20100524Water Loan Letter of Interest, etc.pdf

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January 13,2010
Idaho Deparment of Environmental Quality
ATTN: Nancy Bowser
1410 N. Hilton
Boise, ID 83706
MNV-Lz- tD-Of
RE: Deparent of Environmental Quality Drinking Water Planng Grant or Drinking
Water Loan Letter of Interest Submitted on Behalf ofMomingview Water Company.
Dear Ms. Bowser:
Enclosed is a completed Department of Environmental Quality Drinking Water Planning
Grant or Drinking Water Loan Letter of Interest submitted on behalf of Morningview Water
Company of Rigby, Idaho. We have completed the attached form to the best of our understanding,
and provide this letter in accordance with the form's instrctions to submit additional explanation
regarding various steps located on the letter of interest form. We have also enclosed exhibits, which
we believe will help you understad the current difficult situation Mornigview Water Company is
in, and why we are applying for both a planing grant and a loan.
Attached at Exhibit A is a cover letter and consent order executed by Momingview \Vater
Company on October 18, 2007. The consent order was necessar because of pressure problems
Mornngview faced in its system. The Mornngview water system generally consists of two pmnps
and wells that divert into a common system. After various reports of pressure problems below 40
psi, IDEQ investigated Mornngview, and ultimately the paries entered into the consent order to
address some of the deficiencies identified by IDEQ in the system. To date, Momingview has met
most of the requiements of the consent order, but there remain unesolved signficant issues relating
to capital improvements that need to be made on the system. After the consent order was entered
into, IDEQ determined that there were additional violations, and had indicated its desire to proceed
forward with the filing of a complaint against Morningview. A draft complaint is attached as
Exhibit B.
In an effort to resolve the matter amicably, IDEQ has entered into additional negotiations
with Mornngview to char a path forward to resolve these issues. In discussing the contents of that
consent order, it became evident that Morningview needed to secure additional funding to perform
the additional improvements. Unfortunately, with the recent downturn in the economy, and the
tightening of bans in loaning money, Momingview has been unsuccessful in obtaining private
financing to fund the capital improvements identified in its original facility plan. Additionally,
Morningview is a private corporation, and due to the disapproved status of its system, was informed
Idaho Dept. of EnyirolU11ental Q( )y
ATTN: Nancy Bowser
January 13,2010
Page 2 of6
that it does not qualify for any type of state or federal fuding to improve its system. After additional
investigation, and the provision of additional information by IDEQ to Morningview, it was
detennined that Morningview may qualify for a loan provided they submit the letter of interest
attached hereto.
Mornigview and IDEQ have recently negotiated an amended consent order, which we
anticipate to be completed within the next seven (1) days. Once the amended consent order is agreed
upon aiid executed, we will provide a copy of the amended consent order and request that it be
attached as an addendum to the enclosed application in this letter.
Specifically regarding the various sections of the letter of interest, we provide the following
descriptions and/or additional information.
Step 1: In discussing Morningview's situation with IDEQ loan officials, staff people, and
their attorneys, it has been determined that Morningview should and is applying for both a
constrction loan and a planng grant. The grant is necessary for Morningview to complete some
additional work on its facility plan in order to finally be approved by IDEQ. The grant would go
toward paying of engineering costs, and environmental assessments that may be required in order
for the facility plan to be implemented.
Additionally, Morningview seeks a constrction loan to malee, in order of the following
priority, these improvements:
1. Installation of varable speed drives for both pumps.
2. Instalation of approximately 25 meters on one acre lots within the Morningview subdivision.
3. Performance of pllllp testing on Morningview's existing two pumps, to determine whether
or not a third well will be necessaiy for the Morningview water system.
4. Installation of a backup generator. .
5. If necessary, construction of a i'ew municipal welL.
Step 2: SECTION 2: We have checked four boxes under Section 2 of Step 2 of the LOl form.
The form requests that we provide documentation to support aiiy statement for which the answer was
yes. The first box checked yes is under the portion of the LOI stating that "no reports of water borne
illness and low potential for such exists." The consent order attached at Exhibit A docwnents the
pressure deficiencies the Morningview system has faced. Under IDAP A 58.01.08.552.0. .b.v, the
Idaho Rules for Public Driing Water Systems, it requies that "when pressures within the system
are known to have fallen below 20 psi, the water system must provide public notice and disinfect the
system." Therefore, when pressures drop below 20 psi, there is the potential for contamination
withn the system. While all ofMornngview's water quality samples have shown no water quality
cOhtanlÎnation, the low pressure issues experienced by Momingview would increase the potential
for a public health hazard.
Idaho Dept. of Environmental Q",
ATTN: Nancy Bowser .
January 13,2010
Page 3 of6
In addition, Mornngview has checked all three boxes under the general condition of the
system. Next to the heading of this section, it requests that we provide docunientation, such as an
engineer evaluation. Enclosed as Exhibit C is a final facility plan for Morningview Water Company
prepared by Ryan Loftus of Aspin Engineering, Inc. The recommendations in the repoli have
preliminar been accepted by IDEQ, but IDEQ has found the report deficient in that it does not set
forth a time line for the capital improvements. Other than tiiis deficiency of a lack of time line, it
appears tIiat the facility plan meets IDEQ standards. Specifically regarding the general condition of
the system, there are infastiuctue deficiencies of pumping facilities, and insufficient capacity to
meet pressure and customer demand, and other system deficiencies related to lack of meters on tiie
system. As stated above, we have a priority list of five major capital improvements which we
believe wil signficantly improve customer satisfaction and improvement of the system.
Additionally, witIl the installation of variable speed drives, we believe that this will improve energy
efficiency throughout the system, and be a major improvement over the curent manual operation
of the two wells.
Morningview has been subject to a consent order, a copy of which is attached at Exhibit A.
The consent order does require mandatory public notification, and in particular, informing users on
tiie Morningview system that they system is currently in a disapproved status. Under Section 2 of
LOI, it requests a discussion if we are seeking hmding for "a phased approach to your systems needs
when if tiie phase in strategy has been discussed with the DEQ regional engineer." We have
proposed a phased-in strategy to improve the system. Because Morningview is a private company
and is subject to the regulations of the Public Utilities Commssion, costs for capital improvements
performed pursuant to loan proceeds will need to be recouped though fees charged to consumers
on the system. As such, fiscal responsibility requires that it may be implemented in a phased in
approach. We anticipate installing the variable speed drives immediately upon receipt of any loan
proceeds, and securing the meters for the one acre lots within the Mornigview subdivision, as water
use on those lots have significantly strained the system. With these two immediate items addressed,
the otIier prioritized capital improvements can be addressed in a fiscally responsible maner.
Lastly,' there has not been an officially declared or designated public health hazard or
emergency tIiat has been certified by IDEQ. However, give the consent orders, and the multiple year
process in resolving this issue between IDEQ and Mornigview, we submit that the curent situation
is of immediate concern toIDEQ.
SECTION 3: Under Section 3, it requests information relative to management based efforts
to determine the costs of our efforts. Anticipated costs of our proposed improvements is generally
outlined in the final facility plan, with the one exception that we are not proposing meters for all of
tiie lots within the Morningview system. The Morningview subdivision consists of a number of one
acre lots, half acre lots, quarer acre lots, and much smaller trailer lots. In an effort to be as cost
effective as possible, Morningview is proposing to meter tiie high users, who significantly irrigate
the one acre lots withn the subdivision. If it is determined at a later date that the half acre and
quarer acre lots need to be metered, then tIl0se meters could be installed at a later date in a fiscally
responsible maner. Additionally, in an effort to prioritize those needs within the system, it is more
Idaho Dept. of Environmental Q(
A TT: Nan~y Bowser .
January 13,2010
Page 4 of6
likely that a new well would be needed prior to installation of meters on the half acre and quarer
acre lots.
Under Paragraph 2 of Section 3, it asks for an explanation of the management base
sustainability initiative efforts that you wil engage as par of the project. Notable, it mentions the
installation of variable frequency drive pumps. Based upon the recommendations of our engineer,
and comments from Mornngview water users received at a meeting held in June 2009 to discuss the
system deficiencies and how to improve them, the general consensus was to first install variable
frequency drive pumps on both Morningview pumps. In addition to the savings received hom the
more energy efficient drives, the variable frequency drives would also allow the \'vt i Is to
"cornnunicate" with one another to maintain a more constant pressure within the system.
Additionally, we propose the installation of water meters on the approximate 25 lots within the
subdivision that are one acre in size. Morningview's observations over the years has been that there
has been significant water usage on these lots for ilTigation purposes, and we believe metering such
uses would encourage these homeowners to implement greater water conservation measures, which
wil lessen demand on th system, and improve pressure and service to other members of the
subdivision. Section 3, Par 2 requests documentation supporting the technology based efforts. The
benefits of the meters, are set forth in the final facility plan, and it is generally understood that from
cornnunications from IDEQ officials, this will substantially reduce water usage.
Under Paragraph 3 of Section 3, it requests that we explain the construction practices
sustaiability initiative efforts that we will engage in as par of our project. The construction eff011s
willbe performed using generally accepted engineering principles for the installation of the variable
speed drives and the meters. However, it is also proposed that Morningview explore the opportunity
to use an existing capped ilTigation well that was drilled in the late 1970s as an additionall1unicipal
welL. Whle the well does not meet current IDEQ standards for casing for public water systems,
Morningview hopes to explore potential use of the well as a third well for the subdivision. In effect,
this would recycle or reuse the existing well on the property, which would potentially save costs to
conswners. Obviously, if ths well is used, it would need to be constructed in a manner that would
protect the public health and safety of those within the Morningview system. Nevertheless,
Morningview is committed to determine whether or not this well could be used.
SECTION 4. Paragraph 1. We estimate that the total cost to prepare a facility plan or
engineering report, and to prepare any environmental information document, enviroil11ental
assessments, or environmental impact statements, to be approximately $30,000.00. Regarding our
interest in receiving a planing grant, question 2 of Paragraph 1 of Section 4 asks if we would have
our 50% required matched fimds available within the next twelve months. We believe we would
. have the fuds available, but would use the loan proceeds requested under this letter of interest to
match the grant amount. In other words, we believe the 50% requied match will be available if the
loan is also granted. We have been informed by IDEQ offcials that loan money could be used in
this maner. Under Paragraph 2 of Section 4 it asks whether a facility plan or engineering report has
bèen completed. The final facility plan has been preliminarily accepted by IDEQ, but has not been
Idaho Dept. of EnvironmentaJ Qi )
ATTN: Nancy Bowser
January 13,2010
Page 5 of6
formally approved because of additional plaiming regarding time lines that would need to be
implemented into the plaii.
We estimate that approximately $275,000.00 would be needed to correct the problems
identified in the facility plan and engineering report. This amount would be for the totality of the
capital improvements so requested, but as indicated previously in tins letter, we must proceed in a
fiscally responsible maner so as to not burden Morningview"with excessive debt, or substantial
increase in the rates of the Momigview consumers provided the public utilities commission
approves a rate increase to offset the cost of tiie loan. We estimate the cost for the variable speed
drives to be approximately $10,000.00. We estimate that each meter would cost approximately
$2,000.00, and for 25 homes, estimate this to equal $50,000.00 . We anticipate testing of the existing
tapped irrigation well to be approximately $10,000.00. To the extent a new well is requied to be
driled, we estimate this cost to be approximately $150,000.00. And lastly, we anticipate a backup
generator to cost approximately $40,000.00. Ifwe also include the $15,000.00 that would be used
for our grant match, the grand total for all of these improvements is $275,000.00.
Regarding the communty's interest to proceed on the project, attached as Exhibit D is a letter
sent to all Morningview water customers to attend a June 9th meeting in tiie Rigby City Library to
discuss the pressure problems with the Monnngview system. A majority of those there were
interested in cost effective solutions, but did express tIieir frustration over the issues that were
currently facing the system. Overall, tiie patrons seemed interested in improving the system iii a cost
effective manner.
Additionally, under Section 4, the LOI asks whether financial documentation is in place or
does the system of legal autIiority to incur the debt associated with tiie proposed project.
Morningview Water Company is a private company, aiid can therefore incur debt. The detemiination
of how Mornngview can repay the loan will be subject to PUC approval.
Summary: To the extent aiiy additional information is requied, we would be happy to
provide it immediately. As indicated in the consent orders, the Mornngview system has been a
concern for IDEQ for a number of years. In our dealings with IDEQ officials, they have been patient
and helpful in working towards a resolution, but at ths point, all paries desire to improve the
system. Financing has been the primar hurdle for malcing the improvements, but with a loan aiid
grant from IDEQ, we believe that the system can be brought back to an approved status. We very
much appreciate your consideration of this application. If it is deficient in any respect, please notify
us immediately, and we will provide tiie necessary information as soon as possible. We look forward
to receiving word of whether or not Morningview qualifies for the grant and/or loan requested in the
LOI.
Idaho Dept. ofEnviromnental Q()Y
ATTN: Nancy Bowser ....
January 13,2010
Page 6 of6
Best Regards,~t-~
Robert L. Hars
HOLDEN, KIDWELL, HAHN & CRAPO, P.L.L.c.
Enclosures
c: Morningview Water Company
Lisa Kronberg, Deputy Attorney General
G:\WPDATA\RLH\9348-06 Gneiting\Nancy Bowser, IDEQ It i' 0113 i O. wpd:cdv
Department of Environmental Quality
Drinking Water PLANNING GRANT or
Drinking Water LOAN LETTER OF INTEREST
FORMA
STEP 1. Decide if your community is interested in pursuing a DEQ Drinking Water
PLANNING GRAT or a DEQ Drinking Water LOAN by answering the following questions. It
is strongly recommended that you work closely with your engineering consultant to complete this form.
1. Do you need to make improvements or upgrade your public drinking water system? YES il NO 0
· Proceed to QUESTION #2 if you answered YES and are interested in being rated and placed on the new
fiscal year's planning grant or Ioan priority list for FY 2010. .
· If you answered NO, you wil not be placed on the new fiscaI year's priority list. DEQ wil notify you next
year when the grant and loan process begins. If you answered NO, please do not complete or submit this
form toDEQ.
2. Has your community completed a drinking water facilty plan or engineering report (with a final
environmental determination) in the last five (5) years or is one in progress now?
YES (we are interested in a construction loan) il
NO (we are interested in a planning grant) Il
· If you answered YES, are you ready to design and constrct your project? If so, and you want your project
rated and placed on the drinking water loan priority list, please proceed to STEP 2 and compIete Sections 1,
2,3 and 4B.
· If you answered NO, you need to do some planning work. If you are interested in receiving a drinking
water planning grant, pIease proceed to STEP 2 and complete Sections 1, 2,3 and 4A.
STEP 2 PROJECT INFORMTION - Please provide complete and accurate answers to
receive the highest possible rating for your drinking water system.
SECTION 1: SYSTEM ID,ENTIFICATION System PWS No. ID 7260063
System Name MORNING VIEW WATER COMPANY
System Address P.O. BOX 598
Population Served 265
Owner's Name NOLAN GNEITING
City RIGBY State ~ Zip 83442
System Ownership (Check one): For Profit ~ Not for Profit_
Owner's Phone # [phone]
Contact Person/Title (If different from owner)
Address
Phone No.
City
FAX No. 208-745-0041
State Zip
Email Addressmomingviewhomes(Qqwestoffce.net
SECTION 2: DRl1naG WATER SYSTEM PROBLEMS
Is your drinking water system experiencing any of the following problems? Ifso, check YES to ALL that apply. Then,
describe the problem(s) and provide documentation to support any statement for which the answer was YES on a separate
sheet of paper.
