On February 1, 2019, the California Water Association (CWA) filed comments with the State Water Resources Control Board (SWRCB) on the draft Options for Implementation of a Statewide Low-Income (LIRA) Water Rate Assistance Program (report), a program mandated by Assembly Bills 685 and 401. The report outlines possible components for developing a successful program to help low-income households pay their water bills.

CWA’s comments addressed options for the design, funding, and administration of a statewide LIRA program, based on the experience of its Class A water utility members that have had LIRA programs in their service areas for years.

CWA members are regulated by the California Public Utilities Commission (CPUC), which currently oversees LIRA programs for both regulated water and energy utilities. The letter supported discontinuing those programs if a single, statewide LIRA program is implemented, provided CWA members’ concerns about the program design and customer messaging can be addressed. CWA also supported a monthly benefit to eligible households calculated as a percentage of a fixed consumption level and agreed that further examination of a tiered design for households in high-cost areas is warranted provided administering a tiered system is not overly burdensome to implement.

To fund the statewide program, CWA agreed with a progressive personal income tax option, combined with a bottled-water tax, but only if the customer surcharge that funds the current CPUC LIRA programs is discontinued.

CWA supported administering the LIRA program by distributing the benefits in a single, consistent manner such as through an eligible household’s electric or gas bill since crediting water bills is unworkable for low-income households in multi-unit or multi-family dwellings that are not water utility customers. CWA considered the option of distributing the benefit through a food assistance program to be sub-optimal because of the associated administrative costs. CWA’s letter concluded with a request to correct Appendix C relative to how two of the Class A Water utilities’ LIRA programs are funded.


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