Docket Number	Docket Name	Company
UP 439	SUNSTONE ET AL. APPLICATION TO MERGE INTO SUNSTONE	SUNSTONE WATER LLC (DBA HILAND)

Created Date	Comment Type	First Name	Last Name	Comment
2/12/2026 6:41:09 PM	General Comment	Brian	Lauterbach	Salmon Valley Water was acquired By NW Natural Water / NW Natural Holdings in 2017. Hiland Water was acquired by NW Natural Water in October 2023, then on December of 2023 , became part of Sunstone Water LLC: a wholly-owned subsidiary of NW Natural Holdings. Sunstone Water, LLC was formed in March 2019 in Oregon as a platform for acquiring and managing water utility assets. It is a wholly-owned subsidiary of NW Natural Water. This strategy is NOT to provide clean and safe water, it is to MAKE profit by buying water companies and raising rates, which they do EVERY TIME. After rates are grossly increased, NW Natural acquires more water companies, to then raise the rates even more. Water quality has decreased immensely since Salmon Valley Water bought by NW Natural Water. Infrastructure, aging pipes, etc. have not been repaired. Now they want throw it under the "umbrella" of Sunstone Water LLC, a a wholly-owned subsidiary of NW Natural Water. This is corporate 3-card Monte. These acquisitions and re-acquisitions of the same water companies over and over, and no increase in water quality. Just rate increases, and unsafe wate This family has had sickness , cancers, destroyed appliances, ruined clothing, and 3 animals getting cancer, 2 of which died from water that was dangerous. We went into debt to spend $4000.00 on a whole house water treatment system to have clean and safe water. My water company should be doing this. This has got to stop. I do not support this acquisition of Salmon Valley Water to go under the "umbrella" of Sunstone Water LLC. Corporate scam. Thank You, Brian Lauterbach
2/13/2026 4:53:47 PM	General Comment	James	Robinson	Commissioners: I am submitting this comment as a customer of Salmon Valley Water Company in the small mountain community of Welches, Oregon, regarding the proposal in UP 439 to merge Salmon Valley Water Company into Sunstone Water, LLC. Salmon Valley currently serves households throughout Welches, while Sunstone Water, created in 2019 and owned by NW Natural, is headquartered in Portland. Although the companies describe this merger as a simple internal change, it directly affects our community because it is being carried out at the same time NW Natural is pursuing new rate increases. On December 31, 2025, NW Natural filed UW 209, a major rate-increase request for Sunstone, Salmon Valley, Lakeshore, Seavey Loop, and South Coast Water—exactly the same companies involved in the proposed merger. This filing asks the Commission to implement new rates on December 1, 2026, the very same day the merger is planned to take effect. The merger application even states that NW Natural intends to consolidate all of the different water companies’ tariffs in a future general rate case, and UW 209 is clearly that case. This means the merger and the rate increases are not separate events; they are coordinated steps timed to happen together. Our community has already experienced a major financial impact. In 2023, Salmon Valley Water customers saw their bills nearly double, increasing from about $39.92 per month to roughly $78.63, according to PUC notices and the company’s own customer announcement during the UW 195 rate case. Now, before customers have fully adjusted to that large increase, NW Natural is preparing the next round of rate changes by grouping Salmon Valley with several other systems under one large umbrella. This merger also makes it easier for NW Natural to spread shared costs onto small communities like ours. Salmon Valley and the other water companies already rely heavily on NW Natural’s affiliated companies for operations, management, staffing, and technical services. Some of these affiliate arrangements were approved recently, and in at least one case, the Commission granted a waiver from the rule that normally protects customers by requiring affiliates to charge the lower of cost or market price. If all of these systems are merged into Sunstone, it becomes much harder for customers and regulators to see whether we’re being charged fairly, because expenses from multiple systems and affiliates can be blended together under a single corporate entity. The companies claim that the merger will have “no customer impact,” but their own filings show otherwise. The merger and the new multi-system rate case are set to take effect on the same date, and the company has already stated it plans to consolidate rate structures afterward. These actions will directly affect the bills of Salmon Valley customers who have already experienced steep increases under NW Natural ownership. For these reasons, I respectfully ask the Public Utility Commission to deny the merger. If the Commission approves it, I urge strong protections for our community. These include requiring Salmon Valley’s financial information to remain separate for several years, limiting affiliate charges until a full review can occur, preventing any combining of rate structures unless the company proves bills for Salmon Valley customers will decrease, and prohibiting the company from passing merger-related costs onto customers, as the Commission has done in past NW Natural water cases. Residents of Welches rely on Salmon Valley Water for essential daily needs, and we deserve protection from unnecessary costs and corporate restructuring that offers little or no benefit to customers. Based on the evidence in the record, the merger into Sunstone Water primarily benefits NW Natural, not the people who pay the bills. Respectfully, JF Robinson - Welches, OR
