20250520Comment_1.pdf

From: Read Tuddenham <[e-mail]>
Sent:Tuesday, May 20, 2025 2:16 PM
To: secretary<[e-mail]>
Subject: Comments for Case VID-W-02
Idaho PUC,
The following information is submitted in support of my attached comments.
Case Number:First Name:Last Name:Address:CityStatelDZipDaytime Phone:Email:Utility
Company:
I am interested in attending an online workshop or potentially an in-person
workshop. ( )Yes, I am interested. () No thanks.
I am interested in attending a customer hearing to give testimony(verbal comments)for the
record on this case. ()Yes, I am interested. () No thanks.
I acknowledge that submitting a comment in an open case constitutes a public
record under Idaho Code §74-101 (13) and all information provided by me on this form is
available for public and media inspection. My comment may be reviewed by the utility.
My comments are attached below:
Sincerely,
Read S. Tuddenham
Read S.Tuddenham
512 S. Idaho Club Dr.
Sandpoint, ID 83864
208-265-8077 (H)
513-290-5765 (C)
[e-mail]

From: Read S. Tuddenham
Submitted: 20 May 2025
Subject: Case No.: VID-W-25-02; Public Comment
To: IPUC and IPUC Staff;
The following comments and questions pertain to case VID-W-25-02,TIC Utilities—
Application for Authority to Increase Its Rates and Charges for Water Service in the State of Idaho. In
their comments, Mr. Norton and Mr. Frohnen provide excellent discussions of the issues and
questions that need to be investigated to determine a "just and reasonable" rate for TIC Utilities
water service. My comments present a few more details from my perspective.They fall into two
categories, water company accounting and separateness from other Applicant affiliates, and
customer relations.
The Applicant for the water rate increase is also the real estate developer (the Developer) of
the Idaho Club Community, the owner of a real estate company, and the Idaho Club Golf Course (the
Club) and associated facilities, as well as TIC Utilities. All apparently operate under Valiant Idaho LLC.
Shouldn't TIC Utilities be required to maintain an accounting system as a standalone company?As
such, all transactions between TIC Utilities and the Club, other Applicant affiliates and other
commercial businesses should be conducted via "arm's length" transactions.
The Developer has placed a significant financial burden on TIC Utilities from his real estate
development and sales. Before TIC Utilities became a regulated utility, the Developer waived water
standby and or hookup fees in some real estate sales price negotiations with individuals and
builders (compensation for installing infrastructure). These price concessions result in current and
future lost revenues to TIC Utilities. The lost revenues will have to be recovered. Rate calculations
based on the reduced revenues, caused by the price concessions, mean that rate payers,
homeowners, will be subsidizing real estate sales and community expansion.
The current tariff schedule includes a $45/month standby fee (for platted lots that have no
finished home and consume no water) and a one-time $2,500 hookup fee when service is initiated.
The Idaho Club is an expanding community with 10 to 15 homes in the design and construction
process at any time and several homes connecting to the water system each year. The waived fees
already show up in Applicant Exhibit 2. Only$455.50 was collected in hookup fees, less than one
new home's hookup fee.The waived standby fees probably contributed to the low unmetered water
revenue reported in Applicant Exhibit 2 (See Mr. Bailey's comment regarding standby fees).
The number of platted lots in the Idaho Club Community is less than the number permitted
by the Planned Unit Development document (PUD). Over fifty new lots have been proposed but
have not completed the plat process.
This raises the following questions:
• Should TIC Utilities customers bear the burden of funding the real estate price concessions
and community expansion through higher rates to make up for lost revenues?

• If not, how can the responsibility for funding the real estate price concessions be placed on
the Developer and separate the water company from the real estate sales?
• Can the Developer waive hookup and or standby fees for future lot sales?
• TIC Utilities currently collects standby fees. If standby fees are approved, should the
developer pay them for unsold lots?
• Does TIC Utilities have any other economic ties or share any services or suppliers with the
Applicants other entities?
The Club is a commercial entity. It operates a golf course, club house, course maintenance
facility and a restaurant that are open to members and the public. Gem State, the wastewater
operator, may also have a connection to the water system.The proposed rate schedule, Applicant
Exhibit 6, does not have a provision for commercial entities. This raises the following questions:
• Does the Club pay for water service or is it currently not required to, based on common
ownership with TIC Utilities, resulting in homeowners subsidizing the Club?
• If it does pay for water, is it appropriate for the Club to pay the same rate as a single-family
household?
In other words, how separate do the Applicant's real estate, Club and utility businesses have
to be for TIC Utilities to meet the accounting standards for a small water company?
Regarding customer relations, my comments and questions relate to billing and the
Applicant's public notice of the pending rate increase.
The invoices do not show payments made since the previous invoice as required by IDAPA
31.21.01.
IDAPA 31.21.01 also requires a payment due date in the billing invoice. Current invoices list
the payment as "Due Upon Receipt". The Applicant's Exhibit 6 says payment is due 15 days after the
billing date. The April 2025 invoice was dated 15 April and post marked in Spokane, WA 18 April.
Assuming 3 days in the mail, the invoice and remittance spend 9 of the 15 days in transit. That is not
enough time.
Like Mr. Norton, I paid my third quarter 2024 water bill in advance in July without an invoice,
having received no notice of the billing change from billing in advance to billing in arears. Also, at
this time,TIC Utilities changed billing agents and the payment address without notice.The October
invoice for third quarter from Panhandle Management,the new billing agent, was the first
indication of the change in billing and did not reflect my July payment. My bank said the checks
were cashed. Gem State said they received my payment, but did not cash the checks, because they
were no longer the billing agent. Instead, they delivered the payment to the Applicant. I complained
to Panhandle Management.They responded saying the October invoice was the first invoice they
had sent. One of their conditions for taking over the billing from Gem State was that all customers

