March 27,2014
Public Service Commission of West Virginia
C/O Executive Secretary
P.O. Box 812
Charleston, WV 25323
Dear Mr/s Executive Secretary, Public Service Commission:
I am writing in regards t o the “Public Notice of Change in Rates” for the Greater
Harrison County PSD (hereto after referred t o as the GHCPSD). After stringent review
and accompanying research, I would like t o express many concerns and questions t h a t 1
have regarding this rate increase.
The following statements create my formal protest t o the proposed rate increase:
Financial justification - Per the West Virginia Code Section 24-2-4b(b) and the Public
Service Commission Rules for the Construction and Filing of Tariffs 150-2-22.1.f.3, a
financial justification for rate increases is required documentation accompanying t h e
tariff. What justification does the GHCPSD have for the rate increase? As a working
individual, I am unable t o make my way t o the location on Highland Dam Road in West
Milford to review the complete tariff documentation during their operating hours. Also,
I have been unsuccessful in my requests t o obtain an electronic copy of the complete
tariff, therefore I remain unsatisfied with the single sheet of paper we’ve received t o
“explain” these changes
Accounting Restrictions - I am also aware that the GHCPSD is a public utility office, thus
rendering it applicable t o Enterprise Fund accounting treatment per the rules set forth
by the Governmental Accounting Principles & Standards Board (GASB). Per GASB
requirements, Enterprise funds must only use revenues to continue providing their
principle service and nothing more. The notice we received states that nearly $400,000
in additional revenues will result from this tariff annually, but it does not specify what
the GHCPSD intends t o do with these funds. The notice also fails t o mention any
external factors that would cause the GHCPSD t o need these funds t o cover their
existing operational expenses- thus allowing the assumption that any additional
revenue they receive is above and beyond their operating needs.
Customer Classes
-
Per the public notice, the GHCPSD currently charges all of i t s
1
customer classes the same rate for their water consumption. My third concern is t h e
fairness of this pricing matrix. Even without my extensive business knowledge, I could
still garner a strong assumption that industrial and commercial consumers require more
product, maintenance and time than a residential customer would. So how is it fair for
the GHCPSD t o charge all three customer classes the same rate for their water usage?
Since it is common business practice to price services based on their underlying cost
basis, why should our small town residential customers have t o pay the same prices
that large business incur?
It is for these reasons that I have submitted my formal protest against this proposed
rate hike. Considering the tagline that adorns the very top of your website reads, “...
ensuring that reasonably priced and reliable utility services are available t o all
customers”, I would also like to request a formal response to the issues discussed
above.
Very humbly submitted,
Frank & Linda Gump
P.O. Box 412
Lost Creek, WV 26385
2
f
March 27,2014
Public Service Commission of West Virginia
C/O Executive Secretary
P.O. Box 812
Charleston, WV 25323
Dear Mr/s Executive Secretary, Public Service Commission:
I am writing in regards t o the “Public Notice of Change in Rates” for the Greater
Harrison County PSD (hereto after referred t o as the GHCPSD). After stringent review
and accompanying research, I would like t o express many concerns and questions t h a t I
have regarding this rate increase.
The following statements create my formal protest t o the proposed rate increase:
Financial justification - Per the West Virginia Code Section 24-2-4b(b) and the Public
Service Commission Rules for the Construction and Filing of Tariffs 150-2-22.1.f.3, a
financial justification for rate increases is required documentation accompanying t h e
tariff. What justification does the GHCPSD have for the rate increase? As a working
individual, I am unable t o make my way t o the location on Highland Dam Road in West
Milford t o review the complete tariff documentation during their operating hours. Also,
I have been unsuccessful in my requests t o obtain an electronic copy of the complete
tariff, therefore I remain unsatisfied with the single sheet of paper we’ve received t o
“explain” these changes
Accounting Restrictions- I am also aware that the GHCPSD is a public utility office, thus
rendering it applicable t o Enterprise Fund accounting treatment per the rules set forth
by the Governmental Accounting Principles & Standards Board (GASB). Per GASB
requirements, Enterprise funds must only use revenues t o continue providing their
principle service and nothing more. The notice we received states that nearly $400,000
in additional revenues will result from this tariff annually, but it does not specify what
the GHCPSD intends t o do with these funds. The notice also fails t o mention any
external factors that would cause the GHCPSD t o need these funds t o cover their
existing operational expenses- thus allowing the assumption that any additional
revenue they receive is above and beyond their operating needs.
Customer Classes
-
Per the public notice, the GHCPSD currently charges all of i t s
1
customer classes the same rate for their water consumption. My third concern is t h e
fairness of this pricing matrix. Even without my extensive business knowledge, I could
still garner a strong assumption that industrial and commercial consumers requir- more
product, maintenance and time than a residential customer would. So how is it fair for
the GHCPSD t o charge all three customer classes the same rate for their water usage?
Since it is common business practice t o price services based on their underlying cost
basis, why should our small town residential customers have t o pay the same prices
that large business incur?
It is for these reasons that I have submitted my formal protest against this proposed
rate hike. Considering the tagline that adorns the very top of your website reads, "...
ensuring that reasonably priced and reliable utility services are available to all
customers", I would also like to request a formal response to the issues discussed
above.
Very humbly submitted,
Robert and Barbara Wilt
9057 Good Hope Pike
Lost Creek, WV 26385
2