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CC SR 20210907 F - Cal Water 2021 GRCCITY COUNCIL MEETING DATE: 09/07/2021 AGENDA REPORT AGENDA HEADING: Consent Calendar AGENDA TITLE: Consideration and possible action to participate as a party in the Cal Water 2021 California Public Utilities Commission General Rate Case. RECOMMENDED COUNCIL ACTION: (1)Authorize the City Manager, or designee, to serve as a party in a proceeding for the California Water Service Company’s (Cal Water’s) General Rate Case with the California Public Utilities Commission (CPUC); (2)Direct Staff to serve and file a Motion for Party Status in the Application Proceeding (Application 21-07-002); (3)Authorize the Mayor to sign a letter to the CPUC offering McTaggart Hall at Hesse Park as a public hearing location; and (4)Direct Staff to publish information regarding the Cal Water ratemaking process on the City website to update residents as the General Rate Case progresses. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: McKenzie Bright, Administrative Analyst REVIEWED BY: Karina Bañales, Deputy City Manager APPROVED BY: Ara Mihranian, AICP, City Manager ATTACHED SUPPORTING DOCUMENTS: A.Draft Motion for Party Status (page A-1) B.Draft letter to the CPUC offering McTaggart Hall as a public hearing location (page B-1) C.Draft City of Rancho Palos Verdes Proposed Rate Calculator D.Cal Water 2021 General Rate Case (filed July 1, 2021) E.Palos Verdes Tariff Area 2021 proposed rates (Page E -1) F.April 20, 2021 staff report reviewing Cal Water’s 2021 rate increase G.June 1, 2021 staff report authorizing participation in Cal Water’s 2021 Cost of Capital Application H.Correspondence between the City and the CPUC regarding Cal Water rates (page H-1) 1 CITYOF RANCHO PALOS VERDES BACKGROUND AND DISCUSSION: Every three years, California Water Service (Cal Water) is required to submit an Infrastructure Improvement Plan to the California Public Utilities Commission (CPUC), including all rate changes, to ensure water rates accurately reflect the costs of providing safe, reliable water service.1 In this General Rate Case (GRC) process, the CPUC sets rates to cover the costs of providing service. Major costs to operate a water system include but are not limited to capital projects, purchased electric power, purchased water, labor, and chemicals. Cal Water submitted its 2021 General Rate Case (GRC) application on July 1, 2021, which, if approved, would affect all Cal Water ratepayers from 2023-2025. In its application, Cal Water proposes to replace 27,000 feet of water main to prevent failure of aging and high-risk pipelines; meter, control valve, tank and pump retrofits and replacements to increase system reliability; system improvements related to wildfire preparation to ensure that a reliable source of water and adequate fire protection is consistently available; and safety upgrades at facilities to enhance security measures and reduce vulnerability. According to Cal Water, the proposed rate increases are needed to fund these improvements as well as routine costs. If Cal Water’s proposal is approved by the CPUC as submitted, it is anticipated to increase the average residential customer’s bill by approximately $2.64 or 2.5% per month. The average residential customer in Rancho Palos Verdes has a 5/8” x 3/4" meter, using 15 CCF (one-hundred cubic feet), or 11,221 gallons of water per month. The table below illustrates the proposed changes to service charges, assessed based on the two most common residential meter sizes and quantity rates (tiers). Table 1: Proposed Change in Cal Water Residential Rates in RPV2 Current Rate Proposed Rate Percent Change Service Charge: 5/8” Meter $31.78 $39.42 24% 1” Meter $79.45 $98.56 24% Quantity Rates ($/ccf): Tier 1 (1-6 CCF) $4.9799 $1.6598 -67% Tier 2 (7-17 CCF) $4.9799 $6.6380 33% Tier 3 (18-25 CCF) $6.2276 $8.2974 33% Tier 4 (25+ CCF) $9.3539 $12.4459 33% 1 In July 2020, Cal Water filed Advice Letter No. 2387 for the cost recovery of the Palos Verdes Peninsula Water Reliability Project (project) and rates resulting from the project took effect on January 1, 2021. The advice letter was the result of a 2018 GRC Settlement Agreement negotiated between Cal Water and the Public Advocates Office where the parties agreed to remove the project cost from the 2018 GRC proceeding and require that Cal Water file for recovery upon the project entering service (project entered service August 27, 2020) through an advice letter. This increase was the subject of the April 20, 2021 Council agenda item (see Attachment F). 2 Actual rates may vary. The CPUC and the California Public Advocates Office (Cal Advocates) evaluate proposals and may make recommended changes, a decision is expected in November 2022. 2 Water bills are a function of the service charge and quantity rates at each usage level – a typical resident using 15 CCF will have their first 6 CCF charged at the Tier 1 quantity rate and the remaining 9 CCF at the Tier 2 quantity rate. Therefore, regardless of total usage, all residential customers benefit from the reduced Tier 1 (the first 6 CCF used). On May 12, 2021, the City sent a letter to the CPUC, encouraging the reevaluation of the cost structure to remove unfair burdens on both low-usage ratepayers and ratepayers with large families that may be unfairly impacted by ultra-increased rates in response to the 2018 GRC (see Attachment H). In the previous rate cycle, tiers had a variable increase where Tier 1 increased by 5%, Tier 2 increased by 2 3%, and Tier 3 increased by 55%. The City specifically requested a transition of the cost burden from service charges to tier usage, expansion of water rate tiers, enhanced transparency regarding tier assignments, and establishment of a tier reclassification process tied to a customer’s individual annual water usage. Cal Water’s proposed 2021 GRC incorporates some of these suggestions, and the proposed changes address the need for adjustments for both low-usage and high-usage users. Across all service areas, Cal Water has introduced a new low -usage tier with a discounted unit rate for all residential customers, with the first 6 CCF of water usage per month at a greatly reduced rate than previously existing tiers. The CPUC considers 6 CCF as essential for basic needs. Additionally, rather than a stepped increase at the higher tier levels, such as the method approved in the 2018 GRC, quantity rates for Tiers 2-4 each increased by 33%, resulting in both a smaller increase for low-usage and high- usage ratepayers than seen during the 2018 GRC. Service Charges Service charges are a factor of readiness-to-service, to the cost to essentially have the water supply available for the moment the tap is turned on. The proportion of the service charge, or the difference between meter sizes, is a direct correlation of the maximum outflow capacity of the meter. This report focuses on 5/8” and 1” meters because they are the most common residential meter. The service charge for a 1” meter is 2.5 times greater than a 5/8” meter due to the greater maximum outflow capacity of the 1” meter. The allocation of service charges for the various meter sizes are calculated based on the CPUC’s Standard Practice Manual U-7-W3, which directs water utilities to spread the service charge over the meter sizes in proportion to the maximum capabilities of the meters themselves to handle flows. To provide background on the maximum outputs of meters, a 5/8” meter has a maximum flow rate of 20 gallons of water per minute, and a 1” meter has a maximum flow rate of 50 gallons per minute. As a utility, Cal Water is required to deliver up to the maximum capabilities of every meter in their system, whether or not the tap is on. If a customer has a bigger meter, there is increased water flow, and as a result, there are associated higher costs to handle and meet those higher demands. Utilities must have appropriately sized water lines (or may need to upsize their water lines) 3 See CPUC Standard Practice Manual U-7-W; Rate Design for Water and Sewer System Utilities Including Master Metered Facilities, pages 4-7 3 to accommodate customers’ demand and fire flow requirements to keep the water system reliable and available 24 hours per day, 365 days per year. Part of the fixed costs associated with this requirement are captured in the service charges. The City’s proposed service charge increase of 24% is among the smallest increases proposed in the 2021 GRC, across all Cal Water’s tariff regions.4 Service charges in different tariff areas, even within the Cal Water system, can fluctuate greatly due to the relative cost of the water. Rancho Palos Verdes does not have any groundwater reserves, and all water is purchased and must be pumped uphill, making readiness-to-service relatively more expensive compared to other tariff areas. Therefore, despite the minimal increase, the Palos Verdes tariff area service charge remains among the most expensive, following only the Dixon, Oroville, and Willows tariff areas. Proposed Bill Changes With the 2021 GRC as currently proposed, RPV ratepayers could see anywhere from a 20% decrease to a 33% increase in their monthly bill, depending on meter size and water usage. The table below illustrates (for example purposes only) proposed bills for ratepayers at three usage levels, holding water usage constant. Table 2: Proposed RPV Bills, Based on Water Usage and Meter Size Water Usage Meter Size Current Monthly Bill Proposed Monthly Bill Percent Change Low-usage (6 CCF) 5/8”x3/4” $61.66 $49.38 -19.92% Low-usage (6 CCF) 1” $109.33 $108.52 -0.74% Average (15 CCF) 5/8”x3/4” $106.48 $109.12 2.48% Average (15 CCF) 1” $154.15 $168.26 9.16% High-usage (30 CCF) 5/8”x3/4” $213.03 $251.01 17.83% High-usage (30 CCF) 1” $260.70 $310.15 18.97% Staff has prepared an interactive calculator for residents to input their current water usage and see their estimated proposed bill change, based on the 2021 GRC proposed rates (see Attachment C). This calculator will be updated as changes are made to the rate case and once a decision is reached. The Ratemaking Process The six steps in the rate case process are as follows: 1. Cal Water reviews its historical costs, projected costs, and planned water system improvements and prepares a GRC application for the consideration of the CPUC staff. 