20251110Final_Order_No_36841.pdf

Office of the Secretary
Service Date
November 10,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN ) CASE NO. GNR-E-25-03
PACIFIC, LLC'S PETITION FOR )
EXEMPTION FROM MASTER METERING )
RULE 101 OF THE COMMISSION'S ) ORDER NO. 36841
MASTER METERING RULES FOR )
ELECTRIC UTILITIES )
On August 14,2025, Intermountain Pacific,LLC("Company")petitioned the Idaho Public
Utilities Commission ("Commission") requesting an exemption from Rule 101 of the
Commission's Master Metering Rules for Electric Utilities ("Rule 101"), for a development to be
built in Meridian, Idaho.
On September 4,2025,the Commission issued a Notice of Petition and Notice of Modified
Procedure, establishing a twenty-one(21)day,deadline for public and Commission Staff("Staff')
comments, followed by a seven (7) day, deadline for the Company to file reply comments. Order
No. 36752.
We now issue this Order granting the Company's Petition, subject to conditions, as
explained herein.
THE APPLICATION
The Company requested an exemption from Rule 101 for a senior housing project located
on Linder Rd., in Meridian,Idaho ("Project"). Petition at 2. The Company provided the property's
legal description with its Petition. Id. at Exhibit A.
The Company stated the Project had been reviewed and approved by the City of Eagle. Id.
at 2.It submitted copies of the recorded Development Agreement and the City of Eagle's approvals
in support of its request.Id. at Exhibit B.
The Company asserted that the Commission's rules governing metering in multi-occupant
residential buildings posed challenges to the Proj ect's goal of providing residents with a single,
consolidated bill from the Company, thereby eliminating the need for multiple invoices from
different service providers. Id. at 2. The Company stated that, even if individual metering were
required,it would still be responsible for administering the electric bills and payments for all units.
Id. at 3.
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The Company indicated that the Project would be constructed with energy-efficient
features designed to ensure equitable and efficient energy use among residents. Id. at 3-4. The
Company also expressed its willingness to comply with any conditions of approval the
Commission might impose. Id. at 4. The Company recommended that the Commission consider
conditions such as: limiting the exemption to periods during which the Project operates as an
independent living, assisted living, memory care, or similar institutional-type facility; requiring
that the exemption terms be recorded with the Ada County Recorder's Office to provide notice to
prospective purchasers, tenants, or guests; and mandating disclosure of the exemption terms in
private agreements between residents and the Project. Id.
STAFF COMMENTS
Staff recommended that the Commission deny the Company's Petition seeking an
exemption from Rule 101, which prohibits master metering in multi-occupant residential
buildings. Staff Comments at 3. Staff believed that the Company had not satisfied the requirements
of Rule 101 because the facility's heating and air-conditioning systems were not designed for
central control and instead allowed residents to directly manage their individual electrical usage
for heating and cooling.Id. at 2-3. Staff argued that this design was inconsistent with the provisions
of Rule 101 and therefore recommended that the Commission deny the requested exemption. Id.
at 3.
COMPANY REPLY
In response to Staff s Comments, the Company acknowledged that its proposal was not
consistent with Rule 101, emphasizing that this inconsistency was precisely the reason for
submitting the Petition. Company Reply Comments at 2. The Company believed that Staff s
analysis should not have centered on whether the Project complied with Rule 101, but rather on
prior Commission Orders in which similar exemptions had been granted under comparable
circumstances.Id.
The Company reaffirmed its position that an exemption was appropriate in this case and
cited three prior Commission Orders where exemptions were approved for facilities such as
assisted living developments.Id. at 3. The Company further contended that Staff should have taken
these precedents into account when formulating its recommendation. Id. at 4.
ORDER NO. 36841 2

COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over this matter under Title 61 of the Idaho Code; the
Commission's Rules of Procedure, IDAPA 31.01.01.000 and the Commission's Master-Metering
Rules for Electric Utilities, IDAPA 31.26.01.000 et. seq.
IDAPA 31.26.01.101 provides: "Non-transient tenants living in multi-occupant residential
buildings connected for electric service after July 1, 1980, containing an electric space heating,
water heating,or air-conditioning(space cooling)unit that is not centrally controlled and for which
the dwelling unit's tenants individually control electric usage will be individually metered and
billed by the electric utility."
The Commission has previously stated that "the primary reason that master-metering was
prohibited was to encourage conservation by providing direct signals(through individual metering
and billing)to consumers regarding their use." Order No. 26451 (quoting Order No. 23936).
Historically, the Commission has granted exemptions from its Master-Metering Rules for
Electric Utilities to senior living and institutional care facilities when petitioners have
demonstrated that individual billing would not effectively promote energy conservation among
residents and that the facility's design includes adequate energy efficiency measures. Having
reviewed the record,we find that the characteristics of this Project do not support the effective use
of individual metering and billing as a means to encourage conservation. Furthermore, the
Company has proposed to implement sufficient energy efficiency features to fulfill the primary
objectives of the master-metering rules. Accordingly, we find it reasonable to approve the
requested exemption from Rule 101 of the Commission's Master-Metering Rules for Electric
Utilities, subject to specified conditions.
1) The exemption from the prohibition of master-metering applies only so long as the facility
is used for assisted living or similar institutional type care-giving;
2) The Project continue to incorporate energy efficiency measures into the Project; and
3) The terms of this exemption are recorded at the Ada County Recorder's office in a manner
that would put any prospective purchaser of the facility on notice to the terms of this
exemption.
ORDER
IT IS HEREBY ORDERED that the Company's request for an exemption from Rule 101
of the Commission's Master-Metering Rules for Electric Utilities is granted for the Project located
ORDER NO. 36841 3

on Linder Rd., in Merdian, Idaho, subject to the three conditions set forth above in the
Commission's Findings and Decision.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order about any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. See Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this loth day of
November 2025.
YRDDGE, RE I ENT
AOHN HAMMOND JR., COMMISSIONER
DAYN HARDIE COMMISSIONER
ATTEST:
?4UO -4
L a Calderon Robles
Interim Commission Secretary
IALega1\ELECTRIC\GNR-E-25-03_MM exempt\orders\final_em.docx
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