20250313Staff Comments.pdf

RECEIVED
MARCH 13,2025
CHRIS BURDIN IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
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-25-01
RESERVE FUND DISTRIBUTION FOR 2024 )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Chris Burdin, Deputy Attorney General,
submits the following comments.
BACKGROUND
On January 20, 2025, Teton Water& Sewer Company("Company") filed an application
("Application") with the Commission requesting approval of Emergency Reserve Fund
Distribution for necessary projects in 2024. Application at 1.
The Company represented that the total cost of projects for the calendar year 2024 was
$44,602.78. Id. The Company stated that the total amount exceeded the available funds in the
reserve account for 2024, and only $7,217.30 was used from reserve funds in 2024 with the
balance of the invoices being paid from operating funds. Id.
STAFF COMMENTS 1 MARCH 13, 2025

STAFF ANALYSIS
In Order No. 30718, the Commission authorized the establishment of the Emergency
Reserve 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.'
In the Application, the Company included expenditures for three projects completed in
2024:
• 16"Tank Main Line Water Leak Repair, $16,692.30;
• 46 Rammell Water Leak Repair, $11,462.60; and
• 71 Beesley Water Leak Repair, $16,447.88.
The Company provided invoices and photo documentation for all projects. Based upon
this evidence, Staff believes that all three projects were unplanned emergency repairs, which
fulfills the second requirement. Documentation provided with the Application fulfilled the final
requirement. The total cost of the three projects, $44,602.78, exceeds the available funds in the
reserve account by $37,385.48. Staff reviewed the Company's Application and recommends the
Commission find the $7,217.30 cost for the materials and well pressure transducer at the Water
Tank, to be prudent and be recovered from the Emergency Reserve Fund. Staff also
recommends the remaining repairs of$37,385.48 be booked to account 101.333 ("Plant-in-
Service", sub-account"Services"), to be recovered in the next general rate case.
Staff recognizes that the Company's Emergency Reserve Fund surcharge has been
insufficient to cover these repairs over the last four years. Since 2021, the Company has incurred
around $111,405 in emergency repairs not covered by the Emergency Reserve Fund. Staff
recommends the Company consult with Staff about alternative ways to fund future repairs.
' The 10%annual revenue requirement was eliminated in order No. 34000.
STAFF COMMENTS 2 MARCH 13, 2025

STAFF RECOMMENDATION
Staff recommend the Commission:
• Approve the Company's use of the reserve fund for 2024 in the amount of$7,217.30;
and
• Require the remaining amount of 2024 repairs— $37,385.48, to be recorded in
Account 101.333 for recovery in the Company's next general rate case.
Respectfully submitted this 13th day of March 2025.
(�A t,�A,
Chris Burdin
Deputy Attorney General
I
Technical Staff: Leena Gilman
L\Utility\UMISC\COMMENTS\TTS-W-25-01 Comments.docx
STAFF COMMENTS 3 MARCH 13, 2025

CERTIFICATE OF SERVICE
A
I HEREBY CERTIFY THAT I HAVE THIS 0 DAY OF MARCH 2O25,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. TTS-W-25-01, BY E- MAILING A COPY THEREOF, TO THE
FOLLOWING:
JON PINARDI
TETON WATER& SEWER CO
PO BOX 786
DRIGGS ID 83422
E-MAIL: jpinardiasilverstar.com
Tetonws(acr�silverstar.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE