20071025Intermountain Gas comments.pdf

EXECUTIVE OFFICES
INTERMOUNTAIN GAS COMPANY 11 t: r. t ,,~ '-" '-.
555 SOUTH COLE ROAD. P,O. BOX 7608. BOISE, IDAHO 83707. [phone]. FAX: [phone]
2001 OCT 24 PH 3: 33
October 24, 2007 tf'Jz"bO PUBLIC11 '
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UTILITIES C N\i~;; ;:, vi
Jean Jewell
Idaho Public Utilities Commission
472 W Washington St.
PO Box 83720
Boise, ID 83720-0074
Re: Intermountain Gas Company
IPUC Docket No. 31-2101-0701
R,uL-O"1-0~
Dear Ms. Jewell:
Intermountain Gas Company ("Intermountain does hereby submit for
consideration by this Commission several comments regarding the proposed
changes to the IPUC Customer Relations Rules.
Intermountain appreciated the Commission s efforts to establish a Best Practices
forum. We believe those meetings are a necessary step in helping to facilitate the
Rule change process. Intermountain supports, with comment, many of theproposed changes which were fostered by those meeting sessions. Intermountain
believes, however, that several of the proposed changes are inconsistent with the
Best Practices general work sessions and we therefore also provide comments on
the few specific Rule change proposals that we oppose.
Rule 105:AMOUNT OF DEPOSIT
Intermountain supports.
However, Intermountain would like to point out that our experience has
shown that for our space heating only RS-1 customers, the existing two
(2) highest month bill deposit requirement is insufficient to adequately
protect the Company and its customers from the bad debts incurred from
this same RS-1 customer class. Intermountain is committed to working
with the Commission Staff to formulate solutions to what Intermountain
believes to be inadequate RS-1 deposit requirement.
Rule 203:BILLING UNDER INAPPROPRIATE TARIFF SCHEDULE.
Intermountain SUDportS.
October 24, 2007
Rule 204: INACCURATELY BILLED SERVICE UNDER CORRECT TARIFF
SCHEDULE - FAILURE TO BILL FOR SERVICE.
Intermountain SUDport, in part, and opposes, in part.
Intermountain supports the proposed six (6) month time period
limitation for under billings. However, Intermountain opposes the
requirement that an overcharge be given different (longer) time period
calculation parameters than an undercharge. This asymmetric
component of the proposed Rule has a built-in unfavorable financial bias
to the Company as we view this asymmetry as automatically imposing a
financial penalty to the Company.
Rule 300:FURTHER DEFINITIONS
Intermountain supports.
Rule 302: GROUNDS FOR DENIAL OR TERMINATION OF SERVICE WITH
PRIOR NOTICE.
Intermountain opposes the Rule Change of 302.08.
It appears this change is put in place in an attempt to be aligned with
Idaho Code regarding statute of limitations for the collection of
outstanding debts. While Idaho Code does provide a time frame for
which old debts may no longer be pursued through litigation , there is no
provision in the Code to dismiss the debt entirely. Additionally, there is
no requirement for the creditor to enter into a new agreement with the
debtor while the old debt remains outstanding.
It is unreasonable to expect a utility to expose itself, and ultimately all
ratepayers, to additional risk by entering into a credit agreement with a
customer that has not satisfied the prior debt that was accumulated with
that utility. Furthermore, it could be contended that a customer that is
not disputing the legitimacy of the prior debt and enters into a new
credit agreement with the utility would be resetting the running of the
statutory period.
Intermountain believes that with the exception of debts discharged in
bankruptcy, all prior obligations owed by the customer, regardless of the
passage of time, should be paid in full prior to establishing new service
with the utility. As a result, the Company requests that the proposed
changes and additions to Rule 302 and 310 not be adopted and remain
in their current form.
October 24, 2007
Rule 310:
SERVICE.
INSUFFICIENT GROUNDS FOR TERMINATION OR DENIAL OF
Intermountain opposes for the same reasons provided for Rule Change
302.08.
Rule 311: TIMES WHEN SERVICE MAY BE DENIED OR TERMINATED -
OPPORTUNITY TO AVOID TERMINATION OF SERVICE.
Intermountain opposes the Rule Change of 311.01 and 311.04.
Rule 311.01: Intermountain contests the premise that access to
personal financial resources ends on Thursday at 4:00 p., and is not
available again until Monday. This premise is unsubstantiated in today
society. There are more opportunities for financial resources today than
when the Customer Relation Rules were adopted in 1978.
Customer complaints are a key driver in how we approach the day to
day work. To our knowledge, we have received no complaints from our
customers concerning the lack of access to financial resources
Fridays.
Fifteen percent of the weekly disconnect workload is completed on
Fridays and most banks are open through Saturday until noon or later.
Customers also have a very broad array of payment options open to
them including ATM's and credit card payments available thru our
Interactive Voice Response System or directly on line and ACH payment
options available on line. We also have 63 pay station locations open toaccept payments after 5: OOpm , evenings and weekends for the
customer s convenience. Each of these various payment options are
available over a broad time horizon , many being available 24 hours per
day. Staff is available to reconnect the service Friday evenings and
throughout the weekend. The customer currently has a minimum of 45
days from receipt of the bill until actual disconnection. At any pointduring this process the customer is encouraged to contact
Intermountain and make payment arrangements to extend or postponethe disconnection date. Further restricting the Company s time to
perform disconnect work will increase the Monday through Thursday
workload, significantly delaying service to other customers.
Also, we find including the 2 day notification requirement covered in
Rules 301 and 312 with requirements stated in Rule 311 to be unfair.
Intermountain currently allows one (1) additional day to the 2 day
requirement. Postponing disconnect of service, an additional three days,
places an unfair burden on both the previous customer and the
company.
October 24, 2007
Intermountain oDposes the need to provide information concerning the
denial of service and restricting times when service may be denied.
Rule 311.04: We oppose the requirement of providing confidential
information to the service technician concerning reasons why service is
being denied. This information has already been provided verbally
and/or in writing to the applicant as required in Rules 301 and 312. This
information is of a confidential nature and we prefer not to release it
through the service technician. We also oppose the addition of denial tothis rule. Denying service does not change the existing status of the
service. Under the proposed change if the applicant contacted
Intermountain on a Friday, any weekday after 5:00 p.m. or on a
weekend requesting service be connected or be put into their name and
we determined that the applicant had an outstanding amount or first
installment of the deposit to be paid, we would be unable to inform the
applicant of the service denial. We would have to postpone the denial
until the following workday. This rule would cause additional confusion
and workload.
Rule 403:RECORD OF COMPLAINTS.
Intermountain SUDportS.
Rule 600:DEFINITIONS.
Intermountain SUPDortS.
Should you have any questions, or if I can be of additional assistance, please do not
hesitate to contact me at 377-6075.
Sincerely,
--)h
Jv v,;
Terri Shoen
Director Customer Services
cc: Eldon Book
Mike McGrath
Paul Powell
Mike Rich