20251124Request for Reconsideration.pdf

RECEIVED
November 24, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
VALIANT IDAHO, LLC
TIC UTILITIES, LLC
151 CLUBHOUSE WAY
SANDPOINT, ID 83864
[phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. VID-W-25-02
IN THE MATTER OF THE APPLICATION OF )
TIC UTILITIES,LLC FOR AUTHORITY TO ) ORDER NO. 36818
INCREASE ITS RATES AND CHARGES FOR )
WATER SERVICE IN THE STATE OF IDAHO ) REQUEST FOR
RECONSIDERATION
1
COMES NOW TIC Utilities, LLC, an affiliate of Valiant Idaho, LLC, ("Company") and
holder of Certificate of Public Convenience and Necessity No. 554 from the Idaho Public
Utilities Commission("IPUC"), hereby is responding to the Final Order No. 36818 dated
November 3, 2025 ("Final Order").
REQUEST FOR RECONSIDERATION
Company hereby acknowledges and accepts most of the conclusions of IPUC in its Final
Order. However, Company hereby requests that IPUC reconsider the following Commission
Discussion and Findings in the Final Order for the reasons stated below.
REVENUE REQUIREMENT: Company acknowledges and agrees that the
calendar year 2024 is an appropriate test year for the establishment of Company's revenue
requirement. However, Company disputes that certain pro forma adjustments to Company's
actual 2024 revenue and expenses should be made, as such adjustments will unfairly, unjustly
and unreasonably limit Company's allowable revenue to an amount that will not cover

Company's actual operating expenses. Basing these conclusions on historical data from years
preceding 2024, or a 3-year average, significantly understates Company's actual expenses due to
the fact that Company added certain equipment, i.e. a chlorination system and later an ATEC iron
filtration system at the source wells, as well as increasing the number of active connections from
new home construction. All of these factors, as well as general market inflation during this
period, contribute significantly to the actual expenses for Electricity, Chemicals and Water
Testing, among other operating expenses.
REVENUE NORMALIZATION: Company disputes that it failed to provide evidence
of its actual revenue collected as Company provided financial statements for each of the full
years of operation—2022, 2023 and 2024—prepared by an independent Certified Public
Accountant. As those financial statements plainly show, Company has not collected $165,240 in
revenue in any of the 3 full years of operation, nor is Company tracking to do so based on an
annualized total for 2025. Company hereby reasserts that this discrepancy between actual
revenue collected and potential revenue is primarily due to credit loss, as Company has no
practical legal means to force compliance without a lien right or the option to deny service.
SALARIES: Company hereby reasserts its claims related to Expense Adjustments -
Salary Adjustment (Adjustment No. 6) in its Responses to Comments of Commission Staff&
Public Comments dated September 3, 2025 ("Company Responses to Comments"). Company
disputes that it could hire a competent water system manager in North Idaho, at the proposed
annual salary of$30,000, with the specific skill set to successfully manage all of the necessary
components of such a system including, but not limited to, regulatory compliance, financing,
billing and accounting, tax reporting, hiring and managing qualified third party professionals,
and customer service. Further, given that IPUC is charged with auditing water system operators
in this specific jurisdiction, it is arbitrary to base such an expense on generic national data from
the US Bureau of Labor Statistics rather than the current actual wage data for managers of water
systems regulated by IPUC. Thus, if salary and wage data from other IPUC-regulated Idaho
water systems supports a higher salary than $30,000 per year, Company requests that IPUC base
its final conclusion on such actual and relevant data.

INCREASING VARIABLE OPERATING COSTS: Company hereby reasserts that its
operating expenses have increased each year due to the addition of a chlorination system in
March 2022, the addition of an ATEC iron filtration system at the source wells in May 2023, and
the increase in active connections due to new home construction over the past 4 years as
evidenced by significant increases in well production over that same period. According to IPUC
in its Final Order, IPUC asserted that Company did not provide evidence substantiating and
explaining the purported link between customer growth or the installation of the chlorination
system and ATEC system and the significant jump in operating costs. Below is a Summary Table
showing the actual annual operating costs incurred by Company for Electricity, Chemicals and
Water Testing from 2021 (partial year) to 2024, as well as the trailing 12 months through October
2025. Also, Exhibit A attached is a spreadsheet that shows the actual monthly expenses and
actual well production to show the increasing demand due in large part to the addition of new
homes, i.e. flowing customers, from October 2021 through October 2025. The back-up monthly
invoices from Avista Power for Electricity, and E3 Consulting for Chemicals (highlighted in
yellow) and Water Testing (highlighted in pink), are also provided herewith.
VARIABLE OPERATING COSTS &WATER PRODUCTION
SUMMARY TABLE
$1,268 $7,273 $10,675 $15,935 $17,968
$335 $11,102 $5,984 $11,453 $7,560
$7,090 $30,400 $12,466 $8,910 $16,656
WATER 2,146,315 15,036,977 21,287,833 23,251,215 30,545,571
RO •
(1) Partial year-Commencement of operations from October 2021 through December 2021.
(2) Trailing 12 months from November 2024 through October 2025.

The Summary Table above, as well as the detailed spreadsheet attached as Exhibit A,
clearly show the following:
(1) Actual annual costs for Electricity have increased in each of Company's years of
operation, exceeding the IPUC allowed annual Electricity expense reimbursement of$9,794 in
each of 2023, 2024, and the trailing 12 months through October 2025. Such actual increases are
consistent with Company's addition of equipment such as the chlorination system and ATEC iron
filtration system, increased water production due to the addition of flowing customers, and
increases in the CPI during this period of operations. Regardless of the contributing factors,
there is no reasonable basis to impose a reimbursement amount that is significantly less than the
actual expenses in 2023, 2024 and/or the trailing 12 months of operations through October 2025.
(2) Actual annual costs for Chemicals have exceeded the IPUC allowed annual
chemical expense reimbursement of$3,944 in every full year of operations 2022, 2023, 2024
and the trailing 12 months through October 2025. As a result, there is no reasonable basis to
impose a reimbursement amount that is less than the actual expenses incurred in every full year
of operations.
(3) Actual annual Water Testing costs have also exceeded the IPUC allowed annual
expense reimbursement of$1,338 in each full year of operations—2022, 2023, 2024, and the
trailing 12 months through October 2025. Even more perplexing is that the allowed annual
reimbursement is also less that the actual water testing costs for the partial year of operations
from October 2021 to December 2021. The amount determined by IPUC Staff for Water Testing
is so far below Company's actual costs that there is simply no reasonable basis to impose a
reimbursement amount that equals a small fraction of the actual expenses in 2024, not to mention
a small fraction of every other year of operation.
(4) Annual water production has increased significantly each year, which clearly
supports Company's assertion that there has been a significant number of new connections
during its period of operations. This is also consistent with Company's assertions that variable
operating costs are likely to continue to increase each year. There is no reasonable basis to