2/14/2026 10:59:49 AM	General Comment	Rhonda	Cross	This merger and subsequent rate hikes will have a severely adverse effect on the tiny Mt. Hood village communities swept up by it. We are small community made up of primarily service workers that are dependent on the tourist trade from Mt. Hood. The proposed rate hikes have a detrimental impact financially on a community of people already trig to get by. This merger and rate changes forces our community to support the overhead and uses of much larger areas such as Portland due to the ownership of NW Natural. The needs and interests of our community will be lost under the large corporate structure and politics involved with NW Natural as already evidenced by the significant rate increases scheduled for the very same day the merger takes place. Please do not crush our community under the weight of this Goliath and deny the merger request
2/14/2026 12:15:02 PM	Oppose Docket	Douglas	Lee	. Commissioners: I am submitting this comment as a customer of Salmon Valley Water Company in the small mountain community of Welches, Oregon, regarding the proposal in UP 439 to merge Salmon Valley Water Company into Sunstone Water, LLC. Salmon Valley currently serves households throughout Welches, while Sunstone Water, created in 2019 and owned by NW Natural, is headquartered in Portland. Although the companies describe this merger as a simple internal change, it directly affects our community because it is being carried out at the same time NW Natural is pursuing new rate increases. As a member of the Cedars HOA, a community of 2 dozen homes the reley on water from Salmon Valley Water Co, I am very much concerned that this merger will not only increase rates, but will ultimately cause the original customers of Salmon Valley to essentially to subsidize other customers --even those belonging to larger jurisdictions and even those related to Portland. I strongly oppose the proposed mergers and attendant price increases, which are not likely to be proportionale to the smaller number of members in the original community served. Thank you for your consideration. Douglas B. Lee
2/15/2026 8:15:01 AM	Oppose Docket	Chris	Sveen	I do not support this merger and I implore you to stop this merger from happening. We here in our small community of Welches, OR will be hit the hardest as Sunstone Water is already asking for a rate increase which will be financially burdensome to my family and this community as a whole. Many of us have to commute to work, myself included, which takes up a lot in gas money people in Portland take for granted. I wish I had throw away money but I don’t and businesses like this take more and more every chance they get. These corporations are big enough, they don’t need to be larger. It just puts more of our money in their pockets. Please don’t let this happen!
2/15/2026 10:34:48 AM	Oppose Docket	Todd	Ellis	Public Comment on Proposed Utility Merger Thank you for the opportunity to provide comment on this proposed merger. I am a resident of Welches, Oregon, and a customer of Salmon Valley Water. After reviewing the application materials, I do not find sufficient justification to support this merger. The filing states that the entities involved are already directly or indirectly under the umbrella of NW Natural Water. As such, the proposed merger does not meaningfully change ownership or oversight. The primary benefits cited—reducing administrative and regulatory complexity—appear to benefit the company rather than customers. The examples provided in the application describe efficiencies for Salmon Valley Water or NW Natural Water, but do not demonstrate tangible, measurable advantages for ratepayers. In addition, most of the systems included in the proposed merger are located near Salem or Eugene. Salmon Valley Water is approximately 100-160 miles—roughly two to three hours—away. Given this geographic distance, the concept of operational resource sharing appears impractical. It is unclear how customers in Welches would meaningfully benefit from consolidation with systems so far removed. While the benefits appear limited, the potential risks and liabilities for Salmon Valley customers could be significant. The application does not provide information regarding the condition of the other water systems involved or the capital improvements they may require. If consolidated, Salmon Valley customers could ultimately bear the cost of upgrades to infrastructure in distant communities. When Salmon Valley Water was acquired by NW Natural Water, customers experienced a rate revision to fund upgrades to our own system. Those upgrades represent the only substantial capital expenditures customers have been made aware of during NW Natural’s seven years of ownership, and we continue to pay for them. It would be unreasonable to expect Salmon Valley customers to assume additional financial obligations for other systems whose needs and conditions have not been transparently disclosed. The potential financial exposure associated with unknown capital requirements clearly outweighs the limited and largely administrative benefits described in the filing. Salmon Valley Water has historically operated as an independent system, and many customers value that independence. This proposal appears primarily designed to allow NW Natural Water to expand its customer base and distribute system-wide costs more broadly. That objective may serve the company’s interests, but it does not necessarily serve the interests of Salmon Valley ratepayers. The Oregon Public Utility Commission’s mission is to ensure that Oregonians have access to safe, reliable, and fairly priced utility services. Approving a merger that presents unclear benefits and potential financial risks to existing customers does not align with that mission. For these reasons, I respectfully urge the Commission to deny the proposed merger.
