20250714Comment_1.pdf

From: [e-mail] <[e-mail]>
Sent: Sunday, July 13, 2025 3:50 PM
To: secretary<[e-mail]>; Bob Hamilton <[e-mail]>
Subject: Order No. 36664 Comments on Staff Investigation & Decision
PUC Commission Secretary
13 Jul 2025
Submitted by Robert Ferrell
E-mail: [e-mail]
[phone]
1913 S. Scharelant Ln
Coeur d'Alene, ID 83814
Name of Utility: Syringa Water Co
Case No. SWI-W-24-02
I, Robert Ferrell(RFF), submit the following comments on behalf of myself personally and
as President of Syringa Grove HOA representing a total of six(6) customers of Syringa Water
Co. (SWC). I thank the Staff for their time and hard work investigating this case and agree
with all of their findings generally speaking except for the following issue as stated below:
No Proper Credit Issued for Overcharges
On page 5 of the Staff report dated July 1, 2025, in the 4th paragraph they state:
"During its audit, Staff found that the Company did not consistently apply its tiered rates. In
some cases, customers with usage in multiple tiers were charged the highest tier rate for all
consumption rather than the correct rate per tier. This billing error resulted in customer
overcharges. Upon notification, the Company agreed to correct the billing for all of 2024.
(emphasis added) and apply appropriate credits to customer accounts in October 2024.
The Company has since corrected its billing practices and is now properly billing tiered
usage:"
On a personal level I know this required correction of billing for all of 2024, to be reflected
on the October 2024 invoice, has not taken place nor has a proper credit been issued on
my account. Of the other 5 customers in Syringa Grove, 2 received no credit, 1 received an
additional charge, 2 couldn't produce a copy of their Oct 2024 invoice and therefore did not
know if they got a credit or not, and 1 house was still under construction and not yet
receiving a billing. I believe a similar situation most likely to exist, to some degree or
another, for all the other 72 customers in Syringa Heights, Camas Estates, and Silver
1

Beach. It appears maybe SWC only looked one month backwards to determine if a credit
was due, not the entire year of 2024, I don't know, it's unexplainable. The fact is, based on
the Staff report and directive issued from them to SWC, any customer that had even one
month in all of 2024 in which they used over 40K gallons would be due a credit when
applying the proper method of calculation.
There are probably as many different situations as there are invoices concerning a proper
credit. I can't address those but would like to review with you my personal experience with
the invoice for Oct 2024 and a lack of proper credit. For clarity I have attached a 3 page
spreadsheet, EXHIBIT A dated 7/10/2025, that reflects the actual billing on my account for
2024 alongside what the proper calculations should have been. As you can see, I should
have received a credit of$395.80 for the total year of 2024. That did not happen. I suspect a
similar calculation on the account of many other customers would reflect a similar result,
especially for the 15 - 20 or so high-end users.
Also attached is a scan of all 12 invoices I received for 2024 to back up my figures as true
and correct. On my invoice#2287 dated 10/30/2024 you will see the line items when
added up total$131.44 but the balance for the month at the bottom of the page indicates
$73.44, a difference of$58. There was never any mention of this being a credit nor any
explanation of why the total at the bottom of the page was different from the sum of the line
items above. It simply appeared to be another mathematical mistake that happens more
often than it should with a regulated utility company. If this was SWC's attempt to issue a
credit as directed by PUC, then it was handled very unprofessionally and mathematically
incorrect.
Now that SWC is applying the proper method of calculation for each tier in 2025 1 do not
advocate for any punitive action to be taken against SWC, merely a reconciliation of the
2024 invoices, applying the proper method of calculating the usage charges in order to
"Balance Up"the accounts for all customers.
In order to regulate SWC, Staff should review the monthly usage of all customers for all of
2024 and apply a similar calculation to what I performed in order to determine the proper
amount of credit due, if any, for each customer and so direct SWC to issue the appropriate
credit.
Respectfully
Robert Ferrell
2

Invoice
Syringa Water
P.O Box 3064
��. Coeur d'Alene, ID 83816 Date Invoice#
syringawatercdaggmail.com E1/24/2024 1603
Bill To
Robert Ferrell w5
1 1913 S Scharelant Lane
Coeur d'Alene,1D 83814
I
Due Date
2/12/2024
Quantity Description Rate Amount
Standard service fees 60.00 60.00
r `
1 ,
,,
(
_______..___-______a_.__..__...__--___n_.____,.____-.._. .....
a
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 o This month balance $60.00
synngawatercdaggmail.com
208-704-2041 a Customer Total Balance $60.00

Syringa Water Invoice
c9 P.O Box 3064 Date Invoice#
Coeur d'Alene, ID 83816
syringawatercda:@gmail.com 2121/2024 1709
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
3/15/2024
Quantity Description Rate Amount
Standard service fees 60.00 60.00
i
I � ,
1 �
i
l
i
I
-----------------------------------._____m..m__----.__-_-
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $' 60 00
[e-mail]
208-704-2041 Customer Total Balance $60.00

