20080911Comment.pdf

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Jean Jewell
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westonscottdavis(§hotmail.com
Tuesday, September 09,20082:18 PM
Jean Jewell; Beverly Barker; Gene Fadness; Ed Howell
PUC Comment Form
A Comment from Weston Davis follows:
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Case Number: ROC-W-98-91
Name: Weston Davis
Address: 4 N. Birch Cir
City: Rigby
State: Idaho
Zip: 83442
Daytime Telephone: [phone]
Contact E-Mail: westonscottdavis~hotmail. com Name of Utility Company: Rocky Mountain Utility
Co.Add to Mailing List :~
Please describe your comment briefly:
I am concerned by the itemized charges Rocky Mountain Utility Company is proposing to recover
as a basis for its request of $42.59 a month. Of foremost concern is that raised by IDAPA
31.36.91.193 Presumptions of Contributed Capital, where it is presumed the capital investment
in plant associated with the system is deemed to be contributed, and non-recoverable by the
company.
In the protective covenants of the subdivision Section 4.6 the subdivider recognized this
principle by stating: 'All lots shall have a central water and sewer system provided by the
Developer and included as part of the lot.' However, pages 23 - 26 of Rocky Mountain's
95/13/98 application show the company is working against the covenants and regulatory
presumption of contributed capital, because it seeks to recover the cost of contributed
capl tal for the water system. These attempts to recover contributed capital are labeled
'Refurbish Costs', i Depreciation net of refurbish costs', i General repair services', and
, Emergency. ' These costs to recover the cost of the water system make up a large share of
the proposed expenses and are impermissible, as we have already paid for the system as part
of our lot. As a result, the utility company i s request should be reduced by its attempts to
recover capital contributions.
The utility company also mentions in its application that it requires $3,999.99 a year to
maintain its park. However, during the whole summer it has only mowed the lawn two or three
times. It appears this is another attempt to use a utility company to recover a capital
expenditure of providing a park, instead of a recovering a legitimate utility expense.
Additionally, this company runs a sewer company for the subdivision. While I understand you
do not currently regulate sewage, the sewage utility company has shared office expenses with
the water utility, which should be considered in reducing the water utility's labor, staffing
and other reported costs. Failure to do so may result in a double recovery of several
expenses by running both a water and sewer utility company.
Further, I am aware that eight residences in the subdivision were just occupied last month
and that another eight residences will soon be completed and occupied. The increase in
occupants should reduce and distribute the burden of the cost on the number of residents
stated in the application.
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Several of the occupants of the subdivision are young families and older couples on a limited
budget. We would appreciate your close attention and consideration to these issues.
The form submitted on http://www . puc. idaho. gov /forms/ipuc1/ipuc. html
IP address is 75.174.58.99
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