20260204Comment_1.pdf

From: Chris Norton <[e-mail]>
Sent:Wednesday, February 4, 2026 2:51 PM
To: secretary<[e-mail]>
Subject: Re: Complaint and Public comment in Case No. VID-W-25-02
February 4, 2026
To whom it may concern:
Pursuant to instructions from the staff of the IPUC, I am requesting that the attached
document be processed as follows:
1. Placed in the public comment section of the Case No. VID-W-25-02;
2. Be filed as a complaint with copies provided to all three Commissioners of the IPUC;
and
3. Provide copies to staff members
a. Joseph Terry: Joseph.Terry(&auc.idaho.gov
b. Travis Culbertson:[e-mail]
Thank you for your anticipated cooperation and assistance in this matter.
If you have any questions or you need me to clarify any related issues, please contact me.
Sincerely,
Christopher Norton
346 North Star Ln.
Sandpoint, Idaho 83864
Phone: [phone]
Email: chrisnortoniphone gmail.com
----------------------------------------------------------------------------------------------------------------

Date: February 4, 2026
To: Idaho Public Utilities Commission
Claimant:Christopher Norton, 346 North Star Lane, Sandpoint,Idaho. Phone: 713-301-
1492. Email: [e-mail]
Copy: Bonner County, Idaho Commissioners Williams,Domke, and Korn
Re: COMPLAINT REGARDING RETALIATORY CONDUCT BY Valiant Idaho,
LLC; TIC Utilities,LLC; and William Haberman
Respondent: I submit this complaint against Valiant Idaho, LLC ("Valiant"), TIC Utilities, LLC
("TIC"), and William Haberman, the owner and managing agent of both entities.
INTRODUCTION
The Idaho Public Utilities Commission ("Commission") has both the authority and the statutory
duty to investigate and correct improper utility conduct. In Order No. 36520, the Commission
expressly committed to examining the "practices, rules and regulations, service,
instrumentalities, equipment, facilities, classifications, and customer relations" of Valiant'. That
inquiry is mandated by Idaho law, which requires the Commission to ensure utilities comply with
the Constitution, statutes, and Commission orders,prohibits unlawful acts or omissions, and
authorizes corrective action and cumulative penalties for violations. See, Idaho Code §§ 61-701,
61-702, 61-703, 61-704, 61-705.
Retaliation is not hypothetical—it has already been identified by the Commission. In Order No.
36312, the Commission found evidence that"some members of the public have refrained from
filing comments out of fear of having their golf, tennis, and social privileges at the Idaho Club
revoked—indicating that this has already happened at least twice,"2 and warned that retaliation
against customers "is a very serious matter and could result in the imposition of penalties."Id. at
page 5.At the August 14, 2025 public hearing, after observing widespread fear of retaliation for
speaking out among residents, the Commission specifically requested notification of any future
retaliatory acts.
Despite those warnings, retaliation has continued. Respondents targeted Idaho Club resident
David Frohnen after he raised concerns about their conduct. Mr. Frohnen has filed a complaint a
few days ago stating, "I've been hesitant to make this report out of concern of further
retaliation."That fear is well-founded. Such conduct chills lawful customer participation and
directly undermines the Commission's regulatory authority.
Both David Frohnen and I have submitted public comments with the Bonner County
Commissioners regarding a subdivision application filed by Valiant or its affiliates (See Bonner
County File Numbers S00004-24 and S0006-22). Respondents'actions against us are a clear
attempt to silence opposition and deter residents from exercising their rights before public
' See,Order No. 36520 in Case No.VID-W-25-02 filed March 20,2025.
'See,Pages 3-4 of Order No.36312 in Case No. GNR-W-24-01 filed 9/6/2024.
Page 1 of 12

bodies. Because this retaliation affects both Commission proceedings and local land-use matters,
a copy of this complaint is being provided to the Bonner County Commissioners.
STATEMENT OF FACTS
Valiant has engaged in retaliatory conduct against me on multiple occasions. The facts set forth
below demonstrate a continuing pattern in which Mr. Haberman—through his complete control
of Valiant, TIC, The Idaho Club golf facilities, and the Homeowners Association—uses affiliated
entities to punish residents who speak out,participate in regulatory proceedings, or oppose
actions adverse to homeowners.
These retaliatory actions have occurred despite express warnings from the Idaho Public Utilities
Commission("IPUC")that retaliatory conduct by a regulated utility is a serious matter and may
warrant penalties.As demonstrated by the filing of Mr. Frohnen and the facts below, the
retaliatory actions of Mr. Haberman through his control of Valiant and TIC have been ongoing
for several years. To date, Governmental agencies have issued warnings against Mr. Haberman
but have not taken any action. This lack of any enforcement by governmental agencies has
emboldened Mr. Haberman, Valiant and TIC. Not only has the lack of any governmental action
emboldened him, but it has also had a chilling effect on the residents of The Idaho Club.
Residents have seen retaliatory actions taken against other residents who have spoken up with no
response from any government agencies. The effect is that most residents are afraid to voice any
concerns out of fear that their membership in the golf or social club at The Idaho Club will
likewise be revoked.
I. CONTROL AND STRUCTURE
Mr. Haberman owns and manages both Valiant and TIC. He is also the Declarant under the
Declaration of Covenants, Conditions, Restrictions and Easements for The Idaho Club ("CCRs").
Through super-majority voting authority reserved under the CCRs, Mr. Haberman exercises
effective control over the Homeowners Association ("HOA"), including appointing himself
President of the Board of Directors.
Mr. Haberman has publicly described himself to residents as a"benevolent dictator."In practice,
this concentration of control has enabled him to use multiple affiliated entities interchangeably to
reward compliance and punish opposition.
II. PROTECTED ACTIVITY
Prior to relocating full-time to Ponderay and then becoming a year-round resident of The Idaho
Club, I was an attorney for approximately 35 years after obtaining my degree in engineering. In
2022, I was elected to the Board of Directors of the Idaho Club HOA.As a director, I owed
fiduciary duties to the Association and its members under Idaho law. See Hanny a Sunnyside
Ditch Co., 82 Idaho 271 (1960); Coeur d'Alene' Lead Co. a Kingsbury, 59 Idaho 627 (1938). I
understood my fiduciary obligations were to act in the best interests of the homeowners.
I served as chair of an HOA committee formed to evaluate whether the Association should
acquire The Idaho Club water system. Based on the committee's investigation and the extensive
documentary evidence obtained through that investigation, I made a presentation to the HOA, on
Page 2 of 12

behalf of the independent board members and the committee, opposing Valiant's proposed sale of
the water system. I have also submitted public comments to the Idaho Public Utilities
Commission, the Idaho Department of Environmental Quality, and the Bonner County Board of
Commissioners concerning water system operations, quality, and rates. In each instance, my
statements were drawn directly from documentary sources, many of which were created by
Valiant, Mr. Haberman, or their agents. To ensure accuracy and transparency, I attached excerpts
of the underlying documents so that decision-makers could independently verify my statements
(including 34 exhibits to the HOA, 14 exhibits to the IPUC, 21 exhibits to the Bonner County
Commissioners, 1 exhibit to IDEQ, and 17 exhibits in this filing).Valiant nonetheless asserts that
quoting its own documents or public records by those who oppose its position is defamatory.
That assertion is unfounded. The quotation and submission of documentary evidence in public,
regulatory, and governance proceedings constitutes lawful, good-faith, and protected
participation in matters of public concern.
III.WATER SYSTEM TRANSACTION AND ESCALATION
In 2023,Valiant sought to sell the water system to Gem State Water Company for approximately
$821,6723, and Gem State obtained IPUC approval to proceed.After due diligence, Gem State
declined to close.
Later, Mr. Haberman told the Board of Directors of the HOA that he wanted the HOA to
purchase the water system from Valiant. However, Mr. Haberman and Valiant refused to provide
necessary due-diligence documents and later demanded that the HOA purchase the system—at
an increased price of approximately$2,000,0001, nearly 250%higher than the Gem State
transaction. Valiant attempted to force the HOA to buy the water system through various means
including threatening to use his super majority voting rights to override any homeowners votes,
filing a petition to create a water and sewer district controlled by Mr. Haberman, and finally
making a presentation directly to the homeowners.
In each case, the independent board members successfully opposed the efforts of Mr. Haberman.
Also, in each case Mr. Haberman and Valiant took retaliatory action against those who opposed
them. The timing of the opposition and retaliatory actions are not a coincidence.
1. On March 14, 2024, the independent board members were informed by a resident in The
Idaho Club that Valiant had filed a petition to form a water and sewer district to force the
HOA to purchase the systems from Valiant.
a. Two days later-March 16, 2024, the independent board members sent out an email
to homeowners stating that the upcoming court hearing regarding the potential
water district could adversely affect everyone.
b. On March 19, 2024, Valant informed the Board of Directors that it was cancelling
the hearing on the petition to form a water and sewer district.
c. The very next day, Mr. Haberman called an executive session of the board of
directors and demanded the resignations of the independent directors.
s See Attachment to 1/24/224 email from Mr.Haberman to Board of the HOA. Relevant pages are attached as
Exhibit 01.
4 See Exhibit D to Valiant's Petition to Form Water and Sewer District outlining purchase price for water and sewer
system. Relevant pages are attached as Exhibit 02.
Page 3 of 12

