20250805Comments_3.pdf

The following comment was submitted via PUCWeb:
Name: James Duncan
Submission Time: Aug 4 2025 4:56PM
Email: iduncanCa�cbsonoma.com
Telephone: [phone]
Address: 210 N Star Ln.
Sandpoint, ID 83864
Name of Utility Company: Valiant Idaho Inc
Case ID: VID-W-25-02
Comment: "An increase of 333%to potentially 733% is unreasonable.
The owner of the water company is the developer(successor to the original developer) and
there for had an obligation to provide water compliant with state laws (both purity and
volume) but it seems they are trying to re coup "Power pumping equipment and Purification
Systems"which were necessary to meet State standards through this requested rate
increase. No one objects to a reasonable increase but this proposal is more than
excessive."
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The following comment was submitted via PUCWeb:
Name: Joaneen Stamegna
Submission Time: Aug 4 2025 9:13PM
Email:[e-mail]
Telephone: [phone]
Address: 230 N Idaho Club Dr
Sandpoint, ID 83864
Name of Utility Company: TIC Utilities, Valiant Inc
Case ID: VID-W-25-02
Comment: "August 4, 2025
Reference: Case Number: VID-W-25-02
IPUC,
The proposed rate increase directly opposes Idaho Code § 61-301, which explicitly requires
that: mandates that all charges by public utilities for their products, commodities, or
services must be just and reasonable. It explicitly prohibits and declares unlawful any
unjust or unreasonable charges.
Idaho Code § 61-622 places the responsibility on the filer(public utility)to prove that a
proposed rate increase is justified before the Idaho Public Utilities Commission (IPUC) can
approve it.
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Valiant Idaho Inc. is asking for an increase that does not meet either of the above codes.
It appears that Valiant was asking for an increase from $45 per month flate rate to $90 until
September 2024 when IPUC had them discontinue this increase until approved and
documents were filed. Upon re-filing, the request did not remain at$45 to $90 but moved
from $45 to $150 a month plus a usage charge. What happen to the company in that 30 day
period that the new request is 333% increase instead of the original 100% increase?Was
this request increased so that the final result would lead them back to $90 per month and
throw in the metered charge. Even at$90 plus a usage charge does not meet"just and
reasonable". If Valiant needed to make update and renovate the wells, this should have
been part of the negotiated price when purchased.
The flat rate of$150 plus a usage charge could start at a bill of$227 per month for a
household of 2(for 6 months). A water bill would be around $2262 per year from the current
$540. (*Calculation below)This is clearly unjust and not reasonable.
The monthly flat rate is an unprecedented increase and not comparable to any of the
surrounding water district.
Local rates:
Southside Water and Sewer: $39.20 for the first 12k gallons ( $1.25 per 1000 gal. over 12k)
Schweitzer Water: $44.80 VP Inc: $75.43 West Bonner Water and Sewer: $44.00 Ponderay
Water District: $39.20 for 12k gallon
This well is servicing the Golf Course but we are not seeing how the course, if any, is being
impacted with the .01 cent per gallon charge The Gallon usage over 7500 gallons that is
trying to be implemented is less than any I could find in Bonner County.This is also an
unreasonable limit with such a high flat monthly rate.
In Idaho, the average usage is approx.. 100 gallons per person a day. This does not account
for lawn irrigation.
Irrigation contributes to a large percentage of water usage.With absorbent rate increases,
many residences may choose to discontinue much of their irrigation resulting in the
community not being aesthetically appealing for a golf community.
*Calculation of average bill
Most residences are on .34 to 1 acre lots and have 2 people in their household. A rotary
head sprinkler system output is approximately 15 to 16 gallon per minute per station. To
water a .25 lot for 30 minutes @5 day a week will result in 9000 gallon per month. Most
residences water for longer terms than listed and have multiple stations (4 to 5 stations).
9000 gallons irrigation for 6 months plus household of 2 (100ga1/per day) is 15,200 gallons—
7500 including usage = 7700 gallons of overage a month @.01 cent= $77 to be added to the
$150 monthly rate.