assume that water production will decrease, or that the variable operating costs to produce such
increasing volumes of water will be lower in the future.
CHEMICAL ADJUSTMENT: Company hereby reasserts its claims related to Expense
Adjustments - Chemical Adjustment(Adjustment No. 10) in the Company Responses to
Comments. Specifically, Company's operating expenses have increased each year due to the
combination of the addition of a chlorination system, the addition of an ATEC iron filtration
system, and the increase in active connections due to new home construction over the past 4
years as evidenced by significant annual increases in well production. This is clearly supported
by the E3 Consulting invoices provided herewith showing the increases in actual expenses for
Chemicals. All of these factors—the chlorination system, the ATEC iron filtration system and
increasing active connections have and will continue to contribute to increasing, not
decreasing, variable operating expenses such as Chemicals. Note that IPUC Staff has provided
no evidence to the contrary. Thus, Company asserts that the actual expenses for 2024, or a
trailing 12-month total through October 2025, would more accurately reflect Company's actual
Chemical expenses going forward. There is simply no reasonable justification to assume that
Chemical expenses will be less than the actual expenses for 2024, given the increasing variable
costs of operating the additional equipment and increasing water production volumes. To
support this assertion, Company has included, on the attached Exhibit A, a break-down of the
actual Chemical expenses by month from October 2023 through October 2025. Using any data
from 2021, in which Company operated the system for only 3 months, may be worth
consideration but obviously should not be considered in an annual average. As a result,
Company requests that IPUC base its final conclusion on the actual Chemical costs for 2024
equal to $11,453, or the trailing 12 months through October 2025 equal to $7,560, and not a 3-
year average that grossly understates the current Chemical demands of the system.
WATER TESTING ANNUALIZED: Company hereby reasserts its claims related to
Expense Adjustments -Annualizing Water Testing (Adjustment No. 11) in the Company
Responses to Comments of Commission Staff&Public Comments dated September 3, 2025.
As with Chemical expenses, Company's Water Testing expenses have increased each year due to

the addition of the chlorination system, addition of the ATEC iron filtration system, and the
increase in active connections due to new home construction. This is clearly supported by actual
invoices showing the increases in expenses for Water Testing. Again, all of these—chlorination
system, iron filtration system and increasing active connections—are contributing to increasing,
not decreasing, variable operating expenses. Thus, Company asserts that the actual expenses for
2024, or the trailing 12-month total through October 2025, would more accurately reflect the
actual Water Testing expenses going forward. There is simply no reasonable justification to
assume that Water Testing expenses will be lower than those in the current year or most recent 12
months. To support this assertion, Company has included on Exhibit A a break-down of the
actual monthly Water Testing expenses from October 2023 through October 2025. As a result,
Company requests that IPUC base its final conclusion on such actual invoices for Water Testing
costs for 2024 equal to $8,910, or the trailing 12 months through October 2025 equal to $16,656,
and not a 3-year average that grossly understates the actual current Water Testing requirements of
the system.
ELECTRICITY ADJUSTMENT: Company hereby reasserts its claims related to
Expense Adjustments - Electricity Adjustment(Adjustment No. 14) in the Company Responses
to Comments. It is indisputable that Company's Electricity expenses have increased each year,
as clearly supported by the actual invoices from Avista Power provided by Company for the full
period of its operations. To further illustrate how arbitrary it is to conclude that Company's
Electricity expense will be only $9,794, it clearly shows on the above Summary Table and
Exhibit A that Company's actual Electricity expenses have never been equal to or less than
$9,794 in each of 2022, 2023, 2024, or the trailing 12 months through October 2025. Thus,
Company asserts that the actual expenses for 2024 equal to $15,935, or the trailing 12-month
total through October 2025 equal to $17,968, would more accurately reflect the actual Electricity
expenses going forward. Again, there is simply no reasonable justification to assume that
Electricity expenses will be lower than those in 2024 or the most recent 12 months, let alone be
less than those in 2023. To support this assertion, Company has included on Exhibit A a break-
down of the actual Electricity expenses by month from October 2023 through October 2025. As