Invoice
Syringa Water
P.O Box 3064
Coeur d'Alene, ID 83816 Date Invoice#
r
[e-mail]
3/20/2024 1785
Bill To
Robert Ferrell
1413 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
4/10/2024
Quantity Description Rate Amount
Mar Standard service fees 60.00 60.00
D ,
I
r
1
_____________________________a-_..-___n____-_____.___--
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $60.00
[e-mail]
208-704-2041 Customer Total Balance $60.00

Syriga Water Invoice
P.O Box 3064 Date Invoice#
r� Coeur d'Alene, ID 83816
syringawaterc da@gmail.c om
4/17/2024 1857
Bill To
Robert Ferrell
1913 S Scharelant Lane
I Coeur d'Alene,ID 83814
Due Date
5/20/2024
Quantity Description Rate Amount
April Standard service fees 60.00 60.00
I
i
i
I �
I
i
I
i
L --------------------------------------------------------
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $60.00
[e-mail]
208-704-2041 Customer Total Balance $60.00

Y Syringa Water Invoice
R'ry C9
/JA
P.O Box 3064 Date Invoice#
=� Coeur d'Alene,ID 83816 [e-mail] 5/22/2024 1916
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
6/10/2024
Z uan�ity 3 - Desefiption Amount
May Standard service fees 60.00 60.00
Last read 3088720 May read 3221000
average monthly use 16535
82.6 Jan through May 1-20,0001 gallons used 2.50 206.50
I
i
I,
i
I
If
I
i
I
I
f
I
I
----------------------------------------------------
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene,ID 83816 This month balance $266.50
[e-mail]
208-704-2041 Customer Total Balance $266.50

Syringa Water Invoice
�� P.O Box 3064
Coeur d'Alene, ID 83816 Date Invoice#
syringawatercda@a gmail.com
6/26/2024 1989
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
7/10/2024
`a Description
Standard service fees Rate Amount
read 9940310
60.00 60.00 meter
20 1-20-0001 gallons used
893 90.001 - 120,000 gallons used-overage fee 2.50
50.00
12.00 1,071.60
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance
syringawatercda $1,181.60
@gmail.com
208-704-2041 Customer Total Balance
$1,181.60

Syringa Water Invoice
�~ P.O Box 3064
Date —7—Invoice#
Coeur d'Alene, ID 83816
[e-mail] 7/29/2024 2067
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
8/12/2024
I Quantity Description Rate Amount
July Standard service fees 60.00 60.00
meter read 3408460
20 1-20,0001 gallons used 2.50 50.00
58.1 40,001-80,000 gallons used overage fee 6.00 348.60
I
I
I
i
i
I
i
i
I
I
I
i
I
I
i
I
I
i
I
i
i
.----------------------------m__--------__----_--- t
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $458.60
[e-mail]
208-704-2041 Customer Total Balance $1,640.20

Syringa Water Invoice
P.O Box 3064
Coeur d'Alene, ID 83816 Date In!221E39
#
[e-mail] 8/30/2024
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
9/16/2024
Quantity Description Rate Amount
Aug Standard service fees 60.00 60.00
meter read 3461590 j
s !
20 1-20,0001 gallons used 2.50 50.00
33.1 20,001 -40,000 gallons used-overage fee 4.00 132.40
i
i
i
i
__.u__.__._..__.._..n.._...-n_._-_.-------------
Make Checks payable to:
Syringa Water Co.
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $242.40
[e-mail]
208-704-2041 Customer Total Balance $242.40

i
Syringa Water Invoice
\ P.O Box 3064
= Coeur d'Alene Date invoice#
�ID 83816
�
[e-mail] 9/30/2024 2211
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
10/15/2024
Quantity Description — - --—- a e moun
Standard service fees 60.00 60.00
meter read 3536660
20 1-20,0001 gallons used 2.50 50.00
55 40,001 -80,000 gallons used overage fee 6.00 330.00
I
I
I
I
i
I
i
i
i
I
1
I
----------------------------------------------------
Make Checks payable to:
i
i
Syringa Water Co.
i ,
PO Box 3064
Coeur d'Alene, ID 83816 ` This month balance g440.00
[e-mail]
Customer ustomer Total Balance

�s
Syringa Water Invoice
P.O Box 3064
Coeur d'Alene, ID 83816 Date invoice#
[e-mail] 10/30/2024 2287
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
11/15/2024
Quantity Description Rate Amount
Standard service fees 60.00 60.00 "
meter read 3562020
20 1-20.0001 gallons used 2.50 50.00 s
5.36 20,001 -40,000 gallons used-overage fee 4.00` 21.44 l
I
I
�I
i
I
Make Checks payable to:
Syringa Water Co.
PO Box 3064 ;
Coeur d'Alene, ID 83816 This month balance $73.44
[e-mail]
208-704-2041 Customer Total Balance $73.44 j

