20261020Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: KELSEA E. ROSS
DEPUTY ATTORNEY GENERAL
DATE: OCTOBER 20, 2026
SUBJECT: INVESTIGATION INTO DALE RAINEY DESIGN GROUP,OWNER OF A
HOUSING DEVELOPMENT AND UNDERGROUND PIPELINE SYSTEM;
CASE NO. GNR-G-25-01.
BACKGROUND
In early October 2024, Commission Staff("Staff') discovered that Old Mill Land, LLC1
("Company") was allegedly building a new underground pipeline system for a new housing
development in Old Town, Idaho. The Company is not a utility; is not currently regulated by the
Idaho Public Utilities Commission ("Commission"); and does not currently possess a Certificate
of Public Convenience and Necessity.
Staff learned that the location in Old Town could not be serviced by the existing pipeline
system in the area. Staff visited the development site on Old Mill Road to confirm that a new
development was being built by the Company that included a buried pipeline system.
At the Commission's March 4, 2025, Decision Meeting Staff recommended that the
Commission open an investigation into whether the Company and its underground pipeline system
should be regulated by the Commission.
On March 12, 2025, the Commission issued a Notice of Investigation, ordering Staff to
investigate the status of the Company and its underground pipeline system. Order No. 32497 at 1.
On March 18, 2025, the Company filed a response to Order No. 32497 to inform the Commission
1 The Commission was informed through a letter from the Company that the owner of the new housing development
was not Dale Rainey Design Group,but Old Mill Land,LLC.Company Response to Order No.36497.
DECISION MEMORANDUM 1

of the correct owner of the Company,to describe the private propane system for the development,
and the Company's work with the local fire district. Company Response to Order No. 36497 at 1.
STAFF RECOMMENDATION
Staff corresponded with the Company regarding its pipeline system plans and the relevant
regulatory conditions and requirements. Staff also conducted an onsite inspection of the
Company's pipeline system in August 2026. Based on representations from the Company
regarding changes it made to its pipeline system plans,and Staff s onsite inspection, Staff believes
that the Company has changed its pipeline system plan so that said system does not fall under the
jurisdiction of the Commission's pipeline safety program.
Accordingly, Staff believes that the investigation is complete and that no further action
from the Commission is necessary. Thus, Staff recommends that the case be closed. Staff will
remain vigilant of the Company's pipeline system and will request another investigation into said
system if Staff believes the need arises.
COMMISSION DECISION
Does the Commission wish to order that the investigation is complete and that this case is
closed?
V kt,� 9 4n-
Kelsea E. Ross
Deputy Attorney General
I:\Legal\GAS\GNRG2501_DRD_investigation\memos\GNRG2501_dec2_kr.docx
DECISION MEMORANDUM 2