20231130Affidavit C. Thaden.pdf

From: Brad Pfannmuller <[e-mail]>
Sent: Thursday, May 18, 2023 5:17 PM
To: Curtis Thaden <[e-mail]>
Cc: Sarah Martz <[e-mail]>; Bill M. Hadlock <[e-mail]>; Cole Coba
<[e-mail]>; Paul Bierlein <[e-mail]>; Catherine Cooper
<[e-mail]>
Subject: Avimor - INCA Public Charter School
Good Afternoon Curtis,
Thanks for taking the time to talk with me yesterday afternoon about the water service to the
Charter School here in Avimor. I have attached a couple of plans that show this lot was part of a 2015 -
2016 Phase 5 Avimor Village subdivision. This lot was designed to have a 12” water main stubbed to it
for the future school. (see the approved plans) the approved plans was to also have a 16” Transmission
main heading north to future phases of Avimor. After much negotiation between Suez and the City of
Eagle the future development land north would be served by the City of Eagle so the 16” main would
not be extended to the north. It would be ideal for the school to just run a loop from the 12” stubbed
line to the site and loop it around the school and back to the 12” stubbed line since it has no other
future service needed north of the school site. Veolia has stated that the school is required to install a
main in McLeod Way because there is not one there currently, but our stance is that the 12” Veolia main
exists on both sides of McLeod Way and it does not benefit anyone to run this line between the two
intersections. Since we have been asked by Scott with Veolia to contact the PUC we are reaching out to
see if we could have a zoom meeting with your department and Veolia to get this resolved quickly since
the school is slated to open in the fall of 2024 to reduce the current overcrowding in the valley schools.
Please let me know if you have any questions and if there is a time that works for you your team.
Thank you for the time on this matter.
Sincerely,
Brad R. Pfannmuller
General Manager
208.899.1061
[e-mail]
EXHIBIT 1
Page 1 of 1
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EXHIBIT 2
Page 1 of 3
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EXHIBIT 2
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EXHIBIT 2
Page 3 of 3
From: Pierce, Scott <[e-mail]>
Sent: Thursday, May 25, 2023 10:32 AM
To: Curtis Thaden <[e-mail]>; Rick Keller <[e-mail]>
Cc: Catherine Cooper <[e-mail]>
Subject: IPUC - Idaho Novus Classical Academy
Curtis & Rick,
Thanks for meeting with us today to discuss this Project. Attached is the PDF of Design Options we were
referencing during the meeting today and the Avimor Subdivision #5 VEOLIA Plan.
VEOLIA's review of this Project finds that this is not a Service Connection but is a Main Extension.
o Rules and Regulations Governing The Rendering of Service.
▪Sheet No.28
▪7. The Company will make all connections to its existing mains which
front the property to be served and will furnish, install, and maintain all
service lines from the main to and including the meter box or vault,
meters and service setting. The meter box or vault shall be placed inside
the curb line or Company right-of-way. All service lines shall be property
of the Company and shall be accessible to and under its control. In
instances where the existing mains do not front the property to be
served, the Applicant shall enter into the appropriate main extension
agreement as provided under Company's Rules and Regulations
Governing Main Extensions.
SInce no VEOLIA Main fronts this Property a Main Extension is required.
o Rules and Regulations Governing Water Main Extensions
▪Sheet No. 37
▪61. The normal routing for water main extensions shall be in dedicated
streets. The Company may, but will not be required to, make extensions
under this rule in easements or rights-of-way where final grades have
not been established or where street grades have not been brought to
those established by public authority. If extensions are made when
grades have not been established and there is a reasonable probability
that existing grade will be changed, the Company shall require the
Applicant(s) to deposit the estimated cost for altering the facilities
installed.
▪Sheet No. 38
▪62. Company shall design and be the sole judge as to the adequacy of
any water main extension and appurtenances.
▪Sheet No. 39
▪69. A water main extension must extend to the extreme property lines
of the building lot to be served.
We feel that the proposed Main Extension below meets our Tariffs and is in the best interest of our
existing Customers.
EXHIBIT 3
Page 1 of 2
Thanks
Scott Pierce
Construction Supervisor
Idaho Operations (Municipal)
VEOLIA NORTH AMERICA UNITED STATES
Office
[phone]
8248 W Victory Rd / Boise, ID 83709
[e-mail]
www.veolianorthamerica.com
EXHIBIT 3
Page 2 of 2
From: Curtis Thaden
Sent: Thursday, May 25, 2023 2:38 PM
To: Brad Pfannmuller <[e-mail]>; Cole Coba <[e-mail]>
Cc: Rick Keller <[e-mail]>
Subject: Update - Veolia - Line Extension (Avimor)
Hi Brad and Cole,
Based on Rick Keller’s review of Veolia’s tariff, his discussions with Brad, and our conversation this
morning with both Cathy Cooper and Scott Pierce, we believe Veolia is following the requirements of the
Company’s tariff. During our meeting with the Company we discussed your proposal. Veolia believes
the cost of your proposed routing might be just as expensive as running the new 12” main line in N.
Mcleod Way. Veolia suggested procuring two bids while working through the details with the Company
for verification. However, Veolia will not deviate from its position.
The Company’s tariff can be found at the following link:
https://puc.idaho.gov/Fileroom/PublicFiles/WATER/VEO/General/0Tariff/Veolia%20Water%20Idaho%20
Inc.pdf
Since no Veolia Main fronts the property, a Main Extension is required per the Company’s tariff.
o Rules and Regulations Governing The Rendering of Service.
▪Sheet No.28
▪7. The Company will make all connections to its existing mains which
front the property to be served and will furnish, install, and maintain all
service lines from the main to and including the meter box or vault,
meters and service setting. The meter box or vault shall be placed inside
the curb line or Company right-of-way. All service lines shall be property
of the Company and shall be accessible to and under its control. In
instances where the existing mains do not front the property to be
served, the Applicant shall enter into the appropriate main extension
agreement as provided under Company's Rules and Regulations
Governing Main Extensions.
o Rules and Regulations Governing Water Main Extensions
▪Sheet No. 37
▪61. The normal routing for water main extensions shall be in dedicated
streets. The Company may, but will not be required to, make extensions
under this rule in easements or rights-of-way where final grades have
not been established or where street grades have not been brought to
those established by public authority. If extensions are made when
grades have not been established and there is a reasonable probability
that existing grade will be changed, the Company shall require the
Applicant(s) to deposit the estimated cost for altering the facilities
installed.
EXHIBIT 4
Page 1 of 2
▪Sheet No. 38
▪62. Company shall design and be the sole judge as to the adequacy of
any water main extension and appurtenances.
▪Sheet No. 39
▪69. A water main extension must extend to the extreme property lines
of the building lot to be served.
In summary, Veolia is unwilling to change its position and accept your proposal. Staff is unable to Order
the Company to accept your proposal. You have the option to file a formal complaint to challenge
Veolia’s position. A favorable outcome for your proposal is unknown.
I will be out of the office for the rest of the day. If you have any questions please contact Rick (208-334-
0348).
Thanks,
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
EXHIBIT 4
Page 2 of 2
-----Original Message-----
From: Curtis Thaden
Sent: Monday, October 2, 2023 3:46 PM
To: Paul Bierlein <[e-mail]>
Subject: Idaho Public Utilities Commission
Hi Paul,
Thank you for contacting the Idaho Public Utilities Commission (Commission) regarding the line
extension issue with Veolia North America. In May 2023, IPUC staff was contacted by Brad Pfannmuller
of Avimor. As you are aware, the Commission staff was unable to resolve the issue through the informal
complaint process. Is your intent to file an informal complaint or a formal complaint?
When an individual is dissatisfied with the outcome of their informal complaint, they may file a formal
complaint for review by the Commission under its Rules of Procedure, IDAPA 31.01.01.000 et seq” - Rule
054. Formal Complaints – Defined – Contents and Process, available online at:
https://adminrules.idaho.gov/rules/current/31/310101.pdf.
The formal complaint must be in writing, state the facts and specify how you they would like the
problem to be resolved. Unlike an informal complaint, which is handled by the commission’s staff, the
commissioners must consider a formal complaint. The commissioners will decide whether it is
appropriate to accept the formal complaint. If it is accepted, a formal legal proceeding will be started. If
the Commission does not accept the formal complaint, then nothing further will be done by the
Commission.
In summary, a formal complaint should state:
• The name of the utility or person the complaint is against.
• A full statement of the facts constituting the acts or omissions of the utility or person against
whom the complaint is filed, and the dates when the acts or omissions occurred.
• The specific provision of statute, rule, order, notice, tariff or other controlling law that the utility
or person has violated.
• What action or outcome should be taken to resolve the complaint.
The address to send the formal complaint to the Commission is:
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
In lieu of mailing the complaint, the complaint may be electronically submitted to the Commission
Secretary by emailing it to [e-mail].
Please know that a formal complaint becomes part of the Commission’s public records for anyone to
view.
If you have any questions, please let me know. My contact information is listed below.
EXHIBIT 5
Page 1 of 2
Curtis Thaden
Idaho Public Utilities Commission
208-334-0322
EXHIBIT 5
Page 2 of 2