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•• Mr. David F. Webb <br />• <br />- 2 - ~ January 6, 1977 <br />7. They are asking that the rate design be substantially as proposed. Of <br />course there again I have not seen the details. <br />8. The rate schedule includes the clause which each year would adjust rates <br />to compensate for the increase of providing services. This is on top of <br />the monthly cost of gas. adjustments. <br />The following statement is of utmost interest. "It is now appearing clearly estab- <br />lished that wages-and other expenses will increase regularly at a rate which will <br />require annual adjustments in our rates to our customers". I shall like to <br />challenge that statement and ask them how they know what the future holds when it <br />comes to wage rates, prices, etc.? Companies should not be allowed to plan and <br />anticipate additional and continued inflation. • <br />9. Number nine (9) states that no action on <br />sary for these rates to go into effect. <br />now not yet made a full rate study. Undo <br />ment to that effect. -They indicate that <br />which they are proposing,,is unacceptable <br />;?are a rate study. Of course, they mean <br />tTrey are entitled to. <br />the part of the city is neces- <br />Presumably the. company has of <br />~r nine (9) they make the state- <br />if this uniform change, <br />to the city they-will then pre- <br />the full return they think <br />10. The Company indicates further horse trading by offering to make the <br />effected date May 1, after the cold weather is over in order to avoid <br />placing the increase in effect during cold winter months. <br />Further I do not think much of this horse trading approach because this whole <br />• approach here is to ask fora cost plus arrangement whereby Entex can automatically <br />pass on their increases and maintain who knows what level of earnings. In effect <br />they are advocating to do away with the old fishing license theory of regulations. <br />Under this theory a company is given a set of rates and told to go and do the best <br />they can with these rates, that if they are efficient they should make money and if <br />they are inefficient they may in fact lose money. Naturally, a small town or <br />village who does not have competent staff to keep constant surveillance over the <br />company's operations may be at a major disadvantage under an arrangement in the <br />nature proposed. <br />SUMMARY: <br />• • <br />1) Cost of capital may be in a downward swing. <br />2) l:ittl:e or no information is given on how the Company's purported adjusted <br />value rate base was derived. <br />3) It is.unlikely that there has been a sharp decline in the rate of return in <br />the last 18 months. How have they survived? <br />4) Utilities should not be given the liberty requested in this application by <br />Entex--- especially small towns. <br />J RW/ tmt <br />Respectfully submitted, <br />~~, . <br />~r~ i 11 ~1/~Z- ~ ~ ~ L ,r <br />:` ames R. Watkins, Rate Analyst <br />Department of Public Service <br /> <br />