20250804Comment_1.pdf

3uly 22, 2025 11269 Augusta Drive
Idaho Falls, ID 83404
Commissioner John R. Hammond, 3r.
P.O. Box 83720
Suite 201-A
Boise, ID 83720-0074
RE: PUC Case #FLS-@-24-02
Dear Commissioner Hammond,
I am writing to express my opposition to the proposed rate increase by Fails Water's
parent company. I have submitted previous letters regarding the fiduciary responsibility
that the PUC has to advocate for the ratepayer rather than the utility. Frankly, I believe
that a forensic audit of audit of Falls Water & its parent company would be in order to
gather facts and to create a "real world"view from the ratepayer's point of view. I reside
at 11269 Augusta Drive, ID 83404. The six households in our cul-de-sac have expressed
concern for the lack of water pressure every since Falls Water assumed operational
oversight. We literally have one home on the Idaho Falls Golf Course that is just weeds
& dead plants because the homeowner does not have sufficient pressure to operate a
sprinkler system. The PUC granted an exclusive franchise to Falls Water to operate &
ensure adequate service to its customer despite increases in rates. Water is a necessity,
ever increasing profits through rate increases affects & hurts the most vulnerable who
live on fixed incomes. There are considerable fixed income residents in the service area
who will be harmed by the proposed draconian increases. Frankly, if the utility seeks to
increase profits it can be accomplished through increased productivity, utilization
available AI tools that minimize or reduce the human labor factor.
I am attaching a copy of the analysis prepared by Romney B. Duffey, who lives in my
neighborhood. His thorough analysis should provide the Commission justification &
reasoning for disallowing the proposed rate increase that has been submitted by Falls
Water's parent company. It is pathetic that an Oregon-based company, who's sole stated
motive is every increasing profits. I have said before & I will say it again, utilities are
granted a unique position in operating within their territory without any competition.
Think of that! No competition! Competition drives innovation & drives prices down. In
theory, I guess all of the households in the service area could decide to drill their own
wells!
\pectfully.
I
Da 'd R. A Berson

I , ROMNEY B DUFFEY OF IDAHO FALLS, respectfully ask Idaho's PUC acting on
behalf of the customers in this Case to reject and substantially reduce Falls Water
Rate claim based on their own submission and the available data.
A) THE BASIS FOR MY TESTI MONY AND FINDINGS: I THANK THE PUC FOR LETTING
ME TESTIFY AND APPEAL DIRECTLY TO YOU. I AM A VERY CONCERNED CUSTOMER
AND WORRIED A S WATER ACCESS, COST AND SUPPLY IS A MAJOR NEED AND VITAL
ISSUE HERE IN IDAHO. TODAY IS A GREAT DAY FOR DEMOCRACY AND FOR IDAHO
CUSTOMERS - AND A HUGE OPPORTUNTY FOR THE PUC TO DO THE RIGHT THING TO
PROTECT BOTH OF THEM.
ALTHOUGH LOCALLY WE ARE BLESSED WITH AMPLE SUPPLY FROM OUR MOUNTAINS,
R IVERS AND GROUNDWATER A NON - LOCAL CORPORATE ORGANIZATION NOW HAS
THE MONOPOLY - WHICH IS WHY I ASKED THE PUC NOT ONLY TO INTERVENE BUT
TO DRASTICALLY LOWER THE REQUEST BASED ON THE ACTUAL LOCAL SITUATION.
FALLS WA TER IS A 1% OR LESS PROPORTION OF THE OREGON NWN HOLDING
COMPANY'S $1.2 B ILLION AND NWN WATER $290 M ILLION INCOME AND CASH
FLOWSTREAMS. I WAS PERSONALLY AMAZED THEREFORE TO SEE THE SIZE OF THIS
LOCAL RATE REQUEST. I FELT THAT JUST MY COMPLAINING WAS NOT SUFFICIENT -
OTHER CUSTOMERS HAVE DONE THAT VERY EXTENSIVELY (SEE WEBSITE) AND HAVE
ELOQUENTLY RAISED THEIR MAJOR SOCIETAL AND PERSONAL ECONOMIC ISSUES
AND QUESTIONS .
