20260121Comment_1.pdf

From: Chris Norton <[e-mail]>
Sent:Tuesday, January 20, 2026 4:26 PM
To: secretary<[e-mail]>
Cc: Joseph Terry<[e-mail]>
Subject: Case No.: VID-W-25-02; Company:TIC Utilities, LLC
To whom it may concern:
Please accept the attached as a public reply to Company's recent submittals and requests
for Reconsideration on Final Order 36818.
Thankyou,
Chris Norton
Christopher Norton
346 North Star Ln.
Sandpoint, Idaho 83864
Phone: [phone]
Email: [e-mail]
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Christopher Norton
346 North Star Ln., Sandpoint, Idaho 83864
Phone: [phone]
Email: chrisnortoniphone(abgmail.com
Re: Case No.: VID-W-25-02
Company: Valiant Idaho LLC/TIC Utilities, LLC
Re: Comments Opposing TIC Utilities, LLC Request for Reconsideration—Final Order 36818
To the Idaho Public Utilities Commission: secretary&puc.idaho.gov
Please accept the following comments in opposition to Valiant Idaho LLC/TIC Utilities, LLC's
("TIC") Request for Reconsideration of Final Order No. 36818.
TIC asserts that the revenue normalization approved by the Commission does not accurately reflect
revenue collected in 2024, claiming the shortfall was caused by "credit loss" resulting from an
inability to compel customer payment. That assertion is incorrect and unsupported by the record.
As demonstrated in numerous prior public filings, the reduction in 2024 revenue was not caused by
credit loss. It resulted from TIC's unilateral change in billing practices during 2024—specifically, a
shift from billing in advance to billing in arrears.
Attached as Exhibit A are the four invoices I received in 2024. The first two invoices, dated January
I and April 1, 2024,billed in advance. The final two invoices, dated September 30 and December 30,
2024, billed in arrears. The December 30 invoice covered service for October, November, and
December 2024.
Because TIC issued the fourth-quarter invoice on December 30, 2024, it was physically impossible
for customers to remit payment and for TIC to receive and process those payments within the final
two days of the year.As a result, fourth-quarter payments were necessarily received in 2025.
If TIC utilized cash-basis accounting—as its financial statements suggest—then its 2024 financials
would necessarily reflect only nine months of collected revenue,not twelve.This accounting outcome
is entirely attributable to TIC's billing decision, not to customer nonpayment.
Accordingly, TIC's claim of"credit loss" is factually inaccurate.
To properly normalize revenue to a full twelve-month period, the unmetered water revenue reported
by TIC on TIC's Operating Results—(Schedule A Revenues) must be adjusted. The reported amount
of$127,583.50(See Attached EXHIBIT B)reflects only nine months of collected revenue and should
be multiplied by 12/9 (1.33333), resulting in normalized revenue of$170,111.33.
The Commission's adopted revenue figure of $165,240 already benefits TIC by approximately
$5,000. There is no evidentiary or legal basis for further upward adjustment. If the Commission were
to reconsider the revenue normalization at all, the record supports an increase—not a decrease—to
$170,111.33.
For these reasons, TIC's Request for Reconsideration should be denied.
Respectfully submitted,
Christopher Norton

TIC utilities Invoice
PO Box 3388
Coeur D Alene ID 83816
1-877-755-9287 Invoice#: 17192
Invoice Date: 1/1/2024
Due Date: 1/31/2024
Bill To:
Christopher&Meleah Norton
346 North Star Ln
Sandpoint, ID 83804
Item Description Amount
Water Water Invoice for January, February and March. 135.00
2o-- 21
Total $1 as.00
Balance Due $135.00
Lot 2.Blk 5,GTE 4
Please make checks payable to:TIC Utilities,LLC
EXHIBIT "A"

TIC Utilities Invoice
PO Box 3388
Coeur D Alene ID 83816
1-877-755-9287 Invoice#: 17491
Invoice Date: 4/1/2024
Due Date: 5/1/2024
Bill To:
Christopher 8 Meleah Norton
346 North Star In
Sandpoint, ID 83864
Item Description Amount_ ----
Water Water Invoice for April, May and June. 135.00
-- Total $135.00
Balance Due $135.00
Lot 2.Blk 5,GTE 4
Please make checks payable to:TIC Utilities,LLC

TIC Utilities
PO Box 1544 Invoice
Sandpoint, ID 83864
1-208-255-1645 ?o
T 11
•i• Invoice#: 17777
UTILITIES Invoice Date: 9/30/2024
Due Date: Due Upon Receipt
Bill To:
Christopher&Meleah Norton
346 North Star Ln
Sandpoint, ID 83864
Account# Lot 2.Blk 5,GTE 4
Doscription Amount
Water Invoice for July, August, September 135.00
Balance Due $135.00
Please make checks payable to:TIC Utilities,LLC
[e-mail]

TIC Utilities Invoice
PO Box 1544
Sandpoint, ID 83864
1-208-255-1645
I Invoice M 18124
UTILITIES Invoice Date: 12/30/2024
Due Date: Due Upon Receipt
Bill To:
Christopher&Meleah Norton
346 North Star Ln
Sandpoint, ID 83864
Account# Lot 2.Blk 5,GTE 4
Description Amount
Water Invoice for October, Novernber, December 135.00
Balance Due $135.00
Please make checks payable to:T1C Utilities,LLC
[e-mail]

OPERATING RESULTS(SCHEDULE"A"REVENUES)
Company Name: TIC Utilities LLC(The Idaho Club)
Idaho PUC Case Number: 554
Test Year ended: 2024
(A) (B) (C)
Test Year Known Pro Forma
(See Annual Report page 3) Actual Changes* (A+B)
Water Revenues:
1 Unmetered 127,583.50 127,583.50
2 Metered-Residential
3 Metered-Commercial&Industrial
4 Fire Protection Revenue
5 Other Water Sales Revenue
6 Irrigation Sales Revenue
7 Sales for Resale
8 Total Water Revenue(Add lines 1 -7)
9 DEQ Fees billed separately to customers
10 Hook-up or Connection Fees collected 455.50 455.50
11 Commission-approved Surcharges collected
12 TOTAL REVENUE(Add lines 8- 11) 128,039.00 128,039.00
*Attach detailed explanations and calculations
showing the development of each"Known Change"
to the test year data.
Exhibit No.2
Schedule A
EXHIBIT B
1