20130715Amended Comments.pdf

ZI3 JUL 1 5 9 oo 3358$North Kelso Drive
Spirit Lake,Idaho $3869
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JTL1]ISS C):i’.
July 12,2013
Idaho Public Utilities Commission
P.O.Box 83720
Boise,Idaho 83720-0074
RE:CASE NO.SPL-W-13-O1 REQUESTS FOR COMMENTS
In view of further research and discovery,I wish to amend my previous comments
as follows:
REGULARITY OF READINGS
One point overlooked at the presentation,is the regularity with which Water Meter
Readings are taken.It is common knowledge to Residents,that Meter Reading is difficult
under normal summer conditions,but virtually impossible during winter conditions.
The following information is taken from the Policy Information supplied by the Company
to its Users.“Meters are read on the last day of each quarter except on Dec.31,when an
estimate is made.”
LOT 111
MONTHLY BILLING
With due respect to whatever consideration the Commission may decide regarding
the proposed Rate Increase to $24.75.I offer a proposal,under the authority of IPUC
Rules Governing Customer Relations,for their mutual consideration and approval:
“The authorization and imposition of a One Time prepayment requirement equivalent to
Three months service for existing and future clients”
At contracts termination,an appropriate refund or final billing would adjust any
existing balance.If acceptable to the Company,this accommodation would serve to
stabilize the Company’s income stream and enable it to continue with its existing Policy of
reading meters and Billing on a Quarterly Basis as outlined in its Policy Statement.
This procedure is consistent with policies set forth by many Municipal Service
Companies.I previously recommended to the Commission one possibility would be for
the Company to set up a Monthly Billing formula based on Statistical Inference.This
proposition requires 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.
A policy change,would serve as an interr1ediate stage to such time in the future
when the Company at its option may remotely monitor the reading of Meters.At that
future date the frequency of meter reading and billing may be as simple as the clicking of
a computer key directly relating consumption and prearranged billing to the Client’s
account.
I believe the Commissioners will appreciate,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.
LOT 111
CONDITIONALLY FAVOR MONTHLY INCREASE SUBJECT TO INCREASED
MONTHLY ALLOTMENT
ifl my Straw Polling of,Twenty Resident Owners,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 viewed by some
as inadequate in view of the requested 106%proposed increase in the Monthly Charge to
$24.75.
The Monthly Allotment,established in the 1970’s by the Company to provide 1203
CF (9000 G),is an antiquated accounting provision.It was based on the Company’s
inability to provide the oversight necessary to currently monitor the system.It is a
carryover to the present Owner,serving as a fiscal crutch to accommodate the system.
Whether it is 1000 CF or 1500 CF really has little significance tied to the Quarterly
reading of the Meters.At some future date,the system will of necessity be upgraded to
accommodate and respond to supply and demand.The Company will certainly modify
Billing requirements at that time.Residents of this Community have already experienced
these changes in their accounts with respect to the Kootenai Electric Company.
This antiquated policy is part of the contractual agreement between the parties set
forth in the Policy Statement.In my opinion and subject to a substantial increase in the
Monthly Assessment,conventional usage could merit an increase to an allotment 1500 CF,
(11,222 G)without detrimental effect to either party.
LOT 111
PROPOSED MONTHLY INCREASE IN WATER ALLOTMENT
The Proposed Monthly Increase In Water Allotment is withdrawn.The Allotment is
mainly a matter of convenience to the Supplier and User.
CONDITIONS OF APPROVAL
The Enforced Plat of Spirit Lake East,in Kootenai County and Public Treeport
Plat,in Bonner County were included in the Municipal District approved by the Idaho
Department of Water Resources,95-9865 in 2009.IDWR has no knowledge of any
exclusivity although it was included in the language of a previous allotment.In that
respect,my previous comments are historical and are withdrawn.They describe the
acquisition of Right of Way Easements,recorded December 15,1997 on Lots 300.301,
313 and a Beneficial Interest in Lot 271 for access,by Treeport Residents to the Private
Roads in SLEPLAT.These ROWS contain existing waterlines servicing the Treeport Plat.
It is not difficult doing the math,from the language of the Grant,that,WA.Hanson
Company Inc.,Developer of the Enforced Plat and Owner of the Water,Road and Utility
Rights;possessed the capability,as original Owner and Developer,to provide a Monthly
Allocation of slightly over 2500 CF of Water at a cost of $12.00 per month.This is without
provision for irrigation as contained in the language of the above Grant.
REVISION OF PREVIOUS REQUEST TO INCLUDE 1800 CF ALLOCATION AT NO
ADDITIONAL COST PROVIDED THE REQUESTED MONTHLY INCREASE IS
APPROVED.
In my opinion the Monthly Allotment is more of an accounting convenience than a
necessity to the Company and Residents.Subject to the Company’s Review and
Approval,a revision to the Policy to provide an allotment of 1500 CF would be an
accommodation to both the User and the Supplier.
LOT 111
This concludes my participation in the solicitation of Commentsj awaiting the
Commissioners’review and decision.
My comments are based on Materials:
Provided by the previous owner and my continued residence,since occupancy in June 1993.
General Rules and Regulations for Small Water Utilities dated Mar 6 -‘84 effective April 1
‘84.Issued by the Spirit Lake East Water Company
Frank B.Carr VP
Provided by:Eric J.Davis,SWR Agent,Idaho Department of Water Resources.,
Water Rights 95-9865,95-9949,96-8830.
Provided by Attendance:SLEHOAINC Quarterly MTG November 8,2005
Provided by Residents:Response to Mailings,Telecon,No Internet,Conversation
Provided by:Idaho Public Utilities Commission
Respectfully submitted,
Spirit Lake East ‘Association Incorporated
P.O.Box 217
Spirit Lake,Idaho $3869
Spirit Lake East Water Company
P.O.Box 338$
Coeur d’Alene,Idaho $3816