20250310Comments_1.pdf

The following comment was submitted via PUCWeb:
Name: Michael Herron
Submission Time: Mar 7 2025 5:31 PM
Email: [e-mail]
Telephone: [phone]
Address: 67 Waterdance Way
Sandpoint, ID 83864
Name of Utility Company: TIC UTILITIES, LLC
Case ID: GNR-W-24-01
Comment: "FORMAL REBUTTAL TO TIC UTILITIES, LLC PROPOSED RATE INCREASE
**RE: Case No. GN R-W-24-01**
**SUBMITTED TO: Idaho Public Utilities Commission**
INTRODUCTION
I am writing to formally oppose the rate increase application submitted by TIC Utilities, LLC
("the Company") in Case No. GNR-W-24-01. The Company's proposal to increase water
service rates by 333%for finished homes is excessive, unjustified, and inconsistent with
Idaho's statutory requirements for"just and reasonable" utility rates.
LEGAL BASIS FOR OPPOSITION
The proposed rate increase directly contravenes Idaho Code § 61-301, which explicitly
requires that:
> "All charges made, demanded or received by any public utility for any product or
commodity furnished, or to be furnished, or for any service rendered, or to be rendered,
shall be just and reasonable:'
Furthermore, Idaho Code § 61-625 places the burden of proof squarely on the utility to
demonstrate that proposed rates are just and reasonable. Based on the information
provided,TIC Utilities has failed to meet this burden for the following reasons:

GROUNDS FOR OPPOSITION
1. The Proposed Increase is Unprecedented and Disproportionate
A 333% increase is extraordinarily excessive by any reasonable standard. Such an increase
would impose sudden, severe financial hardship on customers, many of whom are on fixed
incomes or have budgeted based on established utility costs.
2. Inadequate Justification Provided
The notification vaguely references "increased operating costs and necessary investments"
without providing:
- Specific breakdown of these costs
- Evidence that all investments were necessary and prudently incurred
- Demonstration that alternatives to such a dramatic rate increase were fully explored
- Evidence that operational efficiencies were maximized before seeking additional revenue
3. Discriminatory Rate Structure
The proposal unfairly targets finished homes with a 333% increase while imposing no
increase (0%) on developed lots.This discriminatory structure appears to violate the
principle of equitable rate design, where costs should be allocated proportionally among
customer classes based on their service requirements and usage patterns.
4. Violation of"Gradualism" Principle
IPUC precedent typically favors phased implementation of necessary rate increases to
mitigate customer impact. A one-time 333% increase violates this principle of gradualism,
which is a standard regulatory practice for managing significant rate adjustments.
5. Excessive Rate of Return
The application mentions providing"a reasonable rate of return on the Company's
investment" but fails to specify the proposed rate of return or demonstrate that it is
consistent with returns allowed for similarly situated utilities in Idaho.
REQUEST FOR COMMISSION ACTION

In accordance with Idaho Code § 61-502, which grants the IPUC authority to determine just
and reasonable rates, I respectfully request that the Commission:
1. Suspend the proposed rates forth e full statutory period (up to 7 months) under Idaho
Code § 61-623 to conduct a thorough investigation
2. Require TIC Utilities to provide detailed justification for each component of the proposed
increase
3. Consider rejecting the application outright or significantly modifying the requested
increase
4. If any increase is deemed necessary, implement a phased approach over multiple years
to minimize customer impact
5. Ensure any approved rate design equitably distributes costs across all customer classes
CONCLUSION
While I recognize that utilities must remain financially viable to provide reliable service, rate
increases must be reasonable,justified, and implemented with consideration for customer
impact. The proposed 333% increase fails to meet these standards and should be rejected
or substantially modified by the Commission.
I respectfully request to be notified of any hearings or public comment opportunities
related to this case.
Sincerely,
Michael Herron
67 Waterdance Way
Sandpoint, ID 83864
March 7, 2025
*References:*
- Idaho Code § 61-301 (Just and reasonable charges)
- Idaho Code § 61-502 (Commission authority to determine rates)
- Idaho Code § 61-622 (Notice of intent to increase rates)
- Idaho Code § 61-623 (Procedure for rate change applications)
- Idaho Code § 61-625 (Burden of proof on utility)"
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