20240214SWC to Staff Supplemental 24_25_30_32.pdf

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 1

61730.0002.16804821.1
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS & HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5253
Email: [e-mail]
[e-mail]
Attorneys For Schweitzer Water Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF SCHWEITZER WATER COMPANY FOR APPROVAL OF ACQUISITION OF THE ASSETS OF RESORT WATER CO. INC. AND FOR THE ISSUANCE OF A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY

Case No. SWC-W-23-01
SCHWEITZER WATER COMPANY’S FIRST SUPPLEMENTAL RESPONSE TO THE COMMISSION STAFF’S FIRST PRODUCTION REQUEST

Please find enclosed Schweitzer Water Company’s (the “Company”) First Supplemental
Response to the Commission Staff’s First Production Request, supplementing the Company’s
responses filed February 6, 2023 for Request Nos. 24, 25, 30 and 32. For purposes of providing
the contact information of the recordholder and/or sponsor identified for certain responses, the
following contact information is applicable:
Tom Trulock Jennifer Brownlie, Esq.
Vice President, General Counsel,
Schweitzer Water Company Alterra Mountain Company U.S., Inc.
165 Village Lane, Suite A 3501 Wazee St., Suite 400
Sandpoint, ID 83864 Denver, CO 80216-3787
[phone] [phone]
[e-mail] [e-mail]
Answers to each relevant production request are enclosed, along with referenced Exhibits.
RECEIVED
Wednesday, February 14, 2024 8:00AM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 2

61730.0002.16804821.1
IPUC REQUEST NO. 24

Please provide the Resort Water Annual Reports for 2019 and 2021.

RESPONSE TO IPUC REQUEST NO. 24

The Annual Reports for Resort Water for years 2019 and 2021 are included in “Exhibit
1” attached hereto, in excel format. While the Company believes that the signed original
versions were sent to the Commission via U.S. Mail, it is unable to locate the signed
versions within its files at this time. If the Commission is in need of signed versions,
please let the Company know.

Recordholder: Tom Trulock

Sponsor: Tom Trulock

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 3

61730.0002.16804821.1
IPUC REQUEST NO. 25

Please provide the Ridge Water (a.k.a Acme Water) Annual Reports for 2018, 2019,
2020, 2021 and 2022.

RESPONSE TO IPUC REQUEST NO. 25

The Annual Reports for Ridge Water for years 2018 through 2021 are included in
“Exhibit 2” attached hereto, in excel format. While the Company believes that the signed
versions were sent to the Commission via U.S. Mail, it is unable to locate the signed
versions within its files at this time. If the Commission is in need of signed versions,
please let the Company know. The Company will supplement its response to this question
with the Annual Report for 2022 as soon as it is available.

For additional context regarding the delivery of Annual Reports for the Ridge Water
system—in prior years, the “company information” portion of the Annual Report for
Ridge Water listed the “utility” as “Ridge Water Co., Inc.,” however this should likely
have been reflected as “Resort Water Co., Inc.” as the owner of the Ridge Water system
for years 2018 through 2022. The use of “Ridge Water Co., Inc.” appears to be intended
by Resort Water to file annual reports for the Ridge Water system it acquired and to show
its separate treatment of the Resort Water and Ridge Water systems so the Annual
Reports for the two systems were not confused. The versions attached hereto make the
attempt to clarify the owner at “Resort Water Co., Inc. (formerly Acme) dba Ridge
Water” to clarify that these reports are intended for the Ridge Water system owned by
Resort Water Co. (and formerly owned by Acme Water).

Recordholder: Tom Trulock

Sponsor: Tom Trulock

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 4

61730.0002.16804821.1
IPUC REQUEST NO. 30

Please provide a copy of the allocation methodology for allocation of costs from the
parent company to Schweitzer Water Company.

RESPONSE TO IPUC REQUEST NO. 30

The Company does not yet have an established methodology for allocating costs from the
parent company to the Company. The Company is in the process of determining what
parent costs might be allocable to the Company, as well as the potential methods used to
perform the allocation. To the extent that the Company seeks to recover costs allocable
to the parent company, the Company will present those costs in the context of a general
rate case for Commission review, along with the associated allocation methodology.

Recordholder: Tom Trulock

Sponsor: Jennifer Brownlie, Esq.

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 5

61730.0002.16804821.1
IPUC REQUEST NO. 32

Please provide a schedule showing the amount of Ridge Water’s (a.k.a Acme Water)
revenues and expenses that are included in Resort Waters’ Annual Report and Gross
Intrastate Operating Revenue report for years 2018 to present.

RESPONSE TO IPUC REQUEST NO. 32

Ridge Water’s revenues and expenses are not included in Resort Waters’ Annual Report
and Gross Intrastate Operating Revenue report for years 2018 to present. Resort Water
has separate reports for Ridge Water – see Response to IPUC Request No. 25.

Recordholder: Tom Trulock

Sponsor: Tom Trulock

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 6

61730.0002.16804821.1
Dated: February 13, 2024.

HAWLEY TROXELL ENNIS & HAWLEY LLP
By ______________________________________
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
Attorneys For Schweitzer Water Company

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – 7

61730.0002.16804821.1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing
SCHWEITZER WATER COMPANY’S FIRST SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF’S FIRST PRODUCTION REQUEST by the method indicated below,
and addressed to each of the following:
Commission Staff
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714
[e-mail]

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail
 Facsimile
 iCourt
Tom Trulock, Vice President
c/o Schweitzer Water Company
165 Village Lane, Suite A
Sandpoint, ID 83864
[e-mail]
 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
 Facsimile
 iCourt
Brad Mullins
Principal Consultant
MW Analytics
Teitotie 2, Suite 208
Oulunsalo Finland, FI-90460
[e-mail]
 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
 Facsimile
 iCourt

Dated: February 13, 2024.
_________________________________________
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – EXHIBIT 1

61730.0002.16804821.1

EXHIBIT 1

RESORT WATER ANNUAL REPORTS (2019 & 2021)

See attached.

FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST – EXHIBIT 2

61730.0002.16804821.1
EXHIBIT 2

RIDGE WATER ANNUAL REPORTS (2018 – 2021)

See attached.