24-0798-WW-AIR

Key events and submissions in the Christi Water System, Inc. rate case (PUCO Case No. 24-798-WW-AIR) include:

- August 8, 2024: Christi filed its initial abbreviated application for a rate increase.
- August 29, 2024: The application was amended and accepted as of this date.
- October 15, 2024: The Commission approved the test year, date certain, and request for waivers; scheduled future procedural deadlines.
- March 21, 2025: PUCO Staff filed its Staff Report of Investigation.
- April 21, 2025: Deadline for filing objections to the Staff Report and motions to intervene.
- April 28, 2025: Deadline for filing motions to strike objections; local public hearing scheduled at 6:00 p.m., Defiance City Hall.
- May 5, 2025: Deadline for filing memoranda contra motions to intervene and motions to strike objections.
- May 14, 2025: Deadline for filing all direct expert testimony; Joint Stipulation and Recommendation filed.
- May 21, 2025: Evidentiary hearing scheduled to begin at the Commission's offices.
- May 27, 2025: Hearing for subpoenaed PUCO staff scheduled (per OCC motion) 1, 1.

Additional requirements included publication of public hearing notices in newspapers for two consecutive weeks prior to the local hearing and ongoing submission of proof of publication by Christi 1.

The docket concerns the application of Christi Water System, Inc. (Case No. 24-0798-WW-AIR) to increase its water service rates and charges in Defiance County, Ohio. Key details include:

- Christi Water System, Inc. filed its application for a rate increase on August 8, 2024, seeking approval to raise the base monthly rate from $34.34 to $44.96 and increase the per-cubic-foot charge, resulting in a proposed overall rate hike of 30.51 percent 1, 2.
- The company submitted required financial documents, including its annual report and federal income tax return, and requested waivers for certain filing requirements 1.
- The Public Utilities Commission of Ohio (PUCO) staff reviewed the application and recommended it be accepted for filing as of August 29, 2024, subject to recommendations 3.
- The process includes a prehearing conference on April 30, 2025, and an evidentiary hearing starting May 21, 2025, both at the PUCO offices in Columbus, Ohio. Deadlines for objections, interventions, and filings are outlined in the procedural schedule 4.
- Public notice of the proposed rate increase and upcoming hearings was published in a local newspaper as required 5.
- Consumer feedback has included strong objections to the size of the proposed increase, with concerns about affordability and the impact on low- and fixed-income households. Suggestions include phasing in any increases and exploring cost-saving alternatives 2.
- The docket will determine whether the proposed rates are reasonable or if alternative rates should be set to ensure fair compensation for Christ Water System while protecting customers 1.

The key stakeholders in the Christi Water System, Inc. rate increase docket (PUCO Case No. 24-0798-WW-AIR) are:

- Christi Water System, Inc. (the utility/company)
- Public Utilities Commission of Ohio (PUCO) Staff
- Office of the Ohio Consumers’ Counsel (OCC)
- Residential consumers served by Christi Water System, especially in Christi Meadows subdivision, River Chase Properties, and Webco Properties in Noble Township, Defiance County, Ohio
- Individual consumers (e.g., Jena Stites and others providing public comments)

Positions and Proposals:

Christi Water System, Inc.
- Proposal: Seeks a 32.3% increase in base water service rates, from $34.34 to $45.434 per month for up to 50 cubic feet of water, citing the need for reasonable compensation and return for utility service, infrastructure, and compliance investments 1, 2.
- Position: For the rate increase and supporting associated operational improvements.

PUCO Staff
- Position: Conducted a review and recommended the application be accepted for filing, with several recommendations such as modernizing billing, updating credit/collection policies, and addressing meter replacement and accounting practices 3, 4, 3, 5.
- Position: For a modified rate increase (supported a rate of return of ~9.26%) and various compliance and operational improvements.

Office of the Ohio Consumers’ Counsel (OCC)
- Proposal: Advocates for residential consumers, opposes excessive rate increases, and argues the proposed return is too high given Christi’s non-compliance with past PUCO directives and reporting standards. OCC also objects to the company's failure to implement prior infrastructure recommendations 2, 2, 5.
- Position: Against the proposed level of rate increase; argues for a lower rate of return and for requiring Christi to implement overdue compliance and infrastructure improvements.

