20230131_ISLW2301_cs1.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON COMMISSIONER HAMMOND COMMISSIONER LODGE COMMISSION SECRETARY COMMISSION STAFF LEGAL FROM: CLAIRE SHARP DEPUTY ATTORNEY GENERAL DATE: JANUARY 31, 2023 SUBJECT: IN THE MATTER OF ISLAND PARK WATER COMPANY’S FAILURE TO COMPLY WITH IDAHO PUBLIC UTILITIES COMMISSION REPORTING AND FISCAL REQUIREMENTS; CASE NO. ISL-W-23-01.
Island Park Water Company, Inc. (“Island Park” or “Company”) operates a “Water system”
as a “Water corporation” as defined by Idaho Code §§ 61-124 and 61-125 and is a public utility
subject to the jurisdiction of the Commission under Idaho Code § 61-129. The Company operates
under Certificate of Public Convenience and Necessity No. 317. Island Park’s service area
comprises seven separate water systems located in Fremont County, Idaho.
This matter comes before the Commission due to the Company’s failure to respond to audit
requests from Commission Staff and file required annual reports, notwithstanding multiple
requests and extensions from Commission Staff.1 Affidavit of Joseph Terry. Exhibit 1.
THE NOTIFICATION OF ISLAND PARK
On July 14, 2022, Commission Staff (“Staff”) sent an Audit Request to the Company.
Exhibit 2. The Company did not respond despite multiple communications from Staff about the
Audit Request. On August 1, 2022, Counsel mailed a demand letter alerting the Company of its
failure to submit its 2021 Gross Intrastate Operating Revenue & Audit Request (“GIOR”) report
and respond to Staff’s Audit Request. Exhibit 3. The August 1, 2022, demand letter was sent to
the Company’s address of record at the Commission but was returned as undeliverable.

1 The Company failed to file its annual Gross Intrastate Operating Revenue (“GIOR”) reports in a timely manner.
DECISION MEMORANDUM 2
On August 11, 2022, and August 18, 2022, Staff communicated with the Company through
email about complying with the Commission’s Audit Request. Exhibit 4. The Company did not
provide its 2021 GIOR report or respond to Staff’s Audit Request
On August 29, 2022, Staff’s Counsel sent a demand letter entitled, Re: Gross Intrastate
Operating Revenue & Audit Request – Notice of Possible Legal Action via process server to
the Company.2 Exhibit 5. The August 29, 2022, demand letter alerted the Company of its
responsibility to update its address of record with the Commission, submit its 2021 GIOR report,
and respond to Staff’s Audit Request, as follows:
Commission Staff made efforts to contact Island Park through email, and allowed
a brief extension for Island Park to respond. That extension has now expired, and Island Park must respond to the audit request or face penalties under Idaho Code § 61-706.
Id.
On September 12, 2022, the Company submitted its 2021 GIOR report. On September 14,
2022, Staff mailed an invoice for the late GIOR report.3 The Company did not respond to the Audit
Request.
On September 19, 2022, Island Park informally requested a 90-day extension of time from
Staff to become compliant due to the personal circumstances of the operator. Exhibit 6.
On October 4, 2022, Counsel responded to the Company’s extension request via process
server, entitled Re: Failure to Respond to Audit Request – Notice of Possible Legal Action.
Exhibit 7. Counsel reminded the Company that its request for an extension was untimely under
the Commission’s Rule of Procedure 225.03, IDAPA 31.01.01.225.03, which allows “14 days for
[the Company] to object or explain why the questions cannot be answered.” Id. The 14-day period
to request an extension for the July 14, 2022 Audit Request needed to be filed by July 28, 2022.
Id. The Company’s failure to maintain current contact information on file caused delays and
required a process server to deliver routine correspondence. Id. Counsel’s October 4, 2022,
demand letter continued:
Further, it is inexplicable why the Company only responds to selected emails from Commission Staff sent to the email addresses on file, but later claims to be unable
to use those email addresses. For example, the email address the Company used to
contact Nancy Ashcraft and Terri Carlock is the exact same email address that

