20260423Staff Comments.pdf

RECEIVED
April 23, 2026
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11560
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION )
INTO MEADOWS WATER, LLC'S RATES ) CASE NO. MWL-W-25-01
AND CHARGES FOR SERVICE )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On May 8, 2025, the Commission issued an order granting Meadows Water, LLC
("Company") a Certificate of Public Convenience and Necessity ("CPCN"). Order No. 36595.
The Commission also directed Staff to open a separate docket to evaluate whether the Company's
interim rates are fair,just, and reasonable.
Case No. MWL-W-25-01 was opened on October 1, 2025, to investigate the rates and
charges of the Company.
STAFF ANALYSIS
Staff performed an audit of the Company's operating expenses and plant-in-service for the
12-month period ending December 31,2024,to evaluate whether its current revenues are adequate
to support safe and reliable service while providing an appropriate return on investments. As part
STAFF COMMENTS 1 APRIL 22, 2026

of its analysis, Staff reviewed the Company's system description, revenues, rate design, non-
recurring charges, and overall system reliability. Based on its investigation, Staff believes that the
Company's current rates generate revenues in excess of those necessary to recover prudently
incurred costs associated with providing safe and reliable service. Staff also identified operational
concerns related to system reliability that warrant continued monitoring and corrective action.
System Description
The Company owns and operates a water system serving 214 customers in the Meadows
at West Mountain subdivision in Valley County, Idaho. Response to Staff s Production Request
No. 6. The system currently consists of two groundwater wells, two bladdered pressure tanks,
treatment systems with chlorine and polyphosphate, and a distribution system, as recorded in the
sanitary survey by the Idaho Department of Environmental Quality("IDEQ") in 2022.
Revenue at Present Rates
For the 12-month test period ending December 31, 2024, the Company reported total
revenues of$146,663, consisting primarily of residential sales charged at a monthly flat rate of
$55.00. In Order No. 36595 the Commission directed the Company to maintain its current rate of
$57.00 per residential customer, until Staff could evaluate whether the rates are fair, just, and
reasonable. In addition to residential customers, the Company serves a Homeowners Association
("HOA") common area and charges $500 per month for service provided from May through
September.
Using the Company's current rates, Staff calculated revenues of$148,376 and increased
reported 2024 revenues by $1,713 to reflect the Commission-authorized rate.
Revenue Requirement
The Company reported revenues of$146,663 during the 2024 test year.Using present rates,
Staff calculated revenues of $148,376. After applying the adjustments described below, Staff
calculates a revenue requirement of$133,502, which is $14,874 lower than revenues generated
under present rates. Staff s calculated revenue requirement is approximately 10 percent lower than
revenues generated under present rates, indicating an over-recovery that warrants a reduction in
rates. Without an adjustment to rates, the Company will continue to collect revenues in excess of
STAFF COMMENTS 2 APRIL 22, 2026

those necessary to recover prudently incurred costs and provide an appropriate return on
investment. Each component is discussed in greater detail below and calculations are included as
Attachment A.
Rate Base
Rate base represents the Company's investment in utility plant that is used and useful in
providing service and is eligible to earn a return. Rate base consists of plant-in-service ("PIS")
and working capital, offset by accumulated depreciation and any contributions in aid of
construction or contributed capital. Staff calculated a net rate base of$300,214, consisting of net
PIS of$288,453 and working capital of$11,761. The calculations are included as Attachment B.
Plant In Service
The Company has made capital investments in its water system dating back to 2005,
primarily consisting of well-house and well-system improvements completed in 2005 and 2006.
More recently, in 2021, the Company recorded a generator rebuild as a plant-in-service addition.
Based on discussions with the Company, Staff learned that the generator was taken to an offsite
facility in 2021 to modify the fuel source required for its operation. Although the generator was
subsequently returned to the water system, it was never connected or placed into service and is not
currently used to provide service to customers.
The Commission has consistently held that plant must be used and useful in providing
utility service to be included in rates. Because the generator has not been placed in service and
does not provide any current benefit to customers, Staff removed the generator rebuild cost of
$31,418 from plant in service, along with its associated accumulated depreciation of $26,247.
Attachment B.
Accumulated Depreciation
Accumulated depreciation represents the total amount of depreciation expense recorded
against utility assets since the assets were placed in service. The Company reported accumulated
depreciation of$198,266. Staff excluded $26,247 related to the generator rebuild, resulting in an
adjusted balance of $172,019. Staff also reviewed the Company's depreciation rates and
STAFF COMMENTS 3 APRIL 22, 2026

methodology and recalculated accumulated depreciation, finding the results reasonable and
consistent with standard regulatory practices. Attachment B.
Working Capital
Working capital represents the amount of funds necessary to support the Company's day-
to-day operations prior to being paid for services rendered, and is a component of rate base. Staff
calculated a working capital allowance of$11,761 using the one-eighth method applied to adjusted
operating expenses. Attachment B.
Rate of Return
The rate of return ("ROR") represents the overall return a utility is allowed to earn on its
invested capital. The Company has no authorized debt; therefore, the return on equity ("ROE")
represents the Company's overall ROR. Consistent with recent general rate cases for similarly
situated small water utilities, Staff based its revenue requirement on an ROE of 11%. See Order
Nos. 35973, 35978 and 36012.
Operating Expenses
For the test year ending December 31, 2024, the Company reported total operating
expenses of $265,247, including purchased power, chemical expenses, cost of goods sold
("COGS"), contracted services, and other general operating expenses. Staff conducted a detailed
review of the Company's test year expenses and made adjustments to reflect reasonable and
prudent costs. Based on its review, Staff calculated total adjusted operating expenses of$104,298,
which reflects expenses that Staff believes to be reasonable and prudent for its analysis. Staff s
calculated operating expense is a decrease of$162,662 from the Company's reported amounts.
Attachment B.
Staff notes that COGS is not a standard account classification used in National Association
of Regulatory Utility Commissioners ("NARUC") Uniform System of Accounts ("USoA"). The
Company recorded certain expenses,including chemical costs and water testing,within this COGS
account. In a future general rate case, these expenses should be reclassified to their appropriate
functional accounts in accordance with the NARUC USoA and regulatory accounting practices.
STAFF COMMENTS 4 APRIL 22, 2026

Each expense category and corresponding adjustment is discussed below. The absence of
discussion for a particular expense does not indicate Staff's acceptance of that expense in future
proceedings.
Power Expenses
Staff estimated purchased power expense of$16,781. This estimate is based on power
consumption per gallon of pumped water using three years of historical data from 2023 through
2025. This method normalizes expenses based on system usage and provides a reasonable estimate
for ratemaking purposes. Staff encourages the Company to use the calculation method in
Attachment C to calculate purchased power expense when the Company files its next general rate
case.
Chemical Expenses
Staff calculated $5,809 of normalized chemical expense based on three years of chemical
invoices and the actual amount of water pumped from 2023 through 2025. This approach aligns
chemical costs with system usage and removes variability in annual expenses. Staff s calculations
are included in Attachment D to these comments. Staff also encourages the Company to use this
methodology in future filings to ensure chemical expense are aligned with system usage.
Staff believes that the absence of auto-proportioning chlorinators may result in excessive
chlorine usage. Staffs review indicates chlorine injection per unit of water is higher in the
Company's water system than in comparable systems, which may increase chemical costs.
Excessive chlorine can inflate chemical expense. Installation of auto-proportioning chlorinators
may reduce these costs.
Contract Services—Professional
Contract Services — Professional Fees represent payments for specialized services
performed by third-party providers. During the 12-month test period ending December 2024, the
Company reported $178,152 in professional fees. These expenses primarily included costs for
bookkeeping, engineering, water testing, and legal services.
Total bookkeeping expense for the test year was $1,626. The Company contracts with
Olsen Hendricks CPA to provide bookkeeping services. Staff notes that Reid Olsen, of Olsen
STAFF COMMENTS 5 APRIL 22, 2026

Hendricks CPA, is also an affiliate owner of Meadows Water. As such, this arrangement
constitutes an affiliated transaction.
To ensure that charges were reasonable and did not exceed market-based rates Staff
reviewed supporting documents and evaluated the nature and frequency of services provided.
Given the relatively small dollar amount, limited scope of services, and consistency with typical
bookkeeping costs for a utility of similar size, Staff believes these charges reasonable and
appropriately included in operating expenses.
Total legal expenses recorded in the Company's books for the test year were $153,826,
representing approximately 68% of total Contract Service Expenses. During the audit, Staff
reviewed all legal invoices for 2024 and requested a narrative describing the nature of the legal
dispute between Meadows Water and the HOA; however, the Company did not provide the
requested narrative.
In a general rate case, Staff would recommend an adjustment to remove legal expenses
from rates so that customers would not bear legal expenses arising from a dispute between the
Company and its customers, who have raised concerns regarding the Company's operations.
Allowing recovery of these costs would require customers to bear the financial burden of both
sides of the dispute. Accordingly, Staff excluded all legal fees from the revenue requirement.
Attachment B.
Insurance
During Staff's onsite audit,the Company provided documentation supporting its insurance
premiums for the water system. Staff reviewed the documentation and believes the insurance
expense reasonable for inclusion in the revenue requirement. Thus, Staff included an additional
$3,778 for insurance expense in the test year.
Miscellaneous
The Company recorded $1,784 in miscellaneous expenses during the test year, consisting
solely of recurring monthly internet service charges. Staff reviewed these costs and believes them
to be routine and necessary for the Company's day-to-day operations and administrative functions.
Accordingly, Staff considers these expenses to be reasonable and appropriate for inclusion in the
revenue requirement.
STAFF COMMENTS 6 APRIL 22, 2026

Depreciation Expense
Depreciation Expense represents the allocation of utility plant investments over their
estimated useful lives, reflecting how those assets are used over time to provide service to
customers. The Company calculates depreciation using the straight-line method, which allocates
asset costs evenly over the service lives.
For the 12-month test period ending December 2024, the Company recorded depreciation
expense of$10,685 based on plant in service of$491,890 and applicable depreciation rates. Staff
reviewed the Company's depreciation calculations, including plant balances, applied rates, and
service life assumptions, and concludes the methodology consistent with standard regulatory
practices.
However,because the generator rebuild was excluded from plant in service, Staff removed
the associated depreciation expense of $4,488, resulting in an adjusted depreciation expense of
$6,197. Attachment B.
Fines and Penalties
Regulatory Fines and Penalties reflect charges incurred by the Company as a result of
enforcement actions taken by the IDEQ for non-compliance with applicable requirements. For the
12-month test period ending December 2024,the Company reported$5,800 in this category. Staff
reviewed these costs and believes they consist of fines and penalties assessed by IDEQ. Fines and
penalties are not considered prudent operating expenses and are not recoverable in rates.
Accordingly, Staff excluded$5,800 from the revenue requirement. Attachment B.
Rate Design
The Company utilizes a flat-rate structure under which customers are billed a fixed monthly
charge regardless of usage. While common for small systems,this structure does not reflect usage-
based cost recovery. During 2024,the Company charged residential customers a monthly flat rate
of $55.00, which increased to $57.00 in 2025, pursuant to Commission approved rates. The
Company's current rate of $57.00 generates revenue in excess of those necessary to recover
prudently incurred operating expenses included in Staffs calculated revenue requirement. Absent
a reduction to rates, the Company will continue to collect revenues in excess of those necessary to
STAFF COMMENTS 7 APRIL 22, 2026

provide safe and reliable service at just and reasonable rates. Accordingly, Staff does not believe
the currently charged rate of$57.00 is fair,just, and reasonable and recommends the Commission
order the Company to file a general rate case to reduce rates and align revenues with Staff s
calculated revenue requirement.
In addition to residential customers, the Company serves an HOA common area account,
which is billed a fixed fee of$500 during the months of May through September. The Company's
rate design does not include a volumetric component and relies entirely on fixed charges to recover
costs from both residential customers and the HOA account.
Non-Recurring Charges
Non-recurring charges are one-time fees assessed to recover costs caused by individual
customer actions, such as returned payments, reconnections, or new service requests. These
charges ensure such costs are not borne by the general body of ratepayers. Staff reviewed the
Company's tariff provisions to evaluate whether the charges are reasonable and consistent with
Commission practice. Based on its review, Staff believes the Company's non-recurring charges
to be generally reasonable. Staff recommends the Commission order the Company to file a
compliance tariff that clearly identifies these charges.
Return Check Charge
Idaho Code § 28-22-105 allows a company to collect additional charges when a check has
not been honored, but the amount is not to exceed twenty dollars ($20.00) or the face amount of
the check, whichever is less. Consistent with the statute, Staff believes the Company's returned
check charge of$20.00 to be reasonable and appropriate.
Reconnection Charge
The Company's tariff includes a reconnection fee of $50 during office hours and an
additional $50 for reconnections after office hours. A reconnection fee is appropriate following
an involuntary disconnection of service. In addition, the Company charges $100 for new
connections or customer transfers. Staff believes the reconnection charges to be reasonable and
consistent with the cost of restoring services.
STAFF COMMENTS 8 APRIL 22, 2026

