20230428Final Comments.pdf

Sent by: Certified USPS, Email
April 28, 2023
Jan Noriyuki , Commission Secretary
Terri Carlock, Administrator
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
Boise, ID 83714
~✓~
STONE RIDGE ---~---
Sto neridge Utilities
P.O. Box 298
Blanchard, ID 3 04
Ph (20 ) 437-3148 Extn. 4
RE : Motor Coach Village Account #247 Complaint-Final Comments
Dear Ms. Noriyuki , Ms. Carlock;
We have reviewed the comments made on behalf of Motor Coach Village by their legal counsel
and would like to add the following to the discussion :
A. Did CDS StoneRidge Ut!lities, LLC-Water "Underbi/1" Motor Coach Village from 2018-
2021 for their 6 " water meter Account #247?
Yes, in November 2021 a review of the water company's billing records showed that
Motor Coach Village's Meter Account #247 status had been put in "Seasonal
Disconnect" mode in the fall of 2018, at that time most of the "carryover" staff were still
employed with the Utility Company. Over the first quarter of 2019 several utility staff left
the company and were replaced by new staff unfamiliar with the day-to-day operations of
the water company.
The following spreadsheets for 2019-2022 are based upon application of CDS
StoneRidge Utilities, LLC current tariff rules for this 6" Water Meter Account #247.
The minimum monthly Fee is $1 ,536.00 due each month unless the meter is put into
"Seasonal Shutoff' by the property owner-typically that would be done for November­
March each year. If the meter is not put into seasonal shutoff, then per our current tariff,
we bill the minimum monthly fee of $1 ,536.00 each month year-round.
In reviewing and revising these spreadsheets we made a decision to assume that a
Seasonal Reconnect Fee was charged each April/May rather than charging the minimum
monthly fee from November to March each year. This reduces the total billing since the
Seasonal Reconnect Fee of $4,160 is less than five months of $1 ,536.00 (equals
$7,680.00) for a savings to the customer of approximately $3,520.00 per year.
Page 1 of 4
RECEIVED
2023 April 28, 5:25PM
IDAHO PUBLIC
UTILITIES COMMISSION
It appears that even though the water was turned back on for the 2019 season to Meter
#24 7 in May 2019, the billing status on the meter was inadvertently left in several
subsequent incorrect rate code selections up until the fall 2021 when an audit of the
account discovered the errors:
1. 2019
a. Original Billing: From January 2019 to December 2019 no minimum
monthly charge was made to the account for $1 ,536 each month. Usage
was tracked and billed at $.79/1 ,000 gallons through September. In
October 2019 the usage code was changed to a flat $.79/month vs
$.79/1,000 gallons and this usage rate code continued in place till
December 2020 (other than the month of Sept. 2020 when a local wildfire
pre-empted the normal monthly water billing).
b. Rebilling: Minimum Monthly was billed April through October 2019 at
$1,536.00/month . A Seasonal Reconnection Charge of $4,160.00 was
charged in April 2019 (the charges of $4, 160.00/mo. vs Five Months at
$1 ,536.00 saved the customer approximately $3,520 .00 per year the rebill
covered Nov. 2018-March 2019 Minimum Monthly charges that would be
required per Tariff)
2. 2020
a. Original Billing: No Seasonal Reconnect Charge was incurred and
Monthly Minimum of $1 ,536.00 was charged June through December
(other than September 2020 when a local wildfire resulted in no monthly
billing being made to any customers.) Note: the November and
December Minimum Monthly Charges were adjusted with a credit to the
customers account made in February 2021 for $3,073.58. Usage was
charted at a flat $. 79/month during all of 2020 other than Sept.
b. Rebilling: In April 2020 a Seasonal reconnection Charge of $4,160.00 was
made in lieu of billing the monthly Minimum Monthly charge November
2019 to April 2020.Monthly minimum was charged June-October 2020.
Usage was charged each month at $.79/1 ,000 gallons.
3. 2021
a. Original Billing: Beginning April 2021 , a minimum Monthly Charge of
$1 ,536.00/month was charged April through October 2021 . In
February 2021 a credit adjustment was made to the account to
remove the November 2020 & December 2020 Monthly minimum
charges and the $1.58 in usage charges. $.79/Month usage charge
was incurred April 2021-October 2021 (when the audit revealed this
charging error).
b. Rebilling: Seasonal reconnect fee of $4,160.00 charged in April 2021
to cover the months from November 2020 to March 2021 minimum
Page 2 of 4
monthly fees. Usage charged June 2021 to October 2021 at
$. 79/1 ,000 gallons.