1
Public Health Emergency
. Waterborne ilness outbreak
· Acute microbiologicaI, chemical, radiological, nitrate or E-coli
source contamination problems
. Failed primary water source
YES D NOIl
YESD NO~
YESD NO
Public Health Hazard
. Recorded evidence of waterborne ilnesses
. Reported ilnesses may be waterborne
· No reports of waterborne ilnesses, but high potential exists
· No reports of waterborne ilness and low potential for such exists
YEsD NO~
YESD NO~
YES D NO ii
YES Il NO D
Water Quality Violations
. Ongoing chemical contamination violations
. Ongoing bacterial contamination vioIations
. Surface water treatment rules violations
. Identify constituents in violation:
YEsD NO~
YES D NO i!
YESD NO~
General Condition of System (provide documentation other than sanitary survey, e.g. engineer evaluation)
· Infrastructure deficiencies of pumping facilties, distribution lines, or treatment facilties, YES Il NO D
· Inadequate or deficient storage, capacity to meet pressure or customer demand, etc. YES ii NO D· Oter system deficiencies YES (!0 D
Has your public water system been subject to any of the following corrective measures recently?
Compliance Agreement: YES D NO D Administrative or consent orders: YES Il NoD
Drinking Water Advisory Issued (e.g. boil water advisories, mandated public notifications, etc.): YES Il NO D
On a separate sheet, describe the issues that you have provided a "Yes" response to above, providing any support
documentation that wil assist in an understanding of the problem/s. Please discuss if you are seeking funding for
a phased approach to your system's needs and if the phasing strategy has been discussed with the DEQ Regional
Engineer. Describe the alternative selected to correct the identified probIem(s). Use the selected alternative in the
facilty plan. Does an officially* declared or designated public health hazard or emergency exist? (*Certifed by
DEQ or Health Dept. Board.) Label this description as Section 2.
SECTION 3: BOi\'(S POINTS QUESTIONS. (Check YES to all that apply):
· Is your source water assessment done?
· Have you established a protective zone around your well(s)?
· Have you established a drinking water system replacement fund?
· Do you have an active backflow protection program in place?
· Do you have a conservation-oriented rate structure (meters)?
· Do you have licensed operators for your system as required under IDAP A 58.01.08?
. Is your system current on monitoring requirements?
YES (ioD
YES~NODYESpOD
YES NoD
YEsD NO~
YES PODYES NoD
Sustainable Infrastructure Initiatives ("Green Infrastructure")
1. Management-based efforts. Please explain the management-based sustanabilty initiative efforts your
system wil engage in as par of the project and the cost of the effort. Management-based efforts could
include (but would not be limited to):
Implementing a capital budget that is funded, and is supported by a capital improvement plan;
Implementing a formal asset management system (using a tool such as EPA's CUPSS);
2
Implementing sustainable design principles, including energy effciency and design for disassembly;
Implementing a formal environmental management system (exemplified by ISO 14001
Certification);
Implementing a system consolidation (i.e. public/private, small/large);
Implementing a SI benchmarking progråm;
Funding the provision of water efficient fixtues for the community;
Applicant has an energy audit and plans on implementing the suggestions of the audit;
Applicant is an EPA GreenPower parer.
Include documentation supportng the management-based efforts. Label the documentation as Section 3,
Part i. Some green infrastructue related websites include:
htt://www.epa.govlcupss/
http://en.wikipedia.org/wiki/ISO 14001
http://n,'W.iso 14000-iso 14001-envirolUnental-management.coini
htt://www.iso.org/iso/iso 14000 essentials
http://ww .energystar.gov/index.cfm?c=evaluate performance. bus portoliomanager;
,http://ww.energystar.gov/index.cfm?c=evaluate performance. bus portoliomanager benchmarking;
http://www .epa.gov/region09/waterinfrastructure/benchmark.html http://www.epa.gov/greenpower/
http://wvvw.nema.org/gov!energy/effciencyipremium ; http://www.nema.org/stds/complimentary-
docs/uploadfMG Ipremium.pdf.
http://www.ceeI .org/ind/mot-svs/mtr-ms-main.php3
2. Technology-based efforts. Please explain the management-based sustainabilty initiative efforts your
system wil engage in as part of the project and the cost of the effort. Technology-based efforts could
include (but would not be limited to):
On-site energy generation, such as:
· Fuel cells
. Solar
. Wind;
Installation of variable frequency drive pumps;
Installation of turbines /hydrogen era tors in pipelines;
Installation of premium energy-effcient motors that exceed NEMA definition;
Constrction/renovation of buildings that incorporate LEED criteria;
Installation ofleak detection equipment;
Installation of water meters and water conservation measures that meet the EPA Green Project Reserve
guidance document's requirements (Items A-7 and A-9). The guidance document is located at
.chttp://ww.deq.idaho.gov/water/ara/green..rojectJeserve_ q&a. pdf:;
Implementing energy effciency savings of20% or more;
Installation of green roofs;
Include documentation supporting the technology-based efforts. Label the documentation as Section 3,
Par 2.
3. Construction practices. Please explain the construction practices sustaÍnabilty initiative effort your
system will engage in as par of the project and the cost of the effort. Constrction practices efforts could
include (but would not be limited to):
Use of a brownfield site for the facilty, use of recycled materials for facilty construction and design
for deconstruction.
Include documentation supporting the construction efforts. Label the documentation as Section 3,
Part 3.
3
SECTION 4: SYSTEM READINESS TO PROCEED WITH PROJECT.
1. Drinking Water Planning Grant -- What's the estimated total cost (DEQ + your match) to prepare
your facility plan/engineering report? $30,000.00 Has the cost of preparing an Environmental
Information Document, as one of the required elements of a facilty pIan/engineering report, been included in the
price above?
If interested in receiving a planning grant, wil you have the fifty percent (50%) required match funds availablewithin the next twelve (12) months? .
If loan is granted
Drinking Water Loan -- Has the facility plan/engineering report been completed (and a finaI
environmentaI determination issued)?
2.
YES Ij NoD
Title of Document FINAL FACILITY PLAN DEQ Approval Date Nolyelapproved
Describe the selected alternative to correct the problem(s) identified in the facilty plan/engineering report.
First to install variable speed drives to improe pressure and energy effciency; Second to install meters on one-acre lots; Third to test existing well to determine
feasibilty of well for new well; Fourth, to install new well, if needed, to improve system; and Fifth, to install backup generator.
Estimated cost to correct the problems identified in the facilty plan/engineering report $275,000.00
Briefly describe indicators or actions that reflect the community's interest or readiness to proceed on this project
(e.g. minutes from public hearings).
Morningview Water Company had a meeting with its patrons in June 2009 to discuss solutions
to pressure problems. A majority of the patrons were interested in cost-effective solutions.
Monthly User Service Rate:
What is the current average monthly user
service rate?
What is the projected average monthly user
service rate impact from the change to
operation and maintenance cost after
implementation of this project?
What is the number of equivalent dwellng
units served by your system?
$40.94 (1/4 acre); $41.66 (1/2 acre); $49.48 (1 acre)
Rates would need to be increased to pay for improvements.
106
Is financial documentation in place or does the system have legal authority to incur the debt associated with
the proposed project?
Choose one
D The system does not yet have legal authority to incur this debt.
D Bond council or financial consultant retaned.
Date of proposed bond election (if applicable).
Il Legal instrument( s) in place (e.g., bond election, judicial confirmation, etc.).
Wh t. th t f d bt th t bIll. d? puc approval (Momingview is a private company)a is e amoun 0 e a can e ega y incurre .
4
I understand that if awarded a grant, costs incurred prior to the awarding of the grant are not eligible for reimbursement.
Likewise if awarded a loan, costs incurred prior to the awarding of the loan are not eligible for reimbursement.
I certify that, to the best of my knowledge, all informati()n providedJiere is valid and correct:
Authorize S;gnat ~- ,~Jtle.øM~-"'" Date /- Á?-:Oí i ~ .'I
Return cOlTpleted form to:
Idaho DEQ
1410 N. Hilton
Boise, ID83706
, Attn: Nancy Bowser
5
Exhibit A
11-...... ....ii.. ""..1.&t=ua- ,-r;J-UU"'.L ¡v. c;
.'
e STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
1410 Nort Hil~n. Boise. 1083706-1255' [phone] C.L. "Butch" Oter. Governor
Toni Hardesty. Oirector
October 9, 2007
CERTIFIED MAIL:
RETURN RECEIPT REQUESTED
Mr. Nolan Gneiting
Morning View Water Company
P.O. Box 598
Rigby, 10 83442
Upon receipt of the signed Consent Order we wil obtain the Director's signature and mail a fully executed
copy to you for your records. Thank you for your attntion to this matter.
Sincerely, ~
Bs. ll. i
Barry N. Burnell
Water Quality Division Administrator
BNB:jt
Enclosure
c: Courtey Beebe, Deputy Attorney General
Greg Eager. Idaho Falls Regional Engineering Manager
Rochelle Mason, Idaho Falls Regional Ofce
Enforcement File
COF
"---.. -..----"D
',: ..
IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY
In the matter of:)
)
)
)
CONSENT ORDER
Idaho Code § 39-108
Morning View Water Company
1. Pursuant to the Idaho Environmental Protection and Health Act, Idaho
Code §§ 39-101 through 39-130, the Idaho Department of Environmental Quality
(Department) enters into this Consent Order with Morning View Water Company,
(Morning View). Morning View owns and/or operates a communit public water
system (System), PWS ID7260063, which serves 97 connections and
approximately 200 persons on a daily basis in Rigby, Jefferson County, Idaho.
2. By letter dated October 21,2003, the Department notified Morning View
that an enhanced sanitary survey conducted on October 9, 2003 resulted in the
discovery of several significant deficiencies. Morning View was required to
submit a plan to correct the signifcant deficiencies within 45 days of notification
in accordance with IDAPA 58.01.08.302.03. Morning View did not submit a plan
to correct the significant deficiencies.
3. On July 5, 2007, the Deparbent investigated and verifed complaints
regarding inadequate pressure within the System. A 24-hour pressure wheel
indicated that pressure fell below 20 pounds per square inch (psi). By letter dated
July 6,2007. the Department notified Morning View of the Department's
investigation and required Morning View to remedy pressure problems within ten
(10) days through the process outlined in Idaho Rules for Public Water Systems,
IDAPA 58.01.08.552.01.b.ii.
4, By letter dated July 25,2007, the Department notifed Morning View of the
results of additional pressure testing conducted at five (5) connections during a
July 23, 2007 inspection. The average water pressure in the System during this
inspection was 22 psi. The letter also notified Morning View of the requirement to
provide public notification and to properly disinfect the distribution system at
times that pressure drops below 20 psi. as was recorded by the 24-hr. pressure
wheel on July 5,2007, and required by IDAPA 58.01.08.552,01.b.v. The
Department required Morning View to diagnose and correct the quantity and
pressure problems in the System and notify the Department by August 6, 2007.
5. By letter dated August 8,2007, the Department notified Morning View of
the failure to notify the Department of the diagnostic and corrective actians taken
to resolve the pressure problems.
6. By letter dated August 15. 2007, the Department notified Morning View
that the System was disapproved due to failure to maintain adequate pressure.
Morning View Water Company
Consent Order
1
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- - - - - ._-..-_.._.1 _iiii¿. 'I¿"'ó ~Ug- , "T,.-UUï.L
7. By letter dated September 24,2007 and addressed to Mr. Nolan Gneiting.
the Idaho Bureau of Occupational Licenses indicated the operator is not currently
a licensed drinking 'water operator, as required by IDAPA 58.01.08.554.01.a.
8. By Notice of Violation (NOV) dated September 12, 2007, the Department
notified Morning View of violations of the Idaho Rules for Public Drinking Water
Systems, IDAPA 58.01.08. The NOV is incorporated by reference into this
Consent Order. The NOV provided Morning View an opportunity for a compliance
conference to discuss the violations and enter into a consent order. A compliance
conference was held on September 26, 2007.
9. Morning View hereby agrees to perform the following actions in the time
periods set forth in order to achieve compliance with Idaho Rules for Public
Drinking Water Systems, IDAPA 58.01.08:
a. Significant Deficiencies. Within thirt (30) days of the effective date
of this Consent Order, Morning View will respond in writing to the
Departent indicating what actions.wil be taken to address the signifcant
deficiencies noted on the October 9, 2003 sanitary survey ånd a timeline
for corrective measures, in accordance with IDAPA 58.01.08.302. All
actions and timelines will be subject to the Departent Submittal Review
Process as described in Paragraph 10.
i. No later than 30 days from the effective date of this Consent
Order, Morning View shall schedule a sanitary survy with the
Department to confirm all deficiencies and any other system
components that the Department determines to cause, or have
potential to cause, risk to health or safety, or that could affect the
reliable delivery of safe drinking water have been properly
addressed and/or corrected in accordance with IDAPA 58.01.08.
b. Public Notice. Effective immediately, Morning View shall provide
quarterly public notices to each residence on the System by mail or hand
delivery. the public notices shall inform the residents of the Department's
disapproval of the System, and shall identify the violations in the NOV
dated September 12, 2007, in accordance with IDAPA 58.01.08.150.
i. Morning View shall continue to provide quarterly public notices
until such time as the Department notifies Morning View in writing
that quarterly notices are no longer required.
ii. Morning View shall provide the Department with proof of
each quarterly notification via the Departent's supplied
notification form and a copy of each quarterly notification
within ten (10) days of completion in accordance with IDAPA
58.01.08.150.
Morning View Water Company
Consent Order
2
¡v. '"
---- --. -
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.._.._'. _...... l;."le LUU ,.l¡ UU"".L
(; Pressure Maintenance. No later than ninety (90) days from the
I effective date of this Consent Order, Morning View shall submit to the
.. Department a written plan detailing how Morning View wil ensure that the
. System shall be made capable of maintaining a minimum pressure of fort
(40) psi throughout the distribution system, dunng peak hourly demand
conditions, excluding fire flow, measured at the service connection or
along the property line adjacent to the consumer's premises, in
accordance with IDAPA 58.01.08.552.01.b.ii. The plan shall include, but is
not limited to;
i. The results of a local pressure monitoring study, conducted
in accordance with IDAPA 58.01.08.552.01.b, to diagnose and
correct pressure problems within the System.
\ií. Assurance that the individual booster pump installed at 200
N. 3987 wil cause no adverse effcts on System operation,
including acknowledgement that any future installations of
individual booster pumps wil be subject to Department approval
per IDAPA 5B.01.08.552.b.iv.
\
;
The Departent shall review, comment and/or approve the plan as
specified in Paragraph 10 ofthis Consent Order.
~(d. Facilty Plans. No later than ninety (90) days from the effectiveate of this Consent Order, Morning View shall submit to the Department
a detailed facility plan in accordance with IDAPA 58.01.08.502. The
Department shall review, comment and/or approve the facilty plan as
speaified in Paragraph 10 ofthis Consent Order.
e. Licensed Operator. Within thirty (30) days of the effective date of
this Consent Order, Morning View shall submit documentation to the
Department for a licensed Responsible Charge Operator in accordance
with IDAPA 58.01.08.554.02.
i. Morning View agrees to contract with a licensed operator
until such a time that Morning View can license their own operator.
Morning View agrees to provide the Department with a copy of a
signed contract with a licensed operator and an invoice for services
within thirt (30) days of the effective date of this Consent Order.
f. Sampling Plan. Within thirt (30) days of the effective date of this
Consent Order, Morning View shall submit for Department approval a
sampling plan that addresses bacteria monitoring in accordance IDAPA
58.01.08.1 00.01.a., which adopts by reference 40 CFR 141.21. The
bacteria sampling plan shall identify monitoring locations of routine
Morning View Water Company
Consent Order
3
t" 0 ..
