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ACC Investigation Into Potential Improvements to its Water Policies – DOCKET NO. W-00000C-16-0-151 – MAY, 2016

BEFORE THE ARIZONA CORPORATION COMMISSION

DOUG LITTLE,  CHAIRMAN

BOB STUMP, COMMISSIONER

BOB BURNS, COMMISSIONER

TOM FORESE, COMMISSIONER

ANDY TOBIN, COMMISSIONER

 

Arizona Corporation Commission Investigation into Potential Improvements to its Water Policies Docket No. W-00000C-16-0151

PUBLIC COMMENT

A RATEPAYER PERSPECTIVE

The primary responsibility of the Commission is to ensure safe, reliable, adequate, and reasonably priced utility service to ratepayers and maintain financially healthy utility companies. For almost two decades the effort to consolidate the disjointed fragmented water/wastewater systems has gone without resolution.  It is refreshing that Chairman Little and his Commissioners have elected to vigorously work toward resolution of solving the statewide problem of these small, fragmented borderline companies.

This docket and the subsequent presentations given on May 19, 2016 by a number of parties, prove testament to continuation of the effort.

The initial Policy Statements one through five (1-5) as initiated by the Commissioners are a good starting point.  Of course, the development of a more strategic roadmap and action plan will need to be developed.  A joint effort including the Commissioners, ACC Staff, RUCO, Large and Small Utility, Developer and Legislative representation would seem appropriate and necessary to move toward a successful solution.

At this point in the conversation, the main target seems to be an attempt to consolidate the Arizona water and wastewater industry by promoting the acquisition of the numerous small, underperforming companies throughout the state, currently under the control of the Commission, by the larger more stable companies in the state.  This along with possible municipal and other consolidation type efforts make sense.

In the short-term, acquisitions and consolidations are generally detailed, comprehensive in nature, technical and expensive to one degree or another, for all parties concerned.  However, if done correctly, the long-term paybacks are well worth the initial pain, particularly with the advent of likely escalating costs in the water and wastewater utility arena throughout the state.  It is not to say that such efforts will be easy, particularly when it will likely be necessary to keep “cost causer” principles intact.

A concerted bilateral effort will be needed by all affected player types to effect a suitable long term solution.  It would not suffice, for example, to put a consolidation program together while still allowing further development of outlier communities being serviced by small companies lacking economies of scale historically proven to be lacking in the ability to provide continued safe, reliable, adequate, and reasonably priced utility service to their ratepayers.

Good start – Let’s not come up short again.

RESPECTFULLY SUBMITTED this _____ day of __________________, 2016.

___________________________

Greg Eisert – Director SCHOA

AN ORIGINAL AND THIRTEEN COPIES

of the foregoing filed this ___ day

of _____________, 2016 with:

Docket Control

Arizona Corporation Commission

1200 West Washington

Phoenix, Arizona 85007

COPIES of the foregoing hand delivered/

mailed/emailed this ____ day of ___________, 2016 to:

Arizona Corporation Commission

Janice Alward

1200 W. Washington

Phoenix, Arizona  85007

Arizona Corporation Commission

Thomas Broderick

1200 W. Washington St.

Phoenix, Arizona  85007

Arizona Corporation Commission

Dwight Nodes

1200 W. Washington

Phoenix, Arizona  85007-2927

By:_______________________

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