20150814Comments (2 Total).pdf

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Name:Allen DeLaney “:
Case Number:SCH-W-15-01,Schweitzer basin Water Company ;tl H”1,‘‘1 .e-mail:[e-mail] t .tfl
Telephone:[phone] IAddress:446 UlIr Drive,Sandpoint,ID 83864 UJLI CO
Name of Utility Company:Schweitzer Basin Water Company
Idaho Public Utilities Commission August 11,2015
P.O.Box 83720
Boise,ID 83720-0074
Re:Case SCH-W-15-01
Dear IPUC Commissioners:
I would like to comment on the application under your consideration by the Schweitzer Basin Water
Company,LLC (SBWC)to become a regulated utility.
My credentials to comment upon this application include that I am a customer of SBWC now for 10
years;I am a partially retired graduate industrial engineer and physician with considerable experience as
an owner’s agent in the construction and management of medical facilities involving extremely complex
plumbing requirements under NFPA,&other regulatory agencies requirements.
I’ve reviewed a number of documents and letters on the present subject in the public domain,attended
some meetings of parties involved in commenting upon this application,and interviewed the owners of
SBWC.I’ve observed the behaviors in public meetings of many of the individuals that have chosen to
submit written comments.Additionally,I’ve reviewed detailed maps of the water system including
piping specifications,together with much of the available engineering data available to the owners of
SBWC.
Several items seem to be clearly evident from my review,listed in the following not necessarily in strict
order of importance:
1.A number of written comments are by parties involved with the Schweitzer Fire District (SFD).
Hopefully,the IPUC is aware of the lawsuit filed by SFD against SBWC.Interestingly,the multiple
hydrant lack of sufficient flow criteria that is a major basis for the lawsuit is not met by nearby
communities to include Bonnets Ferry,Pondetay,&others.Further,from information available
to the public,it seemclear to me as an engineer,that SFD has no clue,nor a constructive
engineering solution to the problem their lawsuit seeksto address.Certainly commentary by
present and former SFRD commissioners must be considered in light of the present lawsuit.
2.The oldest parts of this water system are more than 50 yrs old,and almost all major lines were
not built to present standards of piping diameters,or piping pressure specifications.The
present owners bought this water system when it was over 25 yrs old.Engineering details and
piping locations at the time of their purchase were sparse to be kind.Peak water demand has
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more than tripled due to increased population,but per capita water use has actually decreased
due the SBWC ongoing program if finding and repairing leaks ever since they purchased the
system.
3.There is a recurring allegation of malfeasance,lack of infrastructure investment,and lack of
attention to the water system by the owners by Mssrs.R.Lowe,Flener,Hutton,and Alexander.
Although I am a part time resident on Schweitzer Mountain,I know that the SBWC owners have
expended considerable funds placing new wells,constructing a new 100,000+gallon concrete
reservoir,and on a yearly basis marking valve location,repairing/replacing valve access covers,
and replacing broken lines,and identifying leaks during my 10 yrs.of residence.The large
reservoir mentioned above,together with the associated well,and feeder lines to the main
system cost in excess of $300,000,doubling SBWC storage capacity.Note that Mr.Alexander
and Mr.Hutton are not on the SBWC system for water supply
4.The new reservoir approximately doubled the water stored in the system and hence the ability
of the SBWS system to meet an emergent issue such as fire fighting
5.Given the fact that the present owners purchased a system with only partial documentation at
best,the following is an example of what has been required to find a leak.In 2013,dropping
reservoir levels indicated a major leak of at least 14,400 gal/day.Mr.Bailey,and Ms.Bell,the
SBWC owners,both engineers of considerable experience,then spent over 400 hours by my
count searching for the leak.I found them out every day for over 6 weeks on our local roads
searching.They hired an outside expert with electronic listening equipment to no avail,and
eventually isolated the leak to a section of Mogul Hill Road on their own.Finally they dug up a
pipe section in that area only to discover a large,failed,and leaking valve in a manhole buried
three feet below the present paved road surface.That valve was documented absolutely
nowhere on any document received from the original water system owner.