V4:BI .iL .LU A.'¡c;ïwCl nULcin unei~inl?ëUtl--(..~ -UU"l 1
monitoring and how the system will address repeat and routine monitoring
following coliform and/or fecal coliform presence results. Upon the
Department's written approval of the sampling plan, the plan shall be
incorporated by reference into this Consent Order and shall be
enforceable as provided by applicable law.
g. Sand Separator. Morning View shall collect a water sample from
each welL. The sand concentration from each well shall be determined and
added together. The resulting average shall be utilzed to determine sand
production from the water supply. A total of four (4) sampling events shall
be required. The first sample is due by October 31,2007 with subsequent
sampling conducted in the months of March, April, and May. The
Departent shall be contacted prior to all sampling events. All sampling
shall be conducted as follows:
i. Water shall be drawn from a sampling tap installed prior to
the pressure tank(s) and collected into a clean 5-gallon container.
Water should be collected in a manner which permits the water to
f1t?w into the container in a circular pattern, creating a centrifugal
force that shall force suspended solids to the center of the
container. The duration of time taken to fil the container shall be
recorded and flow rate determined.
ii. Solids shall be decanted from the water and measured in a
graduated cylinder to determine the concentration of suspended
solids present in the 5-gallon solution. The concentration shall be
recorded in parts per milion (ppm).
iii. Should any sample described in Paragraph 9.g.i result in a
concentration offive (5) ppm or greater, Morning View shall submit,
for Departent approval, a monitoring plan to evaluate sand
production from the water supply wells utilzing a Rossum Sand
Tester, which shall include the actions to be taken to reduce sand
concentration in the water to five (5) ppm or less, and the timelines
to achieve compliance, in accordance with IDAPA
58.01.08.510.06.b.
iv.. Morning View shall submit a statistical analysis of the
sampling results,to the Department by no later than June 30, 2008
before a determination of the need for sand removal by the
Department is made, Samples collected as described in Paragraph
9.gj resulting in a concentration of less than five (5) ppm shall
require no further action as a result of this Consent Order.
V. In lieu of conducting sand sampling, Morning View can
choose the following options:
Morning View Water Company
Consent Order
4
po Ö
ClI'~ "' 01.. 0 awCI Iluiciri l.rilCl.lWl.nc:C:Ut:- '''~-UU''i p. '(
a. installng a Department approved sand separator.
b. installng a Department approved well screen in each
well.
h. Dead End Mains. No later than thirt (30) days from the effective
date of this Consent Order, Morning View shall ensure that all dead end
mains within the System are equipped with a means of flushing, and that
all such dead ends are properly flushed in accordance with IDAPA
58.01.08.542.09.
10. Department Submittal Review Process. Unless otherwise set forth
specifically herein, the following document submittal and review process
(Submittal Review Process) shall be followed regarding submittals required by
this Consent Order. This process shall be followed until the Department approves
the document or the document review time frame has expired. .
a. Within thirty (30) calendar days of receipt of Morning View's
submittal, the Department shall 1) notify Morning View in writing the
document is approved; 2) notify Morning View in writing of any
deficiencies in the document; or, 3) notify Morning View of the
Department's extension of the Department's review and comment period.If the Department notifies Morning View of deficiencies in the document,
Morning View shall submit a revised document to resolve those
deficiencies within thirt (30) calendar days of receipt of the Department's
notice.
b. The Submittal Review Process shall be repeated until the
Department notifies Morning View the document is approved. However,
the submittal must meet the Department's approval within sixty (60) days
from'the due date for the first submittal ofthe document, unless the
Department provides Morning View with a written extension of the sixty
(60) day time frame. Morning View's failure to obtain Department approval
of a submittal within such time frames shall constitute a viôlation of this
Consent Order.
c. Once the Department approves these documents, they shall be
incorporated herein and enforceable as a part of this Consent Order.
11. Civil penalties of FOUR HUNDRED FIFTY DOLLARS ($450) were
assessed in the NOV and wil be resolved as follows:
a. Beginning the quarter of October 1, 2007 through December 31,
2007, and for three (3) consecutive quarters thereafter, Morning View shall
submit to the Department a payment of $112.50. for a total of four hundred
fifty dollars ($450) in total assessed penalties.
Morning View Water Company
Consent Order
5
11......11 ..'10:1. \'l.n~C:UtJ-/"t;:-UU"t!
b. Payment(s) shall be made payable to the Idaho Department of
Environmental Quality and shall be submitted to:
Idaho Department of "Environmental Quality
Financial Management
Attn: Drinking Water Penalty Payment
1410 N. Hilton
Boise, Idaho 83706
12. All communications required of Morning View by this Consent Order shall
be addressed to:
Greg Eager, Engineering Manager
Departent of Environmental Quality
Idaho Falls Regional Office
900 N. Skylinel.Suite 8
Idaho Falls, 10 83402
13. All notices. reports and submittals required of the Department by this
Consent Order shall be addressed to:
Mr. Nolan Gneiting
Morning View Water Company
P.O. Box 598
Rigby. JD 83442
14. This Consent Order shall not in any way relieve Morning View from any
obligation to comply with any provision of the Idaho Rules for Public Drinking
Water Systems. or any applicable local, state, or federal laws.
15. Morning View recognizes that failure to comply with the terms in this
Consent Order may result in district court action seeking specific performance of
this Consent Order; assessment of costs and expenses; available penalties
under Idaho Code §39-108; restraining orders; injunctions; attorney fees; and
other relief available by statute or rule as the court considers to be just and
reasonable under the circumstances.
16. This Consent Order shall remain in full force and effect unti the
Department acknowledges in writing that the Consent Order is terminated and
that Morning View has fulfilled all requirements of this Consent Order.
17. This Consent Order shall bind Morning View. its successors and assigns,
until terminated in writing by the Department.
Morning View Water Company
Consent Order
6
p. tJ
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18. Each undersigned representative to this Consent Order certifies that he or
she is fully authorized to enter into the terms and conditions of this Consent
Order, and to execute and legally bind such part to this document.
19.. The effective date of this Consent Order shall be the date of signature by
the Director of the Idaho Departent of Environmental Quality.
DATED this 1i"~YOf ~,2007.
By:--
Ellan Gneiting
Morning View Water Campan
DATED this day of ,2007.
By:
Toni Hardesty, Director
Department of Environmental Quality
Morning View Water Company
Consent Order
7
Exhibit B
:.....:. "., .,.:.¡
... ."':,:'J
LAWRENCE G. WASDEN'
Attorney General
, REC:ElVED '.~. ., " '.
DØJt -5 'PH ll;~Ôø":
UriL\9MàOtclJ':liSldN
CLIVE J. STRONG
Deputy Attorney General
Chief, Natural Resources Division
COURTNEY E. BEEBE, ISB # 6755
Deputy Attorney General .
.1410 N.Hilton, 2nd Floor
Boise, Idaho 83706
Telephone: [phone]
Facsimile: (208) 373-081
Attorneys for Plaintiff
IN THE DISTRICT COURT OF THE
THE STATE OF IDAHO, IN AND FOR F
STATE OF IDAHO, DEPARTME
OF ENVIRONMENTAL QUALITY,
v.
Nolan Gneiting,
Company,'Filng Fee: ExemptrCategoryAJ
Idaho Code § 31-3212
partment of EnvironmentalOuality ("Department'),by andi ,
orney General, makes this, complaint and claim for: relief
follows:
, .... '.
, d/b/a Momingview Water Company ("Defendant"), alleging as' '. "
IDEO v~ Nolan Gneiting, d//a Momingview Water Company COMPLAINT _ i
'.. ,,
NATURE OF THE CASE
1. This is a civil action initiated pursuant to the Idaho Environmental
Protection and Health Act (EPHA), Idaho Code § 39-101et seq., specificlly, LC. §39-, .
. per viola.tion or one thöusand ($1,000) for each
is greater, pursuant to Idaho Code
108, and the terms and conditions of a consent order dated October 25,2007, between
the Department and Defendant ("Consent Order," attached h 0 as Appendix I). The
Department seeks speific performance of the unperform s of the' Consent Order
and seeks a permanent mandatory injunction requi
IDAPA 58.01.08 as alleged below.
2.The Department seeks penal , ($10,000)
3.ing this action to enforce
Consent Order, asthe EPHA, IDAPA
4.able attorneys' fees, witness fees, and
d by Idaho Code § 12-117 and I.R.C;P.54.
lenON AND VENUE
urisdiction over tt-e subject matter of this action pursuant to .
6.
and Idaho .Code § 1.705.
rt has personal jurisdiction over the Defendant pursuant to Idaho
Code § 5-514(a-e) for the reason that the Defendant has commited acts within the
State of Idaho out of which this cause of action' arise.s and Which violate the laws of the
State of I.daho. Additi~nally, the Defendant owns real propert within the State of Idaho,
IDEO v. Nolan Gneiting, d/b/a Morningview Water Company COMPLAINT _ 2
. ... ' ,
which is related to the subject matter involved 'in this 'action.
7. Venue is proper in the Court, pursuant ioldaho Code.§ 39-108(3)(b) and
Idaho Code § 5-404, because the .violations and,'acts and omissions alleged herein
occurred and the action arose in Rigby, Jefferson County, Idaho.
PARTIES
8. The Departent is a duly authoried go
pursu~nt to Idaho Code § 39-104 and charged by' t '
enforce the Rules of the Department of Environ
9. Nolan Gnèiting '. is a person,
103(11).
10. MomingviewWater
Code § 39-103(11).
11.tes that if the recipient of a notice of
Director of the Department "agree on a
alleged violation and to assure' future
r into a consent.order formalizing their agreement. The
provision providing for payment of any agreed civil penalty.
-108(3)(a)(v) provides that "a consent order shall be effecive , ", ,
immediately ~pon signing by both parties and shall preclude any civil enforcement
action for the same alleged violation. If a part, does not comply with the terms of ~he
consent 'order, the director may. seek and obtain, in any appropriate district court,
IDEO v. Nolan Gnelting, d/b/a Morningview Water Company COMPLAINT - 3
l' ".;-:;.
"
specific perfonnance of the consent order and such other relief as authorized 'in this
. chapter."
Momingview
13. Idaho Code § 39-1Q8(b) allows the Department 'to commence a civi.
enforcement action, "in the district' court in and for th.e county in which. the, alleged
violation occurred, and may be brought :against ány person 0 is' alleged to . have
violated any provision of this act or any rule, pénnit or ord
pursuant to this' act. Such action may be brough
provision of this act or with any rule, pennit or
relief or remedies authorized in this act. T . initiate or
14.s 58.01.08.003.87 defines a
public drinking water system as ,a "s o the public of water for
1998, other constructed
(15) service connections, regardless .ofconveyances, if
of the distribution system, or regularly',
. .
n Gneiti~g is the president and sole share hoider of the
ny. according' to the 2009 Annual Report on file with the
Idaho Secretary of
16. Defendant owns' and operates a public drinking water system fCSystem")
that serve,s approximately one hundred and six (106) connections and approxima.tely
two hundred twenty five (225) persons on a daily basis in Rigby, Jefferson County,
IDEO v. Nolan Gneiting, d//a Momingview Water Company COMPLAINT. 4
":,,' "'~'.';i~~:~1:r"t':
"
Idaho.
17. 'Idaho Rule for Public Drinking Water Systems 58.01.08.552..01.b.i'
requires that "(a)ny public water system shall be capable of providing sufticient water
during maximum day demand conditions, including fire flow to .maintain a minimum
pressure of twenty (20) psi throughout the distribution syst , at ground level,. as
measured at the seivice connection or along to the
consumers premises."
18. Idaho Rule for Public Drinking
"(a)ny public water system constructed or 985, shall
peak hourly demand conditions,'e
or along the propert line adjacent to
19.. , .08.552.01.b.v requires that
'.
,'to havefallen below twenty (20) psi, the
nfect the system."
the) Department investigated and verified a consumer,
he System regarding inadequate pres~ure an~
the system fell below twenty pounds per square inch (20
0/ .
21.Department notified Defendant of the System's
inadequate pressure by letter and required Defendant to remedy the inadequate ..
pressure within ten (10) days. '
22. On July 23,2007, the Department conducted additional pressure testing at
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company COMPLAINT - 5
¡-:......"...:'.
five (5)connectiöns to the System, and disçovered the average pressure in the $ysterr
during a twenty-four hour period was tWenty-two pounds per square inch (22 psi). '
.23. On July 25, 2007, the Department nQ.tified the Defendant of the results of
the July 23, 2007, pressure testing by letter and required the Defendant to diagnose and
correct pressure deficiencies' by August 6, 2007. The letter i
Defendant of IDAPA 58.01.08.552.01.b.v, and required
notification of pressure loss to each connection to the
24. By letter of August 8,2007, the'
Defendantl$ failure to notify the Departm'Systems
pressure deficiencies or corrective actions t~
deficiencies by August 6,2007.
25.tified the Defendant that '
the diagnose and resolve
27.
partment issued a Notice of Violêition .',
Oa(a)(i) and ,notified the Derendant of multiple violations
ing Water Systems (IDAPA 58:01.08). The N.9V
portunity for a compliance conference and the Departmeht
cewiththe Defendant on September 26, 2007.
to Le. § 39-108(a)(iv) and (v), the. Deparent and the
Defendant, entered into a Consent Order on October 25,2007., '
28. Paragraph 9.b of the Consent Order requires the Defendant to provide. .,'
quarterly public notices 'to each connection to the System by mail or hand delivery,. .':.::.:,.
IDea v. Nolan Gneiting, dlb/a. Momingview Wat~r Company COMPLAINT - 6
.~.".J:.:-. ~
informing the consumers of the Departm~nt'sdisapproval of' the System and' shall
identify the violations in the September 12, 2'007,. NOV, as required by IDAPA
58.Q1.08.150. Para.graph 9.b. of the Consent Order also . required the Defendant to
"continue to provide quarterly public notices until such time as the Department notifies
(the Defendant) in writing that quarterl notices ate.not longer ~ irecl.- Additionally, the
Defendant agreed to "provide the Department with próo , ch quarterly.notification
via the Department's supplied notification form, and a
within ten days of completion." .
29. The Defendant failed to pri.
ed to the
June 30, 2008, or provide a c,
Notice to the
30. The
r the period of Januar 1 , 2009, through
March e First Quarter PubHc Notice to the
onsent Order requires the. Defendant to .submit to
(90) days, "a written plan detailng how (the Defendant)
shall be made capable of maintaining a, minimum pressure
. .. ... .. uare inch (40psi) throughout the distribution system during peak.
hourly demand conditions, measured at the service connection oraloog the property
line adjacent to the consumets premises as required by IOAPA 58.01.08.552.01.b.ii."
The plan must' include a 'local pressure monitoring study and assurance that the
IDEO v. Nolan Gneiting,dlb/a Morningview Water Company COMPLAINT - 7
..~..;. .
facilty plan and listed the reasons for disapproval of the facilty plan.
. 36. On Januaiy 13, 2009, the Departent received a complaint regarding
pressure loss at the System from one of the connections to the System.' , ,
37. Defendant has failed provide public notice of pressure .
loss that ocurred
in lheSystem on January 13, 200, as per IDAPA 58.01.08.55
38. On April 22, 2009, the Department regding, .pressure loss at the System from one of the coneci '
39. Defendant has fciiled to provide Q
consumers that occurred in the
IDAPA
58.01.08.552.01.b.v.
