20260716Comments_3.pdf

From: Cristina Jacuzzi <[e-mail]>
Sent:Thursday, July 16, 2026 10:13 AM
To: secretary<[e-mail]>
Cc: Dalila Martinez <[e-mail]>; Virginia Bradley<[e-mail]>;
Rachel Bonilla <[e-mail]>; Dan Goodman <[e-mail]>
Subject: Case No. SSW-W-26-02-Southshore Subdivision No. 2 HOA Comments
Dear Commissioners,
Please find attached the Southshore Subdivision No. 2 Homeowners Association's
comments regarding Case No. SSW-W-26-02, along with Southshore 2 Water Company,
LLC's 2021, 2022, and 2023 Profit& Loss Statements referenced in the letter.
Thank you for your time and consideration of these materials.
Respectfully,
Board of Directors
Southshore Subdivision No. 2 Homeowners Association
Cristina Jacuzzi, President
Dalila Martinez-Roberts,Treasurer
Rachel Bonilla, Secretary

July 15, 2026
Southshore Subdivision No. 2 Homeowners Association
c/o Idaho HOA Management
Attn: Virginia Bradley, HOA Manager
P.O. Box 9
Caldwell, ID 83606
Idaho Public Utilities Commission
Commission Secretary
11331 W. Chinden Blvd., Building 8, Suite 201-A
Boise, ID 83714
Re: Case No. SSW-W-26-02 — Southshore 2 Water Company, LLC Application for Rate
Increase
Dear Commissioners:
The Board of Directors of Southshore Subdivision No. 2 Homeowners Association respectfully
submits this letter in opposition to the proposed water rate increase requested by Southshore 2
Water Company, LLC.
Southshore 2 Water Company is requesting that the monthly flat water rate be increased from
$95 to $195 per customer, an increase of more than 100 percent. The Board respectfully
requests that the Commission deny, or at a minimum defer, approval of this request until the
significant financial, legal, and ownership issues surrounding the water system have been fully
evaluated.
The current monthly water rate of$95 already represents a substantial expense for many
homeowners in our community. Many residents are retired or living on fixed incomes, and an
additional $100 per month would create a significant financial hardship for numerous
households. Before imposing such a dramatic increase, we respectfully ask the Commission to
carefully consider the effect it would have on the families who call Southshore Subdivision No. 2
home.
The HOA has retained legal counsel to investigate the history of the water system, the
associated water rights, and the related property transfers. Based upon counsel's review of the
recorded deeds and historical documents, our attorney has advised the HOA that there are
substantial legal questions regarding whether the physical water infrastructure and associated
water rights were ever effectively conveyed to Southshore 2 Water Company.
According to our attorney's analysis:

• In 2015, the Warranty Deed conveying Lot 16, which contains the community's water
facilities, was recorded with Canyon County, transferring ownership of the property to the
HOA.
• Our attorney found no recorded reservation, exception, or exclusion of the water system
or associated water rights when the developer conveyed Lot 16 or any of the subdivision
lots.
• Likewise, the recorded Warranty Deeds issued to homeowners contain no language
reserving, excluding, or separately conveying the water system or associated water
rights to any third party.
• It was not until 2017, after Lot 16 had already been conveyed and recorded in the HOA's
name, that a Buy/Sell Agreement and related documents were executed, attempting to
transfer the water system and associated water rights.
Based on this recorded chain of title, our attorney has advised the HOA that there are
substantial legal questions regarding the effectiveness of the 2017 transfer and whether the
water system and associated water rights had already been conveyed before those documents
were executed.
Historically, Mr. Martin administered and billed the community water system while Hubble
Homes was the developer. When the HOA was first formed, Mr. Martin conducted the
Association's initial HOA meeting and was retained for approximately two months to provide
HOA management services. At that time, the HOA had already received title to Lot 16 in 2015
and believed the remaining administrative step was to transfer the community water billing into
the HOA's name. The Board was not informed of any claimed ownership of the associated water
right. When the HOA was unable to obtain control of the community water billing, it continued
investigating. In 2018, while reviewing historical Idaho Department of Water Resources records,
the HOA discovered for the first time documents reflecting a 2017 transfer of the water right.
The IDWR records also state that the Department's approval of a change in ownership does not
verify the legal validity of the underlying transfer documents. Following that discovery, the HOA
investigated the matter and ultimately retained legal counsel in late 2025 to determine the
validity of the claimed transfer. At the time many homeowners purchased their homes from
Hubble Homes, they received documentation at closing indicating that the community water
system and associated water rights were intended to serve and benefit the community.
The HOA has attached Southshore 2 Water Company, LLC's 2021, 2022, and 2023 Profit and
Loss Statements for the Commission's review. These historical financial statements were
provided only after years of repeated requests by the HOA for financial information regarding
the operation of the water system. Upon reviewing these statements, the Board observed
several significant differences between the historical financial records and the current rate
application, including:
• Management fees increased from $2,750 in 2021, to $3,750 in 2022, to $6,000 in 2023,
while the current filing presents separate labor and compensation categories totaling
approximately $13,200.

