20211013Reply Comments.pdf

Reply to Comments of Commission Staff Case No. NSW-W-21-01
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Hookup Fee & Reserve Fund , ,i .,. :^ ,.:-,lli!u,*n
We have never constructed/repaired a water system for a developer before North
Star. We called it a hookup fee and apparently we shouldn't have. What we called
the hookup fee was actually our other company Black Water, LLC's profit for going
through the engineering process, DEQ approval, and repairing the water system.
We have since fixed this and sent the developer an invoice for work completed.
See attachment 1 Invoice. Therefore, we will not have that reserve fund. When we
started this project we thought it would be a good idea to have some reserves for
the water system. However, it seems that we are basically being penalized for
having reserves and not being able to charge the rates we feel appropriate
because of it. Black Water LLC will have to loan North Star LLC some funds in the
beginning because it will not be able to generate enough revenue to covers its
expenses. Please see attachment 2 North Star Water Operation & Maintenance
Expenses.
Revenue Requirement and Rate Base
Our revenue needs to be higher than $19,869 per year. When you adjust for the
correct sampling schedule, and budget for reserves more revenue needs to be
generated. I also added a few additional rows to the North Star Water Operation &
Maintenance Expenses (attachment 2) that were previously missed these include
Sanitary Survey (once every 3 years) $166.67 per year, WaterAssessment Fee
$100 per year, Consumer Confidence Report $100 per year, and Public Utility
Commission Regulatory Fee $50 per year. We budget $500 for every sanitary
survey. This equates to $125 per hour for 4 hours. We prep for the sanitary survey,
meet DEQ at the water system for the inspection, and turn in any paper work
required. The water assessment fee is just a fee that DEQ charges us every year
for the water system. The consumer confidence report covers office staff
generating the report each year and sending it out to everybody on the system.
Repairs
The $500 for Repairs and Maintenance expenses should be added back into the
budget. There will no longer be a reserve account.
Lab Testing Fees
Attachment No. B. Lab Testing Required by IDEQ has several errors. Total
coliform & E. coli are required monthly not annually and the price is $17 for both.
Nitrate & Nitrite both cost $19 a piece not $35. Volatile Organic Contaminants are
not on the table and they are required quarterly the first year, then annually for 3
years, then every 3 years. A group called Semi Volatile Organic compounds was
left out of the list of Synthetic Organic Contaminants. lt costs an additional $250
and is quarterly for at least 1 year then every 3 years. PIease see attachment 3 for
emails from Brandon Lowder at IDEQ regarding the missed SemiVolatile Organic
Compounds. I made a new spreadsheet for North Star's Sampling costs for
2022-2030. See attachment 4 North Star Sampling Costs. The average annual
sampling costs over the 9 year time frame is $1702.89 per year. North Star first
year of sample is going to cost $8,443.00. This is an average of $703.58 per
month. We will have to start sampling when 10 homes are connected so we will
only be receiving 41o/o of our revenue when we have this expense. See
attachment 5 Sampling requirements at 10 home occupancy. How are we
suppose to pay these costs when you state that under Reserve Fund, .Staff
recommends that these funds should be placed in a separate account, and their
usage be restricted to emergencies and major unplanned capital expenditures
such as leak repairs and other unplanned replacements." The sampling costs are
planned expenses that you are not allowing us to budget for. I am very confused
on how the commission staff is estimating the sampting costs at $600.67 per year.
There will no longer be a reserve account. !t is not fair to make a company charge
less than what it actually costs to run a water system just because they have
reserves. With the Public Utilities Commission recommendations the system
would be bankrupt within a few years.
Equipment and Spare Parts
The $1,000 for inventory and spare parts should remain in the operation and
maintenance expenses. The subdivision may take a few years to build out. lt
doesn't make sense for us to have to carry these expenses for an extended period
of time when as you can from above we wil! spend $8,443.00 on sampling in the
first year.
Rate Design
We do not agree with merging the two and charging one flat rate. lt makes sense
to have them as two different line items on the bill. We can adjust the following
year if more expenses are the potable/irrigation vice versa.
Late Payment Charge
ls there a ldaho Code that actually states what we can charge for a late payment?
With our previous experiences the less of late fee we charge the more often we
get late payments.
Reconnection Fee
Our proposed rates of $35 for reconnection during normal business hours, and
$70.00 when the request is after normalbusiness hours is completely reasonable.
See attachment 6 Google Maps Office to North Star Water System The North Star
Water System is 25.9 miles from our office. 51.8 miles roundtrip. This drive takes
approximately t hours and 14 minutes. If you count our employees time at what it
costs us including socialsecurity, medicare, unemployment tax, workers comp, for
just the drive time, not time for reconnection, and the mileage we would pay our
employee for driving the 51.8 miles it costs us $59.30. ls there an ldaho Code
stating what I can charge for this? I appreciate the staffs recommendation but it is
completely out of touch with reality. lt also doesn't make sense that municipalities
are allowed to charge these kind of fees when they are generating much more
revenue but you guys want to restrict small businesses from charging a
completely reasonable fee. As you can see from above the $35 reconnection fee
is being very generous.
Black Water, LLC
PO BOX 3723
Nampa,ID 83653
lnvoice
Date lnvoice #
l0t7/2021 7260
BillTo
Elevation 2500 Partners LLC
10284 W. River Rock Lane
Garden City, Idaho 83714
P.O. No.Terms Project
Quantity Description Rate Amount
Water system upgrades-labor and materials 75,000.00 75,000.00
Total $75,000.00
Payments/Gredits $0.00
Balance Due $75,ooo.oo
Phone #Fax #E-mail
208-250-9275 208-461-3098 blackwaterllc. [e-mail]
Attachment 2 - North Star Water Operation & Maintenance Expenses
North Star Water Svstem Oneration & Maintenanm F-xnenses
Year
I ).4 5
Ceteqoru IVlonthlv Cost Annual Cost Annual Cosf Annual Cosf Annrral Cosf Annrral Cosf
Contract ODerator s450 00 ss 400 00 $5.400.00 $5-400.00 $s-400.00 $5.400.00
Sanitarv Surverv (once everv 3 vears)$ r 3.89 st66.67 $166.67 s166.67 $166.67 st66.67
Routine Maintenance (labor + Materials)$20.83 $250.00 $250.00 $250.00 s250.00 $250.00
Renairs $41.67 $500.04 $s00.04 s500.04 s500.04 s500.04
Eauioment and Snare narts $83.33 $1.000.00 $1.000.00 $l_000.00 s1.000.00 s1_000 00
Power $445.00 s5-340.00 $s.340.00 $5-340.00 ss_340.00 s5.340.00
Lab fees $142.00 $l-704.00 $1 704.00 $t-704.00 sl-704.00 s1.704.00
Insurance $120.00 $l-440.00 $l-440.00 $l-440.00 $1.440.00 s1.440.00
Office and Billins $200.00 $2.400.00 s2-400.00 $2_400 00 s2.400.00 s2.400.00
Office Suonlies- Postape- Notifications s20.00 s240.00 $240.00 $240.00 s240 00 $240 00
Other utilities ss0.00 $600.00 s600.00 s600.00 s600 00 $600.00
Professional Services $200.00 $2.400.00 $2_400.00 s2.400.00 s2 400 00 $2.400.00
Water Assessnrent Fee fDEO)$8.33 $100.00 s100.00 st 00.00 st00 00 sl00 00
Consumer Confi dence Renort s8.33 s100.00 s100 00 st00 00 sl00 00 sl00 00
Puhlic Iltilties Commission Repulatow Fee s4.1 7 sso 00 s50 00 s50 00 $50 00 s50 00
[,andscane/ weed control sl00 00 sI,200 00 sl 200 00 $1 200 00 sl 200 00 sl 200 00
Suhtotal $1.907.55 s22_8S0 70 $22 890 70 s22 Rgo 70 s22 890 70 s22 8S0 70
Reserve l)eht seroice (Asfl 1?ss 4qq q6 $5 499 96 $5 49S 95 s5 4SS S5 $5 4SS 96
Total O&.lvl Emense with ?o/" inflation ??6( Rq (rR 100 66 s29 242 1R sio I ls 6s s3t 021 24 s1l SSi 9i
Revemre s2 400 s28 800 00 s28 800 00 s28 800 00 s2R R00 00 $28 800 00
Profit $34 ll s409 34 -s442 38 -$1 ils 65 -s). ))1 ),4 -$? t5i 9?
M Gmail Black Water LLC williams-black <[e-mail]>
North Star Water Monitoring Schedule
6 messages
Black Water LLC<blackwaterllc. [e-mail]>
To: Brandon. Lorder@deq. idaho.gov
Wed, Sep 22,2021at5:11 PM
HiBrandon,
I am looking for a sampling schedule for North Star Water so I can get an annual average price
over to the public utilities commission. ls this something you could help with?