2. On June 20, 2024,Valiant proposed to the HOA at an HOA meeting that the HOA form a
water district and buy the water system from Valiant. I made a presentation quoting 34
documents in opposition to the acquisition. The homeowners did not agree to purchase
the water system from Valiant.
a. 5 days later, June 25, 2024, Mr. Haberman advised one of the independent board
members that he was being removed from the Design Review Board after many
years of service on the Design Review Board.
b. 11 days later, July 1, 2024, Mr. Haberman's lawyers sent an email to me and
another independent board member threatening civil litigation against us. The
email specifically stated it was done in response to my presentation at the June 20,
2024 HOA meeting.
i. The email also revoked my golf club membership;
ii. Revoked my wife's membership at The Idaho Club; and
iii. Valiant refused to return our$12,500 golf membership initiation fee.
3. On July 18, 2024, I submitted a public comment in IPUC Case GNR-W-24-01 outlining
some of the retaliatory actions that Valiant had taken against me and argued that Valiant
should be regulated.5
a. On December 20, 2024, the IPUC made clear that Valiant was a regulated entity
and issued Certificate No. 554 to "Valiant Idaho, Inc. and its successors and
assigns".6
b. On January 14, 2025, the Staff of the IPUC recommended the Commission open a
separate docket(VID-W-25-01)to evaluate the rates on Valiant's tariffs.'
c. On January 23, 2025, Valiant connected the 3-inch water line to the Moose
Mountain Reservoir through the Booster Station and began providing pressurize
water to the lots and homes at the top of Moose Mountain (where I live), but
Valiant failed to connect our home to the pressurized water line in violation of
Idaho law.
d. We did not get pressurized water until I filed a complaint with the IDEQ (on April
22, 2025), the IDEQ Ordered Valiant to connect us to the 3-inch pressurized water
line (on July 25, 2025), and Valiant finally connected us on October 20, 2025.
All of Valiant's retaliatory actions occurred immediately or shortly after I opposed Valiant's
water-system demands or proposed tariffs and had no legitimate business justification.
IV. RETALIATION FOR DISCLOSING FACTUAL MISREPRESENTATIONS
The presentations and statements made by myself and other independent directors at the HOA
meeting were factual and quoted directly from 34 Exhibits, many of which were authored by
Valiant, TIC, or Mr. Haberman. These Exhibits were made available to all homeowners and
copies of all the Exhibits were provided to anyone that asked for them.
s See 07/18/2024 Public Comment in IPUC Case No.GNR-W-24-01.
6 See Certificate No. 554 in IPUC Case No. GNR-W-24-01 dated 12/20/2024.Relevant pages are attached as
Exhibit 03.
7 See Staff's Decision Memorandum in IPUC Case No.GNR-W-24-01 dated January 14,2025.
Page 4 of 12

One example of Valiant's factual misrepresentation to a public agency which was disclosed to the
home owners at the HOA meeting illustrates the pattern:
On March 25, 2024, Valiant emailed the HOA Board that Valiant was revoking its offer to sell
the water system to the Idaho Club Homeowners Association. Thirteen (13)minutes later,
Valiant, in attempt to avoid regulation by the IPUC, emailed the IPUC Staff stating it had elected
"to sell and transfer the Idaho Club water system to the Idaho Club Homeowners Association. "8
That statement was false and confirmed in the Comments filed by the IPUC Commission Staff.
As the Staff of the IPUC noted, such misrepresentations by Valiant to the IPUC "cast doubt on
any promises the Company may make for future action". Id. When such deceptions were
exposed, retaliation followed.
V.DENIAL OF PRESSURIZED WATER SERVICE
My wife and I live year-round at the top of Moose Mountain on property contiguous to the
Moose Mountain Reservoir and Booster Station. The booster station serves other homes on
North Star Lane and Green Monarch Lane and is located approximately 25-30 feet from our
driveway. Water lines run servicing North Star Lane and Green Monarch Lane run beneath our
driveway-thus, giving us a bird's eye view of all work done on the water lines running across our
property and under our driveway.
When our home was constructed in 2019-2020, the booster station had not yet been built. When
we connected to the 3-inch water distribution line, the water line contained no water and no
pressure, in violation of Idaho's minimum pressure requirements of 40 psi.
As a result, we were forced to connect to a parallel low-pressure line (10-15 psi) and purchase a
private booster pump merely to obtain water service.
Valiant later represented inconsistent positions with different agencies regarding their ownership
of the water system.
• In 2019,Valiant represented to Bonner County that it owned the system and had reserved
capacity9.
• In 2024,Valiant represented to the IPUC that it acquired the water system in 201610
• Yet when defending its failure to provide pressurized water, Valiant in 2025 claimed our
home was constructed before it owned the system.'1
These representations cannot all be true. Valiant has made contradictory representations to
different agencies regarding the timing and nature of ownership. Valiant cannot simultaneously
claim ownership when seeking approvals and disclaim ownership when defending compliance
failures. These inconsistencies undermine credibility and do not excuse prolonged violations of
minimum service standards.
a See Page 3 of Comments of the Commission Staff in Case NO. GNR-W-24-01 filed 7/18/2024.Relevant pages are
attached as Exhibit 04.
9 See Will Serve letter submitted by Valiant to Bonner County Planning Department in support of MLD0006-19.
Relevant pages are attached as Exhibit 05.
io See Valiant's Comment to Order Nos. 36149 and 36254.Relevant pages are attached as Exhibit 06.
" See Valiant's Responses to Comments of Commission Staff&Public Comments.Relevant pages are attached as
Exhibit 07.
Page 5 of 12

We lived in our home for approximately five years with water pressure significantly below the
minimum pressure requirements of Idaho Law. This includes approximately 5 years after Valiant
concedes it owned the water system and nearly a year after Valiant was issued its CPCN. Valiant
finally connected the 3-inch line to the Moose Mountain Reservoir through the Booster Station
and began providing pressurize water on January 23, 2025. Despite this, Valiant refused to
connect our home to the 3-inch pressurized line, making us the only residence in The Idaho Club
without pressurized water.
It was only after I filed a formal complaint with the Idaho Department of Environmental Quality
("IDEQ"), and after the IDEQ issued an order on July 25, 202512, directing Valiant to connect us,
that we were connected to the 3-inch pressurized line. Even after being ordered by the IDEQ,
Valiant delayed over 3 months, completing the connection on October 20, 2025. Post-
enforcement compliance does not negate prior violations. The necessity of an IDEQ enforcement
order demonstrates refusal to correct known deficiencies voluntarily. The duration of
noncompliance and resistance to correction remain relevant to findings and penalties.
The correction required less than half a day and only required switching the connection of our
home's water line from the connection line to the low-pressure line to the connection line to the
3-inch water line that was filled and pressurized on January 23, 2025. Both connection lines
were in place and lying parallel to one another only a few inches apart. A photograph showing
the close proximity of our tie in lines to both water lines is attached as Exhibit 09. It
nevertheless took an IDEQ enforcement order to compel compliance.
Compliance after enforcement does not erase violations. The need for an enforcement order
demonstrates not resolution, but refusal to comply voluntarily with Idaho law.
VI. FAILURE TO INSTALL FIRE HYDRANTS ON NORTH STAR LANE
North Star Lane, where my home is located, is the only street within the Idaho Club without fire
hydrants. Valiant does not dispute this fact. Despite requests to install fire hydrants on North Star
Lane,Valiant has refused to do so.
Valiant has acknowledged that it has a responsibility to maintain adequate fire suppression and
flow for all parcels within its service area yet has refused to install hydrants on North Star Lane
despite the requirements of the Idaho Fire Code. Valiant has indicated that it will not comply
with the requirements of the Idaho Fire Code until there is an Order to comply.
Fire hydrants are not aesthetic improvements—they are life-safety infrastructure tied directly
to water system capacity and pressure. Fire-flow capacity and hydrant availability are
inseparable from water system pressure, design, and operation. Valiant has acknowledged
responsibility for fire suppression within the service area. Moreover,Valiant has used its
"responsibility to maintain fire suppression and flow for all parcels within the service area" as
a rationale for a non-flowing rate or standby fees for vacant lots in its Application for Authority
12 See 7/25/2025 Letter from IDEQ to Bill Haberman Ordering connection to 40 psi distribution system. A copy of
the Order is attached as Exhibit 08.
Page 6 of 12

to Increase its Rates and Charges for Water Service 13. Disparate denial of hydrants on a single
street lacks any legitimate technical or safety justification.
There is no legitimate basis for treating this street differently from all others within the
development. The refusal constitutes another retaliatory act.
VII. COMMISSION JURISDICTION AND ALTER-EGO CONDUCT
A Certificate of Public Convenience and Necessity("CPCN")was issued to Valiant Idaho,Inc.
and its successors and assigns for the purpose of operating"a water system and provide a potable
water supply to customers in a development and golf club called the Idaho Club". See, Exhibit
03. The issuance of the CPCN brings Valiant squarely within the Commission's Jurisdiction.
The Commission acknowledged this in Order No. 36459 when it stated"The Commission has
jurisdiction over the Company's[Valiant]Application and the issues in this case...The
Commission is empowered to investigate rates, charges, rules, regulations,practices, and
contracts...to determine whether they are just, reasonable,preferential, discriminatory, or in
violation of any provisions of law"14. However, even if the IPUC had not issued the CPCN,
Valiant is a water corporation under Idaho Code IC 61-125, and thus a public utility"subject to
the jurisdiction, control and regulation of the commission". Idaho Code IC 61-129.
The IPUC previously considered some of these issues and declined to do anything. The rationale
of the Commission at that time was "Although the alleged retaliation associated with this case
ostensibly occurred via entities outside Commission jurisdiction, allegations of a regulated
utility retaliating against customers are a very serious matter and could result in the imposition of
penalties. See Order No. 35817 at 32."15
Many things have transpired since the IPUC Commission's conclusion in August 2024 which
unequivocally demonstrate that the entities engaging in these retaliatory actions are clearly
within the Commission's Jurisdiction and no longer can Valiant be considered an entity outside
Commission Jurisdiction.
Likewise, the Bonner County Board of Commissioners has jurisdiction over land-use approvals,
including conditional and special use permits, as well as enforcement of compliance with those
permits. In exercising that authority, the Commissioners are required to receive and consider
public comments as part of the official record. See, Bonner County Code BCRS 12-267 and
Idaho Code IC 67-6509. Valiant's retaliatory actions have had a demonstrable chilling effect on
public participation in these proceedings. If unchecked, such conduct will deter members of the
public from reporting violations or providing comments on Valiant's applications and
compliance with either the IPUC or the Bonner County Board of Commissioners, undermining
the integrity of both regulatory and land-use review processes.
"See Valiant's Responses to Comments of Commission Staff&Public Comments filed in Case No.VID-W-25-02
on 9/3/225.Relevant pages are attached as Exhibit 10.
14 See IPUC Order No. 36459 in IPUC Case NO.GNR-W-24-01 at Page 1 dated 2/7/2025.
15 See IPUC ORDER NO. 36312 in IPUC Case NO. GNR-W-24-0lat Pages 4-5 dated 8/6/2024
Page 7 of 12

