20240411Staff Comments.pdf

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Thursday,April 11,2024 3:2321 PM
IDAHOPUB IC
UIIIITIES Cb1VMS4ON
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
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 SCHWEITZER WATER )
COMPANY'S APPLICATION FOR ) CASE NO. SWC-W-23-01
APPROVAL OF ACQUISITION OF THE )
ASSETS OF RESORT WATER CO. INC. AND )
FOR THE ISSUANCE OF A CERTIFICATE ) COMMENTS OF THE
OF PUBLIC CONVENIENCE AND ) COMMISSION STAFF
NECESSITY )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Michael Duval, Deputy Attorney General, submits the following
comments.
BACKGROUND
On December 27, 2023, Schweitzer Water Company("Schweitzer"),' a subsidiary of
Alterra Mountain Company U.S. Inc. ("Alterra"), applied for approval of its acquisition of
Resort Water Co. Inc.'s ("Resort Water") assets ("Transaction"). Specifically, Schweitzer
requested that the Commission(1) approve the acquisition of Resort Water's assets, (2) grant
I This same company previously filed a case with equivalent requests—except that the proposed entity to be named
on that requested CPCN was Husky Water Company. See Case No.HWC-W-23-01. After deciding that the
Company name on the requested CPCN should instead be Schweitzer Water Company,the Application in Case No.
HWC-W-23-01 was withdrawn. In October 2023,Husky Water Company amended its Articles of Incorporation
with the Idaho Secretary of State to reflect the new name Schweitzer Water Company.
STAFF COMMENTS 1 APRIL 11, 2024

Schweitzer a new Certificate of Public Convenience and Necessity ("CPCN")pursuant to Idaho
Code § 61-526 and Rule 112 of the IPUC Rules of Procedure, IDAPA 31.01.01.112 that
authorizes service to the area previously served by Resort Water and the Ridge System, and (3)
approve Schweitzer's proposed tariffs ("Application").
Schweitzer stated that on August 22, 2023, it acquired Resort Water from its parent
company—Schweitzer Mountain LLC. Schweitzer stated that Resort Water operated two
smaller water systems (the"Resort System" and the"Ridge System"). At the time of these
acquisitions, Schweitzer was known as Husky Water Company. The Resort System operates
under CPCN No. 445. The Ridge System, once known as Acme Water Works, Inc. ("Acme")
previously operated under CPCN No. 518 when it was known as Acme. "[The Ridge System]
has been operated by Resort Water since January 1, 2018, but without amendment to or transfer
of Acme's CPCN No. 518."2 Application at 5. If Schweitzer's Application is approved, it will
provide water to both service areas under a new CPCN number. Schweitzer stated that it intends
for Resort Water's employees and contractors to fill their same roles when working for
Schweitzer.
Schweitzer's Application is structured to conform with the requirements of Idaho Code §
61-328. However, Schweitzer acknowledged that Idaho Code § 61-328 is not a mandatory
authority as it specifically applies to the sale of assets by electric utilities—not water utilities.
STAFF ANALYSIS
Based on its review of the Application, exhibits, and responses to Production Requests,
Staff recommends the Commission issue a new CPCN authorizing service to the areas previously
served by Resort Water and the Ridge System. Additionally, Staff recommends the Commission
cancel CPCN No. 445 for Resort Water and CPCN No. 518 for the Ridge system.3 Finally, Staff
recommends the Commission approve the proposed tariffs subject to the recommendations
discussed below.
z It is not clear from the Application that the Ridge System is currently operating under a valid CPCN.
s CPCN No. 518 issued to ACME Water Order No. 33210.
STAFF COMMENTS 2 APRIL 11, 2024

