2025-UN-34

The docket concerns the 2025 Formula Rate Plan (FRP) annual report for Great River Utility Operating Company, LLC, regarding its water operations in Mississippi. Key points:

- Great River is a public utility providing water and wastewater services in Mississippi and is part of a larger affiliate group owned by CSWR, LLC.
- The 2025 FRP annual report, filed on February 28, 2025, included financial documentation, pre-filed testimony, and exhibits as required by commission rules.
- The company's report showed an actual return on rate base (AROR) of 8.54%, resulting in no requested change in revenues or rates for water operations. The company also requested reconsideration of a previously rejected amended and restated stipulation offering three alternative rate mitigation proposals.
- After review and stakeholder feedback, Great River submitted a supplemental filing on June 9, 2025, with a fourth rate mitigation proposal (Proposal No. 4), estimating immediate bill reductions for nearly all water customers and about two-thirds of sewer customers. The proposal includes a three-year rate moratorium.
- On June 17, 2025, the Mississippi Public Service Commission approved Proposal No. 4 without modification. The new rates and compliance tariff were to be implemented beginning with the first billing period in July 2025 for bills sent in August 2025 1 2.

No parties intervened in the proceeding, and no motions regarding discovery deficiencies were filed. The final order deems the compliance tariff just and reasonable.

Key events and submissions in this proceeding include:

- February 28, 2024: Great River filed its 2024 FRP (Formula Rate Plan) annual report for water operations, the company's first such report under Rider FRP 1.
- November 13, 2024: An initial stipulation was executed and filed between Great River and the Mississippi Public Utilities Staff 2.
- December 3–4, 2024: Evidentiary hearings were held, during which Great River presented witnesses and evidence; subsequent meetings among parties addressed issues raised at the hearing 3.
- February 28, 2025: Great River filed its 2025 FRP annual report, pre-filed testimony, and exhibits. This is also the deadline for the 2025 FRP filings as referenced in the context of pending proceedings 4, 5.
- June 9, 2025: Great River filed a supplemental 2025 water FRP annual report with a fourth rate mitigation proposal, including testimony and exhibits 4, 4.
- June 17, 2025: The Commission found the filings to comply with applicable rules and adopted proposal no. 4, instituting a three-year rate moratorium through calendar year 2027. Great River is to seek no change in rates or tariffs before the FRP annual reports due by February 28, 2028 4.

No parties intervened or filed motions concerning deficiencies in discovery, and the staff conducted extensive investigations and data requests during both the 2024 and 2025 proceedings 4, 3.

The primary stakeholders identified in this docket include:

- Great River Utility Operating Company, LLC (Great River)
- Mississippi Public Service Commission (the Commission)
- Mississippi Public Utilities Staff
- Various stakeholders, including customers (as referenced in feedback)
- Legal representatives and counsel for Great River and the Commission (names and emails listed in correspondence)

Regarding positions on proposals:
- Proposal No. 4 was filed by Great River in response to staff review and feedback from various stakeholders, including customers. This proposal was designed to provide immediate bill reductions for nearly all water customers and about two-thirds of sewer customers, with a three-year rate moratorium aimed at delivering significant bill reductions compared to projections without Proposal No. 4. The Commission adopted Proposal No. 4 in full without modification 1.
- No parties have intervened in the 2025 FRP annual report docket, and no party objected to the amended compliance filing. The Mississippi Public Utilities Staff reviewed and approved the amended tariff submission correcting a previous error, indicating support for the proposal as adopted by the Commission 2.

In summary:
- Great River proposed Proposal No. 4 and supports it.
- The Mississippi Public Utilities Staff reviewed, approved, and raised no objection to the compliance filing for Proposal No. 4.
- The Commission adopted Proposal No. 4 in full.
- No other parties are recorded as intervening or opposing, and no objections are noted from any other stakeholders.

Thus, the significant stakeholders (Great River, the Public Utilities Staff, and the Commission) are all in support of Proposal No. 4, and there is no record of opposition in the docket 1, 2.

The docket identifies two main areas of growth:

1. Acquisition and System Integration:
- Great River has been acquiring wastewater systems that previously operated without commission-approved rates and with significant non-compliance in annual regulatory reporting. The commission notes that while the reasons for non-compliance vary, there is clear room for improvement in regulatory adherence and service quality. There have also been customer complaints of poor service concerning some acquired systems, highlighting the need for operational improvements and better customer service 1.

Key considerations:
- Bringing acquired systems into compliance with commission regulations and annual reporting requirements.
- Addressing legacy issues of poor maintenance and customer service.

2. Infrastructure Improvement and Operations:
- The acquired wastewater collection systems generally consist of gravity and low-pressure collection systems. The low-pressure systems are in fair condition, but gravity systems often have undetected damage, leading to inflow/infiltration problems and increased flows to treatment plants. Many lift stations were found in failed or very poor condition, with broken/missing equipment, little or no system control, and no remote monitoring. Significant accumulation of solids in wet wells has been common, reducing capacity and potentially causing equipment damage or sewage overflows 1.

Key considerations:
- Upgrading and maintaining gravity collection systems and lift stations.
- Installing system controls and remote monitoring.
- Addressing operational risks like inflow/infiltration, equipment failure, and sanitary sewage overflows.

Both areas of growth require focused attention on regulatory compliance, infrastructure investment, and operational best practices to ensure reliable service and customer satisfaction.

The excerpts do not specifically discuss detailed financial or timeline risks and concerns in the docket. However, the following related points are mentioned:

- There was an error in the originally submitted tariff pages which included incorrect information related to non-residential service. This typographical error required an amended compliance filing to correct, indicating a risk related to administrative accuracy and the need for prompt correction to avoid improper rate implementation 1.
- The timeline for implementation is explicitly stated: the amended and corrected tariff is to be implemented beginning with the first billing period in July 2025, with bills sent to customers in August 2025. Any delay in the acceptance of the amended tariff or further Commission instruction could affect this timeline 1, 2.
- The process followed Commission rules and orders, and there were no motions filed citing deficiencies in discovery access, and no parties intervened in the proceeding. This suggests minimal regulatory or procedural risk identified during this docket 3.
- The shift from mitigated to unmitigated rates for some customers, as mandated by prior Commission orders, is expected to result in bill changes for some, but this is described as a requirement rather than a risk. The three-year rate moratorium under Proposal No. 4 is intended to provide bill stability and mitigation 3.

In summary, the main concerns addressed are administrative (correction of tariff errors) and timeline (ensuring implementation by July 2025), with no explicit discussion of broader financial or operational risks in the provided excerpts.