Idaho Precedent on Utility Authority to Replace Meters under Tariff Provisions

Introduction

In Edwards v. Idaho Public Utilities Commission, 2025-ID-SC-51238, the Idaho Supreme Court addressed whether Rocky Mountain Power Company (“Rocky Mountain”) could terminate service to Samuel and Peggy Edwards for refusing installation of a “smart” meter on grounds of health concerns. The Edwards argued that their refusal did not constitute a denial of access under Rocky Mountain’s filed tariff or under the Idaho Utility Customer Relations Rules (UCRR), and that they had a constitutional right to opt out. The central issues were (1) the scope of Rocky Mountain’s tariff authority to access the meter base for replacement, (2) whether the PUC was required to interpret UCRR 302 when no UCRR claim was pleaded, and (3) whether the Edwards’ constitutional rights were infringed.

Summary of the Judgment

The Supreme Court of Idaho affirmed the PUC’s orders dismissing the Edwards’ complaint and denying their reconsideration request. The Court held that:

Rocky Mountain’s tariff provisions (Electric Service Regulation Nos. 6 and 7) unambiguously grant authority to access customer meter bases to repair, remove, and furnish meters—including replacing analog meters with smart meters.
The PUC was under no obligation to interpret or apply UCRR 302 when the Edwards’ formal complaint did not plead that rule as a basis for relief.
The Edwards’ novel constitutional claim was not supported by proper authority or factual foundation and was therefore waived.

Analysis

1. Precedents Cited

Intermountain Gas Co. v. Idaho Pub. Utilities Comm’n, 97 Idaho 113, 540 P.2d 775 (1975) – Standard of review for PUC findings (abuse of authority or lack of substantial evidence).
Industrial Customers of Idaho Power v. Idaho Pub. Utils. Comm’n, 134 Idaho 285, 1 P.3d 786 (2000) – PUC findings supported by substantial, competent evidence must be affirmed.
Lowden v. Simonds-Shields-Lonsdale Grain Co., 306 U.S. 516 (1939) – Filed tariffs bind utilities and customers as law and form the contractual agreement.
Afton Energy, Inc. v. Idaho Power Co., 111 Idaho 925, 729 P.2d 400 (1986) – PUC’s subject-matter jurisdiction is strictly limited to enabling statutes; unpleaded issues are outside its authority.
Cole v. Idaho Pub. Utils. Comm’n, 2025-ID-SC-___, 565 P.3d 815 – Private parties are not state actors for purposes of constitutional due process under the Fifth and Fourteenth Amendments.

2. Legal Reasoning

The Court began by identifying the controlling documents: Rocky Mountain’s filed tariff under Idaho Code § 61-305 and the UCRR (IDAPA 31.21.01). Tariffs bind customers “with the force of law” once approved (Lowden). Rocky Mountain’s Electric Service Regulations (ESR) create two relevant obligations:

ESR No. 6: Customers must provide “safe, unencumbered access” for reading, inspecting, repairing, or removing metering devices and wiring.
ESR No. 7: Rocky Mountain will “furnish and maintain all meters and other metering equipment.”

Taken together, these provisions grant Rocky Mountain authority to remove existing meters and furnish replacement devices—necessarily encompassing “smart” meter installations. The Court rejected the Edwards’ strained reading that removal and furnishing could not imply replacement. Because the Edwards refused access in violation of the tariff, termination of service was permitted under Rocky Mountain’s terms.

On the UCRR issue, the Court held that the PUC lacked authority to interpret UCRR 302 when the Edwards never pleaded it. PUC Rule IDAPA 31.01.01.054 requires formal complaints to specify the statute, rule, or tariff provision alleged to be violated. Absent a UCRR claim in the complaint, the PUC properly confined its analysis to the tariff issue actually raised.

Finally, the Edwards’ constitutional argument under Article I, § 1 of the Idaho Constitution was waived for failure to cite controlling authority or demonstrate how a private utility’s actions trigger constitutional protections. The Court noted that due process claims require state action, which was not shown.

3. Impact

This decision clarifies several important principles for Idaho utility regulation:

Tariff Authority: Filed tariffs granting utilities broad meter-access rights will be enforced according to their plain language, including meter replacement.
PUC Jurisdiction: The PUC’s adjudicatory scope is strictly confined to allegations presented in complaints; unpleaded regulatory or constitutional issues may not be addressed sua sponte.
Customer Options: Idaho customers have no inherent “opt-out” right from smart meters unless expressly provided by tariff or rule.
Future Filings: Consumers challenging meter installations or service terminations must expressly invoke the relevant tariff provisions, UCRR rules, or statutory rights in their initial pleadings.

Complex Concepts Simplified

Tariffs: Official rate schedules and service rules that utilities file with the PUC and that function like a contract with customers.
Electric Service Regulations (ESR): Sections within a tariff that detail customer and utility obligations—here, about meter access and ownership.
PUC Standard of Review: The Supreme Court reviews PUC decisions only for abuse of authority or lack of substantial evidence; it does not re-weigh facts.
UCRR: Uniform rules that impose minimum standards on all utilities; where a tariff conflicts with UCRR, the UCRR controls.
State Action: Constitutional protections (like due process) apply only when a government actor, not a private party, takes the challenged action.

Conclusion

Edwards v. IPUC establishes that under Idaho law utilities may rely on plainly worded tariff provisions granting meter-access and replacement rights to install smart meters and may terminate service for customer refusal. The PUC need not rule on unpleaded UCRR grounds, and private utilities’ actions do not alone trigger Idaho constitutional guarantees. Moving forward, both utilities and customers must carefully frame disputes around the precise tariff language and UCRR provisions they seek to enforce.