Public Interest
Staff believes this transaction is consistent with the public interest. Schweitzer plans to
make investments to increase both the safety and reliability of the system. Schweitzer will have
access to capital that is not currently available to Resort Water via Schweitzer's parent company,
Alterra.
Schweitzer will maintain its expertise in operating a regulated water utility by retaining
employees, procedures, and licensed officials of Resort Water. See J. Brownlie Di, pp. 6 - 7.
Schweitzer will continue to provide 24-hour response to repairs or water quality issues.
Application at 9.
Customer Rates
Customer rates will not increase due to the sale of the Resort System or the Ridge
System. The two water systems have different customer rates. Schweitzer charges Resort Water
and Ridge System customers a fixed monthly charge for each Equivalent Residential Unit
("ERU"). The Resort Water charge is $44.80 per ERU per month, or$537.44 per year. The
Ridge System charge is $29.25 per ERU per month, or$351.00 per year.
Resort Water's CPCN and rates were established in Order No. 29732, Case No. RES-W-
04-01. The rates for the Ridge System were established in Order No. 33219, Case No. AWW-
W-13-01. While the rates and a partial CPCN were approved in that case, a formal tariff is not
on file with the Commission. Schweitzer's proposed tariff rates do not increase. However,
Schweitzer proposed modifications to the tariff language as described in the tariff section below.
Schweitzer Intent and Ability to Operate
Staff believes that Schweitzer, with the support of its parent Company Alterra, has a bona
fide intent and the financial ability to operate and maintain the water systems. Alterra owns and
operates water systems and treatment plants at other resort properties in Vermont, California,
Utah, and Washington. Application at 3. Alterra will also retain the employees from the Resort
Water Company. These employees have familiarity with the system and have historically
maintained adequate service.
Staff reviewed Alterra's Consolidated Accounting Statements for 2022. Alterra shows a
consolidated cash and cash equivalent of$1.1 billion, consolidated revenue of$1.6 billion, a net
STAFF COMMENTS 3 APRIL 11, 2024

income of$106 million, and a net cash from operation activities of$441 million. This illustrates
that Alterra has sufficient financial resources to fund any capital expenditures needed to maintain
the system.
Alterra states that rates would not be increased due to the proposed Transaction.
Application at 6. At this point, all the costs of the transaction have been paid by Alterra and not
Resort Water. Therefore, the only way that the costs of this transaction could be placed into
rates is for some or all those costs to be allocated from the parent company to Schweitzer. As of
this time, there has not been an allocation methodology developed to allocate costs from Alterra
to Schweitzer. This allocation methodology will be reviewed when Schweitzer files an
application to change its rates in a future proceeding.
Accounting
Assessment Fees and Annual Reports
Schweitzer has agreed to pay the past due balance owed by the Ridge System, formerly
Acme. Schweitzer will be responsible for assessment fees and annual reports. As of March 5,
2024, the amount owed by Acme for Commission fees and interest on unpaid balances was
$355.60. The invoice was mailed to Mr. Trulock by certified mail on Wednesday, March 6,
2024. On March 21, 2024, counsel for the Company confirmed that the invoice will be paid. On
March 22, 2024, in a conversation with Staff, the Company stated that the statement would be
submitted for expedited processing on March 25, 2024. As of April 11, 2024, the payment has
not been received.
When the Application was filed, the Commission had not received any annual reports
from Acme, nor the 2019 and 2021 annual reports for Resort Water. The Commission received
the signed copies of annual reports for Acme from 2018 to 2022 and the missing Resort Water
annual reports on March 11, 2024.
CPCN
Per Schweitzer's request, Staff recommends the Commission cancel CPCN Nos. 445
(Resort System) and 518 (Ridge System) and authorize a new CPCN that combines the two
service territories as provided in Attachment A to Staff Comments. Supplement to Application
at 2. Staff verified that these combined legal descriptions match the mapped area that Schweitzer
STAFF COMMENTS 4 APRIL 11, 2024

plans to provide service and that the area does not interfere or encroach upon any other water
systems.
While reviewing the maps and proposed legal descriptions supplied in Exhibit Nos. 0006
and 0007 of the Application, Staff discovered that the legal descriptions and the existing CPCN
Nos. 445 and 518 do not accurately reflect the service areas of the Resort and Ridge systems.
Due to these discrepancies, Staff conducted a teleconference with Schweitzer on March 22,
2024, and requested Schweitzer resubmit legal descriptions and maps for service areas of both
systems, which were then provided through supplemental filings. Second Supplement to
Application at 2. Schweitzer also requested to cancel the existing CPCNs used for the Resort
Water CPCN No. 445, and the Ridge System (formerly known as Acme) CPCN No. 518. Staff
determined the amended legal descriptions accurately describe Schweitzer's requested service
territories for both the Resort and Ridge systems, which are provided as Attachment A to Staff
Comments: (1) A-1: Legal Description Of"Resort System," and (2) A-2: Legal Description of
"Ridge System."
Staff also determined that there are no overlapping service territories between the
amended and combined Resort Water and Ridge Water system service territories and any other
water utilities. The combined territory shares common boundaries with the Spires system and
with the Schweitzer Basin Water Company ("SBWC") service territory under CPCN No. 521.
However, Staff verified that they do not overlap, SBWC and Schweitzer independently operate
with their respective infrastructures, and there have not been any territory disputes to date.
Engineering
Overview of the Waiter System
The Schweitzer Water Company consists of two different water systems located in
Bonner County, Idaho: the Resort System and the Ridge System. Both the Resort and Ridge
systems operate independently without interconnection with each other, or to other systems as
stated by Schweitzer's Response to Production Request No. 16. The Resort System has 770 total
ERUs, with 538 ERUs currently active, 89 inactive committed, and 143 available. Further, the
Ridge System has 118 total ERUs with 28 active, 60 inactive committed, and 30 available.
The Resort System and the Ridge System are separated by two other water systems
unrelated to the transaction but possibly relevant to future water system expansion by
STAFF COMMENTS 5 APRIL 11, 2024