40.ems IDAPA 58.01..02;100.06
incorporates 40 C.ER. 141.26(1), w
monitor quarterl for '
41.
ent notified the Defendant by letrer that it ',' ,
y throughout 2008. ,
. ed to monitor the System for Radium 226 as per lOAPA
F.R. 141.26, for the period of April 1, 2008, through
to submit the results to the Department. Sample'. was '
for Public Dnnking Water Systems 58.01.02..100.03 incorporates .
40 C.F.R. 141.23(d) which requires all public drinking water systems to monitor annually
/
for nitrates.
44. The Defendant failed to monitor the System for nitrate as per IDAPA
IDEQv. Nolan Gneiting, d//a Momingview Water Company COMPLAINT _ 9
0'
/';' ; .' , .'".:....d',..'~~t'¡df:'l'
58.01.08.100.03, incorporating 40 C.F.R. 141.23(d), during the year of 2008 and failed
to submit the results to the Department.
45. The Department nòtified the Defendant that it had not received
documentation of nitrate sampling by letter of January 15, 2009. Department received a
nitrate sample on January 21,2009.
COUNTI,'Violation of ,Consent Order' P
.46. Plaintif realleges each and every ai
herein.
47. Defendant has failed to perfo
Consent Order.
, .
48.by virtue of his failure to'
, .. hneced to the Sy~tem a '
period of April 1, 2008, through June 30,.
r Public Notice to 'the Departent as '"
Ie to the Department for penalties, costs, expenses,
ees P rsuant to Idaho Code § 39-108(5) ' and Idaho Code §,
12-117.
COUNT II¡olation ~f Consent Order Paragraph'9.b
50. Plaintiff realleges each and every allegation contain~ in paragraPtis 1-49
herein.
51. Defendant has faileà to perfomi the actions requíred pursuant to the
IDEa v. Nolan Gneiting, d/b/a Morningview Water' Company COMPLAINT _ 10
, Consent Order.
52. Defendant is in. breach of the Consent
Order by virtue of his failure t~
~ubmit to the Departent or each residence connected to the S~em a First Quarter
of
2009 Public Notice for the penod of January 1, 2009, through Marc 31,200,
and
provide a copy of the First Quarter Public Notice to the De ment as requiréd, by, .
paragraph 9.b of the Consent Order.
53. The Defendant is liable to the Oépartm . s, costs, .expenses, .
witness fees and attorney's fees pursuant to Id
12-117.
..;'
onsent Order by virtue of his failure to
su w the Defendant wil ensure that its System Win be
inimum pressure of forty (40) psi throughout the
eak 'hourly demand, ,excluding fire flow, measured at the
ong . the propért .line adjacent to the consumets premises, in
accrdance with IDAPA 58.01.08.552.01.b.ii. as required by paragraph 9.c of the
Consent Order.
S? Plaintiff, is entitled to an order of specific performance of the terms and ,
conditions of the Consent Order.
54.ntained in paragraphs 1-53
herein.
55.
Consent Order.
the actions required pursuant to the
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company COMPLAINT _ 11
, Consent Order.
58. The Plaintif is entitled to a permanent mandatory injunction reuiring th~t
the DefEtndantmaintain fort pounds per square inch (40 psi) of pr~ssLire irHhe,System
as required by IDAPA 58.01.552;01.b.ii.
59. The Defendant is liable to the Department for penalties, costs, expnses,
witness fees and attorney's fees pursuant to Idaho Code § 39. '(5) and 'ldahoCOde §
12-117.
couNtry
Violation of Consent Ord
60. Plaintiff realleges eachande¥,'
herein.
~
61. Defendant has faUe
62.
epartment forpenalties,costs, expenses, ,
ursuant to Idaho Code§ 39.108(5) and Idaho Code §
64.
COUNT V
PA 58.01.08.100.06, Failure to, Monitor Radium'
eålleges each and every allegation contained in paragraphs 1.;63
herein.
65. Defendant has failed to monitor the System for
Radium 226 as per IDAPA
58.01.02. i 00.06, incorporating 40 C.F.R. 141.26, for the period of April 1, 20a8, through. .
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company COMPLAINT. 12 '
..........-...:.. ..:';':~. " . . "!?;;;ri~~~~ll?:T
. .
herein.
COUNT ViViolation oflDAPA 58.01.oà.1 00.03, Failure to
67. Plaintif realleges each alld every allega .
herein.
68.. Defendant failed to
58.01.08.100.0~, incorporating 40 C.F.R. 14
to submit the results to the Depa.
69.
, and failed
nallies, costs, expenses,
-108(5) and Idaho Code §
12-117. ,
and every allegation contained in paragraphs 1-69
69..s failed provide public notice of pressure loss that oc~urred
ary 13,2009, as per IDAPA 58.01.08.552.01.b..v.
72. The D.epartent is entitled to a permanent mandatory injunction requiring
that the Defendant comply with IOAPA 58.01.08.552.01.b.v.
73. The Defendant is liable to the Department for penalties, costs, expenses,
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company COMPLAINT - 13
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..
'. "~ . ;::~.,.¿: ~'\;;::'?:J:?;'jT::ff\.;~;~;")'t,:''-'',
June 30, 2008, and failed to submit the results to the Departent.
66. The Defendant is liable to the' Department for penalties, costs, expenses,'
witness fees and attorney's fees pursant to Idaho Code § 39-108(5) and Idaho Code §
12-117.
COUNT ViViolation of lDAPA 58.01.08.100.03, Failure to
67. Plaintif reallegeseach al1d every allegat '. ad in paragraphs 1-64 ,;'g€i~¡;;.r!t
herein.
68.' Defendant IOAPA
58.01.08.100.03, inorporating 40 C.F.R. 14' . .and failed
to submit the results to the Depa ,
69., nalties, costs, expenses,
-108(5) and 'Idaho Cod §
12-117.
and every allegation contained in' paragraphs 1-69
herein.
69.s failed provide' public notice of pressure loss that ocurred
ary 13, 2009, as per IDAPA 58.01.08.552.01.b..v.
72. The Department is entitled to a pennanent mandatory injunction requiring
that the Defendant comply with IDAPÀ58.01.08.552.01.b.v.
73. The Defendant is liable to the Department for penalties, costs, expenses,
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company CQMPLAINT - 13
.. ~:,'
~
witness fees and attomey's fees pursuant to Idaho Code § 39-108(5) and Idaho Code §
12-117.
COUNTVUI
Violation of IDAPA 58~01.08.552.01.b.v, Failure to Provide Public Notice of. Pressure Loss '
12-117.
74. Plaintif' realleges each and every allegation c d in paragraphs. 1-71
herein.
"
75. Defendant' has failed
, occurred in the, System on April 22, 2009
Defendànt failed to submit a copy of the publl .
76. The Department is e
that the Defendant comply with IDA
77.
, '.
naltes,'costs, expenses,
witness fees and aho Code § 39-108(5) and Idaho Code §
Department of Environmental
A.the Defendant, as authorized ,by Idaho Code, §39~ 108, '
n thousand dollars ($10,00) f.or each separate 'violation and'
one thousand dollars ($1,000) for each day of continuing violation. '
B. Issue a permanent mandatory injunction, as authorized by Idaho ~ode §
39-108, requiring the Defendant to perform the terms and conditions of the Consenf;,
Order and IDAPA 58.01.08 as ~pecified above.
IDEO v. Nolan Gneiting, d/b/a Momingview Water Company CqMPLAINT - 14
, '
"
~ c.
D
-
C. Provide other such injunctive relief as the Court deems appropriate:
according to proof.
D. Assess against Defendant all costs, expenses, winess fees and attorney's,
fees incurred by Plaintif pursuant to Idaho Code § 39-108 and Idaho Code' § 12-117, in
an amount according to proQf. '
E. Grant such other relief as the Court deems
DATED this _ day of May, 2009.
I" .
. ¡
'-
..l"
,.
IOEQv. Nolan Gneiting, d//a MomingviewWater-Company COMPLAINT - 15
.:-,....
Exhibit C
Contents
Chapter Page
Contents ........................................................................................................................... 1
Chapter 1 Summary ........................................................................................................ 3
Introduction ........................................................................................................... 3
Water Requirements ..............................................................................................3
Supply ...................................................................................................................3
Storage ...................................................................................................................3
Distribution ........................................................................................................... 4
Water Quality and Regulations .............................................................................4
Capital Improvement Program ............. ...... .... .......................... ............................. 4
Recommendations/Conclusion .............................................................................. 4
Chapter 2 Introduction ..... ................ ..... .... ....... .... ...... ... .... ... .................................... ...... 6
. History ....................................................................................................................6
Curent Assets ........................................................................................................ 7
Operations/Administration ..............................,...................................................... 8
Rates .......................................................................................................................8
Chapter 3 Existing System .............................................................................................. 9
Supply ...................................................................................................................9
Treatment ..........................................................................................................~. 10
Pressure Zone ...... . .... ............. . ..... .................................... .... .. . ...... ........... ............ 10
Standby Power ..... ......... ..... .... ...... ..... ...... ..................................... .... ....... .........,.. 11
Storage ................................................................................................................ 11
Telemetry System . ................. ....... ................................... . ... ... ........................ ..... 1 1
Distribution System ............................................................................................ 1 1
Chapter 4 Water Requirements ................................................................................... 13
Definition of Terms ............................................................................................. 13
Demand ...................................................................................................13
Consumption ........................................................................................... 14
Peakng Factors ....................................................................................... 14
Water Production .................................................................................... 14
Per Coiuiection Demand ......................................................................... 15
"Unaccounted-For" Water ............ ........ ............... ..... ..... .................. .:...... 15
Demand Projections ......... ........................ ........ ... ....... ......................... ........ .... .... 15
Population Projections .. .... ... ........ ... ... ....... ..... ................... ........ ...... .... .... 15
Future Water Demands ........................................................................... 16
Chapter 5 Water Supply and Storage ......................................................................... 17
Morning View Water Company
Final Facility Plan Page I
Water Rights ...................................................................................................... i 7
Water Supply and Storage Requirements ........................................................... i 7
Water Supply Criteria ............................................................................. 17
Water Demand Projections ...................................................................... i 8
Chapter 6 Distribution ............ .......... ............. ......... ......... ....... ..... ..... ......... ............ .... 19
Regulations .................................................................................:...................... 19
Peak Hour Demand Under Normal Operating Conditions .............................. i 9
Maximum Day Demand Under Normal Operating Conditions ......................20
Current System Evaluation .............................................................................. 20
Chapter 7 Water Quality and Regulations . ... ..... ............ ...... ........... ....... ......... ... ..... 2 i
Chapter 8 Capital Improvement Program . ........ ............ ....... ... ... ..... ...... ................. 22
Cost Estimating ................................................................................................. 22
Water Meters ...................................................................................................... 22
Variable Frequency Drives .............. ..... ............... ... .............................. ..... ....... 22
Backup Power Generation ........ ........ ........ .... .... ........ ....... ........... .... ....... ........... 22
Drill Water Supply Well ...................................................................................22
Appendices
Appendix A Consent Order Documents
Appendix B Maps
Appendix C Water Rights
Appendix D Well Logs
Appendix E Water Production Data
Appendix F Water Company Documents
Morning View Water Company
Final Facility Plan Page 2
CHAPTER 1
Summary
Introduction
The Morning View Water Company (MVWC) has contracted with Aspen Engineering to
complete a Facility Plan in accordance with the Consent Order from the Department of
Environmental Quality. The consent order identified multiple deficiencies including
insufficient pressure, significant amounts of sand, non-flushable dead end mains, and operator
licensing. Each of the eight items listed in the consent order, required action from Morning
View Water Company. A detailed facility plan (this report) is listed as requirement 9d in the
consent order. MVWC has completed all ofthe items listed in the consent order in addition to
complying with items listed in recent sanitary surveys.
The findings of this study are summarized below:
Water Requirements
The population serviced by MVWC is approximately 250 people via approximately 100 active
individual connections. Morning View Water Company's historical average daily demand
(ADD) for the years 2005 through 2008 was 170,750 gallons.
As an un-metered community, MVWC's ADD consumptive values are very high (2.6 to 3.0
times) in comparison with metered communities. It is recommended that MVWC implement
conservation measures including individual meters and a tiered rate structure. The ADD water
use for the 2008 year is 178,560 gallons, with an MDD of 446,400 gallons and a peak hour
demand (PHD) of 535,685 gallons. Water demand projections for the end of the 3-year studyperiod (2011) are 184,000 gallons for ADD, 460,000 gallons for MDD, and 800,000 for PHD.
Supply
MVWC cUrrently utilizes groundwater as its sole source of water. The groundwater is supplied
by two wells. Both wells are located on a single lot and are separated by a distance of 100 feet.
Both wells lie within the Company's platted service area. Total pumping capacity of the two
active production wells is estimated at 600 gpm or 864,000 gallons per day.
The current firm capacity (largest well out of service) of the Company's production wells is 200
gpm or 288,000 gallons per day. Current firm capacity does not meet PHD or MDD flow
requirements and an additional well is needed immediately.
Storage
The only storage in MVWC's water system provided in the two air over water pressure tanks
at the pump building and has no practical/useable quantity.
Morning View Water Company
Final Facility PIan Page 3
Distribution
The distribution system is composed of both 4 inch and 6-inch main lines. These mains are
exclusively class 200 PVC. Future expansions should continue to incorporate similar materials
throughout the distribution system. The water system does not have fire hydrants, and the
distribution mains are adequate to supply domestic flows.
Water Quality and Regulations
All of Morning View's water is supplied by groundwater wells. Water quality is good, and
compliance with both State and Federal regulations for contaminants is currently being
maintained. Currently, There is no water treatment available or provided at the MVWC
facilities. Lack of adequate pressure during the irrigation season has been and still is a large
concern for the system. Compliance with current regulations is also an issue as discussed in
Chapter two.
Federal drinking water regulations proposed or promulgated by the Environmental Protection
Agency (EP A) as part of the mandates of the Safe Drinking Water Act (SDWA) Amendments
must be met and certain new regulations are in effect and future regulations are anticipated to
be finalized within the next few years.
Capital Improvement Program
Currently there are no capital improvements planned for the system. However, a new well with
adequate capacity to meet the firm ADD demand must be planed and completed within the
next three years. The estimated cost to complete the new well and pump is $150,000.
Additionally it is recommended that backup power generation and/or storage be provided in
order to prevent depressurization events during power outages.
Reco mmeo da tio nsf Con cl u sio ns
Providing and maintaining adequate system pressure is the first priority for the MVWC water
system. System operating pressures were adjusted in late July of 2008 to 50 psi min and 75 psi
max. Pressure monitoring data collected November 13-20,2008 indicates adequate pressures
are being maintained in system indicating the low pressures are due to the increased demand
during the irrigation season.
Installation of meters to promote water conservation should be the first capital improvement
to the system. Implementation of a tiered rate structure, after installation of the meters, will
further aid conservation efforts and reduce the ADD.
If adequate pressures are still not maintained then installation of variable frequency drives
(VFD) should be installed first on the main well and secondarily on the smaller welL. This will
eliminate the need for the air over water pressure tanks and will provide a much tighter range
for pressure fluctuation.
Morning View Water Company
Final Facility Plan Page 4
In summary, the following items have been addressed by Morning View Water Company:
.Maintain a minimum of 40 psi throughout the system
a. Adjust pressure settings.
b. Eliminate all individual booster pumps. (Only one could be verified)
c. Install VPD . still required after meter installation if needed.
.Install screening at end of discharge pipe from well house (west side) and provide a
minimum clearance of 12 inches above the ground. (2003 Sanitary Survey
Requirement).
Clean out well house (2003 Sanitary Survey Requirement).
a. remove all hazardous materials.
b. remove all non-water related items.
c. organize items on shelves.
d. remove all old/used/worn out parts and equipment.
