20250826Petition to Reconsider.pdf

RECEIVED
Mark R. Mecord
PO Box 871 28 AM 10: 08
Athol, ID 83801 : ;'U ?i.IC
31562 N. Spirit Drive -°' ' ! : " oMWSSION
Spirit Lake, ID 83869
[phone]
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF GEM STATE WATER ) CASE NO. GSW-W-24-01
COMPANY, LLC'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES ) Petition for Reconsideration
AND CHARGES FOR WATER SERVICE )
Gem State Water Company (GSW) was granted a rate increase in 2023 (case GSW-W-22-01) of
46% in the base rate/allowance and an increase 13.51% in the excess (per 1000 gallons). While
this placed additional financial strain on its customers, increases in materials, labor and inflation
did play a part in the decision of the IPUC as well as the spreadsheets that GSW provided.
In 2024 GSW applied for another rate increase (case GSW-W-24-01) and was granted 31.43% in
the base rate/allowance and an increase of 61.51% in the excess (per 1000 gallons). These
numbers are derived from the spreadsheet below.
2022
Current Proposed Awarded Increase Notes
Base $25.55 $35.00 $35.00 36.99%
Allowance 8000 8000 7500 -6.25%
Per Gallon $0.003194 $0.004375 $0.004667 46.12% Actual increase of base due to allowance decrease
Excess was billed at$1.74 per ccf which works out to$2.22 per 1000
Excess $2.22 $5.10 $2.52 13.51% gallons,not the$2.33 in the application
2024
Current Proposed Awarded Increase Notes
Base $35.00 $53.50 $46.00 31.43%
Allowance 7500 5000 7500 0.00% Proposed amount are from the amended application
Per Gallon $0.004667 $0.010700 $0.006133 31.43%
Excess $2.52 $4.50 $4.07 61.51% Application states current as$1.88
Petition For Reconsideration Page 1 of .5'

On page 14 of the final order (20250731Final—Order—No-36703.pdf) there is a paragraph that
states: "Public utilities are entitled to a reasonable rate of return on prudent investments." If
Gem State had performed it due diligence when acquiring Spirit Lake East Water Company, it
would have found that the current rates it was charging would not cover GSW requirements.
We believe that Gem State did not make a prudent investment and as such does not meet the
requirement of the reasonable rates. The fact that GSW has come back for rate increases in two
years shows that they either do not understand small water systems or just want to increase
their revenue.
Additionally, a cursory review of water rates in nearby communities show that the rates GSW is
requesting is out of line.
Greenferry Water charges:
• Minimum monthly fee for operations of$35.00 per month up to 25,000 gallons of water
usage during any metered month.
• $0.75/1,000 gallons for usage in excess of 25,000 gallons during a metered month, up to
50,000 gallons of water usage.
• $1.30/1,000 gallons for usage in excess of 50,000 gallons during a metered month, up to
100,000 gallons of water usage.
• $2.00/1,000 gallons for usage in excess of 100,000 gallons during a metered month.
• A fee of$4.00 per account, charged annually by IDEA, is passed through as a cost to the
District.
City of Coeur d'Alene charges:
• $12.47 for 1" base (no allowance)
• $1.22 for 0—30,000 gallons, $1.75 for 31,000—50,000 gallons.
• $2.38 in excess of 51,000 gallons
City of Rathdrum charges:
• $15.55 for 1" base (5,000 gallon allowance)
• 5000 to 20,000 gallons excess $0.67/1000 gallons
• Above 20,000$1.40/1000 gallons
The final order mentions the public comments for the increases, but does not address them. It
does address the low pressure and water loss.
Petition For Reconsideration Page 2 of 5

It also directs GSW to shift revenue recovery from minimum charge to commodity charge in the
future. GSW did mention that in the application, but would do so gradually. This would be
another avenue for GSW to increase its revenue.
Gem State Water Company is a subsidiary of NW Natural Water of Idaho, which is a subsidiary
of NW Natural Water Company, which is a part of NW Natural Holdings Company. Institutions
have a 75.9% share of stock in the Holding Company and the major stockholder is Blackrock.
These investment firms are more concerned with profits and dividends than the water
customers at the GSW level. If you follow their history, which is quite extensive, It is apparent
they're going after smaller water companies with the idea of raising rates and increasing profits
for NW.
We, the undersigned are petitioning the Idaho Public Utilities Commission (IPUC)to reconsider
the order given to case GSW-W-24-01. We request that IPUC revise its final order to deny the
GSW rate increase. If they cannot come into alignment with the other local water districts,then
they should exit the market and find a new buyer.
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Petition For Reconsideration Page 3 of 5

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Petition For Reconsideration Page 4 of 5

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Petition For Reconsideration Page 5 of

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