20250912Amended Petition for Reconsideration.pdf

RECEIVED
Martin Reighard SEPTEMBER 12, 2025
4970 N. Anne St. IDAHO PUBLIC
Coeur d'Alene. Idaho 83815 UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF GEM STATE CASE NO. GSW-W-24-01
WATER COMPANY, LLCM
APPLICATION FOR AUTHORITY TO AMENDED PETITION FOR
INCREASE ITS RATES AND CHARGES RECONSIDERATION
FOR WATER SERVICE IN THE STATE
OF IDAHO
GEM STATE WATER having filed an Application for increase of monthly rates, increase
of commodity charge and decrease in monthly gallons included in monthly charge, filed
12/27/2024; Errata to Application 1/31/2025;Amended Application and Exhibits 2/28/2025; and
Amended Application 2/28/2005, all submitted to the Idaho Public Utility Commission and is
incorporated herein by reference.
The Idaho Public Utilities Commissions filed their Final Order July 31, 2005, and is
incorporated herein by reference.
Troy Hoffman Water District hereby files their Petition of Reconsideration to the order of
July 31, 2025 in its entirety. Troy Hoffman Water District does hereby join, and incorporate by
reference the petitions for reconsideration made herein by Spirit Lake East Water District,
Diamond Bar Estates and Bitterroot Water Districts in their request for Reconsideration.
Troy Hoffman Water district filed a written request for reconsideration, a copy of which is
attached hereto as Exhibit"A"which was received by the PUC on August 4,2025, a copy of which
is attached hereto as Exhibit`B".
It should be noted that each of these water districts did not come under the purview
of the PUC until they were bought out by an out-of-state company which is disturbing on three
fronts not previously mentioned. 1. Why should out of state corporations that are in the business
of making money be in charge of Idaho's natural resources? Who are they to be telling the

consumer how much water to use? Their responsibility should be bringing the resource to the
consumer. 2. How can we trust the PUC to be fair in making decisions for the residents of Idaho
using "Public Utilities" when the PUC directly profits off those "Public Utilities" used by the
consumers they are entrusted protect?
3. The fact GSW continues to reduce, is allowed by the PUC to reduce the minimum
allotted water allowance per month, with the plan to eliminate any minimum allowance in its
entirety in a fire prone area is criminal. All the properties in Troy Hoffman struggle to maintain
their green space, which is clearly apparent as you drive through our community. Do we flush our
toilets, take a shower, let our gardens die which feed us, what about our livestock. Should we tell
them they are only allowed to drink so much water per day?
IT IS HEREBY requested that the Idaho Public Utilities Commission reconsider
the Final Order No 36550 filed on July 31, 2025.
Respectfully Submitted,
Exhibit A
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Exhibit B

Exhibit A
August 1, 2025
State of Idaho
Office of the Attorney General
700 W. Jefferson Street Suite 210
P.O. Box 83720
Boise, Idaho 83720-0010
Dear Mr. Labrador;
SUBJECT 20250731-Final_Order_No_36703.pdf and Case#CSW-W-24-01
FYI-At 8:24pm August 1, 2025 we received an email/text from Gem State Water Alert that the Troy
Hoffman system experienced a low pressure event.They experienced a drop in water pressure below
the state standard of 20 psi due to an unplanned well shut down event.While the system did maintain
some pressure,a drop in/loss of water pressure creates conditions that could allow contamination to
enter the distribution system through backflow, by backpressure,or back-siphonage.
So now, since we are forced to buy water for drinking and cooking,etc.for at least the next 4 days, per
their notice.We will expect to be reimbursed for all the water gallons we will have to purchase,along
with a water gallon consumption credit on our bill for the entire time this issue remains in effect. We
will be sending our receipts to Gem State water for cash reimbursement due to this additional
expense. Please inform them of this so they can be ready to reimburse us,especially those on fixed
incomes.
WE ARE PETITIONING FOR RECONSIDERATION OF THE SERVICE DATE OF THIS
ORDER. PLEASE READ THE BELOW LETTER. AWAIT YOUR COMMENTS.
We are residents of Troy Hoffman Water district, located within Coeur d'Alene city limits. Our
district was purchased by Gem State Water Company in 2022. We endured a substantial
increase in 2023. The increase was at least 100% because the normal Bi-Monthly billing was
changed to Monthly. Gem State is now proposing an even larger increase, with a reduction of our
currently allowed gallons per month which includes both the base rate and the overage rate. We
attended a meeting in Athol Idaho at the Athol Community Center on 6-18-2025 where all
Water Systems customers of Gem State Water were invited to attend a Public Workshop and
Customer Hearing to voice their concerns about a proposed (UNREASONABLE) Rate increase
schedule to go into effect as early as August 2025.
After having attending the meeting that involved one PUC commissioner (as well as numerous
PUC staff) in Athol Idaho we are left with more questions than answers. Probably over one
hundred people spoke at this meeting, all addressing the injustice of these proposed increases,
with virtually no transparency forthcoming from the PUC and Gem State Water. We represent a

