Subsequent to input provided at an August 30, 2018, California Public Utilities Commission’s (CPUC) public workshop, the first step in a CPUC initiative designed to increase public involvement in the Commission’s regulatory proceedings, the California Water Association (CWA) submitted informal written comments to the CPUC on September 13.

CWA emphasized that the best way to enhance public participation in CPUC proceedings is to ensure customers are well informed and do not receive confusing, unnecessarily repetitive, or conflicting notices. Additionally, CWA noted that interested parties and the CPUC should have an opportunity to respond to issues raised by the public, while weighing any efforts to enhance public participation against the CPUC’s legal obligation to base its decisions on the evidentiary record and with full consideration of the potential cost to customers of such efforts.

The letter explained that CPUC-regulated water utilities frequently engage in customer outreach and education about rates, drought management, conservation, and other issues that may be addressed in CPUC proceedings. Customers are engaged through open houses, public meetings, bill inserts, traditional media, and social media. CWA urged the CPUC to explore ways of improving the content, timing, and frequency of customer notices and suggested ways of increasing customer participation in CPUC proceedings

While recognizing the value of public input, CWA cautioned the CPUC against placing too much weight on public comments since they are not sworn testimony or subject to cross-examination and cannot be given the weight of evidence. CWA added that public comments, even if well intentioned, may mischaracterize the issues, misconstrue the facts, or rely on inaccurate information.

Finally, CWA urged the CPUC to consider ways to maximize the efficiency and cost-effectiveness of enhancing public participation in proceedings since water utilities must spread those costs over significantly smaller customer bases compared with energy utilities.

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