The link for comments.
http://www.kcc.state.ks.us/pi/public_comment.htmMy comments, FWIW,
Dear KCC,
Having just learned about the proposed rate increase yesterday, I have some concerns. The Westar website was not clear how the rates would change except that it is clear that the changes are not clear, even to someone like me, who has a master's degree in economics.
My concern is that the rate increases will be regressive, that they will impact the smallest users and the poorest people the most. It seems like they usually do. Looking at my utility bills for the last three years, I find that the rate went from $4 + .058/KWH (KiloWatt Hour) to $6 + .0593/KWH. I am sure that is not correct however, since rates per KWH usually decrease when usage is higher and I do not have a rate table.
However, based on this approximation, I can calculate the impact for various customers - one using 200 KWH per month, one using 1000, and one using 5000. Of course, this is an approximation again, since I, myself, have gone from 1488 KWH/month in July to 134 in September. Still, it is the average impact of an average month. The results follow:
usage ** old bill *** new bill *** % increase *** rate incr. alone
200 **** 15.6 ******* 17.86 ***** 14.5 ****** 16.2 (3.85%)
1000 **** 62.0 ******* 65.3 ***** 5.3 ****** 65 (4.84%)
5000 **** 294.0 ****** 302.50 ***** 2.89 ***** 309 (5.1%)
As the table shows, the small user bore a disproportionate share of the last rate increase. Their rate of inflation was five times as high as that of the larger customer. Furthermore, that method of increasing rates takes away from a customer's ability to lower their bills by cutting back on usage. Under the old rates 25% of their bill was fixed costs, and that rose to 33% under the new rates. My guess is that Westar is proposing to make it higher still. They should not be allowed to do so.
My table also shows that a simple equal increase in the KWH rate has a much more progressive impact. A 5.3% increase in the KWH rate impacts the small user a little bit less than the large user, and it also gives all users a larger financial incentive to be more efficient.
A rate increase need not have the largest impact for the smallest, and likely poorest, customers. If you look after the interests of the public and the interests of fairness and justice, you will insure that it does not.