Schweitzer. A map of these various systems can be found in Exhibit 6 of the Direct Testimony
of Tom Trulock.
The Resort System is classified as a non-transient, non-community public drinking water
system located on Schweitzer Mountain in Bonner County, Idaho, serving water to the
Schweitzer Resort and portions of the Schweitzer Basin Public Utility Division ("P.U.D."). The
water system consists of three drilled wells, three storage reservoirs, two control buildings, one
treatment facility, a series of three booster pumps and two water tanks supporting the booster
pumps, and distribution systems. As water sources, Well No. 4 has a capacity of 93 gallons per
minute("GPM") equipped with a 15 HP ("Horsepower") pump, Well No. 5 has 98 GPM
capacity through a 5 HP pump, and Well No. 6 can produce water at 71 GPM using a 2 HP
pump. The lower reservoir(Reservoir No. 1 at 5032-feet elevation), middle reservoir(Reservoir
No. 2 at 5062-feet elevation), and the upper reservoir(Reservoir No. 3 at 5194-feet elevation)
have approximate capacities of 42,000 gallons, 65,000 gallons, and 206,000 gallons,
respectively. The water treatment, chlorination, and soda ash injection take place in the Upper
Control Building, whereas the Lower Control Building controls the transfer flow from Reservoir
No. 2 to Reservoir No. 1 and then to distribution lines. The Resort's distribution system operates
in four main pressure zones controlled by six main-line pressure reducing valves ("PRVs") and
consists of 2-inch to 8-inch PVC pipes, 35 fire hydrants, and 45 isolation gate valves. There is a
15-kW backup generator located in the Upper Control Building that provides emergency power
to one well pump, building heating and lighting, and the water treatment system. See Response
to Production Request No. 6—Exhibit No. 4 at 3. The system utilizes booster pumps and water
tanks to supply water to the Sky House Lodge located at an approximate elevation of 6,400 feet.
The Ridge System is classified as a transient, non-community public drinking water
system that serves water to the Schweitzer Village subdivision, located on Schweitzer Mountain
in Bonner County, Idaho. The system comprises one active groundwater well (Well No. 1) with
a production capacity of 30 GPM, a well house/control building (Wellhouse No. 1), and a
200,000-gallons storage reservoir(Reservoir No. 1 at 5045 feet elevation). The Ridge system
also has a second well (Well No. 2), which is currently not in use but may be brought on-line in
the future. The distribution system engages two pressure zones controlled by two main-line PRV
assemblies and it embodies 4-inch to 8-inch PVC plus ductile iron pipes and 12 fire hydrants.
STAFF COMMENTS 6 APRIL 11, 2024

Currently the Ridge system does not have water treatment and the system does not have a backup
generator.
ReliabilitAnalysis of the Water Systems
Staff believes the assets being transferred to Schweitzer, including both Resort and Ridge
systems, are adequate to ensure reliable service to its customers and that current water rights
included within both Resort and Ridge systems provide an adequate supply of potable water to
support Schweitzer's maximum production capacity to meet its current water consumption
needs. Staff s conclusions are based on the performance of the current systems since the assets
being transferred include all the assets and infrastructure currently being used to supply water to
its current customers (See Response to Production Request No. 13 —Confidential Exhibit No. 8).
However, the only reliable performance data available was the absence of customer complaints
or compliance issues included in the Idaho Department of Environmental Quality("IDEQ")
sanitary surveys or water rights issues with the Idaho Department of Water Resources. See
Response to Production Request Nos. 2 and 9.
Lack of Customer Complaints or Regulatory Compliance Issues
Staff reviewed the customer complaints database of both Acme and Resort Water and
learned there have been no complaints regarding water quality/reliability or low water pressure
during the last 5 years. Staff also reviewed IDEQ sanitary surveys for Resort and Ridge systems
(completed in years 2019 and 2017 respectively) and determined there are no reported significant
deficiencies that may have impaired reliability of either system. Because of these reasons, Staff
believes that the transferred assets for both Resort and Ridge systems are sufficient to reliably
meet current customer demands.
Consumption Data and Metering Issues
Ideally, Staff prefers to quantitatively measure system capacity against consumption as a
measure of reliability. Staff was able to determine Schweitzer's annual water production from
2018 through 2022. Schweitzer's highest water production occurring in 2022 was 19,994,453
gallons at approximately 339 GPM (both systems combined). See Response to Production
Request No. 12 —Exhibit No. 7. However, Staff was not able to compare annual consumption
STAFF COMMENTS 7 APRIL 11, 2024