I EXAMINED THE SUBMISSION IN GREAT DETAIL AND FOUND ERRORS, OMISSIONS
AND KEY MISLEADING STATEMENTS WITH SIMPLE USE OF A COMPUTER AND THE
INTERNET. THEREFORE, I ASKED THE PUC BOTH TO EXAMINE THE CLAIMS AND
REJECT THE SUBMISSION ANALYSES AND TO REDUCE THE REQUESTED INCREASE
AMOU NT TO NO MORE THAN 6%, BASED ON CORRECT STATISTICAL ANALYSIS.
I APPLAUD AND AM PLEASED TO SEE THAT THE PUC STAFF COMMENTS REPOR T
ISSUED ON JULY 3 ADDRESSES MANY OF MY QUESTIONS AND SIGNIFICANTLY
REDUCES THE 24% REQUEST TO 7.93% - QUITE CLOSE TO MY ESTIMATE OF 6% .
IT IS A GOOD START THE STAFF HAVE DONE A THOROUGH REVIEW AND KINDLY
PROVIDED THE DETAILED NUMBERS AND REVISED CALCULATIONS FOR WHICH I AM
MOST GRATEFUL.
AFTER EXAMINATION I FIND THE FOLLOWING ITEMS REMAIN FOR THE PUC TO
ADDRESS AND CORRECT:
1. THE RATE INCREASE PLUS LARGE BASE ALLOWANCE REDUCTION CAUSES
BILLS TO ACTUALLY RISE WITH MAJOR SOCIETAL AND ENVIRONMENTAL
IMPLICATIONS DUE TO OUR LARGE FLUCTUATING SEASONAL USE PATTERN.

2. THE STAFF CALCULATIONS DO NOT INCLUDE THE ACTUAL STANDARD ERROR
FOR INVESTMENT AMOUNTS SO UNCERTAINTY REMAINS DUE TO USING
INAPPLICABLE COMPARABLE DATA AND A VERY SMALL SAMPLE.
3. THE EXCESSIVELY LARGE SHARE (6%) OF CORPORATE EXPENSES LIKE
NATURAL GAS COSTS, SYSTEMS AND SALES DUE TO SOME PRIOR OUT - OF -
STATE AGREEMENT' OR FORMULA SHOULD NOT BE ALLOWED OR APPLIED TO
FALLS WATER.
4. THE LOWER BASE ALLOWANCE AND MUCH HIGHER TIER OR BLOCK 2 RATES
CONFLI CT DIRECTLY WITH ADDING NEW CUSTOMERS AND PROJECTED
CONNECTION GROWTH (ABOUT 5% PER ANNUM) SO ARE INCONSISTENT
WITHTHE CLAIMED GOAL OF CONSERVATION AND OBVIOUSLY ANY AND ALL
NEW WATER RIGHT S NEEDS AND COSTS SHOULD BE FULLY RECOVERED
FROM NEWNOT CURRENT CUSTOMERS.
5. EVERY STATE IS DIFFERENT GEOLOGICALLY AND GEOGRAPHICALLY AND WE
ALLOW CORPORATIONS THE BENEFIT OF OPERATING AND MAKING MONEY
HERE BUT AT THE SAME TIME REQUIRE AND EXPECT BOTH ACCOUNTABILITY
AND SENSIT IVITY TO LOCAL NEEDS AND CULTURAL HE RITAGE WHEN
MANAGING OUR PRECIOUS RESOURCES.
THE NW NATURAL HOLDINGS CORPORATE POSITION IS CLEAR: OUR CORPORATE
PROFILE IS STRONG AND OUR FINANCIAL BACKING IS STEADY" (STATED AT
HTTP S://WWW.NWNATURALWATER.COM/NW - NATURAL - HOLDINGS FEBRUARY,
2025), THIS COMFORTING PUBLIC ASSURANCE IS TOTALLY ABSENT FROM THE
PUBLIC SUBMISSION AND TESTIMONY AND ALONE IS SUFFICIENT GROUNDS FOR
REJECTING THE REQUESTED INCREASE.
TODAY I AGAIN ASK THE PUC AND ITS STAFF TO NOT ALLOW THE DEVASTATING
REDUCTIONS TO THE BLOCK ALLOWANCES AND LARGE INCREASES IN BILLS DUE TO
THEIR POTENTIAL ADVERSE LOCAL, SOCIETAL, ECONOMIC AND ENVIRONMENTAL.