2. The California Public Advocates Office (Cal Advocates) analyzes Cal Water’s application and makes a recommendation. Cal Advocates usually recommend a smaller increase than that requested by the utility. 4 The 24% increase in service charge is true for all meters in the Palos Verdes tariff area. Se e Attachment E for proposed rates for all meter sizes. 4 3. The CPUC hosts Public Participation Hearings (PPH) to receive input from customers on the application. Customers may also write to the CPUC. 4. The CPUC holds a formal hearing presided over by an Administrative Law Judge (ALJ), which is similar to a court proceeding. 5. The ALJ issues a proposed decision. 6. The CPUC Commissioners vote on the proposed decision. New rates typically become effective five days later. The entire process can take 18 months or more. City Participation in the 2021 General Rate Case Through its correspondence with Cal Water and the CPUC, the City has stated its intent to file a motion to be a party in 2021 GRC and is currently a party in the 2021 Cost of Capital Case (see Attachments F, G, and H). The City was informed that its concerns regarding the 2018 GRC would be forwarded to the appropriate Commissioner’s office and ALJ when the 2021 GRC was filed. Participation in the 2021 GRC ensures the City has adequate notice and opportunity to respond to issues, claims, and arguments that may be raised during the proceedings. The City has a direct interest in protecting its constituents by ensuring the continuation of the most cost-effective and deliverable water supply, and in ensuring the various components of the overall water supply system on the Palos Verdes Peninsula are effective and adequately reflect the public’s needs and wishes. Public participation hearings are scheduled for September to November 2021. Testimony will be served by Cal Advocates and other Parties through February, with Cal Water expected to provide testimony in March 2022. Negotiations will continue through 2022, with a decision expected to be authorized by the CPUC in November 2022 for rates effective January 1, 2023. Public Participation Hearing Locations In preparation for this report, Staff met with Cal Water representatives who shared that the CPUC hosts remote Public Participation Hearings (PPH). While the ultimate decision of where to locate the hearing is up to the CPUC, Cal Water has requested that one of the PPH be held in the Palos Verdes Peninsula, due to the high level of resident engagement and recent Palos Verdes Peninsula Water Reliability Project. In conjunction with this, Staff is recommending the City Council authorize the Mayor to sign a letter to the CPUC offering McTaggart Hall at Hesse Park as a potential location for a public hearing (see Attachment B). ADDITIONAL INFORMATION: On August 5, 2021, Cal Advocates, an independent organization within the CPUC that advocates on behalf of utility ratepayers, filed a protest to Cal Water’s application. This protest includes identifying issues that need further review, including whether proposed rate increases are reasonable and justified, whether estimates of expenses are reasonable, and whether the proposed rate designs are just and reasonable. In particular 5 to the Palos Verdes tariff area, Cal Advocates will review and analyze whether Cal Water requests to open a memorandum account to track certain costs associated with the Palos Verdes Peninsula Water Reliability Project that exceed the amount already authorized in rates, including legal or other costs, is reasonable. CONCLUSION: As currently proposed, beginning on January 1, 2023, the average residential customer using 15 CCF with a 5/8” x 3/4" meter in Rancho Palos Verdes will see their service charge (which is one component of the bill) increase by 24%, with the overall bill seeing a $2.64 or 2.5% per month increase. While the City issued a formal protest to the rate increase proposed in the 2021 Cost of Capital application, Staff recommends the City Council instead consider a motion for party status with the GRC, as any protests will be covered by the one already issued by Cal Advocates and the deadline for submitting a formal protest has passed. In order to participate as an advocate for Rancho Palos Verdes ratepayers and to ensure they are receiving and safe and reliable service at low costs, Staff recommends the City Council authorize the City Manager, or designee, to become a party in the proceeding for Cal Water’s 2021 GRC, to advocate on behalf of residents, and direct Staff to serve and file a Motion for Party Status, as drafted or with revisions. Becoming a party ensures the City receives all information provided during the ratemaking process, which can educate and/or advocate for residents. Staff recommends that the City Council authorize the Mayor to sign a letter, as drafted or with revisions, offering Hesse Park as a location to host a public hearing in the course of the 2021 GRC, to provide greater access for Rancho Palos Verdes customers to the ratemaking process. It is also recommended the City Council direct Staff to publish materials related to the 2021 GRC on the City website to help educate ratepayers about the process and anticipated rate increases. ALTERNATIVES: In addition to the Staff recommendation, the following alternative action s are available for the City Council’s consideration: 1. Do not seek party status for the GRC. 2. Identify revised language to add to the letter. 3. Do not authorize the Mayor to sign the letter offering McTaggart Hall as a public hearing location. 4. Take other action, as deemed appropriate. 6 1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA MOTION FOR PARTY STATUS OF THE CITY OF RANCHO PALOS VERDES William Wynder Aleshire & Wynder, LLP 1881 Von Karman Ave., Suite 1700 Irvine, CA 92612 Telephone: 310-527-6667 E-mail: wwynder@awattorneys.com September 7, 2021 Attorneys for the City of Rancho Palos Verdes In the Matter of the Application of California Water Service Company (U-60-W), a California corporation, for an order (1) authorizing it to increase rates for water service by $80,484,801 or 11.1% in test year 2023, (2) authorizing it to increase rates on January 1, 2024 by $43,582,644 or 5.4% January 1, 2025 $43,197,258 or 5.1% in accordance with the Rate Case Plan, and (3) adopting other related rulings and relief necessary to implement the Commission’s ratemaking policies. Application 21-07-002 Filed July 1, 2021 A-1 2 MOTION FOR PARTY STATUS OF THE CITY OF RANCHO PALOS VERDES I. Introduction The City of Rancho Palos Verdes (“City”), respectfully moves for party status in this proceeding in accordance with Section 1.4 of the California Public Utilities Commission (“Commission”) Rules of Practice and Procedure. II. Interest in this Proceeding The City of Rancho Palos Verdes is a general law city, located in Los Angeles County on the Palos Verdes Peninsula, with water service for all residents and businesses within the City provided by the California Water Service Company (“Applicant”). A. The City requests party status in this proceeding to ensure the CPUC is informed of the interests of the City, and all its citizens, that may be affected by this proceeding, and to ensure the City has adequate notice and opportunity to respond to issues, claims and arguments that may be raised by any party in the course of this proceeding. B. The City has a direct interest in protecting its constituents by ensuring continuation of the most cost-effective and deliverable water supplies. In addition, the City has a direct interest in ensuring the various components of the overall water supply system on the Palos Verdes Peninsula are effective and adequately reflect the public’s needs and wishes. To these ends, the City promotes a full and balanced consideration of perspectives and a comprehensive analysis of cost-effective service. III. Notice Service of notices, orders, and other correspondence in this proceeding should be directed to the City at the address set forth below: William Wynder, City Attorney Ara Mihranian Aleshire & Wynder, LLP City Manager 1881 Von Karman Ave., Suite 1700 30940 Hawthorne Blvd. Irvine, CA 92612 Rancho Palos Verdes, CA 90275 Tel: 310-527-6667 Tel: 310-544-5202 E-mail: wwynder@awattorneys.com E-mail: aram@rpvca.gov A-2 3 IV. Conclusion For the foregoing reasons and pursuant to Rules 1.4 and 11.1, Rancho Palos Verdes respectfully requests that the CPUC grant this Motion for Party Status filing. Dated: September 7, 2021 Respectfully submitted, __ ___________________ William Wynder Aleshire & Wynder, LLP 1881 Von Karman Ave., Suite 1700 Irvine, CA 92612 Attorneys for the City of Rancho Palos Verdes A-3 September 8, 2021 Via Email The Honorable Marybel Batjer C/O Terence Shia, Water Division Director California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 SUBJECT: Proposition of Facilities for Public Participation Hearing of Cal Water 2021 General Rate Case (A. 21-07-002) in Rancho Palos Verdes Dear President Batjer and Director Shia, Following the recent filing of Cal Water’s 2021 General Rate Case (GRC) (A.21 -07-002), the City of Rancho Palos Verdes would like to offer a facility to host a Public Participation Hearing (PPH) on this case. McTaggart Hall at Hesse Park, located at 29301 Hawthorne Boulevard, Rancho Palos Verdes serves as the City’s Council Chambers, can host up to 150 guests, and is equipped for teleconferencing over virtual platforms. The City of Rancho Palos Verdes is located in the Cal Water’s Palos Verdes Tariff Area, recently separated for