· Secure underground vault. provide locking cover to vault (1997 & 2003 Sanitary
Survey Requirement).
Remove the threads from sample tap located in well house (2003 Sanitary Survey
Requirement).
· Cleanup well lot
a. mow/cut down all weeds
b. fill in hole next to well #2
c. remove trash, wood, and debris
d. fill in hole where sand separator is purged and pour concrete pad or provide rip
rap to prevent future erosion.
Ultimately, the system cannot meet the firm pumping capacity requirements and an additional
water source, including water rights, is needed to provide adequate capacity. Installation of
backup power generation is also recommended in order to maintain system usefulness during
outages from the primary power source.
Morning View Water Company
FinaI Facility Plan Page 5
CHAPTER 2
Introduction
The Morning View Water Company (MVWC) is a privately held public water system that is
currently regulated by the Idaho Public Utilities Commission. The system services
approximately 100 single family residences in an unincorporated area of Jefferson County
Idaho. The intended purpose of this report is to provide an assessment of the existing water
system and provide recommendations to maintain and improve the facilities.
The following topics are contained in the report:
.Existing System (Chapter 3)
Water Requirements (Chapter 4)
Water Supply and Storage (Chapter 5)
Distribution (Chapter 6)
Water Quality and Regulations (Chapter 7)
Capital Improvement Plan (Chapter 8)
.
.
.
.
The report covers the current configuration ofthe water system as well as a projection of threeyears from now when the system wil likely be completely finished - i.e. all interior lots sold
and occupied. As' a reference for construction time frame, in 2002 the system serviced
approximately 65 connections.
History
In October 2007, MVWC entered into an agreement with the State of Idaho Department of
Environmental Quality (DEQ) known as a consent order. The order made arrangements for
MVWC to complete eight action items to come into compliance with current state and federal
drinking water regulations. The eight items requiring MVWC action are:
a. Correct and report deficiencies noted from the October 2003 sanitary survey and
schedule a new sanitary survey with DEQ.
b. Provide quarterly public notices to each residence on the system informing them of the
DEQ's dis-approval of the system.
c. Submit a written plan to DEQ detailing how MVWC will maintain 40 psi throughout the
distribution system
d. Complete a detailed facility plan in accordance with IDAPA 58.01.08.502
e. Contract with a licensed operator.
f. Submit a sampling plan addressing how MVWC will monitor the distribution system for
bacteria.
g. Sample four times for sand and report sampling results to DEQ or install a DEQ
approved sand separator.
h. Install adequate means of flushing dead-end mains.
Morning View Water Company
Final Facility Plan Page 6
MVWC has taken the following actions in response to the consent orderaction items. Records
of such actions are included in Appendix A.
a. Cleanup at the well lot and pump house has been completed and a draft cross-connection
control plan has been submitted. The overflow piping still needs to have a screen
covering and the erosion at the sand separator discharge needs to be filled in.' All other
items listed previously has been completed.
b. Quarterly notices have been sent.
c. Pump control settings have been changed to 50 psi (low) and 75 psi (high) to improve
system pressures. DEQ pressure monitoring showing minimum pressures above 20 psi
during the irrigation season has been established and a minimum pressure of 40 psi
during the non-irrigation season has been maintained.
d. Final Facility Plan submitted by Aspen Engineering to DEQ on April 13, 2009.
e. Nolan Gneiting completed the requirements to update and make current his Idaho
Drinking Water Operators license.
f. MVWC submitted a "System Sampling Plan" to DEQ in March of2008.
g. Installation of a sand separator in the pump building is complete and separator is
currently in operation.
h. All dead-end mains have been fitted with flushing hydrants.
Current Assets
Current assets ofMVWC includc two deep wells, a 30' x 32' wood frame pump house, and 2.5
miles of distribution lines. The pump house encloses two 900 gallon tanks, a 40 gallon air
compressor, meters, valves, and piping. Two Furnas brand pump controllers are also located
in the pump house. The following table presents the various components and their anticipated
useful life and replacement data.
Morning View Water Company - Capital Replacement
Item Date Installed Anticipated Replacement Replacement
Life Cycle Date Cost -
30 well pump July 2007 15 years 2022 $12,000
10 well pump July 2007 15 years 2022 $8,000
900 gallon 1998 30 years 2028 $7,500 Ea
galvanized
storage tanks
Morning View Water Company
Final Facility Plan Page 7
Motor 2002 10 years 2012 $5,000 Ea
Controllers
Well House 1998 40 years 2038 $50,000
Flushing 2007 20 years 2027 $300 Ea
Hydrants
Operations/Administration
MVWC maintains an office located at 3996 East 200 N Rigby, Idaho. The office handles
billings, customer service, complaints, notifications to its customers and correspondence with
DEQ and the Idaho Public Utilities Commission (IPUC). Office personnel document each
occurence and have a complete recording of customers and correspondence. The office is
operated Monday through Friday 8 am to 3 pm. In order to be responsive to customers needs,
a 24 hour answering service (Ideal Answering -Roberts Idaho 228-2094) takes calls during
weekends and off business hours. Their goal is to "keep our customers aware of what we are
here for, and that is to serve them in the best way we can and to let them know the extent of the
management of MVWC."
In case of emergencies or outages, Nolan Gneiting, "Owner/Operator" is first contacted. If he
is not available, Denise Kynoch, "Office Manager" is contacted. In the event the owner
becomes incapable of carrying out his responsibilities, Dawn Gneiting would step in to handle
the water system's operation. Contracting with a certified Idaho Water operator would also be
required.
Operations plans include a daily check of the well house with written record keeping of water
pressure, pressure tank air levels, flow rate and flow totalization. The sand separator is flushed
daily to minimize sand in the distribution system.
Rates
Currently, the MVWC rate structure is regulated by IPUC. The IPUC has recently conducted
several audits of the company's books and is in the process of completing an audit to support
a either a rate increase or billing surcharge to help fund water service meters and installation
of the meters.
Morning View Water Company
Final Facility Plan Page 8
CHAPTER 3
Existing System
The existing MVWC water system includes two wells and approximately 11,000 feet of six
inch diameter class 200 PVC water main. 2,300 feet of four inch diameter, class 200 PVC is
also included on the system. A map of the system and its features is shown in Appendix B.
The current service area for the MVWC includes 109 acres located in the Morning View Acres
Divisions 1, 2, 3, and 4. Division NO.1 of Country Grove Estates Mobile Home Subdivision
is also included on the system. There are currently 102 connections to single family residences.
Residences include site constructed homes (stick built), mobile trailer homes, and manufactured
homes on permanent foundations.
Lot sizes range from one quarter of an acre to just over one acre in area. The smaller lots are
typically occupied by either mobile trailer houses or manufactured homes. Stick built single
family residences generally occupy the larger lots.
Future growth within the existing service area boundary will include water service connections
to 25 lots in the stick built divisions, as well as an additional 22 trailer lots in Division 4 of
Morning View Acres. This will make a total of 149 individual connections to the system.
It is estimated that the system wil be fully developed within the next three years.
Supply
Well 1 - The main well for the MVWC water system is 12 inch diameter well approximately
120' deep. The well is located on "well lot" at the northwest corner of Division NO.3. The well
lot comprises 1.64 acres. The well log for this well shows it was completed in July 1996 and
Is cased to a depth oÍ 118 Íeet. This well has not been pump tested and the actual well capacity
is unknown. Currently a 30 horsepower submersible pump is installed in the welL.
Well 2 - The backup well is a six inch diameter well that is 120 feet deep. According to the
well log, this well has a surface seal 18 feet deep and was constructed in June 1986. No pump
test data is available and a 10 horsepower submersible pump services the welL.
Both wells feed into a central pump house via separate pitless adapters and buried six inch
diameter pipes. The pump building accommodates two 900 gallon, air over water, pressure
tanks which then feed into the distribution system. Both well pumps are single speed pumps
and are equipped with soft start motor controllers to prevent water hammer and extend the life
of the pumps.
Water quantities are monitored using a totalizer/flow meter located in the pump house. The
meter reads the instantaneous flow through the meter as well as providing the total quantity
passing the meter (totalizer). No individual well meters are installed and it is not possible to
determine individual well production, only total water production can be recorded. The water
Morning View Water Company
Final Facility PIan Page 9
quality of these two wells currently meets drinking water regulations. Chapter 7 includes dialog
of compliance with drinking water regulations. .
Two 900 gallon galvanized water tanks are installed in the pump house. The two tanks are
maintained between half and two-thirds full of water with pressurized air occupying the top
portion of the tanks. The tanks are about ten years old and are in good shape with no rust or
leaks showing. The estimated useful life of the tanks is at least another ten years.
A third well is located on within the platted subdivision on Lot 5 in Division 3 of Morning View
Acres. This well currently does not meet State Rules for Public Drinking Water Systems and
is not connected to the distribution system. In order to use Well 3 in the system, the Company
would need to conduct a 24-hour pump test on the well to verify long-term sustainable yield,
compliance with water quality standards, and provide a satisfactory well seal thus meeting the
current well construction standards. After completing the required tests and obtaining DEQ
approval, the next step would be to construct a new well house using current construction
standards.
Treatment
The only treatment currently in operation for the company's water supply is to separate sand
from the well production water. The sand separator consists of a centrifugal type separator with
raw water being fed into the unit, centrifugal action then separates the heavier sand particles
which fall to the bottom of the unit and treated water is returned to the top of the unit and put
into the distribution system. The unit operates manually and the only maintenance required is
to purge the solids from the bottom chamber of the unit on a periodic basis. Adetermination
of how often this is required can be made by flushing the solids into a bucket and then
measuring the amount of sand produced per unit of water. It is likely the unit will operate at
peak efficiency with only weekly or bi-weekly purging. No other treatment or treatment
equipment is provided or necessary.
For emergency circumstances manual dosing of the individual wells would be required to treata bacteriological outbreak, should one occur. The Company may want to purchase an
emergency chlorination system to provide emergency disinfection capabilities.
Pressure Zone
The entire system is served by a single pressure zone. System pressures throughout the
development are established by the pressure switch setting at the pump house building on the
well lot. Most recently, the pressure settings have been adjusted to operate between 43 and 67
psi. This pressure is measured at the pump building and customer pressures at the point of usewill vary due to friction losses and the variation in demand especially during peak demand
hours. The pressure settings at the pump building could be adjusted to provide only a ten pound
differential. This would increase the lowest pressures without compromising fittings and other
equipment due to increased high end pressures. Monitoring of the well pumps to ensure the
Morning View Water Company
Final Facility PIan Page 10
minimum run time is still met would be required. Generally during the irrigation, water
demands will easily provide for adequate pump run time.
Based on the information obtained from pressure monitoring, the system usuallyoperates above
the minimum pressure of 40 psi except during the irrigation season. It appears that the system
undergoes abrupt pressure changes each day as irrigation systems begin operation. The
previously held notion of individual booster pumps coming online and degrading the pressure
to surrounding areas has been dispelled as only one booster pump could be found and the
operation thereof has been extremely limited according to the homeowner.
Aspen Engineering conducted a survey of customers suspected of having individual booster
pumps and found only one that is currently installed. It is still our recommendation that all
individual booster pumps be eliminated from the system. If acceptable pressure ranges cannot
be maintained, it is recommended that a variable frequency drive (VFD) be installed in the
pump house for each of the submersible well pumps. The VPD can be set to maintain 60 psi
and so long as the pumps can keep up with demand, operating pressures will remain constant
within 3-4 psi.
Standby Power
Currently there is no standby power or emergency power generation equipment ate the MVWC
system. In the event of an area wide power failure, no water production is realized and the
system pressures will drop to zero as users draw a limited amount (less than 500 gallons) of
water supplied by the two pressure tanks.
It was estimated by MVWC personnel that power outages account for system shutdown 3-4
times per year. Typically outages occur during strong weather events such as high winds or
heavy thunder showers. Loss of power for more than a couple of minutes during the irrigation
season results in a depressurization of the system.
Storage
The only storage in MVWC's water system provided in the two air over water pressure tanks
at the pump building and has no practical/useable quantity
Telemetry System
There is no telemetry system installed at the MVWC water system. The two wells are operated
by an automatic pressure switch located in the pump house and both wells respond
simultaneously.
Distribution System
Water distribution for the Morning View system includes approximately 11,000 feet of six inch
Morning View Water Company
Final Facility Plan Page J I
pipe and 2,300 feet of 4" pipe. All ofthe pipe consists of class 200 polyvinyl chloride (PVC).
A map of the existing water distribution system is presented in Appendix B. Recently, three
flushing hydrants at the dead end mains were installed. There are no fire hydrants on the
system.
Service connections are exclusively one inch and are typically polyethylene. There are twelve
control valves within the distribution system, four of which are four inch valves controlling
flow to the two four inch diameter loops - one at the east end of the system and the other from
the two cul-de-sacs on 3950 East. The maximum number of residents on one continuous,
isolatable loop is at 178 North where there are 32 trailers on one loop. Generally there are
adequate valves to isolate ten to twelve homes without interrupting water service to others.
Periodic flushing ofthe dead-ends should be completed. A written plan identifying when each
location is/was flushed and the results of the flushing (i.e. water conditions, turbidity, etc)
should be included in the operations. Dead end mains should be flushed at least twice per year.
Cross-connection contamination of the distribution system is controlled by the use of back flow
prevention devices, generally consisting of a double-check valve. Check devices are required
to be inspected and tested after the initial installation with written verification given to the
either the owner/operator or the office manager. Periodic testing of the valves is not currently
part of the operation plan and should be implemented. The cost of testing each device should
be charged to the home-owner. Records showing the location of the device, along with the test
date and results should be kept on a master plan at the office. The proposed cross connection
control plan has been submitted to DEQ.
Morning View Water Company
Final Facility PIan Page 12
CHAPTER 4
Water Requirements
This chapter is to summarizes the current water system demands and projects future water use
for 3 and 20-year planning horizons. This includes a description of historical water use and
forecasting estimates developed to project future water use.
Definition of Terms
Demand
Demand refers to the total system demand, which is that quantity of water obtained from the
water supply source during a given time period required to meet the needs of domestic use, lawn
irrigation, system losses, and miscellaneous applications. Demands are normally discussed and
quantified in terms of flow rates, such as gallons per minute (gpm) or gallons per day (gpd).
Flow rates can be described in ariy terms involving a given volume of water delivered during
a specific time. Flow rates pertinent for the analysis and design of water systems are as follows:
Average Day Demand (ADD): the total volume of water delivered to the system in a year,
divided by 365 days.
Maximum Month Demand (MMD): the average rate of water delivered to the system during the
month of greatest demand during the year.
Maximum Day Demand (MDD): the rate of water delivered to the system during the day of
highest demand during the year.
Peak Hour Demand (PHD): the rate of water delivered to the system during the hour of highest
demand during the year.
These demands are typically presented in units of mgd. The following conversion factors may
be used to express rate of demand in other terms:
1 mgd = 694 gpm = 1.55 cubic feet per second (cfs)
1 gpm = 60 gallons per hour (gph) = 1,440 gpd
1 cfs = 450 gpm = 0.648 mgd
Volumetric conversions are:
1 cubic foot (d) = 7.481 gallons (gal)
1 gallon = 0.134 cubic feet (d)
The concept of per capita demand provides a convenient method of comparing water use by
different water systems or areas served by the system. The per capita demand is obtained by
dividing the total system demand by the total population served. Differences in climate, type
of development, and water use trends infuence the per capita demand for different water
systems.
Morning View Water Company
Final Facility Plan Page 13
Consumption
Consumption refers to the actual volume 'of water used by customers measured at their
connections to the water distribution system. Consumption is typically measured in gallons.
