20250806Comments_5.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.
1

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
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The following comment was submitted via PUCWeb:
Name: Bruce Carpenter
Submission Time: Aug 6 2025 11:52AM
Email: [e-mail]
Telephone: [phone]
Address: 135 Hidden Lakes Drive
Sandpoint, Wa 83864
Name of Utility Company: Valiant Idaho Inc.
Case ID: VID-W-25-02
Comment: "IPUC,
I am providing comment on Valiant Idaho Inc:s request (VID-W-25-02)to object to the
requested rate structure. The requested rate structure is unreasonably high and has not
been justified.
Comparing the requested base rate for active systems shows a rate 3 to 4 times other water
service providers as shown on the IPUC website for water purveyors. Specific reference
and values have been provided in other comments previously submitted, so I will not
repeat them here.
Service costs provided in the application need to be justified. While the rate structure
requested aligns with the service costs shown, there are not sufficient details or history
provided. A breakdown of the service costs should be provided to justify the values
presented. It would also be beneficial to request operating costs from previous years from
the previous operator, the majority of the system has not changed and the much lower
billing rates presumably covered costs. Return on investment (12%) is at the top end of
rates for utilities overseen by PUCs, the rate should be reviewed an set in alignment with
other IPUC reviewed water purveyors.
2

Review of cost allocation should also be considered for active vs inactive lots. The owner
of the water delivery system is also the developer, so hold a large number of the inactive
Lots. As an owner of both active and inactive lots, this is not just an desire to defray my own
costs.
Bruce Carpenter
135 Hidden Lakes Drive
and
Lot E-5, Green Monarch Drive
Sandpoint, ID 83864
509-392-9658
--------------------------------------------------------------------------------------------------------
The following comment was submitted via PUCWeb:
Name: Bruce Carpenter
Submission Time: Aug 6 2025 11:52AM
Email: [e-mail]
Telephone: [phone]
Address: 135 Hidden Lakes Drive
Sandpoint, Wa 83864
Name of Utility Company: Valiant Idaho Inc.
Case ID: VID-W-25-02
Comment: "IPUC,
I am providing comment on Valiant Idaho Inc:s request (VID-W-25-02)to object to the
requested rate structure. The requested rate structure is unreasonably high and has not
been justified.
Comparing the requested base rate for active systems shows a rate 3 to 4 times other water
service providers as shown on the IPUC website for water purveyors. Specific reference
and values have been provided in other comments previously submitted, so I will not
repeat them here.
Service costs provided in the application need to be justified. While the rate structure
requested aligns with the service costs shown, there are not sufficient details or history
provided. A breakdown of the service costs should be provided to justify the values
presented. It would also be beneficial to request operating costs from previous years from
the previous operator, the majority of the system has not changed and the much lower
billing rates presumably covered costs. Return on investment (12%) is at the top end of
rates for utilities overseen by PUCs, the rate should be reviewed an set in alignment with
other IPUC reviewed water purveyors.
Review of cost allocation should also be considered for active vs inactive lots. The owner
of the water delivery system is also the developer, so hold a large number of the inactive
3

Lots. As an owner of both active and inactive lots, this is not just an desire to defray my own
costs.
Bruce Carpenter
135 Hidden Lakes Drive
and
Lot E-5, Green Monarch Drive
Sandpoint, ID 83864
509-392-9658
--------------------------------------------------------------------------------------------------------
The following comment was submitted via PUCWeb:
Name: Melvyn Bailey
Submission Time: Aug 6 2025 1:18PM
Email: [e-mail]
Telephone: [phone]
Address: 138 North Idaho Club rd
Sandpoint, ID 83864
Name of Utility Company: TIC Utilities LLC
Case ID: VID-W-25-02
Comment: "Comments of VID-W-25-202 from Mel Bailey and Marsha Bell
• If special(reduced) rates have been established for some lots or homes, then the
developer shall pay the remaining amount to bring all lots and homes to equality.
• If lots are to be charged for water availability, this applies to all lots. Including the
developed lots owned by the developer and the undeveloped lot proposed by the
developer.
• The average home uses more than 7500 gpm. In Idaho this could be as high as
20000 gpm, see Reference below. The base usage should be higher than 7500 gpm.
• The CCR's of the Idaho Club requires that all homeowners maintain their lawns.
This includes watering their lawns during the summer months. In the reference, irrigation
adds from 30%to 700% of the water used in the average household. This cost needs to
reasonable. There is already an increase in the base rate plus there was no additional
charge for irrigation water usage in the past. It may be an area where homeowners try to
reduce their cost and water less, causing brown lawns and HOA problems.
• Expansion of the water system to provide water to more lots is the financial
responsibility of the developer not the current customers. The expansion costs must be
kept separate, not included in the cost of structures and improvements.
The total revenue required does not change. From the above points, the fees paid would be
redistributed. To offset this redistribution the base number of gallons used per month
should be increased, the rate for the initial gallons used per month should be reduced and
there should be a reduction in the rate for the use of water over the monthly household
gallonage, i.e. for lawn irrigation.
4

Reference: Idaho Dept of Water Resources Hand Book Recommendations for Processing
Reasonably Anticipated Future Needs (RAFN) "
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5

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