BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION
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1 BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION IN THE MATTER OF ZIA NATURAL ) GAS COMPANY S APPLICATION FOR ) REVISION OF ITS RATES, RULES, AND ) FORMS UNDER ADVICE NOTICE NO., ) ) CASE NO. - -UT ZIA NATURAL GAS COMPANY, ) ) APPLICANT. ) ) PREPARED DIRECT TESTIMONY OF K. MARIT COBURN On Behalf of Zia Natural Gas Company Issues: Other Tariff Revenues Proposed Changes to Rules and Forms January, 0
2 NMPRC CASE NO. - -UT 0 I. WITNESS INTRODUCTION Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is K. Marit Coburn and I am employed by Natural Gas Processing Co. ( NGP ). I work from Zia Natural Gas Company s main office at 0 Short Drive, PO Box, Ruidoso Downs, NM,. Q. WHAT ARE YOUR POSITION AND RESPONSIBILITIES WITH NGP? A. I am the Customer Information System ( CIS ) Manager for the utility divisions and I have been in this position since January, 0. As CIS Manager, I am responsible for ensuring the office policies and procedures for Zia Natural Gas Company ( ZIA ) and Wyoming Gas Company ( WGC ) are in compliance with the rules of the New Mexico Public Regulation Commission ( Commission or NMPRC ) and the Wyoming Public Service Commission, respectively, and that these policies are being followed by all office personnel. I am also responsible for all software maintenance, upgrades, and integrations for the customer billing system, meter reading software, customer web access portal, and online payment portal; the monthly newsletter to all customers; newspaper, magazine, and radio advertising; and various other tasks. Q. PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL QUALIFICATIONS. A. I have a Bachelor of Science degree in Finance and Accounting and a Master of Business Administration in Business Management from the University of Colorado at Colorado Springs. I also have taken training in Utility Rate Design sponsored by the American Gas Association. Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING?
3 NMPRC CASE NO. - -UT 0 A. I am testifying on behalf of ZIA. Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE COMMISSION? A. No. Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? A. The purpose of my testimony is to present the proposed changes to service fees and charges as well as changes to the ZIA rules and forms. Q. DO YOU SPONSOR ANY EXHIBITS WITH YOUR TESTIMONY? A. Yes. I sponsor the following exhibits: Exhibit KMC- Other Tariff Revenue; Current and Proposed Rates Exhibit KMC- Other Tariff Revenue; Comparison with Other Utilities in New Mexico Exhibit KMC- Other Tariff Revenue; Local Plumbing Rates Q. WERE EXHIBITS KMC- THROUGH KMC- PREPARED BY YOU OR UNDER YOUR DIRECT SUPERVISION AND CONTROL? A. Yes. Q. ARE EXHIBITS KMC- THROUGH KMC- TRUE AND CORRECT TO THE BEST OF YOUR KNOWLEDGE AND BELIEF? A. Yes. Q. DO YOU SPONSOR ANY SCHEDULES? A. Yes, I sponsor the following schedules: Schedule K- (OTR) Other Tariff Revenues Q. WAS SCHEDULE K- (OTR) PREPARED BY YOU OR UNDER YOUR DIRECT SUPERVISION AND CONTROL? A. Yes.