a result, Company requests that IPUC base its final conclusion on the actual invoices from Avista
Power for 2024, or the actual invoices for the trailing 12 months through October 2025, and not a
3-year average or mere assumptions that ignore actual costs, that grossly understates the actual
current Electricity requirements of the system.
ADDITIONAL SUPPORT: To further support Company's assertions, Company has
provided, as Exhibit B, a letter of opinion from Steve Cordes, P.E. of Welch Comer Engineers,
who is the engineer of record for Company and who designed the wells and well house,
chlorination system,ATEC iron filtration system and other component parts of the system. This
letter of opinion from an Idaho-licensed engineer clearly supports the assertion that the addition
of the chlorination system and ATEC iron filtration system, along with increasing well
production, will necessarily increase the Electricity, Chemicals and Water Testing expenses
required to properly operate the water system going forward.
SUMMARY: Company acknowledges with many of the conclusions and adjustments
outlined in the Final Order. However, if IPUC elects to not allow the proposed adjustments,
Company, which has suffered operating losses in each of the preceding years of operation and
during the IPUC review and rate case,will again suffer such operating losses for 2026. Such a
result would clearly be unfair,unjust and unreasonable. Company asserts that for the variable
operating costs described herein, the actual costs from 2024, or the trailing 12 months through
October 2025, and not a 3-year average or adjusted amounts that ignore the actual costs, will
provide the most accurate basis for estimating such variable costs going forward for the current
number of active connections. If the expense determinations in the Final Order are not adjusted,
the actual operating costs will be understated by a minimum of$21,222 based on the 2024 actual
expenses, or a minimum of$27,108 based on the trailing 12 months through October 2025,
which all but eliminates any assumed return on investment to Company under the Final Order.
This will require Company to undergo a second rate case beginning in January 2027 to more
accurately account for these actual variable costs and others. This would be unnecessary,
inefficient and cost prohibitive to Company and its customers, when actual data is available now
that could potentially eliminate the need for a subsequent rate case in 2027.

Please direct any questions or correspondence related to these Request for
Reconsideration at the following address and/or phone number.
William Haberman
Manager
TIC Utilities, LLC
151 Clubhouse Way
Sandpoint, ID 83864
[phone]
wh&theidahoclub.com
DATED at Sandpoint, ID, this 24th day of November, 2025.
Respectfully submitted,
TIC UTILITIES, LLC
William Haberman
Manager

EXHIBIT A
EXPENSE &WATER PRODUCTION SUMMARY
ELECTRICITY& GAS
CHEMICALS
TESTING
WELL PRODUCTION

EXHIBIT A VALIANT IDAHO,LLC-IPUC RATE CASE-REQUEST FOR RECONSIDERATION
EXPENSE SUMMARY 2021 2022
CHLORINATION
ADDED
10/21 11/21 12121 1/22 2/22 3/22 4/22 5/22 6/22 7/22 8/22 9/22 10/22 11/22 12122
ELECTRICITY&GAS
Wells&ATEC System $0.00 $435.20 $329.42 $436.45 $239.25 $250.99 $280.57 $355.23 $230.17 $432.88 $833.67 $835.39 $682.23 $367.83 $170.02
Booster 1 $113.87 $72.21 $115.93 $132.89 $115.19 $104.34 $94.96 $65.99 $63.99 $114.03 $147.85 $116.43 $122.66 $102.14 $122.56
Booster 2 $105.64 $37.23 $58.62 $41.02 $36.92 $40.81 $50.08 $49.66 $64.73 $105.29 $145.64 $115.81 $121.65 $39.47 $44.53
Booster Upper 0.00 $0.00 $0.00 $0.00 $0.00 $0.00 0.00 $0.00 0.00 $0.00 0.00 $0.00 0.00 0.00 0.00
MONTHLYTOTALS $219.51 $544.64 $503.97 $610.36 $391.36 $396.14 $425.61 $470.88 $358.89 $652.20 $1,127.16 $1,067.63 $926.54 $509.44 $337.11
ANNUALTOTALS PARTIAL YEAR $1,268.12 $7,273.32
CHEMICALS
MONTHLY TOTALS $335.00 $0.00 $0.00 $303.29 $367.67 $465.00 $364.00 $640.88 $1,455.51 $2,400.00 $2,884.16 $1,320.00 $580.42 $321.39 $0.00
ANNUALTOTALS PARTIAL YEAR $335.00 $11,102.32
TESTING
MONTHLY TOTALS $1,010.00 $1,400.00 $4,680.00 $3,955.00 $3,990.46 $300.00 $1,350.00 $855.00 $4,455.00 $1,680.00 $3,140.00 $5,530.00 $1,250.00 $3,495.00 $400.00
ANNUALTOTALS PARTIAL YEAR $7,090.00 $30,400.46
WELL PRODUCTION
MONTHLY TOTALS(GAL) 1,330,182 388,333 427,800 904,166 578,666 341,000 460,000 472,750 1,800,000 3,053,500 2,164,833 2,125,714 2,294,000 438,000 404,348
ANNUAL TOTALS(GAL) PARTIAL YEAR 2,146,315 15,036,977
1

