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~; <br />.• <br />• <br /> <br />• <br />• • <br />Mayor Holmes #. 2, <br />January 7, 1977 <br />city to hire outside legal counsel, accountants, engineers and other <br />necessary rate expertise and charge these expenses back to the yutility. <br />Normally, in our experience, and from what we understand from ~~.,~aller <br />cities as well, these expenses added to the utility's overal~i operating <br />expenses are very minimal, and well worth the expert analysis, which <br />usually results in the Company resolving its rate demands at a much <br />lower°fi~ure than originally proposed. <br />T'~~e Company claims that the cost adjustment clause is necessary to <br />coripeate the Company for increases in the cost of providing service. <br />Here ~~+ey posit that it is reasonably certain that a change of rates will <br />be needed every year, and so it is to the benefit of the customer, the <br />regulatory authority, and the Company to provide for it without an <br />expensive proceeding. This is only possible if there are some checks <br />put on the adjustment and unless adjustment is based on a reasonable <br />formula. There is no check on this adjustment; the manner in which it <br />is calculated is not reasonable. <br />Further a general rate base, rate of return and rate structure or <br />review by a city at least every two years in these rapidly changing <br />ti~,~r~ of energy policy and usage would be well advised in my opinion <br />as a utilities regulator. <br />If you have any further questions, please do not hesitate to contact <br />me by telephone or mail. We will be glad to answer any questions about <br />this particular rate case and/or the Public Utility Regulatory Act, <br />Article 1446(c). <br />Best wishes to you and your City Council in Shore Acres. <br />Sincerely, <br />V <br />~ avid F. Webb, Director <br />Department of Public Service <br />City of Houston <br />DF4J/1 m <br />cc: Mayor Fred Hofheinz <br />cc: City Attorney John Dewey <br />Lake Jackson, Texas (per request) <br /> <br />