20190910Intermountain Gas Comments.pdf

EXECUTIVE OFFICES
I rqtenruouNTArN Gns CorupeNv
555 SOUTH COLE ROAD . p.O. BOX 7608 . BOTSE, |DAHO 83707 . [phone] . FAX: [phone]
September 10,2019
REC E IVED
2019 SEP l0 Pl{ 12: I I
r-,1 tnt l/\i.J- -l1i-i i"U(lt-lUrl :l-i r ; Iri C0l,{iillSSlON
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
RE: Intermountain Gas Company Comments in Case No. RUL-U-19-01
Dear Ms. Hanian
Intermountain respectfully submits the following comments regarding the proposed rule changes outlined in
Case No. RUL-U-19-01.
31.21.01- CUSTOMBR
UTILITIES (THE UTILITY CUSTOMER RELATIONS RULES)
Section 310.01.a
In subsection (a) of Rule 310.01, the Commission proposes striking the language "or two (2) months'
charges for service". Striking this language would eliminate a long-standing interpretation of this rule by
both Intermountain and the Commission Staff which allows the Company to begin the process for
termination of service if a customer's bill is over two months past due, but also under the $50 threshold. It is
quite common for customers that only use natural gas for space heating to owe less than $50 for an entire
summer of service. In some cases, non-payment of bills for a period of several months is due to incorrect
billing information. Often, the collection notice or phone call are the triggers that prompt the customer to
correct the payment issue. If the proposed strikeout is accepted, waiting for the $50 benchmark to accrue
could allow past due bills to accumulate for over six months before an issue is resolved.
Intermountain believes it is in the best interest of all customers to resolve non-payment issues as quickly as
possible. Encouraging payment while past due bills are relatively small and connecting customers with
payment assistance earlier helps keep bad debt expenses from growing. For these reasons, Intermountain
encourages the Commission to leave the phrase "or two (2) months' charges for service" in the final rule.
3t0. rNsl;FFtctENT GROI:NDS rOR TERMIN.TTIOIi OR DE!\lAL OF SERVI('E (Rl:LE Jl0).
01. Tcrminrtiol of Senice. Ne es$€mer rhdl be Eivgn nsti€e sf Lrminfltisn el $ryi€s ner 6h.l! lh3
ffi Utilities must not terminate scn'icc or providc noticc of intcnt to tcrminatc scrvicc
if thc unoaid bill citcd as srounds for tcrmirution is: (4-2{f}
r. @ llcss than lifty dollarr (S50@
ffi. (4-2{t)
Section 401.02
The Commission proposes striking the language "in connection with the subject matter of the complaint" in
section 401.02.If approved, this revision would introduce some ambiguity into the rule regarding the
utility's ability to terminate service in the situation where the customer stops paying all bills, not just
disputed amounts, during the complaint process. Although the rule as proposed would state that "The utility
may continue to issue bills and request payment from the customer of any undisputed amounts," it is unclear
if the utility would still be permitted to terminate service for non-payment of bills unrelated to a pending
complaint.
Because complaints can sometimes take a significant amount of time to go through the Commission process,
the customer could potentially accrue a large balance if they continued to receive service without paying the
bills related to that service during the time a complaint is pending. Additionally, this change might
encourage customers to file frivolous complaints in order to avoid paying bills.
Intermountain encourages the Commission to leave the phrase "in connection with the subject matter of the
complaint" in the final rule.
02. flrrdrm*cvirrTrrdriftnotscruisc-Ulferlclf,lfr.@
titility scrvicc ch.ll musr nor bc rcrminatod nor tcrmination bc thretsd by noticc or o{trcru,irc ie"esmlien+vilh
@fi*whitc thc complaint ir pcoding hforc thc Commi*rico-s{en6lls.*c+urrrcr
r rsFcsmtrtivc ef thc Csmmisgien 'hell be rcquird te ilrrt ryrd e€nfsr, Thc utiliW mav contmuc
rcoucst oaynrnt li'om thc customcr of anv undisoutcd amounts. (7-l-93)
If you should have any questions regarding these comments, please contact me at [phone]
Sincerely%rPilW
LoriA. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
Enclosures
cc: Mark Chiles
Preston N. Carter