20240320Supplement to Application.pdf

RECEIVED
2024 MARCH 20, 6:15PM
IDAHO PUBLIC UTILITIES
COMMISSION
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS &HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5253
Email: [e-mail]
[e-mail]
Attorneys For Schweitzer Water Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF
SCHWEITZER WATER COMPANY FOR Case No. SWC-W-23-01
APPROVAL OF ACQUISITION OF THE
ASSETS OF RESORT WATER CO. INC. SCHWEITZER WATER COMPANY'S
AND FOR THE ISSUANCE OF A SUPPLEMENT TO APPLICATION
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY
Schweitzer Water Company (the "Company")hereby respectfully submits to the Idaho
Public Utilities Commission (the "Commission") this supplement to its Application filed in the
above-referenced case. This supplement is intended to request additional relief from the
Commission under the application and provide additional information or clarification on matters
contained in the Company's original Application.
INTRODUCTION
The Company filed the Application on December 27, 2023, wherein it specifically
requested that the Commission grant a new Certificate of Public Convenience and Necessity
RESPONSE TO SECOND PRODUCTION REQUEST— 1
6173 0.0002.1695 8641.1

RECEIVED
2023 February 15, 5:04PM
IDAHO PUBLIC
UTILITIES COMMISSION
("CPCN") to the Company that authorizes water service to the areas served by Resort Water
Company, Inc. ("Resort Water"). See Application,p. 8. As described in the Application and
subsequent Company filings in response to production requests from Commission staff, the
Company is seeking approval of the acquisition of the assets of Resort Water, who operated two
water supply and distribution systems: (1) the Resort Water system ("Resort System") owned
and operated by Resort Water pursuant to CPCN No. 445 and(2)the "Ridge System"previously
owned and operated by Acme Water Works, Inc. under CPCN No. 518, which was subsequently
transferred to Resort Water and operated by Resort Water since that date without amendment to
or cancellation of CPCN No. 518. See Application, pp.4-5. The Company did not request
cancellation of CPCN Nos. 445 or 518 in its Application.
REQUEST TO CANCEL CPCN NOS. 445 AND 518
In order to provide more clarity regarding the water utility responsible for providing
water service to the Resort System and Ridge System and to reflect the unity of service to these
two systems under one CPCN, the Company respectfully requests that, in addition to the relief
requested in the Application, the Commission cancel CPCN Nos. 445 and 518 upon issuance of a
new CPCN to the Company.
ADDITIONAL INFORMATION
In addition, since the filing of the Application, Commission staff has notified the
Company that the legal description of the service areas for the Resort System and Ridge Systems
described in the Company's Application do not appear to mirror the legal descriptions of the
service areas under CPCN Nos. 445 or 518. The Company is currently working on clarifying the
RESPONSE TO SECOND PRODUCTION REQUEST—2
6173 0.0002.1695 8641.1

RECEIVED
2023 February 15, 5:04PM
IDAHO PUBLIC
UTILITIES COMMISSION
legal description of the service areas and will provide them to the Commission as soon as
possible.
Finally, Commission staff has requested that the Company revise the Customer Notice
sent by the Company to the customers of Resort Water to fully comply with the notice
requirements of IDAPA 31.01.01.125. The Company will provide a draft revised notice to
Commission staff to review for approval. After approval of the form of the new customer notice,
the Company will send the revised notice to all customers.
Dated: March 20, 2024.
HAWLEY TROXELL ENNIS &HAWLEY LLP
By V41t,
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
Attorneys For Schweitzer Water Company
RESPONSE TO SECOND PRODUCTION REQUEST—3
6173 0.0002.1695 8641.1

RECEIVED
2023 February 15, 5:04PM
IDAHO PUBLIC
UTILITIES COMMISSION
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing
SCHWEITZER WATER COMPANY'S SUPPLEMENT TO APPLICATION by the method
indicated below, and addressed to each of the following:
Commission Staff ❑ U.S. Mail, Postage Prepaid
Commission Secretary ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A Q E-mail
Boise, ID 83714 ❑ Facsimile
secretaa9]2uc.idaho.gov ❑ iCourt
Tom Trulock, Vice President ❑ U.S. Mail,Postage Prepaid
c/o Schweitzer Water Company ❑ Hand Delivered
165 Village Lane, Suite A ❑ Overnight Mail
Sandpoint, ID 83864 Q E-mail:
[e-mail] ❑ Facsimile
❑ iCourt
Brad Mullins ❑ U.S. Mail,Postage Prepaid
Principal Consultant ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 0 E-mail:
Oulunsalo Finland, FI-90460 ❑ Facsimile
brmullins(amwanaltyics.com ❑ iCourt
Dated: March 20, 2024.
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
RESPONSE TO SECOND PRODUCTION REQUEST—4
6173 0.0002.1695 8641.1