20250407Comments_3.pdf

From: Peter B
Sent: Monday,April 7, 2025 12:42 PM
To: secretary
Subject: Priest lake Water, LLC, Case# PLW-W-24-02
Please find attached a letter regarding the above-referenced Water system rate case.
Thank you in advance for your time.
Peter Bock
IPUC
Case PLW-W-24-02
Priest Lake Water, LLC/Marvin Estates
Comments submitted by: Peter Bock, 72 Turtle Lane, Priest Lake, ID 83856
Properties owned in Marvin Estates served by PLW, LLC: 67 Ryan Road, Priest Lake ID 83856
My first comment is regarding the rate notice we were sent by PLW, LLC (Jared Horlacher).
In the notice he clearly states that"...The Idaho Public Utility Commission has
recommended that the monthly rate be increased to$98 per meter per month". One of
the IPUC representatives said he felt the statement above was probably just a mis-phrasing
of the situation, but I have to respectfully disagree as Jared has also said this face-to-face
to a few neighbors who spoke with him after the notice was sent to all of us. It was
clearly written the way he or his attorney wanted it to be.
My guess is this misstatement of facts was to make us all feel as if a decision had already been
made, and there's nothing he or we can do about it, so why comment or attend the meetings?As
customers, how can we believe any of his numbers when the first thing he did was lie to us in his
announcement notice?
1

If approved,this water rate will be more than double the next highest rate for water services in our
area, and almost 5 times more than a few of the water systems that I know of up here.
PLW appears to have tried to sooth the pain by increasing the monthly water usage from
10,000 gallons of standard usage to 30,000/month.The fact is most of us don't use the
current maximum of 10,000 gallons, and when people do, it's only for a couple of the late
summer months. He clearly knows this fact.Another aspect to this is that most of his water
customers are only here part-time in the summer, so this seems like a ploy to placate our
concerns over this ridiculous rate increase, or to placate his guilt, I don't know, but it is not a
benefit worth 165% rate increase!This is really a phantom benefit and is worth Zero to the water
customers.
I also want to point out that it certainly doesn't help with water conservation either,
which is a concern for all of us, given the tremendous growth our area is having.
want to add another point here that was brought up in the last meeting but has not been
thoroughly discussed previously.As the HOA President, I receive a lot of comments and questions
regarding this proposed rate increase. One point that many people have brought to my attention
is the fact that their situation, (multiple lots with water access, RV lots, etc), allows them to simply
disconnect from the water system and either use water from one of their other lots or simply bring
water for the weekend from home in a clean water tote.This action could jeopardize the financial
stability of PLW. It would also have the deleterious effect of making the remaining customers'water
bills much higher than even the current proposed rates. (ie., If PLW needed $100,000/year to be
financially stable and there were 50 paying customers=$2,000/per customer. Now, let's say, 10
customers have decided to shut their water off, so we're down to 40 paying customers.This would
mean the remaining 40 would now pay$2,500/year, or 25% more.)The proposed rate increase is
already going to make our neighborhood less affordable than other properties in the area, making
the sale of the remaining—40 lots even more difficult.Adding a scenario like I referenced above
would make it very hard for PLW to attain the maximum user level of 113 paying lots/customers.
Everyone is worse off in this type of scenario.
Thankyou in advance foryour time and consideration.
Respectfully yours,
Peter Bock
2

---------------------------------------------------------------
From: Peter B
Sent: Monday,April 7, 2025 12:45 PM
To: secretary
Subject: Priest lake Water, LLC, Case# PLW-W-24-02
Please find attached another letter regarding the above-referenced rate case. I decided to separate
my concerns into different letters to make it easier on Travis and Jon.
Thankyou in advance for your time.
Peter Bock
IPUC
Case PLW-W-24-02
Priest Lake Water, LLC/Marvin Estates
Comments submitted by: Peter Bock, 72 Turtle Lane, Priest Lake, ID 83856
Properties owned in Marvin Estates served by PLW, LLC: 67 Ryan Road, Priest Lake ID 83856
In the IPUC CPCN document(pg. 3 of 4) under`Rates and Rules', it states that "it is expected that
there will be start-up losses in the operation of the system until the number of customers has
reached 75%or 80%of the number for which the system was designed" Marvin Estates is currently
about 65%complete, as far as lots having water, so whoever operates the water system should
expect some losses going forward for a while.
In other words, PLW should not expect the water system to provide a profit and a personal income
at this time. It is basically trying to get the revenue from 113 potential customers out of 73 actual
customers.
The income/salary shown in PLW's paperwork shows an annual income of$50,000. For reference,
the average income in Bonner County is around $38,000 as of the latest census data.
That average is for full-time work. I would estimate that Jared Horlacher works 15%-20%of the
annual workable hours on the water system. Given Jared also runs an excavation company, it is
hard to discern his exact hours, since the excavation work should be billed to the water customer
who needed those services, not the entire neighborhood. (I also want to clarify from the meeting
in Coolin,that any new customers can choose a qualified excavator of their choice to hook
them into the water system. In this instance,the customer will pay that excavator their going
rates and PLW's hook-up fee schedule would not come into play.)
3

I come up with the 15%as an estimate since there is no meter reading or water service work done
in the winter months (Nov.—April/May). In the summer months, my estimate would be one day a
week to read the 73 meters and take samples monthly to mail to test lab.Add some bookkeeping
into that as well. One day out of five is 20%of the workweek,for those 5-6 months.This comes to
10%-12% of the work week over a one-year period. (I rounded my estimate up to 15%.)This would
mean his$50,000/year income request should really be closer to$7,500/year($50,000 x.15).
That seems much more reasonable for a very part-time job, especially when you factor in the ROE
of around 11%for a water company of this size.
Respectfully,
Peter Bock
4

From: Priest Lake Art&Glass
Sent: Friday,April 4, 2025 4:29 PM
To: secretary
Subject: Case PLW-W-24-02 Public Comment
To whom it may concern,
We have attached our public comment in regards to open case PLW-W-24-02 with Priest Lake
Water, LLC
Thank you,
Evan &Cassie Schaefer
5

Public Comment — Priest Lake Water LLC Rate Case PLW-W-24-02
To the Idaho Public Utilities Commission,
Thank you for the opportunity to share our thoughts regarding the proposed rate increase
by Priest Lake Water, LLC.
First and foremost,we want to acknowledge the importance of maintaining the health and
safety of our water supply.We personally believe we have some of the best water in the
nation,and we understand that keeping it that way requires responsible management,
investment,and compliance with regulatory standards.
That said,when we received the letter regarding the proposed rate increase,we experienced
a degree of sticker shock.As many in the community have noted,this proposed jump from
$37 to$98 per month is extremely large and will make an impact on financial situations for
many,ourselves included,if not all of the current and future property owners.This also
follows a 23%increase ($30 to$37 per month) in three years since Priest Lake Water was
taken over by its current owner. The scope of this latest proposal feels like a significant and
sudden jump and we feel transparency will provide clarity as to why such a high increase is
proposed.
Attending the recent public meeting with the IPUC was helpful in understanding some of the
reasoning behind the increase and the upgrades that are necessary.We appreciate the
IPUC's role in providing oversight and ensuring long-term sustainability for water systems
like ours.Still,we have concerns—not necessarily about the need for upgrades,but about
the scale and pacing of those upgrades and the costs associated that will put a burden on
customers.A few items stand out that we hope can be clarified:
-**Labor and Maintenance Costs**:A minimum annual cost of$50,000 was listed for labor.
Since meter reading isn't done during the months of heavy winter snow and there are many
months most of the lots aren't in use (especially RV lots),a breakdown of the actual labor
hours&the per hour paid involved in the monthly tasks and how the labor expenses are
distributed throughout the year would help us better understand and evaluate that figure.
-**Potential Conflict of Interest and Transparency**: In regulated industries,it is common
for there to be clear documentation of expenses to ensure fair pricing and avoid self-dealing
when the utility owner also owns another company expected to do some of the work.As the
owner of Priest Lake Water also owns an excavation company,which we assume will be
used for at least some of the planned upgrades and maintenance,we believe the clear
documentation will alleviate many issues residents are expressing.To maintain confidence
in the fairness of these expenses,we request that a clear breakdown be provided,including
a detailed outline of the expected work to be performed by the excavation company,
including labor rates,equipment costs,and materials. Documentation of projected hours
worked and invoices/estimates verifying the charges align with industry standards. Finally,
any bidding process that was considered to ensure competitive pricing for excavation or

infrastructure improvements.We understand that upgrades are necessary,but ensuring that
costs are reasonable,transparent,and fairly allocated will help build trust among the
community who is being asked to shoulder a significant rate increase.
-**Transparency in Project Scope and Timeline**:We request the IPUC to review the
systems and determine the level of severity for the upgrades that are needed. If all upgrades
are deemed immediately necessary,that would help us understand why the full increase is
required at this time.However,if some system upgrades are urgently needed while others
could be scheduled in phases,a staggered approach may help ease the burden on residents.
Understanding which improvements are required immediately versus those that could be
addressed over time would go a long way toward easing community concerns.
-**Backflow Preventers**: The proposal includes installing 40 backflow preventers at a
total cost of$200,000.A quick web search shows that these typically range from$300 to
$1,500 each,installed.We respectfully ask the Commission to review this estimate of$5000
each,installed; and request a breakdown by materials,labor,and other costs to help
transparency to the estimate so we,as having zero knowledge of running a water company,
can have clarity to this portion of the rate increase.We're also curious whether, once this
and the other similarly large projects&upgrades are paid off,will there be a reduction in
rates?
-**Assistance Programs**:We would like to know if all possible funding avenues have been
exhausted,including state and federal low interest loans and/or grants. Since Priest Lake
Water is new to this level of regulation,we were unable to find references to assistance
being pursued.If available,can information be provided regarding efforts to secure funding
through agencies such as the DEQ(low-interest loans or grants), IDWR(supply,permitting
&planning),EPA(grants or technical assistance),USDA (water&waste disposal loan&
grant program), or other programs that support small communities in offsetting
infrastructure costs?
Lastly,we recognize that Priest Lake Water,LLC is privately owned that serves as a utility to
our small group who's HOA requires us to receive water from.We want to continue
supporting improvements to our water infrastructure,and a local business,but we also
hope that both the Commission and Priest Lake Water will work to make the process as
transparent and fair as possible.
Thank you again for your time,your review,and your support.
Sincerely,
Evan&Cassie Schaefer
138N Ryan Rd
Priest Lake,ID 83856
208-946-0834