20070503Comment.pdf

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2211 North 14th St.
Boise, Idaho 83702
May 1 , 2007
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I'm writing as a private citizen to voice my opposition to the pending application of
United Water Corporation for a Special Facilities Agreement (SFA) to expand its area of
service into the Dry Creek drainage area, specifically to serve the Avimor planned
community and perhaps some other developments thitfare being contemplated for the
general vicinity. As has been pointed out by the City of Eagle, the proposal is ambiguous
in its key provisions, especially with regard to the precise area of impact.
Having reviewed the relevant materials posted on your Web site, I am convinced that
while this proposal might benefit United Water and Avimor, it is not in the best interests
of the community as a whole, especially current UWC customers.
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While the speCific 9ccasion for the req~est is the provision of water to A vimof Phase I
estimated cost $1.7 million, the proposal asks for UWC's area of service to be expanded
considerably beyond the limited Phase I area, resulting in an increase of the infrastructure
costto, $6) Il1illiort ,While the
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Suncor/Avinior, ilieywouldbeit~imbuI'sedbyUWt , for all but thIs $1.7 million. Inother
words, Suncor/Avimor would end up getting a $6.3 million water system to cover all
phases of its development at a cost of$1.7 million, with the $4.6 million difference beingpaid by UWC ratepayers.
Along with the infrastructure expenses for this larger area, of course, comes the need for
more water. As the March 17 IPUC Staff Comments indicate, the amount of water
required to supply this area could exceed the levels generated by UWC's Columbia River
Plant, which are 6 times those estimated in this current Application; and as IPUC Staff
points out:
When revenue generated from new customers fails to cover the cost of new
supply sources required to serve them, the general body of ratepayers pays
the additional costs,
I a~ one ofthose ;atepayers; ~d I stronglyobjectt~ having rhy ~~tes raisediil ~rder to
fundJhisproj.ej:L
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1\ fu.t;t:her ~~~~d~r~ti9n,~!? t)1fi.tt~~,aqditi,QJ7.8:1 ph~ses of~h~,AyiII1qf ,p.rQject
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been approved tor development; and so forIPUCto approve' this' application worild' .
Guilford: Page 2
amount to a prejudgment that these later phases will indeed be approved, and it would
also allow A vimor to argue during their approval process that water is not a concern, that
it has all been taken care of in advance,
Let's take it one phase at a time. Avimor and other developers should be required to pay
all water expenses for projects that have already been approved, and new projects should
not go forward, especially in such high desert areas, unless they can demonstrate that
adequate infrastructure and water supplies are available without additional costs to
current ratepayers.
Copy to
Ada County Commission