20250130Comment_1.pdf

From: rdoublefCabaol.com
To: secretary
Subject: Rate Investigation SWI-W-24-02 Comments
Date: Wednesday,January 29,2025 5:56:31 PM
Attachments: Rate Comments for SWI-W-24-02.docx
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Mr./Mrs. Secretary
On behalf of Syringa Grove and Syringa Heights Addition 5-9 HOA's we have
attached additional comments and question concerning the current rates being
charged by Syringa Water Co. We desire these comments be incorporated into the
rate investigation and that our questions to be answered in a timely manner.
Thank You
SWI-W-24-02
Robert Ferrell
1913 S. Scharelant Ln
Coeur d' Alene, ID 83814
512-751-1868
[e-mail]
Utility Co. - Syringa Water Co.

Rate Comments for SWI-W-24-02
1/29/2025
1 . In determining a fair, just and reasonable rate, the starting
point is to know the total cost that is to be recovered and
spread over the total number of users in some manner.
Will our HONs ever get to the see actual annual cost
numbers from SWC that the current or proposed new
PUC rates are based upon, and if so, will it be after the
Staff Decision is made but BEFORE the Staff
recommendation goes to the Commission?
2. Of the 22 regulated water utilities in Idaho, NO company
(other than SWC) reverts back to the very first tier to
calculate the upper tier charges instead of the previous
tier before it. In the case of SWC this practice causes
water bills to double, triple and in some cases increase 4
fold over and above what a proper method of calculation
would result in. This method goes so far beyond the
objective line of promoting conservation of a resource it
exceeds the bounds of reason. This is illogical.
Can you describe to us how you determined this to be fair
and reasonable treatment of the customers that fall into
the upper tiers 3,4, and 5 and avoids the appearance of
nothing other than pure punishment to those selected
users?

3. There are 22 currently regulated water utilities in Idaho.
About 1/2 of them have a tiered rate structure of which
about '/2 of those are 2 tiers and 1/2 are 3 tiers. NO
company has a 5 tier system (other than SWC).
Can you describe the methodology used by PUC to
determine that a 5 tier system was needed in this one
and only case in the entire state of Idaho to cover the
allowable cost and reasonable profit for SWC and why no
other method similar to those used by the other 22
regulated water utilities was adequate?
4. Of the 22 currently regulated water utilities in Idaho the
highest rate charge (other than SWC) is $5.00/K gallons
(tier 3) and that is an increase of $1 .25 up from $3.75/K
gallons (tier 2). SWC highest rate charge is $14.00/K
gallons (tier 5) and that is an increase of $11 .50 up from
$2.50/K gallons. This is almost a 10 fold increase ($11 .50
compared to $1 .25) over all other allowable tier increases
in the state. The argument that this increase in needed to
encourage conservation doesn't withstand the test of "fair,
just and reasonable" when compared to the approved
tariffs of all other regulated water utilities in the state of
Idaho.
Can you describe the analytical reasoning used by PUC
to determine that this outrageous increase was needed in
this one and only case in the entire state of Idaho to
cover the allowable cost and reasonable profit for SWC?

5. From cross checking the Legal Descriptions furnished by
SWC against our local knowledge of who is connected to
the system, we believe there are at least 81 current
users, PUC documents continue to show only 78 current
connections. There are 2 houses under construction
(soon to be connected) and at least 22 future users
guaranteed a connection without any additional
expansion or subdivision of existing lots, for a grand total
of 105.
Can you describe to us the method used by PUC to verify
the actual number of users currently connected to the
SWC system?