large group of 164 Troy Hoffman water customers and are appealing to you, with the hope that
this matter can be investigated by your office. We have no intercessors,just neighbors, going up
against a large monopoly. Gem State Water is headquartered in Coeur d Alene Idaho and is a
wholly owned subsidiary of NW Natural Water Company, LLC(NW Natural Water),which is a Portland
Oregon headquartered subsidiary of Northwest Natural Holding Company (NYSE: NWN) (NW Natural
Holdings).
We need your help. Included in this letter are several of the main concerns regarding the
company's lack of transparency, the PUC's dependence upon increases to sustain (conflict of
interest perhaps?), water quality, the nonexistent consumer notification process as well as
several points and concerns that we feel need addressing. We hope you will take the time to
look into this matter, and help us citizens, who need representation in this matter.
A small group of these customers met again on 6- 25-2024 to discuss the ramifications of what
we all learned about the plans Gem State Water has for all of the Water Customer connected
with Gem State Water owned by Gem State Water.
This group decided to target a few top concerns but to be clear not all.
Top 10 Concerns
1. Safety and Quality Testing of our Water Supply. It is a
state law that regular water quality testing be completed
between 6-01-25 and 09-01-25 https://www. deq. idaho. gov/
I spoke with Doug Ebert, compliance official for the Idaho Department of Environmental Quality.
He walked us through the Water Quality analytics and I am confident that we are very protected
and can be 100% confident that our water quality is beyond reproach.
We feel that the main problem with this concern isn't safety it's our water systems owners'
inability to keep the customers informed. Just telling us that they are complying with the states
testing requirements is not enough. We believe they need to provide a detailed copy of the
testing result to each customer when the report is completed each year.
https://www2.deg.idaho.gov/adminILEIAlapi/document/download/23165-see this link for example
of testing results!
2. Reliability -What does that mean? Perhaps to start, mak-
ing sure we have a backup generator if we have an elec-
tric supply outage at any time . Adequate water pressure
mandated by State law, Water quality, and reliability and
Replacement infrastructure, i . e . working pumps, equipment
needed to eliminate down time to sustain excellent supply
to all customers .
The meaning of water supply reliability is often misconstrued. For instance, the 2015 Urban Water
Management Plan update required water purveyors to demonstrate that annual water supplies are
sufficient to meet annual water demands under normal and dry hydrological conditions. This annual
assessment of water supply reliability is misleading.A water system's reliability must be assessed not
only on an annual basis, but also on a monthly and even daily basis. Moreover, reliability is not just a
function of annual physical supply availability but also nuanced details of water rights and contracts,
regulatory and contractual issues, and water system infrastructure limitations.
"Water supply reliability"requires a water purveyor to consistently deliver water to its customers and

that the water system is dependable to continually deliver additional water supplies to the purveyor's
customers into the future.
Also all systems that could fail should have an equipment backup inventory. Does Gem State Water have
those areas covered or NOT?The operative definition is dependable to continually deliver additional
water supplies to the purveyor's customers into the future.
3. Rate increases . Gem State Water took over our small water
system Troy Hoffman just about 3 years ago in 2022 and on
March 1, 2023 increased the Bi-monthly charge from $27 . 50
(every other month) and immediately increased our monthly
rate to $35 . 00 (every month) . Now, if approved by the
Idaho PUC, they are proposing to increase our rates to
$65 . 65 or more per month. They are also proposing a new
ridiculous reduction ridiculous reduction of our base
gallon consumption level along with an increased overage
charge starting at 1000 gallons for each additional gal-
lon used.
An online search shows that in 2025 the average monthly cost of water in Idaho is between
$38.00-$49.00, reflecting the state's balance of affordability and resource management. We
should not be forced to pay a much higher rate than our neighbors.
Customer Rates should also only be based on each water system's needs and not on an
average of all the systems in the state. Each individual system's needs are unique and should
be their responsibility not shared with other systems! We should only be covering the needs
of our system. Not any of the other systems owned by Gem State Water.
Just as an example; at the Athol meeting we heard sworn testimony from many customers of
Gem State Water's various water companies who live on acreages and small farms.These
customers have needs that far exceed the regular city customer's needs. Such as,
• Watering livestock and other Farm animals
• Large Garden areas that provide not only their own
family needs but are also products to be sold at lo-
cal farmers markets that make up their a substantial
part of their income . If they can' t afford the water
much of their income would disappear .
• Green Spaces to protect their properties from fire
threats .