Thanks,
Taylor
Black Water LLC
PO BOX 3723
Nampa, lD 83653
[e-mail] randon. Lowder@deq. idaho. gov>
To: blackwaterllc. [e-mail]
Thu, Sep 23,2021 at 6:48 AM
Cc: [e-mail]
Sure. l' m copying Lisa Bahr on this email. She is the drinking water compliance person at Southwest District
Health that wil! have oversight of the system. She can correct anything I might get incorrect. I was contacted by
Johan Kalala Kasanda from the PUC on September 3'd for this same information, so I would think they already
have it. Below is the list I sent him. I assumed North Star will not have any disinfection or other treatment, but if
that is incorrect, let me know and l' ll update the list. The distribution counts are based on population served,
so I assumed a brand new system with a population less than 100 to start off. lf additional wells are added, they
would follow the same requirements as I have listed for Well#1.
Well#la
Thanks,
Brandon
o lnorganlc Gontaminants (Antimony, Arsenic, Barium, Beryllium, Cadmium, Chromium, Fluoride,
Mercury, Nickel, Selenium, Sodium, Thalium) - Every three years
o Volatile Organic Gontaminants - Quarterly for at least 1 year, then annual for 3 years, then
every 3 years
o Synthetic Organic Contaminants (Carbamates, Chlorinated Herbicides, Diquat, EDB/DBCP,
Endothall, Glyphosate, Chlorinated Pesticides/PCBs) - Quarterly for at Ieast 1 year, then every 3
years.
o Nitrate - Annually
o Nitrite - Every9years
o Radionuclides (Gross Alpha, Uranium, Radium 226, Radium 228) - Quarterly for 1 year, then
reduced anywhere from 3 years to 9 years depending on the results.
Distribution Svstem
o Lead and Copper - 5 samples every 6 months. After two six-month rounds, reduced to annual.
Aftertwo annual rounds, reduce to every 3 years.
o Total collform and E coli - l sample monthly
Brandon lowder ] Drinking Water Compliance Supervisor
ldaho Department of Environmental Quality
1445 N. Orchard, Boise, lD 83706
Office: (208) 373-0s68
http ://www.deq. idaho. gov/
Our mission is to proted humon heolth ond the quolity ol ldoho ' s oir, lond, ond woter.
lQuoted text hidden]
Black Water
LLC<blackwaterllc. [e-mail]>
To: [e-mail]
Thu, Sep 23,2021at 9:29 AM
Cc: "Bahr, Lisa" <[e-mail]
Yes, you are correct, no disinfection. Thanks, !'ll let you know if I have any more questions.
Thanks,
Taylor
lQuoted text hiddenj
Black Water [e-mail]>
To: [e-mail]
Cc: "Bahr, Lisa" <[e-mail]>
HiBrandon,
Fri, Sep 24,2021 alll:42AM
I saw that Semi Volatile Organic Compounds isnt included with the Synthetic Organic
Contaminants. \Mren I called the lab they include this test with the SOCs package. Was this just
missed in your Iist or should we not be having the Semi Volatile Organic Compounds ran when
SOCs are due?
Thanks,
Taylor
lQuoted text hiddenl
[e-mail]<[e-mail] Fri' Sep 24'
To: blackwaterlh. [e-mail]
Cc: [e-mail]
Yes, sorry for the oversight. Semi-volatiles would be included in the SOC group and are
required.
Thanks,
Brandon
lQuoted tsxt hiddenl
1 at 11:57
A[{
Bhck Wabr LlGcbladnraterllc. [e-mail]>
To: [e-mail]
Cc: [e-mail]. gov
Okry that' s what I thought. Thank youl
Thanke,
Taylor
lQuoted text hiddsnl
Fd, Sep 24,2@1at 11:59 AM
North Star Sampling Costs
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Attachment 5 - Sampling Requirements at 10 home occupancy Emails
M Gmail Black Water LLC williams-black <[e-mail]>
First year water sampling lor 23lot sub
Brandon. [e-mail]<Brandon. Lorder@deq. idaho. gov>
To: [e-mail]
Fri, Apr 30,2021 al
6:4,4 AM
That sounds about right. We typically average about 2.5 people per home, so at 10 homes,
you' d have 25 people. Please make sure to reach out to either me or your other drinking
water contact at DEQ. I can tell you exactly which compliance person if you let me know the
system name or number.
Brandon
[Ouoted te]t hiddenl
Attachment 6 -Google Maps Office to North Star Water System
Google Maps
n via l-84 W
Fastest route, the usual traffic
El via W Karcher Rd
El via E Greenhurst Rd
2930 East Deer Flat Road, Kuna, lD to 16890 Long
Meadow Dr Caldwell,lD 83607
Office to North Star Water System
Drive 25.9 miles,37 min
Map data @2021 Googlo 1 ml l--l
37 min
25.9 miles
43 min
26.3 miles
45 min
25.0 miles
Explore 16890 Long Meadow Dr
Restaurants Hotels Gas stations Parking Lots More