• Water-testing expenses and insurance costs differ significantly from those reflected in
the current filing.
• Additional expense categories appearing in the current application were not reflected in
the historical Profit and Loss Statements.
While the HOA recognizes that legitimate operating expenses may change over time, we
respectfully request that the Commission carefully compare the attached historical financial
statements with the current filing and require sufficient supporting documentation, including
invoices, payroll records, contracts, insurance documentation, and other supporting records, to
verify that all claimed expenses are reasonable, necessary, properly documented, and
appropriately recoverable through customer rates.
The HOA also requests careful review of any compensation or expenses involving related
parties, including bookkeeping, administrative services, officer compensation, or other services
performed by family members or affiliated persons. The Association is not asserting that these
expenses are necessarily improper but respectfully requests that the Commission verify that
they were actually incurred, are reasonable for a 15-customer water system, and are directly
attributable to providing regulated water service.
The HOA has historically maintained and paid for insurance covering Lot 16 and the
infrastructure located on that property. Because Southshore 2 Water Company is separately
claiming insurance expense in its rate application, we respectfully request that the Commission
determine the nature of the insurance being claimed, identify the named insured and the
property being insured, and ensure that any insurance costs recovered through customer rates
are reasonable, properly documented, and not duplicative of insurance maintained by the HOA.
The Board also respectfully requests that Commission Staff require the Company to provide
sufficient supporting documentation for all claimed operating expenses, labor, management
compensation, insurance, plant investment, and other costs included in the rate application so
that the reasonableness of the requested rate increase can be independently verified.
We further request that the Commission closely examine the Company's claimed plant
investment, depreciation, and rate base. Many of the assets included in the filing originated from
the original development and construction of the community water system. Given the dispute
regarding whether those assets were later effectively conveyed to Southshore 2 Water
Company, the Commission should determine whether the Company has established a valid
basis to include those assets in its rate base and earn a return upon them.
If the HOA is ultimately successful in establishing ownership of the water system and associated
water rights, the system would be operated for the benefit of the homeowners rather than by a
private owner. The Board believes this would provide greater transparency, local accountability,
and the opportunity to establish water rates based upon the actual costs of operating,
maintaining, repairing, and regulating the system. Over the long term, this could reduce water
costs, protect property values, and make the community more attractive to future buyers.

Finally, should future legal proceedings determine that the water system and associated water
rights were not lawfully transferred as claimed, we respectfully request that the Commission
consider what remedies may be available to protect homeowners who have paid water charges
under those circumstances.
The homeowners of Southshore Subdivision No. 2 appreciate the Commission's careful
consideration of this matter. We respectfully request that the proposed rate increase be denied,
or at a minimum deferred, until the ownership issues have been fully evaluated and the
Company has demonstrated, through competent and verifiable evidence, that its requested
rates, claimed expenses, rate base, and revenue requirement are just, reasonable, and
supported by the record.
Thank you for your time and consideration.
Respectfully submitted,
Board of Directors
Southshore Subdivision No. 2 Homeowners Association
Cristina Jacuzzi, President
Dalila Martinez-Roberts, Treasurer
Rachel Bonilla, Secretary
Attachments:
1. Southshore 2 Water Company, LLC — 2021 Profit and Loss Statement
2. Southshore 2 Water Company, LLC —2022 Profit and Loss Statement
3. Southshore 2 Water Company, LLC — 2023 Profit and Loss Statement

Southshore 2 Water Company, LLC
Profit and Loss
January- December 2021
TOTAL
Income
Domestic Water Service 14,172.75
Interest 5.75
Sales -1,032.75
Unapplied Cash Payment Income 822.25
Uncategorized Income 0.18
Total Income $13,968.18
GROSS PROFIT $13,968.18
Expenses
Bank Charges& Fees 5.00
Insurance 400.00
Interest Paid 0.00
Legal & Professional Services 940.00
Management Fee 2,750.00
Power 935.83
QuickBooks Payments Fees 276.08
Repairs& Maintenance 1,046.04
Water Testing 2,050.00
Total Expenses $8,402.95
NET OPERATING INCOME $5,565.23
Other Income
Interest Income 6.59
Total Other Income $6.59
NET OTHER INCOME $6.59
NET INCOME $5,571.82
Cash Basis Thursday,April 4,2024 09:51 AM GMT-06:00 1/1

Southshore 2 Water Company, LLC
Profit and Loss
January- December 2022
TOTAL
Income
Domestic Water Service 14,003.52
Interest 12.56
Sales 73.95
Unapplied Cash Payment Income 369.25
Uncategorized Income 0.06
Total Income $14,459.34
GROSS PROFIT $14,459.34
Expenses
Ask My Accountant 0.00
Insurance 200.00
Interest Paid 0.00
Legal & Professional Services 730.00
Management Fee 3,750.00
Power 2,001.54
QuickBooks Payments Fees 315.47
Repairs& Maintenance 173.00
Utilities 0.00
Water Testing 5,835.25
Total Expenses $13,005.26
NET OPERATING INCOME $1,454.08
Other Expenses
Bad Debt 0.75
Total Other Expenses $0.75
NET OTHER INCOME $-0.75
NET INCOME $1,453.33
Cash Basis Thursday,April 4, 2024 09:52 AM GMT-06:00 1/1

Southshore 2 Water Company, LLC
Profit and Loss
January- December 2023
TOTAL
Income
Domestic Water Service 17,370.28
Interest 16.18
Sales 134.72
Unapplied Cash Payment Income -675.10
Total Income $16,846.08
GROSS PROFIT $16,846.08
Expenses
Legal & Professional Services 730.00
Management Fee 6,000.00
Power 1,968.96
QuickBooks Payments Fees 382.31
Repairs& Maintenance 653.82
Water Testing 2,680.99
Total Expenses $12,416.08
NET OPERATING INCOME $4,430.00
NET INCOME $4,430.00
Cash Basis Thursday,April 4,2024 09:53 AM GMT-06:00 1/1

From: PUCWeb Notification <[e-mail]>
Sent:Thursday, July 16, 2026 3:00 PM
To: secretary<[e-mail]>
Subject: Notice: A comment, Kylee Williams,was submitted to PUCWeb
The following comment was submitted via PUCWeb:
Name: Kylee Williams
Submission Time: Jul 16 2026 2:44PM
Email: kyleewilliams21 @gmail.com
Telephone: [phone]
Address: 13594 South Shore Ln
Nampa, ID 83686
Name of Utility Company: SouthShore2 Water
Case ID: SSW-W-26-02
Comment: "Hello,
I am a resident of the South shore 2 HOA and neighborhood. The person who has
appointed themselves as administrator of our shared community well, has filed for an
increase in fees of$100 per month, to a total of$195 per month. This is direct retaliation as
we are in legal proceedings to prove that he has no lawful right to administer our water.
My household directly opposes this proposed increase and respectfully requests the
Commission carefully review all of the facts before approving any increase Comparatively
sized communities typically pay between $25 and $45 a month for upkeep, testing, and
required management of their well systems per our current HOA management company.
We are not on city water. An amount of$195 is outrageous. This increase would greatly
cause harmful effects to both the seniors on a fixed income in our neighborhood, and the
young families that have children. In this economy, raising the water bill by 105.26% is
immoral. My family would struggle with this additional cost, for no additional benefit or
purpose. This is pure greed and retaliation.
From my understanding, the water system has been paid off for some time. Ryan Martin
has been collecting$95 (plus fees etc.) per home,for years—without disclosing what is
being done with the extra funds. It is clear that money is being placed in his pocket for
profit. And now he wants more and is taking advantage of a small community of homes
with many seniors. This community well is not meant to operate as a for-profit private
utility. It is for community use.
I have not entered into any contract or agreement with any private water company for
service, nor have I provided consent for the system to be operated as a separate utility. I
have not signed anything."
Thank you for your help and consideration.
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From: Kylee Williams <[e-mail]>
Sent:Thursday, July 16, 2026 12:42 PM
To: secretary<[e-mail]>
Cc: [e-mail]
Subject: Case No. SSW-W-26-02
Hello,
I am a resident of the South shore 2 HOA and neighborhood. The person who has
appointed themselves as administrator of our shared community well, has filed for an
increase in fees of$100 per month, to a total of$195 per month. This is direct retaliation as
we are in legal proceedings to prove that he has no lawful right to administer our water.
My household directly opposes this proposed increase and respectfully requests the
Commission carefully review all of the facts before approving any increase
Comparatively sized communities typically pay between $25 and $45 a month for upkeep,
testing, and required management of their well systems per our current HOA management
company. We are not on city water. An amount of$195 is outrageous. This increase would
greatly cause harmful effects to both the seniors on a fixed income in our neighborhood,
and the young families that have children. In this economy, raising the water bill by
105.26% is immoral. My family would struggle with this additional cost, for no additional
benefit or purpose. This is pure greed and retaliation.
From my understanding, the water system has been paid off for some time. Ryan Martin
has been collecting$95 (per fees etc.) per home, for years-without disclosing what is
being done with the extra funds. It is clear that money is being placed in his pocket for
profit. And now he wants more and is taking advantage of a small community of homes
with many seniors. This community well is not meant to operate as a for-profit private
utility. It is for community use.
I have not entered into any contract or agreement with any private water company for
service, nor have I provided consent for the system to be operated as a separate utility.
I have not signed anything.
Thank you for your help and consideration.
Kylee Williams, CPC
Healthcare Operations
Medical Policy Operations Specialist
Blue
Cross of Idaho
L—CO ro E—C• .n&—Srv.!Asa ti .,
3000 E. Pine Ave. I Meridian, ID 83642 1 [phone]
[e-mail]

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Blue Cross of Idaho, 3000 E. Pine Ave, Meridian, ID 83642
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