20260727Final_Order_No_37108.pdf

Office of the Secretary
Service Date
July 27,2026
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNTAIN ) CASE NO. INT-G-25-08
GAS COMPANY'S 2025 INTEGRATED )
RESOURCE PLAN ) ORDER NO. 37108
On December 23, 2025, Intermountain Gas Company ("Company") filed its 2025
Integrated Resource Plan ("2025 IRP") with the Idaho Public Utilities Commission
("Commission")and requested that the Commission issue an order acknowledging the Company's
2025 IRP. On February 20, 2026, the Commission issued a Notice of Filing, a Notice of
Intervention Deadline,and a Notice of Modified Procedure, setting a deadline for interested parties
to file a petition to intervene and establishing comment deadlines. Order No. 36941. No petitions
to intervene were filed. Commission Staff("Staff') filed the only comments.
Based on our review of the record,we issue this Final Order acknowledging the 2025 IRP
and directing the Company to use the Pipeline and Hazardous Materials Safety Administration
("PHMSA") prescribed formula for all lost and unaccounted for natural gas ("LAUF")
calculations.
BACKGROUND
In response to amended Section 303 of the Public Utility Regulatory Policies Act of 1978
("PURPA"), in 1993 the Commission issued IRP requirements for local gas distribution
companies. Order No. 25342. Since that time, the Commission has issued a series of orders over
the years governing IRP requirements for local gas distribution companies and directed the
Company to file an IRP every two years that includes:
1. A forecast of future gas demand in firm and interruptible markets for each customer class,
which includes the number, type, and efficiency of gas end users as well as effects from
economic forces on gas consumption;
2. An analysis of gas supply options for each customer class, which includes a projection of
spot market versus long-term purchases for both firm and interruptible markets, an
evaluation of the opportunities for using company owned or contracted storage or
production, an analysis of prospects for company participation in a gas futures market, and
an assessment of opportunities for access to multiple pipeline suppliers or direct purchases
from producers;
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3. A comparative analysis of gas purchasing options and improvements in the efficient use of
gas, and an explanation of whether there are cost-effective Demand Side Management
("DSM") opportunities;
4. The integration of the demand forecast and resource evaluations into a long range (at least
a five-year)plan describing the strategies designed to meet current and future needs at the
lowest cost to the utility and its ratepayers;
5. A section on LAUF reports that detail how the Company tested for and remediated leaks
or errors, and the Company's business practice on alleviating measurement errors;
6. A short-term(e.g.,two-year)plan outlining the specific actions to be taken by the utility in
implementing the IRP;
7. A progress report that relates the new plan to the previously filed plan; and
8. Public participation.
See Order Nos. 27024, 27098, 32855, 33314, 33997, and 34742 (collectively the "Commission
Orders").
2025 IRP
The 2025 IRP was approximately one hundred and sixty-six (166) pages, with
approximately five hundred and fourteen (514) pages of Exhibits. The 2025 IRP set forth four
substantive sections: (1) Executive Summary; (2) Demand; (3) Supply and Delivery Resources;
and(4) Optimization. 2025 IRP at ii-vi. The 2025 IRP outlined the Company's projected customer
demand over a five-year planning horizon, the resource strategies expected to meet that demand,
and the decision-making framework used to evaluate resource options. Id. at 1. The Company
represented it incorporates public participation as an element of the 2025 IRP process, and in
accordance with regulatory requirements, the Company submits an updated IRP to the
Commission every two years.Id.
The Company explained that the 2025 IRP represented a point-in-time assessment of
anticipated conditions rather than a definitive roadmap for future resource decisions, as market,
regulatory, and operational factors may evolve over the planning period.Id. The Company stated
its 2025 IRP evaluated residential, commercial, and large-volume customer demand growth under
multiple scenarios and assessed the resulting impacts on its distribution system using design-
weather conditions. Id. at 5. The Company explained forecasted demand was compared with
existing natural gas delivery capabilities to identify the potential magnitude and timing of system
constraints, both system-wide and within specific areas of interest. Id. The Company represented
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it also evaluated a range of resources, solutions, and energy efficiency measures to identify the
most cost-effective and operationally feasible approaches to addressing these constraints. Id.
STAFF COMMENTS
Staff examined the 2025 IRP to determine whether it met the requirements set forth in the
Commission Orders, and whether the Company adequately planned its future resources to meet
demand from 2026 through 2030. Staff Comments at 3. Based on its review, Staff believed that
the 2025 IRP satisfied the requirements set forth in the Commission Orders and was reasonable.
Id. For those reasons, Staff recommended the Commission:
1. Acknowledge the 2025 IRP; and
2. Direct the Company to use the PHMSA prescribed formula for all LAUF calculations
moving forward.
Id. at 15.
Staff believed that the Company provided most of the material the Commission directed
the Company to work on with Staff and to develop in Order No. 36249. Id. at 13-14. During its
review, Staff noted a significant discrepancy between the total LAUF the Company reported to
Staff during discovery in this case and the total LAUF reported to the PHMSA.Id. Staff believed
that the method the Company was using to calculate LAUF was different from the method set by
PHMSA. Id. Staff also believed the Company's LAUF calculation supplied inaccurate LAUF
amounts for the last several years.Id. Through discovery with Staff,the Company represented that
it would conform to the PHMSA set calculation method for all future LAUF reporting starting in
2026.Id.
COMMISSION FINDINGS AND DECISION
The Company is a natural gas corporation and public utility. See Idaho Code §§ 61-116,
-117, and -129. The Commission has jurisdiction over the Company and the issues in this case
under Title 61 of the Idaho Code, including Idaho Code § 61-501.
The Commission has reviewed the record in this case. Based on our review, we find that
the 2025 IRP satisfies the requirements in the Commission's Orders and that the Company
provided the material the Commission directed it to work with Staff on and develop in Order No.
36249. Thus,the Commission acknowledges the 2025 IRP. In doing so,the Commission reiterates
that an IRP is a working document that incorporates many assumptions and projections at a specific
point in time. An IRP is a plan, not a blueprint, and by issuing this Final Order the Commission
ORDER NO. 37108 3

