20260221PC EXHIBIT B.pdf

2/21/26, 12:18 PM Ryan Martin Mail-Southshore 2 PWS#ID3140254
MGmail Ryan Martin <[e-mail]>
Southshore 2 PWS# ID3140254
1 message
Cassandra Lemmons <Cassandra.Lem [e-mail]> Tue, Dec 30, 2025 at 12:36 PM
To: "[e-mail]" <[e-mail]>, "[e-mail]" <[e-mail]>
Cc: Virginia Bradley<[e-mail]>, Dalila Martinez<[e-mail]>, Rachel Bonilla
<[e-mail]>, Travis Culbertson <[e-mail]>, Brandon Lowder
<[e-mail]>, Chris Ababon <[e-mail]>, Tom Mehiel <[e-mail]>, Tyler
Fortunati <[e-mail]>, Kathryn Ritter<[e-mail]>
Cristina and Ryan,
Thank you for keeping DEQ apprised of your situation. I understand how the regulatory realm can be confusing to
navigate. Each agency has their own rules and requirements.
I would like to provide a summary of our discussions, and I've included everyone involved with the system insofar as I
can tell from previous emails:
• DEQ's top priority is ensuring every regulated public water system provides safe, reliable drinking water to the
customers it serves.
• DEQ did not validate, nor refute any claims of ownership by either party. DEQ does not have regulatory
authority to make ownership determinations for water rights, real property, or utility infrastructure. Any such
disputes and associated ownership determinations would be made through civil court with the aggrieved
parties. DEQ would not be a primary party or decision maker in this type of action. Currently,there is no
further pending review, determinations, or actions forthcoming from DEQ regarding ownership of the
Southshore 2 PWS. Any further action by DEQ regarding ownership would be initiated by submittal of legal
ownership documentation and would only be used to justify updates to DEQ's PWS database for facility
ownership and associated points of contact purposes.
• DEQ has a consecutive 12-year regulatory relationship with Southshore 2 Water Company(SSWC) as the
responsible party for the system.
• The system is in substantial compliance with rules, and we currently have no concerns regarding the
delivery of safe reliable drinking water.
o Given that SSWC presented itself as the owner of the system in 2013 when the system first became
regulated, DEQ would not have required a transfer of ownership to demonstrate continuity of ownership
as detailed in IDAPA 58.01.08.008.
o Ryan Martin is listed as the registered agent of SSWC since the system became regulated by DEQ in
2013.
o DEQ will continue that established relationship with SSWC until such a time as we are provided legal
evidence that the responsible party is different.
o DEQ can add HOA Board member as extra "emergency" contacts with the awareness that DEQ does not
leverage this contact for primary regulatory purposes.
o DEQ cannot make the requested deletions and additions of primary contacts without irrefutable
evidence of ownership, which is likely to be in the form of judicial confirmation of
ownership/responsibility for the system.
o DEQ is aware that the Southshore HOA owns the well-lot.
o DEQ is aware that SSWC owns the water right associated with the well on the well-lot. Water rights are
regulated by Idaho Department of Water Resources.
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2/21/26, 12:18 PM Ryan Martin Mail-Southshore 2 PWS#ID3140254
• It is common for water systems to charge reasonable fees to cover costs of services including, but not
limited to: water testing, operations/maintenance, and operator fees.
o It is common for water systems to have established procedures to discontinue service for unpaid fees (or
other reasons)from users of the system.
• Cost of service fees are not regulated by DEQ.
• The current responsible charge operator has a contract and obligation to SSWC, not the Southshore 2 HOA.
• Travis Culbertson,with the PUC is working with the SSWC and the Southshore 2 HOA as related to the PUC's
regulatory purview.
Sincerely,
.� Cassandra Lemmons
Drinking Water Compliance and Enforcement Supervisor
Idaho Department of Environmental Quality
P: [phone] 1 C: [phone]
• www.deq.idaho.gov
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