Docket Number	Docket Name	Company
UW 214	SUNRIVER WATER ALTERNATIVE RATE ADJUSTMENT	SUNRIVER WATER LLC

Created Date	Comment Type	First Name	Last Name	Comment
10/13/2026 12:36:40 AM	General Comment			To: Oregon Public Utilities Commission Attn: Administrative Hearings Division / Public Comments Subject: Public Comment for Docket UW 214 – Sunriver Water LLC (Advice No. 26-1) To the Public Utility Commission: I am writing as a property owner and utility customer in Sunriver, Oregon, to formally express serious concerns regarding Docket UW 214 (Sunriver Water LLC’s Alternative Rate Mechanism / Advice No. 26-1). Sunriver Water’s application for an alternative rate mechanism ("ARM") to recover the costs of a major capital addition—specifically the South Reservoir Replacement Project—through a new base rate tariff is unnecessary and places an unfair financial strain on the community. While utilities require sustainable revenue to maintain safe operations, any alternative rate mechanism or rate adjustment must strictly adhere to the statutory requirement of being "just and reasonable" under Oregon law, while fairly balancing the interests of customers who shoulder the entirety of the system's financial obligations. I urge the Commission to closely scrutinize this filing and address the following critical areas before granting approval: 1. Disproportionate Corporate Overhead and "Pass-Through" Costs Sunriver Water LLC relies heavily on shared services and centralized payroll passed through from its parent company, NW Natural Holdings. Previous operating reports (e.g., the 2023 Annual Results of Operations Report) have revealed over $1 million in NW Natural corporate payroll and administrative overhead passed through to a localized customer base of roughly 4,900 accounts without a markup. 1. The Staggering Financial Impact: When combining this $1 million corporate pass-through with local direct labor ($637,092 in salaries and $155,561 in benefits), total labor-related expenses reach roughly $1.8 million. With Total Operating Revenue of $2,423,270, this means nearly 75 cents of every dollar collected from water bills goes toward personnel and administrative overhead rather than physical infrastructure or water treatment. Furthermore, if the $1M pass-through already covers "Management" salaries, the additional $177k for "Management Services" may represent a duplication of charges that residents are paying for twice. 2. The Concern: Alternative rate mechanisms can sometimes streamline increases for utilities, but they risk insulating corporate overhead from rigorous review. The Commission must ensure that local ratepayers are not subsidizing corporate-level administrative expansion that bears little direct correlation to local service quality or efficiency. 2. The "Small-Pool" Burden and the South Reservoir Capital Crisis Sunriver is a unique master-planned community with a finite, localized base of roughly 4,900 residential customer accounts consisting of permanent residents, retirees, and vacation properties. Because the customer base is finite and localized, major capital additions—such as the South Reservoir Replacement Project proposed under this docket—cannot be absorbed by a vast metropolitan tax base and are distributed across a restricted pool of accounts. * The Affordability Squeeze: Dumping the high capital costs of a major infrastructure overhaul like the South Reservoir onto a restricted pool of roughly 4,900 accounts heavily impacts fixed-income full-time residents who are already burdened by high, unmetered fixed fees on the wastewater/environmental side of the community's utilities creates an acute affordability crisis for fixed-income, full-time residents. * Cumulative Impact: Alternative rate adjustments compound these pressures, heavily impacting fixed-income full-time residents who are already squeezed by heavy overhead allocations and unmetered fixed fees on the wastewater side of Sunriver's dual-utility ecosystem. Major plant and storage replacements must be scrutinized for phased timing, growth-related developer contributions (CIAC), and true necessity, rather than fast-tracked through an alternative mechanism that bypasses ordinary risk review. 3. Comprehensive Cost Transparency Before approving any alternative rate structure or new rate schedule under Docket UW 214, the Commission should require Sunriver Water LLC to provide: * A Complete Management Audit: This would require the utility to prove that $1M worth of "NW Natural employee time" is actually being spent on Sunriver's specific needs, rather than acting as an unscrutinized subsidy for the parent corporation's executive branch. * Operational Incentive Proof: Clear demonstration that the alternative mechanism will incentivize operational cost-control rather than acting as an automatic conduit for predictable, developer-adjacent cost inflation. * Equitable Allocation Verification: Clear verification that commercial, resort, and high-volume users are bearing their absolute equitable share of capacity costs for projects like the South Reservoir, rather than shifting the financial weight entirely onto residential customers. Thank you for your time, your oversight, and your commitment to protecting Oregon ratepayers. I request that this comment be entered into the official record for Docket UW 214. Sincerely, Robert Gamble 34 Fremont Crossing, Sunriver, OR 97707 those.gambles@gmail.com<mailto:those.gambles@gmail.com> 541-977-1740