6.The SBWC presently covers an area with approximately 1000 ft of elevation change.I recently
had the opportunity to review a piping survey of all major lines and connectors of the SBWC
piping.As an engineer,my informal opinion is that over half of all the main lines would have to
be replaced with larger pipe of a higher pressure specification,and at least three new
interconnects between main lines installed to give the system some improvements towards
meeting the multi-hydrant flow specification referenced in the lawsuit referenced in No 1
above.I have no recent experience in this area of construction,but doubt that upgrade could be
completed for less than several million dollars,which would also include extensive road
trenching and reconstruction.The Idaho Insurance Rating Bureau has previously stated that
upgrading the system as described above would not result in any real property cost savings to
the home owners.
7.Fire Hydrants.There seems to be a lot of mis-information being written by the previously
referenced comment writers.I am sure the IPUC commissioners are aware of these issues,but I
want to make sure they are part of the public commentary.The facts as I understand them are
as follows:
a.The original system had NO fire hydrants.
b.After the present SBWC owners bought the system,they began to be involved with the
local community,and contributed by local involvement,and by their taxes,to create a
local rural fire fighting district.
c.They then agreed to allow property owners to install fire hydrants at property owner’s
expense as a fire fighting aid.All involved should note that the system was NEVER
designed to support the water flow require by a fire hydrant with multiple hoses
attached and the valve full open.Nor is/was the system ever required by Idaho DEQ to
provide fire fighting water flow rates.SBWC fire hydrant flows are between 400 and
lO6Ogal per mm,which is more than most Idaho rural systems can provide.
U.Initially,all who opted to install a fire hydrant did so with the understanding that they
also were responsible for maintenance,and that the SBWC system was not capable of
meeting national firefighting flow standards
e.Mr.Flener was chosen by the Schweitzer Fire chief to be on the contested hearing
Board.The local judge,at the show cause legal meeting,stated that the Schweitzer Fire
chief did not have authority to cite the SBWC,nor to choose the people for the
contested hearing Board.The judge then stopped the meeting,and made a court date
for the SBWC to find a remedy against the Schweitzer Fire District
8.Leaks,and responsibility for location and repair of leaks.Reading through the public comments,
several things stand out.I am glad Mr.Flener discovered several leaks.I just hope he doesn’t
expect SBWC,or any other water company to repair leaks on his property in his piping.
There are many dozens of springs and seeps throughout the SBWC service area due to natural
drainage patterns.My opinion is that over a service area this large,with extensive topography,
all in the community should share in the responsibility to spot leaks and notify the owners.
9.Mr.Hutton seems very concerned in his public comment about the accounting of this presently
private company.He sits on the Board of a tax funded entity,the Schweitzer Recreation District
fSRD).As the public record indicates,neither he nor other SRD Board members have any
problem leasing space owned by a Board member for storage of the SRD shuttle,nor does he
have a problem with being involved with the board considering purchase of that storage from a
Board member,nor considering a 50%year over year increase in rent paid by this tax funded
entity to a Board member without any evidence of a competitive bidding process.Until the cold
light of publicity shown upon the SRD board,they were also considering expenditure of taxpayer
funds to purchase this storage space at what I judge to be at least a 40%premium to
comparable commercial storage space in the area,again without any evidence of a competitive
bidding process to protect the public interest.The IPUC should carefully consider Mr.Hutton’s
new found concern about community interest and conflicts of interest.
10.I’ve listened to many conversations on Schweitzer Mountain amongst residents,sat in on one
Fire district commissioner’s meeting,and spoken extensively with the SBWC owners about the
issues of fire protection and water pressure at various locations about the service area.There
seems to be a paucity of constructive commentary.From the tone of the Spring Fire District
Commissioner’s meeting,there may be a lot of personal conflict and animosity involved.My
professional opinion is that there is no financially feasible way for this water system to meet the
multi hydrant flow test advocated by the SFD.However,I do agree with one criticism of the
SBWC ownership,as follows in item 11.
