A public comment on Citizens Water’s petition for water and sewer rate increases

The following is an excerpt from a public comment recently submitted to the hearing record in the Citizens Water’s two pending rate increase petitions–


“Citizens Water has told the community that ‘Indianapolis will continue to grow” and that “we will not be able to conserve our way out of the problem’ (i.e. the perceived need for acquiring additional sources of water supply).

“I hope and trust that the OUCC and the IURC will closely scrutinize the degree to which the proposed rates will encourage water conservation, and ensure that the resultant rate structure would be maximally effective in encouraging customers, especially large customers — but also the broader customer base – to actively practice conservation.   Citizens Water has indicated that this has been accomplished in the proposed rates.  However, now is the time to optimize them, for a number of good reasons.

“One of those reasons is to avoid the need for potentially unnecessary future water supply sources.  Here is a current prominent example.  Earlier this year, The Anderson Corporation for Economic Development announced its plan for a dam and reservoir on White River which, in addition to other negative impacts, would destroy 7 miles of forested riparian land.  It would also be very costly.  The ACED initially told local area citizens and governance bodies that the facility would seek to promote economic development and would be entirely privately funded and no local taxes would be needed.  However, it subsequently approached Citizens Water (a Public Charitable Trust) in an effort to link its economic development project to the public water supply for central Indiana, and to the amelioration of low-flow conditions in the river during the drier months of some years.

“The feasibility of a dam and reservoir has yet to be determined.  However, the possibility exists that CW might consider a destructive dam and reservoir to be a convenient source of future supply to fuel central Indiana’s continued population and economic growth (which, ironically, appears by some Census data, to come at the expense of smaller cities and towns throughout the state).  Presumably, CW’s ratepayers would eventually be required, at least in part, to bear the high costs of such a project, if it is justified on the basis of public water supply for the Indianapolis area.

“Last summer, during the drought, a residential customer in Carmel was drawing more than a million gallons per day from CW’s system.  This might be an extreme example, but it demonstrates that some large users are stunningly insensitive to the need to conserve.  Price signals, via the rates, should be such that conservation and demand-management are actively encouraged.  At the same time educational programs including conservation techniques should be used.   Unfortunately, any incentives to consume less water, or produce less wastewater, can be in direct conflict with the utility’s desire to maximize revenues. “


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