2/16/2026 3:46:43 PM	Oppose Docket	Vanessa	Linn	We just purchased our home in The Cedars and our first night in our new home was January 31st, 2026. We have had nothing but huge bills since we moved in! (PGE at $466.12 for a month we weren't even there!) and now a notification of an increase to a water bill we have not even paid yet! All of these exorbitant costs on a home we have not occupied for more than 17 days! Needless to say, it has us wondering why in the heck we moved here!! I don't know really what to say, because I have not had any time at my new address to even know what our budget busting bills are, but I am sending out my plea to NOT merge the water companies and to keep Salmon Valley Water a separate entity for our mountain community. These types of mergers are devastating to small communities who get lost in the shuffle of the conglomerate at large.
2/16/2026 3:55:30 PM	General Comment	Bryce	behnke	"Re submit from James Roberson on Nextdoor " He states it so well. " Commissioners: I am submitting this comment as a customer of Salmon Valley Water Company in the small mountain community of Welches, Oregon, regarding the proposal in UP 439 to merge Salmon Valley Water Company into Sunstone Water, LLC. Salmon Valley currently serves households throughout Welches, while Sunstone Water, created in 2019 and owned by NW Natural, is headquartered in Portland. Although the companies describe this merger as a simple internal change, it directly affects our community because it is being carried out at the same time NW Natural is pursuing new rate increases. On December 31, 2025, NW Natural filed UW 209, a major rate-increase request for Sunstone, Salmon Valley, Lakeshore, Seavey Loop, and South Coast Water—exactly the same companies involved in the proposed merger. This filing asks the Commission to implement new rates on December 1, 2026, the very same day the merger is planned to take effect. The merger application even states that NW Natural intends to consolidate all of the different water companies’ tariffs in a future general rate case, and UW 209 is clearly that case. This means the merger and the rate increases are not separate events; they are coordinated steps timed to happen together. Our community has already experienced a major financial impact. In 2023, Salmon Valley Water customers saw their bills nearly double, increasing from about $39.92 per month to roughly $78.63, according to PUC notices and the company’s own customer announcement during the UW 195 rate case. Now, before customers have fully adjusted to that large increase, NW Natural is preparing the next round of rate changes by grouping Salmon Valley with several other systems under one large umbrella. This merger also makes it easier for NW Natural to spread shared costs onto small communities like ours. Salmon Valley and the other water companies already rely heavily on NW Natural’s affiliated companies for operations, management, staffing, and technical services. Some of these affiliate arrangements were approved recently, and in at least one case, the Commission granted a waiver from the rule that normally protects customers by requiring affiliates to charge the lower of cost or market price. If all of these systems are merged into Sunstone, it becomes much harder for customers and regulators to see whether we’re being charged fairly, because expenses from multiple systems and affiliates can be blended together under a single corporate entity. The companies claim that the merger will have “no customer impact,” but their own filings show otherwise. The merger and the new multi-system rate case are set to take effect on the same date, and the company has already stated it plans to consolidate rate structures afterward. These actions will directly affect the bills of Salmon Valley customers who have already experienced steep increases under NW Natural ownership. For these reasons, I respectfully ask the Public Utility Commission to deny the merger. If the Commission approves it, I urge strong protections for our community. These include requiring Salmon Valley’s financial information to remain separate for several years, limiting affiliate charges until a full review can occur, preventing any combining of rate structures unless the company proves bills for Salmon Valley customers will decrease, and prohibiting the company from passing merger-related costs onto customers, as the Commission has done in past NW Natural water cases. Residents of Welches rely on Salmon Valley Water for essential daily needs, and we deserve protection from unnecessary costs and corporate restructuring that offers little or no benefit to customers. Based on the evidence in the record, the merger into Sunstone Water primarily benefits NW Natural, not the people who pay the bills. 8
2/18/2026 6:46:38 PM	Oppose Docket	Tristy	Crislip	This increase will make it unaffordable to have basic necessities. The people in this community have had a long term commitment to living here and supporting our community. We don't want NW Naturals quest for money to destroy our affordability. I don't supporting your proposal. We have not used water or sewer for months are still paying the bill. I am looking for work. I can't afford anymore period.