11.SBWC COULD address a number of individual site issues within the water system that I believe
are valid criticisms.My belief is that they should proffer these to the community as part of an
attempt to work together with the SFRD.We would all benefit:
a.SFRD is clearly guilty of NOT communicating proactively with SBWC.It is obvious that
the SFRD performs flow tests without communicating with SBWC,in spite of multiple
requests by SBWC.BOTH entities should be involved in pressure/flow testing.
b.The two entities should work together to attempt to find financially feasible solutions to
improving fire hydrant flow on those hydrants with the lower flow rates.In return for
their monopoly on the water system,financial criteria for SBWC to improve hydrant
flow at the worst hydrants at their expense should be developed.
c.There is one fire hydrant that exists on the downstream side of pressure reducing valves
that presently restrict fire hydrant flow.Moving the fire hydrant up-stream of the
pressure reducing valve would result in a significant improvement in hydrant flow.
Every hydrant with improved flow improves collective community fire protection.SBWC
should offer this as an initial proffer to increase cooperation with SFRD,and accomplish
the work forthwith.In fact,the SBWC made written recommendations for system
improvements presented to the SFD Chief in his office on September 14,2014,which I
personally reviewed prior to this letter to wit:
i.Move fire hydrant 6 as I described above
ii.Reconfigure the system to allow increased flow and pressure to the fire hydrant
in the Die Schmetterling building parking lot
iii.The same modification would probably increase water pressure and flow in the
fire hydrant at the cornice Condo
iv.Locate the source to an apparent constriction in the main line under Telemark
road near NW Passage road that SBWC thinks is limiting flow to the hydrant by
the Eagle View Condo.
U.The SFD has NEVER responded to the SBWC proposal detailed above.Absent any
response from SFD,SBWC chose to temporarily reconfigure the water system as
described in item ii.Above.This temporary fix only made a marginal improvement in
pressure at the Die Schmetterling and Cornice Condo hydrants of about 10%.SBWC has
proposed making that reconfiguration permanent at the time any development occurs
on the land between the two affected water mains.
SBWC completed item iv.Above at the end of September 2014 which did in fact improve
water flow from the hydrant near the Eagle View Condo from nil to 520 gal per mm.
Meanwhile SED filed the present actions against SBWC.SBWC has suspended listed
improvements such a i.above pending the outcome of the present action.SBWC offered
these improvements to SFD as an initial proffer,but SFD has never responded.
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e.It MAY be the case that replacement of one or more pressure reducing valves with more
modern ones of larger flow capacity would contribute marginally to improved
downstream flow.An impartial opinion from an experienced hydrological engineering
firm unrelated to all parties would help.Certainly,given the acrimony present between
SBWC and SFRD,both parties should contribute to pay for that opinion.However,the
owners of SBWC,both experienced engineers,attended training and have already
attended Cla-Valce Company (CVC)training sessions,the company that made the
pressure reducing valves in the system.CVC’s opinion is that the benefit in increased
flow would be negligible,especially since the total cost per valve replaced would be
about $40,000 ea.
f.There are three additional hydrants whose bases could be lowered,which would give an
estimated improved fire flow at those valves of about 10%.That project would not be
excessively expensive,and two of the hydrants are in lower flow areas of the water
system.All three hydrants described herein were installed at the SFD Fire chief’s
request.SBWC told me they will lower these valves if the property owners that own the
valves make that request.
g.SBWC clearly needs to separate accounting for the water system from the rest of the
owner’s businesses IF they become a Regulated Public Utility.They have rights today as
a private business,but meeting reporting standards of the IPUC may contribute to
resolving some of the loss of trust they suffer at present.I have discussed this with
them,and as I understand it they are communicating with John Nobbs of the PUC for
this past year concerning reporting requirements.
Allen G DeLaney,MD,ME
Systems and Industrial Engineer’
Consulting Sports &Wilderness Medicine Physician
Owner,University Park LLC,a real estate rental and management firm in Gainesville,Florida
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August 10,2015
Commission Secretary
Idaho Public Utilities Commission
POBox83720
Boise,Idaho 83720-0074
Comments on Case SCH-W-15-01
Schweitzer Basin Water Co
Several comments come to mind from being a customer of
Schweitzer Basin Water Company (SBWC)since the time our
house was built on Mogul Hill in 2000.