The MVWC water service connections are currently not metered. Customers pay a flat rate
according to the size ofthe lot being serviced. One acres lots are charged $49.4S/month, one-
half acre lot fees are $40.94 and smaller lots are $32.41. Each of the listed fees include a
monthly fee of $5.00 to establish a contingency fund for emergency repairs. The owners should
consider adding customer meters to promote conservation and help leverage the available water
supply to meet current demands. The addition of meters would also allow the Company to
quantify unaccounted-for-water in the system, discussed later in this chapter. Metering in some
cases is a requirement to obtain different sources of funding to finance improvements, including
state and federal grants.
Peaking Factors
The relationships between the ADD and other demand parameters, such as the MDD, MMD,
and PHD, are expressed as peaking factors. Typical peaking factors include the ratios ofMDD
to ADD, MMD to ADD, and PHD to ADD.
Water Production
Available historical water production data is presented in Appendix E. The available historical
data inc 1 udes limited readings for both Well 1 and 2 during the period.
TABLE 4-1 Average Day Demand - ADD for Morning View Water Company
Year ADD (gallons)
2006 171,306
2007 162,394
2008 178,562
Average 170,754
Based on historical averages from Table 4-1 and using recent hourly well production data
recorded on July 25, 2006, an MDD (PF MDD)peaking factor of 2.5 will be used in this study.
A value of 3.0 will be used as the PHD peaking factor (PFPHD).
Morning View Water Company
Final Facility Plan Page 14
Per Connection Demand
The population serviced by MVWC is approximately 225 people via approximately 100 active
individual connections. Morning View Water Cornpanyls historical average daily demand
(ADD) for the years 2006 through 2007 was 167,000 gallons.
As an un-metered community, MVWC's ADD consumptive' values are very high (2.9 to 3.4
times) in comparison with metered communities. MVWC should consider conservation
measures such as customer meters as well as a tiered rate structure. The ADD water use for the
current year (2008) is estimated at 165,000 gallons, with anMDD of 412,500 gallons and a peak
hour demand (PHD) of 495,000 gallons. Water demand projections for the end of the 3-year
study period (2011) when full build out is realized are 217,800 gallons for ADD, 544,500
gallons for MDD, and 653,400 for PHD. Comparing Morning View's ADD with the metered
communities of Rexburg, Caldwell and Meridian shows the per connection water demand is
quite high. In the referenced communities the average per connection ADD is 580 gallons
compared with 1,668 gallons for MVWC.
Per capita ADD consumption for these communities ranges from 170 to 200 gpdpc. Assuming
225 people per connection as in Morning View, this equates to 742 gpd per connection. The
state ADD as reported by USGS for public water systems in Idaho for the year 2000 was 260
gpdpc or using 2:9 people per connection, 754 gpd per connection. Morning View's average
demand rate is 1668 gpd per connection.
Morning View's customer base is exclusively residentiaL. Given the rather insignificant demand
currently exerted by other uses, future water demand is estimated in this report solely on the
residential growth projected for the area.
"Unaccounted-For" Water
"Unaccounted-for" water is the difference bet\veen the volume of water produced anà the
volume of water sold to customers. Because the system is currently not metered, a comparison
of production and water sales cannot be made. Unaccounted-for-water in a metered community
is typically the result of system leakage or unmetered customers.
Demand Projections
Population Projections
Land uses surrounding the MVWC system is generally residential, single family homes. The
area immediately south of the platted subdivision has been platted and developed as single
family homes with individual wells. Immediately north is undeveloped land that has a potential
to be connected to the system if economic conditions are favorable. Economic variables include
Morning View Water Company
FinaI Facility Plan Page is
rate structure, cost of development, and prevailing land prices.
Under the current system layout, it has been estimated that an additional sixteen stick built
homes will be added to the system as the remainder of the lots are sold and built on in Divisions
one through three of Morning View Acres. Also, sixteen more trailer sites are in Morning View
Acres, Division No 4. This will increase the total number of connections to 132 for the entire
system. No other growth has been estimated.
Future Water Demands
Currently, the MVWC system accommodates 225 people via 100 connections. Ultimately it is
conceived that the state average of 2.9 people per connection will be served via the same 100
connections plus the addition 16 lots in Divisions 1-3 and 16 more lots in Division 4 making
a total of 1 32 connections and 383 people. It is anticipated that the 32 additional lots wil be
built out by the end of the year in 2011 - three years from now. Producing the following
results:
· Current Estimated
ADD = 165,000 gpd
MDD = 412,500 gpd
,PHD = 495,000 gpd
· 3- Year Planning Horizon
ADD in 2011 = 217,800 gpd
MDD in 2011 = 544,500 gpd
PHD in 201 i = 653,400 gpd
· 20- Year Planning Horizon
ADD in 2026 = 280,867 gpd
MDD in 2026 = 702,166 gpd
PHD in 2026 = 842,600 gpd
While these projected water demands provide a basis for planing purposes and are used in
other portions of this report, they must be considered estimates. If growth from outside
development is allowed, then significant increases from the predicted annual rates will occur
and demands will be much higher than predicted. Unit demand patterns may also change and
these patterns would influence water needs for the community. Therefore, the projected
demands should be compared each year to actual demands. The timing for recommended
improvements can then be adjusted as needed.
Morning View Water Company
Final Facility Plan Page 16
CHAPTERS
Water Supply and Storage
Topics covered in this chapter include water rights, and anticipated water supply and storage
needs for the 3-year and 20-year planning horizons.
Water Rights
Table 5-1 contains water rights information for the MVWC. Refer to Appendix C for a copy
of the current water rights information. A water right permit is the authorization necessary
from the Idaho Department of Water Resources (IDWR) to begin construction of withdrawalfacilities and begin using water. A license is only issued once water has been used and
documentation of use is submitted and approved by the IDWR. A water rights permit does not
guarantee water for the appropriator. A decreed right is a water right that has been adjudicated
by the court. Under the prior-appropriation doctrine, the water right authorizes diversions of
water only to the extent that water is available.
TABLE 5-1
Morning View Water Company - Water Rights
Source Pumping Priority Right Stage WaterRateDateNo.Right
(gpm)cfs (gpm)
Both 650 10/1 0/1995 25-7593 License 0.79 (355)Wells
Water Supply and Storage Requirements
Currently the only storage provided in the MVWC system is in the two 900 gallon pressure
tanks located in the pump house. This provides for a total storage capacity of 900 to 1200
gallons. However, this water is not immediately accessible to the distribution system becausi:
it requires pressurized air to push the tanks contents into the system. This could be done
manually but an automatic air delivery system would make this water available during
outages or emergencies, thus increasing the available water before complete depletion is
realized.
Water Supply Criteria
The following is a list of key criteria outlined in the Idaho Rules for Public Drinking Water
Systems used to determine the timing and development of new water supply wells, storage,
and emergency power generation capability for the MVWC water system.
· The water system must have a sufficient number of water supply wells with backup
power to satisfy ADD or emergency storage equal to one dayls ADD.
· The water system must have enough firm pumping capacity to satisfy MDD.
· Firm pumping capacity combined with additional storage must be sufficient to supply
Morning View Water Company
Final Facility Plan Page 17
Peak Hour Demand.
.. Total system capacity including supply and storage must be sufficient to meet MDD
while maintaining a 20 psi residual throughout the system.
In this report, firm pumping capacity is defined as the production capacity of the water
supply wells in the system with the largest well out of service.
This chapter explores these criteria using the water demand projections listed in above, to
determine the capital improvements needed for the water system during the 3-year and 20-
year plan horizons.
Criterion 1: Emergency Power Required to Satisfy ADD
The first criterion involving ADD is used as a means of determining the emergency power
requirements for the MVWC water system during the 3-year and 20-year planning horizons.
A comparison of the available supply capacity of Well 1 (720,000 gpd), which is not equipped
with backup power, suggests that the MVWC water system currently does not have sufficient
backup power to supply ADD requirements now or for the projected 20 year horizon.
Criterion 1 Summary: Anticipated Emergency Power Requirements
Emergency backup power is currently needed.
Criterion 2: Firm Well Production Capacity Required to Satisfy MDD
The second criterion involving MDD during the 20-year planning period is used to
determine well supply requirements for the Morning View water system.
Current firm pumping capacity totals approximately 200 gpm or 288,000 gpd. MDD
requirements for current, 3 year, and 20 year are 412,500,544,500, and 702,166 respectively.
Existing supply will not satisfy these MDD requirements. In order to meet this criteria, the
Company will need an additional 90 gpm to meet current demands, 180 gpm to meet 3-year
demands, and 287 gpm to meet the 20-year demands.
Criterion 2 Summary: Anticipated Firm Capacity Requirements to Satisfy MDD
The Company will need to obtain additional water rights and construct a new well immediately
with a capacity of nearly 100 gpm similar to Well 1. Or, Well 3 will need to be upgraded
immediately with a capacity of 100 gpm to meet the current demand.
Criterion 3 Well Capacity and Storage Must to Satisfy PHD
The following is a list of assumptions that are used to calculate required well capacity and
storage volume required under these criteria:
· The PHD must be supplied for up to 8 hours.
.. Firm well capacity is not less than MDD.
Using this set of assumptions in conjunction with the MDD and PHD values cited earlier,
the storage needed to satisfy equalization, also referred to as peaking requirements:
0.17 MG oftotal storage required (Current).
0.22 MG of total storage required by 2011
0.28 MG of total storage required by 2026
Morning View Water Company
Final Facility Plan Page 18
CHAPTER 6
Dîstrîbutîon
This chapter describes the capacity of MVWC's water distribution system. The distribution
system was evaluated under existing and future conditions.
Regulations
The Idaho DEQ has regulatory authority over public water systems in Idaho. In general,
DEQ's rules govern the quality of water distributed, but not the manner in which it is
distributed. However, the rules do contain basic construction standards and some of these
apply to distribution systems.
Significant rules for the distribution system analysis are summarized as follows:
.Distribution piping and the supply system shall be designed and installed so that the
pressure measured shall not be reduced below 40 pounds per square inch (psi) during
maximum hourly demand conditions.
.Distribution piping and the supply system shall be designed and installed so that the
pressure measured shall not be reduced below 20 pounds per square inch (psi) during
maximum hourly demand conditions (including fire flow).
.Wherever possible, dead ends shall be minimized by looping. Where dead ends are
installed, blow-offs of adequate size shall be provided for flushing.
.Wherever possible, booster pumps shall take suction from reservoirs to avoid the
potential for negative pressures on the suction line, which could result when th e
pump suction is directly connected to a distribution main. Pumps that take suction
from distribution mains shall be provided with a low-pressure cutoff switch on the
suction side set at no less than 5 psi.
Peak Hour Demand Under Normal Operating Conditions
The PHD condition represents the average demand rate during the highest hour of water use
for the entire year. This is an extreme condition, but one that the system must be able to
supply. Since PHD has been estimated according to projected growth, the actual occurrence
in the system may be higher. It is also true that demands greater than MDD and approaching
the peak hour value will occur several times during a year.
The estimated 2008 PHD for the system is 495, 000 gpd. PHD can be provided in the
system with adequate pressures (Adequate means that pressures are maintained above 40
psi). Pressures under the current PHD can be maintained above 40 psi. As water demand
increases under peak conditions, pipeline velocity can begin to be a problem; however,
Morning View Water Company
Final Facility Plan Page 19
no pipes in the system exhibited velocities significantly greater than 4 fps. In summary,
no deficiencies were identified under current PHD.
Maximum Day Demand Under Normal Operating Conditions
The MDD condition represents the average demand rate over the highest day of water use
during the entire year. The water system must be designed to equal or exceed the MDn on a
firm capacity basis. When MDD is modeled under normal operating conditions, the distribution
system can provide water at adequate pressures.
The estimated MDD for 2008 is 412,500 gpd. No pipeline velocities greater than 4 fps were
identified and system pressures should remain above 40 psi.
Current System Evaluation
Current system demands have historically produced low pressures as shown by the pressure
survey and the numerous customer complaints. Based on the information given by the
operator and observation at the pump building the system appears to be capable of producing
the required flow at adequate pressures except during the irrigation season. It is
recommended to monitor pressures any location experiencing low pressure again during the
2009 irrigation season particularly after the installation of the watermeters.
Morning View Water Company
Final FaciIity Plan Page 20
CHAPTER 7
Water Quality and Regulations
This chapter includes relevant water quality regulation information for MVWC's reference,
with an accompanying description of how pertinent regulations affects the administration and
operation of the system. Surface water regulations are not discussed, as it is not anticipated
that Morning View will be utilizing surface water to meet current or future demands. As
discussed in previous chapters, the water system relies solely on groundwater as its source of
water. Generally, the quality of the groundwater is good, meeting current Federal- and State-
established regulatory limits for inorganic chemicals (lOCs), synthetic organic compounds
(SOCs), volatile organic chemical (VOCs), lead and copper, coliform, arsenic, and fluoride.
Sand in the water has been the primary water quality complaint and the only consent order
action item. Chapter 2 of this report identifies both DEQ's requirements and MVWC's
compliance with the consent order. With the installation of the current sand separator, the
sand problem appears to be taken care of. Continued monitoring as well as quantification of
sand in the production water should be completed. Quantifying the amount of sand produced
and determining the capacity of the sand separator wil likely reduce the amount of operatormaintenance required and provide tangible data for evaluation by the Company and
regulators.
Morning View Water Company
Final Facility PIan Page 21
CHAPTER 8
Capital Improvement Program
Recommended improvements from previous chapters are shown below and summarized in
this chapter, along with estimates of costs. Improvements are grouped chronologically
according to 3-year,and 20-year planning horizons.
Cost Estimating
Cost estimates for proposed improvements presented are Order-of-Magnitude cost estimates.
The American Association of Cost Engineers (AACE) defines Order-of-Magnitude cost
estimates as estimates made without detailed engineering data. These estimates may be
developed using cost curves, scale-up or scale-down factors, or an approximate ratio. AACE
defines the accuracy for this level of estimate as plus 50 percent to minus 30 percent.
The cost estimates presented below have been prepared for guidance in project evaluation and
implementation from the information available at the time ofthe estimate. The final costs of
the project will depend on actual labor and material costs, competitive market conditions,
final project costs, implementation schedule and other variable factors. As a result, the final
project costs will vary from the estimate presented herein. Because of this, project feasibility
and funding needs must be carefully reviewed prior to making specific financial decisions to
help ensure proper project evaluation and adequate funding.
Water Meters
Purchase and installation of individual meters for each residence is based on a 3/4" meter,
meter base and meter box. Administrative, engineering, contingency, and legal fees are
expected to be an additional 25%. The anticipated cost ofthe installed meters for the MVWC
is $2,000 each x 100 customers = $200,000.
Variable Frequency Drives
The cost to purchase and install VFDs for both of the two wells is based on three phase power
and iohp and 30 hp pumps for the welk Estimated cost for thè VFD's is $10,000.
Backup Power Generator
Natural gas or diesel generated power to run the submersible pumps and controllers at the
pump building will require an 80 to 100 KW generator. Anticipated cost for purchase and
installation of the generator including concrete pad and weather enclosure is $40,000.
Dril Water Supply Well
The cost to drill a new well assumes l2-inch diameter open hole production well 200 feet
Morning View Water Company
Final Facility Plan Page 22
deep, The estimate includes costs for a pilot hole and final production well, and assumes the
Company owns the well lot. A 30 percent allowance for contingency, engineering,
administration, and legal cost is included in the estimate. The estimated cost to drill a new
water supply well is $150,000.
