20250925Staff Comments.pdf

RECEIVED
September 25, 2025
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11560
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN )
PACIFIC,LLC'S PETITION FOR ) CASE NO. GNR-E-25-03
EXEMPTION FROM MASTER METERING )
RULE 101 OF THE COMMISSION'S )
MASTER METERING RULES FOR ) COMMENTS OF THE
ELECTRIC UTILITIES ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On August 14, 2025, Intermountain Pacific, LLC ("Company")petitioned the
Commission requesting an exemption from IDAPA 31.26.26.01.101 ("Rule 101") of the
Commission's Master Metering Rules for Electric Utilities, ' for a development to be built on
Linder Road,just north of US 20/26 ("Property") in Meridian, Idaho. Application at 1.
' Reference IDAPA 31.26.01.101. Rule 101 provides:
10. MASTER-METERING AND INDIVIDUAL METERING IN MULTI-OCCUPANT RESIDENTIAL
BUILDINGS (Rule 101). No multi-occupant residential buildings shall be master metered after July 1, 1990,if the
dwelling units for non-transient tenants contain an electric space heating,water heating,or air conditioning(space
STAFF COMMENTS 1 SEPTEMBER 25, 2025

The Company states that they are developing a senior living project on the Property
("Project"), including independent living and assisted living services. The Company states that
the Project has been reviewed by the City of Eagle, including approval, execution, and recording
of a development agreement authorizing the Project. Id. Independent living and assisted living
services are offered to the Project residents, with the goal of having the residents' needs provided
by the facility itself, including food,utilities, rent, activities, and amenity use costs, etc., included
in one bill. Id. The Commission rules for metering in a multi-occupant residential building
present a challenge for this model and its goal of simplifying living arrangements for individuals
requiring care and assistance. Within the Project, individual residents will be charged the costs
of electricity,but the goal is to ensure that individual residents are not handling invoices or bills
from a variety of service providers; instead, each resident will be charged an amount relative to
the number of units/occupants. The requirement for individual metering is not beneficial under
these circumstances. If individual metering were required in a building with 100 units, there
would be 100 electrical meters and 100 power bills, with all of them being paid by one entity
(the owner of the Project). Application at 2. The goal of the policy is to give residents visibility
into their power use though these residents in many cases are not prepared to have meaningful
input into their power consumption. Id. The Project residents' electrical consumption will be
largely consistent and there is no reason to differentiate or require separate invoices under these
circumstances. Id.
STAFF ANALYSIS
Staff evaluated the Company's Application and Exhibits, responses to Staff s Production
Requests, and historical Commission decisions in forming its recommendation to the
Commission.
Staff believes the Company does not meet the requirements of Rule 101. Rule 101
requires non-transient tenants in multi-occupant residential buildings connected to electric
service after July 1, 1980, to be individually metered if their dwelling units contain electric space
cooling)unit that is not centrally controlled and for which the dwelling units' tenants individually control electric
usage.
STAFF COMMENTS 2 SEPTEMBER 25, 2025

heating, water heating, or air-conditioning units that are not centrally controlled and for which
tenants have individual control over electric usage.
Staff evaluated the facility's space heating, water heating, and air-conditioning systems.
Rule 101 prohibits master-metering when these systems are not centrally controlled. The
Company states that domestic hot water will be provided by a central plant. However, the space
heating and cooling will be served by individual roof-mounted heat pumps (one per unit), and
each unit will have its own thermostat. This design gives tenants direct control over their own
electrical usage for heating and cooling, which conflicts with Rule 101. Accordingly, Staff
recommends the Commission deny the Company's request for an exemption under Rule 101.
STAFF RECOMMENDATION
Staff recommends that the Commission deny the Company's petition for an exemption to
Rule 101 prohibiting master-metering of multi-occupant residential buildings.
Respectfully submitted this 25th day of September 2025.
Erika K. Melanson
Deputy Attorney General
Technical Staff. Jon Kruck
Michael Ott
I:\Utility\UMISC\COMMENTS\GNR-E-25-03 Comments.doex
STAFF COMMENTS 3 SEPTEMBER 25, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 251h DAY OF SEPTEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. GNR-E-25-03, BY &MAILING A COPY THEREOF, TO THE
FOLLOWING:
INTERMO UNTA IN PA CIFIC, LLC
Mike Chidester
2451 E. Gala Street, Suite 310
Meridian, ID 83642
E-MAIL: mike.chidester&eltondev.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE