20260923Letter to RWS RE Responses to Discovery.pdf

RECEIVED
September 23, 2026
IDAHO PUBLIC
=�►!�� UTILITIES COMMISSION
Idaho Public Utilities Commission Brad Little,Governor
P.O. Box 83720, Boise, ID 83702-0074 Edward Lodge,President
John R.Hammond,Jr.,Commissioner
Dayn Hardie,Commissioner
September 23, 2026
Via E-Mail: blackwaterllc.idahogginail.com
and Via Certified Mail: 7016 13 70 0000 2326 6363
Michael Williams-Black
2930 E. Deer Flat Road
Kuna, ID 83653
RE: Responses to Discovery, Order No. 36930 (Case No. RWS-W-26-01)
Dear Mr. Williams-Black,
The Idaho Public Utilities Commission("Commission") Staff("Staff')has made multiple
attempts to contact Rivervine Water and Sewer, LLC ("Company") to respond to the attached
discovery questions and inquiries ("Production Requests") sent to the Company on June 9, 2026.
Responses to these Production Requests are necessary for Staff "to evaluate whether the
Company's rates are fair, just, and reasonable and to perform a reliability analysis of its water
system." Order No. 36930 at 3. Staff requested that the Company provide responses to its
Production Requests no later than Tuesday, June 30, 2026, the 21-days allowed by the
Commission's Rules of Procedure. IDAPA 31.01.01.225.03. As of the date of this letter,
responses are now 64 days past due.
On August 6, Staff attempted to contact the Company via e-mail to request the submission
of the responses to its Production Requests. On August 7, Staff followed up with a phone call, and
the Company indicated that it would respond to the e-mail by August 10. However, Staff never
received a response to its e-mail from the Company. On September 9, Staff attempted to contact
the Company and left a message requesting a return call. Staff did not receive a return phone call.
Staff again attempted to call the Company on September 18 and was told by the Company's
bookkeeper that the owner's daughter would respond to the Production Requests.
To date,the Company has neither responded to the Production Requests nor communicated
with Staff regarding the status of its completion. Idaho Code § 61-406 requires every public utility
to obey and comply with each requirement of every order, decision, direction, rule, or regulation
of the Commission. Additionally, Idaho Code § 61-706 provides that a public utility that fails to
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

Michael Williams-Black
Rivervine Water and Sewer, LLC
September 23, 2026
Page 2
comply with an order, decision, rule, direction, demand, or requirement of the Commission may
be subject to a civil penalty of up to$2,000 for each offense. Idaho Code§ 61-707 further provides
that,in the case of a continuing violation,each day's continuance constitutes a separate and distinct
offense.
Staff requests that the Company submit responses to all of its Production Requests no later
than WEDNESDAY, OCTOBER 7, 2026, at 5:00 p.m. (Mountain Time). Enclosed is a copy of
the e-mail sent to the Company on August 6, 2026.
Staff has worked patiently with the Company to allow it sufficient time to respond to Staff s
Production Requests and remains available to answer any questions necessary for the Company to
respond. However, the Company must actively communicate with Staff and comply with the
Commission's directives and Rules of Procedure.
Staffs objective is to assist the Company in achieving compliance with the Commission's
Rules of Procedure without further proceedings. However, if the Company fails to submit the
required Production Request responses by the date stated above, Staff may recommend that the
Commission initiate appropriate enforcement proceedings,including consideration of the penalties
authorized by Idaho Code §§ 61-706 and 61-707.
Staff appreciates the Company's prompt attention to this matter and looks forward to
resolving this matter without further Commission action.
Thank you for your cooperation and assistance.
Sincerely,
Jeffrey R. Loll
Deputy Attorney General
cc: Travis Culbertson, Program Manager, Accounting
Seungjae Lee, Engineer
Mike Louis, Program Manager, Engineering
Encls: First Production Request of the Commission Staff to Rivervine Water and Sewer, LLC
Copy of August 6, 2026 E-Mail
I:\Utility\UMISC\PRDREQ\RWS-W-26-01\Rivervine Water Ltr 9.23.2026
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]

ENCLOSURES
1) First Production Request of the Commission Staff to Rivervine Water and Sewer, LLC
2) Copy of August 6, 2026 E-Mail

RECEIVED
June 09, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INVESTIGATION )
INTO RIVERVINE WATER& SEWER,LLC, ) CASE NO. RWS-W-26-01
OWNER OF A WATER SUPPLY AND )
DISTRIBUTION SYSTEM )
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO RIVERVINE WATER&
SEWER, LLC
Commission Staff("Staff')of the Idaho Public Utilities Commission("Commission"), by
and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General, requests that
Rivervine Water & Sewer, LLC ("Company") provide the following documents and information
as soon as possible,but no later than TUESDAY, JUNE 30, 2026. All responses should be filed
with the Commission Secretary at [e-mail].
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person acting
on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
FIRST PRODUCTION REQUEST
TO RIVERVINE WATER& SEWER, LLC 1 JUNE 9, 2026

REQUEST NO. 1: Please identify the accounting and financial software used by the
Company. If the Company uses QuickBooks Online,please create "Accountant"user access and
provide credentials for Staff to view the Company's financial records. If the Company uses
another version of QuickBooks other than Online, please export all financial data to Excel for the
period 2024, 2025, through May 31, 2026, and provide the exported files.
REQUEST NO. 2: Please provide copies of all customer billings for October 2025,
March 2026, and May 2026.
REQUEST NO. 3: Please provide a Procedures Manual or a complete description of the
Company's billing process, including meter reading, billing, cash payment, and account
reconciliation. Please include other internal controls the Company uses to ensure the accuracy of
customer bills.
REQUEST NO. 4: Please provide a spreadsheet, in Excel format with formulas intact,
detailing the Company's Plant in Service as of May 31, 2026. The spreadsheet should separately
identify each asset by type,date placed into service, original cost, and depreciable life. Please also
include the following, if available:
a. original cost of the asset;
b. net book value of the asset;
c. annual depreciation expense; and
d. accumulated depreciation.
REQUEST NO. 5: Please provide a copy of all bank statements for all accounts used by
the Company for January 2024 through May 2026.
REQUEST NO. 6: Please provide copies of all monthly electric bills for 2025 through
May 2026 for each well and booster pump. The bills should show monthly energy usage in
kilowatt-hours and peak demand in kilowatts. Additionally,please provide monthly energy usage,
if available, in Excel format with formulas intact for the past five years.
FIRST PRODUCTION REQUEST
TO RIVERVINE WATER& SEWER, LLC 2 JUNE 9, 2026

REQUEST NO. 7: Please provide a map of the system in PDF format that identifies the
location of the major pieces of equipment such as wells, treatment facilities, storage tanks,booster
pump stations, and distribution lines. Also, for each major piece of equipment,please provide the
following:
a. the number and capacity of installed pumps in each well,identifying whether a Variable
Frequency Device is installed;
b. the number and capacity of backup generators;
c. the number and capacity of water treatment facilities, identifying whether an auto
chlorine injection system is installed;
d. the number and capacity of storage tanks, identifying whether they are pressurized or
unpressurized, and whether the capacity includes firewater demands;
e. the number and capacity of booster pumps in each booster pump station, identifying
the service area of the booster pump station; and
f. the size and material of distribution lines.
REQUEST NO. 8: In reference to the water system connections, please provide the
following:
a. the number of currently served connections for each meter size and customer class,
such as residential and commercial; and
b. the number of connections expected to be served in the future within the authorized
service territory.
REQUEST NO. 9: Please provide a copy of the latest sanitary survey conducted by the
Idaho Department of Environmental Quality("IDEQ").
REQUEST NO. 10: Please provide the most recent facility plan approved by the IDEQ.
If there is no approved facility plan, please provide engineering documents such as design
specifications and preliminary engineering reports for the Company's water system.
REQUEST NO. 11: Please provide a copy of all water rights or permits to demonstrate
that the Company has authorization to pump water to serve in the service territory.
FIRST PRODUCTION REQUEST
TO RIVERVINE WATER& SEWER, LLC 3 JUNE 9, 2026

REQUEST NO. 12: Please provide the purchased chemical invoices in 2025, including a
unit price, list, and quantity of the chemicals.
REQUEST NO. 13: Please provide monthly metered water consumption data,in gallons,
in Excel format with formulas intact, for each customer in 2025. Please include the meter size and
customer class for each customer.
REQUEST NO. 14: Please provide the monthly metered water in gallons, in Excel
format with formulas intact,pumped from each of the Company's water sources in 2025.
REQUEST NO. 15: Please provide average monthly pressure data in the main
distribution line in 2025.
DATED at Boise, Idaho, this 9th day of June 2026.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Leena Gilman (for Seungjae Lee)
I:\Utility\UMISC\PRDREQ\RWS-W-26-01 PR#l.docx
FIRST PRODUCTION REQUEST
TO RIVERVINE WATER& SEWER, LLC 4 JUNE 9, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF JUNE 2026,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO RIVERVINE WATER& SEWER,LLC , IN CASE NO.
RWS-W-26-01, BY MAILING VIA U.S. MAIL and also E-MAILING A COPY
THEREOF, TO THE FOLLOWING:
Rivervine Water & Sewer, LLC
Michael Williams-Black, Registered Agent
P.O. Box 3723
Nampa, ID 83653-3723
E-MAIL: blackwaterllc.idaho(agmail.com
PATRICIA JORDA9, SECRETARY
CERTIFICATE OF SERVICE

Seungjae Lee
From: Seungjae Lee
Sent: Thursday, August 6, 2026 10:28 AM
To: [e-mail]
Cc: Mike Louis;Travis Culbertson
Subject: Reminder for overdue response to Production Request in RWS-W-26-01
To whom it may concern,
This is Seungjae from the Public Utilities Commission, the lead for Case No. RWS-W-26-01.
This is a reminder that the response to the first set of Production Requests is overdue.
I hope you file the response as soon as possible.
I will call you later to double check.
If you have any questions, please respond to this email and/or call.
Thankyou.
Seungjae Lee Ph. D., P.E.
Engineer,Associate
Idaho Public Utilities Commission
Email:Seungjae.Lee( puc.idaho.gov
Phone:[phone]
Mobile: [phone]
1