against production due to a lack of customer metering infrastructure and meter calibration issues.
Schweitzer stated it is aware of these issues and is in the process of upgrading more components
and controls to provide better reporting consistency going forward with projected completion by
the summer or fall of 2024. See Supplemental Response to Production Request No. 12.
Facilities Plan
Schweitzer is currently in the process of completing and submitting its facilities plan.
See Response to Production Request No. 9. Without a plan and without the ability to accurately
measure total consumption against system capacity, Staff could not determine whether
Schweitzer can sufficiently meet its future customer's water demand. Because Staff believes it is
critical to understand Schweitzer's ability to continuously provide reliable water service and
meet customer demand in the future, Staff recommends the Commission direct Schweitzer to
submit its completed facilities plan that also addresses metering issues by December 31, 2024.
Water Rights
Staff believes Schweitzer has sufficient water rights to support its maximum production
capacity including both Resort and Ridge systems. See Response to Production Request No. 3 -
Exhibit No. 1.
According to Staff analysis, Schweitzer has total water rights for 2.89 cubic foot per
second("CFS") diversion rate(approximately 1297 GPM), including municipal, commercial,
and storage usage. Additionally, Schweitzer has water rights for a 0.5 CFS diversion rate (224
GPM) specifically reserved for Fire Protection.
Including all systems and booster pumps for both Resort and Ridge systems, Schweitzer
has a total maximum production capacity of 703 GPM. See Response to Production Request No.
6—Exhibit No. 4 at 2. Staff analyzed Schweitzer's annual water production for the past 5 years
from 2018 to 2022, and the highest production capacity in 2021 was approximately 347 GPM
(both systems combined), which is below Schweitzer's currently available water rights. See
Response to Production Request No. 12—Exhibit No. 7.
STAFF COMMENTS 8 APRIL 11, 2024

Tariffs
Schweitzer requested that the Commission approve its proposed tariffs. Schweitzer
edited existing Resort Water Schedule Nos. 1-5 to update the company name. Although
Schweitzer stated it was not raising rates, Schweitzer proposed rearranging the existing
Schedules to add a residential fixed rate service (that would apply to Ridge System customers)
under a newly proposed Schedule No. 6. According to the Application, the proposed Schedule
No. 6 states that"[a]II rates are based on equivalent residential units" from the existing
schedules. Application, Exhibit No. 2, Schedule No. 6.
According to Schweitzer's response to Production Request No. 28, after Resort Water's
acquisition of the Ridge System from Acme, the Ridge System continued operating in
accordance with the "unofficial" tariff in Order No. 33210 for Case No. AWW-W-13-01.
Schweitzer proposed a new Schedule No. 6 that accommodates commercial and
residential customers previously served under the Ridge System with updated language to match
the existing Resort Water tariffs. The Ridge System will have a Basic Fee of$29.25 per month
along with a change in billing structure. The change in billing structure for Ridge System
customers taking service under Schedule No. 6 will no longer be subjected to additional fees for
exceeding 12,000 gallons in monthly water usage.
Previous non-recurring charges for the Ridge System listed under Schedule No. 2 have
been eliminated. The Ridge System will now adopt the Resort Water fixed charges under
Schedule No. 2 of the updated tariffs as shown in the table below. While the non-recurring
charges for the Ridge System are different under the new tariff, they have not increased customer
rates.
Schedule No. 2 Miscellaneous Fees and Charges: Sheet No. 4 and 5 Schweitzer Proposed
Tariffs
Description of Fee or Charge Frequency/Conditions Amount
Return Check Charge Each occurrence $15.00
Reconnection less than 30 days disconnected Normal business hours $20.00
Reconnection less than 30 days disconnected Not normal business hours $60.00
Reconnection greater than 30 days disconnected Normal business hours Four months of
service
Reconnection greater than 30 days disconnected Not normal business hours Four months of
service plus
$60.00
Field Collection Trip Charge Each occurrence $15.00
STAFF COMMENTS 9 APRIL 11, 2024