- 7
4 III 4 1 1 1 I I 1 1 I I I I
HiddenValleyWaterAssociation 49 $70.00 10,000 $1JS $78.75 $140.00 $22750
Garwood Water Cooperative 159 $42.00 12,000 $2-00 $2.00/1,000 for excess of 100,000 548.00 $118.00 $218.00
Rolling Meadows Ranch 21 $34.00 20,000 $1.70 $34.00 585-00 $170.00
Panhandle Village 44 $75.00 20,000 $1.50 575.00 $120.00 $195.00
Emerald Estates 195 $26-50 37,500 $2.00 $4.00/1000 over 50,000/$6 60 ov( 526.50 $51.50 $251.50
Silver Leaf Ranch 25 $45-00 30,000 $1.00 $45.o0 $65 00 $115.00
Harbor View Estates 133 $50.55 5,000 $1.18 $1.48 over 25K,$2,99 Over 45K,$: $62.35 5118.70 $285.45
Lost Creek Water Association 87 $55.00 30,000 $1.00 $1.00 over50K,$1.50 over 106K $55-00 $10250 $125.00
Lone Mountain Water Association 113 $60.00 Unlimited N/A $60.00 $60.00 $60.00
Walking Horse 30 $60.00 Unlimited N/A $6.000 $60A0 560.00
Alpine Meadows 106 $33.50 10,00D $2.00 $4150 $113150 S213.50
Bayview Water B Sewer District 109 $32.00 5,000 $1.75 $49.50 S110.75 $198,25
Greenferry Water District 392 $50.00 25,000 $1.00 $1.30 over 5CK,$2.00 over 100K $50.00 $75.00 514E)o
Hauser Lake Heights 44 $30.00 10,000 $1.80 $39.00 $102.X 5195%
Remington Water District 391 $35.00 25,000 $1.00 $0.60 over 100K $35,00 $60.00 $110.00
Waterford Estates 44 $25.00 10,000 $1.00 $30.00 $65.00 115.00
Pineview Estates Water Association 162 54D.00 Unlimited N/A $40,00 $40.00 540.00
Elkhorn Ranch 37 $55.00 10,000 $1.25 $61.25 $105.00 51650
Ohio Match Rd Water District 55 $60.00 30,000 $1.75 $2,25 over60K $60A0 $95!00 $202.50
Edgemere Owner's HOA 24 $1.50/thousand 20,000 $2.50 $22.50 $94.50 S222 50
Spirit Bend Water Association 25 $55.00 0 $1.40 $76'.00 S125.00 5195.00
Hackney 42 $40.00 15,000 $1.00 $3.00 over 36K,$4.00 over 41 K $40.00 P5.00 $312.00
Troy Hoffman _ 147e $35-00 7,500 52-45 1147connecticning according toDEQ. 553.38 $139.13 $261.63
rov!offrr thproposedratesapplied 147• S53.50 5000 $450 147connecnonmgaccordingtoDEQ $9850 $256100 $4SIDD,,
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ul I_� ��° ;7i��. 14.!rt',i��� I'I#��I'� !L�. �ll��r �1� .�IC�- illrri'lllll� killllli�'IIIiIII �I�iIIIhi111111V 11111111'�llilllll�����
OEM STATE WATER COMPANY
UNMt 2 to Reply Comments
Proposed Rotes Compxhan
Gallons Included in Minimum Cwtaner Charge
Minimum Custaner Charge Commodity Rate:Per 1,OW Gallons Ahoue Volume Included. (Allowance)
Company Staff and
MoterSh4 llnthnr Present Comparry ApPltion Staff Company ReebL Present com latlon Staff Company Reply Present Application Cmicary Reph
STAFF RECOMMENDED
SCNFOUIE1
Bar circle S and Spirit lake 1 $ 35.00 $ 51.50 53%$46.00 32%$47.67 36% 5 2.52 S 4,50 79%$4.17 6S%$4.27 69% 7.500 5,DDO 7,SW
Bar COM 5 and 50H1 lake 15 $ 70.00 $ 1D7.00 S3%$92.00 31%$9S.34 36% $ 2.52 S 4.50 79%$4.37 65%$4.27 69% 15,000 10.000 10,000
Bar Cittie Sand Spldilake 2 $ 112.00 $ 171.20 S3%$147.00 31%$152.34 36% $ 2.S2 5 4.50 79%$4.17 65%$4.27 69% 30,000 20.000 20,000
Bitterroot and Rlcktl 1 $ 35.00 $ 53.50 53%$46.00 31%$47.67 36% $ 2.45 $ 4SO 94%$4.17 70%S 4.27 74% 10,00D 5,0DO 7,500
Troy Hoffman 1 $ 35.D0 S 53.50 53%S 46,01) 31%$47.67 36% $ 2.45 $ 4.5 94%S4.17 70%$4.27 74% 7,500 5,000 7,S00
Diamond Bar Ettatn 1 $ 41.00 $ S3.50 30%$46.DO 12%$47.67 26% $ 2.45 $ 4.50 94%$4.17 70%$4.27 74% 7,500 Sp00 7,500
mo Diand Bar Estates 2 $ 112.00 $ 171.20 53%$247.00 31%$352.34 36% $ 2.45 $ 4.50 84%$4.17 7D%$4.27 74% 35,DDO 20.000 20.000
Diamond Bar lrtlgation 1 $ 3S.00 $ S3.S0 53%$46.00 31%$47.67 36% $ 2.16 $ 4.51 99%$4.17 85%$4.27 89% 7,500 5,DDO 7,SDO
Diamond Bar lrrltrt1 1.5 $ 70.00 S 107.0D S3%$92.00 31%$9S.34 36% $ 2]6 $ 4.50 99%$4.17 85%$4.27 89% 10,000 10,0DO ID,000
0lamond Be,Inlgallon 2 $ 112.D0 S 171.20 S3%$147.00 31%$15234 36% $ 2.26 $ 4.50 99%$4.17 8S%I$4.27 89% 12,000 20.000 2D,D00
STAFF RECOMMENDED
SOIEDULE2
Happy Valley 1 $ 35.00 S S3S0 S3%$46.00 31%S 47.57 36% $ 1.45 $ 4.SO 210%$4.17 188%S 4.27 194% 1S,DOD 5,000 15,000
Nappy Wiley I.S $ 70.00 $ 107.00 53%$92.00 31%S 95.34 36% $ 1.45 $ 00 210%$4.17 188%$4.27 194% IS,(100 10,000 15.000
Happy Valley 2 $ 112.DO $ 173,20 53%$147.00 31%$152.34 36% $ IAS $ 4.50 210%$4.17 189%$4.27 194% 30,000 20,D00 20,000
Lynnwood 1 $ 35,00 53.50 53% 46.00 31%$47.67 36% $ 7.45 $ 4.SO M%$4.17 70%$417 )4% IS,000 S,000 15000