2/19/2026 11:52:06 AM	General Comment	Todd	Ellis	Public Comment of proposed Utility rate change. Thank you for the opportunity to provide comment on this proposed rate increase. I am a resident of Welches, Oregon and a customer of Salmon Valley Water. After reviewing the application materials, I have a couple concerns I’d like to express and explain. 1) This application is seeking a total revenue increase of $1,482,941 and a rate of return for their investors of 7.864%. While they state this is based on cost of equity (10%) and cost of debt (4.66%) it doesn’t identify those two numerical values. The values may appear in the application, but it’s not obvious to the public. On page 13 of Matthew Rowell’s testimony he states Sunstone is 100% equity capital, which carries no debt. This may mean something to an expert, but when I read Sunstone carries no debt, I assume there is no debt. If there is debt, it should clearly identify the amount of debt and who is carrying that debt. This should be explained in detail and a new public comment period offered that affords an opportunity to have meaningful input. My fear is the entire $1,482,941 is going to this rate of return. Increases of this amount should only be entertained if the money is going toward capital expenditures like aging infrastructure that is mentioned numerous times in the application. I’m sure that application will be coming in the next couple years. 2) In several places in the application it states a rate of return is needed to attract investors. NW Natural holdings is a publicly traded entity that doesn’t “attract” investors, it has 43 million stockholders that each share currently receives $2/year - worth 86 million. NW Natural doesn’t profit or lose when shares are sold between stockholders. NW Natural made money on the initial IPO. What it does gain is value from the overall increase in market capitalization and control over the subsidiary's operational profits. Customers should not be paying higher rates to attract “investors” or pay stockholders. 3) In their calculations on page 9 of 17, under “other revenue deductions” account # 403, the depreciation expense is $644,266, with an adjusted value of $821,218. Depreciation is an accounting method used primarily for tax deductions from income, reducing tax obligations. This deduction should not be used when evaluating actual cost incurred, because it does not involve an actual cash outflow for the company like the other items do. This should be removed and new calculations submitted. This depreciation expense appears again in calculations in exhibit 103. 4) I would like to know why in the Salmon Valley Water applications submitted on 9-30-2020 and 2-27-2023, it was stated that there are 859 customers (2020) and 900 customers (2023). However, in this submission there are 674 “connections.” I understand a connection is a physical hookup at a property line and a customer is an entity responsible for paying for the water (which could own multiple connections). So how do you get more customers than connections? I’m assuming customers/connections have some significance in setting base rate (again, no calculations identified). By using customers it would add to the denominator and decrease the base rate. 5) If this proposed merger is approved, why are there three (3) rate schedules? The explanation I found said it’s because all would experience a 51% increase. That makes no sense when the largest number of “connections” are found in Schedule 3. Following that logic, Salmon Valley Water will pay disproportionate increases every time the rate is increased. And if we’re trying to level the playing field, if this proposal goes through as is, Salmon Valley Water “connections” will have incurred a 400% increase on base rate since 2022 ($20.23, $53, and $100 (proposed)). Additionally, the Salmon Valley Water water usage rate tripled from what customers paid in 2022. I could not find rate increases for any of the other water systems included in the merger in the last five (5) years. It seems for this and moving forward, if we all paid (in dollars) the same rate it would be more equitable. There is no differentiation in services or maintenance between the three; therefore, the cost structure should follow suit. 6) For future filings, all references within Q&A and testimony sections should include page citations. This would significantly improve transparency and allow meaningful public review. 7) All water systems in Oregon have the same infrastructure and replacement issues whether they are government- or privately-owned. The economies of scale afford little benefit for water systems. This is a limited comparison of very different populations and their base rates City base rate miles of pipe population per mile of pipe Operator Portland $24.6 2,250 333 city Salem $20.07
2/21/2026 2:26:55 PM	Oppose Docket	Peter	Himes	PUC, thank you for reading my concerns. I urge you to vote no on the Merger of 22 Water Companies owned by NW Natural Gas (aka: Sunstone Water, LLC). I am a customer of Salmon Valley Water in Welches, OR. All this merger would do is add to our costs to fix infrastructure in 21 other water companies. Salmon Valley/ NW Natural Gas gave us a large rate increase two years ago for infrastructure upgrades, so now they want to fix all these other water companies at our expense. Shared efficiencies is another fallacy, being none of the 22 water companies share a common geographic location. The only one that will benefit is NW Natural Gas. Bigger is not necessarily better! Please vote NO!!