The first comment concerns the character of the hot water
from the time of moving into the house until sometime in 2014.
The hot water apparently picked up copper as evidenced by
looking thru a couple of inches of bath water and seeing a
strong,not subtle,blue color.Also,the base of the plastic
shower stall turned blue over a short period of time.The
house has all PEX potable water tubing from the outlet of the
water tank to the faucets;however,the hot water tank itself is
an indirect heated system with a large internal copper coil
transferring heat to the potable water.We presumed the heat
in the tank accelerated the reaction between the acidic
incoming water and the copper coil to corrode the copper and
release the chemical into the outgoing hot water.In addition to
the blue color,flakes of what was probably copper sulfate
would work thru the hot water lines and clog screens in most
all of the faucets.Around 2014 the owners of S3WC notified us
that an injection pump using a base liquid had been added to
the water system.From that point on the creation of blue
copper material just about disappeared in our system.
The reason for the this discussion is to point out that in the
owners application,the last paragraph of Attachment 8,DEQ
Source Water Assessment Report,Dec.4,2000 ,the last
paragraph of this report states “Corrosion is a possible concern
because of the slightly low pH of the system’s water.Levels of
copper have been discovered above the action level for copper
within the distribution system as a result of the water’s
corrosiveness.”Although knowing this years ago and similar
concerns of other users of the system,it took 13-14 years for
SBWC owners to come up with a significant improvement to
the problem.
A second concern has to do with the water flows thru the fire
hydrants throughout the system.Attachment 23,Subpart D,”
Rules and Regulations,Rev 6,Nov 2010”Section 25 addresses
water for firefighting.25.2 indicates that SBWC takes no
responsibility for flows or lack thereof thru customer installed
hydrants.Later in section 25.6 SBWC claims that system
water is only for potable use,thereby unilaterally taking no
responsibility for sufficient water in their system available to
fight fires.At the time of building our house,we installed a
hydrant using a certified contractor.However,we have never
seen a copy of these Rules.Were they originated before any
hydrants ever were installed?Does such a set of rules have any
legal standing when enacted unilaterally sometime in the past
with no notice to customers and providing legal protection
only for SBWC?Are the homeowners who acknowledge
nearness of a hydrant when applying for homeowners
insurance essentially committing fraud if these rules are not
known and minimum flows are not happening?
Lastly,a question arises when looking at Attachment 20,“2012,
2013,2014 Last Three Years financial Statements”.Under
fixed Assets,item 390,Structures and Improvements,the asset
value jumps sometime in 2014 by an amount of $413000.
Below in Long Term Liability the liability amount jumps from
$0 to $290000,mortgage payable,also in 2014.There appears
to be no obvious new structure visible,beginning in 2014,in or
near other components of the water system.Can we ask for an
answer to what that asset might be and where it is located?
$3 00k-$400K is a significantly high valued asset added to the
water system with no apparent visibility!
We are friends with the Bailey/Bell family,and remain so;as a
water system customer of SBWC for 15 years we have a vested
interest in the provision of water service to our community
and felt the need to raise the questions and comments above.
Sincerel
,17
Richard and Carroll Ensminger
1053 Mogul Hill
Sandpoint,ID
From:Dick and Carroll Ensmlnger [e-mail]
Subject:Correction to comments made by the undersigned in response to Application SCH-W-15-01
Date:September 15,2015 at 3:52 PM
To:Mel Bailey scIiwetztrmtbbgmail.com
hard copy of this e-mail being sent to:
Commission Secretary
Idaho Public Utilities Commission
P 0 Box 83720
Boise,ID 83720-0074
Mel ,Marsha,
Your copy of the “Application for Water Service”we signed back in October,2000 you provided
us recently completely negates our response in the subject comments with respect to hydrant flows
and the “Rules and Regulations”
of the SBWC in effect at the time of building our house.We have no excuse for not having retained
our copy of such agreement nor of the recollection of reading said Rules and sincerely apologize for
unsubstantiated comments of hydrant flows in the response to the Commission.We hope that section
of our comments is stricken from our letter to the Commission and our apology is accepted by you.
Dick and Carroll Ensminger
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