20250131Comment_1.pdf

From: Bruce Izatt
To: secretary
Subject: Idaho PUC Case Number SWI-W-24-02 Public Comments
Date: Thursday,January 30,2025 11:09:30 PM
Attachments: Svrinaa Heights Water Billing Rates.Ddf
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Commissioners and Staff,
I am a Board Member of Syringa Heights Property Owners, Inc, Additions 1-4, and a
Customer. I am writing to provide my comments on your Case# SWI-W-24-02, regarding
Syringa Water Co. rates and charges for service being fair,just and reasonable. In December
2023, the Company provided a notification to all Customers of new tiered water usage rates
for 2024. The following are the new rates that were provided, a substantial increase, which we
were told were based on a long term budget covering expenses not anticipated or not charged
in previous years.
Standard Fee $60.00
!st Tier(1 to 20,000 gallons) $2.50/thousand gallons
2nd Tier(20,001 to 40,000 gallons) $4.00/thousand gallons
3rd Tier(40,001 to 80,000 gallons) $6.00/thousand gallons
4th Tier(80,001 to 120,000 gallons) $12.00/thousand gallons
5th Tier(120,001+ gallons) $14.00/thousand gallons
In June 2014 the Company issued another Customer notice advising of their filing of an
application to the Idaho Public Utilities Commission for a Certificate of Public Convenience
and Necessity for authority to operate a water system in Idaho. This notification included the
following new water usage rate chart which is a progressive tiered rate billed at the highest tier
usage over 20,000 gallons to penalize the larger water users. This rate structure was included
in the Company's Tariff and got IPUC approval.
0 to 20,000 gallons $60 plus $2.50/thousand
20,001 to 40,000 gallons $110 plus 4$per thousand over 20,000
40,001 to 80,000 gallons $110 plus $6 per thousand over 20,000
80,001 to 120,000 gallons $110 plus $12 per thousand over 20,000
120,001 and over gallons $110 plus $14 per thousand over 20,000
I prepared the attached Excel spreadsheet that compares these two rate structures at different
usage rates and the subsequent percent increase that the Customer would be required to pay
should the current tariff progressive tiered rate be approved. The spreadsheet shows that there
is no difference in billing amounts from 0 to 40,000 gallons. However, once usage exceeds
40,000 gallons the difference begins, as the tier rate for the total usage amount, less 20,000
gallons, gets charged for all the lesser tiers down to 20,000, At 41,000 gallons the billing
increases by 20% and gradually decreases to 9% at 80,000 gallons, then increases again at
81,000 gallons by 90% and gradually decreases 44% at 120,000 gallons, then increases again
at 121,000 gallons by 65% and decreases to 57% at 130,000. The chances of higher tier rates

being charged is increased due to a lack of consistency that the Company has shown in reading
the meters. Some months they read them at less than a 30 day window and some months they
are read at longer than a 30 day window. We have requested that the Company read the
meters on the same day each month,but that has not happened. We have also requested that
the Company include the meter read date on the monthly invoice but that has not happened
either. A few days longer between read dates in the higher usage months could easily bump
the usage into the next higher tier and increase the cost of all water used above 20,000
gallons. Based on this information, I do not believe that the approved tariff progressive tier
rate provides the Customer a fair,just and reasonable charge for water service. The straight
tier rate should be utilized. Should you have any questions or need additional information,
please advise,
Thank you for investigating this issue,
Bruce Izatt
4187 E Mullan Trail Rd
Coeur d' Alene, ID 83814

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