2/21/2026 7:41:58 PM	Oppose Docket	Judi	Sandsness	We do not support this acquisition of Salmon Valley Water to go under the "umbrella" of Sunstone Water LLC. Corp. The rates are already too high for this small community and it is a hardship to many living within the Salmon Valley Water system. We had to put in a whole house water filtration system a few years ago because of ruined plumbing, clothes and appliances. Not everyone can afford to add this system to their home. And, even though we have a refrigerator filter system and the whole house filtration system, we buy bottled water. Salmon Valley needs to fix the problems with the already increased rates and not rates higher.
2/23/2026 1:50:49 AM	Oppose Docket	Peter	West	I don't support the merger. The community isn't getting what they are paying for up here. The rates have tripled already from the last rate increase and now just a few years later it'll go well over $100 for only water. Please investigate this company's history of negligence. There are people whose water is undrinkable and spending thousands for filtration systems. For me it does leave quite a bit of sediment in my hot water tank, that I need to stay on top of more frequently than should be needed. I have had issues with this company in the past and PUC helped with them charging me the wrong unit of measure with their new meter install.  During the big freeze in early 2024, my pipe burst and my water wouldn't shut off and their emergency number is a third party number that relays the message that isn't available 24/7 or I guess it is, but the water company wont respond until they open. There were supposed to be improvements I believe from the last rate increase, but I haven't seen any. There for I fear more of the same...more broken promises and just giving insane pay boosts to people sitting in chairs. This rate increase doesn't correlate with inflation either. The monthly payments for other bills are going up and we shouldn't have to pay so much for water only. All of these issues I've listed keep multiplying as this company continues to get bought out and merged with companies. Now we will be thrown into another group of companies and have to share the costs and the business will be less local and even more negligent on being efficient on improving things.
2/23/2026 12:49:16 PM	Oppose Docket	Paul	Crutcher	I'm a resident of Welches, OR, and customer of Salmon Valley Water. I oppose this merger. Todd Ellis in particular has done an excellent job outlining the issues with this merger in the comments he submitted, which I'm going to borrow from. 1) As Todd outlined, the filing states that the entities involved are already directly or indirectly under the umbrella of NW Natural Water, thus the proposed merger does not meaningfully change ownership or oversight. The application describe efficiencies for Salmon Valley Water or NW Natural Water, but do not demonstrate tangible, measurable advantages for rate payers. Most of the systems included in the proposed merger are located near Salem or Eugene. Given this geographic distance the concept of operational resource sharing appears impractical. It is unclear how customers in Welches would meaningfully benefit from consolidation with systems so far away. The potential risks and liabilities for Salmon Valley customers could be significant. 2) The application does not provide information regarding the condition of the other water systems involved or the capital improvements they may require. If consolidated, Salmon Valley customers could ultimately bear the cost of upgrades to infrastructure in distant communities. When Salmon Valley Water was acquired by NW Natural Water, we experienced a rate revision to fund upgrades to our own system. Those upgrades represent the only substantial capital expenditures customers have been made aware of during NW Natural’s seven years of ownership, and we continue to pay for them, which seems odd to me since the capital expenditures are one time expenses but the rate hikes are permanent and now there's a proposal to have an even larger increase! 3) Salmon Valley Water has historically operated as an independent system, and many customers value that independence. This proposal appears primarily designed to allow NW Natural Water to expand its customer base and distribute system-wide costs more broadly. That objective may serve the company’s interests, but it does not necessarily serve the interests of Salmon Valley ratepayers. The Oregon Public Utility Commission’s mission is to ensure that Oregonians have access to safe, reliable, and fairly priced utility services. Approving a merger that presents unclear benefits and potential financial risks to existing customers does not align with that mission. For these reasons, I respectfully urge the Commission to deny the proposed merger.
