20240403Staff Comments.pdf

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ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TETON WATER& )
SEWER COMPANY'S APPLICATION FOR ) CASE NO. TTS-W-24-01
RESERVE FUND DISTRIBUTION )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following
comments.
BACKGROUND
On February 12, 2024, Teton Water& Sewer Company, LLC ("Company") filed its 2023
Reserve Fund Usage Report("Report") requesting Commission approval to use its reserve funds
for two projects completed in 2023. The Company requested the application be processed
through Modified Procedure.
The Company submitted its Report on 2023 reserve fund expenditures, reflecting
expenditures of$36,408 for the following projects: Water Leak Repairs at 45 Targhee Trail and
4 Blackfoot Trail.
STAFF COMMENTS I APRIL 3, 2024

The reserve funds were used to cover$5,375 for asphalt work at 45 Targhee Trail and
$5,665 for work at 4 Blackfoot Trail. The remaining project costs $25,368—were paid from
operating funds.
STAFF ANALYSIS
In Order No. 30718, the Commission authorized the establishment of the Emergency
Reserve Fund("Fund") with specific parameters for accessing the funds. The requirements for
accessing the funds were as follows:
1. The Company must file a notice of application to use the funds;
2. The Fund is to be used only for emergencies and major unplanned capital
expenditures (plant repair, maintenance, and replacement);
3. The Company must establish an auditable paper trail for all expenses paid from the
fund; and
4. The funds can be used only for capital expenditures greater than 10% of the
Company's annual revenue requirement.'
On February 12, 2024, the Company filed an application requesting to use the funds for
two projects completed in 2023:
• 45 Targhee Trail Water Leak Repair, $24,612; and
• 4 Blackfoot Trail Water Leak Repair, $11,795.
The Company included invoices and photos documenting all project expenses in its
Application. Staff reviewed all supporting documents and concludes that both projects qualify as
unplanned emergency repairs.
While reviewing invoices and photos for the water leak repair on 4 Blackfoot Trail, Staff
discovered an affiliate transaction between the Company and Teton Management Services Inc.
("TMS"),both owned by Jon Pinardi. The invoice in question included services provided by
TMS for 13.5 hours of general labor at a labor rate of 28 dollars per hour. Staff compared the
labor rate charged by TMS with the fair market labor rate for similar services and determined
that the rate was appropriate for the nature of the repair.
' The 10%annual revenue requirement was eliminated in order No. 34000.
STAFF COMMENTS 2 APRIL 3, 2024

The total cost of the two projects, $36,408, exceeds the $11,850 available funds in the
reserve account, however the Company is only requesting to use $11,040 of the available
funds. Staff recommends the remaining repairs of$25,368 not covered by the emergency
reserve fund be booked to account 101.333 ("Plant-in-Service", sub-account"Services")to be
recovered in the Company's next general rate case.
STAFF RECOMMENDATION
Staff recommends the Commission:
• Approve the Company's use of the reserve fund for 2023 in the requested amount of
$11,040; and
• Require the$25,368 amount for 2023 repairs not covered by the emergency reserve
fund, be recorded in Account 101.333 for recovery in the Company's next general rate
case.
Respectfully submitted this 3rd day of April 2024.
Adam Triplett
Deputy Attorney General
Technical Staff Ty Johnson
1:\Utility\UNHSC\CO1vAfNTS\TTS-W-24-01 Commentsdocx
STAFF COMMENTS 3 APRIL 3, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF APRIL 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. TTS-W-24-01, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
JON PINARDI
TETON WATER& SEWER CO
PO BOX 786
DRIGGS ID 83422
E-MAIL: jpinardi(u,silverstar.com
Tetonwsa,silverstar.com
I
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE