CWA Reiterates Statewide LICA Program Preference in CPUC Proceeding

On a separate and potentially parallel track with the State Water Resources Control Board’s (SWRCB) work, the California Public Utilities Commission (CPUC) is conducting a rulemaking on the CPUC’s Low Income Customer Assistance (LICA) programs. The primary objectives of the full Order Instituting Rulemaking 17-06-024 (OIR) are to:

• better understand the differences between the Class A water utilities’ LICA programs;
• evaluate whether consistency between the Class A water utilities’ programs is feasible and, if so, how such consistency can be attained;
• assess whether other water companies meet the definition of a public utility under the CPUC’s jurisdiction; and
• examine issues concerning affordability of clean, safe drinking water for low-income and disadvantaged communities, including greater pooling and consolidation.

In a filing submitted the same week as its comment letter to the SWRCB, the California Water Association (CWA) emphasized that the CPUC’s primary objective should be to balance the purpose and benefits of the programs against the burdens created to pay for and administer them – especially since those customers not eligible for assistance will bear the burden of additional costs in their rates to support the programs.

Additionally, CWA commented that the CPUC must consider the actions of government-owned utilities with respect to customer assistance programs to ensure the customers of CPUC-regulated utilities are not burdened with either the cost of overlapping subsidies funded by both a utility-administered program and a statewide program or with a customer-subsidized program in the case of the regulated utilities, vis-à-vis a statewide program, subsidized by taxpayer or other non-ratepayer sources.

In this regard, CWA requested that the CPUC refrain from making significant changes to the water utilities’ low-income programs until the Legislature acts on a statewide low-income program as contemplated under AB 401 (Dodd, 2015). With the SWRCB’s recommendations due to the Legislature by February 2018, CWA recommended the CPUC proceed in close coordination with its sister agency to avoid implementing changes that might generate customer confusion and expense, result in double-charging of CPUC-regulated water utility customers and necessitate duplicative (therefore expensive) billing system and administrative modifications.

After answering a series of questions on the mechanics of the current LICA programs, as well as additional questions on jurisdiction and treatment of water users who are not customers (e.g., renters), CWA reiterated the need for CPUC-regulated utilities to be part of a state-administered and financed program. In the absence of a statewide program, however, the CPUC-regulated utilities are, of course, prepared to continue with their current customer assistance programs.

CPUC-Regulated Water Utility LICA Programs