4. Basic Accounting Principles. First a FULL accounting of what happened to the funding to the
Cent of the revenue from the increase after Gem State Water purchased Troy Hoffman in
2022 and increased the rates to EVERY month starting 3/1/2023. Not only the Revenue but an
Audited Balance Sheet with Profit and Loss represented. We expect FULL transparency as to
where our hard earned money was spent and the details of what the increase was used for.
Now with regards to this current proposed increase we expect the same procedures. We
demand knowing all financial justifications for the proposed rate increase. No numbers
regarding costs, repairs, employee compensation, expenditures of any kind have been made
available to us.This is unacceptable where exactly this is proposed increase budgeted to go and
when and how much is proposed.
Where exactly is this proposed increase budgeted to go and when and how much is proposed
for each line item?And a Full Profit and loss and Balance sheet analysis.
We believe the word "proprietary"was used to keep that information confidential.There were
no cost projections going forward presented to the customers, no information forthcoming at all
to justify an increase of any amount. No financial reports showing how the previous increase
Money was spent.Testimony at the public meeting at Athol revealed the fact that the PUC
"Guarantees" Gem State Water make a profit? How, and more importantly,why is this possible?
Their parent company, N.W. Natural Holding companies profit year to date is 20.4%. We are
requesting transparency regarding company expenditures. If they are requesting an astronomical
increase, they should have to show the books or reasonable documentation to all customers to
justify the increase. The mere fact that the PUC sustains itself through revenue made off these
companies is suspect in itself, and not being transparent, is additionally troublesome. Someone
needs to oversee this process.That someone is your office. No oversight, no transparency, makes
the consumer question the integrity of this proposed rate increase.for each line item?And a Full
Profit and loss and Balance sheet analysis.
Then equally important is . . . Where exactly is this proposed increase budgeted to go and when
and how much is proposed for each line item?We demand a full Profit and Loss and Balance sheet
analysis.
We would request that Gem State Water is required to provide a yearly analysis of the company's
financial position.