IMPACTS AND TO NOT ALLOW THESE IN THE FUTURE. DETAILS ARE IMPORTANT —
SO LET US EXAMINE SOME OF THEM.
1. FIRSTLY THE SUBMISSION RAISES KEY QUESTIONS
a. THE FALLS WATER / NWN PUBLIC SUBMISSION APPE A RS TO FOLLOW A
STANDARD STRATEGY, BOTH IN FORMAT AND METHODOLOGY FOR THE
UTILITY BUSINESS. ASK FOR A LOT, COMPLAIN ABOUT IN A DEQUUATE
REVENUE AND RETURN (ROE ETC), AND HOPE TO GET SOMETHING ,
WHILE ANSWER ING ROUTINE QUESTIONS WITH LENGTHY BUT
UNFORTUNATELY INCORRRECT AND INCOMPLETE JUSTIFICATIONS.
b. FALLS WATER'S OPERATIONS MANAGER EVEN PUBLICALLY STATED IN
FEBUARY: I'M MORE CONFIDENT THAN EVER THAT WE HAVE THE
CAPITAL, TECHNICAL AND REGULATORY RESOURCES TO SUPPORT OUR
RAPIDLY EXPANDING SERVICE TERRITORY." (SEE

https://www..nwnaturalwater.comjour-systems). THIS WAS AFTER THE
SUBMISSION ASKING FOR LARGE INCREASES. SO THE SUBMISSION WAS
CLEARLY BIASS ED AND CONTAINS TECHNICAL ERRORS AND ITSELF.
c. RAISED MANY QUESTIONS:
i. DESPITE SO MUCH CLAIMED FINANCIAL PAIN AND WITHOUT
INCENTIVE S TO BE EFFICIENT THE CORPORATE OWNERS AND
COMPANY HAVE NOT EFFECTIVELY MANAGED THE SITUATION, SO
WHY ARE THEY ALSO CLAIMING PUBLICALLY (SEE THEIR WEBSITES)
TO HAVE ADEQUATE RESOURCES AND FINANCIAL STRENGTH?
ii. WHY ARE UNDERLYING OREGON PARENT C 0 R P 0 R A TE DATA
AND DETAILS (FORNWNW AND NW HOLDINGS) STILL NOT AVAI L A
B LE FOR TRANSPARENT REVIEW OR DISCLOSED IN THE
SUBMISSION AND PUC REPORT?
iii. WHY ARE THERE STILL GROWING OVERHEAD COSTS AND BUSINESS
GOALS OF A BIG (5% PER YEAR) SERVICE REGION EXPANSION
WHICH CONFLICT S DIRECTLYWITH CURRENT SUPPLY ISSUES,
OVERPRODUCTION FEES AND KNOWN WATER RIGHTS
INADEQUACIES?
iv. L GIVEN FALLS WATER IS NO MORE THAN 1 % OF THE TOTAL
CORPORATE BUSINESS AND RISK WHY ARE THEY JUSTIFIED IN
CLAIMING 6% AND MORE IN ALLOCATED' EXPENSES INCLUDING M E
M BERSHIPS, TRAVEL, TOTALLY INAPPLICABLE GAS AND OTHER
BUSINESS OVERHEAD COSTS BASED ONLY ON SOME EXISTING
(MASACHUSETTS METHOD) AGREEMENT APPARENTLY WITH IDAHO
AND OTHER PUCS?
v. IT WAS NWN W AND NW HOLDINGS SOLE DECISION TO AC QUIRE
THE IDAHO COMPANIES SO WHY ARE THEY NOW CLAIMING BIG
RISKS AND INADEQUATE RETURNS? (ANYONE ELSE WOULD HAVE
BEEN FIRED OR CASTIGATED FOR DOING THIS!!).
vi. WHY IS THE MULTISTATE OREGON CORPORATE BUSINESS MO DEL
AND LOCAL IDAHO PLAN NOT PUBLICALLY AVAILABLE BUT CLEARLY
BASED ON EXPANSION BY ACQUSITION AND THEN ASKING FOR
MASSIVE RATE INCREASES CASE - BY - CASE IN STATE - BY - STATE?
vii. THE COMPARABLE COMPANIES SELECTED FOR ANALYSIS TO JUSTIFY
INCREASEARE ADMITTED TO BE NOT COMPARABLE - SOME ARE
OVER 100 TIMES LARGER. IN REVENUE THAN TINY FALLS WATER AT
$3M - SO WHY WERE THEY EVEN INCLUDED AND WHY WERE THE
ACTUAL SUBMITTED STATISTICAL ANALYSES ON FINANCIAL
RETURNS INCOMPLETE AND THE CLAIMS SO MISLEADING?