Residential Consumers/Individual Commenters
- Position: Generally against the proposed 30.51%–32.3% rate increase, citing economic hardship and lack of visible infrastructure improvements following past increases. Requests either a lower or phased-in increase and more concrete plans for investment in system upgrades 6, 6, 7.

Summary Table:

- Christi Water System, Inc.: For the rate increase and operational proposals
- PUCO Staff: For a reviewed/modified rate increase with compliance conditions
- OCC: Against the proposed high increase; for a lower rate and stronger compliance requirements
- Residential Consumers/Public Commenters: Against the proposed high increase; for affordability and accountability in promised improvements

No party is explicitly for no increase at all; opposition focuses on the size of the increase and past failures to deliver promised upgrades. The stipulation process involved negotiation among these stakeholders, but positions remain divided on the appropriateness of the proposed rate hike and related company practices 4, 4.

The docket for Christi Water System, Inc. identifies several areas of growth, primarily focused on operational modernization, infrastructure improvement, and regulatory alignment. The key areas and related considerations are:

Billing System Modernization:
- Transition from an outdated billing format to a modern one is expected to streamline billing, reduce printing and mailing costs, and enhance customer understanding, thereby lowering billing disputes and associated costs 1.

Credit and Collection Policy Update:
- Revising policies to align with Ohio Administrative Code requirements is intended to balance customer protection with efficient debt recovery, reducing uncollectible accounts and improving revenue collection 1.

Tariff Revision:
- Updating tariff documents to reflect current billing formats and customer rights promotes transparency, prevents disputes, and reduces legal exposure 1.

Meter Replacement and Monitoring:
- Updating estimates for meter replacement, providing quarterly water volume reports, and annual usage data at the meter level will help target infrastructure improvements and reduce unaccounted-for water, supporting investments in a more reliable water system 1, 2.

Meter Tampering Protocol:
- Developing and implementing a protocol for responding to meter tampering is aimed at deterring tampering, protecting infrastructure, and minimizing revenue losses 1.

Affordability and Consumer Protections:
- There are concerns that recent and proposed rate increases could burden low- and fixed-income households. Key considerations include evaluating disconnection policies, budget billing options, and payment plans to ensure water remains affordable and consumer protections are strengthened 3, 3.

Each area of growth considers both operational efficiency and customer impact, with a focus on regulatory compliance, infrastructure investment, and consumer affordability.

The docket for Christi Water System, Inc. (PUCO Case No. 24-0798-WW-AIR) highlights several financial and timeline risks and concerns:

Financial Risks and Concerns:
- The proposed 30.51% rate increase is considered excessively high by customers and could impose significant financial strain, particularly on low- and fixed-income households. There is concern that such a steep increase is unreasonable in the current economic climate and may create affordability issues for vulnerable communities 1, 1.
- The staff report is criticized for not requiring Christi to implement an effective water loss control program despite unaccounted-for water loss between 31% and 48%. This high water loss rate leads to unnecessary costs for consumers and indicates potential inefficiencies in the system 2, 2.
- Previous rate increases were already substantial, with a 37.8% increase in 2021 for a typical household, and further proposed increases would add to the financial burden for consumers facing rising utility costs overall 2.
- The staff report failed to address affordability concerns, including whether Christi’s disconnection policies and budget billing options are adequate to protect consumers 2, 2.

Timeline Risks and Concerns:
- The staff report did not set a mandatory time frame for Christi to implement previously ordered improvements, such as evaluating and replacing water meters and addressing infrastructure deficiencies. This lack of specific deadlines raises concerns about delayed compliance and ongoing system degradation 2, 2, 2.
- There is no active program for periodic testing, repair, maintenance, or replacement of water meters, and all meters reportedly need replacement. The absence of a clear timeline for these critical infrastructure updates could further delay necessary improvements 2.
- The PUCO staff previously made recommendations for consumer protection in 2021, but Christi has not updated notices, bills, or procedures as recommended, and no mandatory deadline was set for these updates 2.

In summary, the main risks discussed are high consumer costs due to repeated and significant rate increases, lack of effective water loss management, and insufficiently enforced or scheduled infrastructure improvements, leading to ongoing financial and operational risks for both consumers and the utility system.