2/24/2026 9:34:13 AM	Oppose Docket	Peter	Himes	PUC, Please vote no on UP 439, the merger of 22 water utilities. I am a Salmon Valley Water customer in Welches, OR. I don’t see any advantage to our local utility for this merger. What I do see is a large corporation working on greater profits at expense of rural communities. NW Natural Gas under the guise of Sunstone Water, LLC should not be allowed to move forward. This Corporate entity also filed for a rate increase UW 209 at the same time as the Merger request. We had a large rate increase by NW Natural Gas just two years ago, enough please!
2/24/2026 9:46:52 AM	Oppose Docket	Maureen	Pelchar	The new merger that NW Natural is now applying for is not going un-noticed by the many water customers that will see huge price increases once again!! For this & the fact that too many people’s water has been murky ever since Salmon Valley water sold to NW Natural, I along with so many others I am opposed to seeing that move forward.
3/3/2026 5:43:56 PM	Oppose Docket	Mary	Bentson	As a resident of Welches, Oregon, and a Salmon Valley Water customer, I find it unconscionable that NW Natural Water Company is once again proposing yet another huge increase to our water bills, especially for water that is the worst I have even had in any neighborhood I have ever lived in. One would have expected that perhaps some profits from the previous rate increase by NW Natural might have been used to address the poor water quality, but that has not been the case. I sincerely hope that OPUC does their duty and protects Oregon residents from what look like predatory pricing practices on the part of NW Natural.
3/6/2026 11:29:00 AM	Oppose Docket	Jennie	Robinson	Dear Commissioners: I am a Salmon Valley Water customer in Welches, and I am deeply worried about what’s happening to our community. I understand that a merger is being proposed to combine Salmon Valley Water with several other NW Natural-owned water companies that are far removed from Welches. It is supposed to improve company efficiencies, and it may change things down the road. What it will do is double my water bill again, because UW 209 does that on the day the merger goes into effect, if approved. I don’t care who manages this system if I still can’t trust my water. Right now, today, what I need is for someone to look me in the eye and explain where my money went two years ago. What was fixed? What got better? Show me something real. The only outcome of this merger will be to enrich a greedy utility provider who is gobbling up every small Oregon water company they can and immediately increasing water rates. Before anyone approves a merger, I need answers. Not promises, answers. I need to see measurable improvements and a real plan. Welches residents have been patient, have been paying very high water rates, and have been hoping things would get better. We are all running out of patience. Sincerely, Jennie White
3/10/2026 2:07:35 PM	Oppose Docket	Kelly	Munger	I have reviewed the application (UP 439) UP 439 - Joint Application to Merge into Sunstone Water, LLC and object to the request. Upon review of the application, it appears the proposed merger will make it difficult if not impossible to for the customers of the individual water systems to evaluate any future Oregon PUC filing by the applicant in regards to the individual water system. If the applicant is able to aggregate the systems, it may not be possible for an individual water system's customers to request separate rate filings be confined to their system only. It it is unreasonable to expect a well run water system's subscribers to subsidize the operational costs of the owner's other less well run and geographically isolated water systems within the state just because the systems are merged. Coincidentally the applicant has petitioned the commission in a separate filing , see UW 209 filed December 31, 2025, a rate increase for many these geographically disparate water system. Is this an intentional effort by applicant to dampen the affect of future rate increase proposals away from the unrelated geographically isolated individual water systems to an amalgamated system that disregards the disparate financial impact of collective system ownership and management to the individual unrelated component system rate payers? Applicant's proposed merger is harmful to the individual component system's consumers and I urge the Commission to reject the proposal. Furthermore, it is my hope that the Commission directs applicant to make application requests specific to the individual component water system's owned and not of an amalgam of component water system's owned.
