Regulatory Commission of Alaska

Public Comment for TA180-72 by Corinna Dart
To whom it may concern,

My name is Corinna Dart and I live at #2 Spruce Street Manley Hot Springs. First off I would like to acknowledge the work of the Manley Village Council, TCC, and TMG towards acquiring grant funding for: extending service to more residents, updates to our power grid, more efficient generators, and the incorporation of renewable solar. I am sure these steps will be a much needed improvement to Manley’s power system from both an environmental and business perspective. I also am cognizant that there are many challenges to providing power to a fairly remote area with a small customer base. That being said, I have some concerns regarding the preposed permanent rate increase for TMG customers in Manley Hot Springs, which I will lay out in the following:

1. A 27.91% permanent rate increase is an extremely high burden to lay on the shoulders of customers living in an area where “the economy is poor.” I understand that this is an unfortunate situation for TMG as well, but I would like to know what/if any alternatives to raising rates for customers have been explored in order to address the $94, 241 revenue shortfall. Despite initial confusion due to clerical errors listing a 40% increase, a 27.91% rate hike (still an increase of nearly a third) is not likely to be much more affordable and given that all the rates listed in the table of the notice were accurate I don’t think the comments and concerns of residents were only caused by the misprint of a %40 increase. According to PREFILED DIRECT TESTIMONY OF WILLIAM G. VAN COUWENBERGHE “Customer payments are in a number of cases not timely, and fuel expense must be paid within stated payment terms to assure a continued supply of fuel.” If this is the case does the company believe that raising the rate will make it more likely payments are received on time? Because it certainly seems more likely that it would have the opposite effect if this is due to customers struggling to make payments already. Also I think it should be noted that with the uncertain future of Power Cost Equalization (PCE) these rates will become even less affordable to residential customers should PCE fail to be funded in future.

2.The assertion that Manley’s economy is poor may be technically accurate but may not reflect near future growth. It is my understanding that there are several new (or newly changed hands) businesses operating in Manley Hot Springs as of this year which will likely have greater power needs in future years when they move beyond an initial start up phase. Extremely high power rates may be stifling to new businesses trying to get off the ground or encourage business owners to seek their own power solutions off grid thereby depriving TMG of potential revenue. As a person seeking to open a business in Manley in the near future I was already considering the benefits/drawbacks of on grid vs. off grid. The potential for increased renewables is an incentive to stay on grid but if these new rates are approved I will likely to seek other options. Considering “goals of improving overall electrical system efficiency, safety and reliability, integrating high levels of cost-effective renewable energy resources with conventional diesel generation to lower overall energy costs, and operating the utilities in a manner that encourages sustainable economic growth in the communities we serve.” (Prefiled Direct Testimony of John G. Lyons December 21, 2021 TA 180-72 Page 1 of 18) are stated goals of the company I think it may be to everyones benefit to reconsider the long range impacts for such prohibitively high rates and if there are any unexplored alternatives.

3. Complicated industry specific language makes it hard for the lay person to understand the nuances of the documents provided or wether we have any additional recourse (beyond public comment) to address our concerns or collaborate on alternative options. Customers should have the ability to have a basic understanding of the decision making process that lead to the proposed rate increase. Perhaps this can be served by a public meeting between consumers and power company officials or a clearly explained response to consumer concerns given in plain language and posted as public notice/mailed directly to individual consumers.

4.Transparency of information regarding Exhibit WVC-2  TANADGUSIX CORPORATION AND SUBSIDIARIES CONSOLIDATED FINANCIAL STATEMENTS YEARS ENDED DECEMBER 31, 2020 AND 2019. Why is this information confidential? Is this a standard practice? Is any of this information relevant to TMG customers, and if so can it be released on its own without compromising any information that may be proprietary or sensitive for business purposes? I am not saying there is ill intent, but surely it is understandable that not knowing the reasoning for keeping this information confidential impacts public trust.

5. Future power rates. If updates are made to switchgear and generators through funds from the EPA Diesel Emissions Reduction Act and the Volkswagen Diesel Emissions Environmental Mitigation Trust for Indian Tribe Beneficiaries, and if TMG (in conjunction with Manley Tribe) receives the $2,174,398 grant from the USDA High Energy Cost Grant Program for the Manley Village Solar Energy Security and Resiliency Project, will these updates lead to higher or lower power rates in the future? “TMG projects that solar PV production would be almost 195,518 kWh annually.——saving more than 25% of current diesel fuel consumed.——The project would increase diesel fuel efficiency from 12.12 kWh per gallon of diesel to over 17 kWh per gallon of diesel, a 39% increase in overall system efficiency.” PREFILED DIRECT TESTIMONY OF JOHN G. LYONS Would customers be likely to see this increase of efficiency reflected in lower rates? Also as I understand it the preposed rate increase is not specifically to budget for improvements to the system, but in order to address a $94,241 revenue shortfall since the last rate case (which is a concept I find difficult to understand as a lay person and would appreciate some clarification on.) Will rates be raised again in the future in order for TMG to fulfill its commitments for a $135,100 match of funds and a $153,000 cost share (as stated in Mr. Lyons testimony) respectively?

In conclusion I would like to reiterate that I respect the massive challenge and work required to provide energy in rural areas. I think that given the extreme change (nearly 1/3rd increase) in rates TMG is requesting the community should have a chance to have their questions answered and concerns addressed before a change is made, and should be made aware of any additional resources/and or institutions which could help find alternatives to this cost falling so heavily on the shoulders of residents. Thank you for your time and consideration.?
Type
Comments
Date Filed
1/24/2022
Tracking Number
TR2200385
Filed By
Corinna Dart
Entities
Certificate(s)
Means Received
Internet
Related Matters
TA180-72	TDX Manley Generating - Revenue Requirement Study
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