Morning View Water Company
Final Facility PIan Page 23
Appendix A
Consent Order Documents
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System Sampling Plan
Morning View Water Co., Inc. Community Water
System
System Information
Syem Kam Morn View Water Co. Inc. Communty WaterSyte.
Da Pructon
Morn View Wate Co., Inc. system is a Communty
Water Sy.
Stte Syste 10: 726003
Th Morng View Wate Syst is supplied by two
sete grundwate wells, naed wel # 1 (Idao IDAE030) and #2 (Idao ID AE29).
Momi View Water Co., Inc. Communty Systemse apprxiately 30 pe.
Morn View Water Co., Inc Communty System
pretl has approately 100 residenti and 3
faty connecons.
Tyca proucton at Morn View Water Co., Inc is
approxitely 173,000 gaons pe day.
Morn View Wate Co., In Communty Wate
Syste se an reents in the upp and lower
neiborhoos of the Communty.
Th Mor Vie Wate Co., Inc Communty sytem
is supplied by tw we lote on the site. Well ar
retily shw (120-130 fee) in grvelly sos withhi sttic levls (40- fet) afec by a hi,vable wate table and sena condtins.
No Trtments or disiects red.
Syem Clssifcation
ID#
Soure Ty
Popultion Se4
Se Coimecton
Intr4ucOD
Soui
Trtmeimt - Diecii
Trtmat - ConoOD Contrl
Storae: Reservoir
Specia Bote:
The 140,000 gaon concrete stadpipe rervir shows
some exer evdence of efervescce and sepa
and has retl ben repad. A replaentreir is pla.
Syste preurs we reported quite low: 40-65 psi.Tls may be rete to the reseoir conditions and/or
opeti levels. Acon to identi the cause is beinaddr.
Marh 7, 2008 1
Februar 29, 2008
DEQ
900 N Skyline
Idaho Falls, ID 83402
As discussed in today's meetig with Rochelle Mason and Greg Eager, I am requesting a
tie extension to fish competing with the requiements of
the Morng View Consent
Order Items:
1. 9d. I am workig with Ryan Loft, PE, to contrct out his engieerig
servces to draf and complete a facilty plang study per item 9d.
2. I made and sent payment of $450 for the accessed penalty in the consent order
on Februar 29, 2008 to the DEQ stte offce.
3. I set the well pump controls at 43 psi and 67 psi, respectively. I am tag
pressure readings in the system to assess the water system improvements
made laS suer to mae sure pressue requirements are being met. The
stdy resuts will be incorprated into the facilty plang stdy by my ,
engieer, Ryan Loft.
4. Five flushig valves were inled on the dead ends and I will tae pictue
and send them to DE\Q for documentation.
5. As soon as the snow melts, I will contact Rochelle to arange a santar
surey.
6. I drafed a sample plan but forgot to brig it so I will sent it to DEQ next
week.
Pleae extend my deadlines to Apnl 15,2008 so I can complete the requirements.
Than you .-f
r~ pyøu
,MORNG VIW CO-IDAHO PUBLIC UTILITIES
POBOX 598
RIGBY, il 83442-0598
Ocobe 24, 2007
Karn Andr
177N 3950 E
Rigby, ID 83442
De Ms. Ka An,
The purse of th notice is to inor you th Mor View public drg wat syst ha be
"diproved" by the Depaent ofEnvien Quty. Notice of
Violaton was isued Septmber 12,
2007.
The violaons cit by the DEQ ar as follows.
1- IDAPA 58.01.08.552.01.b.üb. Prur
ñ. Any public wate system consct or sigcatly moded af July 1, 1985,
sha mata a mium prsur of fort (40) psi thughout the distributon system,
dug pe hourly dem codion. Excludig fi flow, meaur at the seice
conecon or along th prpert lie adjacnt to the coer's premises.
2 - IDAP A 58.01.08.552.014.b.v (Idao Rules for Public Drg Watr Systms)b. Prsu
v. When presur with the system are known to have faen below twnt (20) psi,
the water system mus prnvide public notice and diint the syste.
3 - IDAP A 58.01.08.554.01.a (Idaho Ries for Pulic Drg Wate Systms)
01. Licened Operr Requi
a. Owers of al commun and no trien non-ommun public drg wat
system mus plac the di suion of their drg water syst includig each
trent facilty and/or distributon syst under the respnsible cha of a properly
licensed oper.
To let you know where wer we are wi these violations.
Poin 1. and 2. Wate prssur has be reore We check and rerd well reg no less th every
other day. Our pressure readi ar between 45 an 70 psi Wh our presue fa to 45 psi, th pump
cycles and bnngs the psi back up to 70.
Poin 3. Morg View Water ha retaed a licens oper un we ca get our lice reined.
Morng View is workig with DEQ to aceve fu complice wi the Idao Rules for Pulic Dn
Water Systms and wil contue to kee cuomers inoted.
We would lie to asur you tht we have ben ta wa sales thoug out the tie oflow presur,
and the rert wer al with norm rage.
Sincerely,
Nolan GneitigOpor
MORNG VIW CO-IDAHO PUBLIC UTITS
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Appendix C
Water Rights
~
Page 1 06125/2008
IDAHO DEPARTMENT OF WATER RESOURCES
Water Pennit Report 25-7593
WATER RIGHT NUMBER: 25-7593
OwnerTvpe
Current Owner
Name and Addre
MORNINGVIEW WATER CO INC
46212TH ST
IDAHO FALLS, 10 83401
[phone]
Priority Date:
Basis:
Status:
1011011995
Active
Source
GROUNDWATER
Tributarv
Total Diversion:
Diversion Rate
0.330 CFS
0.460CFS
O.790CFS
Annual VolumeBeneficial Use
DOMESTIC
IRRIGATION
From To
1/01 to 12/31
4/01 to 11/01
Location of Point's) of Diversion
GROUND WATER
JEFFERSON County
GROUND WATER
JEFFERSON County
NE114NE1/4 Sec. 30, Twp 04N, Rge 39E, B.M.
NW1/4NE1/4 Sec. 30, Twp 04N, Rge 39E, B.M.
Place of Use
IRRIGATION
Twp Rge Sec i Nt: i NW i sw i ~i: i
1 NE 1 NW 1 sw 1 SE 1 NE 1 NW 1 sw 1 SE 1 NE 1 NW 1 sw 1 SE 1 NE 1 NW i sw 1 SE 1 Totas04N 39E 30 I 14.0 9.0 I I I' I 23.0I I I I I
Total Acres: 23
DOMESTIC same as IRRIGATION
Conditions of Approval:
1. 26A Project construction shall commence withínon year from the date of permit issuance and shall
proceed dilgently to completion unless it ca be shown to the satisfaction of th Director of the
Department of Water Resources that delays were due to circumstances over which permit holder had
no contro.
2. 048 The use of water under this right shall not give rise to any claim against the holder of a senior water
right based upon the theories of foneiture, abandonment, adverse possession, waiver, equitable
estoppel, estoppel by laches or customary preference.
3. 049 The Director retains jurisdiction of the right to incorporate the use into a water district, require.
streamflow augmentation or other action needed to protect prior sunace water and groundwater rights.
Close
IDAHO DEPARTMNT OF WATER RESOURCES
Water Permt Report
04/1212007
WATER RIGHT NO. 25-7593
Owner Type Name and Address
Curent Owner MORNGVIEW WATER CO INC
462 12TH ST
IDAHO FALLS, il 83401
Priority Date: 10/10/1995
Status: Active
Sourc ¡TriUtal
GROUN.WATER .
Beneficial Use From To Diversion Rate Volume
IRRGATION 4/01 11/01 0.46 CFS
DOMESTIC 1/01 12/31 0.33 CFS
Tota Diversion 0.79 CFS
Location of pointe s) of Diversion:
GROUNWATER ~Sec. 30 Townp 04N Rage39E JEFFERSON County
GROUNWATER Sec. 30 Townp 04N Rage 39E JEFFERSON County
Place(s) of use:
Place of Use Legal Description: IRRGATION JEFFERSON County
\TOWDshiPllRangetlSectionllLotll Tract IIAcresllLotl1 Tract lIAcresllLot"Tract\lAcres!lLoalTractIIAcresl
htt://ww .idwrjdao.gov/appsÆx:SearhlghtReport .asp?BasinNumber=25&Sequence... 4/1212007
-1104N IU~I~IUINWILIUId). r,
Place of Use Legal Description:DOlvSTIC same as IRGATION -
1139E 1130 II lUi II II
Tota Acres: 23
Conditions of Approval:
Project consction sha commence with one year from the date of permt issuace and shall
'I.26A procee diligently to completion uness it can be shown to the satisfacon of the Director of the
Deparent of Water Resources tht delays were due to circumces over which permt holder
had no control.
The use of wate under ths right sh not give ns to any clai agai the holder of a senior
2.048 water right based upon th theories offorfeite, abadonment, advere possession, waiver,
equitable estoppel, estppel by laches or cusomar preference.
The Director reta jursdicton of the right to incorprae the us into a water distrct, requie
3.049 steaow augmentation or other action neeed to protect prior suace water and grundwater
rights.
A flow measment port or other device as spifed by the Deparent shal be intaed by the
4.oie right holder to provide for the ination of meag eqpment and the determtion of the
rate of diversion by the Depaent.
5.03A The rate of diversion of water for irgation under th right and all other water rights on the same
land shal not exceed 0.02 cubic feet per seond for each acre of land.
6.004 The issuace of ths right does not gr any right-of-way or eaement across the land of anther.
7.Domestic use is for 48 homes.
8.04 Right holder shall comply with the drin pet requiements of Section 42-235, Idaho Code.
Dates:
Prof Due Date: 07/0111994
Proof Made Date: 10110/1995
Approved Date: 07/15/1991
Moratorium Expirtion Date:
Enlarement Use Prority Date:
Enlargement Statute Prority Date:
Application Recived Date: 05/14/1991
Protest Dealine Date:
Number of Protests: 0
Field Exam Date: 7/29/1998
Date Sent to State Off: 413012002
Date Received at State Off: 5/6/2002
Field Exam Remark:
Other Information:
State or Federa:
htt://ww.idwr .idaho.gov/appsÆxtSearchlghtReport .asp?Basinumber=25&Sequence... 4/12/2007
. Owner Name Connector:
Water Distrct Number:
Generic Max Rate pe Acre:
Generic Max Volume per Acre:
Swan Falls Tru or Nontr:
Swan Falls Dismissed:
DLE Act Number:
. Car Act Number:
Mitigation Plan: False
Close
htt://ww.idwr.idaho.gov/appsÆxtSearh/ghtReport.asp?BasinNumber=25&Seauence... 4/12/2007
/
;;OR'M202 l)l)/"216 ;/ ~~qo ~~
V~',~ ~~APPLICATION FOR PERMIT
~ (( .. ~ ~ . ~ ~eqJ:J To appropnate the public waters of the State of Idaho
\.~v ~~~.ieti 1Id- ~~
~e~~0~1Name~cant~ /l~t; ~ Phone?A 7'£-"d2f
Mailing addresS +'¿/ :4:C, ~t? _ '
2. Source of water supply tfbQc!4.b which is a trbutary of
_3. Location of point of diversion is Township ~ Range 'LIU Sec. dà
~ai po~:~,,nWa:;' G~~ -Nt::~ /?£
4. Water will be used for the following purposes:
Amount ¿ Sd ". for );dRflP(L
(cfs o;are-fee per annum)Amount for
(cfs or acrfee per annum)Amount for
(cfs or acre-fee per annum)Amount for
(cfs or acre-feet per annum)Amount for
(cfs or acrefee per annum)Amount for
(cfs or acre-feet per annum)
Ident. No. 7.5- 1'1/e¡Cr
STATE Of IDAHO
DEPARTMENT OF WATER RESOURCES li~ID
, in' the 1/4,
County;
purposes from / tiv. /
purposes from
~ (both dates inclusie)
to (both dates inclusive)
purpoes from to (both dates inclusive)
purposes from to (both dates inclusive)
purposes from to (both dates inclusie)
purpses from to (both dates inclusive)
5. Total quanti to be appropnated is (a)6'&2cubic feet per send
and/or (b)
acre feet per annum
8~ jf~
6. Proposed divertng works:
a. D,~cribe type and size' ~f devices used to divert water from the source(" 1&~ ~¿.s - d:¿¿U¿'d;Ù.s~~a ~ d~$ .7 /b. Height of orage dam feet; acte reservoir capacity acre-feet; total
reservoir capacit acre-feet
c. Proposed well diameter is inches; proposed depth of well is feet
d. Is ground water wih a temperature of greater than 85°F being sought? ~
e. Ifwell is already drilled, when? ; Drillng firm:le d~~I1#..
Well was drilled for (well owner) ; Drillng Permit No.
7. Time required for completion of works and application of water to proposed beneficial use is .. years (minimum 1 year)
8. Description of proposed uses (if irrgation only, go to item 9):
a. Hydropower; show total feet of head and proposed capacit in kW.
. b. Stockwtering; Jist number and kind of livestock.
c. Municipal; show name of municipalit.
d. Domestic; show number of households.
e. oter, describe fully. /.; Áauu,, .t/ LM #~4M~ ¡kr la.
~~~~A'ii. _~'.;~'~;:.;~.~..
:~t;~1 ;. ~ ¿Gfr~
Appendix D
Well Logs
ver'~tJ IDAHO ~r)~~~~~';)
1.DRILUNGPERMITNO~.:S-~"L.e- ó~J'-tK ~
OtrlDWR No. :i;: 7,,e:4
~~WNER:AI LAX, G N~/"1ÍíV6 _
Addre88 ) t4~ s £¿ g ALO. "srhE. ttCit j:D P, k 4'. pit LL. $ State..ZI 1U 40 ,
3. LOCATION OF WELL by leal descripton:
Sketch ma lOti !I agr wi wrn loctin.
Ofce Use Only
Inspeed byTwp_Rge_Se__1/4_114_1/4
la .. Lo:
o Pump l! Baler oAJr o Flowg Artian
Vl _.l.D..Pum i.TI
Water Tem.
water Qulit te or comets:
Bottom hole temp._
Deth fit Water Encunter _
12. LIOLOGIC LOG: (De rers or ..nd) W8l
Twp.:t Nor ~ or Sou 0Rge. Eas li OJ Wes 0ESe. .. .~1/4..1/4--1/4:~lD~~~~eirR1/
9 Add of Well Sit 3 ',r~ ~ ~ d 1:
IV tØ R T"", Cit.. _ , ß_ -(G .. .. i. at rv l 0I tD Ra eM Un
Lt. B1k. Sub. Name., " d N ,'" Lví'f: W
4. USE:
o Domestic 0 Munipal 0 Moor 0 Irro Tlnnl 0 Injec 0 Otr M u Lr,LÆ. Otl
5. TYPE OF WORK chek all that appl (Repnt etc.)~ New Well 0 Moif 0 Aben 0 Ot
6. DRILL METHODo Air Rotary ~ Cable 0 Mud Rota 0 Otr
Il Fmm To Re: liho. W.. Qu & Tem yDi H
'L J a i:r d JljJ, L E Ko(,/YP' KT ~
1.1 ~/J ~n , ~, '"--,,)
I.)/J"..;¡, '"~,.~
'I -tA A r. W *i/F. L...