EXPENSE SUMMARY 2023
ATEC FILTER
ADDED
1/23 2/23 3/23 4/23 5/23 6/23 7/23 8123 9/23 10/23 11/23 12/23
ELECTRICITY&GAS
Wells&ATEC System $223.43 $251.44 $290.44 $301.04 $465.85 $645.06 $835.21 $1,053.96 $1,046.05 $1,066.05 $782.27 $1,063.59
Booster 1 $128.51 $121.57 $126.33 $92.12 $75.27 $148.64 $149.03 $145.86 $141.02 $105.85 $121.68 $174.89
Booster 2 $51.87 $47.70 $51.17 $42.45 $72.79 $111.65 $147.94 $143.98 $140.45 $105.85 $74.68 $130.29
Booster Upper 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
MONTHLYTOTALS $403.81 $420.71 $467.94 $435.61 $613.91 $905.35 $1,132.18 $1,343.80 $1,327.52 $1,277.75 $978.63 $1,368.77
ANNUAL TOTALS $10,675.98
CHEMICALS
MONTHLYTOTALS $0.00 $385.27 $679.00 $0.00 $895.62 $523.68 $400.68 $1,322.75 $880.39 $321.39 $0.00 $575.59
ANNUAL TOTALS $5,984.37
TESTING
MONTHLYTOTALS $400.00 $2,170.00 $1,070.00 $3,390.00 $1,596.68 $460.00 $330.00 $270.00 $1,530.00 $820.00 $120.00 $310.00
ANNUAL TOTALS $12,466.68
WELL PRODUCTION
MONTHLY TOTALS(GAL) 354,286 508,000 598,300 435,0001 2,809,375 3,184,286 4,636,7141 4,154,000 2,601,4291 1,016,8001 502,5001 487,143
ANNUAL TOTALS(GAL) 21,287,833
1

EXPENSE SUMMARY 2024
1/24 2124 3/24 4/24 5/24 6/24 7/24 8/24 9/24 10/24 11/24 12/24
ELECTRICITY&GAS
Wells&ATEC System $875.82 $1,186.49 $1,031.25 $992.63 $954.59 $788.70 $1,150.72 $1,270.57 $1,248.82 $937.30 $1,067.08 $1,159.24
Booster 1 $221.29 $135.31 $139.85 $126.22 $91.17 $124.67 $199.52 $195.10 $0.00 $205.28 $106.22 $87.76
Booster 2 $178.12 $88.43 $98.36 $90.70 $82.32 $124.19 $196.77 $190.56 $0.00 $203.70 $98.09 $64.10
Booster Upper 0.00 0.00 0.00 0.00 115.60 18.00 18.00 18.00 $19.19 129.42 S42.75 SE3.50
MONTHLYTOTALS $1,275.23 $1,410.23 $1,269.46 $1,209.55 $1,143.68 $1,055.56 $1,565.01 $1,674.23 $1,268.01 $1,375.70 $1,314.14 $1,374.60
ANNUAL TOTALS $15,935.40
CHEMICALS
MONTHLYTOTALS $719.81 $676.16 $1,286.01 $681.03 $681.03 $2,340.00 $1,054.22 $1,257.19 $1,420.16 $978.03 $360.00 $0.00
ANN UAL TOTALS $11,453.64
TESTING
MONTHLYTOTALS $40.00 $160.00 $160.00 $120.00 $640.00 $680.00 $745.00 $2,420.00 $1,465.00 $1,050.00 $940.00 $490.00
ANNUAL TOTALS $8,910.00
WELL PRODUCTION
MONTHLYTOTALS(GAL) 1,542,250 616,000 447,286 1,053,750 1,813,500 2,348,571 5,044,143 4,455,143 3,222,857 1,501,286 741,429 465,000
ANNUALTOTALS(GAL) 23,251,215
1

