20250804Comment_1.pdf

The following comment was submitted via PUCWeb:
Name: David Frohnen
Submission Time: Aug 3 2025 6:03PM
Email: davidfrohnen(a)gmail.com
Telephone: [phone]
Address: 105 Vermeer Drive, Suite 2-302
PONDERAY, ID 83852
Name of Utility Company: Valiant Idaho, TIC Utilities
Case ID: VID-W-25-02
Comment: "I have two (2) comments related to Rate Design on the subject Case.
1) Use of water meters and consumptive use rates.
2)Approval of a "non-flowing", Standby or"ready-to-serve" charge on vacant lots.
1) Concerning the Applicant's request to approve the installation of water meters and a
new metered water rate, I have the following comments.
-TIC Utilities has not demonstrated the ability to accurately account for all customer
accounts, quarterly billings, nor revenue receipts. Several customers have complained
about wrong billings and slow corrections to accounts.
-The Applicant has not disclosed details of a metered system's financial prudence and
benefits nor detailed a method for customers to access their"smart meter" meter readings
and consumption data on-line (noting that most smart meters do not have readable
displays).
-The current application is an initial IPUC approval of rates and fees for a new CPCN -thus
simplicity in an initial filing has merit.
Thus -the request is that, prior to approval of any meter installation or metered water rate,
that IPUC require a filling from the applicant addressing:
-The proposed water meter type, sizes, and type of smart meter technology.
-The proposed software for monitoring and recording water usage, customer billing
calculation and final billing/collection of customer accounts.
- Provision for Customers to access water usage data (online, on-site or other means).
- Reasonable procedures and fees for Customers to challenge water consumption data
and/or billing amounts.
- Costs for staffing, installation and on-going implementation for the metering plan.
Financing plan and impacts of same to current and future customers (see my previous
comments about treating this as "contributed capital" and value of water resource for
future development.
Rate schedule prove-up to reconcile with the IPUC approved Revenue Requirement and
adjust proposed consumptive use rates accordingly.

2) Regarding the use of a rate for vacant lots - not consuming water. I am supporting a
reduced rate for these lots based on the following.
-There are real costs to the Utility and benefits to the property owner for the utility to a)set-
aside system capacity for the individual lot, b) upkeep and maintenance costs of the
system such that the utility is in a "ready-to-serve" status at all times for the property
owner.
-Also -there appears to be no time limit on vacant lots connecting to the water system and
after 20 years - it's time the costs for maintaining a water system for the benefit of all lot
owners is shared in a reasonable and fair manner.
END
Thanks you
David Frohnen