Dear Mr. Clough:

The PUC is in receipt of your comment in connection with the Kent
County Water Authority's proposed rate increase that it pending before
the PUC.  The PUC will be holding a public comment hearing at our office
on July 10 @ 7:00 PM.  Attached is the notice of public hearing.




Luly E. Massaro
Commission Clerk
Rhode Island Public Utilities Commission
89 Jefferson Boulevard
Warwick, Rhode Island 02888
401-941-4500, ext. 107
401-941-8827 (fax)
Lmassaro@puc.state.ri.us

Thomas Kogut 04/15/08 11:31 AM >>>

Mary reveived this through the webmaster link.

Mary kent 4/15/2008 11:24 AM >>>

<selahart@verizon.net> 4/15/2008 10:55 AM >>>

To All It May Concern,
As indicated in my previous email, there are very specific concerns I
wish to bring to your attention regarding the proposed rate increase by
the Kent County Water Authority.

As their filing indicates, the Authority has been very successful in
reducing the consumption of water within the district; it has declined
every year since FY 2003. The fact that they cannot offer any
explanation as to why consumption has decreased points either to
complacency or poor research.

I think it is safe to project that increased economic pressures on
consumers, coupled with a growing environmental awareness will lead to
continued decreases in average consumption per user. Couple this with a
continuation of the long-term trend of declining population in the
northeast, we should expect to see further reductions in demand for
water from this District. Yet the Authority has not prepared long-term
plans that incorporate these projections. If they come to pass,
alternative budget scenarios must be developed.

It is partially on the basis of this decrease in sales that the rate
increase is requested. Yet, within their plans are proposals to further
reduce consumption. This suggests that continued rate increases are a
part of their long-term strategic goals. While reduced consumption is a
worthy goal and should be pursued logic would dictate that some cost
savings should ensue. None of these are noted.

Not being a profession water engineer, I can only offer an educated
guess at what some of them might be: reduced stress on the
infrastructure producing a reduction in the need to upgrade as quickly
as anticipated and reduced purchasing and treatment costs for water are
two that immediately come to mind.

Every other agency of government (and most of the private sector) is
aggressively seeking reductions in costs. Why don't we see a similar
emphasis in their reports to the public? Only one area is mentioned:
health care cost increases are being reduced for current employees and
for retired personnel. Salary increases are planned for employees. Are
these increases justified in light of current market conditions? In
other words, are their peers in private industry receiving the same
raises? We have not been told  why they are justified.

At least one additional hire is planned. The base salary is listed as
$40,000. With benefits and accrued pension liabilities, I think it is
safe to assume that the annual cost will be nearer to $60,000. Is the
GIS program this person is expected to manage producing sufficient
saving to justify the expense of setting it up and managing it? We are
not given the answer to this. Have other options been sought out? The RI
Statewide Planning Office maintains a GIS site. Could the information
that the KCWA be obtained through this? If not, has the MUP program at
URI been contacted to see if they could provide interns to manage this?
The Authority points with pride to their employee training programs.
Could not two or three individuals in the agency be trained to manage
aspects of the GIS program when needed?

Since debt service accounts for a substantial portion of the
Authority's budget, I cannot accept their cursory comments that the
present environment in the bond market is unfavorable for refinancing.
Given their record of interest payments and principle reduction, coupled
with their substantial assets and the historically low interest rates,
they need to be aggressive in working with the financial community and
perhaps the General Treasurer's office to develop creative financing
mechanisms to reduce the overall costs.

The Authority must justify it's continuation before the users
continuously, (as they have no competition) explaining why they are
delivering a superior product and/or better service than a private
company would for similar or lower costs. A careful examination of
either privatization of some or all of their functions or continued
regionalization should be undertaken. Northeast RI was successful in
solving their infrastructure financing problems with respect to
wastewater treatment though the merger of the Blackstone Valley Sewer
Distract into the Narragensett Bay Commission. There is an inherent
fiduciary responsibility of the Board to address these issues.

Mr. Brown's testimony regarding the effects of this increase reveals an
arrogant ignorance. Even casually noting the demographics of the
communities the Authority serves will show that in more than one
neighborhood it is unlikely to be "certainly of minimal impact" as he
stated. An analysis of what this will do to property values, rental
housing costs, existing businesses and the ability of the communities
and property owners to attract new businesses must be considered by the
Commission. This effects of this increase added to the other increases
that the ratepayers are facing (property taxes, energy, food, postage,
etc.)
cannot be underestimated.

Finally, a cursory review of the membership of the Board reveals that
it's reputation and therefore motivations can be called into question.
In light of recent events, in the town of West Warwick, I do not
understand why Mr. Boyer is considered the best person to lead this
agency.

For these reasons, I respectfully and strongly urge the Public
Utilities Commission to reject request of this filing, and to urge the
respective towns to require greater accountability on the part of this
Board.


Langdon D. Clough
1650 Main Street
West Warwick, R.I.

April 13, 2008