20251202Final_Order_No_36860.pdf

Office of the Secretary
Service Date
December 1,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. INT G-24-05
OF INTERMOUNTAIN GAS COMPANY )
FOR A DETERMINATION OF 2023 )
ENERGY EFFICIENCY EXPENSES AS ) ORDER NO. 36860
PRUDENTLY INCURRED AND )
APPROVAL OF RATE SCHEDULE EE-RS )
On December 20, 2024, Intermountain Gas Company ("Company") applied to the Idaho
Public Utilities Commission ("Commission") requesting an order: (1) designating $3,846,358 of
2023 energy efficiency expenditures as prudently incurred by the Company; (2) approving the
proposed revisions to Rate Schedule EE-RS; and(3) approving the Company's use of the deemed
savings methodology for evaluating the cost-effectiveness of the Energy Efficiency Program("EE
Program")("Application"). On October 14,2025,the Commission issued a Final Order,approving
the Company's Application and Supplemental Application with modifications. Order No. 36797.
On November 4, 2025, the Company filed a Petition for Clarification or Reconsideration
of Commission Order No. 36797("Petition"). The Commission did not receive any cross-petitions
for reconsideration or answers to the Petition.
We now issue this Order providing clarification of Commission Order No. 36797 and
denying the Petition.
THE PETITION
The Petition concerned the Commission's directive "that the Company's next prudency
filing shall include an [Evaluation,Measurement,and Verification Study(`EM&V')]with a billing
analysis covering Whole Home Tier I and Furnace measures." Order No. 36797 at 13.According
to the Company, the Whole Home Tier I and Furnace measures may not produce sufficient data to
allow for statistically significant EM&V results. Petition at 1. The Company represented that the
results of such an EM&V would not be useful.Id.
Because the Company did not believe it will have a sufficient sample size or timeframe for
a meaningful billing analysis, it requested the Commission issue an order stating "that the
Company's next prudency filing must contain an EM&V evaluation with a billing analysis of the
Whole Home Tier I and Furnace measures if there is sufficient data regarding these measures to
conduct a statistically valid and useful EM&V study."Id. at 1-2. Otherwise, the Company stated,
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ratepayer dollars may be used inefficiently to conduct the Commission-ordered EM&V analysis.
The Company stated that it was willing to obtain and provide to Staff an opinion as to whether the
EM&V study required"is likely to result in a statistically valid or useful study."Id. at 2.
Alternatively,as the Company believed that the Whole Home Tier 1 measure may not prove
cost-effective under a billing analysis,the Company indicated it was willing to retire the measure,
effective December 31, 2025, if the Commission allows it to do so without a separate filing.Id.
COMMISSION FINDINGS AND DECISION
The Commission has the authority to grant or deny reconsideration pursuant to Idaho Code
§ 61-626(2). Reconsideration allows any interested person to bring to the Commission's attention
any question previously determined, and it affords the Commission an opportunity to rectify any
mistakes or omissions. Washington Water Power Co., v. Kootenai Environmental Alliance, 99
Idaho 875, 879, 591 P.2d 122, 126 (1979). Commission Rule of Procedure 331.01 provides:
Petitions for reconsideration must set forth specifically the ground or grounds why
the petitioner contends that the order or any issue decided in the order is
unreasonable, unlawful, erroneous or not in conformity with the law, and a
statement of the nature and quantity of evidence or argument the petitioner will
offer if reconsideration is granted.
IDAPA 31.01.01.331.01 (emphasis added). Any person may petition the Commission to clarify an
order under Rule 325, IDAPA 31.01.01.325. A petition for clarification may be combined with a
petition for reconsideration. Id.
Following our review of the Petition and the previously filed materials in the case record,
the Commission declines to grant reconsideration of Order No. 36797. The Company has failed to
adequately demonstrate that the Order"is unreasonable,unlawful, erroneous or not in conformity
with the law."
The directive that the Company conduct an EM&V with a billing analysis covering Whole
Home Tier I and Furnace measures is consistent with instruction issued in Order No. 36245. In
Order No. 36245, we stated that "the Company's next prudency filing shall include an EM&V
with a Billing Analysis covering Whole Home Tier I and Whole Home Tier II,Furnace, and Smart
Thermostat measures." Despite receiving no express instruction to use multiple years of data for
its billing analysis, in its resulting 2024 EM&V study, the Company "evaluated projects rebated
between April 1, 2021 and December 31, 2023." Petition at 2. In this case, in spite of the fact that
Order No. 36797's language concerning an EM&V study is nearly identical to that of Order No.
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36245, the Company represents that "[t]he EM&V study required by Order No. 36797...would
include only projects rebated in calendar years 2024 and 2025."Id.
As with Order No. 36245, in Order No. 36797, we declined to provide guidance as to the
appropriate timeframe from which the Company should draw billing data for the ordered EM&V
study or to limit the instances in which such a study is required. Due to the Company's inability to
demonstrate the unreasonableness, erroneousness, or unlawfulness of Order No. 36797, we deny
the Company's request to reconsider the Order.We encourage the Company to keep Staff informed
of developments related to the EM&V during the required quarterly meetings.
However, the Commission sees fit to issue clarification of Order No. 36797 regarding the
Company's offer to retire the Whole Home Tier I measure. We find it more appropriate for the
Company to submit a separate application to request changes to its existing DSM programs so that
interested parties may participate in the proceeding. If the Company does not believe the Whole
Home Tier I measure will be cost effective, it can submit a filing to the Commission requesting
authority to retire the measure.
ORDER
IT IS HEREBY ORDERED that the Company's Petition for Reconsideration is denied.
THIS IS A FINAL ORDER. Any party aggrieved by this Order or other final or
interlocutory Orders previously issued in this case may appeal to the Supreme Court of Idaho under
the Public Utilities Law and the Idaho Appellate Rules.
ORDER NO. 36860 3

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 1st day of
December 2025.
G
Gv�
DWARD LODGE, RE YIENT—
?014N R. HAMMOND JR., COMMISSIONER
Recused
DAYN HARDIE, COMMISSIONER
AT
TES
Laura Calderon Robles
Interim Commission Secretary
I:\Legal\GAS\INTG2405_EEE\orders\INTG2405_FO recon_jl.docx
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