20230310TTS Response to Staff.pdf

TETON WATER & SEWER COMPANY
PO Box 786, Driggs Idaho 83422 Date: March 9, 2023 To: Idaho Public Utilities Commission Prepared By: Jon Pinardi, Teton Water & Sewer Company RE: Case No. – TTS-W-23-01
Response to Staff Recommendation Recommendation #1
Approve Company’s use of Emergency Reserve Fund for the entire amount of $3,928 for the repair at 33 Targhee Trail. Comment – We concur Recommendation #2 Reduce the remaining amount of projects to be included in Plant-In-Service by $484 for a total of $24,365. Comment – We will obtain a credit in the amount of $484 from the vendor with the credit to be booked in 2023. We disagree with moving the amount of $24,365 from previously booked expenses to a balance sheet account as taxes for 2022 have already been completed. Request – We request the Staff Recommendation be modified to record future unrecovered repairs as suggested by staff
starting in 2023, but not retroactively for the tax year already closed. This would require adjustments to our accounting books as well as revisiting the tax returns with the CPA and possible filing of amended returns. We do not believe the benefit outweighs the cost of the CPA in making this change retroactively. Also, this recommendation appears to exist solely for the purpose of tracking expenses for a possible future rate case. There does not appear to be any benefit to incurring a cost when we could use records already submitted for the same
purpose at some point in the future. Again, we suggest a new procedure beginning in 2023 to avoid any cost. Recommendation #3 Require the remaining amount of 2022 repairs in the amount of $24,365, along with the 2021 unrecovered repairs of $23,388, to be recorded in Account 101.333 for recovery in the Company’s next general rate case.
Comment – As above, making these changes will create an accounting change after the fact for not one, but two years. We believe the burden and cost of amending tax returns outweighs the benefit of making these changes for 2 years retroactively. Therefore, we request the Staff Recommendation be modified to record future unrecovered repairs as suggested starting in 2023, but not retroactively. Recommendation #4
Approve a depreciation rate of 30 years for these expense for an annual depreciation expense of $1,592. Request – As above, we request that beginning in 2023, a 30-year depreciation rate be applied to unrecovered repairs.
Thank you,
Jon Pinardi Teton Water & Sewer Company Office [phone]
RECEIVED
2023 March, 9 9:47AM
IDAHO PUBLIC
UTILITIES COMMISSION