2 The process server confirmed delivery of the letter on September 7, 2022. 3 The Company submitted payment of the invoice for the GIOR on September 29, 2022.
DECISION MEMORANDUM 3
received the audit emails on July 28, 2022, as well as the reminder email on August 11, 2022. This was also the same email address used in the 2020 audit of Island
Park, with which the Company had responded to during that audit. In any case, it
is expected that all regulated utilities keep current contact information on file with the Commission, and the Company’s failure to update this information does not excuse the Company from its responsibilities.
Exhibit 6 at 2.
Counsel reminded the Company its responses were “overdue on these statutorily required reports.”
Id. Because the Company indicated that a medical issue of the operator was preventing it from
responding to audit requests, Counsel and Staff postponed initiating a show cause recommendation
while reminding the Company of the need to meet statutory responsibilities under Idaho Code §
61-302. Id. The Company was given ten days to explain how it intended to maintain the service
quality required under Idaho law, and told that the Company’s failure to respond “will result in
Staff requesting a motion to show cause with the Commissioners.” Id. Finally, Counsel notified
the Company that its “failure to comply with the requirements of Idaho Code and the
Commission’s Rules of Procedure may result in the Commission imposing penalties under Idaho
Code §§ 61-706 and 61-707,” and that employees and officers can also be subject to penalties
under Idaho Code § 61-709. Id.
On October 13, 2022, Counsel, Staff and the Company discussed the importance of
regulatory compliance and proposed potential paths forward to ensure regulatory compliance. The
Company indicated that it would become compliant.
On November 28, 2022, the Company filed its 2020 and 2021 annual reports. Staff again
reminded the Company of its outstanding response to the Audit Request. Since that time, Staff
continued to remind the Company of the need to comply with the Commission’s regulatory
requirements.
On December 27, 2022, Counsel sent another demand letter via Process Server, entitled
Re: Second Notice of Failure to Respond to Audit Request – Notice of Possible Legal Action.
Exhibit 8. This demand letter notified the Company that:
Because of Island Park’s continued delays and failure to comply with the
requirements of Idaho Code and the Commission’s Rules of Procedure, we are
recommending that the Commission pursue a show cause hearing and penalties under Idaho Code §§ 61-706, 61-707 and 61-709.
DECISION MEMORANDUM 4
If Island Park wishes to avoid a show cause hearing, the Company needs to submit a full and complete response to the Audit Request within ten (10) days from the
receipt of this letter.
Exhibit 8. The Company acknowledged receipt of the December 27, 2022, demand letter on January 3, 2023.
Exhibits 9-10. On January 9, 2023, the Company notified Counsel that its audit responses were
being sent to the Commission via tracked mail.
THE COMPANY’S JANUARY 10, 2023, AUDIT RESPONSES
Staff reviewed the Company’s responses, and determined that only three responses to the
ten audit requests (“AR”) were adequate (Responses Nos. 2, 5, and 8). Confidential Exhibit 11.
There were three responses that incompletely addressed the requests (Responses Nos. 6, 7 and 10),
and four responses that did not address the substance of the requests (Responses Nos. 1, 3, 4 and
9), as follows:
AR No 1: Please provide a customer list broken out by subdivision.
The Company did not provide an updated customer list.
AR No. 3: Please provide a schedule showing all non-recurring fees charged to customers in
2020 and 2021.
The Company denied having a schedule of non-recurring expenses. The Company’s denial
is inconsistent with Company records, i.e., the deposit fees being charged to customers on the
Company bank statements.
AR No. 4: Please provide a copy of all bills sent to customers in 2020 and 2021.
The Company did not provide a list of any customers billed or acknowledge any of the
amounts billed. This response is implausible and reflective of poor bookkeeping practices, because
the Company is billing its customers and must have some documentation of who and what it
charges.
AR No. 6: Please provide a listing of plant-in-service for the Company as of the end of 2021.
Although the Company’s narrative response partially addressed this request for
information, the Company did not provide a list or provide historical cost for the Company’s plant-
in-service.
AR No. 7: Please provide a list of all customer complaints received in 2020 and 2021, along
with each complaint’s resolution.
DECISION MEMORANDUM 5
The Company did not provide a list of customer complaints for 2020 and 2021. This
response is not well taken because the Company is expected to maintain an independent log of
customer relations issues. The Commission has pending informal complaints against the Company
that the Company must document in its records.
AR No. 9: Please provide an accounts receivable aging report for the years ending 2020 and
2021.
An accounts receivable aging report would list customers who have not paid their bills in
a timely manner. The Company did not provide an accounts receivable aging report.
Audit Request No. 10: Please provide all Company bank statements for 2020 and 2021.
The Company provided bank statements that have signs of alterations (sections were
covered with white-out or otherwise obscured).
At this point, the deadlines to respond to Staff’s ARs have passed, and the Company has
failed to provide the needed information for Staff to complete its audit. Staff and Counsel have
spent a considerable amount of time and energy encouraging the Company’s compliance, without
success. Counsel has notified the Company on several occasions that failure to comply with the
requests for information may result in the imposition of penalties under Idaho Code §§ 61-706 and
61-707, and that employees and officers can also be personally subject to penalties under Idaho
Code § 61-709.
Staff believes that the factual circumstances, along with the adequate notices provided to
the Company, warrant a Notice of Hearing and Order to Show Cause on why the Company should
not be subject to a $2,000.00 penalty per day, and all accrued interest, under Idaho Code §§ 61-
706 and 61-707, and possible additional penalties under Idaho Code § 61-709.
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Hearing and Order to Show Cause
why the Company should not be required by the Commission to:
1. Immediately provide full and complete responses to the Audit Request Questions 1, 3, 4, 6, 7, 9 and 10;
2. Pay up to a $2,000.00 penalty per day, and all accrued interest, under Idaho Code §§ 61-706 and 61-707, and any additional penalties under Idaho Code
§ 61-709 against Company employees and officers, for each day that
responses to the ARs were late in breach of a statutory duty.