Mr. Haberman exercises unified control over Valiant and TIC, and the entities operate as alter
egos, including:
• overlapping ownership and management;
o TIC is owned and/or managed by Valiant16;
o Mr. Haberman represents that he is the managing agent of Valiant",-
o Mr. Haberman represents that he is the managing agent of TIC18;
• inconsistent claims regarding ownership and operation of the water system;
o Valiant represents that it owns the Idaho Club water system 19;
o TIC represents that is owns The Idaho Club water system 20;
o Valiant represents that it owns The Idaho Club water system and TIC operates The
Idaho Club Water System2l;
• intermingled invoicing and expenses;
o Valiant represented that TIC "pays nearly$ 38,000 per year for a full-time
equivalent Grill Cook" for the golfclub owned by Valiant and pays the salary of
the "Ground Maintenance Manager" for the golfclub.22
o When Valiant provided invoices to the IPUC to support of its requested tariff
rates,Valiant included invoices submitted to Valiant, TIC, Mr. Haberman, and the
Idaho Club23.
• contradictory representations to regulators.
o The CPCN was issued in the name of Valiant24;
o TIC claims the CPCN was issued in the name of TIC25;
o Valiant represented to Bonner County in 2019 that it owned the water system and
had reserved capacity.26
o Valiant represented to the IPUC in 2024 that it acquired the water system in
201627.
i6 See Annual Report filed by TIC with the Office of the Secretary of State for State of Idaho,a copy of which is
attached as Exhibit 11.
17 See Water System Asset Purchase Agreement between Valiant and Gem State dated 12/9/2022.Relevant pages are
attached as Exhibit 12.
"See Signature page of Valiant's Responses to Comments of Commission Staff&Public Comments in Case NO.
VID-W-25-02 dated 9/3/2025(Relevant pages are attached as Exhibit 13),and Water System Asset Purchase
Agreement between Valiant and Gem State dated 12/9/2022(Relevant pages are attached as Exhibit 12)
19 See Valiant's Comment to IPUC Order Nos. 36149 and 36254 in IPUC Case No. GNR-W-24-01 filed July 30,
2024. Relevant pages are attached as Exhibit 06.
20 See Letter from TIC Utilities,LLC to The Idaho Club Property Owners dated 9/9/2024.Relevant pages are
attached as Exhibit 14.
21 See Water System Asset Purchase Agreement between Valiant and Gem State dated 12/9/2022.Relevant pages are
attached as Exhibit 12.
22 See Pages 5 and 6 of Valiant's Responses to Comments of Commission Staff&Public Comments in Case NO.
VID-W-25-02 dated 9/3/2025.Relevant pages are attached as Exhibit 15.
23 See Invoices submitted to Valiant,TIC,William Haberman and the Idaho Club. Copies of only a few of the
invoices are attached as Exhibit 16.
24 See IPUC Certificate No. 554 dated 12/20/2024.Relevant pages are attached as Exhibit 03.
25 See Application for Rate Increase in IPUC Case No.VID-W-25-02.The relevant page is attached as Exhibit 17.
26 See Exhibit 05.
27 See Exhibit 06.
Page 8 of 12

o Valiant represented to the IPUC in 2025, when defending its failure to provide
pressurized water, that it did not own the water system in 2019 and most of
202021.
The conduct at issue is therefore squarely within the Commission's jurisdiction. Valiant cannot
avoid accountability by shifting responsibility among commonly owned entities while exercising
unified control over all material decisions. We are not asking the Commission to pierce the
corporate veil—only to recognize operational reality, which agencies do routinely.
VIII. PATTERN OF RETALIATION
Retaliation is established by circumstantial evidence, including timing, selective enforcement,
disparate treatment, and absence of legitimate justification. The adverse actions described herein
occurred only after protected participation in regulatory and governance proceedings or Board of
Director actions within the HOA and were directed solely at residents who opposed Valiant's
positions. Such patterns are sufficient to establish retaliation even absent express admissions of
intent.
The Commission has previously recognized that residents have reported retaliation involving
revocation of golf and social privileges, and that some residents refrained from filing comments
due to fear of reprisal.
At the Commission's public hearing on August 14, 2025, the vast majority of residents in
attendance raised their hands when asked whether they feared retaliation by Valiant, TIC, or Mr.
Haberman.
This pattern has continued. Valiant may argue that any claims of retaliation are anecdotal or
speculative. Such assertion fails because of the following corroborating evidence:
• The IPUC Commissioners acknowledgment in prior orders;
• Public hearing where residents raised hands;
• Public comments indicating they were in fear of retaliation;
• The separate complaint by Mr. Frohnen;
• A pattern of retaliation across years.
The issue is not whether every resident was retaliated against, but whether retaliation was
sufficiently demonstrated to chill public participation. The Commission has previously
acknowledged resident concerns regarding retaliation. In public filings with the various agencies,
there have been several public comments submitted under assumed or anonymous names
specifically mentioning they were filing anonymously out of fear of retaliation. Finally, multiple
residents publicly commented they have refrained from participation due to fear, and a separate
formal complaint alleging retaliation has been filed by another customer. The standard is not
universal harm,but whether conduct reasonably discourages public participation.
zs See Exhibit 07.
Page 9 of 12

IX. CONCLUSION
This case is not about golf privileges or water pressure. The issue is whether a regulated utility
used affiliated entities under common control to retaliate against customers who engaged in
protected public participation. The use of non-regulated affiliates to carry out retaliation does not
insulate regulated entities from accountability.
Likewise, this complaint is not motivated by personal grievance,but by concern for regulatory
compliance,public safety, and the chilling effect retaliation has had on resident participation.
Despite prior warnings from the IPUC that retaliation by a regulated utility is a serious matter
warranting penalties, the conduct has continued and, in some cases, escalated. The complaint is
supported by agency orders,public filings, testimony before public agencies, and corroborating
resident statements. It arises from fiduciary service, regulatory participation, and documented
safety deficiencies, not personal disagreement. The issues raised implicate public oversight, not
private grievances.
Valiant and TIC operate under unified ownership, management, and decision-making authority.
They have made inconsistent representations to public agencies regarding ownership and
operation of the water system, intermingled expenses, and exercised centralized control
demonstrating a lack of regulatory candor and accountability. Under such circumstances,
regulators typically have and should evaluate conduct based on operational reality rather than
formal corporate labels. Even if one looks purely to the formal corporate labels, the CPCN was
issued to Valiant, the owner and operator of the golf course and the associated golf and social
memberships in The Idaho Club. Accordingly, no matter how one views it,Valiant and TIC are
clearly within the jurisdiction of the IPUC.
Our primary concern is not preferential treatment, but the orderly, safe, and lawful build-out of
water and sewer infrastructure in a master-planned community—including reliable domestic
water pressure and adequate fire-flow protection for all parcels without discrimination.
This filing is submitted so that current and future proceedings involving Valiant may be
evaluated with a full understanding of the applicant's conduct toward customers and the chilling
effect such conduct has had on public participation.
Retaliation is established by:
1. Protected activity
2. Adverse action
3. Temporal and factual linkage
Retaliation is rarely admitted. It is established by circumstantial evidence, including timing,
selective enforcement, disparate treatment, and the absence of legitimate justification. Valiant's
retaliatory actions
• occurred immediately after opposition;
• only dissenting residents were affected;
• identical conditions existed for others without enforcement.
Page 10 of 12

The issue is not regulation of golf privileges. The issue is whether a regulated utility used
affiliated entities that it controls to retaliate against customers who participated in public HOA
meetings and public entity proceedings.
REQUESTED RELIEF
Absent meaningful consequences, retaliatory conduct becomes a cost of doing business. I
respectfully request that the Commission and other reviewing authorities consider the following:
1. Finding that Valiant, TIC, and Mr. Haberman have engaged in retaliatory conduct;
2. An order directing that at the election of Christopher Norton, Valiant be ordered to
reinstate their golf memberships in The Idaho Club, or alternatively, return the $12,500
golf membership fee;
3. Monetary penalties for periods during which Valiant operated the water system in
violation of minimum pressure requirements as found by the IDEQ;
4. Monetary penalties for failure to timely comply with IDEQ's Order to connect our home
to the 3-inch pressurized water line;
5. An order requiring installation of fire hydrants on North Star Lane at no cost to residents;
6. Consideration of daily penalties until compliance is achieved;
7. Consideration of reduction of the authorized rate of return below the current 11%; and
8. Any additional relief necessary to deter future retaliation and protect public participation
in regulatory proceedings.
I have included many portions of the documents supporting my assertion of retaliation.
However, out of concern for brevity, I have not included all documents referenced. Nor have I
included the entirety of all pages in the documents. Many of the documents are quite lengthy.
Should you wish to examine any of the documents I have referenced or wish to see an entire
document rather than the selected pages I have referenced, please let me know, and I will happily
email them to you.
Respectfully submitted,
e&wa &A .lUott#. n
Page 11 of 12

EXHIBIT LIST
Exhibit No. Description
Exhibit 01: Attachment to 1/24/224 email from Mr. Haberman to Board of the HOA.
Exhibit 02: Exhibit D to Valiant's Petition to Form Water and Sewer District outlining purchase
price for water and sewer system.
Exhibit 03: Certificate No. 554 in IPUC Case No. GNR-W-24-01 dated 12/20/2024
Exhibit 04: Page 3 of Comments of the Commission Staff in Case NO. GNR-W-24-01 filed
7/18/2024.
Exhibit 05: Will Serve letter submitted by Valiant to Bonner County Planning Department in
support of MLD0006-19
Exhibit 06: Valiant's Comment to Order Nos. 36149 and 36254.
Exhibit 07: Valiant's Responses to Comments of Commission Staff& Public Comments.
Exhibit 08: 7/25/2025 Letter from IDEQ to Bill Haberman Ordering connection to 40 psi
distribution system.
Exhibit 09: Photograph showing proximity of water lines.
Exhibit 10: Valiant Responses to Comments of Commission Staff&Public Comments in Case
No. VID-W-25-02.
Exhibit 11: Annual Report of TIC
Exhibit 12: Water System Asset Purchase Agreement between Valiant and Gem State dated
12/9/2022.
Exhibit 13: Signature page of Valiant's Responses to Comments of Commission Staff&Public
Comments in Case NO. VID-W-25-02 dated 9/3/2025.
Exhibit 14: Signature page of Valiant's Responses to Comments of Commission Staff&Public
Comments in Case NO. VID-W-25-02 dated 9/3/2025
Exhibit 15: Valiant Responses to Comments of Commission Staff& Public Comments in Case
No. VID-W-25-02.
Exhibit 16: A small sample of the invoices submitted to Valiant, TIC, William Haberman and
the Idaho Club which Valiant used in support of its proposed tariff rates.
Exhibit 17: Valiant's Application for Rate Increase in IPUC Case No. VID-W-25-02.
Page 12 of 12