Invoice
Water
P.O Box 3064
Coeur d'Alene, ID 83816 Date Invoice#
[e-mail] 11/26/2024 2360
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
12/11/2024
_ Quantity ___ Description Rate Amount
Standard service fees 60.00 60.00 "
meter read 3584730
20 1-20,0001 gallons used 2.50 50.00
2.71 20,001 -40,000 gallons used-overage fee 4.00 10.84
i
i
i
i
i
i
i
i
i
i
i
Make Checks payable to:
Syringa Water Co.
i PO Box 3064
Coeur d'Alene, ID 83816 This month balance $12 0
[e-mail]
208-704-2041 Customer Total Balance $120 84

SY rin a Water Invoice
g
P.O Box 3064 Date Invoice#
Coeur d'Alene, ID 83816
[e-mail] 12/23/2024 2433
Bill To
Robert Ferrell
1913 S Scharelant Lane
Coeur d'Alene,ID 83814
Due Date
1/10/2025 I
--Quantity — - Description - -- - Rate Amount-
Standard service fees 60.00 60.00
Meters are not being read for the remainder or the winter season.Please remember to
expect your winter water usage billed on your Spring bill,itemized between each
month.
I
i
II
it
i
i
1
I
I
I
i
i
i
i
-----------------------------------------------------
Make Checks payable to:
Syringa Water Co. '
PO Box 3064
Coeur d'Alene, ID 83816 This month balance $60.00
[e-mail]
$60.00
208-704-2041 Customer Total Balance

1 of 3
EXHIBIT A
Tabulation of 2024 Actual Charges vs Proper Recalculations
Date
7/10/2025
gallons SWC RFF
used invoice proper
Month x 1000 amount calculation
1/24/2024 std service fee not read $60.00 $60.00
2/21/2024 std service fee not read $60.00 $60.00
3/20/2024 std service fee not read $60.00 $60.00
4/17/2024 std service fee not read $60.00 $60.00
5/22/2024
std service fee $60.00 $60.00
82.6 divided by 5 = 16.52/mo 82.6
usage charge 0-20k gal at$2.50
therefore 16.52 x$2.50 x 5 $206.50 $206.50
this is the "true up" calc for winter
6/26/2024
As calculated by SWC 109.3
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 80-120k gal at$12.00 89.3 $1,071.60
SWC subtotal $1,181.60
As calculated by RFF 109.3
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 20 $80.00
usage charge 40-80k gal at$6.00 40 $240.00
usage charge 80-120k gal at$12.00 29.3 $351.60
RFF subtotal $781.60
7/29/2024
As calculated by SWC 78.1
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 40-80k gal at$6.00 58.1 $348.60
SWC subtotal $458.60
As calculated by RFF 78.1
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 20 $80.00
usage charge 40-80k gal at$6.00 38.1 $228.60
RFF subtotal $418.60

2 of 3
gallons SWC RFF
used invoice proper
Month x 1000 amount calculation
8/30/2024
As calculated by SWC 53.1
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 33.1 $132.40
SWC subtotal $242.40
As calculated by RFF 53.1
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 20 $80.00
usage charge 40-80k gal at$6.00 13.1 $78.60
RFF subtotal $268.60
9/30/2024
As calculated by SWC 75
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 40-80k gal at$6.00 55 $330.00
SWC subtotal $440.00
As calculated by RFF 75
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 20 $80.00
usage charge 40-80k gal at$6.00 35 $210.00
RFF subtotal $400.00
10/30/2024
As calculated by SWC 25.36
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 5.36 $21.44
SWC subtotal F $73.44
The subtotal should have been $131.44 and it appears they miss-added the line items, there was
no indication of a credit on the invoice nor explanation of why "this months balance"was $73.44
instead of$131.44, it appeared to be just another mistake that occurs so often in the billings
As calculated by RFF
std service fee $60.00
usage charge 0-20k gal at$2.50 $50.00
usage charge 20-40k gal at$4.00 $21.44
RFF subtotal $131.44

3 of 3
gallons SWC RFF
used invoice proper
Month x 1000 amount calculation
11/26/2024
As calculated by SWC 22.71
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 2.71 $10.84
SWC subtotal $120.84
As calculated by RFF 22.71
std service fee $60.00
usage charge 0-20k gal at$2.50 20 $50.00
usage charge 20-40k gal at$4.00 2.71 $10.84
RFF subtotal $120.84
12/23/2024 std service fee not read $60.00 $60.00
Grand Total Paid to SWC for 2024 $3,083.38
Grand Total should have been for 2024 per RFF $2,687.58
Credit due that has not been received -$395.80