Late Payment Charge
The Company currently assesses a flat$25 monthly late fee and a$50 water turnoff fee for
non-payment. Staff reviewed these charges to determine whether they are reasonable and
consistent with Commission practice. Late payment charges are appropriate to encourage timely
payment of customer bills and reduce the administrative burden associated with delinquent
accounts. A late payment charge of one percent(1%)per month has been previously approved for
similarly situated utilities and is considered reasonable. Order No. 36846. Based on its review,
Staff believes the Company's late payment charges to be reasonable for the interim period;
however, Staff notes the flat fee structure differs from typical percentage-based charges and may
warrant further review in a future rate case.
Hookup Fees
Hookup fees are charged to new customers to ensure the cost of establishing service is not
borne by existing customers. Staff believes the $250 hookup fee is reasonable for the interim
period because: (1) the Company's service territory is believed to be fully developed, with no
increase in service connections since the 2022 IDEQ sanitary survey; (2) the Company did not
provide sufficient cost support to verify the cost of a new connection; and(3)the system does not
include metered service, reducing typical connection-related costs.
If additional connections occur prior to the next rate case, Staff believes the $250 hookup
fee should cover most, if not all, of the associated costs.
Reliability Analysis
Staff investigated the reliability of the water system in terms of (1) water system
deficiencies identified in the IDEQ sanitary surveys, (2) the required amount of system capacity
to meet customer water requirements, and (3) sufficiency of water rights. Through its
investigation, Staff concludes:
1. The system has unresolved deficiencies that have persisted since 2022.
2. Staff cannot verify whether the system has sufficient capacity due to the lack of
engineering data.
3. The Company may not have sufficient water rights to meet demand of its customers.
STAFF COMMENTS 9 APRIL 22, 2026

Because Staff does not have jurisdiction to resolve these issues, Staff will notify the IDEQ
and the Idaho Department of Water Resources ("IDWR") of its analysis and will continue to
monitor these issues. Staff recommends the Commission order the Company to provide a status
update within 6 months of the final order for this case and to provide documentation for resolution
of these issues in its next general rate case.
System Deficiencies
The IDEQ identified three significant deficiencies as documented in its 2022 sanitary
survey: (1) no annual test for backflow devices, (2) no auxiliary power for safe and continuous
operation, and(3) lack of auto-proportioning chlorinators. However,the deficiencies have not yet
been resolved. The IDEQ entered into a Consent Order ("CO") with Timberline Development
LLC, the Company's owner, on June 2, 2025. In the CO, the Company agreed to provide IDEQ
with several deliverables, including evidence for implementing a Cross Connection Control
Program,an operations and maintenance manual, engineering reports, and plans and specifications
to resolve deficiencies identified by IDEQ. As of March 3, 2026, the Company has failed to file
the requirements. Staff believes the identified deficiencies remain unresolved and are critical to
the system's ability to provide safe and continuous service. Staff will monitor IDEQ's actions and
will revisit compliance within 6 months if the Commission orders a status update from the
Company and in its next general rate case.
Capaci . Analysis
Staff could not verify whether the water system has sufficient capacity to comply with
IDEQ's rules, because the Company failed to provide engineering information about the water
system as requested through Staff s Production Request Nos. 15 and 19. Without this information,
Staff cannot determine whether the system meets regulatory requirements. Because the CO
requires the Company to submit engineering documentation, Staff will coordinate with IDEQ to
obtain the necessary information so that capacity can be evaluated.
Water Rights
Staff identified that Timberline Development LLC only has water right No. 65-22888 for
a groundwater source. The water right allows pumping water flow of 0.33 cubic feet per second
STAFF COMMENTS 10 APRIL 22, 2026

