20250527Comments_2.pdf

The following comment was submitted via PUCWeb:
Name: Romney Duffey
Submission Time: May 26 2025 12:45PM
Email: duffeyrb(@gmaiLcom
Telephone: [phone]
Address: 2352 East Greenbrier Drive
Idaho Falls , ID 83404
Name of Utility Company: Falls Water
Case ID: FLS-W-24-02
Comment: "Additional comments and questions on Falls Water submission and PUC
actions on Rate Increase and on Consolidation
The major action for the PUC is to refuse the proposed large rate increases and assess a
more realistic minimum and reduce the impact on the captive customers.
1. Consolidation is a minor and easily accommodated by Falls Water
Rowell p 7"The Company proposes to consolidate its tariffs into a single rate design for all
customers. Currently, the vast majority of customers are served under a single tariff with a
much smaller number (the Morningview customers) served under a different tariff....The
Larger customer base attained through rate consolidation also mitigates rate volatility for
the respective, smaller systems."
This Rowell table (page3) shows the consolidation proposed is clearly for only 2% of the
customer base of 6,833.The Proposed 19 to 56% Morningview reduction (138 meters)
represents a tiny 0.3 tol% average decrease ($11,977 to $35,931 for 2024) in Falls Water
revenue and can easily be absorbed by the company.
Adjusting Morningview rates is therefore a miniscule part of the unsupported overall major
rate increase request of over 25% (= $902,493 increase over 2024 revenue). The claimed
`volatility' is negligible, so`Consolidation' is therefore a minor distraction from the main
issue of the proposed total customer-wide increase of a massive 25 to 44%.
2. The requested rate increases numbers and percentages are notjustified in or by the
public submittal and should be revised downwards by the PUC
This analysis of the submitted data, errors and revision was sent in prior comments to the
PUC dated March 7, 2025, which are not readilyvisible at the PUC public comment Case
website.
The extent of the requested increase and major impact on captive customers is well
illustrated by determining the average proposed increase over all 6,833 meters/customer
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which data are not given in the Falls Water submission. The average annual customer bills
(ACB) and minimum rate increases should be calculated by the PUC. Excluding any
additional and controversial`peak rates'or tiered usage charge impacts we find:
• For 2024, ACB is $3,593,153/6833 meters = $525.85 per annum per meter
• For the excessive Falls Water(2025+) request, ACB would become $4,494,646/6833
_$657.93 per annum per meter
• For the independent estimate of c5to 6% minimum rate increase derived in previous
comments, the ACB is approximately$ 3,772,810/6833= $552.14 per annum per meter, or
$563.18 including Morningview consolidation
Therefore, the yearly requested ACB increase for the 6,695 meters is about$100 per year
and should be reduced by the PUC to no more than $27 per year(=$552-525 per annum),
including any impact of the Morningview consolidation.
This suggestion and correction should be acted on by the PUC.
3. Key questions for the PUC: this Case has been on-going for many months and is a Sword
of Damocles for customers while many real questions remain
Have Falls Water revised their PUC submission or corrected it at all, and confirmed "we
have the capital, technical and regulatory resources to support our rapidly expanding
service territory"(see https://www.nwnaturalwater.com/our-systems)which also nullifies
all the grounds for the proposed increase?
Have Falls Water admitted to beingjust a negligible fraction (c1%)of total corporate risk
and not having valid comparables for their ROE and rate proposals, and has the PUC
confirmed that fact and/or confirmed that risk?
Has Falls Water parent companies and owners (NWN and Natural Water) released their
financial, expenses and other relevant subsidiary company data for review?
Has the PUC examined these data and revised the Falls Water shared allocation and hence
the submission downwards? If not, why not?
Has the PUC re-analyzed the data to determine the minimum permissible/possible rate
increase based on reviewing and revising the excessive claimed expenses?
What is the PUC's estimate of the minimum justified rate increase compared to the
independent estimate of 5 to 6% and how was it derived?
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Does the PUC agree that based on the submission the average minimum bill for Falls Water
customers should be circa $563 per annum or derived any alternative estimate?
Will the PUC require that costs and charges for all future and/or new connections, territory,
rights and infrastructure by Falls Water be billed to and born entirely by the new
customers/meters, and any such expansion not funded by existing customers or their rate
affected?
Will these matters be discussed and open for discussion at the proposed PUC Workshop or
any other venue?
When will there be live hearings by the PUC in Idaho Falls, being the affected area with all
the concerned ratepayers reside? If not, why not? "
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The following comment was submitted via PUCWeb:
Name: PATRICK HOLM
Submission Time: May 27 2025 10:13AM
Email: [e-mail]
Telephone: [phone]
Address: 4081 John Adams Pkwy
Ammon, ID 83406
Name of Utility Company: FALLS WATER
Case ID: FLS-W-24-02
Comment: "This rate increase is excessive, and a duplicate of one that occurred very
recently. This name-it-and-claim-it mentality for"cost increases" is rampant in this state
and country. If only the average person could give themselves pay increases to keep up
with it all, we would be less harmed. I am a father of 4 and the sole support for my family
and my income is greatly limited.The local cost of living increases in the past 5 years has
FAR exceeded the pay increases I've gotten, and we are a lot worse off now than we were
then. The proposed 27 to 44 percent increase in our residential water bill is ridiculous and
it's a monopoly. There's no true say in it and nowhere else to get water to serve our area.
We also are required to keep our lawn green due to our property lease agreement and city
requirements.
Please consider struggling families and deny or greatly reduce this residential water bill
increase!"
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