20260723Comment_1.pdf

From: Cristina Jacuzzi <[e-mail]>
Sent:Wednesday, July 22, 2026 8:41 PM
To: secretary<[e-mail]>
Subject: Supplemental Comments-Case No. SSW-W-26-02
Dear Commissioners,
Please find attached two supplemental documents for your consideration in Case No.
SSW-W-26-02:
1. Supplemental Comments
2. Timeline of Ownership and Administrative Control of the Southshore
Community Water System
These documents are provided to offer additional historical context and explain the
circumstances that led the HOA to seek the Commission's assistance.
Thank you for your time, consideration, and service throughout this proceeding. I
appreciate the opportunity to submit these additional materials for the record.
Respectfully,
Cristina Jacuzzi
President
Southshore Subdivision No. 2 Homeowners Association

Dear Commissioners,
I respectfully submit the attached Timeline of Ownership, Administrative Control,
and Water System Events for your consideration in Case No. SSW-W-26-02.
The purpose of this timeline is to provide historical context and explain why the
Southshore Subdivision No. 2 Homeowners Association originally sought the
Commission's assistance.
The HOA did not come to the Commission because it wanted its community water
system regulated. We sought assistance because homeowners continued receiving
water bills from Southshore 2 Water Company, LLC while the Association had no
contractual relationship with that company and could not understand why it was unable
to manage what, based on the recorded deeds, subdivision plat, Water Right License
No. 63-32259, Hubble Homes' Purchase and Sale Agreements, and other documents
available to the Board, it believed was its own community water system and water right.
As mentioned in my prior public comments, one critical event stood out during the
Board's investigation. By 2017, the HOA had already been deeded Lot 16—the property
on which the community well is located—and, based on the recorded deed, subdivision
plat, Water Right License No. 63-32259, Hubble Homes' Purchase and Sale
Agreements, and other documents available to the Board, understood that the
community water system and the water right had been conveyed to the Association.
After the HOA was formed and Mr. Ryan Martin's brief service as the HOA manager had
ended, DEQ sent correspondence regarding the administrative updates needed for the
community water system to Mr. Martin because he remained the contact on file. Rather
than transitioning that administrative responsibility to the newly formed HOA, Mr.
Martin requested that future DEQ correspondence be directed to Southshore 2
Water Company, LLC. As a result, the Association never received the information
necessary to update the system's ownership and contact information or assume
administrative control of the public water system. That single event left the HOA trying
to understand why it could not take over the operation of what it believed was its own
community water system.
The attached timeline documents those events chronologically and explains how the
Board arrived at the questions now before the Commission.
As you review this matter, I respectfully ask the Commission to look beyond the
historical operation of Southshore 2 Water Company, LLC and examine the legal
documentation supporting its authority to own, operate, and bill for the community water
system. Has the Commission identified a recorded deed, reservation, severance,

easement, or other legal instrument showing that Hubble Homes retained the
community water system or Water Right No. 63-32259 before conveying Lot 16 to the
HOA in 2015? Based on the documents available to the Board, we have been unable to
locate such documentation.
For nearly nine years, homeowners have continued paying monthly water bills to a
private company that the HOA never hired and with which it has never had a contractual
relationship, while the HOA has continued maintaining Lot 16 and paying the property's
insurance and related expenses. We believe Southshore 2 Water Company, LLC was
originally created to manage and bill for the community water system during the
development of the subdivision until the HOA became operational. Once the HOA was
formed, we believe the administrative transition should have occurred but did not.
We respectfully ask for the Commission's help in carefully reviewing the legal authority
supporting Southshore 2 Water Company, LLC's continued operation before approving
any request from this company. We simply want to understand why the HOA was never
able to assume administrative control of its community water system and why
homeowners continue paying a private company with which the Association has never
had a contract when the HOA is fully capable of operating and managing the system
itself.
Thank you for your time and consideration of the attached timeline.
Respectfully,
Cristina Jacuzzi
President
Southshore Subdivision No. 2 Homeowners Association

Critical Issue at Hand
2015-2026: Although the HOA acquired Lot 16 in 2015, it states it never received
administrative control of the community water system or Water Right No. 63-32259.
According to the HOA, Ryan Martin, through Southshore 2 Water Company LLC, remained
the primary point of contact with the regulatory agencies, continued operating the community
water system, and continued billing homeowners for water service while the HOA remained
without administrative access or control.
Timeline of Ownership, Administrative
Control, and Water System Events
Southshore Subdivision No. 2 Community Water System
Date Who Event Significance
2010 First Security First Security Bank Establishes the beginning of the
Bank acquires the documented chain of title leading to
Southshore Hubble Homes.
subdivision through
foreclosure.
2012 First Security First Security Bank Establishes Hubble Homes as the
Bank ---> conveys the owner and developer before conveying
Hubble Homes subdivision, including Lot 16 to the HOA.
LLC Lot 16, to Hubble
Homes.
October Boardwalk During development, Demonstrates that Don Hubble and
2012 Property Boardwalk Property Ryan Martin were jointly managing
Management Management LLC Boardwalk during development,
LLC manages the establishing Ryan Martin's involvement
subdivision. An years before the HOA became
amendment lists E. operational.
Don Hubble and
Ryan Martin as

