20241017Comments_2.pdf

From:tavis buys<[e-mail]>
Sent: Wednesday, October 16, 2024 11:00 PM
To: secretary
Subject: Case No ASP-W-24-03: ASPEN CREEK WATER COMPANY-APPLICATION TO AUTHORIZE A
GENERAL INCREASE IN WATER RATES AND NEW CONNECTION FEES
Commission Secretary,
I am writing to you concerning the application to increase water rates by the Aspen Creek Water
Company. I have two lots in the service area, one with a house and one with no water connection. I hope
the comment period for this application is still open as I only recently received the Customer Notice. I am
not an accountant or an expert in government affairs, so I apologize if I use the wrong terminology or
misinterpret the excel worksheet that was included in the application.
I would like to lead with a note that I am a wholehearted proponent of having a financially healthy water
system and in ensuring the water company has sufficient funds to meet annual operating expenses,
unplanned/emergency maintenance costs, and being able to plan for future needs. I appreciate the
attentiveness and care the current operators have shown in providing us clean water with minimal
disruptions while keeping costs low. I also understand the need for an increase in water rates considering
the same rate has been charged since 2002 and rising costs have impacted all of us. I currently pay $350
per year for my lot with a connection and $120 per year for my lot without a connection. The proposed
increase to$1,608 per year would actually be approximately a 459% increase for our household and
would be a significant burden, especially if paying for two lots. I am also concerned about those full-time
residents for whom a $1258 yearly increase would create a real challenge in today's world of high inflation
and increased costs.
That said I have the following concerns regarding the application for the proposed increase:
1)The Customer Notice was not sent in time for interested parties to provide notice by the October 4th,
2024, deadline.
• The letters were not postmarked by the SLC Utah post office until October 10th, 2024, which
was after the deadline to become an interested party.
o On the puc.idaho.gov website for this application, in the Case Summary under the
"Company" section there are two notices uploaded.
0 1 don't believe the notice dated September 4, 2024, was sent. Evidence to support that is
that on October 10, 2024, another notice was uploaded and is the one that appeared in
our mailboxes.
0 1 do have an unopened, 10 Oct 2024 postmarked envelope containing the notice if
needed.
• I'm not clear if the October 4, 2024, date is also the date by which to provide comments to the
Public Utility Commission, but I believe the deadline should be re-opened to allow reasonable
time for affected parties to respond and comments to be received before a decision is made.
2) 1 am confused by the data in the excel workbook"ATTACHMENT EXHIBIT 1-4.XLSX". It appears that
there may be an error in filling out the worksheet unless the proposed changes are only supposed to be
for 1 year to capture the one-time expenses of$86,162 for the Pump House, PRV's Supply Mains, and
etc. I certainly may have missed something, but I don't see in the data how the total expenses for future
years would equal $117,384 (73 connections X$134 X 12 Months)going forward if we pay for the
majority of the one-time expenses in the first year.
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• It appears that$71,142 of the "Known Changes" (all but$15,020 from Exhibit 2, Schedule B) are
one-time expenses for a new pump house, mains, etc. but those amounts are being included in
the operating budget and the "Known Changes" in Exhibit 4 going forward in perpetuity.
• Exhibit 2, Schedule B shows Total Operating Expenses at$49,006 for future needs, $345 for
Property Taxes, $3745 for Federal Income Tax, and $1344 for State Income Tax for a total of
$54,440. Even with the required rate of return, etc., I don't understand how there would be
$62,000+ remaining to be included as a Depreciation Expense each year. Exhibit 1, Schedule A
shows the Annual Depreciation Expense at$18,708.20. That amount includes the depreciation
for the one-time Known Changes included.
• These one-time expenses should either be classified as a special assessment for the upcoming
fiscal year separately from the yearly operating expenses or they should be amortized across
multiple years under the Depreciation Expense category. It seems as if those are being
accounted for twice in the budget and inflating the monthly charge. Either way it would reduce the
monthly proposed monthly increase significantly.
3) It is not clear in the Customer Notice if only customers in the service area with actual connections
would pay the monthly fee or if all lots/potential connections would be required to pay the $134 per
month. Can that be clarified?
Regards,
Tavis Buys
435-213-6300
22 Grizzly Rd
Fish Haven, ID 83287
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The following comment was submitted via PUCWeb:
Name: Matthew DeHaan
Submission Time: Oct 17 2024 10:07AM
Email: [e-mail]
Telephone: [phone]
Address: 37 Old Ephraim Cir.
Fish Haven, ID 83287
Name of Utility Company:Aspen Creek Water Co.
Case ID: ASP-W-24-03
Comment: "After reviewing Exhibit 1-4, it would appear that Aspen Creek Water Co. is requesting a rate
increase to cover, in large part, one-time improvements that are planned for 2025 (Exhibit 1, Schedule
A). Given these are one-time costs required to expand the existing system, why would they be factored
into the rate in perpetuity?
It is obvious that a rate increase is needed after 20 years, however, I would think that the expansion of
the existing system would be covered by hookup fees, which appear to be excluded from operating
revenue (Exhibit 2, Schedule C). I also do not believe there were 47 hookups done last year so Aspen
Creek Water Co. was already collecting more than $1k/per hookup. If it is appropriate to fund expansion
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through water rates,then the requested increase should only apply to 2025 before dropping to
something closer to the Test Year requirement.
Please correct any misunderstandings. Thanks!"
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