Letter: Rate Filing by Berkshire Gas Company
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To the Editor:
This is a testimonial letter submitted to the Public Utilities Commission:
Massachusetts Department of Public Utilities
Re: D.P.U. 25-170 – Rate Filing by The Berkshire Gas Company
To the Commissioners:
I write in unequivocal opposition to the rate increase proposed in D.P.U. 25-170 and, specifically, to challenge the excessive and unjustified return on equity (ROE) and capital structure assumptions embedded in this filing.
At its core, this case is not simply about infrastructure or cost recovery. It is about how much profit Berkshire Gas expects Massachusetts ratepayers to guarantee corporate interests regardless of economic conditions.
The requested ROE asks working families, seniors on fixed incomes, and small businesses to underwrite private shareholder returns that are insulated from the very market risks everyone else must bear.
That is not equitable, and it is not consistent with the Department's duty to ensure rates are just and reasonable.
A regulated monopoly is not entitled to premium-market returns without premium-market risk. Utilities operate with guaranteed customer bases, cost recovery mechanisms, and regulatory protections that dramatically reduce exposure compared to competitive enterprises. When risk is reduced, allowed return must follow. Anything else is a windfall at the public's expense.
If the proposed ROE exceeds what is necessary to attract capital under current economic conditions, then it is excessive. If the proposed capital structure overweights equity relative to debt in a way that inflates earnings, then it shifts avoidable cost onto customers.
Ratepayers should not finance a balance sheet designed to maximize shareholder yield rather than minimize consumer impact.
The Department must rigorously test:
- Whether the proposed ROE reflects actual capital market conditions or simply industry wish-list benchmarks;
- Whether the equity ratio is artificially high compared to comparable utilities;
- Whether risk factors cited by the company are already mitigated by regulatory mechanisms;
- Whether downward adjustments are warranted to reflect the company's low-risk, regulated status.
Every tenth of a percentage point in ROE translates directly into millions of dollars extracted from captive customers. This is not theoretical. It is real money coming out of household budgets in communities that are already stretched to the brink.
The responsibility of the Massachusetts Department of Public Utilities is not to preserve earnings targets. It is to protect the public from overreach. Approving an inflated ROE or an imbalanced capital structure would effectively compel residents to subsidize shareholder returns beyond what is reasonably required.
That would be a failure of regulatory discipline.
I urge the Department to substantially reduce any requested ROE to reflect true risk, require a capital structure that prioritizes affordability, and reject any element of this filing that places investor return ahead of consumer protection.
Before a single additional dollar is extracted from residents, the Department must also demand clear and compelling evidence that Berkshire Gas has:
- Exhausted all internal cost controls;
- Eliminated inefficiencies and unnecessary spending;
- Scrutinized executive compensation and significantly reduced administrative overhead;
- Minimized the financial impact on customers to the greatest extent possible.
If this increase is granted without aggressive examination and meaningful reductions, it will send a clear message that affordability is secondary to corporate earnings. That message would be deeply damaging to the public trust.
I demand that you reject this proposal in its current form and require substantial justification, transparency, and revision before any increase is even considered. The public deserves protection — not platitudes.
Ratepayers are not a blank check. They are the people you are charged with defending.
Respectfully,
Ashley Shade
City Council President
City of North Adams, Mass.
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