20250611APPLICATION.pdf

RECEIVED
June 11, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
GARRETT RICHARDSON,PLLC
Bradley S.Richardson ISB No.7008
Cameron G.Francis ISB No. 12523 C 1 2'E'25��2
738 S. Bridgeway Place Suite 100
Eagle,ID 836I6
Telephone: [phone]
Facsimile:208-93 8-2277
Email: [e-mail]
Email: [e-mail]
Attorneys for Riverside Electric Company,Limited
GOODMAN LAW OFFICE
Alan Goodman ISB No.2778
717 Th St.,P.O. Box D
Rupert,ID 83350
Telephone:[phone]
Facsimile:208-436-483 7
Email: [e-mail]
Attorneys for East End Mutual Electric,Limited
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of Riverside )
Electric Company,Limited and East End )
Mutual Electric,Limited for an Order ) Case No.
Approving a Service Territory Agreement )
between the Applicants. 1
Pursuant to Rule 51 of the Idaho Public Utilities Commission Rules of Procedure
("IPUCRP") and Idaho Code § 61-333, Riverside Electric Company, Limited ("Riverside") and
East End Mutual Electric,Limited("East End") respectfully apply for Commission approval of a
Service Territory Agreement between Riverside and East End on the grounds and for the following
reasons:
I. On December 8, 2020, the Idaho Legislature, meeting in special session amended
the Idaho Electric Supplier Stabilization Act, §§61-332 through 61-334B of the Idaho Code.Idaho
Code § 61-333 provides that any electric supplier may contract in writing with another electric
supplier for the purpose of allocating territories,consumers,and future consumers between electric
APPLICATION—RIVERSIDEXAST END- 1

suppliers and designating which territories and consumers are to be served by which contracting
electric supplier.The statute further provides that the Commission shall, after notice and hearing,
review and approve or reject such contracts between electric suppliers. This joint Application is
filed with the Commission for approval. Approval of the Commission of Service Territory
Agreements is necessary to comply with the purposes of the Electric Supplier Stabilization Act.
2. The Petitioners have for some time had a Territory Agreement ("Agreement")
between them. Such Agreement predated the amendment to Idaho Code § 61-333, and therefore
Riverside and East End seek approval from the Commission of the existing Agreement.A copy of
that Agreement is attached as Exhibit A.
3. The Agreement was negotiated between the parties in order to: settle a service
territory between the parties,provide for stability of service with consumers,eliminate duplicating
services, and provide safety in the respective territories. The petitioners believe the agreement is
in the best interests of both entities and the customers of both entities.
4. For the foregoing reasons and to fulfill the requirements of Idaho Code § 61-333,
Riverside and East End request the Commission, after notice and hearing, approve of the
Agreement pursuant to law. �—
Dated this eday of y'AA 2025.
GARRETT RICHARDSON,PLLC
By:
Bradley S. Richardson, Of the Firm
Attorneys for Riverside Electric Company,Limited
GOODMAN LAW OFFICE
By: ,F �";'�f zmzw
Alan Goodman, Of the Firm
Attorney for East End Mutual Electric,Limited
APPLICATION—RIVERSIDE/EAST END-2

SERVICE AREA STABILIZATION AGREEMENT
This Service Area Stabilization Agreement ("Agreement") is made effective as of the La
day of A 2025,by and between RIVERSIDE ELECTRIC COMPANY,LTD of P.O.Box
12, Rupert, Idaho 83350 ("Riverside"), and EAST END MUTUAL ELECTRIC, LTD of 528 E.
Street, Rupert, Idaho 83350 ("East End"). Riverside and East End shall collectively be known as
the"Parties"or individually as a"Party."
I.
RECITALS:
1.1 Riverside and East End are electric non-profit corporations organized in the State
of Idaho and distributing electric energy to their respective members.
1.2 The service areas of Riverside and East End, in part, are adjacent and contiguous
to each other.
1.3 The Parties have, in recent years, had an oral understanding relative to the
respective service areas. The Parties, however, deem it appropriate to reduce their respective
understandings to this written Agreement and to have the same approved by the Idaho Public
Utilities Commission pursuant to Idaho Code § 61-333.
In consideration of the recitals, the covenants and conditions herein contained and by
statutory authority the Parties agree as follows:
2. TERRITORY DEFINED: Exhibit "1," attached to this Agreement and made a
part hereof by reference, defines the territories of the respective Parties as they are contiguous to
each other. All the area south of the red line identified on Exhibit "1" shall be the Riverside
SERVICE AREA AGREEMENT—RIVERSIDE/EAST END- 1