DECISION MEMORANDUM 6
COMMISSION DECISION
Does the Commission wish to issue a Notice of Hearing and Order to Show Cause for this
matter for FEBRUARY 22, 2023, at 1:00 pm (MST) directing the Company to appear and explain
why it should not be required to:
1. Immediately provide full and complete responses to the Audit Request
Questions 1, 3, 4, 6, 7, 9 and 10;
2. Pay up to a $2,000.00 penalty per day, and all accrued interest, under Idaho
Code §§ 61-706 and 61-707, and additional penalties under Idaho Code § 61-709 against Company employees and officers, for each day that responses to the ARs were late in breach of a statutory duty;
3. Anything else?

Claire Sharp
Deputy Attorney General

I:\Legal\WATER\Island Park Demand Letter GIOR\memos\ISLW2301_dec1_cs.docx
EXHIBIT 1
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ISLAND PARK WATER COMPANY'S FAILURE TO
SUBMIT REQUIRED DOCUMENTS.
) CASE NO. ISL-W-23-01
) ) AFFIDAVIT OF JOSEPH TERRY
----------------) ST A TE OF IDAHO ) ss. County of Ada ) I, Joseph Terry, being first duly sworn under oath, depose and state as follows: 1.My name is Joseph Terry. I am over 21 years of age, of sound mind, and l have personalknowledge of the facts stated herein.2.The information contained herein is true and correct to the best of my knowledge andbelief.3.I am a Public Utilities Auditor 3 at the Idaho Public Utilities Commission("Commission"). I started working in this position in 2011. I am responsible forauditing and verifying revenues, expenses, rate bases, and capital structure to determinefinancial condition as described in Idaho Code § 61-610.4.In my position I am aware that Island Park Water Company ("Company") failed torespond to multiple requests for information. A true and correct copy of the AuditRequest is attached hereto and incorporated by reference herein as Exhibit 2.5.I have reminded the Company of its obligation to respond to the audit requests, Staffsent emails on August 11, 2022 and August 18, 2022, reminding the Company of theoutstanding Audit Request and the due dates. A true and correct copy of these emailsis attached hereto and incorporated by reference herein as Exhibit 4. I did not receivea response to those emails.6.At this point Staff sent notice of potential legal action through its Counsel. A true andcorrect copy of this correspondence is attached hereto and incorporated by referenceherein as Exhibit 5.7.The first official notice I was directly involved in was a letter sent on August 29, 2022.Exhibit 5. This letter was served with a process server as the previous letters mailed tothe Company's address on file with the Commission were returned as undeliverable.AFFIDAVIT OF JOSEPH TERRY
The Company responded to this letter on September 19, 2022, claiming that it had not received any of the previous attempts to contact it about the audit request. A true and correct copy of the Company response letter is attached hereto and incorporated by reference herein as Exhibit 6. In this response the Company requested a 90-day extension to answer the audit requests. I wish to note that the email address used to respond to Staff was the same email address I used in my attempts to contact the Company described in Exhibits 4, 6. 8.On November 28, 2022, the Commission received the Company's annual reports for2020 and 2021. This fulfilled Audit Request No. 2.9.Again, on December 27, 2022, Staff sent notice of potential legal action through itsCounsel and notified the Company that it would be recommending a show causehearing and penalties under Idaho Code§§ 61-706, 61-707, and 61-709.10.The Company responded to the December 27, 2022 notice via email on January 9,2023, stating its responses had been mailed. The Commission received the Company'sresponses on January 11, 2023. A true and correct copy of the Company's response isattached as Confidential Exhibit 11.11.I reviewed these responses on January 12, 2023. Overall, three responses wereadequate, three responses were somewhat adequate, and four responses wereinadequate.12.The response to Audit Request No. 1 was inadequate. The Company stated theCommission should already have that information because it claimed we did not returnthe previous audit information. This is inadequate because I returned the informationafter the audit was completed as requested by the Company. Additionally, theinformation previously provided is outdated, and I wanted a current customer list.13.The response to Audit Request No. 2 was adequate. The Company provided AnnualReports on November 28, 2022, and included copies of the Annual Reports with itsresponse.14.The response to Audit Request No 3. was inadequate. The Company claims to not havea schedule of its non-recurring expenses. Referencing the Company's tariff and annualreport, the Company is charging customers something that is not in the $280 per yearwater rate.AFFIDA VII OF JOSEPH TERRY 2
15.The response to Audit Request No. 4 was inadequate. The Company sent a blank copy
of a bill and claimed to keep no record of the bills it sends to the customers.