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6 months@ $150 ... November thru April
6 month @ $227 ... May thru October
Yearly starting rate is $2262 per year for water
Will the meters be transparent for residence to view(as is gas or electric meters) so that
the usage can be monitored by homeowner?
Clearly, the $105 monthly rate increase combined with a low included usage (7500 gallons)
is completely unreasonable.
JoAneen Stamegna
230 N Idaho Club Dr.
Sandpoint, ID
Joaneen.st(a)gmaiLcom
435.300.1091
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From: [e-mail] <[e-mail]>
Sent: Monday, August 4, 2025 9:53 PM
To: secretary<[e-mail]>
Subject: Case No.: VID-W-25-02; Matter: Application of TIC Utilities, LLC for Authority to
Increase its Rates
Please find attached my consumer public comment for the above referenced matter.
would appreciate it if you could file this Public Comment in the file.
Thank you for your anticipated cooperation.
Sincerely,
Chris Norton
Christopher Norton
346 North Star Ln.
Sandpoint, Idaho 83864
Chris Phone: [phone]
Chris Email: chrisnortoniphone -gmail.com
Name: Christopher Norton
Email: [e-mail]
Phone: [phone]
Address: 346 North Star Ln., Sandpoint, Idaho 83864
Re: Case No.: VID-W-25-02
Company:TIC Utilities, LLC
Matter: Application of TIC Utilities, LLC for Authority to Increase its Rates
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To: [e-mail]
I want to thank the Commissioners for their entry of Order No. 36632 ordering a Virtual
Public Workshop on July 10 and a Customer Hearing on August 14. The Workshop was
extremely helpful. I wanted to attend and participate in the August 14 hearing, but
unfortunately, my wife and I will be on a lengthy plane ride at the exact time of the hearing,
and I will not be able to attend either in person or by phone. Accordingly, I would like to
incorporate my previously filed comments and exhibits dated 4/22/2025 into the record as
testimony for use in the August 14, 2025 Customer Hearing. In addition to my prior
Comments, I would like to address two issues.
Installation of water meters and use of new metered water rate.
I oppose the installation of water meters and a new metered water rate for the following
reasons.
1. If one looks at the Applicant's Pro Forma Schedule"B"expenses on Exhibit No. 2, it
demonstrates that the vast majority of the proposed $233,936.33 of expenses are fixed
costs.The variable costs are minimal. The cost of producing an additional 1,000 gallons of
water would only include the additional electricity costs for running the pumps and an
incremental amount of materials used in the filtration system. However, if one looks at how
this affects the residents who live along the golf course (which I do not) and who must
water their yards, then their monthly summer water bills, assuming they use 30,000 gallons
per month, would be $375 ($150 flat rate and $225 metered rate). See, comments by the
Staff of the IPUC at the Virtual Public Workshop regarding volume of water use, and my
volumetric analysis at Pages 9— 10 of my original Public Comment dated 4/22/2025.The
golf course residents would effectively be paying 60% of their water rate for variable costs
when the variable costs are only a small fraction of that amount.
2. Applicant has been unable to demonstrate that it can accurately generate water billings
even when it uses only a flat rate per month. How can we expect the Applicant to
accurately generate water billings for metered rates when it would need to also take
measurements and perform calculations. As I stated on Page 7 of my original Public
Comment dated 4/22/2025, 1 paid my water bill in July of 2024. For more than a year,
Applicant has been unable to send me a correct water invoice when all it had to do was
multiply$45 times three. This past month, Applicant sent me two invoices with two
different amounts, neither of which complied with requirements of IDAPA 31.21.01. Until
such time as Applicant can demonstrate that it is capable of generating an accurate invoice
for a simple flat billing rate, it should not be permitted to use metered billing rates.