GEM STATE WATER COMPANY
Exhibit 1 to Reply Comments
Revenue Requirement Comparison
Company Original Staff Company Reply
Request Recommended Recommended
1 Rate Base $ 3,813,776 $ 3,774,729 $ 3,776,659
2 Required Rate of Return 7.96% 7.51% 7.51%
3 Net Operating Income Requirement $ 303,538 $ 283,293 $ 283,438
4 Net Operating Income Realized $ (145,019) $ 12,850 $ (24,674)
5 Net Operating Income Deficiency $ 448,557 $ 270,443 $ 308,112
6 Net Operating Income Deficiency 448,557 270,443 308,112
7 Gross up Factor 1.345668 1.339644 1.339644
8 Total Incremental Revenue Requirement $ 603,609.33 $ 362,297.95 $ 412,760.96
9 Revenues at existing rates $ 763,610 $ 763,610 $ 763,610
10 Total Revenue Requirement $ 1,367,219 $ 1,125,908 $ 1,176,371
11 Percent Increase Required 79.0% 47.4% 54.1%
L ==EMM
5 . We believe this is an unfair Monopoly where we don' t have
any other option.
A monopoly is a market structure where a single seller or
producer has complete control over the supply of a
particular good or service, allowing them to influence
prices and limit competition. This lack of competition can
lead to higher prices and fewer choices for consumers .
1 . Single Seller? Yes
2 . Complete control over the supply of a particular good or
service? Yes
3 . Allowing them to influence prices and limit competition?
Yes
4 . Higher prices and fewer choices for consumers? Yes
Mr. Attorney General - Aren' t there laws prohibiting Monopolies?
We do not have a reasonable alternative to Gem State Water. It
has been suggested by many that if any current customers choose
to disconnect from Gem State Water and elect to join another
local water supplier we would be charged a usury financial fee
for doing so . We believe that should be illegal .

6 . At the end of the year our Aquifer is in the
excess capacity situation at 14, 327 K gallons per second
returning to the Aquifer. These rate hike proposals are not
because of scarcity and conservation necessity. We believe it' s
purely that they, Gem State Water, is trying to make as much
Balancing the water budget .
IN OUT
600 600
500 TOTAL INFLOW o, 500
c
985 million gallons 420 a o
400 QJ
> E c Q 400
per day(mgd) .> �, a
300 280 v = c E a 300
200 153 a, 0 a y o �0 3 200 °
a c V) v
Y
100 83 o a `-' W > 100 °
14 35 ° � a ¢ .J a �
0 0 `^
-100 ' m -33 -23 -22 -18 -100 Q
L `� L -133 -200 `
o -200 g Cu�' C a) Y -166
a
m o -300 a-300 N _a' ° TOTAL OUTFLOW
-400 i= °' 980 million gallons -400
-500 0- -585 per day (mgd) -500
-600 -600
The SVRP Aquifer budget values shown on this page represent
average conditions of all days in the years 1995 to 2005.
money as they can to increase the value of their asset for
future sale or just stock profits .
7 . it' s been suggested that the Idaho PUC should have a
representative on their Board from
each water system. This would allow transparency for each
water customer.
8 . Water Rights . What does that really mean? Does anyone
have the legal authority to
Infringe on the Water Rights of the citizens of Idaho? This
comes from the young lady at
the Athol meeting that presented an argument that no one can

own the water that is really ours but can charge for the
infrastructure, wells, equipment etc . getting the water
to us .
A water right is authorization to use water in a prescribed manner, not to own the water itself.
Without diversion and beneficial use,there is no water right.
"Well" is an artificial excavation or opening in the ground more than eighteen (18)feet in vertical
depth below land surface by which ground water of any temperature is sought or obtained.
"Water right" is the legal right, however acquired, to the use of water for beneficial purposes.
Idaho's constitution and statutes also guarantee the right to appropriate those public waters.
When a private right for the use of public waters is established by appropriation, a water right
is established that is a real property right (much like property rights in land), and Idaho law
protects real property rights. See Idaho Constitution Article XV and Idaho Code § 42 et al.
A domestic right is a right to the use of water for homes, organization camps, public
campgrounds, livestock, and for any other purpose in connection with these uses including
irrigation of up to one-half acre of land. See Idaho Code § 42-111.
CHAPTER 1
APPROPRIATION OF WATER — GENERAL PROVISIONS
42-111. DOMESTIC PURPOSES DEFINED. (1) For purposes of sections 42-221, 42-227, 42-
230, 42-235, 42-237a, 42-242, 42-243, and 42-1401A, Idaho Code:
(a) The phrase "domestic purposes"or "domestic uses"means:
(i) The use of water for homes, organization camps, public campgrounds, livestock, and for any
other purpose in connection therewith, including irrigation of up to one-half(112) acre of land, if
the total use does not exceed thirteen thousand(13,000) gallons per day; or
(ii) The use of water for any other purpose, if the total use does not exceed a diversion volume of
two and eight-tenths(2.8) acre feet per year.
(b) "Domestic purposes" or "domestic uses" shall not include water for the following purposes,
unless the use meets the diversion rate and volume limitations set forth in paragraph (a) of this
subsection:
(i) Mobile home parks or recreational vehicle parks;
(ii) Apartments, condominiums, and similar developments with multiple dwelling units;
(iii) Except as provided in subsection (3) of this section, subdivisions, as defined in chapter 13, title
50, Idaho Code;or
(iv) Commercial or business establishments or mixed-use establishments where the water is used
primarily for commercial or business purposes.
(2) Except as provided in subsection (3) of this section, multiple water rights for domestic
uses or domestic purposes shall not be established or exercised in a manner to satisfy a single
combined water use or purpose that would not itself come within the definition of a domestic use
or purpose under this section. The purpose of this limitation is to prohibit the diversion and use of
water, under a combination of domestic purposes or domestic uses as defined in this section, to
provide a supply of water for a use that does not meet the exemption of section 42-227, Idaho Code,

and is required to comply with the mandatory application and permit process for developing a right
to the use of water pursuant to chapter 2, title 42, Idaho Code.
(3) Multiple water rights for domestic purposes or uses may be established and exercised
from the same point or points of diversion if the use is limited to residential, in-home use. This
subsection does not affect any other permitting requirement or other requirement that may apply
to the use of water within a subdivision. For the purposes of this section, the term "in-home use"
means the utilization of water within a residence or household, including all activities that require
water, such as drinking, cooking, bathing, and cleaning within and around the household. It does
not include irrigation of lawns, gardens, landscaping,pastures, or other open spaces.
History:
[(42-111)1899,p. 380,part of sec. 12;reen. R.C. & C.L., sec. 3250;C.S.,sec.5566;I.C.A., sec.
41-111; am. 1990, ch. 319, sec. 1, p. 870;am. 1995, ch. 233, sec. 1,p. 790;am. 2025, ch. 129, sec. 1,
p. 663.]
After reviewing these Statutes I think we can assume that Gem State has acquired all the legal
authority to our Water Rights. This would require a lot of time and research on our part. So, I would
just ask the AG this question.
"Does Gem State Water have the legal authority to regulate our water distribution and comply
with the Water Rights authority of Idaho? "Does Gem State Water comply with Idaho State law?
Again - A water right is authorization to use water in a prescribed manner, not to own
the water itself. Without diversion and beneficial use, there is no water right
9. Communication between Gem State Water and their customers for the various water
systems.
Communication has been terrible from Gem State Water. We, as customers, require clear, concise, pro-
fessional communication on a regular basis.
Some of us in the Troy Hoffman Water District only received one letter back in April 2025. This letter
was not even dated,just stated on February 28, 2025,Gem State Water Company filed an amended ap-
plication with the Idaho Public Utilities Commission (IPUC). One customer stated the Gem State website
stated they sent out a letter in December 2024. 1 did not received the letter in December, I received a
generic letter in April. Also that letter stated the current Median bill and Proposed Median Bill on their
chart. . . but is probably inaccurate since the letter has no date and just states on February 28, 2025
Gem State filed an amended application, so I would think that their letter is NOT an accurate represen-
tation of the true impact for consumer costs since the current median bill is only for 2025 which has
maybe 2-3 months of data and does NOT include the summer months. It seems like window dressing
instead of accurate info. That was the first some of us even heard about a rate increase request. And
since then, absolutely lousy communication. Some of us only found out about the June 18,2025 meet-
ing for public comment because someone saw it posted on the Next Door App from someone else.
One customer called and asked to speak to the manager and was told the "acting manager"was some-
one named Tim.The lady that she spoke with was named Leslie,who apparently is no longer working
there. Leslie told the customer when asked why we all had not been notified about the June 18th meet-
ing, and that they had done what they were required to do. She was unable to clarify just what they are
required to do. What are they required to do to notify customers of meetings, changes, rate increases,
any info that we should be informed of. I couldn't get a straight answer out of her on any question that