THE
IDAHO
CLUB
Summary of Proposed Sale of Water & Sewer Systems at The Idaho Club
Executive Summary
Valiant Idaho, LLC, and it subsidiary, TIC Utilities, LLC (collectively, "TIC"), acquired the water
and sewer systems at The Idaho Club via foreclosure and other successful legal actions. In
November 2022, TIC sold the sewer system to Gem State Water ("Gem State"), a subsidiary of
NW Natural, Inc. As part of that transaction, Gem State also entered into a contract to purchase
the water system upon approval from Idaho Public Utility Commission ("IPUC") which was
expected to close in November 2023. Gem State elected to not proceed with the purchase of
the water system. During our recent discussions with Gem State, their business contact has
agreed that it makes sense to keep the two systems under common ownership and indicated
their willingness to sell the sewer system back to us or our assignee for the amount paid plus
reimbursement for its capital expenses. TIC proposes that The Idaho Club HOA purchase both
of these systems for several reasons outlined below, the most significant of which is that the
HOA should control these strategic assets to avoid the issues experienced during the one year
of outside ownership of the sewer system and the historical issues experienced with outside
ownership of the water system.
Benefits to Ownership by HOA:
Operation as a Non-Profit: Given that the HOA is a non-profit, and other ownership
alternatives are not, rates and hook-up fees can be maintained at the minimum amounts
required to properly operate and maintain the systems without the addition of profit or returns on
equity. No outside owner, TIC included, will be willing to operate the systems at a loss or at
breakeven and thus rates established by an outside for-profit owner will reflect this additional
financial load.
Lien Rights for Collection of Fees: There are significant accounts receivable due to many
absentee owners simply not paying their monthly fees. Collecting those delinquent fees is
costly primarily due to it requiring the pursuit of legal claims without a definitive lien right against
the properties. By contrast, the delinquencies for HOA fees are less than 5% and only rarely
result in expensive collection actions. Thus, ownership by the HOA with a legal right to lien for
unpaid fees will significantly improve the cash flow, reducing the burden on the owners who do
pay on time and ensuring that capital is available to cover the costs of maintaining the systems.
EXHIBIT 01

Exemption from IPUC Regulation for HOA Owned Water Systems: Unless owned by a
HOA, or other approved non-profit corporation or water district, a community water system falls
under IPUC regulation. While having the system be unregulated may not sound ideal,
regulation by IPUC is limited to the monthly rates and hook-up fees. Water quality remains
under the jurisdiction of Idaho Department of Environmental Quality regardless of the ownership
of the water system. Under this exemption to IPUC regulation, a HOA has the flexibility to make
immediate changes to its rate structure and hook-up fees to ensure financial security, while for
an owner of a regulated system under IPUC such actions would require a formal rate case with
an uncertain result. This is the primary stated reason that Gem State decided to not complete
the purchase. If owned by the HOA, necessary changes can made more efficiently, while
keeping any increases to the minimum necessary to property operate and maintain the system.
Elimination of Risks Related to Outside Ownership: With outside for-profit ownership
comes several risks — financial failure, poor service without accountability and/or rate and fee
hikes beyond what is necessary, among others. The Idaho Club has had to deal with all of
these issues at various times over the years. While TIC has done its best to avoid or mitigate
such risks, there are simply no guarantees that future owners will. Only though HOA ownership
are these risks manageable and/or fully mitigated. Simply put, the HOA owning these strategic
assets and operating them for the collective good of the HOA members, rather than for the
financial gain of a for-profit enterprise, is the best way to maintain the property values and
financial health of the project.
Seamless Transition: I plan to personally manage the transaction with Gem State, TIC and the
lender, as well as initially manage the operator and engineers during the transition, with
oversight by the HOA Board. Given that TIC still owns the water system, and previously owned
both systems, the team for the outside management of the systems is in place: Welch Comer
Engineers (Steve Cordes) for technical system knowledge and compliance; E3 Consultants
(Jason Wereley) for licensed on-site operations; and, Kootenai Excavators (Mark Graham) for
on-site repair and maintenance work. For billing, it is anticipated that would be covered by
Panhandle Management/Tom Curtiss as part of the HOA billing process.
Proposed Acquisition Terms:
TIC sold the sewer system to Gem State for $1,388,860 and had a contract with Gem State to
sell the water system for $821,672. In addition, TIC was to receive an earn-out payment from
Gem State in January 2026 equal to a 5.5 x multiple of revenue collected for 2025 LESS the
amounts already paid ($1,388,860 + $821,672). These amounts represent a significant
discount to both the amounts TIC has invested in the systems during its period of ownership
and an even steeper discount to the actual value of the system components due to how the
legacy systems were acquired by TIC.
Thus, TIC proposes that the HOA acquire both of these systems for a total of $2,210,532 up-
front, with an earn-out amount to be calculated just as was in the Gem State agreements to be
paid in January 2026. In lieu of an earn-out in 2026, TIC would agree to a fixed total purchase
price of $2,400,000 up-front for both systems with no future earn-out payment.

i
' I
EXHIBIT D
PROPOSED INIPROVEM);NTS&ESTIMATED CONSTRUCTION COSTS
Proposed water and sewer improvements include those necessary for water supply production,
treatment,storage and distribution facilities, and wastewater collection,treatment and disposal
facilities,to initially serve 30 residential dwelling units with the ability to expand to
approximately 425 residential dwelling units.
THE IDAHO CLUB
ESTIMATED WATER&SEWER INFRASTRUCTURE COSTS
Description Amount
Acquisition of Existing Water Infrastructure $1,200,000 j
New Booster Station $400,000
Future Water Lines $400,000
Acquisition of Existing Sewer Infrastructure $1,400,000
New Lift Stations $350,000
Future Sewer Lines $400,000
Stormwater System Improvements $350,000
I
Total Costs $4,500,000
I
Source: Valiant Idaho,LLC based on engineer estimates,
i
I
PETITION FOR THE CREATION AND ORGANIZATION OF THE IDAHO CLUB WATER
AND SEWER DISTRICT-IS
EXHIBIT 02

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION ) CASE NO. GNR-W-24-01
INTO VALIANT IDAHO, INC. AND TIC )
UTILITIES, LLC, OWNERS OF A )
NORTHERN IDAHO WATER SUPPLY AND ) CERTIFICATE NO. 554
DISTRIBUTION SYSTEM )
IT IS HEREBY CERTIFIED that the Public Convenience and Necessity requires Valiant
Idaho, Inc. and its successors and assigns to hold, construct or otherwise acquire, to maintain and
to operate a water system and provide a potable water supply to customers in a development and
golf club called the Idaho Club in or near Bonner County, Idaho, more specifically:
See attached as Attachment 1 - Service Territory Legal Descriptions
See attached as Attachment 2 - Service Territory Map
This Certificate is for such purpose to own, hold, construct or otherwise acquire and to
maintain and operate within said territory water wells, reservoirs, tanks, towers, stand pipes
collectors, settling basins, galleries and other works and structures, and also to lay,take up,repair,
renew, extend, alter, maintain, and operate water mains, pipes, conduits, aqueducts hydrants and
other appliances, equipment and facilities, in, upon, over, under, along, through and across all
streets, avenues, alleys, streams, highways, roads, and other public places in said territory as the
same now exists or may hereafter be extended, laid out or established, and to exercise the rights
and privileges granted, or to which hereafter may be granted to Valiant Idaho, Inc., its successors
or assigns, by any franchise conferred by the State of Idaho or any political subdivision thereof.
This Certificate is predicated upon and issued pursuant to the findings and conclusions of
Order No. 36312 in Case No. GNR-W-24-01 to which reference is hereby made.
CERTIFICATE NO. 554 1
EXHIBIT 03

DATED at Boise, Idaho this 201h day of December 2024.
ERIC ANDERSON, PRESIDENT
1-��- ;4�
J R. HAMMOND JR., COMMISSIONER
G
EDWARD LODGE, C MISSIONER
ATTEST:
I L
�..
Ba os- a
Commission Secreta
;!5
1:\Legal\WATER\GNR-W-24-01\orders\GNRW 2401_Cert.docx
CERTIFICATE NO. 554 2

RECEIVED
Thursday, July 18, 2024 4.04.03 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
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 THE INVESTIGATION )
INTO VALIANT IDAHO,INC. AND TIC ) CASE NO. GNR-W-24-01
UTILITIES,LLC, OWNERS OF A )
NORTHERN IDAHO WATER SUPPLY AND )
DISTRIBUTION SYSTEM ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission,by and
through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following
comments.
BACKGROUND
In Order No. 36149, the Idaho Public Utilities Commission("Commission") directed
Commission Staff("Staff') to investigate whether Valiant Idaho, LLC. ("Valiant"or
"Company") and TIC Utilities, LLC ("TIC Utilities") (collectively the "Companies") are
operating as a public utility and if any steps should be taken by the Companies to comply with
Idaho law.
The Commission also directed the Companies to respond to discovery questions and
inquiries made by Staff, and notified the Companies that Staff would make a recommendation to
STAFF COMMENTS l JULY 18, 2024
EXHIBIT 04

