20121004Rebuttal.pdf

COUNTRY CLUB HILLS UTILITIES COMPANY REBUTAL R :-. C, : •
CASE NO. CCH-W-12-01 2011 2. OCT - API 9 13
The fact that Country Club Hills Utilities did not request the establishment of a fund to pay for tern F.UbL.
deficiencies in its original application does not deter from the fact that the Company is indfrehetOf .'
system improvements. Moreover, the request for this type of a fund was made early enough in the Rate
Increase process that there has been sufficient time for the IPUC to consider the request given the
process has been going on for over six months.
It must be pointed out again that the establishment of this type of fund is mandated by the IDAPA
58.01.08 - Idaho Rules for Public Drinking Water System. The rule reads as follows:
"Demonstration of revenue sufficiency, that includes but is not limited to billing and collection
procedures, a proposed rate structure which is affordable and ensures availability of operating
funds, revenues for depreciation and reserves, and the ability to accrue a capital replacement
fund."
When designing new private water systems, the designer must provide DEQ a Preliminary Operating
Budget demonstrating the revenue sufficiency to support a Capital Replacement Fund before they will
grant approval.
That being said, Country Club Hills Utilities is in immediate need of the following improvements:
$23,000.00 1. Credit Card Debt Repayment:
a.Pump Failures
b.Service Line Repairs
c.Replacing Customer Landscaping
d.Street Repair
2. Replace 14 broken water meters at $700 each
3. Install previously purchased SCADA Equipment for
Automatic Control of Water System
4. Construct Pump House at Well No. 2 to house pump controls
S. Replace water meters at both wells at $3,000 each
6. Repair or replace sand separator on Well No. 1
TOTAL
$9,800.00
$5,000.00
$7,500.00
$6,000.00
$5.000.00
$56,300.00
The above costs are estimates only, but it brings to light the urgent need to create a Capital
Replacement Fund for the Company and in our opinion, the IPUC Staff recommended rate increase does
not go far enough.
Respectfull submitted,
Je Freiberg
Cc: Mike Groth