3. As demonstrated by various Public Comments, Applicant has been unable to correctly
identify its pro-forma revenue (including only 9 months of revenue rather than 12 in its
Application) and expenses as a company(including pro-forma expenses double those of
only one year earlier when Applicant attempted to sell the water system to the HOA). See,
Pages 5—8 of my earlier Public Comment dated 4/22/2025. Since Applicant has been
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unable to accurately account for simple flat rate billings, it should not be permitted to
engage in metered billings.
4. It is unknown whether the proposed and/or installed water meters would allow the
residents to examine and check their water usage, either by visual examination or online
communication. In short, the residents would be entirely dependent upon the integrity of
Applicant to truthfully measure and bill for the water usage. Given the fact that Applicant
has been less than honest with the IPUC and its customers, it makes it extremely difficult
for a customer of Applicant to trust their water bill if the customer must rely upon the
veracity of Applicant. Examples of Applicant's questionable statements include the
following:
a. Applicant's notice to residents regarding the proposed rate increase 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." Nowhere in the Public
Notice does Applicant mention that Applicant is also seeking a metered rate that could be
150 to 200% above the base rate when the base rate alone would be 333% over the current
rate.The truth is that during the summer months, residents'water rates could easily be
$375 or more, an increase of 833% rather than 333%. (See the Public Notice attached to
Applicant's Application).
b. Applicant represented to the IPUC that it had elected "to sell and transfer the Idaho Club
water system to the Idaho Club Homeowners Association"only thirteen minutes after
Applicant sent an email to the HOA board of directors revoking the offer to sell the water
system. (See Page 11 of my Prior Comments dated 4/22/2025.)
c. Applicant's representation to the IPUC that its revenue included only 9 months of
revenue rather than 12 months. (See Pages 6&7 of my Prior Comments dated 4/22/2025
and Page 15 of David Frohnen's comments dated 4/28/2025).
Because Applicant has been less than forthright in its representations to the residents of
The Idaho Club and the IPUC, it is a far reach to ask us consumers to simply"trust"
that Applicant will accurately measure and bill us for the correct amount of water.
Therefore, an appropriate flat monthly rate would be best.
Reduced Flat Rate for Vacant Lots.
I support Applicant's request for a reduced flat rate for vacant lots for the following
reasons.
1. If a development is complete or nearly complete, then the benefit of water conservation
might outweigh the negative consequences of not charging standby fees for vacant lots.
However, when a development is not close to complete, it is unfair to both the
developer/utility company and the developed lot owners not to charge the vacant lot
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owners a standby fee. An example in the extreme demonstrates my point. If there was a
development of 300 lots of which only 10 lots were developed, the developer/utility
company had expenses of$150,000, and the vacant lot owners were not charged for water,
then either the 10 developed lot owners must be charged $15,000 per year for water or the
developer/utility company must charge the 10 developed lot owners a reduced fair rate and
the developer/utility company loses money every year until the development is nearly
complete. If the vacant lot owners do not contribute toward the expenses of the
developer/utility company, then it unfairly places the expense burden on the developed lot
owners and/or the developer/utility company. The IPUC should discover the number of
developed lots in the service area.The number of developed lots that are consuming water
should be somewhere between one-third and one-half of the lots in The Idaho Club. Since
the number of lots that are vacant in The Idaho Club and not taking water is 50% or more,
this places an unnecessary burden on the developed lot owners and/or the
developer/utility company if the vacant lots do not contribute to the payment of the
expenses. Even though the vacant lots may not be consuming water, they still have the
benefit of the system being maintained until such time as they connect to the system. In
addition, the undeveloped lots receive the benefit of having water available for fire
suppression should the need arise in the future.
2. Many of the undeveloped lots were purchased for investment purposes with the idea of
selling them in the future. When the lots were purchased, the owners knew there would be
carrying costs while holding the property. These carrying costs include interest payments,
taxes, insurance and HOA dues. It is neither unfair nor unanticipated that the carrying costs
could also include standby water rates.
Until such time as the development becomes nearly complete, the vacant lot owners
should pay a reduced amount toward the developer/utility company's expenses
Thank you for your consideration of these comments.
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