20260225Comments_1.pdf

Name: DAVID FROHNEN
Submission Time: Feb 25 2026 10:58AM
Email: [e-mail]
Telephone: [phone]
Address: 545 Green Monarch Lane
SANDPOINT, ID 83864
Name of Utility Company: Valiant Idaho, TIC Utilities
Case ID: VID-W-25-02
Comment: "Revenue Normalization:
There appears to be an major oversight in accounting for lost revenue in the current
General Rate Case. Applicant continues to argue for adjustments to rates based on
incomplete and erroneous analysis of accounting for revenue. The Applicant continues to
offer a significant number of monthly service charge waivers to select/preferred
customers. Nowhere in the public record is there any accounting for these waivers. While
these waivers appear to represent a contractual obligation of the Applicant's Real
Estate/Land Development Division -they are not an obligation of the regulated Water
Company and rate payers should not subsidize them..
The Applicant's tariffs do not allow for waivers. Yet, they could represent approximately
15% of the PUC authorized revenue requirement($28,080/year). The Applicant's practice
has been to offer these waivers as sales incentives for its Real Estate/Land Development
Division. The accounting for these waivers is simply a "no bill" the customer on the Water
Company's books. Without access to the connection and billing records, we relied on
public records and personal knowledge to estimate the number of waivers still in place.
Tabulated here:
- GTE Add. 10 (Oxbow Subdivision) 13
- Ironwood Addition 3
-Jim Brown Way 5
-Timber Grove Lots 6
-Valiant- Owned by RE Division 10
-Valiant- Sold and Vacant 15
The estimated total waivers are 52 at$45/month -that amounts to $28,080 per year.
Requests:
1. In the current GRC. Deny any rate adjustments for"revenue normalization".
1

2. Order Applicant to properly account for and report on the waiver obligations of the Real
Estate Division and its subsequent impact to the books of the Water Company and insure
that rate payers are not subsidizing the waivers offered by the Real Estate Division.
Thank you for the consideration.
2