the cost recovery of the Palos Verdes Peninsula Water Reliability Project (as decided in D.20-12-007). The City has a high level of resident engagement concerning water rates and hosting a PPH in the City will allow ratepayers in the Palos Verdes region to directly engage in the public hearing process to help the CPUC reach an informed decision on Cal Water’s proposed rate increase. The City looks forward to working with the CPUC to host a PPH. Should you or your staff require any further information regarding McTaggart Hall, or any other City facilities, please contact City Manager Ara Mihranian at 310-544-5202 or aram@rpvca.gov. Thank you for considering this request. We appreciate your considerable efforts to ensure that ratepayers have access to safe, reliable, and affordable drinking water. Sincerely, Eric Alegria Mayor, City of Rancho Palos Verdes B-1 ERI C A LE GR IA, MAYOR D AV ID D. BRADLEY, M AYOR PRO TEM JOHN CRU ll<SHAN I<, COUNC ILMEMBER l(E N DYDA, COUNC ILMEMBER BARBARA FERRAR O, COUNC IL MEMBER President Batjer and Director Shia September 8, 2021 Page 2 cc: Public Advisor’s Office, via public.advisor@cpuc.ca.gov Asia Powell, Local Government and Community Liaison, California Public Utilities Commission Rancho Palos Verdes City Council and City Manager Angie Gilbride, Cal Water Regional Community Affairs B-2 CALIFORNIA WATER SERVICE COMPANY 1720 North First Street San Jose, CA 95112 (408) 367-8200 Revised Cal. P.U.C. Sheet No. XXXXX-W Cancelling Cal. P.U.C. Sheet No. 12475-W Schedule No. PV-LAR-1-R Page 1 Palos Verdes Tariff Area (Los Angeles County Region) RESIDENTIAL METERED SERVICE (Continued) (To be inserted by utility) Issued By (To be inserted by CPUC) Advice Letter 2021 GRC July Filing Greg A. Milleman Date Filed Decision Vice President Effective Resolution APPLICABILITY Applicable to all metered water service provided to single-family residential customers. TERRITORY Palos Verdes Service Area: Palos Verdes Estates, Rolling Hills, Rolling Hills Estates, Lomita, Rancho Palos Verdes, and vicinity, Los Angeles County. RATES 1 CCF is 100 cubic feet (748 gallons) Quantity Rates: For 1 - 6 CCF, per CCF $1.6598 For 7 to 17 CCF, per CCF $6.6380 For 18 to 25 CCF, per CCF $8.2974 For over 25 CCF, per CCF $12.4459 Service Charge: Per Meter Per Month For 5/8 x 3/4 - inch meter$39.42For 3/4 - inch meter$59.14For Fire Sprinkler with 1 - inch meter$40.60For 1 - inch meter$98.56For 1-1/2 - inch meter$197.10For 2 - inch meter$315.36For 3 - inch meter$591.30For 4 - inch meter$985.50For 6 - inch meter$1,971.00 For 8 - inch meter$3,153.60 For 10 - inch meter$4,533.30 For 12 - inch meter$6,504.30 For 14 - inch meter$8,869.50 The service charge is a readiness-to-serve charge which is applicable to all metered service and to which is added the charge for water used computed at the quantity rates. (C) (R)(C) (R)(C) (R)(N)(I) | | | | | | | | | | | (I) 2021 GRC Application, Attachment F (Proposed Tariffs), Page 94 94 / 130 94 / 130 E-1 CALIFORNIA WATER SERVICE COMPANY 1720 North First Street San Jose, CA 95112 (408) 367-8200 Revised Cal. P.U.C. Sheet No. XXXXX-W Cancelling Cal. P.U.C. Sheet No. 12474-W Schedule No. PV-LAR-1-R Page 2 Palos Verdes Tariff Area (Los Angeles County Region) RESIDENTIAL METERED SERVICE (To be inserted by utility) Issued By (To be inserted by CPUC) Advice Letter 2021 GRC July Filing Greg A. Milleman Date Filed Decision Vice President Effective Resolution SPECIAL CONDITIONS 1. Qualifying low-income individually metered residential customers are eligible for credits as shown on Schedule CAP.2. All bills are subject to the following tariff schedules: Schedule UF (CPUC reimbursement fee) and applicable surcharges and surcredits on Schedule RSF (Rate Support Fund), Schedule CAP (Customer Assistance Program), and Schedule AS (Additional Surcharges and Surcredits).3.Fire sprinkler rate: A single-family residence with a meter size that has a “fire sprinkler” rate (listed above) is eligible for that rate if: (a) the customer is paying for service where a residential fire sprinkler system is required/requested to be installed by local fire or building codes; (b) a smaller meter would be large enough to provide adequate service in the absence of the additional demand needed to supply water to the system; (c) the sprinkler system is served through the meter providing residential water service; and (d) the customer requests the “fire sprinkler” rate. The Company may seek verification that the above criteria are met. This service will be considered a general metered service, and not a fire service, so the rules and conditions for general metered service shallapply.