Being unable to offer dividends or distributions to the owner is the primary indicator that the
Company is operating at cost and not for profit. Currently, the rate payers do not own the
Company, have no input into the operations of the Company, or the rates it charges for water
services. Given that the water users do not have input in the operations of the Company, or the
rates charged by the Company, water users have no other means of protection from excessive
billing other than regulation as provided for in Title 61 of the Idaho Code.
The Company has stated that they are intending to sell the water system to the HOA and
therefore would not be regulated. In the past, the Company has requested that the Commission
delay determining if the Company should be a regulated utility until it can confirm that the HOA
is willing to purchase the system. The Company stated its intention to sell in Confidential
Attachment A. However, in response to Production Request No. 3, the Company provided an
email sent to the HOA Board revoking the offer to sell the water system. See Confidential
Attachment B. The date and time of the email revoking the offer to sell is only thirteen minutes
later than the email sent to Staff assuring the Company was looking to sell and transfer the water
system to the HOA. The timing of the emails cast doubt on any promises the Company may
make for future action, whether to transfer the system to the HOA or file for regulation. Staff
does not believe this is a good reason to delay issuing a CPCN.
Issuing a CPCN does not prevent the water system from being transferred or sold. The
Commission has cancelled the CPCN of water companies in the past when they had been
transferred to an HOA, converted to a water district, or became a non-profit entity. See Case
Nos. EVG-W-12-01, MUR-W-14-01, CCH-W-15-01, and PKS-W-15-01.
STAFF RECOMMENDATION
Staff recommends the Commission issue Valiant a CPCN. Staff further recommends the
Commission order the Company to file a compliance filing and to work with Staff to submit the
following: tariffs; a notice to customers regarding regulation; full description of the location, i.e.
metes and bounds legal description; and a map in suitable scale showing the location of the
utility service. Lastly, Staff recommends the Commission open a separate docket to evaluate
whether its rates are fair,just, and reasonable.
STAFF COMMENTS 3 JULY 18, 2024

THE
IDAHO
CLUB
R :^ NED
January 22, 2019 JAN 2 8 2019
BANNER COUNTY
PLANNING DEPARTMENT
Martin Taylor, AICP cv��--V_)bCU'plP _�q
J. A. Sewell & Associates
1319 North Division Avenue
Sandpoint, ID 83864
Will Serve Water & Wastewater Service for The Idaho Club T-Lots
With this letter, TIC Utilities, LLC, an affiliate of Valiant Idaho, LLC, confirms it has
reserved capacity in our water and sewer systems for the lots to be created by a minor land
division of the area referenced as the T-Lots ("Lots"), a copy of the plat for which is attached,
and hereby states that it will serve these Lots under the following conditions:
No more than one (1) single family residence may be constructed on any of the Lots.
The sum of two thousand five hundred dollars ($2,500). for each of the Lots, will be paid
to TIC Utilities, LLC for a water hook-up fee upon connection to the water service owned and
operated by TIC Utilities. LLC.
Monthly service fees in the amount of forty-five dollars ($45) per month, for each of the
Lots. shall be paid beginning when each of the Lots are connected to the water system.
The sum of ten thousand dollars ($10,000), for each of the Lots, will be paid to TIC
Utilities. LLC for a sewer hook-up fee upon connection to the wastewater service owned and
operated by TIC Utilities. LLC.
Monthly service fees in the amount of ninety dollars (S90) per month, for each of the
Lots, shall be paid beginning when each of the Lots are connected to the wastewater system.
EXHIBIT 05

The applicable requirements of TIC Utilities, LLC for the improvements necessary on
each of the Lots for the connection to its water and wastewater treatment systems shall be
completed prior to the provision of service.
If you have any questions, please contact our Managing Member at the email or
telephone number provided below.
Regards,
TIC UTILITIES, LLC
William Haberman
Managing Member
[phone]
william.haberman @ me.com

RECEIVED
Tuesday, July 30, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Taylor R. Brooks, ISB # 11542
McConnell Wagner Sykes & Stacey PLLC
827 East Park Boulevard, Suite 201
Boise, Idaho 83712
[phone] Telephone
[phone] Fax
[e-mail]
Attorneys For Valiant Idaho, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
INVESTIGATION INTO Case No. GNR-W-24-01
VALIANT IDAHO,LLC AND
TIC UTILITIES, LLC, OWNERS OF A COMPANY COMMENT TO
NORTHERN IDAHO WATER SUPPLY ORDER NOS. 36149 AND 36254
AND DISTRIBUTION SYSTEM.
COMES NOW, Valiant Idaho, LLC ("Valiant"), by and through its attorneys of record,
McConnell Wagner Sykes& Stacey PLLC,pursuant to Rules 201-204 of the Idaho Public Utilities
Commission's Rules of Modified Procedure, IDAPA 31.01.01.201-204, Order No. 36149,
and Order No. 36254, and hereby submits its Company Reply Comments to the investigation into
Valiant's ownership of a northern Idaho water supply and distribution system opened by the
Idaho Public Utilities Commission ("IPUC").
I.
BACKGROUND
On or about April 23, 2024, IPUC noticed an investigation into Valiant through Order
No. 36149 to determine whether Valiant operates a northern Idaho water supply and distribution
Case No. GNR-W-24-01
COMPANY COMMENTS EXHIBIT 06
TO ORDER NO.36254- 1
I:\l0482.014\PLD\Company Reply Comment.docx

system and, if so, whether Valiant should be a public utility subject to IPUC regulation under
Title 61 of Idaho Code ("Investigation"). See also Idaho Code § 61-129. The Investigation stems
from Valiant's acquisition of a water supply and distribution system in and throughout
a community commonly referred to as "The Idaho Club" ("Idaho Club"). See Genesis Golf
Builders, Inc. v. Pend Oreille Bonner Development, LLC, et al., Case No. CV-2009-01810
(Idaho 1st Dist., April 2017); see also Valiant Idaho, LLC v. VP Incorporated, 164 Idaho 314,
429 P.3d 855 (2018); Valiantldaho, LLC v. JVL.L.C., 164Idaho 280, 429 P.3d 168 (2018).
In November of 2016, Valiant purchased the Idaho Club at a Sheriff's sale in
Bonner County, wherein it also acquired the Idaho Club's water system ("Water System"). Id.
Through two contentious years of litigation, many improvements and fixtures to real property,
and many capital contributions to the water system to render it operational, ownership and
authorization to operate that water system was granted to Valiant, subject to a preliminary
injunction entered in Genesis Golf Builders, supra. See Valiant's Response to Commission
Request No. 1. All relevant portions of the injunction related to the Idaho Club and/or Valiant
have been lifted or are no longer relevant.
In 2017,the IPUC began investigating the interests of Valiant, TIC Utilities,LLC ("TIC"),
and VP, Inc. ("VP") in the Idaho Club Water System. See GNR-W-17-01. However,much of this
matter was stayed due to the litigation ongoing in Genesis Golf Builders, Valiant Idaho v. VP, and
Valiant v. JV L.L.C., supra. Valiant would not have been able to comply with IPUC regulations
until the litigation over ownership of the Water System could be fully determined. In late 2022,
the First Judicial District Court in Bonner County granted Valiant enough authority to fully own
and operate the Water System, which it subsequently elected to sell to Gem State Water
Company, LLC ("Gem State"). See GSW-W-23-01.
Case No. GNR-W-24-01
COMPANY COMMENTS
TO ORDER NO.36254-2
I:\l0482.014\PLD\Company Reply Comment.docx

RECEIVED
September 03, 2025
VALIANT IDAHO, LLC IDAHO PUBLIC
TIC UTILITIES, LLC UTILITIES COMMISSION
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 ) RESPONSES TO COMMENTS
INCREASE ITS RATES AND CHARGES FOR OF COMMISSION STAFF
WATER SERVICE IN THE STATE OF IDAHO ) & PUBLIC COMMENTS
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 Comments of the Commission Staff
dated August 6, 2025 ("IPUC Staff Comments") and the public comments related to the
Company's rate case and related documentation ("Public Comments").
RESPONSES TO IPUC STAFF COMMENTS
RATE BASE - CONTRIBUTIONS IN AID OF CONSTRUCTION ("CIAC")
(ADJUSTMENT NO. 1): Company disputes that IDAPA 31.36.01 applies to Company and
its water system. IDAPA 31.36.01 reads as follows:
"101. SMALL WATER COMPANIES DEFINED (RULE 101). Small water companies
are water corporations as defined by the Public Utilities Law that:
EXHIBIT 07

RESPONSES TO PUBLIC COMMENT NO. 4 - CHRISTOPHER NORTON:
Due to the lengthy and largely inaccurate Public Comments from Christopher Norton
("Norton"), Company is compelled to address these comments separately. To address the many
duplicative claims made in Norton's public comments, Company again asserts that comments
and claims that are clearly outside the legal jurisdiction of IPUC are not applicable or relevant,
and thus should not be considered when determining Company's water rates. Notably,Norton's
comments related to the following topics should not have any bearing on this rate case and the
determination of final water rates: (1)water system capacity, condition and compliance with
IDEQ regulations; (2) third-party owned wastewater service and systems; (3) wastewater reuse;
(4) golf course operations, management or membership issues; (5) The Idaho Club HOA
operation and management; (6) legal rights of parties under The Idaho Club DCCRs; (7)
Bonner County or Idaho Code regarding the recording and requirements for plats; (8) legal
ownership structure of Company and assumed tax implications; (9) issues related to Idaho Fire
Code; (10) claims related to Norton's non-compliant connection to the water system that predate
Company's operation of the water system; and(11)wholly unsubstantiated and unproven
allegations of discriminatory pricing or retaliation against Norton.
According to the timeline in Norton's comments, he commenced construction of his
home "beginning in 2019" and completed it in"early 2020." It is hereby noted that Company
did not commence operations of the water system until September 22, 2020. Even though this is
an IDEQ issue, the water pressure claims warrant context given the unsubstantiated claims of
retaliation by Norton. Any water pressure issues existed when Norton commenced construction
and later completed his home, before the water system was owned or operated by Company.
Further, any current water pressure issues are directly related to Norton's non-compliant
connection to a 12" transmission main rather than the 3"pressurized distribution line that is
designed to service his home. This connection, deemed non-compliant by IDEQ, was made
before Company commenced operations of the water system. Thus, it is unclear to Company
whose financial responsibility it is to correct such a non-compliant connection made prior to
Company assuming operational control of the system. Company asserts that any costs related to