3/10/2026 2:09:30 PM	Oppose Docket	Kelly	Munger	I have reviewed the application (UW209) by Sunstone Water for rate revision for Illahe Water in Salem, Oregon and object to the request. Upon review of the application, it appears Illahe Water has been and an efficient run well managed system. This conclusion can not be made for many of the other systems included in application. The proposed rate increase appears be shifting system improvement costs from the less efficiently managed systems owned by applicant in the proposal to the well managed systems owned by applicant such as Illahe Water. It is not unreasonable to expect periodic rate increases for individual water system that take into account inflation, system upgrades inline with industry best practices and long term operation plans of the specific water system. However, it is unreasonable to expect well run water system's subscribers to subsidize the operational costs of the owner's other less well run and geographically isolated water systems within the state. Coincidentally the applicant has petitioned the commission in a separate filing , see Docket UP 439 filed December 31, 2025, to merge these geographically disparate water system within this rate increase proposal into a single system. Is this an intentional effort by applicant to dampen the affect of the proposed rate increase away from the unrelated geographically isolated individual systems to an amalgamated system that disregards the disparate financial impact of collective system ownership and management to the individual unrelated component system rate payers? Applicant's one size fits all proposed rate increase is unfair and harmful the individual component system's consumers and I urge the Commission to reject the requested rate increase proposed. Furthermore, it is my hope that the Commission directs applicant to make future rate application requests specific to the individual component water system's owned and not the amalgam of component water system's owned.
3/10/2026 4:01:33 PM	Oppose Docket	Dee	Duarte	The request by NW Natural Water to revise their rates would directly affect the bills of my neighbors and myself as Salmon Valley customers, who have already experienced steep increases under NW Natural Water ownership, after it filed a similar rate revision request with the OPUC in 2023. The proposed increase of rates seems disproportionate to the service provided. Additionally, the proposed rate increase comes on the heels of a general increase to the cost of living imposed by our current economic climate. Families that are already struggling to pay rent, buy groceries, put gas in their tank and pay healthcare premiums should not be faced with the additional burden of unaffordable water bills. Please protect our community and protect our livelihoods.
3/16/2026 10:48:50 AM	Oppose Docket	Carol	Hughes	(Resubmitting, originally posted 3/10/2026) I am submitting public comments about the proposed rate increase submitted by Sunstone Water, LLC. I am a Salmon Valley Water Company customer. The Public Utility Commission of Oregon has a commitment to maintaining the public interest and ensuring that utility services are provided in a fair and reasonable manner. I respectfully request that the Commission does NOT approve the rate increase for the following reasons: 1) Salmon Valley Water customers appear to be bearing the greatest financial impact without clearly understanding corresponding improvements in service. The rate increases for Salmon Valley Water customers do not appear fair, reasonable, or equitable. Please see the table titled “Bill Impact of Proposed Rates Summary” (page 113 of docket UW 209, which is Exhibit 108, page 1). For comparison’s sake, I am using the 5/8” service meter size from that table due to the largest number of connections for all the rate schedules that fall within that service meter size, except flat rate. Salmon Valley Water customers are within rate schedule 1, which shows a 66% increase, while rate schedules 2 (Shady Cove) and 3 (Sunstone & ICH) show 17% & 14% increase, respectively. And even less equitable, flat-rate customers would receive a decrease of 13%. In trying to find numerical support for the Salmon Valley Water 66% rate increase, I looked at Exhibit 104 (pg. 94 of docket) which is a table that shows Pro-forma Plant by account description and system. Adding up these projects and the purchase of a truck for Salmon Valley Water (rate schedule 1) they account for 25% of the total, while Shady Cove (rate schedule 2) accounts for 2% of the total, Sunstone & ICH, Lakeshore Water and South Coast Water (rate schedule 3) account for 51% of the total, and Seavey Loop and College Park (rate schedule 4) account for 21% of the total. While I know this