territory and all territory north of the red line shall be the East End territory. Riverside shall serve
all new customers in its defined area and East End shall serve all new customers in its defined area.
3. EXISTING CUSTOMERS: To the extent that either Party is currently providing
service to customers within the service area assigned to the other Party by this Agreement, said
Parties shall continue to serve said customer. Neither Riverside nor East End shall be required to
withdraw from the service area allocated to the other.Notwithstanding the foregoing, the right to
continue to serve existing customers within the service area of the other Party shall not be
construed to authorize extension of service to new customers within the service area allocated to
East End or Riverside by this Agreement.
4. CAPTIONS: The captions of the paragraphs of this Agreement are for
identification purposes only and the captions shall not be construed to define or limit the express
provisions of the respective paragraphs.
5. ATTORNEYS'FEES:Reasonable attorneys'fees and costs may be granted to the
prevailing Party in any action to enforce or interpret this Agreement pursuant to Idaho Code§ 61-
617A. Otherwise, the Parties agree that each Parry will be responsible for its own attorneys' fees
and costs.
6. DELAYED RESPONSE: Because this Agreement has previously been submitted
to the Idaho Public Utilities Commission and subsequently dismissed due to failure to obtain
signatures from both Parties in a timely manner, upon approval of this Agreement by the Idaho
Public Utilities Commission,both Parties shall sign the Agreement within the allotted time.Should
either Party fail to sign the Agreement within the allotted time, the non-breaching Parry shall be
entitled to a one thousand dollar($1,000)fee per incident from the breaching Party.
SERVICE AREA AGREEMENT—RIVERSIDE/EAST END-2

7. OTHER CUSTOMERS: Nothing contained herein shall prohibit the Parties from
entering into a written agreement to permit the service of a new customer by the Party whose
distribution system is located in the service area of the other, if the new customer can be served
more efficiently and safely from the existing service lines of the other Party or by the extension of
existing service lines. Such agreement shall be in writing,authorized by the respective authorized
officers of each Party, and when executed, shall be appended to this Agreement. The decision to
enter into such agreement is in the absolute discretion of each Party and neither Party shall have
the right to action against the other for the exercise of such discretion.
8. TERM: This Agreement shall remain in full force and effect so long as each of the
Parties shall continue to operate as electric suppliers under their present form of ownership.In the
event either Party should terminate operations as an electric supplier, the boundary lines
established by the respective service area shall remain in effect as to the successors in interest. In
the event either or both Parties merge,consolidate,sell,or otherwise become a different entity,this
Agreement shall nevertheless remain in full force and effect as to the successor in interest of the
respective Parties.
9. EFFECTIVE DATE: This Agreement shall be effective upon its execution by the
respective Parties and approval by the Idaho Public Utilities Commission. When so executed and
approved, a copy shall be recorded in the office of the County Recorder, County of Minidoka,
State of Idaho.
10. ENTIRE AGREEMENT & MODIFICATION: This Agreement constitutes the
entire understanding of the respective Parties. All prior negotiations and understandings are
deemed merged herein. This Agreement may only be modified in writing executed by the
authorized officers of the Parties and approved by the Idaho Public Utilities Commission.
SERVICE AREA AGREEMENT—RIVERSIDE/EAST END -3

7-2--
IN WITNESS WHEREOF the Parties have executed this Agreement this day of
2025.
RIVERSIDE.ELECTRIC COMPANY LIMITED
Chad-Surrage -
Its: mr'.X-.o ''
STATE OF IDAHO )
_; 'ss.
County of le'-0 6 )
1 ;/`
On this ; J day of 2025,before me,the undersigned,a Notary Public in and for
the State of Idaho,personally appeared, Chad Surrage,known to me to be the person whose name
is subscribed to the within instrument, and acknowledged to me that he executed the same.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official seal the
day and year fiffj M9ye written.
Xl
�.Q'.••'"• ' •.F,p; Notary Public for Idaho
NOTA1,� Residing at:
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My Commission Expires:
N'•.r UBL�a.
���'9•.?►m"O'Szo r�0` EAST EN TU ECTRIC,LIMITED
•,rF'OF'%1D
B :
Randy S 20don, Manager
its: M ov�
STATE OF IDAHO ) —�
:ss.
County of )
On this I;;: day of-January 2025,before me,the undersigned,a Notary Public in and for
the State of Idaho, personally appeared, Randy Sneddon, known to me to be the person whose
name is subscribed to the within instrument,and acknowledged to me that he executed the same.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official seal the
day and year first above written.
Notary Public for Idaho
• NOTARY _ Residing at: 1
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My Commissi
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SERVICE ARr> X'XC*EMENT—RIVERSIDE/EAST END-4

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Defining the proposed service boundary area between East End Mutual Electric Co. and Riverside
Electric Company.
Beginning at RP09S24E343000 FORGEON LAMAR N2NW4 34-9-24, 105 E 100 S RUPERT,
ID 83350. East to S 200 E. South at RP09S24E353620 KOWITZ DAVID, S2NW4 LESS TAX 5
& 8 35-9-24, 132 S 200 E RUPERT, ID 83350. East at RP09S24E355420 ROLLHEISER
GABRIEL L, ROLLHEISER COURTNEY, N25W4 &TAX 8 IN S2NW4 LESS TAX 2 35-9-24, 180
S 200 E. South at RP09S24E355420 ROLLHEISER GABRIEL L, ROLLHEISER COURTNEY
N2SW4&TAX 8 IN 52NW4 LESS TAX 2 35-9-24.to E 200 S.
Legal descriptions, Property Identification Number (PIN), and current owner(s) are from
IIUps:/j:il .Lis
EXHIBIT