2110 Ironwood Parkway Brad Little,Governor
Coeur d'Alene, ID 83814 • [phone] Jess Byrne, Director
July 25, 2025
Bill Haberman, Owner
Idaho Club drinking water system
[e-mail]
Subject: Water Service and Main Line Sanitary Defects—Action Required
Dear Mr. Haberman:
Upon review of water system upgrades and water services for the Idaho Club public drinking water system, the
Idaho Department of Environmental Quality(DEQ) has determined there are sanitary defects in the drinking
water system and violations of the Idaho Rules for Public Drinking Water Systems (IDAPA 58.01.08)that require
correction. Water services are provided from a transmission main on North Star Lane with low to no pressure,
and a dead-end exists off Green Monarch without a means to flush. Idaho Club water distribution mains must
maintain at least 40 psi throughout the distribution system and at the building site for each service connection
(IDAPA 58.01.08.542.13 & 552.b.iv.). All dead-end water mains must be equipped with a means of flushing
according to rule (IDAPA 58.01.08.542.09.).
Please be reminded that the Moose Mountain Booster Station must receive authorization to serve and is
intended to provide adequate pressure in the distribution mains on Moose Mountain, and to services on North
Star Lane. Water services must not be connected to transmission mains and must be connected to distribution
mains with at least 40 psi. A means to flush all dead ends must be installed so that lines may be flushed at a
velocity of 2.5 feet per second.
Within 30 days contact DEQ, Coeur d'Alene Region, to set up a compliance conference call. Following
consultation, submit a corrective action plan with proposed actions and dates these corrections will be made
within 30 days.
I may be contacted by phone at [phone], or by email at [e-mail]. Additionally, Katy
Baker-Casile may be contacted for engineering review.
Sincerely,
Anna Moody
Drinking Water Compliance Supervisor
Ec: Jason Wereley, Designated Operator, iasondwereley@l;mail.com
Keegan Kime, Drinking Water compliance Officer—DEQ, [e-mail]
Steve Burns, Water Quality Engineering—DEQ, [e-mail]
Katy Baker-Casile, Engineering Manager— DEQ, [e-mail]
Laserfiche: ID1090297 Idaho Club
EXHIBIT 08

Photograph takeon October 20, 2025 when our • - was connected to the Idaho Club
Water Distribution Line that was filled and pressurized on 1 from ••
MountainBooster Station.
` ` Distribution Water Line Fi ::�, � ` '
i
••Ft and Pressurized on January 23, -
2025 \ -
/l� 4
,�� L, �smlssion Water Line i ��.� ..-
>
Exhibit09

RECEIVED
September 03, 2025
VALIANT IDAHO, LLC IDAHO PUBLIC
TIC UTILITIES, LLC UTILITIES COMMISSION
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 ) RESPONSES TO COMMENTS
INCREASE ITS RATES AND CHARGES FOR OF COMMISSION STAFF
WATER SERVICE IN THE STATE OF IDAHO ) & PUBLIC COMMENTS
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 Comments of the Commission Staff
dated August 6, 2025 ("IPUC Staff Comments") and the public comments related to the
Company's rate case and related documentation ("Public Comments").
RESPONSES TO IPUC STAFF COMMENTS
RATE BASE - CONTRIBUTIONS IN AID OF CONSTRUCTION ("CIAC")
(ADJUSTMENT NO. 1): Company disputes that IDAPA 31.36.01 applies to Company and
its water system. IDAPA 31.36.01 reads as follows:
"101. SMALL WATER COMPANIES DEFINED (RULE 101). Small water companies
are water corporations as defined by the Public Utilities Law that:
EXHIBIT 10

RATE OF RETURN: Company acknowledges and agrees with IPUC Staff's conclusion
as to the proposed Rate of Return.
TAXES AND NET TO GROSS MULTIPLIER: Company acknowledges and agrees
with IPUC Staff's conclusions as to the proposed Taxes and Net to Gross Multiplier.
TAX RATES: Company acknowledges and agrees with IPUC Staff's conclusion as to
the appropriate Tax Rates.
PUC ASSESSMENT: Company acknowledges and agrees with IPUC Staff's
conclusion as to the PUC Assessment.
RATE DESIGN: Company acknowledges IPUC Staff's conclusions as to the proposed
Rate Design, but reasserts that Company's proposed changes to the revenue requirement inputs
described herein be considered and permitted by the Commission. A non-flowing rate, or
standby fee, is appropriate in this case. Company has a responsibility to maintain fire
suppression and flow for all parcels within the service area, and Company incurs significant
incremental costs to build and maintain a much larger system for future flowing customers. Said
differently, standby fees strike a fair balance between Company viability and customer rate
fairness. If standby fees are not permitted, the flowing customers will be forced to subsidize
construction and maintenance costs to maintain Company viability and consequently, customer
rates will necessarily be significantly higher.
METER READING: Company acknowledges IPUC Staff's conclusion as to the
benefits of metering water usage. However, Company is concerned that initial and prospective
costs of meters are not properly recognized in the IPUC Staff's Comments, because such costs
will not be recoverable for another year after the completion of the rate case. These initial costs
also do not appear to be recoverable at all from the customers with active connections. Thus,
Company proposes that reimbursement for the actual cost to install all meters, including those
for existing active connections, be permitted under the final tariff schedule.

bd
CD
CD
0006189383 N
ryAT•SE9t STATE OF IDAHO For use only
�¢ �'`��` ^ °•� Office of the secretary of state, Phil McGrane
y c ANNUAL REPORT -FILED-
Idaho Secretary of State CD
s� ti4� PO Box 83720 File#:0006189383 4p
ATE o4 Boise, ID 83720-0080 Date Filed:4/4/2025 8:59:26 AM \
[phone] CD
Filing Fee:$0.00 p
N
CD
N
Entity Name and Mailing Address: 0_1
Entity Name: TIC UTILITIES, LLC 00
The file number of this entity on the records of the Idaho 0000544835
Secretary of State is: U'
Address 151 CLUBHOUSE WAY
SANDPOINT, ID 83864-9194
Entity Details:
Entity Status Active-Existing
(D
This entity is organized under the laws of: IDAHO n
N
If applicable,the old file number of this entity on the records of W180129 N
the Idaho Secretary of State was: C
N
The registered agent on record is:
Registered Agent RICK L STACEY
Registered Agent
Physical Address
827 EAST PARK BLVD STE 201 O
BOISE, ID 83712 rh
Mailing Address ~
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Agent or Address Change
❑ Select if you are appointing a new agent. �
Limited Liability Company Managers and Members (fi
Name Tltle Business Address
Valiant Idaho, LLC Member 310 CHARLESTON PLACE H
CELEBRATION, FL 34747
The annual report must be signed by an authorized signer of the entity. O
Job Title: Registered Agent W
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Rick L. Stacey 0410412025
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EXHIBIT 11
Page 1 of 1 Page 1 of 1

Water System Asset Purchase Agreement
This Asset Purchase Agreement(this"Agreement")is made between Gem State Water Company,LLC, an Idaho
limited liability company("Buyer"),Valiant Idaho,LLC("Seller"),TIC Utilities,LLC, an Idaho limited liability
company("Operator")and William Haberman,as managing member of Seller("Owner"),effective as of
December 9,2022(the"Signing Date"). Capitalized terms used in this Agreement are defined where they are
first used or in Schedule 1.
Seller owns water supply and distribution systems in or near Bonner County(the"Business") and operates the
Business. Seller wishes to sell, and Buyer wishes to purchase, and to assume specified liabilities, substantially all
of the assets of the Business. Seller also owns a wastewater system in or near Bonner County(the"Wastewater
Business"). The assets of the Wastewater Business will be sold pursuant to a separate Wastewater System Asset
Purchase Agreement of even date herewith(the"Wastewater Agreement"). The parties,therefore, agree as
follows.
1. Assets; Assumed Liabilities.At Closing,Buyer will buy, and Seller will sell and transfer,the assets of the
Business, including without limitation, the items listed on Schedule 2, other than the Excluded Assets
(defined below)(the"Assets").At Closing,Buyer will assume the liabilities of Seller in respect of Assigned
Contracts only to the extent required to be performed after the Closing, incurred in the ordinary course of
business,and unrelated to any failure to perform,improper performance,or other default or violation by
Seller before Closing. (the"Assumed Liabilities"). Seller and Operator jointly and severally represent and
warrant to Buyer that the statements set forth on Schedule 3 are true and correct on Signing Date and will be
true and correct on the Closing Date.
2. Excluded Assets; Excluded Liabilities. At Closing,Buyer will not buy, and Seller and Operator will not
sell, corporate seals, organizational documents,minute books, stock books, Tax Returns,books of account or
other records having to do with the corporate organization of Seller;benefit plans and assets attributable
thereto; accounts receivable; short-term investments cash and cash equivalents; and the rights that accrue to
Seller under the Transaction Documents(the"Excluded Assets"). Buyer will not assume and will not be
responsible to pay,perform or discharge any liabilities,obligations or commitments of any nature whatsoever,
asserted or unasserted,known or unknown, absolute or contingent, accrued or unaccrued,matured or
unmatured, or otherwise ("Liabilities") of Seller or any of its affiliates other than the Assumed Liabilities(the
"Excluded Liabilities").
3. Purchase Price.
a. The"Purchase Price"for the Assets is equal(w) $421,672 (the"Closing Payment")plus (x)up
$400,000 as reimbursement for reasonable and documented costs incurred by Seller and related to a green
sand filtration system plus(y)the Earnout Payment;plus (z)the assumption of the Assumed Liabilities.
At Closing,Buyer will pay the Seller$379,505 in cash by wire transfer of immediately available funds
pursuant to written instructions provided by the Seller at least five Business Days before the Closing,
subject to the adjustments set forth in Section 3(d)below. Twelve months after Closing,Buyer will pay to
Seller an amount equal to $42,167 (the"Holdback") less the amount of any claim a Buyer Indemnitee
has under this Agreement. After that date and after all claims by Buyer Indemnitees are resolved and
paid, Buyer will promptly pay the remaining Holdback,if any,to Seller.
b. The allocation of the Purchase Price among the Assets and Assumed Liabilities(plus other capitalizable
amounts)for all Tax purposes in accordance with Schedule 4. Each party will file all Tax Returns
(including Internal Revenue Service Form 8594)and information reports in a manner consistent with that
allocation.
c. Each party will bear its own costs and expenses, including of its Representatives,incurred in connection
with the transactions contemplated by this Agreement(the"Transaction") and related due diligence,
whether or not Closing occurs.
d. Buyer is entitled to adjust the Purchase Price with a decrease by the amount of all Taxes that Buyer may
be required to deduct and withhold under any applicable Tax Law. Buyer is entitled to adjust the Closing
1 of 26
EXHIBIT 12