4 NMPRC CASE NO. - -UT Q. IS SCHEDULE K- (OTR) TRUE AND CORRECT TO THE BEST OF YOUR KNOWLEDGE AND BELIEF? A. Yes. II. OTHER TARIFF REVENUES 0 Q. PLEASE EXPLAIN SCHEDULE K- (OTR) OTHER TARIFF REVENUES. A. Schedule K- (OTR) presents Other Operating Revenues earned by ZIA. Other Operating Revenues include Interest on Unpaid Customer Bills, Other Tariff Revenues, Revenues form Merchandising, Non-Tariff Revenues, and Special Contract Revenues. ZIA has proposed some changes to the Other Tariff Revenues. Q. WHAT ARE OTHER TARIFF REVENUES? A. Other Tariff Revenues are the revenues from the non-gas charges in ZIA s current Applicable Rate Schedules and Applicable Rules and Regulations on file at the NMPRC under Docket No UT, th Revised Rate No. Canceling th Revised Rate No., Special Fees and Charges. These include the New Connection Fee, the Account Transfer Fee, the Reconnection Fee, the Returned Payment Fee, and the Labor Rates for all services. Q. HAS ZIA PROPOSED A CHANGE TO THE OTHER TARIFF REVENUES? A. Yes, ZIA proposes a change to the Returned Payment Fee and the Labor Rate for Service Technicians. ZIA is also proposing the addition of two new fees: a Trip Charge for Door Tag Fee and an Energy Diversion/Meter Tampering Fee. Q. PLEASE EXPLAIN THE PROPOSED CHANGE TO THE OTHER TARIFF REVENUES. A. On Exhibit KMC- I outline the current rate, current revenue, proposed rate, and proposed revenue for each fee or penalty. ZIA proposes an increase to the Returned
5 NMPRC CASE NO. - -UT 0 Payment Fee and the Labor Rate for Service Technicians ( Service Charge ). ZIA also proposes to implement a new Trip Charge for Door Tag Fee and a new Energy Diversion/Meter Tampering Fee. Q. PLEASE EXPLAIN THE PROPOSED INCREASE TO THE RETURNED PAYMENT FEE. A. ZIA proposes to increase the Returned Payment Fee from $.00 to $.00 to recover the bank charges for processing a returned check as well as ZIA s costs for processing the returned check. ZIA s costs include reapplying the amount to the account, processing the fee, and contacting the customer either by phone, mail, or field contact. On Exhibit KMC-, I compare different non-gas charges for other utilities in New Mexico. Line lists the returned payment charges for different utilities. The proposed charge of $.00 is comparable to other utilities in New Mexico. In addition, the penalty will apply to all returned payments including checks, electronic draft, or credit card chargebacks. Q. PLEASE EXPLAIN THE PROPOSED INCREASE TO THE SERVICE CHARGE. A. ZIA proposes to increase the hourly Labor Rate for Service Technicians under the Service Charge category from $0.00 to $.00. The hourly Service Charge is billed primarily when reconnecting service or when requesting a connection after normal business hours. Work performed after :00 pm and before :00 am during weekdays, and any time on Saturday and Sunday, is billed at ½ times the normal rate. To determine the rate, I compared hourly service charges for local plumbing companies in each of our service areas and selected a comparable rate. Local hourly plumbing rates are shown on Exhibit KMC-. Local plumbing rates range from $0/hour to $/hour. Q. PLEASE EXPLAIN THE TRIP CHARGE FOR DOOR TAG FEE.
6 NMPRC CASE NO. - -UT 0 A. ZIA proposes to implement a Trip Charge for Door Tag Fee of $ per Door Tag. Approximately - days past the due date of the bill, ZIA Service Technicians hang a door tag on the door of each customer who still has a remaining balance over $ from the previous month s bill. Expenses incurred in hanging an average of,000 door tags each month include Service Technician labor, fuel, and wear and tear on vehicles. I believe these expenses should be borne by the delinquent customers who represent % of ZIA s customer base, and not by the % of ZIA s customers who pay their bills prior to receiving a door tag. We estimate the addition of this fee would encourage approximately % of ZIA s delinquent customers to pay their past due amount prior to the week ZIA Service Technicians would hang door tags, thus reducing the total number of door tags hung each month. Q. PLEASE EXPLAIN THE PROPOSED ENERGY DIVERSION/METER TAMPERING FEE. A. ZIA proposes to implement an Energy Diversion/Meter Tampering Fee of $0.00 per incident. This fee will be charged for the detection and investigation of any incidence of meter tampering, bypassing, or diversion of a meter, including incidents where service is connected or reconnected without authority. In addition to this fee, the customer shall be charged for the cost of any gas used, all materials, equipment, and Service Technician labor necessary to repair or replace ZIA s equipment damaged due to meter tampering. ZIA experiences multiple incidents of meter tampering each year in each of its service areas, has worked closely with local law enforcement to report every one of these incidents, and has attempted to have criminal charges brought against the customer under