7A ,.r i 'A u,..L' N A- i//~ J ¿
ii''''A ",~¿,i i/~
£'7 "...,I~".II
L ,.,r- N I\- v F_ i
i:j Jø p I¿ L .. ,r-i '1
..~
i t: ~ ~.- · " t: :.~n.. ......, ~~~__ NeSO.ifcøs
. :.-
:iCE~-~,
l1 ,~r::o .:
Cole De 1 I 'F (Me~~1
Da: Strted .~ ¿- - "'l /Coleed 7-:iTi- '/
N
'I
Vi
7. SEALING PROCEDURES
!oa;;wl
Was dre &h use ii YON Sh Deths)
Was drie shoe seal tested dY DI Ho
8. CASINGINER:~-ß~~~g~
ME
Un..We Th
.r 0o. 0o 0
Leng of Headi~ length of Tailpe
9. PERFORATIONSICREENS
o Perforations Mehodo Sceens SC T~
I-I '" æ-ic.
o
o
o
o
o
o
13. DRILLER'S CERTINATIN
lIe oe tht aU mim we coruio stnd were coplie with at.the time 1h rt wa re.
LIr
Arm Name Finn No.3' CJ
10. STATIC WATER LEVEL OR ARTSIAN PRESSRE:
::.3 ft. below gronå Artesia presure _lb.
Depth flw encountered ft. Deribe acc port or
control devices:
\Date
(Si on it Rm Oll & Opreto)
FORWARD WHITE copy TO WATER RESOURCES
Arm Ofl
an
Supr or Optor
STATE OF IDAHO
DEPARTMO/'~,\OF WATER RESOURCES
WEll D~..LLER'S REPORT
Sta law relr that this nirÌbe fi wit th Dirr. Depent of Vlii R_rc
wi1h1n 30 cta af the CØet or abnmt of th well.
rm23S-7
82
,j/
USE TYPEWRITER OR
BALLPOINT PEN
:~::.i:.: ..
7. WATER LEVELi. WELL OWNER ~(;(I LlU4 pI! "''l 14,,,tit!"L-t
Name -'a I Q"' b ~*,' ,,""
Addre /If,d 5k 7l~b'1 frtt~
Owners Pennit No.
8. WELL TEST DATA
2. NATURE OF WORK
~_ well 0 De 0 Replaement
o Abandned (deribe abandonment procdures such 81
materials. plug deths. etc. in litlogic logl
Stic water levl øFloing? 0 Ves gfoAran closin prreCorolled by: 0 Valve 0 CaTempeatre OF. Qulity
oe¡¡s;n", ,._'me z_s be/ow
fee below land surfac.
G.P.M. flow
p.s.1.
o Plug
o Pump o Salle o Air o Other
Dlsd G.P.M.PUlnguo HQU Pumi
3. PROPOED USE
lrDoes 0 Irron 0 Tes 0 Municpa
o Indstial 0 Stock 0 Wast Dissal or Injecono Other (spfy typel
4. METHOD DRILLED
WR°tary
o cable
o Air
o Dug
o Hydraulic
o Oter
OR_rot
S. WELL COSTRUCTION
Caing scedule: ~I D Concet 0 OtherTlclMl 01__ From Toe LS inces ~ Inc + -L fee -. feetinces Inces fe feinch. ines - fe - feinches ines == fe == fe
Was cang drl ii us? M"es D NoWas a paer or _i use? ì5 Ves at~ed? DVes ~o
Ho perfor? 0 F8Cry 0 KnIfe 0 Tor
Size of peraon _ Inc by _ incNumbr Frm Topeio fe feperans fe fetpeniio fe feeWell scen Instled? 0 Yes ~o
Maflres namïyPl Mod No.Diimet_Slotslie _SefrÐn _feto_feDla Slot size Se fro fe to fe;;
Grapaked? 0 Ves ~. 0 S1ieof\l1 -Plac fro fe to feSurf~1 de .. Mat us In se: 0 Cø gr
(Ø 8eite 0 Pulin clay 0
s.ln prre use: 0 Slurr pit 0 Temp. surt cengCOre to'" dellod of joining caing: 0 Th ""el 0 SoWel
9. LITHOLOGIC LOG
Bor De it..Pni To,,_.' . ~? ". ,:;l'" -;
873~=l1We_Mi1 V.. No.. -.. \lI -y
o Ceen be sita
Desribe lI po
6. LOCTIO OF WELL
Slet map loion mus agee wit wri loon.
N
, -t- i. .---- --T-, IW-. ~E'+.'. i--+-- --+--i iI I
Subdivi Name
Lot No. _ BIo No.
')~rS~ -
.l%~Se~ ,T. '+ ~.R.~.
s
Conty
."11 '~Il~
""
_ 'AAA -U.., ~v .-
.,~.~, ~y_ ,.:.,,~. :"!l'-"~
r ~I ::-'"
: Uf.. ""
~
10.Worsu ~1C ll finsh \'?e" ~
11. DRILLERS CERTIFICATION &J
I/We cefy tht all minimi m wel cclo sts we
çømplie lI at th tie ti t! - re.
Finn Nem '" - - r L IIlinLFIn No. ie
Adre ~ q/j:rll,~ Oa1l L 2P ~
(;: OfclJ //2.~ Æ-,~' .. -,end r'- ':\ ~ ~ /(Opeat) "- U ~.~, -: \ "
USE ADDITIONAL SHEETS IF NECESRV - FORWARD THE WHITE co TO THE DEPARTMENT
::~~bAddre~ ~
Owner's Peit No,
USE TYPl:WI1II I:t'. un
lPi/"t!lr~ALL~OINT PEN
J.i ) ~-Stsl_ reir tIattlis re be fi wi 1h Direc, Deof Wat R ..i ':.1,.. '. ( ;~~~ ~
within 30 de 8f lbe -. o..blndOf ohbe well. V,v,;, "" ~~ 'J(l
7. WATER LEVEL ,:;'_hl$
Stc Wat level S S fet beow lanG ~It
Flowing? D Yes pi No G.P.M. flowArtan cl-in prre p.s.i.Contlled by: D Vøle 0 Ca 0 Plug
Tempere _OF. Quality
STATE OF IDAHO
W~~~ó~"J~~;;~ R~~;~~T
n 238-7
3
. NATURE OF WORK
11 Newwell 0 Dee 0 Replacentb Abaned ldebe met of eblng)
8. WELL 1'ES DATA ~ '.
D Pup 0 BeUer 0 Air D Other
oi..G.P.M.Pumpng..,Hou Pump
l. PROPOED USE
pf Doesic 0 Irrgaon 0 Tes 0 Municipalo Industl 0 Stok 0 Wa Displ or Injeono Oter (spify tYpe)
o Aotirv
pi Cable
o Air
o Dug
o Hydnilii;
o Other
o Reer rot II "
Waú
Yei No
I"" .
'I '
Ý.
'oL
Me~~,r~:." ..l. METHOD DRILLED
~
~,
II
L'
..
"'
'I-.
x
)l
'J
,r " -
5. WELL CONSRUCTION ,/
.,
fefefe
To
,1)1 fefefe . '..
.. I 'X'.
IiNo
-.. '" ~I ,I) ;~ ii;: !? II WI 15 'IIH _iJ~.. "" I
.1m.! 2i= IQii
n .. VI n"teKesun es
10.Worsie!.k IS -~a finised a_ ~..- ~ J.F
DRILLERS CERTFICATION c.b d L
I/We ce tht all minlmui wel costctn stars were
i:mplled wi at th time 1h rig was. remov.~--~..~Firm Nøme Finn No. 3 ,3 S
Addre fèØ ~ D"~ :u-rl
Sign bY (Finn Ofiã~~an 8~'lOpen) W~"\ A "i!
6. LOCTION OF WELL . . /~ ~) 11.
o Ske map loilo must agee wit wrtæioc. ~ ~/o N '" \--..
. ... t .' ... Subdlvblon Name ,~ . ,l--.!-r--~- -
:.~~~_t-+E ~'.' ... I--~-- --t-- Lo No. _ Blok No..' I .00.. S 0;y~~~Yi % SI. 3., T. .. NIK R.~ E~
~ USE ADDITONAL SHEET OF NECESRY - FORWARD THE WHITE co TO THE DEPARTMeN
Appendix E
Water Production Data
Morning View Water Co., Inc.
An Idao PUC Reguated Company
3996 E. 200 Nort
P.O. Box 598
Rigby, Idao 83442
Offce: 208-745-0029 Fax: [phone]
Date Sta End Total #of Gals. PerReadgReadillservicesHousehold
Januar 12/31/05 24521200 89
Febiucy 1131106 24185600 264000 90 29318
March 3/1/06 25001700 2161000 91 23747
April 4/2/06 252361000 2344000 94 24936
May 5/31106 261014000 8653000 95 91084
June 6/30/06 270303000 9289000 95 97779
July 7/31/06 . 28360000 13301000 97 137124
Aup;st 8/31/06 296210000 12606000 99 127333
i September 10/2/06 303056000 6846000 99 691512
October 10/31106 304775000 171900 99 17364
November 11/30/06 3061200 1347000 98 13745
December 1/2/07 3077390 1611000 98 16500
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t-eo LU U~ U~:Uc:¡o Nolan Gneí'tíng 208-745-0041 ¡O. 3
SECTION II Water Level InfOl iination (Optional data if available)
Depth to ~ater. Recotd the .dare. jf the pump was.oa' 9r off,.-oríf Other nearby pumps were on.
Static Water Level (pump off, water level stable): ft. Date
. Dynamic Water Level (pump on): ft Date
Section III Rate of flow ahd volume divertd (RQUIRED DATA)
Meter information:
Make Model No.Serial No.
Does the meter totalizer measure in acre. feet o~ (circle one) Whai is the muliiplier?
Does ihe meier Taie of flow indicator sb0v80r cfs? (circle one) What is the multiplier')
For meters without rate of flow indicators, check here 0 and see page 4 for meter information and rate measurement
methods.
Reading of the meter totalizer, flow rate and discharge pressure should be taken and recorded once each
month on or near the same date. Please provide the actual totalizer reading and not the total volume
since last reading.
Date Oe('~'~ i Totalizer Flow Rate Discharge
(date of readjn~)31/(Ol 7.' Readin2 (circle: cfs or gpm)Pressure
January ( ~ I )3 teßSa 0 no()3'i? -.110'-'50 - 'í.S
February (1,'1 )370/ 'f i hbO 37v.~/w So-~
i Marh (~I )3'1 iint/ 000 ()o - '" ()J So - (pçApril (2-u):JT/.-:f'"OOO 3 7l)- L/OO ::D -" ~-J J ..!)~.
May (~O)2 '¡r.' ., r .) .... DO . 310-400 ~o -711~ v.l.'r.fL)
June (;šú )3'3:1 n -J Çl fXO 310 -'"IOU -So - "/ù! l _ Li'
July (';1 )""I D i ~I ':/ ,. ODD 375- J.öú ç(¡- '/5'
August ( ¡;'D Ao/I ~ 85 :¿OOD b7o- £100 So- '1'5
September (d-e¡)Af.Î (:7 ll 'i.e bOO :'"'0 - '-00 So. ./~_~. ~ 1-"
October ( ~())Ao/J. q aRL()o 370 -'/00 f;) -~'(-
November (~e)~/3 ù (~'L("Ðö 3Sò ---100 $.i. - . 75Decembei ( 3/)'- 3 £. f 6 i3 000 3';0 --. oc;5(; - . r-/5
Do totalizer and flow readings above include meter multipliers? _Yes_No
Total Acre-feet OR Total Gallons (p~ 11"15,000
(there are 325,850 gallons per acre-foot)
Calculatìons or Comments (If flow meter was installed, calibrated, or replaced dunng this reporting year,
Please note the dale.)
~
Appendix F
Water Company Documents
.
.
00'1....~~/
I D 1~(Poo(p3
p t;.¡f;'ii:; n If'-- \"!I~:'=~96il1ft:!..'
MornIDg View Water Coo, Inco
An Idao PUC Reguated Company
3996 E. 200 Nort
P.O. Box 598
Rigby, Idao 83442
rE~;:: .¿~ (J '.;~': :;)
Df.A QIRAHe", ';'..-l~~~BYn 'l ~-"--:t:_..._.
Offce: 208-745-0029 Fax: [phone]
Febru 25, 2008
Rochelle Masn
Dearent of Envionmenta Quaty
900 N. Skylie Dr.
SuiteB
Idaho Fals, Idao 83402
De Rochelle,
Ibs leter is to inorm you that the Rocky Mounta ha a power outge on Sunday
Febru 24, 2008. Ths oute afted over 1700 peple in Jeffern County. We were
one of the sites tht lost power. It took jus over one hour for the power compay to
complete reai andreS"iore power.
As soon as the power wa restored, Nolan Gneitig went to the well house and flushed
and reet the system.
S.~~y, dJ/4...../J~
iol~ Gneiti
Operator
ccfie
faxed 2125/08
SCANNED
/FEB 2 6 200~
Offce: 208-745-0029
Morng View Water Co., Inc..
An Idao PUC Reguated Compay
3996 E. 200 Nort
P.O. BoxS98
Rigby, Idao 83442
RECEIVED
APR .11 2008
DEQ-IDAHO FALLS
Fax: 208~745-001
Apr i 0,2008
Depaent ofEnviomnenta Quty
900 Nort Skyline Dr.
SuiteB
Idao Fals, Idao 83402
Rochelle Masn,
. As you have re the pre on the wa sy ha ben set-up to cycle and SO
poun low and 75 pounds high Howeve, in the pa th ha blown out some of the
wa syst in the maufed home addition. Most of thes are plumbed with 3/8"
diameter PEX pipe and the ficton loss is rey high and the pipe is of exly low
quaty. Becau of th poenal damage we ar denyig any liabil on our pa for
wa damage wi-in the trei.
Should you hae any prblem with th, plea cota me at 74S..29
Regads,
;/~/T1t .
~oian Gneiti
Maner
Morn View Water Co., Inc.cc/fie
SCANNED
APR j i 20Sl
Morning View HOmeS)").From:
To:
Sent:
Subject:
"Morning View Homes" -:morningviewhom~westnep.
"Rochelle Mason" -:Rocelle.Masn(§deq.idaho.gov:;
Monday, July 23, 2007 8:51 AM
DEQ Mandate
RECEIVED
JUL 242007
DEQ-IDAHO FALLS
A TTENTlON: Rochelle Masn
REGARDING: Morning View Water Co., Inc.
July 23, 2007
Please be adivsed that as of July 20, 2007 at .3:30 p.m., well tr was fully functonaL.
The following was done to accmplish this:
1. The old pump and motor has been removed from the well casing.
2. The pump and the motor have ben replace.
3. The system has been con~rted to a three phase eleccal system.
4_ The leaks have been repaired and the well has ben chlorinated.
We believe we are in compliance wi the DEQ mandate, dated July 6, 2007, and inside the time frme allotted.
.i:~AOperations Manager
copy on file I, ~ce _ ,##x?~
JPA '7~/ .d..~":.. /7 /i~ A;:=~ß-~¿3~
.~
SCANNED
JUt 2 l 207 7/23/2007
.o¡
Exhibit D
Morning View Water Co., Inc.
An Idaho PUC Regulated Company
3996 East 200 Nort
POBox 598
FUgby, Idaho 83442
Office: 208-745-0029 Fax: [phone]
mornngviewhomes~qwestoffice.net
June 4,2009
Morning View Water Customers,
This letter is to inform you of an informational meeting to be held by Mornng View
Water Company on Tuesday, June 9th 2009 ~ 6:30PM in the meeting room of the Rigby
City Librar located at 110 North State Street. The followig people will be in attendace
to share information about the company and answer any questions you may have
regarding company proceedings.
Rob Haris
Holden, Kidwell, Crapo & Hah
Greg Eager
Deparent of Environmental Quality
Ryan Lofts
Aspen Engineering
We look forward to your attendance and encourage your paricipation. Than you for
your attention to this matter.
Sincerely,
r~rr;;¿~'.',
//
Nolan Gneiting
Morning View Water Company