GEM STATE WATER COMPANY, LLC VALIANT IDA110. 11C
By: By:..—
Name: Name: William Habennan
Title: Title: Managing Member _
TIC UTILITIES,LLC
By:
Name: William Haberman,owner
Title:
Communications to Buver:
Gem State Water Company, LLC
250 SW Taylor St.
Portland.Oregon 97204
Attn: Justin Palfreyman
With copies, which will not constitute notice to:
NW Natural Water Company, LLC
250 SW' Taylor St.
Portland.Oregon 97204
Attn: Darren Nakata
Email: [e-mail]
Communications to Seller,Operator and Owner:
Valiant Idaho, LLC/TIC Utilities, LLC
The Idaho Club
IS I Clubhouse W'av
Sandpoint, ID 83864
Attn: William Haberman
Email: William.Haberman(tLme.com
7 of 26

RECEIVED
September 03, 2025
VALIANT IDAHO, LLC IDAHO PUBLIC
TIC UTILITIES, LLC UTILITIES COMMISSION
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 ) RESPONSES TO COMMENTS
INCREASE ITS RATES AND CHARGES FOR OF COMMISSION STAFF
WATER SERVICE IN THE STATE OF IDAHO ) & PUBLIC COMMENTS
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 Comments of the Commission Staff
dated August 6, 2025 ("IPUC Staff Comments") and the public comments related to the
Company's rate case and related documentation ("Public Comments").
RESPONSES TO IPUC STAFF COMMENTS
RATE BASE - CONTRIBUTIONS IN AID OF CONSTRUCTION ("CIAC")
(ADJUSTMENT NO. 1): Company disputes that IDAPA 31.36.01 applies to Company and
its water system. IDAPA 31.36.01 reads as follows:
"101. SMALL WATER COMPANIES DEFINED (RULE 101). Small water companies
are water corporations as defined by the Public Utilities Law that:
EXHIBIT 13

Please direct any questions or correspondence related to these Responses at the following
address and/or phone number.
William Haberman
Manager
TIC Utilities, LLC
151 Clubhouse Way
Sandpoint, ID 83864
[phone]
whktheidahoclub.com
DATED at Sandpoint, ID, this 3rd day of September, 2025.
Respectfully submitted,
TIC UTILITIES, LLC
William Haberman
Manager

THE
IDAHCJ
TIC Utilities, LLC
The Idaho Club Water System
Management& Billing Update
September 9, 2024
The Idaho Club Property Owners:
Please be advised that TIC Utilities, LLC, the owner of The Idaho Club water system, is
changing its billing agent and updating its monthly rates, effective immediately. All previous
payments sent to Gem State Infrastructure, LLC have been or will be credited to your account.
TIC Utilities, LLC has recently established itself as a regulated water system under Idaho
Public Utility Commission ("IPUC") jurisdiction. Based on preliminary conversations with IPUC
representatives, a rate structure that includes higher rates for homes than those paid for
undeveloped lots, along with metering for excess water usage, is the billing structure preferred
by IPUC.
As a result of IPUC guidance and historical operating losses, monthly rates for improved
lots — i.e. those with homes completed or under construction — will be one hundred dollars
($100.00) per month beginning in October of 2024. Monthly rates for unimproved lots will
remain at forty-five dollars ($45.00) per month. Further changes may be required upon the
establishment of our rate base by IPUC.
The amounts for 3rd Quarter 2024 will be the last period under the previous rates and
will be due and payable, in arrears on September 30, 2024, in the total amount of forty-five
dollars ($45.00) per month. Thereafter, owners will be billed on a quarterly basis at the new
rates described above.
Further, TIC Utilities, LLC are purchasing water meters to be installed in all completed
homes. Homes under construction, and all future homes, will be required to install water meters
specified by TIC Utilities, LLC. We plan to have these installed before the end of 2024 and put
into service beginning January 1, 2025. The fixed monthly water rates will cover up to seven
thousand five hundred (7,500) gallons of water usage per month, and water usage above that
volume will be billed at an additional one cent ($0.01) per gallon.
Our engineers have identified tw7. potential sources of abnormally high water usage,
during periods when owners are not using their homes, that are causing increased operating
costs and contributing to excess wastewater to the sewer pond:
EXHIBIT 14

RECEIVED
September 03, 2025
VALIANT IDAHO, LLC IDAHO PUBLIC
TIC UTILITIES, LLC UTILITIES COMMISSION
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 ) RESPONSES TO COMMENTS
INCREASE ITS RATES AND CHARGES FOR OF COMMISSION STAFF
WATER SERVICE IN THE STATE OF IDAHO ) & PUBLIC COMMENTS
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 Comments of the Commission Staff
dated August 6, 2025 ("IPUC Staff Comments") and the public comments related to the
Company's rate case and related documentation ("Public Comments").
RESPONSES TO IPUC STAFF COMMENTS
RATE BASE - CONTRIBUTIONS IN AID OF CONSTRUCTION ("CIAC")
(ADJUSTMENT NO. 1): Company disputes that IDAPA 31.36.01 applies to Company and
its water system. IDAPA 31.36.01 reads as follows:
"101. SMALL WATER COMPANIES DEFINED (RULE 101). Small water companies
are water corporations as defined by the Public Utilities Law that:
EXHIBIT 15

the adjustment related to depreciation of Plant In Service be increased to reflect a higher Plant In
Service determination for the reasons discussed above in Rate Base - Contributions In Aid Of
Construction ("CIAC") (Adjustment No. 1).
REVENUES (ADJUSTMENT NO. 4): Company acknowledges IPUC Staff's
conclusions related to the gross potential revenue from operations. However, actual revenue is
also dependent upon the actual percentages of collections and credit loss. To date, Company has
not generated actual revenue of$165,240 in any single year of operations. Actual total revenue
for 2024 was $128,039. Actual total revenue for 1 st and 2nd Quarter of 2025 was $64,323.
Thus, Company proposes that the revenue adjustment reflect actual revenue collected and not
hypothetical gross potential revenue. Thus, Company requests that the revenue calculations be
based on actual revenue for 2024 and the first half of 2025.
EXPENSE ADJUSTMENTS -PUC FEES ADJUSTMENT (ADJUSTMENT NO. 5):
Company acknowledges and agrees with IPUC Staff's conclusions as to PUC Fees Adjustment.
EXPENSE ADJUSTMENTS - SALARY ADJUSTMENT(ADJUSTMENT NO. 6):
Company disagrees with IPUC Staff as to its methodology and conclusions regarding the
appropriate salary for a professional manager. The manager is responsible for profit& loss,
management of professional engineers and attorneys,planning and financing of capital
improvements, legal and regulatory compliance, billing and customer service, and tax matters,
among other responsibilities. First, using general data from the US Bureau of Labor Statistics for
the generic title of"Manager" is flawed because it does not distinguish between Managers based
on job responsibilities, industry, geographic region, current labor market conditions or
credentials, among other criteria—all which are critical to salary determinations. At a minimum,
IPUC should have relevant data on the management salaries for similarly sized water systems in
Idaho and need not rely upon general national data that is inherently flawed. For perspective,
Company pays nearly $38,000 per year for a full-time equivalent Grill Cook, when including
hourly wages and payroll taxes and assuming a 35-hour work week. Such a position obviously is
not responsible for any of the management functions described above. For Company's other

management positions—General Manager,Assistant General Manager, Food& Beverage
Manager and Ground Maintenance Manager—none earn less than $75,000 per year with the
General Manager and Assistant General Manager earning over$100,000 per year. In fact,
Company does not have any full-time equivalent employees that work year around who earn less
than the proposed salary expense. As a result, Company reasserts that the proposed salary of
$48,000 is appropriate for the level of expertise required and job responsibilities.
EXPENSE ADJUSTMENTS -E3 CONSULTING EXPENSES
RECLASSIFICATION (ADJUSTMENT NO. 7): Company acknowledges and agrees with
IPUC Staff's conclusions as to the proposed E3 Consulting Expenses Reclassification.
EXPENSE ADJUSTMENTS -E3 WASTEWATER EXPENSES (ADJUSTMENT
NO. 8): Company acknowledges and agrees with IPUC Staff's conclusions as to the E3
Wastewater Expenses.
EXPENSE ADJUSTMENTS - SEWER EXPENSES FROM PRODUCTION
REQUEST NO. 34 (ADJUSTMENT NO. 9): Company acknowledges and agrees with IPUC
Staff's conclusions as to the Sewer Expenses inadvertently included.
EXPENSE ADJUSTMENTS - CHEMICAL ADJUSTMENT (ADJUSTMENT NO.
10): Company disagrees with IPUC Staff's conclusions and suggested adjustment for chemicals.
Company saw significant growth in the number of active connections in the last eighteen(18)
months. Company also introduced an ATEC filtration system in 2023, which greatly increased
the efficiency and operational quality of the water system,but also greatly increased the chemical
requirements. It is inaccurate for IPUC Staff to give any weight in its calculations to include
2021,because Company had just recently commenced operations, was not operating the ATEC
filtration system and had many fewer active connections. Including 2021 skews the chemical
costs below the actual costs incurred in 2023, 2024 and the monthly average in 2025. Thus,
Company proposes that the actual costs from 2024, the most recent full year of operations, or the
actual costs from the first half of 2025 grossed up for a full year,be used. Those calculations

Wood's Crushing & Hauling, Inc.
933 Woodside Road Invoice
Sandpoint, Idaho 83864
Date Invoice#
208-263-4800
8/9/2021 39255
Bill To
Valiant Idaho,LLC
Bill Haberman
216 Clubhouse Drive
Sandpoint, Idaho 83864
P.O. No. Terms
19062 Net 30
Quantity U/M Description Rate Amount
IDAHO CLUB ROCK AND PAVING 2019
1 LS Mobilization 1,500.00 1,500.00
80 Tons Place and Compact 3/4" Minus 22.50 1,800.00
380 Tons Place and Compact 2" Hot Mix Asphalt 79.00 30,020.00
Sales Tax 6.00% 0.00
THANK YOU !!
Total $33,320.00
UNPAID BALANCE OVER 30 DAYS SUBJECT TO A CHARGE OF 1%PER MONTH payments/Credits $o.00
WHICH IS AN ANNUAL RATE OF 12%.
IF PAYING BY CREDIT CARD A FEE OF 3%WILL BE ADDED.
Balance Due $33,320.00
EXHIBIT 16