would start with a $0 balance and the first charges would be for the 3rd quarter billed in arears. Any
past dues or other items recorded by Gem State were between Gem State and the Applicant.
After submitting bank statements and Bill Pay status statements (multiple lots), Panhandle
Management emailed,
"I've told Bill [Haberman] that when we get this type of evidence ... we are trusting
members and will be exciting credits accordingly. Bill agreed.
You are good ... Q4 will be sent 12/30." [typos from original email]
No corrected invoice was received. The 12/30 invoice was still incorrect. Panhandle Management's
response was an email to the bookkeeper:
"Dianne,
Please-- This needs cleared up in line with the other 9 . Reads October
payment clearly was for his q4 as his payment deposited by Bill via his mobile
app( and not hitting our ledger ) is the challenge here.
Read, we are reviewing all deposited checks between the transition of GEM , Bill
[Haberman] and us... not an easy task. We will get it cleared up. This includes
auto pay folk... we have gap period to resolve and will.... We will error on the
side of customers not TIC utilities and Bill knows this.
Tc"
The first correct invoice was dated 15 April 2025. Why should customers have to petition with
documentation to get credit for their payments?
The public notice of the proposed rate increases only announced two flat rates and is silent
regarding the variable metered rate in Applicant Exhibit 6 Metered Rates. The notice states:
"If IPUC approves the request in full, rates would adjust by 333%for a finished home and 0%
for a developed lot.The average bill for a finished home would increase by$ 105 per month,
and the average bill for a developed lot would increase by$0 per month."
It appears that a developed lot is one with utilities installed to the property line. All lots with
finished homes will fall under the metered rate tariffs in Applicant Exhibit 6.The tariff schedule
shows a fixed Customer Charge and a Usage Charge. The Usage Charge consists of two tiers, a fixed
fee for the first 22,500 gallons/quarter and a meter-based fee for usage greater than 22,500 gal/qtr.
The fixed usage fee is the $105/month, the increase identified in the public notice. The notice makes
no mention of usage metering or the meter-based fee.
The notice says the "average bill for a finished home would increase by$105 per month"
[$315/quarter]. The "average increase" only includes the fixed usage fee and does not address the
metered fee. Most homes consume more that 22,500 gallons/quarter, especially in the summer
when irrigation systems are turned on.The "average increase" of the public notice is really the
minimum increase customers can expect.
The notice also says that lots without finished homes (do not consume water) will continue
to pay$45/month ($135/quarter) standby fees. The proposed tariff schedule does not explicitly list

a standby fee. Applicant Exhibit 6 only lists metered rates and flat rates. Both metered and flat rates
include a Customer Charge AND a Usage Charge. If either of these apply the standby fee would
increase to $450/quarter a 333% increase, which is not the 0% increase in the public notice.
Others have raised the issue of fire protection. The Idaho Club is a heavily wooded area. TIC
Utilities has in the past checked hydrants by using them to fill the water truck used to clean the
roads. TIC Utilities should install the required hydrants, repair any hydrants that are out of service
and test all hydrants for the required flow rate.
Based on reviews of recent water rate decisions, the current $45/month flat rate for water
service is probably too low. But the requested rates are too high as discussed by Mr. Norton and Mr.
Frohnen.TIC Utilities should be permitted to charge "just and reasonable" rates for water.
Homeowners and customers should not have to fund the Developer's price concessions,
development costs to expand the community and water system, and subsidize commercial activities.
The accounting and billing need to be corrected. I concur with recommendations for a full audit to
ensure TIC Utilities separateness from other Applicant affiliates, accuracy of the accounting
presented in the application and compliance with the applicable standards for small water company
accounting.
recommend that the IPUC Staff hold an informational meeting this summer at the Idaho
Club or somewhere nearby. If there is a final hearing on TIC Utilities' application, recommend that
the hearing be conducted in Bonner County.
If you have any questions, my contact information is below.
Thank you for considering these comments.
Sincerely,
4e��- 7wa�
Read S. Tuddenham
512 S Idaho Club Drive
Sandpoint, ID 83864
(C) 513 290 5765
Email: [e-mail]