In KRWC's rate increase application, it asked the PUC for a protective order to allow it not to identify the meters in the usage tables it provided. This is Kelly Pomeroy's request to the acting Consumer Advocate on the subject of access to water company information in general:
I urge you to ask the PUC to lift the protective order, which I believe is contrary to state law, and to ask KRWC to make available the meter information with lot identifiers in place.
No compelling case has been made to support the need for confidentiality which KRWC asserts. Since no public agency has shown concern about our projected demand vis-à-vis supply, this is something we need to monitor ourselves. That includes being able to tie consumption figures to actual development on each lot. For example, does low consumption indicate a frugal user, a windbreak with the house not yet started, a home under construction, or a leak on a lot with no activity?
And who is going to determine whether all uses are being properly charged? How do we know that the sudden spike in unmetered losses last year, up almost to 15% while all that watering has been going on in the new subdivision, really represents lost water that we should all have to chip in to cover?
HRS §92F-12(12) specifically says that "[W]ater service consumption data maintained by the boards of water supply" should be available for public inspection." In fact, the County Dept. of Water Supply allowed me to see meter readings for another area, upon request, and I believe this policy applies in many other places as well. If this is the case for government documents, why should it be different for a government-regulated utility?
HRS §92F-14 says that disclosure of a government record "shall not constitute a clearly unwarranted invasion of personal privacy if the public interest in disclosure outweighs the privacy interest of the individual." Again, why should our water company be different? With water as crucial a commodity as it is, and with so many questions about the water supply and service in the Kohala Ranch area, what personal privacy issue can be so important that it trumps the public interest?
The statute goes on to cite specific examples of information in which the individual has a significant privacy interest. They are: personal information relating to medical conditions, criminal investigations, eligibility for public assistance, certain personnel matters and employment history, finances, fitness to receive or keep a license, recommendations and evaluations, and Social Security numbers.
None of these apply in the case of water consumption, and KRWC has not made a case for why it's so important to keep meter identifications secret.
In addition to meter identifiers, I request ongoing access to operational data such as chloride counts, daily pumpage and consumption figures, details of any simultaneous pumping from both wells, fluctuations in water level in the wells and in the tanks. Such information is important to determining the health of our water supply and the adequacy of the physical plant and operations procedures.
No legitimate interest is served by withholding this information that is crucial to our well being. Who is going to monitor these things if we don't? The company is not going to warn us that there are serious questions about supply or the adequacy of the physical plant, or confess to inefficiencies or malfeasance.
They were not the ones who warned us that work on outfitting and hooking up Well #3 was overdue and we could run out of water at any time if the larger pump went down . The State Water Commission receives some well and pumpage information, but apparently it gets filed without any comprehensive analysis. They did not warn us of potential trouble, and no other agency is paying attention.
That was written before it was known that the fixed charges for a 1" meter were going up to $46 a month. One public benefit of being able to tie users to meters would have been to allow people with one-inch meters to get in touch with each other in order to more effectively oppose that aspect of the rate increase.
But neither the Consumer Advocate nor the PUC seemed to be influenced by public input on any issue except, perhaps, the tiered rate structure.