4. 2022
a. Original Billing: Beginning April 2022 the account was billed $1 ,536
minimum monthly charge through December 2022 as they did not file a
formal request for disconnecting the water over the winter and one of their
members was in residence up to approximately the middle of December
2022.
b. Rebilling: We added a seasonal reconnect charge of $4, 160 in April 2022
to cover the months the meter was disconnected from November 2021 to
March 2022.
B. What was the specific amount of the underbl'lling on this Account?
Approximately $43,220.74 from Jan 2019 to Dec. 2022.
C. What was the date the "underbilling" was discovered and shared with the customer and
/PUC?
November 2021
D. How far back should a "rebi/ling" extend? Customer cited "budgetary concerns" prompted
them to request a letter from CDS StoneRidge Utilities, LLC confirming the balance on
their account in March of 2020.
Since their balance was current, the only reasonable concern on their part for asking for
written confirmation had to be that they were in fact concerned they were being
underbilled, not overbilled.
They did not share this concern with CDS StoneRidge Utilities, LLC, but rather requested
confirmation that the balance was correct. A review of communications between the
HOA Board members, as well as with their property management company during this
time period might confirm that they were aware they were running up to $10,000.00
under their annual "Water Budget" per year due to the "misbilling"-but apparently chose
to not share that knowledge with us.
We have previously provided you with copies of the HOA Annual Budget for several
years documenting the MCV HOA Annual budget being below forecast for water during
the 2018-2022 period. It is our position that we are allowed to go beyond the standard 6-
month period up to three years provided under the Idaho Code in the event that a
reasonable party would have realized an "underbilling" occurred on this account for
several years.
E. Special Contract Exists? Initial comments from the HOA Board stated that the
agreement/letter from Dean Allara of the StoneRidge Golf Community was a "Special
Contract" as identified in our current Tariff.
Page 3 of 4
It has been our position that agreement/letter has not been a binding agreement upon
this account in the past nor is it going forward for the following reasons:
1. As a Special Contract our current Tariff requires IPUC review and approval-there is
no evidence that has occurred.
2. The agreement/letter is between Motor Coach Village HOA and StoneRidge Golf
Community and not the CDS StoneRidge Utilities, LLC so StoneRidge Utilities, LLC a
separate legal entity was not bound by the agreement/letter.
3. The agreement/letter does not address if the agreement/letter is binding upon
successor parties to the original agreement-and we were never provided with a copy
of the agreement by the prior owners of the Utility Company, nor Motor Coach Village
HOA until the 1st quarter of 2022.
We look forward to resolution of these matters by IPUC Staff/Commissioners in the coming
months so that we might proceed with clear guidelines on this account. Thank you and your
staff for patiently working with us on this matter.
Please let us know if you need any further information from us on this matter.
Sincerely
Steve Durbin
Page 4 of 4
I 2019 I
Per IPUC Tariff I --
Acct. 247 Motor Coach Vdlag" HOA Monthly Water Bnting Reconciliation
Rate Code SB #29 6" has been #14 MC Minimum with Fixed .79/Mo '
Pr"P'lred by JGM
Wednl!Sday, April 26, 2023
FYE 12/31/2019 .L l I --------NoSeas~sconnect ----No Seaonal Disconnect --Jan-19 Fl!l>-19 Mar-19 Apr-19 19-May Jun-19 Jul,-19 Aug-19 Sep--19 Oct. 2019 Nov.2019 Dl!c-19 Totals -' -
Beginninc Stmt Balance ----$ $ 2,145.09 $ -$ -$ 5,696.00 $ 9,775.42 $ 11,643.22 $ 13,563.16 $ 15,216.08 16,292.30 17,299.00 19,686.00 -Should ha"" been Billl!d
Monthly Minimum Charge $ $ -$ -$ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ $ $ 10,752.00
Seasonal Re-Connect s 4,160.00 s 4,160.00
Usage Gallons --198,000 618,000 1,104,000 1,252,000 670,000 -3,842,000
Sewer Usage 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 1$ 28,644.00
Usage Charge DJe -156.42 488.22 872.16 989.08 529.30 s 3,035.18
~.-,., ---L I --$2,387.00 $ 2,387.00 $ 2,387.00$ 8,083.00 s 4,079.42 $ 4,411.22 s 4,795.16 3,923.00 s 2,387.00 s Total Should have been Biled s 4,91208 $ 4,452.30 $ 2,387.00 $ 46,591.18
Actual Billed This Month L _j_ _j___
-~ -~ ----¼ .--¼ --¼ --¼ l L ...1 I Monthly Min. Water Billed ,.L $ __s__ $ . s . s ---~ -~
Monthly Min. Sewer 13!_11ed 2,387.00 _ 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 2,387.00 -2,387.00 2,3871 2,387.00 2,387.00 28,644.QO ---...L Re-Connect Billed -
Usage Charged --156.42 488.22 872.16 989.08 529.30 0.79 0.79 0.79 3,037.55
=-$ 2,387.00 s 2,387lXJ$ 2,387.00$ 2,387.00$ 2,543.42 -$ 2,815.n s 3,259.iG s 3,376.08 s J..... ..L _j____ L
Total Biled This Month 2,916.30 $ 2,387.79 $ 2,387.79 $ 2,387.79 s 31,681.55
Payment Adjustments on Account I
Payment on Account s (241.91) $ (4,532.09) $ (2,387.00) $ (2,387~ $ (2,543.42) $ (2,875.22) $ (3,259.16) (3,376.08) (2,916.30) -I (24,518.18)
Adjustment To Account Increase ----I 1,163.37 _I 7,163.37
~ustment To Account Decrease (14,326.74) (14,326.74)
I I
Total Pymts/Credits to Account $ (241.91) $ (4,532.09) $ (2,387.00) $ (2,387.00) $ ---$ (2,543.42) $ (2,875.22) $ (3,259.16) $ (3,376.08) $ (2,916.30) $ -$ (7,163.37) $ (31,681.55)
Ending Stmt Balance -$ 2,145.09 $ -$ -$ 5,696.00 $ 9,775A2 $ U,643.22 $ 13,563.16 $ 15,216,0I $ 16,292.30 $ 17,299.00 $ 19,616.00 $ 14,!lO!l.63
I I I I I I I I I I I I I
Under/(Over) Billing for Month Total s -s -$ -s 5,696.00 s 1,536.00 $ 1,536.00 $ 1,536.00 s 1,536.00 s 1,536.00 $ 1,535.21 $ (0.79) $ (0.79) $ 14,909.63
Under/(Over) Billing for Month Sewer s -s -s -s -$ -$ -s -s -s -s -s -$ -$ -
Under/(Over) Billing for Month Water $ -s -$ -$ 5,696.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 s 1,536.00 $ 1,536.00 $ 1,535.21 $ (0.79) $ (0.79) $ 14,909.63
Per IPUC Tariff LULU
Acct. 247 Motor Coach Villitg,, HOA Monthly Waiter BiUing Reconciliiltion
Raite Code SB #29 6" has been 1114 MC Minimum with Fixed .79/Mo
Prepared by JGM
~esday, April 26, 2023 ----~ -FYE J2/31/2fJ2JJ
Jan-20 Feb-20 Mar-20 Apr-20 May--20 Jun-20 Jul--20 Auc-20 Sep-20 Oct-20 Nov--20 Dec-20 Tolills
No Seasonal Disconnect No Bill In Sept No Seasonal Disconnect
Becinlnc Stmt. Balilna! -$ 14,909.63 $ 14,909.63 $ 14,909.63 $ 14,909.63 $ 20,607.21 $ 22,143.21 $ 23,945.44 $ 24,279.61 $ 25,312.14 s 26,848.14 $ 27,698.97 $ 26,162.18
Should ha"" been Billed T
Monthly Minimum Charge D.Je $ $ $ $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ 1,536.00 $ $ $ 10,75200
Seasonal Re-Connect 0 0 0 4,160.00 0 0 0 0 0 0 0 0 4,160.00
Usage Gallons 2,000 337,000 429,000 1,308,000 . 1,078,000 . 3,154.E.
Sewer Usage D.Je
Usage Charge Clue $ $ $ $ 1.58 $ . $ 266.23 $ 338.91 $ 1,033.32 $ . $ 851.62 $ . $ . $ 2,491.66
--------------------------------_ _J
r-1 Should haw been Blled -~ . . . 5,697.58 1,536.00 1,802.23 1,874.91 2,569.32 1,536.00 2,387.62 . 17,403.66
Actual Billed This Month
Acutal Monthly Min. Billed 0 0 0 0 0 1,536.00 1,536.00 1,536.00 . 1,536.00 1,536.00 1,536.00 9,216.00
Actual Min. Sewer Billed
Seasonal Re-Connect Billed . . . . . .
Actual Usage Charged 0.79 0.79 0.79 0.79 0.79 0.79 0.79 0.79 0 0.79 0.79 0.79 8.69
-----------------_J
T-1 Blled Tllis Moatll 0.79 0.79 0.79 0.79 0.79 1,536.79 1,536.79 1,536.79 . 1,536.79 1,536.79 1,536.79 9,224.69
Payments/Adjustments on Account
Payment on Account ~ I (3.95) (1,540.74) (1,536.79) (1,536.79)i (1,536.79) (6,155.06J ~ { Adjustment To Account Increase
Adjustment To Account Decrease 0 3.95 3.95
I I I I
Total Pymts/Credits to Account . . . . (1,540.74) (1,536.79) (J..S36.79) (1,536.79) . (6,151.11)
--Endiftc Stmt Balance $ 14,909.63 $ 14,909.63 $ 14,909.63 $ 20,607.21 $ 22,143.21 $ 23,945.44 $ 24,279.61 $ 25,312.14 $ 26,848.14 $ 27,698.97 $ 26,162.18 s 26,162.18
I I I I I I I I I I I I I
Uncler/(<>ver) Billing for this Month Tobll $ (0.79) $ (0.79) $ (0.79) $ 5,696.79 $ 1,535.21 $ 265.44 $ 338.12 $ 1,03253 $ 1,536.00 $ 850.83 $ (1,536.79) $ (1,536.79) $ 8,178.97
Uncler/(OVer) Billing for this Month Se-, $ . s . $ . $ . $ . s . $ . $ . s s . $ . s . s .
Under/(OVer) Billing for this Month Watff s (0.79) $ (0.79) $ (0.79) $ 5,696.79 $ 1,535.21 s 265.44 $ 338.12 s 1,03253 $ 1,536.00 $ 850.83 $ (1 536. 79) $ (1,536.79) $ 8 178.97
Per IPUC Tariff 2021
Acct. 247 Motor Coach Village HOA Monthly Water Billing Reconciliation
Rate Code SB #29 6" has been #14 MC Minimum with fixed .79/Mo
Prepared by JGM
Wednesday, April 26, 2023
FYE 12/31/2Ul.1
No Bill No Bill -----
Feb-21/ Jan~2.1 Mar-21 Apr-21 May-21 Jun-21 Jul-21 Auc-21 Sep-21 Oct. 2021 Nov-21 Dec-21 Totals I-------No Seasonal Disconnect No Seasonal Disconnect
Beslninc Stmt. Balance --$ 26,162.U $ 26,162.11 $ 23,()81.60 $ 23,088.60 $ 27,'1T7.14 $ 21,613.14 $ 30,504.64 $ 32,53L23 $ 36,257.90 $ 39,430.71 $ 40,1165.42 $ 41,219.65
Should have been Billed
Monthly Minimum Charge !Ale -1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 -$ 10,752.00
Seasonal Re-Connect --4,160.00 ------4,160.00
Usage Gallons 450,000 621,000 2,773,000 2,072,000 1,817,000 537,000 -8,270,000
Sewer Usage Due
Usage Charge Due --355.50 490.59 2,190.67 1,636.88 1,435.43 424.23 -$ 6,533.30
----------------~-----~~ L
Total Should haw! been Billed ----5,696.00 1,536.00 1,891.50 2,026.59 3,726.67 3,172.88 2,971.43 424.23 -$ 21,445.30
Actual Billed This Month -Monthly Min.Water Billed 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 --$ 10,752.00
Min. Monthly Sewer Billed
Re-Connect Billed -----$ ---~ -... -. Useage Charged 0.79 0.79 0.79 0.79 0.79 0.79 0.79 424.23 $ 429.76
----------.L ..J I .1 I L _j_ -Tolal BIiied T1lis Month ---1,536.79 1,536.79 1,536.79 1,536.79 1,536.79 1,536.79 1,536.79 424.23 -$ 11,181.76
Payments/Adjustments on Account -Payment on Account Total --(1,707.46) (1,536.79) s (3,244.25)
Adjustment to Account Increase -J__ --
Adjustment to Account Decrease (3,073.58) --(3,073.58)
Total Pymts/Credits to Account -(3,073.58) -(1,707.46) ---(1,536.79) $ (6,317.83)
--I I Ellcli111 Stmt Balance $ 26,162.ta $ 23,0U.60 $ 23,0U.60 $ 27,077.14 $ 21,613.14 -$ 30,504.64 $ 32,531.23 $ 36,257.90 $ 39,430.71 $ 40,865.42 $ 41,219.65 $ 41,219.65
I I I I I I I I I I I I I Uncler/(Over) BiAing for Month Total $ -$ -$ -$ 4,159.21 $ (0.79) $ 354.71 $ 489.80 $ 2,189.18 $ 1,636.09 $ 1,434.64 $ -$ -$ 10,263.54
Under/(Over) Billing for Month Se_, $ -$ -$ $ -$ -s -$ s -$ $ -$ -s -$ -
Uncler/(Over) Billing for Month Water $ -$ -s -$ 4,159.21 $ (0.79) $ 354.71 s 489.80 s 2.189.88 s 1636.09 $ 1,434.64 $ -s -$ 10,263.54
Per IPUC Tariff 2022
Acct. 247 Motor Coach Vdlilge HOA Monthly Water Btl ling Reconciliation
Prepared by JGM
Wednesday, April 26, 2023
FYE 12/31/2022
>ate Code S8 #29 6"' has been #14 MC M,nimum witt. ~ited .79/Mo
Jan-22 Feb-22 Mar-22 April2022 May-22 Jun-22 Jul-22 Aug-22 Sep-22 Oct. 2022 Nov-22 Dec-22 I Totals
-----j
Becieilic stmL Balance ~-$ 41,219.65 $ 41.219.65 $ 41,219.65 $ 41,219.65 $ 47,159.61 $ 41,739.n $ 50,292.&3 $ 31,514.94 $ 40,274.13 $ 40,233.27 $ 40,147.95 $ 41,613.95
Should have been Billed I _J l ----J -Monthly Minimum Charge Due 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 1,536.00 $ 13,824.00
Seasonal Re-Connect -4,160.00 -4,160.00
Usage Gallons 220,200 55,900 21,600 162,100 283,400 109,500 1,500 -1,000 855,200
Sewer Usage Due ---Usage Charge Oue 173.96 44.16 17.06 128.06 223.89 86.51 1.19 -0.79 $ 675.61
----------...L -.-L .-L ~ ~ .....L ....l ....L .....L ....L
Total Should have been Baed --5,869.96 1,580.16 1,553.06 1,664.06 1,759.89 1,62251 1,537.19 1,536.00 1,536.79 $ 18,659.61
Monthly Min.Water Billed -Monthly Min.Water Billed ---r--1,536.00 ~ 1,536.00 ~1,5~ 1,536.00 1,536.00 1,536.~ 1,536.00 _1,536.00 1,536.00 $ 13,824.00
Min. Monthly Sewer Billed ---Re-Connect Billed ----$ -----------Useage Charged ___ 173.96 44.16 17.06 128.06 223.89 86.51 1.19 -$ 674.83
-------------------~---~ ~-....L Total Baed TIiiis Month ----1,709.96 1,580.16 1,553.06 1,664.06 1,759.89 1,62251 1,537.19 1,536.00 1,536.00 $ 14,498.83
Payment on Account Tota.I
Payment on Account Total ---(13,441.95) ~ (1,664.06) (1,62251) 0 $ (16,728.52)
Adjustment to Account Increase 0 -
Adjustment to Account Decrease --0 -
0 ----~ ---Total Pymts/Credits to Account --(13,441.95) (1,664.06) (1,622.51) --$ (16,728.52)
--Eftdiac Sta ll■llula $ 41,219.65 $ 41,219.65 $ 41,219.65 $ 47,159.61 $ 41,739.77 $ 50,292-13 $ 31,514.94 $ 40,274.13 $ 40,233.V $ 40,147.95 $ 41,613.95 $ 43,220.74
I I I I I I I I I I I I I
UndH/(Over) Bllinc for Month Total $ $ $ -$ 4,160.00 $ 0.00 $ 0.00 $ (0.00) $ (0.00) $ (0.00) $ (0,01) $ -$ 0.79 $ 4,160.78
U~/(Over) Billing for Month_, $ $ -$ $ -$ -$ -$ -$ -$ $ -$ -$ -$ -
U~/{Over) BiliM for Month WatH $ $ -$ -$ 4,160.00 $ 0.00 $ 0.00 $ (0.00) $ (0.00) $ (0.00) $ (0.01) $ -$ 0.79 $ 4,160.78