EXPENSE SUMMARY 2025
1/25 2/25 3/25 4/25 5/25 6/25 7/25 8/25 9125 10125 11/25 12/25
ELECTRICITY&GAS
Wells&ATEC System $1,190.48 $929.54 $1,013.00 $914.80 $856.79 $1,225.40 $1,278.70 $1,394.48 $1,204.36 $1,031.16
Booster 1 $149.80 $164.65 $159.05 $171.85 $94.95 $91.53 $203.62 $228.52 $258.00 $250.54
Booster 2 $118.61 $125.58 $122.83 $104.90 $68.67 $87.07 $202.36 $227.72 $253.55 $247.12
Booster Upper $122.66 117.33 153.73 112.78 $94.59 $71.84 $62.75 58.20 58.20 $58.20
MONTHLYTOTALS $1,581.55 $1,337.10 $1,448.61 $1,304.33 $1,115.00 $1,475.84 $1,747.43 $1,908.92 $1,774.11 $1,587.02
ANNUALTOTALS Trailing 12 Mos $15,279.91 YTD 2025 $15,279.91
CHEMICALS
MONTHLYTOTALS $0.00 $762.70 $762.70 $531.00 $0.00 $874.69 $1,069.87 $1,600.00 $1,600.00 $0.00
ANNUALTOTALS Trailing 12 Mos $7,200.96 YTD 2025 $7,200.96
TESTING
MONTHLY TOTALS $530.00 $690.00 $330.00 $831.93 $1,720.00 $1,930.00 $3,056.36 $2,290.87 $2,047.00 $1,800.00
ANNUALTOTALS Trailing 12 Mos $15,226.16 YTD 2025 $15,226.16
WELL PRODUCTION
MONTHLY TOTALS(GAL) 473,857 660,000 947,714 900,000 2,728,000 4,847,143 4,920,143 4,862,571 4,547,143 4,452,571
ANNUAL TOTALS(GAL) Trailing 12 Mos 29,339,142 YTD 2025 29,339,142
1

EXHIBIT B
ENGINEER'S LETTER OF OPINION
LETTER FROM STEVE CORDES, P. E.
WELCH COMER ENGINEERS

1208-664-9382
WELCH—COMER 1'
ENGINEERS I S U R V E V O R S
1 E.Lakeside Avenue, 1
Coeur1 83814
Memorandum
TO: IDAHO PUBLIC UTILITES COMMISSION
FROM: STEVE CORDES, P.E.
PRJ.#: 44026.00.001
SUBJECT: VALIANT IDAHO/TIC UTLITIES WATER RATE CASE
DATE: NOVEMBER 24,2025
CC: WILLIAM HABERMAN
Welch Comer has been heavily involved in the improvements to the Idaho Club water system since
Valiant/TIC took ownership.
In that time period,we have designed several improvements to the system including a new storage
reservoir,a new booster station, new wells,a Chlorination system(March 2022)and a filtration
system to remove iron and manganese from the water(May 2023).
This infrastructure requires electricity,chemicals,and operator time to operate and maintain. These
costs increase proportionally as water production increases. The filtration system requires
additional chemicals in the form of chlorine and potassium permanganate. As homes are
constructed on vacant lots and as more water connections become active we would expect to see
water use and operating costs continue to increase.
The Idaho Club system contains many vacant/inactive lots and water demands are forecasted to
increase significantly as the system develops. These projections can be found in the water system
facilities plan.
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