(MANAGING A SMALL SUBSIDIARY IS NOT AT ALL LIKE OPERATING A
BIG CORPORATION).
viii. THE TIE RED BLOCK RATES IN TH E PUC REPORT LOOK TO BE A
NICE "CONSERVATION' IDEA ON THE SURFACE BUT HIDE A SERIOUS
ISSUE - AS YOU CAN TELL TODAY THE IDAHO WEATHER IS TOTALLY

SEASONAL WITH HUGE PEAK SUMMER DEMAND PERHAPS 20 TIMES
OR MORE HIGHER THAN WINTER. WE IN IDAHO FALLS LIVE IN HIGH
DESERT AND THE DATA SHOWS THIS HUGE PEAK USAGE NOT ONLY
EXCEEDING THE BASE ALLOWANCE BUT IS NOT NORMALLY
DISTRIBUTED OR POSSIBLE TO REDUCE FURTHER SO WHY IS THIS
NOT CONSIDERED? (SEE GRAPH).
ix. SUMMER WATERI NG HERE IN IDAHO FALLS IS NOT A CHOICE SO
THERE IS LARGE MAJOR ENVIRONMENTAL IMPACTS FROM FORCING
COST— DRIVEN REDUCTIONS. ANY INABILITY TO PAY MORE, BIG
SPRINKLER CHANGE COSTS OR JUST NOT ABLE TO AFFORD TO
FULLY WATER ARE NOT DISCUSSED. DESPITEOUR BEST EFFORTS
SOME OF OUR MODEST GARDENS, PRECIOUS FRUITS, FLOWERS AND
LANDSCAPES WILL JUST DIE OR JUST REVERT TO DESERT -
CAUSING HUGE DAMAGE TO NEIGHBORHOODS AND LANDSCAPING.
THIS SIGNIFICANTLY INCREASES THE FIRE HAZARDS AND ENTAILS
POTENTIALLY HUGE COSTS FROM INEVITABLY DYING TREES,
SHRUBS AND GROUNDCOVER, PLUS PRUDENT FIRE PREVENTION
REQUIREMENTS AND COSTS SO WHY ARE THESEREAL CONCERNS
NOT ADDRESSED?
x. IN IDAHO WE NEED MANAGED GROWTH ESPE CIALLY FOR
OPTIMIZING OURWATER SUPPLY AND DEMAND GIVEN THE
ADMITTED PRESENT FALLS WATERCOMMODITY SUPPLY SHORTAGE
SO WHY ENDORSE THE FALLS WATER 5%CUSTOMER AND REVENUE
GROWTH TARGET, ALLOW NEW CONNECTIONS ATEXISTING COSTS,
AND WHY HAVE ANY APPAR ENT CUSTOMER GROWTH GOALS FOR
THE COMPANY AT ALL?
xi. NONE OF THIS DISCUSSED SO SERIOUSLY WHY AND HOW COULD
THIS CLAIM EVEN BE RE QUESTED LET ALONE ALLOWED?
xii. AND WHY NOW? WATER LOSS' IS STATED TO BE STILL ABOVE 10%
(PUC STAFF REPORT TABLE 4) OR ABOUT A MONTH'S SUPPLY SO
SURELY IT IS BEST TO REDUCE THIS ASAP TO OFFSET ANY BLOCK
ALLOCATION CHANGES AND REDUCE OVERPRODUCTION .FEES. WE
DO AGREE WITH THE STAFF ON ALLOWING THE MINOR
MORNINGVIEW RATE DECREASE - BUT THE VAST MAJORITY OR 98%
OF CUSTOMERS ARE STILL FACED WITH MASSIVE INCREASES THAT
THEY HAVE NO MEANS TO ABSORB.