was asked. Tim,the acting manager,was not very forthcoming or informative on the next day when he
called the customer either. Some people stated Gem State sent the letter out with our bill. I don't think
that is accurate as the only bill we get each month is a small postcard, not in an envelope either.
Also, in this letter,their chart shows 79% increase for 4 water systems owned by Gem State and 53% in-
crease in the other two companies owned by Gem State. How many users are on each of these sys-
tems? I believe Troy Hoffman has 164 users, how many users are on each of the other water sys-
tems? How can 4 systems require the same 79% increase? I want and need documentation provided
for our review.
It seems like there are always constant excuses.We want full transparency and professional accurate
COMMUNICATION. Someone commented that the last price increase we had was because Gen State
Water said it was to upgrade people's out of date systems. We want and need documentation provided
for our review. What have they done with the money from the last rate increase for the Troy Hoffman
water system? We need and deserve a full breakdown of what's been replaced to each owner in our
water district including parts and labor. Show us proof!
Even their website keeps changing. Just 2 weeks ago it had two new customer service representative
and a field technician. Now the field technician is gone. It seems like all the previous employees are
gone.
One of the customers called Gem State this past Tuesday 7/29/25 and spoke with Cynthia, a Customer
Service Representative, and asked her some questions:
o Who is the current manager? All she could tell me is that it is a new person named Mar-
shall, she didn't have a last name.
o I asked what happened to the field service technician whose picture was on the new
website but is gone now. She said he no longer works there. I asked who the field tech-
nicians are. She said they have a new OPS field manager named Garrett, again she didn't
know his last name.
o I asked her why our bill shows usage but does not designate whether that is gallons, she
said that is cubic feet on the bill but it is not marked as such. How would we know if we
are being deceived? Nothing is consistent or adds up with this company. Why should we
believe anything they say?She gave me the formula to convert the usage (cubic feet) on
my bill into gallons so I would know how much was used. 3031.7 usage x 7.48=
22677.12 (gallons). 22677.12 Minus 7500(base allowed) = 15179.36 x$2.45 =
$37.19. Why can't they have a more understandable bill?
On their"new" website, it states: Gem State Water operates water and wastewater utility ser-
vices in the growing Coeur d'Alene metropolitan area and is a wholly owned subsidiary of NW
Natural Water.Gem State Water serves about 2,200 people through 880 connections.We are
proud to serve customers in North Idaho of Spirit Lake East Water, Lynwood Water, Diamond
Bar Water, Bar Circle 'S'Water, Bitterroot Water and Happy Valley Water. They don't even have
Troy Hoffman Water listed here,yet when I questioned Cynthia, she said it was listed. Well it's
not!
On another website, maybe NW Natural Water it shows Gem State serves about 3750 people
thru 1500 connections. So which one is true? How can we believe anything they say? If they
can't get simple information posted accurately, why should we believe anything they post or
say??