(T) (T) 2021 GRC Application, Attachment F (Proposed Tariffs), Page 95 95 / 130 95 / 130 E-2 CALIFORNIA WATER SERVICE COMPANY 1720 North First Street San Jose, CA 95112 (408) 367-8200 Revised Cal. P.U.C. Sheet No. XXXXX-W Cancelling Cal. P.U.C. Sheet No. 12473-W Schedule No. PV-LAR-1-NR Page 1 Palos Verdes Tariff Area (Los Angeles County Region) NONRESIDENTIAL METERED SERVICE (Continued) (To be inserted by utility) Issued By (To be inserted by CPUC) Advice Letter 2021 GRC July Filing Greg A. Milleman Date Filed Decision Vice President Effective Resolution APPLICABILITY Applicable to all metered water service except that provided to single-family residential customers. TERRITORY Palos Verdes Service Area: Palos Verdes Estates, Rolling Hills, Rolling Hills Estates, Lomita, Rancho Palos Verdes, and vicinity, Los Angeles County. RATES 1 CCF is 100 cubic feet (748 gallons) Quantity Rates: Per CCF $7.3047 Service Charge: Per Meter Per Month For 5/8 x 3/4 - inch meter$34.57For 3/4 - inch meter$51.86For 1 - inch meter$86.43For 1-1/2 - inch meter$172.85For 2 - inch meter$276.56For 3 - inch meter$518.55For 4 - inch meter$864.25For 6 - inch meter$1,728.50 For 8 - inch meter$2,765.60 For 10 - inch meter$3,975.55 For 12 - inch meter$5,704.05 For 14 - inch meter$7,778.25 The service charge is a readiness-to-serve charge which is applicable to all metered service and to which is added the charge for water used computed at the quantity rates. SPECIAL CONDITIONS 1. All bills are subject to the following tariff schedules: Schedule UF (CPUC reimbursement fee) and applicable surcharges and surcredits on Schedule RSF (Rate Support Fund), Schedule CAP (Customer Assistance Program), and Schedule AS (Additional Surcharges and Surcredits). 2. Qualifying non-profit group living facilities, agricultural employee housing facilities, and migrant farm worker housing centers are eligible for credits as shown on Schedule CAP.(R) (I) | | | | | | | | | | (I) (T) (T) 2021 GRC Application, Attachment F (Proposed Tariffs), Page 96 96 / 130 96 / 130 E-3 May 12, 2021 Via Email The Honorable Marybel Batjer and Commissioners California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 Elizabeth Echols, Director Public Advocates Office 505 Van Ness Avenue San Francisco, CA 94102 SUBJECT: Rancho Palos Verdes Concerns Over Cal Water Rates for Residential Ratepayers Dear President Batjer, CPUC Commissioners, and Director Echols, On behalf of the residents and City Council of the City of Rancho Palos Verdes, I am writing to express our concerns over the recent substantial increase in service charges for residential ratepayers imposed by the California Water Service Company (Cal Water) in the Palos Verdes service area of the Rancho Dominguez District. On December 3, 2020, the California Public Utilities Commission (CPUC) approved Cal Water’s General Rate Case for 2020-2022, and residents began seeing the related increases to their water bills during the February billing cycle. The approved rate increase incorporated the fees associated with Cal Water’s recently completed $96 million Palos Verdes Peninsula Water Reliability Project. This project added seven miles of new drinking water pipeline for customers on the Palos Verdes Peninsula and added a new pump station. As a result, customers’ service charges increased by 50%, and tier usage rates increased by 5% for Tier 1, 23% for Tier 2, and 55% for Tier 3. While the City appreciates the work by the CPUC and the Public Advocates Office (Cal PA) to review, analyze, and approve the recent Cal Water General Rate Case, we are concerned that the substantial increase in service charges unfairly penalizes customers for the readiness-to-service charge. Of particular concern to residents is the significant service charge associated with a 1” meter. Residents in Rancho Palos Verdes most likely did not have a choice in their meter size and may not have considered the H-1 CITY OF RANCHO PALOS VERDES President Batjer, CPUC Commissioners, and Director Echols May 13, 2021 Page 2 financial implications of having a larger meter. We would therefore like to formally express our concerns over the substantial increase in water bill rates, on behalf of Rancho Palos Verdes ratepayers. The City recognizes that the rate setting process has ended, and that Cal Water anticipates starting its 2023-2025 General Rate Case in the summer. The City anticipates participating in this process as an intervenor to better protect the interests of Rancho Palos Verdes ratepayers. We understand that many considerations go into approving new rates for private utility companies, and appreciate the time, effort, and advocacy that occurred as part of the 2020-2022 General Rate Case. As the new cycle begins for Cal Water, we encourage the CPUC and Cal PA to reevaluate how costs like the Palos Verdes Water Reliability Project are borne by residential ratepayers. To that effect, for the next rate increase hearings, we propose the following recommendations aimed at alleviating the significant rate increase associated with the completion of the Palos Verdes Peninsula Water Reliability Project for residential ratepayers: • Transition of cost burden from service charges to tier usage. Transitioning some of the service charge cost to the tier usage may help encourage conservation