d. WHAT IS THE MIN I MUM JUSTIFIABLE INCREASE? THE REAL NEED IS
TO ESTABLISH WHAT MIN I MUM INCREASE SHOULD THE PUC ALLOW
AND WE THE PEOPLE AND THEIR CAPTIVE CUSTOMERS ALLOW? THE
PROBLEMS IN THE SUBMISSION ARE NOT HARD TO FIND BUT NOT EASY
TO CORRECT. A CLEAR EXAMPLE OF EXTORTION AND BIAS IS IN THE
SUBMISSON ITSELF (P29 LINE 1).
e. "THERE IS NO UNIVERSALLY ACCEPTED METHOD FOR DETERMINING AN
APPROPRIATE RISK - BASED AJUSTMENT. THEREFORE, I RECOMMEND

THAT THE IDAHO PUC NOT AUTHORIZE AN ROE IN THE LOWER END OF
THE RANGE OF ROE ESTIMATES PRESENTED HERE."
f. THE PUC STAFF HAS CAREFULLY REDONE THE CALCULATIONS AND
ALREADY FOUND THIS'ADJUSTMMENT' IS NOT APPROPRIATE WE ALL
KNOW THAT AS MARK TWAIN EXPLAINED "THERE ARE LIES, DAMN' LIES
AND STATISTICS" SO HERE WE HAVE ANOTHER FINE EXAMPLE. THE
MAJOR TECHNICAL ISSUE I FOUND IS THE LACK OF A PROPER
STATISTICAL ANAL YSIS - NOT ONLY WERE THE 'COM PARABLES'
FINANCIAL DATA NOT GIVEN IN THE SUBMISSION BUT THE SUBMITTED
ANALYSIS DETERMINES AND USES AVERAGES' WITHOUT STATING THE
TRUE ERROR RANGE OR ANY CONFIDENCE LEVELS. THIS ERROR AND LO
WER LIMIT ESTIMATE IS NOT ROCKET SCIENCE OR COMPLEX AND
OBSCURE STATISTICS - IT IS COMMON PRACTICE AND AVAILABLE IN
TEXTBOOKS THE WELL KNOWN PROVEN WAYS FOR QUANTIFYING THE
MOST LIKELY RANGE ARE CALLED THE '95% CONFIDENCE LEVEL' OR
THE STANDARD ERROR' IN POLITICAL POLLS WITH WHIC H YOU MAY
BE FAMILIAR IT IS OPENLY CALLED "THE MARGIN OF ERROR". THIS
ERROR IS A LWAYS A SERIOUS PROBLEM WHEN POOLING'
INCOMPATIBLE DATA ESPECIALLY HAVING ONLY A VERY SMALL SAMPLE
FROM WILDLY DIFFERENT OPERATIONS - IN THIS CASE FOR SEVEN
COMPANIES 300 OR MORE TIMES LARGER THAN FALLS WATER!! THE
LIKELY CLAIM IS THAT THEY ARE COMPARABLE TO NWN WATER AND
NW HOLDINGS FOR WHOM WE HAVE NO DATA SUBMITTED. BUT
CLEARLY FALLS WATER IS A MINISCULE 1% OF THE CORPORATION AND
I S FISCALLY INSIGNIFICANT AND JUST A SMALL SUBSIDIARY AND
NEGLIGIBLE RISK.