16.The response to Audit Request No. 5 was adequate. The Company supplied two sets of
minutes. One for 2020 and one for 2021. Both sets of minutes were identical except for
the title that included different years. However, the first line in both sets of the minutes
stated the minutes were for 2020. These are red flags for Staff, but still a complete
answer.
17.The response to Audit Request No. 6 was somewhat adequate. The Company provided
a narrative of what plant in service the Company has. However, the response did not
include any values associated with that plant.
18.The response to Audit Request No. 7 was somewhat adequate. The Company did not
provide a list of customer complaints received in 2020 and 2021 as requested. The
Company asserted that the Commission has the list of complaints against the Company.
While the Commission has records on informal and formal complaints against the
Company, the Company has an obligation to document complaints, including those
complaints which are not escalated to the Commission.
19.The response to Audit Request No. 8 was adequate. The Company stated it does not set
budgets.
20.The response to Audit Request No. 9 was inadequate. The Company claims to not have
any accounts receivable, aging reports and claims that it lacks the ability to build such
a report. The Company cannot support this assertion without additional documentation,
which it failed to provide.
21.The response to Audit Request No. 10 was somewhat adequate. The Company sent
copies of its bank statements, but the Company redacted information from those bank
statements. These redactions were not serious, primarily redacting payees for cleared
checks and details of the deposit slips. However, these redactions do compromise the
value of the response for reporting purposes.
22.The Company stated it denies permission for anyone to retain any of their responses in
any manner. However, there was no explanation on why these responses would be
confidential per IDAPA 31.01.01.67.
AFFIDAVIT OF JOSEPH TERRY 3
Dated this 'Z'f day of January 2023.
seph Terry
, ... , ___ _ L__ >
Public Utilities Auditor Idaho Public Utilities Commission
SUBSCRIBED AND SWORN to before me this �day of January 2023.
AFFIDAVIT OF JOSEPH TERRY 4
Notary Publifor Idaho Residing at: lhD j W l DCommission expir�Y)t?ik2,C-lij I�, 2015
EXHIBIT 2
Idaho Public Utilities Commission Brad Little,Govemor
PO Box 83720,Bolse,ID 83720·0074 Paul igellander, commissionerKrisUneRaper,Commissioner
Eric Anderson,Commissioner
July 14,2022
Dorothy McCarty
Island Park Water Company
P.O.Box 2521
Idaho Falls,ID 83403
Dear Ms. McCarty:
It is the policy of the Idaho Public Utilities Commission Staff to do periodic financial and
operating audits of companies under the Commission's jurisdiction.The Idaho Public Utilities
Commission Staffwill be conducting an audit of the financial and other records of Island Park
Water Company for the calendar years ending December 31,2020, and 2021.As part of this
audit,an onsite visit and observation of facilities may be arranged at a later date.Staff requests
that Island Park Water Company provide the followingdata, copies of records,and other
information not later than Thursday, August 4,2022:
Audit Request No.1:Please provide a customer list broken out by subdivision.
Audit Request No.2: Please provide annual reports for the years ending 2020 and 2021.
Audit Request No.3: Please provide a schedule showing all non-recurring fees charged
to customers in 2020 and 2021.
Audit Request No.4:Please provide a copy of all bills sent to customers in 2020 and
2021.
Audit Request No.5: Please provide a copy of the minutes for every Board of Directors
Meeting from 2020 to present.
Audit Request No.6: Please provide a listing of plant-in-service for the Company as of
the end of 2021.
Audit Request No.7:Please provide a list of all customer complaints receive in 2020
and 2021,along with each complaint's resolution.
Audit Request No.8: Please provide a copy of the Company's budgets for the years
2020 and 2021.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]
Dorothy McCarty
Island Park Water Company
July 14,2022
Page 2
Audit Request No.9:Please provide an accounts receivable aging for the years ending
2020 and 2021.
Audit Request No.10:Please provide all Company bank statements for 2020 and 2021.
If it appears that a response will take longer,please call me to work out any necessary
timing changes.Review of the requested documents may require additional written (e-mail)orverbalinquiries.If you have any questions regarding the above audit requests,please do not
hesitate to contact me at [phone] or by e-mail at joseph.terrv puc.idaho.cov.You may
also contact Donn English at [phone] or [e-mail] you foryourcooperationandassistance.
Sincerely,
Joseph Terry
Senior Auditor
e-mail:[e-mail]
EXHIBIT 3
EXHIBIT 4
EXHIBIT 5
State General Counsel and Fair Hearings/Idaho Public Utilities Commission
P.O. Box 83720, Boise, Idaho 83720-0074 Telephone: [phone], Fax: [phone]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A, Boise, Idaho 83714

STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN

August 29, 2022

VIA PROCESS SERVER

Island Park Water Company
Dorothy McCarty
P.O. Box 2521
Idaho Falls, ID 83403

Re: Gross Intrastate Operating Revenue Report & Audit Request – Notice of Possible Legal Action

Dear Ms. McCarty:

The Office of the Attorney General for the State of Idaho submitted its August 1, 2022, demand letter
alerting you that Island Park Water Company (“Island Park”) has failed to submit its 2021 Gross Intrastate
Operating Revenue (“GIOR”) Report as required by Idaho Law. That demand letter was sent via Certified
Mail to Island Park’s address of record at the Commission. The August 1, 2022, letter was returned as
undeliverable, even though it was sent to your address of record. Please update your address of record
with the Commission as soon as possible.

We are also aware that Commission Staff sent an audit request to Island Park’s address of record at the
Commission. Commission Staff made efforts to contact Island Park through email, and allowed a brief
extension for Island Park to respond. That extension has now expired, and Island Park must respond to
the audit request or face penalties under Idaho Code § 61-706.

Sincerely,

Claire Sharp
Deputy Attorney General

Enclosures
cc: Maria Barratt-Riley, Claire Sharp
I:\Legal\WATER\Island Park Demand Letter GIOR\20220829_CvrLtr_GIOR Demand_Audit Req.docx
EXHIBIT 6
EXHIBIT 7
State General Counsel and Fair Hearings/Idaho Public Utilities Commission
P.O. Box 83720, Boise, Idaho 83720-0074 Telephone: [phone], Fax: [phone]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A, Boise, Idaho 83714
STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
VIA PROCESS SERVER
October 4, 2022
Island Park Water Company
Dorothy McCarty
155 E. 23rd Street
Idaho Falls, ID 83404
Re: Failure to Respond to Audit Request – Notice of Possible Legal Action
Dear Ms. McCarty:
We received your responses to our correspondence on September 12, 2022 and September
19, 2022 and Island Park Water Company’s (“Island Park” or “Company”) Gross Intrastate
Operating Revenue (“GIOR”) report. We also understand that you are requesting a 90-day
extension to respond to the audit request.
The Company’s request for an extension of time is not well-taken. First, the Company’s
September 19, 2022 request for an extension to respond to the audit request is untimely. IDAPA
31.01.01.225.03 allows 14 days for you to object or explain why the questions cannot be answered.
The Audit Request was sent on July 14, 2022. Therefore, an objection to these questions would
have needed to be lodged by July 28, 2022. Second, the Company has not complied with routine
audit requests and its responses are long overdue.
The Company’s failure to maintain current contact information on file caused delays and
required the Commission to obtain a process server to deliver routine correspondence to the
Company. Your most recent annual report from the Company, filed August 3, 2020 for the year
ending 2019, stated that your contact address was P.O. Box 2521, Idaho Falls, ID 83403.
Commission Staff sent a physical copy of the audit request to that address. Commission Staff acted
in good faith based on the information you provided, and that you had signed claiming to be a
correct statement. If this address became invalid, then it was incumbent upon the Company to
provide the new address to the Commission.
State General Counsel and Fair Hearings/Idaho Public Utilities Commission
P.O. Box 83720, Boise, Idaho 83720-0074 Telephone: [phone], Fax: [phone]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A, Boise, Idaho 83714
Further, it is inexplicable why the Company only responds to selected emails from Commission
Staff sent to the email addresses on file, but later claims to be unable to use those email addresses.
For example, the email address the Company used to contact Nancy Ashcroft and Terri Carlock is
the exact same email address that received the audit emails on July 28, 2022, as well as the
reminder email on August 11, 2022. This was also the same email address used in the 2020 audit
of Island Park, with which the Company had responded to during that audit. In any case, it is
expected that all regulated utilities keep current contact information on file with the Commission,
