20130709Comment.pdf

3358$North Kelso Drive/013 JUL 5 f 8 t9 Spirit Lake,Idaho $3869
LIP:SL July3,2013
Idaho Public Utilities Commission
P.O.Box 83720
Boise,Idaho 83720-0074
RE:CASE NO.SPL-W-13-01
REGULARITY OF READINGS
One of the points overlooked at the presentation which should be addressed at the Public Hearing is the
regularity with which Water Meter Readings are taken.It is common knowledge in the Community,that Meter
Reading is difficult under normal Summer conditions,but virtually impossible during Winter conditions in this
Enforced Plat.
MONTHLY BILLING
I recommended to the Commission that one possibility would be for the Company to set up a Monthly
Billing formula based on Statistical Inference.This proposition requires that a Unit Data Base for water usage
actually exists.Present billings are January,April,July and October with a 30 day grace period for payment.
I believe the Commissioners will appreciate,that if this condition cannot be resolved in dealing with a
relatively small sample size,Monthly Water Billings are more likely to become a major and contentious future
issue for all concerned.There are several options out of this dilemma,mainly based on existing On Line
Banking,or Advanced Payment for examples.Otherwise,twelve checks per year by U.S.Postal Service.
CONDITIONALLY FAVOR MONTHLY INCREASE SUBJECT TO INCREASED MONTHLY
ALLOTMENT
In my Straw Poll.of the Enforced Plat,(Fifteen Resident Owners to date and growing),I do not find a
great deal of resistance to the Company’s request for a Rate Increase,I believe this is a result of the improved
service the Company has rendered over the past five years.I did find a General demand for an increase in the
Monthly water allotment tied to any increase in the Monthly Charge.It was evident that my previous
recommendation for an increase from 1200 Cf to 1500 Cf was inadequate in view of the requested 106%
proposed increase in the Monthly Charge to $24.75.
LOT 111
PROPOSED MONTHLY INCREASE IN WATER ALLOTMENT
It is proposed that an increase to 1800 CF for the Monthly Allotment would be more appropriate to all
concerned.Looking back to the late 1970’s it was apparent the proposed Monthly Allotment was considerably
greater than the present allocation based on the Developer’s request for Water Rights..This proposal when I
spoke with some of the residency’s going back to the 1980’s,would offset Summer usage to Winter usage and
allow for any Irregularity of Meter Readings during the year Overages would be accommodated by $0.15 for
each additional 15 Cubic feet used.The computation ofthe Overage Expense is virtually the same as at present.
CONDITIONS OF APPROVAL
As pointed out at the Public Hearing,Water Rights 96-07849 and 96-08830,(Affirmed in the Idaho
Department of Water Sources letter of February 4,2009,Water Right 95-9949 confirm the Location and
Diversion as well as Usage solely within Kootenai County),Those Rights when combined shall not exceed a
total annual maximum diversion volume of 148.5 Acre Feet for irrigation of a total of 49.5 Acres and 219.6
Acre Feet for in-house use for a total of 316 homes.There are 313 Ten Acre Plus Tracts in the Enforced Plat of
Spirit Lake East.“Domestic use under this right does not include lawn,garden,landscape,or other types of
irrigation..”The 65 Five Acre Tracts in the Treeport Public Plat in Bonner County are not included in these
Rights and may appropriately have been be addressed elsewhere.
It is apparent the present allocation of 1203 CF fails to take into account the diverse nature of the
Enforced Plat of Spirit Lake East,which in its Corporate “Codes,Covenants and Restrictions provides a
uniform plan for the development of the property and for residential,recreational,or agricultural purposes and
rural atmosphere and charm which is compatible with the natural environment and,further to provide every
practical and legal means to safeguard and protect the interests of all Owners and the stability of the
development.”
It isn’t difficult doing the math,from the language of the Grant,that,R.A.Hanson Company Inc.,the
Developer of the Enforced Plat and Owner of the Water,Road and Utility Rights had the intent,as the original
Owner and Developer,to provide a Monthly Allocation of slightly over 2500 CF of Water at a cost of
approximately $12.00 per month..This is without any provision for irrigation as contained in the language ci
the above Grant..
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LOT 111
REVISION OF PREVIOUS REQUEST TO INCLUDE 1800 CF ALLOCATION AT NO ADDITIONAL
COST PROVIDED THE REQUESTED MONTHLY INCREASED IS APPROVED.
In view of th,foregoing,it appears that an adjustment of the Monthly Allocation to Residents of the
Enforced Plat of Spirit Lake East to 1800 CF per month is now recommended.I believe it is well within the
Original intent and purpose of the Developer,and availability and capability of the system to provide an
adequate supply of water,is justified and so requested..
Respectfully,
Association Incorporated
Spirit Lake East Water Company
P.O.Box 3388
Coeur d’Alene,Idaho $3816
ALL INTERVIEWEES
)irit Lake East
P.O.Box 217
Spirit Lake,Idaho 8
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