COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF PUBLIC UTILITIES
(D.P.U. No. 23-65)
PETITION OF HOUSATONIC
WATER WORKS COMPANY, INC.
FOR APPROVAL OF A
GENERAL RATE INCREASE
COMMENTS OF LEIGH DAVIS,
CONCERNING THE PROPOSED SETTLEMENT AGREEMENT
As a citizen of Great Barrington, I respectfully submit my comments regarding the proposed Settlement Agreement between Housatonic Water Works Company, Inc. ("Company") and the Office of the Attorney General.
I have serious concerns about the Proposed Settlement, which would result in rapid and significant cost increases for the roughly 850 homes serviced by Housatonic Water Works Company (HWWC). Many of these residents cannot afford and should not be forced to pay 65% more over a few short years simply for potable water. (It should be noted that the Company's original petition sought a 112% increase.) The Company has long deferred maintenance on its aging infrastructure while its owners profited. Due to this negligence, customers have paid for brown water that cannot be safely consumed or used for household purposes. Now, the Company is asking these customers to bear the costs of decades of neglect and questionable operating budget priorities.
While these repairs are urgently needed, imposing the entire financial burden on customers over a short period without holding the Company accountable and disincentivizing future neglect is unjust. I urge the Department to find a way to distribute the financial burden of the proposed projects equitably. This could be achieved by scrutinizing the Company’s annual reports (in particular, the annual expenditure summary), requiring the Company to pursue grants for capital improvements, reducing its 9.5% profit margin, lowering borrowing costs, or finding a responsible purchaser. These customers have long suffered from the Company’s ongoing neglect. It is only fair that the Company is held accountable for its failure to maintain the system.
Specific Concerns
Water Quality: Persistent complaints about brown water raise fears about safety related to elevated levels of haloacetic acids (HAA5) and manganese.
Financial Hardship: Customers are experiencing significant financial strain due to water use fees. This burden will be compounded by the requirement for customers to cover the costs of constructing, installing, operating, and maintaining their private water mains, with the threat that the Company may place a lien against their property for unpaid amounts.
Health and Safety: Residents compelled to use bottled water and filters due to concerns about water quality.
Meter Reading System: Inaccurate transmission of water use data.
Appliance Damage: Discolored water causing damage to appliances.
Firefighting Concerns: Insufficient water pressure in firefighting hydrants.
DEP Compliance: Issues with compliance with DEP water quality requirements, including chemicals like haloacetic acids.
Customer Service: Poor responsiveness to customer inquiries and service issues.
Workarounds: Additional expenses incurred by customers to avoid harm or damage, such as avoiding showers, purchasing bottled water, and using commercial laundries.
Urgent Need for DEP-Required Improvements
The Company cites system improvements required to comply with DEP regulations as a substantial reason for the rate increase. If customers are to pay the proposed increased rates, it is crucial that DEP-required improvements are completed in a timely manner and achieve the intended results. The DPU should obtain detailed information regarding improvements and proposed costs related to DEP requirements, ensuring an accurate and complete record of costs associated with DEP compliance.
Given decades of neglect, the proposed manganese removal system, improved water treatment, disinfection methods, and significant upgrades to the distribution system are necessary. However, the Company should only be granted a rate increase after exploring all other revenue streams and eliminating operating budget waste.
Conclusion
Housatonic Water Works Company customers deserve clean, safe drinking water at a reasonable price. It is incumbent upon the DPU and the DEP, the two state agencies responsible for regulating public drinking water supplies in the Commonwealth, to ensure this. While the proposed Settlement marks a step in the right direction, it must fully address the public interest. The longstanding issues of the HWWC have led to the current situation, which should have been addressed much earlier. It is crucial that the DPU thoroughly scrutinizes the origins of this crisis and its impact on customers.
I appreciate the hard work of the Attorney General’s office in this matter and urge the DPU to ensure that the public interest is thoroughly protected in any decision made.
Thank you for your time and consideration.
DATED: June 6, 2024
Leigh Davis