and the Company’s failure to update this information does not excuse the Company from its
responsibilities.
Audit Request No. 2 requests you to provide the Annual reports for years 2020 and 2021,
which were due, per Idaho Code § 61-405, to the Commission on April 15, 2021, and April 15,
2022, respectively. The Company response is overdue on these statutorily required reports.
Ms. McCarty has indicated that a medical issue is preventing the Company from
responding to audit requests. If so, and if this medical issue is expected to persist such that the
Company is unable to meet its statutory responsibilities under Idaho Code § 61-302, the Company
needs to immediately implement a plan to remedy this situation. Staff requests that the Company
respond within ten (10) days explaining how the Company intends to maintain the service quality
required under Idaho law, including, but not limited to responding to customer complaints,
emergencies, and water quality testing. Failure to respond within the requested timeline will result
in Staff requesting a motion to show cause with the Commissioners.
The Company’s failure to comply with the requirements of Idaho Code and the
Commission’s Rules of Procedure may result in the Commission imposing penalties under Idaho
Code §§ 61-706 and 61-707. Additionally, Idaho Code § 61-709 states that employees and officers
can also be subject to penalties. The Company must respond promptly to avoid being subject to
penalties. For your convenience the audit request has been attached to this letter.
Sincerely,
Claire Sharp
Deputy Attorney General
Enclosures
20221004_Follow-up Demand Ltr_Audit Req.docx
Idaho Public Utilities Commission Brad Little,Govemor
PO Box 83720,Bolse,ID 83720·0074 Paul igellander,commissionerKrisUneRaper,Commissioner
Eric Anderson,Commissioner
July 14,2022
Dorothy McCarty
Island Park Water Company
P.O.Box 2521
Idaho Falls,ID 83403
Dear Ms.McCarty:
It is the policy of the Idaho Public Utilities Commission Staff to do periodic financial and
operating audits of companies under the Commission's jurisdiction.The Idaho Public Utilities
Commission Staffwill be conducting an audit of the financial and other records of Island Park
Water Company for the calendar years ending December 31,2020,and 2021.As part of this
audit,an onsite visit and observation of facilities may be arranged at a later date.Staff requests
that Island Park Water Company provide the followingdata,copies of records,and other
information not later than Thursday,August 4,2022:
Audit Request No.1:Please provide a customer list broken out by subdivision.
Audit Request No.2:Please provide annual reports for the years ending 2020 and 2021.
Audit Request No.3:Please provide a schedule showing all non-recurring fees charged
to customers in 2020 and 2021.
Audit Request No.4:Please provide a copy of all bills sent to customers in 2020 and
2021.
Audit Request No.5:Please provide a copy of the minutes for every Board of Directors
Meeting from 2020 to present.
Audit Request No.6:Please provide a listing of plant-in-service for the Company as of
the end of 2021.
Audit Request No.7:Please provide a list of all customer complaints receive in 2020
and 2021,along with each complaint's resolution.
Audit Request No.8:Please provide a copy of the Company's budgets for the years
2020 and 2021.
11331 W.Chinden Blvd.,Building 8 Suite 201-A,Boise ID 83714
Telephone:[phone] Facsimile:[phone]
Dorothy McCarty
Island Park Water Company
July 14,2022
Page 2
Audit Request No.9:Please provide an accounts receivable aging for the years ending
2020 and 2021.
Audit Request No.10:Please provide all Company bank statements for 2020 and 2021.
If it appears that a response will take longer,please call me to work out any necessary
timing changes.Review of the requested documents may require additional written (e-mail)orverbalinquiries.If you have any questions regarding the above audit requests,please do not
hesitate to contact me at [phone] or by e-mail at joseph.terrv puc.idaho.cov.You may
also contact Donn English at [phone] or [e-mail] you foryourcooperationandassistance.
Sincerely,
Joseph Terry
Senior Auditor
e-mail:[e-mail]
EXHIBIT 8
State General Counsel and Fair Hearings/Idaho Public Utilities Commission
P.O. Box 83720, Boise, Idaho 83720-0074 Telephone: [phone], Fax: [phone]
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A, Boise, Idaho 83714

STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWRENCE G. WASDEN
VIA PROCESS SERVER

December 27, 2022

Island Park Water Company
Dorothy McCarty
155 E. 23rd Street
Idaho Falls, ID 83404

Re: Second Notice of Failure to Respond to Audit Request – Notice of Possible Legal Action

Dear Ms. McCarty:

The Commission has not received Island Park Water Company’s (“Island Park” or
“Company”) response to Staff’s Audit Request, notwithstanding a generous time extension to
accommodate the operator’s personal circumstances. Because of Island Park’s continued delays
and failure to comply with the requirements of Idaho Code and the Commission’s Rules of
Procedure, we are recommending that the Commission pursue a show cause hearing and penalties
under Idaho Code §§ 61-706, 61-707, and 61-709.
If Island Park wishes to avoid a show cause hearing, the Company needs to submit a full
and complete response to the Audit Request within ten (10) days from the receipt of this letter.
As a courtesy reminder, filings of applications and other pleadings with the Commission
will be deemed filed when the electronic submission is received by the Commission Secretary. See
Commission Rule of Procedure 14.02, IDAPA 31.01.01.014.02. The Commission does not accept
filings or responses sent to personal phone numbers of Commission Staff. Please send all
correspondence by email to [e-mail] or by mail to: Public Utilities Commission,
11331 W. Chinden Blvd. Building 8, Suite 201-A, Boise, ID 83714.
Sincerely,

Claire Sharp
Deputy Attorney General

Enclosures
I:\Legal\WATER\Island Park Demand Letter GIOR\word docs\20221227_Follow-up Demand Ltr_Audit Req.docx
EXHIBIT 9
1
Claire Sharp
From:[e-mail]
Sent:Wednesday, January 4, 2023 3:25 PM
To:Claire Sharp
Cc:[e-mail]
Subject:Receipt of Letter
Importance:High
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any
concerns.
Island Park Water Company
Attention Claire Sharp
Date January 4, 2023
This email acknowledges that I received your letter today regarding the requested information for the
Audit and to assure your that I will do everything possible to see that the information is sent to you
within the next ten days. I just wanted to clarify this so you know.
I sincerely appreciate your patience and understanding. Please know I was not ignoring this
and had reached out to Joseph Terry via email but had not heard a response back from him.
Please know that I will inform you the day the information is mailed and will send via overnight
delivery directly to Joseph Terry at the address provided.
Thank you again for your patience.
Sincerely,
Dorothy McCarty
Island Park Water Company
EXHIBIT 10
EXHIBIT 11
CONFIDENTIAL