("cfs") or 148 gpm for domestic use, which is less than the peak hour demand of 1,005 gpm
recorded in the Company's documents submitted to IDEQ on May 16, 2006. In addition,the total
diversion rate for pumping water in the water right is 4.15 cfs or 1,863 gpm. Staff believes that
the diversion rate in the water right should be adjusted according to beneficial use. Because IDWR
has jurisdiction over water rights enforcement, Staff will notify IDWR and revisit this issue within
6 months and in its next general rate case.
CUSTOMER COMMENTS
As of April 22,2026, eight customer comments were filed. Customers expressed concerns
about service quality, infrastructure deficiencies, a lack of confidence in the Company's ability to
provide safe, reliable water service, as well as an attempted rate increase not authorized by the
Commission.
Customers report frequent service disruptions,particularly during power outages,resulting
in loss of water pressure and recurring"Do Not Drink" and"Water Boil"notices. Customers also
assert that these conditions pose potential health risks, which have persisted for years without
adequate resolution. Concerns were also raised about the Company's accountability and
communication. Several comments referenced delayed or insufficient notice regarding water
safety issues and alleged noncompliance with regulatory requirements, including prior actions by
the Department of Environmental Quality.
A primary concern expressed is the Company's failure to make necessary infrastructure
improvements. Customers repeatedly cited the absence of a backup generator and effective
backflow prevention systems, which they believe would mitigate water pressure loss and reduce
the risk of contamination.
Customers objected to an attempted rate increase in monthly rates from $57 to $62, with
two customers noting that it was implemented without Commission approval. Customers also
expressed frustration with repeated rate increases in recent years without corresponding
improvements in service.
STAFF RECOMMENDATION
Staff s investigation indicates that the Company's current rates generate revenues in excess
of those necessary to recover prudently incurred operating expenses and provide an appropriate
STAFF COMMENTS 11 APRIL 22, 2026

return on investment. Absent a reduction to rates, the Company will continue to collect revenues
in excess of those necessary to provide safe and reliable service at just and reasonable rates.
Accordingly, Staff recommends the Commission order the Company to file a general rate case to
reduce rates and align revenues with Staff s calculated revenue requirement. Staff also
recommends the Commission order the Company to file a compliance tariff that clearly identifies
non-recurring charges consistent with these comments. Finally, Staff recommends that the
Commission order the Company to provide a status update within 6 months of the final order in
this case and to provide documentation for resolution of these issues in its next general rate case.
Respectfully submitted this 22nd day of April 2026.
Y l�cMn�n
Erika K. Melanson
Deputy Attorney General
Technical Staff: Ty Johnson
Seungjae Lee
I:\Utility\UMISC\COMMENTS\MWL-W-25-01 Comments.docx
STAFF COMMENTS 12 APRIL 22, 2026

REVENUE REQUIREMENT -ATTACHMENT A
(A) (B) (C)
Company Staff
Ending 12/31/2024 Pro Forma Total
I Rate Base (Ex. 1, Sch C, line 11) $ 324,218 $ (24,004) $ 300,214
2 Required Rate of Return (Ex. 3, line 7) 11.00% 11.00%
3 Income Required(Line I x Line 2) $ 35,664 $ 33,024
4 Income Realized(Ex. 2, Sch C, line 29) $ (118,584) $ 162,662 $ 44,079
5 Income Deficiency(Line 3 less Line 4) $ 154,247 $ (11,055)
6 Net Operating Income Required $ 154,247 $ (11,055)
7 Gross Up Factor 1.345436 1.345436
8 Total Incremental Revenue Requirement $ 207,530 $ (14,874)
9 Revenues at Existing Rates $ 146,663 $ 148,376
10 Total Revenue Requirement $ 354,193 $ 133,502
I I Percent Increase Required 141.50% -10.02%
$ 52.00
REVENUE CONVERSION FACTOR
15 Total Gross Revenues 1.000000 1.000000
16 Less Regulatory Fees (percentage) 0.002223 0.002223
17 State Income Tax Rate 0.05695 0.056950 0.056950
18 Total Expenses 0.059173 0.059173
19 Federal Income Tax Base 0.940827 0.940827
20 Federal Income Tax Rat, 0.21 0.197574 0.197574
21 Net Operating Revenue 0.743253 0.743253
22 Net Income to Gross Revenue Multiplier 1.345436 1.345436
ATTACHMENT A
Case No. MWL-W-25-01
Staff Comments
April 22, 2026

