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Home My WebLink About20240312SWC to Staff 33-35.pdf RESPONSE TO SECOND PRODUCTION REQUEST – 1 61730.0002.16924130.1 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: 208.344.6000 Facsimile: 208.954.5253 Email: rwilliams@hawleytroxell.com bhelgeson@hawleytroxell.com 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 RESPONSE TO THE COMMISSION STAFF’S SECOND PRODUCTION REQUEST Please find enclosed Schweitzer Water Company’s (the “Company”) Responses to IPUC Production Request Nos. 33 – 35. 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 Vice President, Schweitzer Water Company 165 Village Lane, Suite A Sandpoint, ID 83864 (208) 255-3046 ttrulock@schweitzer.com Answers to each production request are enclosed, along with referenced Exhibits. RECEIVED Tuesday, March 12, 2024 12:54:02 PM IDAHO PUBLIC UTILITIES COMMISSION RESPONSE TO SECOND PRODUCTION REQUEST – 2 61730.0002.16924130.1 IPUC REQUEST NO. 33 The Application indicates that current Ridge customers will take service under the proposed Schedule No. 6. Please answer the following questions: a. What new non-recurring charges will be applicable for the Ridge system customers that take service under the proposed Schedule 6? b. Please explain if hook-up and line extension fees are applicable. If so, what does the Company intend to charge? c. Are there any non-recurring charges from the previous Ridge system tariffs that are not specifically addressed in the new tariff proposal? RESPONSE TO IPUC REQUEST NO. 33 a. To simplify the administration process, the Company has designed its proposed tariff in a way that all customers, including those within the Ridge system, will pay the same non- recurring charges and will be subject to identical rules and regulations. This includes the Miscellaneous Fees and Charges specified in Schedule 2. Note that there are minor differences between the non-recurring charges in the Schweitzer tariff and those in Order 33219 in Case No. AWW-W-13-O1 for Acme Water Works, Inc. The table below details the differences: Given the similarities between the charges, the Company would propose to conform the non-recurring charges in the tariff to be based on a single set of charges from the former Resort Water Company, Inc. tariff. Notwithstanding, the Company would not be opposed to implementing separate non-recurring charges for the two systems at the request of Staff, although Schweitzer’s preference is to maintain a single set of non- recurring charges to the extent that Staff and the Commission find those charges to be reasonable. b. No separate hook-up or line extension fees would be applied under the Tariff proposal. Line extensions would be governed for all customers under the Rules and RESPONSE TO SECOND PRODUCTION REQUEST – 3 61730.0002.16924130.1 Regulations Governing the Rendering of Service (“Rules”) §§65-71. Under the Rule § 4, however, there would be a $60.00 service charge for afterhours requests for service, which would only apply to application requests after regular office hours. For the purposes of conforming the two Tariffs, Schweitzer is proposing for the $150 hook-up fee approved in Order 33219 to not apply. Otherwise, the charges specified in response to subpart (a.), above, would be applied. Recordholder: Tom Trulock Sponsor: Tom Trulock RESPONSE TO SECOND PRODUCTION REQUEST – 4 61730.0002.16924130.1 IPUC REQUEST NO. 34 Please provide a schedule showing the amount billed to each customer of Resort Water and Ridge Water for August of 2022. Please break out the amount billed by service charge, volumetric charge, and non-recurring charges. RESPONSE TO IPUC REQUEST NO. 34 Please see the excel spreadsheet in Exhibit 1 attached hereto. These reflect service charges as there were no non-recurring charges or bulk use charges during this cycle. Please note, service charges are fixed rate and not determined by meter readings. Recordholder: Tom Trulock Sponsor: Tom Trulock RESPONSE TO SECOND PRODUCTION REQUEST – 5 61730.0002.16924130.1 IPUC REQUEST NO. 35 Please provide examples of customer bills for Resort Water, Ridge Water and Schweitzer Water Company. RESPONSE TO IPUC REQUEST NO. 35 Please see the sample bills in Exhibit 2 attached hereto. The Commission will notice that Ridge Water and Resort Water bills were not differentiated by name on the invoice, just the rate. The sample bill provided for Schweitzer Water Company reflects a bill prior to the name change from Husky Water Company to Schweitzer Water Company. Recordholder: Tom Trulock Sponsor: Tom Trulock RESPONSE TO SECOND PRODUCTION REQUEST – 6 61730.0002.16924130.1 Dated: March 11, 2024. HAWLEY TROXELL ENNIS & HAWLEY LLP By ______________________________________ Ronald L. Williams, ISB No. 3034 Brandon Helgeson, ISB No. 11615 Attorneys For Schweitzer Water Company RESPONSE TO SECOND PRODUCTION REQUEST – 7 61730.0002.16924130.1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I caused to be served a true copy of the foregoing SCHWEITZER WATER COMPANY’S RESPONSE TO THE COMMISSION STAFF’S SECOND 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 secretary@puc.idaho.gov  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 ttrulock@schweitzer.com  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 brmullins@mwanaltyics.com  U.S. Mail, Postage Prepaid  Hand Delivered  Overnight Mail  E-mail:  Facsimile  iCourt Dated: March 11, 2024. _________________________________________ Ronald L. Williams, ISB No. 3034 Brandon Helgeson, ISB No. 11615 RESPONSE TO SECOND PRODUCTION REQUEST – EXHIBIT 1 61730.0002.16924130.1 EXHIBIT 1 AUGUST 2022 BILLING SCHEDULE See attached. RESPONSE TO SECOND PRODUCTION REQUEST – EXHIBIT 2 61730.0002.16924130.1 EXHIBIT 2 SAMPLE CUSTOMER BILLS See attached. RIDGE WATER SAMPLE BILL RESORT WATER SAMPLE BILL SCHWEITZER WATER SAMPLE BILL