merely acknowledges the Company's ongoing planning process, not the conclusions or results
reached through that process.
The Commission does not approve the 2025 IRP, or any resource acquisition referenced in
it, endorse any particular element in it, opine on the Company's prudence in selecting the 2025
IRP's preferred resource portfolio,nor allow or approve any form of cost recovery.The appropriate
place to determine the prudency of the Company's decisions to follow or not follow the 2025 IRP,
and the validation of predicted performance under the 2025 IRP, is a general rate case or other rate
proceeding where the issue is noticed.
Lastly, due to the discrepancy between the total LAUF the Company reported to Staff
during discovery, and the total LAUF reported to the PHMSA, we direct the Company to use the
PHMSA prescribed formula for all LAUF calculations moving forward. The Commission
appreciates the work done by the Company and by Staff to ensure that the IRP and the IRP process
continues to be informed by the most accurate and relevant resource information.
ORDER
IT IS HEREBY ORDERED that the 2025 IRP is acknowledged.
IT IS FURTHER ORDERED that the Company shall use the PHMSA prescribed formula
for all LAUF calculations moving forward.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within 21 days of the service date of this Order regarding any matter decided in
this Order.Within seven days after any person has petitioned for reconsideration, any other person
may cross-petition for reconsideration.Idaho Code § 61-626.
ORDER NO. 37108 4

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 27th day of
July 2026.
G
EDWARD LODGE, Rb9IDENT
J R. HAMMOND JR., COMMISSIONER
DAYN HA IE, COMMISSIONER
ATTEST:
do i a fi
anchez
Commission Secretary
I:\Legal\GAS\INTG2508_IRP\orders\INTG2508_FO_la.docx
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