20250407Answer to Formal Complaint.pdf

RECEIVED
April 7, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
Megann E. Meier, ISB No. 11948
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]
18864573.1 [14168.371
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION Case No. INT-G-25-01
STAFF'S FORMAL COMPLAINT
CONCERNING INTERMOUNTAIN GAS INTERMOUNTAIN GAS COMPANY'S
COMPANY AND THE REXBURG LIQUID ANSWER To FORMAL COMPLAINT
NATURAL GAS FACILITY
Intermountain Gas Company (Intermountain Gas or the Company) files this Answer in
response to the Formal Complaint.
INTRODUCTION AND BACKGROUND
Intermountain Gas and Staff have engaged in negotiations in an attempt to reach a
mutually agreeable resolution of the Complaint.
Intermountain Gas believes that these negotiations will be successful.
Out of an abundance of caution; to preserve its rights; and to avoid requesting another
extension; Intermountain Gas files this answer to the Complaint. Intermountain Gas reserves all
its rights, including the right to amend this Answer if the case progresses.
RESPONSES TO ALLEGATIONS
To preserve its rights, Intermountain Gas denies each of the allegations in the Complaint.
ANSWER TO FORMAL COMPLAINT PAGE 1 OF 3

To preserve its rights, Intermountain Gas affirmatively alleges its actions regarding the
ownership, operation, maintenance, and otherwise regarding the Rexburg LNG Facility have
been reasonable and consistent with applicable laws and regulations.
To preserve its rights, Intermountain Gas affirmatively alleges that the allegations in the
Complaint do not support or warrant any civil penalties or the other relief requested in the
Complaint.
REQUEST FOR RELIEF
To preserve its rights, Intermountain Gas requests that the Commission:
1. Establish a procedural schedule that allows sufficient time for continued settlement
discussions;
2. If a settlement agreement is not reached, establish a procedural order that allows
Intermountain Gas a full and fair opportunity to investigate and respond to the allegations
in the Complaint, including the right to conduct discovery and to present legal and factual
responses and defenses to the allegations in the Complaint;
3. If a settlement agreement is not reached, and after such proceedings as established by the
Commission, that the Commissions dismiss or deny the Complaint without imposition of
a civil penalty or other relief sought in the Complaint.
Dated: April 7, 2025.
GIVENS PURSLEY LLP
By G
Preston N. Carter
Attorneys for Intermountain Gas Company
ANSWER TO FORMAL COMPLAINT PAGE 2 OF 3

CERTIFICATE OF SERVICE
I hereby certify that on April 7, 2025, I caused to be served a true and correct copy of the
foregoing document to the person(s) listed below by the method indicated:
Commission Staff Via Electronic Mail
Monica Barrios-Sanchez secretarykpuc.idaho.gov
Commission Secretary monica.barriossanchezg]2uc.idaho.gov
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Chris Burdin chris.burdinkpuc.idaho.gov
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Preston N. Carter
ANSWER To FORMAL COMPLAINT PAGE 3 OF 3