10 . Well Meter
How much water is leaking? How does this affect us or not affect us?
It has been established, and admitted by Gem State Water that their proposed increases would
"encourage conservation" when in reality it would force conservation. Our position is that,that is not
their right.Their responsibility to consumers is delivery of safe reliable water, not forcing conservation,
we believe they have no right to do that.
As mentioned earlier regarding Conservation, remember that the Aquifer is replenishing roughly 14,327
K gallons per second returning to the Aquifer. It is on the record that our water quantity currently
exceeds capacity available. So, it's our opinion that forcing conservation through excessive price increase
is NOT a justification.
If conservation is a concern of Gem State Water, It is believed that there is no meter on the pump in the
pump house, why?Typically, a water company must check the meter in the pump house monthly,
compare it to the monthly billing totals, identify any leakage and address the discrepancy. So, while
they're forcing conservation upon its consumers,they themselves may have no idea if or how much
leakage is occurring.The hypocrisy is astounding. Please hold them accountable.
State of Idaho Department of Water Resources Water Measurement Guidelines
Water Meter?SECTION 4.-STANDARDS FOR MEASURING FLOW IN CLOSED CONDUITS WITH INSTALLED
FLOW METERS.The following are minimum requirements for measurement of flow in a closed conduit
using installed flow meters:The meter shall meet the requirements found in the Department's Minimum
Acceptable Version 7.c 06/30/2009 WATER MEASUREMENT GUIDELINES-4 Standards for Open Channel
and Close Conduit Measuring Devices (see Appendix A) 1.The accuracy of the meter shall be checked
and calibrated when installed, and at least once every three years thereafter in accordance with the
provisions of Section 5. Meters not meeting these requirements shall be replaced with an acceptable
meter except that the department may grant a variance to individual requirements on a case by case
basis.
So, Mr.AG can you verify that Gem State is complying with this requirement and provide verification that
it has complied!
11. Many customers, in fact probably all have commented that it is unfair that Gem State is bundling ALL
of their systems together as to the amount of increase they are requesting. We believe that our rates
should only be based on our Troy Hoffman needs. We should only be covering the needs of our system.
Not any of the other systems owned by Gem State.
12. Ownership or Access Rights
The legal framework surrounding water supply often depends on ownership and access rights, which can
vary significantly based on whether the water supply is privately owned, municipally controlled, or part
of a shared resource. In many jurisdictions, water rights are treated as property rights, which can be
bought, sold,or leased.This is especially true in areas where water scarcity creates complex legal
systems to manage allocation and usage. For example, riparian rights, common in water-abundant
regions, allow landowners to reasonably use water from a river or stream bordering their property.

In arid regions, prior appropriation rights allocate water based on a first-come,first-served principle,
regardless of proximity to the source.These rights,governed by state laws,often lead to disputes,
particularly during shortages.The intersection of these rights with the obligations of water utility
companies adds complexity. Utility companies, regulated by state or local governments, must balance
individual property rights with public interests, ensuring equitable access to water while maintaining
infrastructure and service standards.
Water Utility Company Regulations
Water utility company regulations play a critical role in governing disconnections.These companies,
whether public or private, are subject to federal, state, and local rules designed to ensure fair and
reliable water access. At the federal level,the Safe Drinking Water Act sets water quality standards, while
state regulations address operational aspects like billing and customer service. Local ordinances may
refine these rules further to meet community-specific needs.
Utility companies are generally required to provide notice before disconnecting services,with timelines
usually ranging from 10 to 30 days.These notices often include instructions on resolving issues, such as
overdue payments. Disconnections are typically prohibited during extreme weather conditions to
protect public safety. Courts have intervened when utility companies violate these regulations, imposing
fines or ordering service restoration.These cases emphasize the accountability of utility providers to
adhere to legal requirements.
We would like to suggest to you Mr.Attorney General Labrador to go to the site below and read the
comments from the customers who attended the meeting in Athol Idaho at the Athol Community Center
on 6-18-2025.This should give you a better understanding of how"We the People" feel about this issue.
https.-Apuc.idaho.gov/case/Details/7471
Sincerely,
Martin Reighard, Diane Pryor, Peggy Cooper, Ian Kuchenski, Kim Heistuman current customers of
Troy Hoffman Water System
Martin Reighard
4970 North Anne St.
Coeur d'Alene, Idaho 83815
Cell: 208-651-8900
Diane Pryor
904 E Margaret Ave
Coeur d'Alene, ID 83815
Cell: 208-755-6769
CC:ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, ID 83720-0074
[phone]
Idaho Bar No. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8,SUITE 201-A BOISE, ID 8371

NORTH ' • HOFFMAN WATER
These Yards are owned by Retired customers on fixed incomes
END THE
s�
i � ,• l �� ..rl i t � i;.
GREED AND ABUSE •

Gem State Water Pump house—Anne St and Hoffman
THIS IS THE CURRENT CONDITION AS OF 5-01-2025
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66
APPARENTLY GEM STATE WATER CAN'T AFFORD TO WATER