20250602Comment_1.pdf

The following comment was submitted via PUCWeb:
Name: Romney Duffey
Submission Time: Jun 22025 2:17PM
Email: [e-mail]
Telephone: [phone]
Address: 2352 East Greenbrier Drive
Idaho Falls, ID 83404
Name of Utility Company: Falls Water
Case ID: FLS-W-24-02
Comment: "Ten Reasons for the PUC to reject and substantially reduce Falls Water Rate
claim to no more than a 6% increase
There follows at least ten sufficient and stand-alone Reasons for the PUC to require
submission revision, rate increase rejection and massive reduction. Falls Water Exhibits,
Testimony and financial analysis includes misleading statements, statistical errors,
omissions and inaccuracies:
1) Increase is not justified by the submission and the public claims of adequate
resources. It is is clearly extortion of captive customers
2) Potential customer bill increase is much higher than the"average 25%" disclosed
due to manipulation of base allowances and block or tiered rates
3) Decrease in base usage`allowance'of 2000 gallons is arbitrary and actual average
bill change impacts/increase is 40% (see Rowell Exhibit and PUC)
4) Allocated `Shared services'of 6.1% of corporate costs are inequitable and crippling.
They are effectively extortion by the corporate owners NWN and should be no more than
1%, being the Falls Water overall corporate business fraction and risk. All corporate gas
services should also be excluded (Rowell Exhibit) and others disallowed
5) The claimed rate case capital major drivers from spending circa $4M remain a
relatively small part of the Total Rate Base of$16M and is misleading.These costs do not
justify the rate increase (see PUC Workshop)
6) Increases in CAPM, ROE etc. are based on inapplicable comparables and proxy
companies and the analysis should be rejected as they are at least 100 times larger in
revenues and customer base than Falls Water. They are not comparable at all and the
derived average and range are therefore totally inapplicable
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7) Statistical analysis of the claimed risk and financial`comparables'submitted by
Falls Water to determine some "average return" is fundamentally not correct.The standard
error and 95% confidence bounds are not derived or given and full analysis reduces the
minimum ROE significantly to be a minimum allowable rate increase of no more than 6%
8) Relevant data for the parent corporations and owners of Falls Water are not
disclosed, while the few publically available records show similar large rate increase
tactics imposed on their other subsidiaries in other locales and states
9) Expansion of the service territory is planned but in reality is really at the expense of
current customers via artificially low connection charges of only 1 to 3 years of bills (see
Bruce Testimony p12). Clearly new infrastructure and connections should be entirely self-
funded by new customers and new water rights obtained, amortized and fully repaid on a
per connection/meter basis.
10) The Natural Holdings business and risk position is clear: "Our corporate profile is
strong and our financial backing is steady"(stated at
https://www.nwnaturaLwater.com/nw-natural-holdings February, 2025)which comforting
public assurance is totally absent from the public Submission and Testimony. That alone
should be sufficient grounds for PUC rejecting the requested increase.
Further details are contained in previously submitted comments and also available on
request.
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