g. CALCULATING A LOWER LIMIT TO DO THIS CALCUATION USING EXCEL I
HAD TO FIND THE NEEDED FINANCIALRETURN AND REVENUE DATA
ONLINE AND CALCULATE D THE RANGE - THIS WAS QUITEA TASK AND
WAS DETAILED IN MY WEBSITE COMMENTS.AS REQUESTED, THE PUC
STAFF HAVE ALSO RE-ANALYZED AND ADDED ANOTHER COMPARABLE'
BUT DO NOT GIVE THE STANDA RD DEVIATION OR ERROR. WE CAN
CALCULATE IT IN A FEW MINUTES USING EXCEL XLS,IF WE INCLUDE
THIS ADDED COMPANY. EVEN IF UNWISELY ACCEPTING THE NWN -
SIZED $300M+ COMPARABLES AS PROVIDING SOME AVERAGE, THE
STATISTICALLY DERIVED MINIMUM FINANCIAL RET URNS AT 95%
CONFIDENCE ARE 5.5% WHEN INCLUDING 'THE MARGIN OF ERROR'
THE TRUE UN CERTAINTY OR TWO STANDARD ERROR RANGE IS LARGE,
AND THIS LOWER LIMIT FOR THE ROE EXPLAI NS WHY IT IS NOT GIVEN
IN THE SUBMISSION. THIS ALSO SHOWS CLEARLY THE REQUEST IS
HEAVILY BIASSED UPWARDS (EUPHAMISTICALLY CALLED THE
REQUIREMENT') BECAUSE THE RANGE IS NOT STATED OR EVEN
DISCUSSED JUST SO ME AVERAGE' BASED ON A SMALL IN APPLICABLE

SAMPLE. EVEN ADDING ON THE 1% CORPORATE RISK THAT FALLS
WATER TRULY REPRESENTS TO ITS OWNERS AND INVESTORS GIVES MY
6% SUGGEST ION WHICH IS 3% LOWER THANTHE PUC STAFF REPORT
PROPOSAL. THE ADDED SAVINGS WOULD BE ABOUT 6/9.7 X $59,223 =
$36,632. WE IN IDAHO FALLS DO NOT WANT TO BE AMONG THE
HIGHEST RATE PAYERS BUT NEARER TO THE MIN I MUM POSSIBLE FAIR
AMOUNT.
h. THERE ARE OTHER INFLATED NUMBERS BEHIND THE NUMBERS FALLS
WATER WHILE ONLY 1% OF NWN I NCOME AND CASH FLOWS IS BEING
ALLOCATED 6.1% OF THE CORPORATE EXPENSES IN CURRED IN
OREGON. IDAHO CUSTOMERS ARE BEING ASKED TO PAY FOR A SHARE
OF EXPENSES OVER WHICH THEY HAVE NO INPUT, CONTROL OR SAY. IF
6% IS AGREED' FOR SOME REASON I ASK THAT THE PUC SHOULD STILL
EXCLUDE THE ACTUAL IRRELEVANT CORPORATE GAS CHARGES ($
1,398, 166 ROWELL EXHIBIT 2H). USING THIS IDAHO FALLS METHOD
GIVES A SHARE REDUCTION OF $86,126, WITH STILL $174,795 BEING
PAID TO THE OREGON CORPORATE ENTITIES BUT REDUCING THE
AMOUNT TO FALLS WATER FAIR SHARE OF 1% GIVES A
MASSIVEREDUCTON OF OUT - 0 F - STATE COSTS OF $218, 610
INSTEAD OF PAYING NWN $260,291 (ATTACEMENT A P2).WE CAN NOT
UNDERST A ND WHY THE ' MASSACHUSETTS METHOD ' SHOULD BE
APPLIEDFAR AWAY IN IDAHO WHERE WATER NEEDS AND USE ARE SO
DIFFERENT.THE PUC STAFF EVEN SAY ON SHARED SERVICES: STAFF
DOES NOT BELIEVE THE BUDGETED AMOUNTS ARE KNOWN OR
MEASURABLE " (P21) SO WHY SHOULD WE PAY ANYTHING? SO IDAHO
PUC AND ITS WATER -ONLY USERS REALLY DO NEED TO CREATE A
NEWAGREEMENT WITH OREGON AND NOT PAY FOR INAPPLICABLE GAS
SERVICE COSTS. ALSO STATED IS "FALLS WATER IS SEEKING TO
RECOVER MORE IN SHARED SERVICES COSTS THAN IT ACTUALLY
INCURRED IN 2024, WITH A 3% INCREASE INCLUDED OVER THE 2024
CHARGES ". THIS IS SIMPLY NOT JUST I FIED IN THE SUBMISSION AND
THE STAFF HAS REDUCED THE AMOUNT BUT ONLY BY $35,903.
i. MAJOR MONTHLY BILL IMPACTS ARISE FROM THE PENALTIES OF
REDUCED FIRST BLOCK BASE ALLOCATION OF 2000 GALLONS AND
INCREASED TIER 2 RATES SUMMER IS REALLY WHEN FALLS WATER
MAKES MOST OF ITS 'INCOME', SO WHAT IS THE INCREASE I N ACTUAL
BILLS?