and minimize financial penalties to residents with a 1” meter. • Expansion of water rate tiers – increasing the number of tiers from three to five for single-family residential customers may provide a more equitable distribution of recovery costs for the Palos Verdes Peninsula Water Reliability Project based on a ratepayer’s water usage. • Enhanced transparency regarding tier assignments and establishment of a tier reclassification process that is tied to a customer's individual annual water usage. Thank you for your continued efforts to ensure Californians’ access to safe and reliable utility infrastructure and services at low ratepayer costs. We understand that the recently approved Cal Water General Rate Case underwent a rigorous review process, but we, on behalf of Rancho Palos Verdes ratepayers, believe there may be other rate options available to distribute the costs of the Palos Verdes Water Reliability Project more equitably across ratepayers, while promoting conservation efforts. The City looks forward to being an intervenor and active participant in the next Cal Water General Rate Case cycle, to ensure that Rancho Palos Verdes residents have safe, reliable, and low-cost water. H-2 President Batjer, CPUC Commissioners, and Director Echols May 13, 2021 Page 3 Sincerely, Eric Alegria Mayor, City of Rancho Palos Verdes cc: Rancho Palos Verdes City Council Ara Mihranian, City Manager Karina Bañales, Deputy City Manager Angie Gilbride, Cal Water Regional Community Affairs H-3 300 CAPITOL MALL, 5TH FLOOR • SACRAMENTO, CALIFORNIA 95814 505 VAN NESS AVENUE •SAN FRANCISCO, CALIFORNIA 94102 June 14, 2021 Mayor Eric Alegria City of Rancho Palos Verdes 30940 Hawthorne Blvd. Rancho Palos Verdes, CA 90275 RE: Response to May 12, 2021 Letter regarding Residential Rates in Cal Water’s Palos Verdes District Dear Mayor Alegria and the City of Rancho Palos Verdes, Thank you for your May 12 letter which raises concerns regarding California Water Service Company’s (Cal Water) rate increase in the Palos Verdes District associated with Cal Water’s previously approved General Rate Case (GRC) and the associated Palos Verdes Peninsula Water Reliability Project (PVPWRP). Your concerns address the increase in service charges adopted in rates and the rate increase implemented as a result of including the costs for the PVPWRP in rates. As you are aware, the changes in rates reflect the adopted rate design authorized in December by Decision (D.) 20-12-007 in Cal Water’s previously approved GRC proceeding. Also included in this rate increase are the rate impacts of the PVPWRP, which added $96 million in capital costs. Both of these rate impacts were made effective in rates in February 2021. Additional factors in D.20-12-007 impacting rates include adjustments in the revenue allocation between the service charges and quantity rates and the break points between residential quantity rate tiers. For revenue allocation, Cal Water initially requested to shift the ratio for all its districts to a 40% service charge and a 60% quantity rate revenue allocation in order to better recover the higher fixed costs versus variable costs of providing water service and to provide increased revenue stability. The Public Advocates Office stated their concerns that the significant increase in service charges could lead to greater H-4 MARYBEL BATJER PRESIDENT PUBLIC UTILITIES COMMISSION STATE OF CALIFORNIA TEL : (916) 823-4 8 4 0 WWW .CPUC .CA .GOV Mayor Eric Alegria June 14, 2021 Page 2 water usage and less conservation. Ultimately, a settlement was reached between the two parties, and for the Palos Verdes District, the ratio changed from a 22% service charge and 78% quantity rate to a 25% service charge and 75% quantity rate revenue allocation. This was one of the contributing factors in the increases applied to service charge rates, but this outcome from the settlement is significantly lower than what Cal Water requested. Regarding the residential tier breakdowns adopted in D.20-12-007, Cal Water updated their rate design model that was originally adopted in D.08-02-036 1 and uses more recent sales data. The updated model assigns Tier 1 quantity rate usage as representing between zero and average winter residential usage, Tier 2 as covering between the top of Tier 1 and average summer residential usage, and Tier 3 covering all usage above Tier 2. The Tier 1 quantity rate was set as the baseline rate with the rate of Tier 2 being 1.25 times Tier 1 and Tier 3 as 1.5 times Tier 2 in order to recover the 75% quantity rate revenue allocation adopted in the settlement for D.20-12-007. This change in tier breakdowns from D.08-02-036 to D.20-12-007 largely contributed to the escalating rate increases between tiers. While the rate increases attributable to the PVPWRP are also significant, the project addresses the need for an additional source of water and increased water resiliency. The installation of a second pipeline and pump station on a separate