20260213Reply Comments.pdf

VALIANT IDAHO, LLC RECEIVED
TIC UTILITIES, LLC FEBRUARY 13, 2026
151 CLUBHOUSE WAY IDAHO PUBLIC
SANDPOINT, ID 83864 UTILITIES COMMISSION
[phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. VID-W-25-02
IN THE MATTER OF THE APPLICATION OF )
TIC UTILITIES,LLC FOR AUTHORITY TO ) ORDER NO. 36818
INCREASE ITS RATES AND CHARGES FOR )
WATER SERVICE IN THE STATE OF IDAHO ) RESPONSE TO COMMENTS
OF COMMISSION STAFF
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 responding to Comments of the Commission Staff
("Comments of Staff') regarding Company's Request for Reconsideration of the Final Order No.
36818 dated November 3, 2025 ("Final Order").
RESPONSE TO COMMENTS OF COMMISSION STAFF
Company hereby responds to certain Comments of the Staff dated February 9, 2026.
Company reasserts it claims in its Request for Reconsideration, and also requests that IPUC
consider Company's supplemental responses herein to Comments of the Staff for the reasons
stated below.
REVENUE NORMALIZATION: Company disputes that it failed to provide evidence
of its actual revenue collected as Company provided financial statements for each of the full
years of operation—2022, 2023, 2024 and nine months of 2025 —prepared by an independent

Certified Public Accountant. As those financial statements plainly show, Company has not
collected $165,240 in revenue in any of the three full years of operation, nor will Company do so
based on the preliminary totals for 2025. Company hereby reasserts that this discrepancy
between actual revenue collected and potential revenue is primarily due to credit loss, as
Company has no practical legal means to force compliance without a lien right or the option to
terminate service. Staff claims that it is unable to calculate a reasonable bad debt percentage, in
spite of the fact, Company has provided its actual revenue collected and Staff has determined the
potential income from operations. The difference between the two represents the historical bad
debt. As for collection practices, it is not financially feasible to pursue small dollar
denominations through the legal system, in particular in the absence of lien rights or a
meaningful remedy of termination of service to non-flowing customers. Further, during the
approximately two year process of first obtaining the CPCN and later completing the Rate Case,
it was our understanding that Company was prohibited from making any changes to its rates or
billing practices. As a result, Company reasserts that the actual revenue collected should be
considered over a hypothetical potential revenue calculation that has not, and will not, reflect the
financial realities of the operations.
SALARY ADJUSTMENT: Company hereby reasserts its claims related to Expense
Adjustments - Salary Adjustment(Adjustment No. 6) in its Responses to Comments of
Commission Staff& Public Comments dated September 3, 2025. Further, while the owner of the
Company estimated an average of 12.5 hours per week historically dedicated to Company
management, that was during a period in which Company was not regulated by IPUC; not
required to participate in the CPCN, Rate Case, and other regulatory processes; and, not required
to maintain the Office Hours (16 hours per week), Business Hours (40 hours per week) and/or
After Hours schedule specified in Schedule 1 of the IPUC Tariff Schedule. Thus, Company
reasserts that a competent, qualified manager or management team could not be employed under
current labor market conditions in North Idaho for the gross amount of$30,000 per year,
including all payroll taxes and costs, that could perform all of the duties required to successfully
operate the Company under IPUC regulation. While Staff disputes this, it continues to base its

conclusions on national averages for the generic title of"Manager,All Other" from the U. S.
Bureau of Labor Statistics, rather than actual management expense data from the private water
companies in Idaho, the relevant the trade area, that IPUC actually regulates and audits. For
these reasons, Company reasserts that the methodology and data used result in an inherently
flawed conclusion, and an allowable salary reimbursement that is grossly understated.
CHEMICAL ADJUSTMENT: Company reasserts that the actual expenses for 2024
equal to $11,435, adjusted for inflation, would more accurately reflect Company's actual
Chemical expenses going forward. There is simply no reasonable justification to assume that
Chemical expenses will be less than the actual expenses for 2024, given the increasing variable
costs of operating the additional equipment, increasing water production volumes, and any
reasonable estimate of inflation. Company agrees with Staff's recommendation to include all of
the costs of Chemicals, including additional overhead, transportation, mileage, administration
and processing fees actually paid by Company to its operator for Chemicals. However,
Company disputes that costs from 2023, which are now two years dated, should be averaged into
this final calculation given that Company's actual costs have increased each year, as evidenced
by a significant increase from 2023 to 2024, and there is no empirical evidence or reason to
believe that costs for Chemicals have or will decrease under otherwise inflationary conditions.
WATER TESTING ADJUSTMENT: As with Chemical expenses, Company's Water
Testing expenses have increased each year due to the addition of the chlorination system,
addition of the ATEC iron filtration system, and the increase in active connections due to new
home construction. The actual expenses for Water Testing are clearly supported by actual
invoices showing increases in these expenses. Staff refers to "the cyclical nature of DEQ testing
requirements"to justify the use of a three year average and other hypothetical adjustments that
are not supported by the actual expenses incurred by Company in the most recent, and thus most
relevant, test year. These assumptions result in a proposed expense reimbursement that is
substantially lower than Company's actual expenses in 2024 and even lower still than the trailing
12 months through October 2025. Again, Company asserts that the actual expenses for 2024,

adjusted for inflation, would more accurately reflect the actual Water Testing expenses going
forward.
CUSTOMER COMMENTS AND HEARING: Company hereby disputes and denies
the wholly unsubstantiated claims that Company retaliated against any customers for simply
participating in IPUC's public comment process. The Company-affiliated business referenced is
a private golf club to which membership is a privilege and not a right. There are certain criteria.
requirements and expectations to remain a member in good standing, none of which restrict or
prohibit the exercise of rights to submit public comments in official proceedings. To specifically
correct the record, it is alleged that the Company affiliate terminated two memberships as a result
of participation in the IPUC public comment process. As of August 14, 2025, the date of the
customer hearing referenced, the Company affiliate had terminated only one membership,for
any reason whatsoever, in June of 2024, before the Rate Case was initiated and thus before any
public comments were proffered. To state the obvious, Company could not have retaliated for
public comments that had not yet been made. The claims on or before August 14, 2025 that a
second membership had also been terminated are patently false. A second membership has been
terminated in January 2026, for business reasons other than participation in the Rate Case and the
public comment process, and was done well after the Final Decision of the Rate Case. As of the
date hereof, there have not been any other memberships terminated for any reason whatsoever.
Thus, Company asserts that these claims are meritless, intentionally misleading and
unsubstantiated, and is fully prepared to defend against such claims, if necessary.
Company respectfully requests that this Response to Staff Comments be considered when
IPUC reaches its final conclusion regarding the Reconsideration of the Final Order in this matter.

Please direct any questions or correspondence related to these Responses to Staff
Comments, or any other filings by Company in this matter, to the following address and/or phone
number.
William Haberman
Manager
TIC Utilities, LLC
151 Clubhouse Way
Sandpoint, ID 83864
[phone]
whgtheidahoclub.com
DATED, this 13th day of February, 2026.
Respectfully submitted,
TIC UTILITIES, LLC
William Haberman
Manager