information is only a piece of this puzzle, when Salmon Valley Water projects only account for 25% of the total, a 66% increase seems steep. And, to highlight, Sunstone & ICH accounts for 51% of this total, yet their rate increase is only 14%. Something seems off base. Exhibit 100 (pages 56 – 81) makes many statements supporting a consolidated corporate structure and consolidated rate structure stating that if the systems “were to embark on the capital investments on a stand-alone basis, the rate implications would be unmanageable. Without a consolidated rate structure, there are simply too few customers over which to spread the costs of necessary capital improvements.” The costs of capital investments on a stand-alone basis should be presented in this docket so that the Commission and the public have adequate evidence to compare the costs of a consolidated structure versus the costs of remaining under the current structure. 2) The evidence to support why rate schedule 1 (only applicable to Salmon Valley Water) base rate and usage rates are higher than the other systems is lacking for me to provide meaningful comments. I need to see the current base rates for each current legal entity (Salmon Valley, Sunstone, Lakeshore Water, South Coast Water, Seavey Loop Water and Sunstone Water (College Park) and compare those current rates to the proposed base rate. Again, Salmon Valley Water’s proposed base rate is the highest ($100) when compared to the other systems’ proposed rates which are $80 (rate schedule 2), $63 (rate schedule 3), and $76.23 (rate schedule 4, flat). Salmon Valley Water’s current base rate is $52.27 (information gathered from my monthly water bill and not the docket). That is an increase of $47.73/month alone in base rate (a 91% increase) for Salmon Valley Water customers. The docket shows current average monthly bill and proposed monthly bill, but that includes usage. Salmon Valley Water customers proposed usage rates are $ .642 for 0-10,000 gallons and $1.605 for usage over 10,000 gallons. And again, these are higher than the other rate schedules. Please see pages 25-31 of the docket for other rate schedules. 3) I do not know the criteria applied when determining “no harm”, but this rate increase can cause financial harm to many fixed and limited income Salmon Valley Water customers. Salmon Valley Water customers appear to bear the brunt as compared to the other companies proposed merging with Sunstone Water, LLC (docket UP 439), or the water systems currently in Sunstone Water, LLC.
3/23/2026 3:15:03 PM	Oppose Docket	Jan	Ostrom	I am writing with concerns regarding the merger and rate hike of Sunstone Water LLC and Salmon Valley Water. I am wondering how from a state point of view that your committee could consider allowing companies to merge and raise the water rates to local, rural communities. I realize this is happening all over our country, but in Oregon we tend to think differently. I understand inflation and the need to provide to ones stock holders, but we are just regular people here, many on fixed incomes that flat out can not afford a $100 water bill, nor should we have to. I have confidence that the employees of our state will look out for the citizens in a fair and legal manner.
3/24/2026 3:25:08 PM	General (Docket-Specific)	Peter	Himes	Please tie UP 439 Merger to UW 209 Rate Increase. These two relate to each other. I don’t understand why they were both filed at the same time. Shouldn’t the Merger happen before a Rate increase is proposed? Regards, Peter Himes Salmon Valley Water customer Welches, OR
3/24/2026 4:19:48 PM	Oppose Docket	JF	Robinson	Dear PUC Commissioners - I wish to reiterate a comment I made during the March 11, 2026, UW 209 public comment hearing. I NEVER received any notice about a "Merger" of NW Natural Holdings' new Sunstone Water LLC and the various small water companies affected. I only received a Sunstone notice of a rate increase filing under UW 209, and it claimed my "system" was "College Park", although I live in Welches and have been serviced by Salmon Valley Water Company. It also incorrectly stated the "Proposed Ave[sic] Monthly Bill" at $76.23. My bill is already at, or beyond, that amount. NW Natural should be required to start the merger UP 439 & rate hike UW 209 processes from the very beginning. ALL affected customers need to be properly informed in accordance with the laws and regulations. Respectfully, JF Robinson
4/2/2026 8:03:12 PM	Oppose Docket	Peter	West	I don't support the continued merging and selling out of Salmon Valley Water. I fear we will be pooled into a bigger group of customers to share costs and increase rates. I also don't want to be paying for data center's water usage by getting pooled into these bigger companies.