electrical grid from the existing water infrastructure enhances the reliability of Cal Water delivering drinking water to the residents and businesses on the Palos Verdes Peninsula. I hope these details help in explaining the rate increase in the Palos Verdes District adopted in D.20-12-007 and appreciate your understanding of the GRC process. We look forward to the City of Rancho Palos Verdes actively becoming a party in Cal Water’s next GRC, which should be filed in July 2021 for rates effective January 1, 2023. The City’s participation in this proceeding as an intervenor would best provide the City an opportunity to represent Rancho Palos Verdes ratepayers. Your letter along with the recommendations you provided will be forwarded to the appropriate Commissioner’s office and Administrative Law Judge once they are assigned to the new GRC and may be considered when developing the scope of the proceeding. The Commission recognizes the 1 Tier 1 quantity rate usages were based on average residential indoor usages with the quantity rates approximately 5% less than Tier 2. Tier 2 quantity rate usages were based on summer residential averages and were set as the baseline rates. Tier 3 quantity rates were approximately 1.2 times Tier 2. H-5 Mayor Eric Alegria June 14, 2021 Page 3 importance of listening to and considering different perspectives to ensure ratepayers have access to safe, reliable, and affordable drinking water. Thank you again for your letter. Should there be any further questions or concerns please contact the Water Division Director, Terence Shia, at Terence.Shia@cpuc.ca.gov or (415) 703-2213. Sincerely, Marybel Batjer, President California Public Utilities Commission CC: Amy Yip-Kikugawa, Acting Director, Public Advocates Office Terence Shia, Director, Water Division Rancho Palos Verdes City Council Ara Mihranian, City Manager Karina Bañales, Deputy City Manager Angie Gilbride, Cal Water Regional Community Affairs H-6 June 29, 2021 Via Email The Honorable Marybel Batjer C/O Terence Shia, Water Division Director California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 SUBJECT: Response to June 14, 2021 Letter Regarding Residential Rates in Cal Water’s Palos Verdes District Dear President Batjer and Director Shia, Thank you for your June 14 letter responding to our concerns regarding California Water Service Company’s (Cal Water) rate increase in the Palos Verdes District associated with Cal Water’s previously approved General Rate Case (GRC). We appreciate the additional background you provided on the reasoning behind the ratemaking process. While we are looking forward to participating as an intervenor in the next GRC, we are still concerned regarding the unfair distribution of service charge between 5/8” and 1” residential meters. We recognize that the service charge is a factor of readiness-to- service, and that larger meters use additional water, which requires additional infrastructure and is the reason for the cost differential. However, a service charge that is 2.5 times greater for a 1” meter compared to a 5/8” meter seems unfair, particularly since actual increased water usage is already captured in the quantity rate fees. This concern is not solely directed at Decision (D.) 20-12-007, as the service charge for a 1” meter maintained the 2.5 factor service charge from a 5/8” meter since at least the previous GRC; this is a concern with the methodology of the allocation of service charges. The table below illustrates the differences between the service charges for the current rates as approved in the GRC D. 20-12-007, as well as the previous GRC D. 16-12-042. Palos Verdes Service Charge per Meter Size Meter Size D. 16-12-042 Service Charge D. 20-12-007 Service Charge Percent Change (D.16 to D.20) 5/8” Meter $21.17 $31.78 50% 1” Meter $52.93 $79.45 50% Multiplier 2.5 2.5 A residential customer with a 1” meter under the current rates pays nearly $50 more per month than a customer with a 5/8” meter, all else equal. We would ask that the service charge levels be re-evaluated so that there is less of a difference between the 5/8” and H-7 CITY OF RANCHO PALOS VERDES President Batjer and Director Shia June 29, 2021 Page 2 1” meters during future GRC cycles: to allow quantity charges to cover the additional readiness-to-service capacity required for larger meters. Thank you for considering our letters and recommend ations, and for forwarding them to the new GRC to be considered in the next proceeding. We appreciate your considerable efforts to ensure that ratepayers have access to safe, reliable, and affordable drinking water. Sincerely, Eric Alegria Mayor, City of Rancho Palos Verdes cc: Amy Yip-Kikugawa, Acting Director, Public Advocates Office Asia Powell, Local Government and Community Liaison, California Public Utilities Commission Rancho Palos Verdes City Council Ara Mihranian, City Manager Karina Bañales, Deputy City Manager Angie Gilbride, Cal Water Regional Community Affairs H-8