RESULTS OF OPERATIONS WITH STAFF ADJUSTMENTS-ATTACHMENT B
(A) (B) (C)
Test Year Pro Forma Staff
Ending 12/31/2024 Total Total
Line Water Revenues
1 Unmetered-Residential $ 144,663 $ 1,713 $ 146,376
2 Revenue HOACommon Area $ 2,000 $ 2,000
3 TOTAL Revenues $ 146,663 $ 1,713 $ 148,376
Operating Expenses
4 Purchased Power $ 13,616 $ 3,165 $ 16,781
5 Chemicals $ - $ 5,809 $ 5,809
6 Materials& Supplies-Operation&Maintenance $ 44,158 $ (5,809) $ 38,349
7 Materials& Supplies-Admin&General $ 2,406 $ 2,406
8 Contract Services-Professional $ 178,152 $ (153,826) $ 24,326
9Insurance $ 3,778 $ 3,778
10 Regulatory Comm. Exp. (Other Except Taxes) $ 856 $ 856
11 Miscellaneous Expenses $ 1,784 $ 1,784
12 TOTAL Operating Expenses $ 244,750 $ (150,661) $ 94,089
13 Depreciation Expense $ 10,685 $ (4,488) $ 6,197
14 Other Taxes(list) Bank Fees $ 12 $ 12
15 Other Taxes (list) DEQ Fines and Penalties $ 5,800 $ (5,800) $ -
16 State of ID Taxes $ 4,000 $ 4,000
17 TOTAL Expenses from Operations $ 265,247 $ (160,949) $ 104,298
18 Net Operating Income $ (118,584) $ 162,662 $ 44,079
Rate Base
19 Plant in Service $ 491,890 $ (31,418) $ 460,472
20 Accumulated Depreciation $ 198,266 $ (26,247) $ 172,019
21 Total Plant in Service $ 293,624 $ (5,171) $ 288,453
22 Net Plant in Service Prior to Working Capital $ 293,624 $ (5,171) $ 288,453
23 Working Capital(1/8 Operating Expenses) $ 30,594 $ (18,833) $ 11,761
24 TOTAL Rate Base $ 324,218 $ (24,004) $ 300,214
ATTACHMENT B
Case No. MWL-W-25-01
Staff Comments
April 22, 2026

Attachment C-Staff Calculation for Power Costs
Line Category Value Unit
1 Total Power Usage 296,607 kWh
1-(a) Power Usage in 2025 92,035 kWh
1-(b) Power Usage in 2024 104,735 kWh
1-(c) Power Usage in 2023 99,836 kWh
2 Total production of water 120.46 Million Gallons
2-(a) Production of water in 2025 43.12 Million Gallons
2-(b) Production of water in 2024 42.49 Million Gallons
2-(c) Production of water in 2023 34.85 Million Gallons
3 Normalized power usage per production of water 2,462.33 kWh/Milton Gallons Line 1/Line 2
4 Power costs in 2025 15,016 Dollars
5 Unit power cost in 2025 0.16 Dollars/kWh Line 4/Line 1-(a)
6 Power Utitlity's rate increase in 2026 4.03 percent
7 Unit power cost in 2025 0.17 Dollars/kWh Line 5 X(1+Line 6)
8 Power Cost per Water Production 417.93 Dollars/Milton Gallons Line 3 X Line 7
9 Normalized production of water 40.15 Milton Gallons Line 2/3
10 Estimated Power expense in 2026 16,781 Dollars Line 8 X Line 9
ATTACHMENT C
Case No. MWL-W-25-01
Staff Comments
April 22, 2026

Attachment D-Staff Calculation for Chemicals Costs
Line Category Value Unit
1 Total Chemicals Usage 2,025 Gallons
1-(a) Chemicals Usage in 2025 810 Gallons
1-(b) Chemicals Usage in 2024 945 Gallons
1-(c) Chemicals Usage in 2023 270 Gallons
2 Total production of water 120.46 Million Gallons
2-(a) Production of water in 2025 43.12 Million Gallons
2-(b) Production of water in 2024 42.49 Million Gallons
2-(c) Production of water in 2023 34.85 Million Gallons
3 Normalized chemicals usage per production of water 17 Gallons/Millon Gallons Line 1/Line 2
4 Chemicals Costs in the lastest invoices 2,323 Dollars
5 Amount of purchased chemicals in the latest invoices 270 Gallons
6 Unit chemical cost 8.61 Dollars/Gallons Line 4/Line 5
7 Chemicals cost per production of water 144.66 Dollars/Millon Gallons Line 3 X Line 6
8 Normalized production of water 40.15 Millon Gallons Line 2/3
9 Estimated Chemicals expense 5,809 Dollars Line 7X Line 8
ATTACHMENT D
Case No. MWL-W-25-01
Staff Comments
April 22, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF APRIL 2026, SERVED
THE FOREGOING Corrected COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. MWL-W-25-01, BY E-MAILING AND MAILING A COPY VIA EMAIL THEREOF
TO THE FOLLOWING:
Registered Agent
Reid Olsen and/or Tony Hendricks
Olsen Hendricks & Webster CPAs
132 SW 5th Avenue Suite 100
Meridian, ID 83642
Email: reido(kolsencpa.com
Mvr0l(d),mac.com
Meadowswater&ols encpa.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE