20250408Comments_1.pdf

From: Debbie Butler
Sent:Tuesday,April 8, 2025 10:00 AM
To: secretary
Subject: Idaho Public Utilities Commission.docx
Good morning, I've attached my comments concerning case#PLW-W-24-02, Priest Lake
Water, LLC. I was having difficulty attaching them to the comment form so I hope you can accept
this format.Thank you Debbie Butler, 208 597 2397.
Idaho Public Utilities Commission
Case Number: PLW-W-24-02, Priest Lake Water, LLC
Comments submitted by Debbie Butler, lot owner Marvin Estates—Block 4, Lot 1
I'd like to thank the IPUC for the presentation provided on March 4,which provided background and
context to the case, along with allowing Marvin Estates residents and lot owners a chance to ask
questions and understand the process.We all desire clean, safe water for our use; however the
proposal brings up concerns for the users, many which have already been expressed.
I have several specific comments identified as follows:
1) Letter provided to the residents of Marvin Estates by PLW, LLC.The letter states"the Idaho
Public Utility Commission has recommended that the rate be increased to$98.00 per meter
permonth."However,this is not consistent with information presented by the IPUC. I hope
this was a case of miscommunication and not a dishonest statement, but I know others at
the meeting had concerns on this as well.
2) Hookup fees:The hook up cost for an individual lot is identified as$7444.00, however more
detailed clarification needs to show what this covers.The proposed Schedule No. 3 for
Hookup of New Service outlines a few items, including a minimum of 10 hours for labor,
which seems unreasonable and should reflect actual costs, instead of an inflated rate of
$150.00/hour. Specifics should be addressed as the length of required trenching and
materials can vary depending on the lot and location of infrastructure.
Commercial Lot: Why is there a different hook up fee for individual versus commercial lots?
Is this defined by the classification of the lot, or the proposal of what the business will be.
This needs clarification as well.
3) Cost Estimates on infrastructure and work that necessitate the increase:Who determines
this work is needed and how are the cost estimates derived?While there is a long list of
items that supposedly need to be done to the system, how can the users know this work is
needed.Without evidence that the work needs to be done, it leaves questions on who is
making the determinations. Example-does Idaho Department of Environmental Quality,
Department of Water Resources or Panhandle Health make periodic inspections of the
water system and issue findings?We should be provided evidence of system requirements
and inspection results. Page 28 of the application does include a Sanitary Survey,
Preliminary Inspection Findings Form conducted by Andy Olson from DEQ, however only 4
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deficiencies are identified, and I couldn't read them due to the scribbly handwriting.
Regardless,4 deficiencies do not equate the work that is proposed over the next 20 years.
4) Infrastructure on PLW lot:The proposal includes costs of work to be done on the PLW, LLC
privately owned lot, such as fencing and a building. Unless the work is necessary and
required for maintenance and code requirements for the water system exclusively,these
costs should not be paid for by the residents. Personal infrastructure should be paid by the
lot owner.
5) Wages:While the work to maintain the water system is extremely valuable, operation of the
system is not a full-time job. $50,000 for a part-time position seems hard to justify.The
wages should be based on prudently incurred expenses and not over inflated.
6) Increase usage from 10,000 gallons to 30,000 gallons:This offer is made to sound like a gift
of what we will receive as part of the rate increase.As stated by many residents, only a few
use over 10,000 gallons a year.There is no benefit to gaining this volume of water usage.
This following is not intended to be a total comparison, as all water systems will have differences,
but I looked up a few existing tariffs in northern Idaho.With rates indicated below it is hard to
understand the huge, proposed increase by PLW, LLC, and why it is necessary.
➢ Kootenai Heights Water System -$57.58/month
➢ Schweitzer Basin LLC-$41.00/month (single units over 500 sq.feet)
➢ Schweitzer Water Company-$44.80/month
Thank you for the opportunity to comment,
Debbie Butler
77 Smokey Drive
Priest Lake, ID 83856
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