7 NMPRC CASE NO. - -UT violation of New Mexico Statute 0-- Theft of Services. ZIA experiences an average of meter tampering incidents each year. Q. PLEASE SUMMARIZE THE PROPOSED CHANGE TO OTHER TARIFF REVENUE. A. The proposed increase to Other Tariff Revenue is $,. Please see Exhibit KMC-. Other Revenues are treated as a Revenue Credit within the Revenue Requirement model and have the net effect of reducing the amount of revenue from direct gas sales. III. PROPOSED CHANGES TO RULES AND FORMS Q. DO YOU PROPOSE ANY CHANGES TO THE RULES AND FORMS INCLUDED IN ZIA S TARIFFS? A. Yes, ZIA proposes the following changes: Rule No. Character of Service: Added Irrigation to paragraph B. Rule No. Rendering and Payment of Bills: Combined section A and B and removed the word residential to make the rule applicable to all rate classes. Added new section B, Payment Options. Rule No. Budget Payment Plan: Removed the word residential to make the rule applicable to all rate classes. 0 Rule No. Estimated Bills: Removed the word residential to make the rule applicable to all rate classes. Rule No. Disputed Bills:
8 NMPRC CASE NO. - -UT Removed the phrase residential or commercial sales and residential to make the rule applicable to all rate classes. Updated the minimum amount of the credit to be refunded from $.00 to $.00 to comply with Commission Rule...(A) NMAC. Rule No. Security Deposits, Guarantees of Payment: Removed the word residential to make the rule applicable to all rate classes. Updated the wording in paragraphs B, C, D, and G to comply with the wording in Commission Rules... through... NMAC. Rule No. Discontinuance and Restoration of Service: Removed the word Denying from the title of this section as it addresses restoration of service, not denying restoration of service. Removed the word residential to make the rule applicable to all rate classes. Replaced subparagraph in section D to comply with Commission Rule...(C)() NMAC. Added subparagraph in section E to comply with Commission Rule...(D)() NMAC. Updated the wording in section G and H to comply with Commission Rule... NMAC. Updated section J to include a reference to Rate No.. 0 Updated the time frame for disconnect in section N to comply with Commission Rule...(D) NMAC. Updated the wording in section O to comply with Commission Rule...0 NMAC.
9 NMPRC CASE NO. - -UT Rule No. Payment Agreements: Updated the title of this section on the table of contents page from Settlement Agreements to Payment Agreements to reflect the actual title of the section. Updated wording to comply with Commission Rules...0 and... NMAC. Rule No. Commission Complaint Procedures: Updated the wording in section A to comply with Commission Rule... NMAC. Rule No. Unauthorized Connections and Tampering with Equipment: Added reference to Energy Diversion/Meter Tampering Fee in Rate No. to paragraph B. Rule No. 0 Service of Notice to Customers: Added last sentence in paragraph A in accordance with Commission Rule...(A) NMAC. Q. DO YOU PROPOSE ANY CHANGES TO ANY FORMS? A. Yes, ZIA proposes the following changes: Form No. Customer Service Guide: 0 Added reference to Commission Rule.. NMAC to front page. Updated locations of payment center offices and phone numbers. Added Reconnection of Service and Payment Options sections. Added last sentence to Energy Assistance Programs, Winter Moratorium Programs, and Applying for Service sections. Added A. in the Billing Procedures section to include rate riders.
10 NMPRC CASE NO. - -UT Updated wording in the Budget Payment Plan section to reflect how ZIA s program works. Added NMPRC contact information to the Disputed Bills section. Replaced th point in the three day notice section to match rule change. Form No. Bill Form: Changed Customer Number to Account Number to reflect the correct field name in ZIA s new billing software. Added Energy Efficiency sections in English and Spanish on the back side of the bill form. Form No. Shut-Off Notice: Added the updated labor cost for reconnection. Form No. Three Day Disconnect Notice: Replaced fourth bullet point to comply with Commission Rule...(C)() NMAC. Added final paragraph to comply with Commission Rule...(D)() NMAC. Added signature line. Form No. Notice of Discontinuance of Service for Failure to Comply with Payment Agreement: 0 Changed Customer Number to Account Number. Added wording to comply with Commission Rule... NMAC. Updated office phone numbers, removed outdated P.O. Box. Form No. Application for Gas Service:
11 NMPRC CASE NO. - -UT Added Irrigation as a type of service. Added with Zia to question about current gas service for clarification. Changed font size and format of question about discontinuing current gas service. Moved Application Taken By to end of signature line. Rearranged the order of some of the other fields requesting information. IV. CONCLUSION Q. PLEASE SUMMARIZE YOUR TESTIMONY. A. My testimony explains the proposed changes to Other Tariff Revenues, as shown in Schedule K- (OTR), to update fees and include new fees; and explains the proposed changes to ZIA s rules and forms to update them and bring them into conformance with the Commission s rules. Q. IN YOUR OPINION, ARE THESE PROPOSALS IN THE PUBLIC INTEREST? A. Yes, these proposals are in the public interest and should be approved. Q. DOES THIS COMPLETE YOUR TESTIMONY AT THIS TIME? A. Yes, it does.
