermountain Gas contacted a number of agencies and organizationsrepresenting potentially effected customers and offered to further explain the Winter ProtectionProgram to them in order to address any concerns they may have. These meetings were veryproductive and typically resulted in statements of support. The significant number of supportingcomments received by the Commission and shared with us by Staff has also been veryencouraging.
Intermountain Gas remains committed to the Winter Protection Program and stands ready toimplement the Pilot on December 1 , 2002 should the Commission approve it.
If you have any questions, or if I can be of additional assistance, please don t hesitate to contact meat 377-6064.
Sincerely,
Paul R. Powell
Sr. Vice President, Finance & Administration CFO
PRP/sik