Coldstream Corner: Fair Play a Rarity at GVWater

They count on GVAC directors to be fooled!

The lack of fair play at Greater Vernon Water is endemic to the Regional District of North Okanagan, and appears to serve several purposes:

it masks--indeed hides--GVW's lack of action on illegal water usage over many years, while placing blame where it does not belong;
it fools GVAC directors with spurious data to approve recommendations that continue to promote a lack of procedural fairness via flawed policy.

How interested are Directors in seeing through manipulated information from GVW?
How concerned are Directors that they've become pawns in the GVW bureaucracy?

Rather than rehashing previous stories (whose links are provided below), today's comments are based on the 17-page "Draft Private Fire Hydrant Policy" presented in the February 5, 2015 agenda for the Greater Vernon Advisory Committee directors to peruse.

But first my submission to GVW back in September, 2014; data which is entirely supportable!

"Here are the facts:

- Fire departments will use the nearest hydrant to fight a fire. Both private and public hydrant locations are marked on fire department maps for ease of locating.

- Each director’s community is charged $133 annually for each public hydrant’s annual servicing. Private hydrants are taxed $560—up from $470 last year—for no servicing.

- Neither private—nor public—hydrants are metered. All were inspected by water officials prior to holes/pipes being closed, then tested.

- Engineering states they don’t know how much water private hydrants consume. There is NO consumption! None! Nor is there consumption on public hydrants. Presumably they also don’t leak.

- Whether it’s 17 (first reported by McTaggart)—or 123—private hydrants is immaterial. All serve their communities – not just owners’ residences. Proof is that a neighbour 60 m from my private hydrant gets a discount from his fire insurance company—just as I do—for being within 300 metres of a hydrant. Insurance companies don’t care whether it’s private or public, just that it’s a fire hydrant.

- As further proof that my hydrant is infrastructure is the fact that the hydrants west and east of me are 2300 feet (7/10 km) apart. Both were installed later than mine, proving that officials considered mine as infrastructure when siting the west public hydrant.

I respectfully ask that you reconsider the current lack of procedural fairness in the tax rates imposed on private fire hydrants. Thank you!"

When reading the 17 page report from GVW's engineers on February 5, 2015, recommended questions that Directors should have asked are in bold italics:

Presumably the public (including private hydrant owners) pay for public fire hydrants' "infrastructure to the hydrant" via taxes, or perhaps the Base Rate on their water bills. If so, then private hydrant owners--by being charged $560 versus the public hydrant costs of $133--are taxed twice, as private hydrant owners are also residents that are taxed for public hydrants. Why would it cost more for infrastructure piping (that GVW/NOWA installed with their crew in 2001) to an unmetered private hydrant than it costs to provide infrastructure pipes to an unmetered public hydrant? Yet that's what GVW infers. (The private owner paid all construction costs beyond the fenceline on private property).
GVW states its operators have noted illegal use (parking lot and driveway rinsing, etc.) of private hydrants. Were fines levied? If not, why not? Was "communication" sent to the offender(s)? What has GVW done with the "reports" of illegal use...over how many years?
GVW continually refers to water consumption on private fire hydrants. There is NO water consumption! The Highlands Golf private fire hydrant was tested and approved by a NOWA official during construction/development permit, and it has never been used (fortunately) to fight a fire. It has never issued a drop of water since 2001, so why talk about water usage because the hydrant is unmetered? There is no water usage on unmetered public hydrants either! Note that it was optional in 2001 whether to meter the private fire hydrant.
On page 2 of GVW's February 3, 2015 "summary", they state "any hydrant maintenance and/or specific conditions required are between the hydrant owner and the insurance company and does not involve GVW". So why (on page 5 of 9) list six security devices that staff could require to "deter water theft" and/or contamination? Is GVW abdicating recourse against the insurance company if water theft and/or contamination occurs? GVW is either involved or it isn't. But not both. Engineering states they take "no responsibility" on annual maintenance being performed, despite a permit being required. And they're apparently buying testing equipment to rent out.
"Required to pay a fee that covers rental of backflow protection and meter box" for annual testing. What will the permit fee be? What will the rental fee be? Or will it be another "exorbitant" rate (quoting last year's comment by Juliette Cunningham, chair of GVAC).
A review of other jurisdictions..."some limit (private) hydrant access to only fire fighting use to ensure a hydrant is in good working order in the event of an emergency". That was the way it was in 2001...the Highlands Golf private fire hydrant was for fire protection only. GVW should move the goalposts only for new private hydrant construction, not pre-existing (grandfathered) owners who complied with construction rules of the day. Directors should deny GVW's intent to seek a policy change to install meters at the property line for existing hydrants. Temporary backflow prevention and a meter box only required during testing under the annual Permit, with supervision by a GVW operator. Impose large fines to deter illegal use! Don't just complain about it!
GVW allows contractors to use public hydrants, and GVW has one truck fill station. GVW allows street cleaning and other activities provided by a municipality/city. Is this where the unknown water usage (~40 per cent) occurs? Quit implying/infering that it's private fire hydrant owners!
"...non regulated use of private hydrants"..."contamination risk of water hauling or street cleaning trucks connecting to hydrants may be used for other purposes and are not likely cleaned before connection." How many years has GVW known this? Water hauling or street cleaning trucks do not connect to private hydrants!
...risk to public safety from potential unreported damage to the hydrant...."when damage occurs it often goes unreported". Since GVW only allows their operators to operate GVW equipment, is GVW saying that their operators do not report hydrant damage?
"We are not recommending at this time that increased monitoring of hydrant use is required. However if increased staff time is required, rates would need to be adjusted to cover those costs to the utility." Private fire hydrant owners already pay $560 for no servicing (versus public hydrants $133, which are serviced).
GVW refers to illegal use in the BX that caused 4 frozen hydrants in 2013 and one case where a hydrant was not available during a fire. So other than playing the victim, what has GVW done about illegal use? Other than to state "if all non-fire fighting use was to be prohibited by GVW, an increase in enforcement activity would be required". (An incredulous statement!)
GVW often recommends that condo owners ... system flush for water quality with private unmetered hydrants, and potentially other uses." Huh?
"other jurisdictions often require metering at the property line before private hydrants..." But there are likely many more jurisdictions that do not require metering at the property line before private hydrants! Wonder how many jurisdictions GVW did not include because it doesn't suit their purposes!
"Annual maintenance is not tracked by GVW or the local Fire Response Service." Neither is illegal use, apparently.
"Possible enforcement consequences of denying fire service coverage". GVW is concerned about liability/responsibility yet they make THAT statement?
Private hydrant tracking system..."yes, use the current GIS system that tracks public hydrants. But since GVW wants no responsibility, put the tracking job onto area Building Inspectors, who have the National Fire Protection requirements at their fingertips anyway! Presto, no extra work/labour for GVW.
On 5. Rates, page 8 of 9, add the $133 public hydrant rate charged to communities. "In the interest of transparency". It took a year to discover the $133 amount because GVW chose to remove the listing from their rate sheets...which now hides the prejudicial amount charged to private fire hydrant owners (versus public hydrants).
"A 40 year lifespan would require approx $250 annually for the repair/replacement cost on a 150mm main. Additional costs to support flow levels must also be recovered, i.e. approx. $400 a year. So the $133 cost to municipalities per public hydrant is at a huge discount and cannot be sustained? Is GVW admitting that private fire hydrant owners are subsidizing public hydrants? (double-dipping taxation?) Misleading statement: "Staff note that the cost to supply water to an unmetered fire main is not known at this time." But they presumably know what it costs to supply water to an unmetered public fire hydrant? "They would be the same, especially if the private fire hydrants aren't using ANY water...not a drop of water!"
Page 9 of 9: "...appropriate rates can be determined to reflect the requirements for staff and infrastructure resources to support the operation of private hydrants." "Rates, including for rental of annual testing equipment and the permit, must form part of the recommendation before Directors will consider it." Not afterwards.
Insurance Rates: Yet another misleading statement by GVW. Insurance benefits are generally 50% if your house is within 300 metres of a fire hydrant (private or public). Something GVW will NOT admit is that your neighbour ~60 or so metres distant WILL ALSO RECEIVE A 50% DISCOUNT ON HIS FIRE INSURANCE PREMIUM. Because no fire department in their right mind will use a public hydrant 300 metres away from your neighbour's burning house when they can use your private hydrant to fight a fire on his property which is only 60 metres away!!!! And so it should be. But GVW believes only the hydrant owner gets a discount (socialism rears its ugly head). Misleading statement: "majority of private fire hydrants are set back a considerable distance from the road and to fight a fire on an adjacent property a public fire hydrant would typically be used." Total bullshit, from both GVW and the Coldstream bureaucrat in his report last year!
Page 2 of 3, June 18, 2014 report: "Unmetered fee where metering is possible". "Why not make those the fines for illegal use?" That'd sure solve GVW's problem of not being able to figure out who is using water illegally from fire hydrants.
Same report, next paragraph as #21 immediately above: "The rate for an unmetered fire main is significantly less than unmetered residential properties for similar sized service connections." Misleading statement! There are NO residential properties with a six-inch fire main to a private fire hydrant!
Page 2 of 3, October 2, 2014: "Metering (by jurisdictions). Hydrants are placed after the property's water meter to account for any water consumption. Also requires backflow prevention for private hydrants." "This would be for new construction! GVW is implying that historical connections are treated the same way, which is false." Sample Fees: Comparison among jurisdictions is incomplete as no annual tax figures are provided for private fire hydrants.

Lastly (whew!) GVW's February 5th, 2015, document entitled: "Greater Vernon Water Private Hydrant Policy": "This must be changed! Should state: Greater Vernon Water Public and Private Hydrant Policy."

Otherwise, GVW is still discriminating between the two. Both public and private fire hydrants are infrastructure that the community relies upon.

"Directors routinely receive 80 to 100 page Agendas," advises Kia, "so they should be forgiven when they fall into the GVW bureaucracy trap."

Greater Vernon Water counts on it.

Links:

History 2013 backgrounder here, with this summing up my "lack of procedural fairness" complaint.
As an example, see Engineer McTaggart's comment here. First he said there were 17 private fire hydrants. Scarce weeks later, he said there were 123 private fire hydrants.

84-page Agenda for February 5, 2015 meeting, Recommendation #7 on Private Fire Hydrants.
17 page report on private fire hydrants begins here (page 38 of 84).