managers, and both
sign the filing.
2012 Idaho Water Right License Establishes that Water Right No.
Department of No. 63-32259 is 63-32259 serves the subdivision
Water issued. The license through the community well located on
Resources identifies Lot 16 as Lot 16. The license further states that
the point of diversion the community water system is to be
and Lots 1-16 as the managed by the Homeowners
authorized place of Association, providing important
use for the community context for the HOA's position that it
water system. should have received administrative
control after acquiring Lot 16 in 2015.
April Southshore 2 Annual Report filed Establishes that Don Hubble remained
2015 Water listing Don Hubble as the manager of Southshore 2 Water
Company LLC the registered agent Company at the time Lot 16 was
and manager. The conveyed to the HOA.
business address is
701 S. Allen Street,
Meridian.
August Hubble Homes Hubble conveys Lot KEY OWNERSHIP EVENT. The HOA
2015 LLC , 16 to the HOA by became owner of Lot 16, where the
Southshore 2 recorded Quitclaim community well is located. The HOA
Homeowners Deed. The deed maintains that because no recorded
Association, contains no reservation, severance, easement,
Inc. reservation or or other legal instrument has been
exclusion of the produced showing Hubble retained the
community water community water system or Water
system or Water Right No. 63-32259 before conveying
Right No. 63-32259. Lot 16, those rights transferred with the
property. However, no documented
transfer of administrative control of
the community water system or Water
Right No. 63-32259 to the HOA has
been identified.

2016 Hubble Homes Final homes are sold. Homeowners purchased their homes
/ Homeowners Hubble's Purchase relying on Hubble's written
and Sale Agreement representations that the appurtenant
state that appurtenant water rights and water system
water rights, water transferred with their property.
systems, wells, and
related rights transfer
with the property
unless otherwise
agreed to in writing.
June Southshore 2 Annual Report filed Demonstrates the beginning of the
2016 Water with Ryan Martin administrative transition from Don
Company LLC signing as Manager, Hubble to Ryan Martin within
while Don Hubble Southshore 2 Water Company before
remains listed as the the HOA became operational.
registered agent and Company correspondence had already
manager. The shifted to Ryan Martin's address.
company mailing
address changes to
Ryan Martin, P.O.
Box 2654, Eagle,
Idaho.
July 2016 Boardwalk An amendment removes Demonstrates that Ryan Martin
Property Don Hubble as a continued operating Boardwalk
Management manager. The after Don Hubble's removal, while
LLC amendment is signed by the same mailing address later
Ryan Martin, and future appears in Southshore 2 Water
correspondence is Company records. This reflects
directed to P.O. Box continuity in administration.
2654, Eagle, Idaho.

March Southshore 2 The HOA becomes No documented turnover of the
2017 HOA/ Ryan operational. Ryan community water system or
Martin Martin conducts the Water Right No. 63-32259
HOA's first occurred. According to the
organizational meeting HOA, it was never provided
and serves as HOA DEQ records, IDWR contacts,
manager for passwords, operating records,
approximately two regulatory correspondence, or
months. administrative control. Ryan
Martin continued operating
Southshore 2 Water Company
LLC, and homeowners
continued receiving water bills
from Southshore 2 Water
Company rather than through
the HOA.
May 2017 Southshore 2 Ryan Martin's services Although Ryan Martin was no
HOA as HOA manager end longer the HOA manager,
with Southshore HOA. administrative control of the
Snake River HOA community water system and
Management is retained Water Right No. 63-32259 was
as their new HOA never transferred to the HOA.
managing company. Ryan Martin continued
operating Southshore 2 Water
Company LLC and continued
billing homeowners for water
service.
August Idaho DEQ sends public water Critical Administrative Event:
2017 Department of system correspondence By August 2017, Ryan Martin
Environmental to Boardwalk. Ryan was no longer serving as the
Quality (DEQ) Martin responds by HOA's manager. The HOA was
requesting that future never notified of this request from
correspondence be DEQ and did not authorize Ryan
directed to his business Martin to receive or manage the
address rather than to HOA's public water system
the HOA. correspondence or control it on
their behalf. At that time, the
HOA also questions what legal
authority Ryan Martin had to
request that DEQ direct the
HOA's administrative
correspondence to his

business address? The HOA
states that this request
contributed to the HOA never
obtaining administrative
control of its community water
system while homeowners
continued receiving water bills
from Southshore 2 Water
Company LLC.
Decembe Hubble Homes / Documents are HOA Position: These
r 2017 Ryan Martin executed purporting to documents were executed after
transfer Water Right Hubble had already conveyed
No. 63-32259 and the Lot 16 to the HOA. The HOA
community water disputes the validity of the
system from Hubble transfer because no prior
Homes to Ryan recorded reservation,
Martin/Southshore 2 severance, easement, or other
Water Company LLC. legal instrument has been
produced demonstrating
Hubble retained ownership
before conveying Lot 16.
2017 Idaho IDWR processes the IDWR expressly states that
Department of ownership update "processing an ownership update
Water submitted for Water does not determine legal
Resources Right No. 63-32259. ownership or validate the legal
effectiveness of the submitted
documents."
2018 Ryan Martin Ryan Martin becomes Secretary of State records
the registered agent thereafter identify Ryan Martin
for Southshore 2 Water as the registered agent. Ryan
Company LLC. Martin continued operating
Southshore 2 Water Company
LLC, remained the point of
contact with regulatory
agencies, and continued billing
homeowners while the HOA
remained without
administrative control.

March Southshore 2 While investigating Nearly nine years after
2026 HOA ownership, the HOA acquiring Lot 16, the HOA
discovered DEQ's discovered it had never
online administrative received administrative access
portal and requested to its own public water system.
access. DEQ provided During those nine years, Ryan
the password; first Martin remained the regulatory
time, however, the contact, continued operating
HOA was granted only Southshore 2 Water Company
emergency contact LLC, and continued billing
access and was not homeowners while the HOA
permitted to update the remained without
system's ownership or administrative control of the
administrative community water system or
information. Water Right No. 63-32259. The
HOA contends this resulted
from Mr. Martin's actions in
2017, when he directed DEQ to
continue sending
administrative correspondence
to Southshore 2 Water
Company LLC rather than
transferring that responsibility
to the newly formed HOA.
March Southshore 2 The HOA contacts the The HOA sought the
2026 HOA Idaho Public Utilities Commission's assistance
Commission seeking because it believed ownership
guidance after of Lot 16, including the
discovering it never community water system
received administrative infrastructure and Water Right
control of the No. 63-32259, had transferred
community water to the HOA, but administrative
system. control of the community water
system had not.

May 2026 Southshore 2 Southshore 2 Water The HOA participates because
Water Company Company LLC it believes unresolved
LLC / Idaho requests regulation by questions remain regarding
Public Utilities the Idaho Public ownership of the community
Commission Utilities Commission water system, Water Right No.
and later seeks to 63-32259, and the legal
increase monthly water authority to operate the system
rates from $95 to $195 and bill homeowners. The HOA
and even as much as has since retained legal
$300. counsel, who believes the 2017
Bill of Sale was ineffective
because ownership of the
community water system and
Water Right No. 63-32259 had
already passed to the HOA
when Lot 16 was conveyed in
2015.

STATE OF I DAHO
Department of
Environmental Quality
1410 North Hilton - Boise, ID 83706 [phone] C. L. "Butch" Otter, Governor
John H. Tippets, Director
August 08, 2017
SOUTHSHORE WATER (ID3140254)
PO BOX 2654
EAGLE, ID 803616
Dear Administrative Contact:
Idaho Department of Environmental Quality's Drinking Water Program routinely provides public water systems
with mail, invoice(s), and/or electronic correspondence. In the event of an emergency, we also need to be able to
contact the appropriate individuals as quickly as possible. To do so, we need to ensure the contact information
for your system is accurate.
Please take a moment to review the back of this letter. It lists the current mailing addresses, phone numbers, and
e-mail addresses for the Administrative Contact, Financial Contact, Emergency Contact, Designated operator(s),
and Sampler(s) associated with your public water system . We also listed the connection count and population
served for your system .
it is important to note that the "Sampler" contact information is used by our auto dialer to remind public water
systems to take samples, provide public notification, or to complete a compliance schedule activity. Make sure to
identify all of the "Sampler" contacts that should be receiving these reminders.
If the information we have is correct, then no further action is necessary and we thank you for the review . If
our records are not correct, we respectfully request that you provide us with updated information as soon as
possible. Please utilize our online tool located at littrj://www..)-.de -n. idaho.gov/wa"L-p- dwcontacts to update your
public water systems contact information. The unique password that has been assigned to your water system is
We appreciate your assistance. Please contact JAMi DELMORE at 208-455-5300 or
Jami.Delriiore@phd3 .idaho.gov if you have any questions, concerns, or to provide updated information.
Sincerely,
Q
Curtis Stoehr
Field Services Lead
59

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