CUSTOMER COMMUNICATION AND NOTIFICATIONS
Schweitzer provided a proposed notice to customers within Exhibit No. 3 of the
Application. Commission Staff found that the Customer Notice draft the Company submitted
with the Application did not meet all requirements required under Rule 125 of IDAPA 31.01.01 -
Rules of Procedure of the Idaho PUC. Subsequently the Company committed to providing an
updated Customer Notice draft. This updated notice was submitted to Commission Staff on
Monday, March 25, 2024. The updated notice appeared to meet the requirements as set forth in
Rule 125. Staff informed the Company that the notice was sufficient and acceptable to send to
Customers. As of April 11, 2024, the Company has yet to send out the revised Customer Notice.
However, the Company has communicated with Staff concerning the planned release of the
revised Customer Notice.
In Production Request No. 19, Commission Staff requested information describing all
public outreach activities that have occurred to date, indicating the type of outreach activities,
locations, and dates. The Company responded, stating that a press release for the acquisition was
provided at the following link: https://www.schweitzer.com/schweitzer-life/schweitzer-alterra/.
In addition, the Company stated that they provided numerous social media posts and e-mail
releases sent by Alterra Mountain Company U.S. Inc. that primarily focus on the acquisition of
the Schweitzer Mountain Resort. The Company also provided copies of the Mountain Utility
Company notice regarding billing, dated October 16, 2023, and the notification letter that was
sent to all customers and published in the Coeur d'Alene Press.
In Production Request No. 35, the Commission asked the Company to provide examples
of customer bills for Resort Water, Ridge Water and Schweitzer Water Company. The Company
responded by providing sample bills for each system. The sample bills provided for Schweitzer
Water Company reflect a bill prior to the name change from Husky Water Company to
Schweitzer Water Company. The Company responded and sent a sample water bill for
Schweitzer. Upon review of the provided bills, it appears that the bills do not comport with Rule
201 of the Utility Customer Relations Rules. The following Staff comments describe the
specific portions of the bills that require modifications to meet the Rule:
1. No toll-free telephone number is listed on the bill. The Rule requires a toll-free
number to allow customers to contact the Company. IDAPA 31.21.01.201.010);
STAFF COMMENTS 10 APRIL 11, 2024

2. No payment due date was observed on the bill. IDAPA 31.21.01.201.01(d);
3. No date funds will be withdrawn if autopayment is used. IDAPA 31.21.01.201.01(d);
4. Under the section of the bill labeled "Payment Terms," no definition of"CC" or"E"
as shown on the bill were described in the Codes located at the bottom of the bill. To
be consistent, Staff recommends referenced payment terms/codes be defined in the
section shown at the bottom of the bill;
5. There was no description of recurring and non-recurring fees shown on the bill.
IDAPA 31.21.01.201.01(e);
6. The sample bill provided had charges (sewer charges) shown on the bill. The
Commission does not regulate sewer services. No charges for services for which the
Commission does not regulate may be contained in the utility's tariff. IDAPA
31.21.01.207;
7. The bills provided did not show payments or credits applied to the customer's
account since the last billing statement. Bills should show payments and credits
applied since the last billing statement. IDAPA 31.21.01.201.01(h); and
8. The Company's Application showed past due interest being charged in Schedule No.
6 of the Sample Tariff. However, no interest was indicated for Schedules Nos. 1
through 5. It is unclear if interest for past due amounts will be charged for all
Schedules, or only Schedule No. 6. Staff recommends that past due interest charges
be identified for each Schedule or be identified in Schedule No. 2 (Miscellaneous
Fees and Charges).
Staff recommends the Commission require Schweitzer to file a compliance filing within 30 days
demonstrating these modifications have been completed.
As of April 10, 2024, the Commission has not received any public comments regarding
this case.
STAFF RECOMMENDATIONS
Staff recommends the Commission:
1. Approve Schweitzer's Application to issue a new CPCN to authorize service to the
areas previously served by Resort Water and the Ridge System;
2. Cancel CPCN Nos. 518 and 445;
STAFF COMMENTS 11 APRIL 11, 2024