12 Zia Natural Gas Company Other Tariff Revenues Exhibit KMC- Current and Proposed Rates [A] [B] [C] [D] [E] [F] [G] Proposed Test Line No. Description Count Current Rate Current Revenue Proposed Rate Proposed Revenue Year Adjustment New Connection Fee $.00 $, $.00 $, $ - Account Transfer Fee $.00 $,0 $.00 $,0 $ - Reconnection Fee 0 $.00 $,0 $.00 $,0 $ - Reconnection Fee (After Hours) $.0 $ 0 $.0 $ 0 $ - Returned Payment Fee $.00 $, $.00 $,00 $, Labor - Service Charge $ 0.00 $,0 $.00 $, $, Labor - Service Charge (After Hours) $.00 $ 00 $.0 $ 0 $ 0 Energy Diversion/Meter Tampering Fee (proposed) $ - $ 0.00 $,0 $,0 Trip Charge for Door Tag Fee (proposed) $ - $.00 $, $, Total $, $, $,
13 Zia Natural Gas Company Other Tariff Revenues Exhibit KMC- [A] [B] [C] [D] [E] [F] [G] [H] [I] [J] [K] New Mexico - Natural Gas and Electric Utilities Line ZIA ZIA Central NM Charge Description NM Gas Raton NG EPE PNM SPS OCEC Lea Co Elec No. current proposed Elec Connect Fee-next day $.00 $.00 $ 0.00 $.00 $. $.00 $ 0.00 $ 0.00 Connect Fee-same day or holiday $.00 $ $ $ 0.00 Reconnect fee - within months $.00 $.00 $.00 $.00 $.00 Reconnect fee - for non-payment $.00 $.00 $ 0.00 $ 0.00 $.00 $ 0.00 $ 0.00 $ 0.00 Returned Payment $.00 $.00 $.00 $.00 $. $.00 $.00 $ 0.00 $ 0.00 Collection charge away from office $.00 $.00 $.00 $.00 Labor rates (hourly) $ 0.00 $.00 $ 0.00 $ 0.00 $.00 Energy Diversion (meter tampering) $ 0.00 $.00 $ $ * $ $ No Access to Meter $.0 $.00 Special Bill Analysis $.00 $.00 Out of Cycle meter reading $.00 $ 0.00 Records Change $.00 Trip to premise to collect or cut for non-pay $ 0.00 Trip charge for door tag $.00 $.00 Notes: *0 first time, 00 each time after that (OCEC meter tampering) Comparison with Other Utilities in New Mexico
14 Zia Natural Gas Company Other Tariff Revenues Exhibit KMC- Local Plumbing Rates [A] [B] [C] Line No. Company Location Hourly Rate Marker Svcs Hobbs $ Jay's Inc. Hobbs $ 0 A-Tech AC & Heating Hobbs $ Tru Degree Maxwell $ D&M Plumbing & Heating Maxwell $ 0 Bonito River Services Ruidoso $ Haynes Plumbing Ruidoso $ Alto Plumbing & Heating Ruidoso $ 0 On the Go Heating & Cooling Las Cruces $ Valley Plumbing Las Cruces $ Stadjuhar's Heating & Cooling Las Cruces $ 0 Sun City Plumbing & Heating Las Cruces $ Four Season's Las Cruces $ 0 Average hourly plumber rate $ Proposed Labor Rate for Service Technicians $ Reference: All rates are from customer invoices submitted for Energy Efficiency Program Rebates
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