Page 1 of 2
A ll Monthly Statement
1,04r VIST'A Valiant Idaho LLC
$645.06 Jun 13, 2023
myavista.com Account Number: 0580783226 (Applies to new charges only)
1 [phone] Statement Date:05/24/2023
Service Address: HIDDEN LAKES DR-MAIN
Bill at a Glance ENTRANCE Your Message Center
Previous Balance Due $465.85
Payment Received on 05/15/2023-Thank you. -465.85
Subtotal 0.00
New Charge(s)
Electric 645.06
Total Amount Due This Month $645.06
Due Date (Applies to new charges only): Jun 13, 2023
A late fee of 1%will be added to past due
balances over$50.
Contact Us
Customer Service: 1 [phone] TTY Service-Our service numbers
Monday through Friday 7 a.m.to 7 p.m. for the hearing impaired are:
Saturday 9 a.m.to 5 p.m. Idaho. . . .7-1-1 or 1 [phone]
After Hours Emergencies: 1 [phone]
Send payments only to: Send correspondence to:
Avista Avista Customer Service MSC-34
1411 E. Mission Ave. PO Box 3727
Spokane WA 99252-0001 Spokane WA 99220-3727
website: myavista.com e-mail:[e-mail]
♦ Please detach and return the bottom portion with your payment.
TRA3-D-0 0 01 34021 50 6 vG2HJ4 St-ET-Mi-000001 12
-
Account Number: 0580783226
/IIw_ _
i'driffSTA 'Total Amount Due $645.06
Due Date(Applies to new charges only): Jun 13, 2023
1411 E.Mission Ave.
Spokane WA 99252-0001 Project Share Contribution ❑$2 ❑$5 ❑$10 ❑Other
(Add to Total Amount Due)
Please check here and fill out reverse if you would
like to establish Automatic Payment Service(APS). Amount
10 NOT PAY
Enclosed
llll'lll'II'llll'I'I'llll'I'I"'I'll'lllll"Illllll'll'llllllllll Your payment will be withdrawn by the next
business day after your due date.
000134 2 MB 0.528 010395/000134/021506 002 002 VG2HJ4
VALIANT IDAHO LLC
310 CHARLESTON PL I.I..Illllllllll�lll'I.I.IIII"II'lll'llllll'll'lllllll'lllllllll
CELEBRATION FL 34747-5063 AVISTA
1411 E MISSION AVE.
SPOKANE WA 99252-0001
058078322650000046585000006450600000645066

Page 1 of 3
Ali Monthly Statement
A ifVASTAM TIC UTILITIES LLC
� .
$1,032.30 Jul 13, 2022
myavista.com Account Number:4933852603 (Applies to new charges only)
1 [phone] Statement Date:06/23/2022
Service Address:000 IDAHO CLUB DR
Bill at a Glance Your Message Center
Previous Balance Due $991.93
Payment Received on 06/13/2022-Thank you. -991.93
Subtotal 0.00
New Charge(s)
Electric 1,032.30
Total Amount Due This Month $1,032.30
Due Date (Applies to new charges only): Jul 13, 2022
A late fee of 1%will be added to past due
balances over$50.
Contact Us
Customer Service: 1 [phone] TTY Service-Our service numbers
Monday through Friday 7 a.m.to 7 p.m. for the hearing impaired are:
Saturday 9 a.m.to 5 p.m. Idaho. . . .7-1-1 or 1 [phone]
After Hours Emergencies: 1 [phone]
Send payments only to: Send correspondence to:
Avista Avista Customer Service MSC-34
1411 E. Mission Ave. PO Box 3727
Spokane WA 99252-0001 Spokane WA 99220-3727
website: myavista.com e-mail:[e-mail]
♦ Please detach and return the bottom portion with your payment.
TRA3-D-000000/008214 V1 BQW
Account Number:4933852603
/IIw_ _
�u1Vfsra kojotal Amount Due $1,032.30
Due Date(Applies to new charges only): Jul 13, 2022
1411 E.Mission Ave.
Spokane WA 99252-0001 Project Share Contribution ❑$2 ❑$5 ❑$10 ❑Other
(Add to Total Amount Due)
Please check here and fill out reverse if you would
like to establish Automatic Payment Service(APS). Amount
10 NOT PAY
Enclosed
003971/000000/008214 000 003 V1 BQW Your payment will be withdrawn by the next
TIC UTILITIES LLC business day after your due date.
[e-mail]
AVISTA
9.1 1411 E MISSION AVE.
SPOKANE WA 99252-0001
493385260380000099193000010323000001032300

j
A T E C Invoice
� SYSTEMS ASSOCIATES
P.O.Box 10329 DATE INVOICE No.
Seattle,WA 98110-0329
10/27/2022 2244
SHIP TO
BILL TO
TIC Utilities, LLC
Attn: William Haberman, Manager
151 Clubhouse Way
Sandpoint, ID 83864
P.O.NUMBER TERMS REP SHIP DATE VIA F.O.B. PROJECT
Letter Prop... Net 30 10/27/2022 C &A Truc... Hollister, CA Fe/Mn Removal
QUANTITY ITEM DESCRIPTION UNIT PRICE AMOUNT
1 48-60-06 ATEC Model 48-60-03 Iron and 151,566.00 151,566.00
Manganese Removal System,
Complete
1 Freight Freight from Hollister, CA to 5,500.00 5,500.00T
Sandpoint, ID
1 Customer De... Customer Deposit, Received -20,000.00 -20,000.00T
10/19/2022
Out-of-state sale, exempt from sales 0.00% 0.00
tax
Total $137,066.00
FEIN: 91-1918395 Telephone: [phone]
UBI: 601-839-692 Facsimile: 360-397-0375

Advanced Dirt Works
and Development, 07.20.2021 Invoice # 11
L.L.C.
Bill To: June 16,2021 through July 20,2021
Bill Haberman Idaho Club Booster Site 1
Idaho Club Item Number Description Price Quantity Amount
407-973-7875 ADW 325 Excavator 158 136.5 21567
ADW 305.5 Mini Ex 100 69.5 6950
ADW Pipe Truck and Tools 170 20 3400
ADW Dump Truck-Hauling 110 13.5 1485
Woods 3/4 inch minus-grade 10 112 1120
rock
ADW Water Truck 100 4 400
ADW Compaction 100 16.75 1675
Ship To: Equipment
Bill Haberman J.A.Sewell Compaction Testing 87.5 4 350
Idaho Club Kootenai Rock Hammer 1000 1 1000
Excavators
407-973-7875 ADW Pipe Layer 55 281.5 15482.5
ADW Foreman 53 60 3180
Consolidated Conduit-Misc. Parts 8091.96 1 8091.96
Supply
0
0
Total items: 12 Subtotal $ 64,701.46
Sales Tax Rate: 0.0% Sales Tax $ -
Less Deposit Received $ -
Make all checks payable to: Invoice Total $ 64,701.46
Advanced Dirt Works and
Development, L.L.C. Due Upon Receipt
If you have any questions Thank you for your business!
concerning this invoice,
contact:
Harvey Rutherford 208-290-6779 Advanced Dirt Works and Development, L.L.C.
[e-mail] Mailing: 931 Woodland Drive Physical: 1437 Jewel Lake Road
Sandpoint, Idaho 83864 Sagle, Idaho 83860

PRES77�0E Invoice
Worldwide Technologies,ILC.
PO Box 1738 DATE 07/29/2021
.........................................................................................................................
Mount Pleasant, TX 75456 INVOICE# 1026
[phone]
[e-mail] TERMS Cash On Delivery
BILL TO SERVICE LOCATION
Idaho Club Idaho Club
[phone] [phone]
JOB# DATE PO/REF# DESCRIPTION
58313367 07/27/2021 jason wereley
Completion Notes:
Job Charges Qty Rate Total
6" 100-01 Hytrol Main Valve Repair Kit 2.00 $331.10 $662.20
CRD Repair Kit CP 15 3.00 $160.00 $480.00
CRL Repair Kit CP16 3.00 $170.00 $510.00
Restriction Fitting 3.00 $57.00 $171.00
Belleville Washer 3.00 $25.00 $75.00
Y Strainer 3.00 $60.00 $180.00
1/4" Ball Valve 9.00 $29.95 $269.55
Quick Disconnect Fittings 15.00 $19.55 $293.25
Plastic Tubing 3.00 $17.25 $51.75
Misc SST Fittings 24.00 $5.00 $120.00
2" 100-01 Hytrol Main Valve Repair Kit 1.00 $137.50 $137.50
Labor 2 5.50 $300.00 $1,650.00
Job Subtotal $4,600.25
Job Total $4,600.25
PRE-WORK SIGNATURE POST-WORK SIGNATURE
Signed By: Signed By:
CUSTOMER MESSAGE Invoice Total: $4,600.25
Deposits (-): $0.00
Payments (-): $0.00
Total Due: $4,600.25
1

RECEIVED
March 4, 2025
Idaho Public
TIC UTILITIES,LLC Utilities Commission
151 CLUBHOUSE WAY
SANDPOINT, ID 83864 Case No.: VID-W-25-02
[phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
TIC UTILITIES,LLC FOR AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR CASE NO. GNR-W-24-01
WATER SERVICE IN THE STATE OF IDAHO )
1
COMES NOW TIC Utilities, LLC, hereinafter referred to as "Applicant" and holder of
Certificate of Public Convenience and Necessity No. 554 from the Idaho Public Utilities
Commission,hereby applies to the Commission for authorization to increase its rates and charges
for water service.
Applicant is an Idaho Limited Liability Company and provides water service to 317
residential customers in or about the city of Sandpoint in Bonner County, Idaho. Attached to this
Application is a current map of the service area showing the location of wells, reservoirs,
transmission mains and distribution lines. Also attached is a written legal description defining
the boundaries of the service area.
Application is made to the Commission to authorize a general increase in water rates as
follows:
Increase flat rate unmetered residential rates from $45.00 per month for individual
residences and improved residential lots, to $150.00 per month for individual residences and
$45.00 per month for improved residential lots. Increase metered residential rates from$0.00
per month to $0.01 per gallon for all consumption in excess of 7,500 gallons per month.
Applicant requests that such changes in rates and charges be effective on July 1, 2025.
Applicant hereby certifies that it shall notify its customers of the Application by regular
mail sent on March 4, 2025. A similar notice has been published in Bonner County Bee
newspaper beginning on March 4, 2025. Copies of these notices are included with this
Application.
EXHIBIT 17