j. THE STAFF REPORT ATTACHMENTS H AND I ON BILL IMPACTS ARE
EXCELLENT AND HAVE ALL THE USEFUL CALCULATIONS AND I THANK
THEM FOR ALL THIS GOOD WORK. BUT THEY SHOW FOR A'SUMMER
AVERAG E' USER THE PROPOSED AVERAGE ACTUAL BILL INCREASE IS
ABOUT 16%, AND FOR A 'HIGH USER' IS ABOUT 11%. THESE ARE AT
LEAST 25% ABOVE THE 7.9% ASSESSED BY THE STAFF SO ARE TOO
JUST MUCH, ESPECIALLY FOR ANYO NE ON A MONTHLY BUDGET, FIXED

INCOME OR STEADY PAY CHECK SO SHOULD BE SGNIFICANTLY
REDUCED. THE PUC SHOULD REDUCE THIS BLOCK COST INCREASE
BASED ON ECONOMIC AND SOCIETAL GROUNDS.
k. EXISTING SUPPPLY SHORTFALL, NEW HOOK UP CHARGES AND NEW
CUSTOMERS THE STAFF REPORT SAYS THE FALLS WATER SYSTEM
SUPPLY FALLS SHORT EVEN NOW AND 'MAY NOT HAVE ENOUGH
CAPACITY'TO SATISFY THE PROJECTED GROWTH (P5) GIVEN THIS
CURRENT SUPPLY SHORTFALL WHY ADD ANY MORE NEW HOOK UPS AT
ALL? THIS IS A REAL BUT HIDDEN ISSUE. TODAY, PRODUCTION BY
FALLS WATER ALREADY EXCEEDS THEIR WATER RIGHTS AND IT DOES
NOT GET BETTER AS "STAFF BELIEVES THAT THERE IS A HIGH
PROBABILITY WILL INCUR ASSESSMENT FEES DUE TO
OVERPRODUCTION IN THE NEAR FUTURE (P2)
I. THE STAFF ONLY RECOMMENDS UPDATING (P25) BUT THE REAL COSTS
ARE FOR ADDING NEW INFRASTRUTURE AND MORE RIGHTS WHILE
PRESENT HOOK UPS ARE STILL ARTIFICALLY CHEAP AND PRESENT
SUPPLY INADEQUATE THERE SHOULD LIKELY BE A MORITORIUM ON
ANY NEW CONNECTIONS AT LEAST UNTIL ABLE TO FULLY MEET JUST
TODAYS NEEDS. THE TRUE COSTS OF ADDING NEW SUPPLY AND
RIGHTS MUST BE ESTABLISHED AND ANY"BUILDOUT" DEFERRED
ANDNEW CONNECTION COSTS RECOVERED IN FULL FROM FUTURE
USERS I HAVE FOUND AND SUBMITTED AT LEAST TEN SUFFICIENT
REASONS FOR THE PUC TO REQUIRE SUBMISSION REVISION, RATE
INCREASE REJECTION AND MASSIVE REDUCTION DUE TO THE
MISLEADING STATEMENTS AND STATISTICAL INACCURACIES IN FALLS
ATER EXHIBITS, TESTIMONY AND FINANCIAL ANALYSIS. THE PRESENT
REMARKS ARE DISTRIBUTED HERE AT MY OWN EXPENSE (THE
TRANSCRIPT COSTS $$$!) FOR THE OPEN PUBLIC RECORD. GIVEN
THEIR OWN INTERESTS AND POSITION, I FULLY E XPECT THE COMPANY
TO OPPOSE THESE FINDINGS AND RECOMMENDATIONS SO ASK THE
PUC TO RULE IN FAVOR OF IDAHO CUSTOMERS. THANK YOU FOR YOUR
ATTENTION - I HOPE I NEVER HAVE TO DO THIS AGAIN! I DO HOWEVER
WELCOME ANY QUESTIONS YOU MAY HAVE.

Idaho Falls is seasonally water-dependent high desert
Summer peak need Is about 20x times proposed base allowance while normal distribution is only Sx times
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Figure 1:Typical Idaho Falls seasonal use variation showing the huge summer peak and very low base.

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