3. Approve Schweitzer's tariffs as filed;
4. Direct Schweitzer to submit its completed facilities plan that includes addressing
metering issues by December 31, 2024; and
5. Require the Company to file within 30 days a compliance filing demonstrating
Customer bills comport with IDAPA 31.21.01.
Respectfully submitted this 1Ph day of April 2024.
Michael Duva
Deputy Attorney General
Technical Staff Jon Kruck
Joseph Terry
Kevin Keyt
Leena Gilman
Shubhra Paul
Michael Eldred
I:\Utility\UMISC\COMMENTS\SWC-W-23-01 Comments.docx
STAFF COMMENTS 12 APRIL 11, 2024

A-1: LEGAL DESCRIPTION OF "RESORT SYSTEM"
A parcel of land in Section 20, Township 58 North, Range 2 West, Boise Meridian, Bonner
County Idaho, further described as follows:
Beginning at the Center Quarter Corner of said Section 20, monumented with a 4 inch
diameter concrete monument with a 2-inch diameter brass cap marked"PLS 1947", from which
the East Quarter Corner bears South 89°51'25" East, 2693.97 feet;
Thence South 00'13'44"West, 1068.16 feet along the north-south center section line to the
southeasterly corner of Ski and Road Easement as shown on Crystal Springs Subdivision Block
E, recorded as Instrument#437196, Records of Bonner County, Idaho;
Thence North 89°58'51" West, 527.03 feet, along said Ski and Road Easement southerly line, to
the southwesterly corner of said Easement;
Thence North 22°14'10" East, 33.20 feet, to the southeasterly corner of Lot 10, Crystal Springs
Subdivision Block D,recorded as Instrument#437196;
Thence, along the southerly line of said Crystal Springs Subdivision Block D the following five
(5) Courses:
1) North 66°17'30" West, 343.67 feet;
2) Thence South 23°39'37"West, 200.23 feet;
3) Thence North 66°19'45"West, 192.32 feet;
4) Thence North 59°15'24"West, 185.93 feet;
5) Thence North 46°26'07"West, 256.60 feet to the southwesterly corner of Lot 6 of said
Crystal Springs Subdivision Block D;
Thence, departing said Crystal Springs Subdivision Block D southerly line, North 3999'51"
West, 961.28 feet;
Attachment A-1
Case No. SWC-W-23-01
Staff Comments
April 11, 2024

Thence North 45°28'38" East, 1912.66 feet, to the northwesterly corner of Lot 6, Block 6,
Trappers Creek, recorded as Instrument#735696;
Thence North 46°36'42" East, 930.90 feet to the northwesterly corner of Parcel 35 as described
in Special Warranty Deed Instrument#102486.
Thence South 89°23'40" East, 330.04 feet;
Thence South 00°15'36" East, 211.23 feet;
Thence South 41°18'17" East, 616.50 feet;
Thence South 89°23'40" East, 605.25 feet;
Thence South 00°33'53" East, 253.90 feet;
Thence South 67°53'34" East, 1456.70 feet to the easterly line of said Section 20;
Thence South 00°52'27" East, 507.70 feet to the east quarter corner of said Section 20;
Thence North 89°51'25"West, 2693.97 feet, along the east-west center section line of said
Section 20, to the Point of Beginning.
And
The West Half of the Southwest Quarter of the Northwest Quarter of Section 17, Township 58
North, Range 2 West, Boise Meridian, Bonner County, Idaho.
Containing 177 acres, more or less.
Attachment A-1
Case No. SWC-W-23-01
Staff Comments
April 11, 2024

A-2: LEGAL DESCRIPTION OF "RIDGE SYSTEM"
Boise Meridian, Idaho
T. 58 N., R. 2 W.
SEC. 29, NE1/4,N1/2NW1/4, SE1/4NW1/4.
Containing 280 acres,more or less.
Attachment A-2
Case No. SWC-W-23-01
Staff Comments
April 11, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE I ITH DAY OF APRIL 2024, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO
SCHWEITZER WATER COMPANY IN CASE NO. SWC-W-23-01, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
Ronald L. Williams Tom Trulock
Brandon Helgeson c/o Schweitzer Water Company
Hawley Troxell Ennis &Hawley LLP 165 Village Lane, Suite A
877 W. Main Street, Suite 200 Sandpoint, ID 83864
P.O. Box 1617 ttrulock(a),,schweitzer.com
Boise, ID 83701-1617
rwilliams(@,,hawleZroxell.com Bradley Mullins
bhelgeson(ci,)hawleytroxell.com MW Analytics
Teitotie 2, Suite 208
Oulunsalo Finland, FI-90460
brmul l i ns(a-,mwanalyti cs.com
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KERI HAW R
CERTIFICATE OF SERVICE