report and recommendations on customer growth …
Post on 09-Dec-2021
2 Views
Preview:
TRANSCRIPT
Docket: Exhibit Number Commissioner Administrative Law Judge Public Advocates Office Witness
: : : : :
A.20-07-012 Cal Advocates - ____ G. Shiroma C. Ferguson E. Odell
REPORT AND RECOMMENDATIONS
ON CUSTOMER GROWTH FACTORS AND GSWC’S LOW INCOME ASSISTANCE PROGRAM
Application 20-07-012
San Francisco, California February 16, 2021
i
MEMORANDUM 1 2
The Public Advocates Office at the California Public Utilities Commission (“Cal 3
Advocates”) examined requests and data presented by Golden State Water Company (“GSWC”) 4
in Application (“A.”) 20-07-012 (“Application”) to provide the California Public Utilities 5
Commission (“Commission”) with recommendations that represent the interests of ratepayers 6
for safe and reliable service at the lowest cost. This report is prepared by Eileen Odell, who also 7
serves as Cal Advocates’ project lead for this proceeding. Victor Chan is the oversight 8
supervisor and Shanna Foley and Jamie Ormond are legal counsel. 9
Although every effort was made to comprehensively review, analyze, and provide the 10
Commission with recommendations on each ratemaking and policy aspect of the requests 11
presented in the Application, the absence from Cal Advocates’ testimony of any particular issue 12
does not constitute its endorsement or acceptance of the underlying request, or of the 13
methodology or policy position supporting the request. 14
i
Table of Contents Memorandum ..................................................................................................................... i Executive Summary .......................................................................................................... iii
I. Introduction ........................................................................................................... iii II. Summary of Recommendations ............................................................................ iii
A. Chapter 1: Customer Growth Factor ................................................................. iii B. Chapter 2: Low Income Assistance Program .................................................... iii
Chapter 1: Customer Growth Factor .............................................................................. 1
I. Introduction ............................................................................................................ 1
II. Summary of Recommendations ............................................................................. 1
III. Discussion .............................................................................................................. 2
A. The Commission Should Reject GSWC’s Use of Customer Growth Factors to Increase Test Year O&M and A&G Expense Forecasts as Adoption Would Likely Overcompensate GSWC for Its Costs. ........................................................................ 2
B. The Commission Should Reject GSWC’s Use of Customer Growth Factors to Increase Test Year District Labor Expense Forecasts as GSWC’s Methodology Would Likely Overcompensate GSWC for Its Costs .................................................. 5
IV. Conclusion ............................................................................................................. 6
Chapter 2: Low Income Assistance Program ................................................................. 8
I. Introduction ............................................................................................................ 8
II. Discussion .............................................................................................................. 9
A. Correcting an Error in CARW Credit Calculation ........................................... 10
III. Conclusion ........................................................................................................... 10
Attachment 1-1: Statement of Qualifications ............................................................... 11
Attachment 1-2: GSWC Response to Public Advocates Data Request CR8-001, Q.4 ........................................................................................................................................... 13
Attachment 1-3: GSWC Response to Public Advocates Data Request SLM-005, Q.2 ........................................................................................................................................... 17
Attachment 2-1: GSWC Response to Public Advocates Data Request EO2-003, Q.2 ........................................................................................................................................... 19
iii
EXECUTIVE SUMMARY 1 2
I. Introduction 3
This report presents Cal Advocates’ analysis and recommendations related to GSWC’s 4
use of customer growth factors to increase test year operations and maintenance (“O&M”), 5
administrative and general (“A&G”), and payroll expenses in its districts. Cal Advocates’ 6
primary testimony and recommendations on O&M can be found in the Public Advocates Office 7
Report and Recommendations on Operations and Maintenance and Supply Expenses. Cal 8
Advocates’ primary testimony and recommendations on A&G and labor can be found in the 9
Public Advocates Report on District A&G Expenses, District Labor Expenses, Conservation 10
Expenses and Special Request 4. 11
This report also provides Cal Advocates’ analysis and recommendations concerning 12
GSWC’s low income assistance program. 13
14
II. Summary of Recommendations 15
A. Chapter 1: Customer Growth Factor 16 The Commission should adopt Cal Advocates’ forecasts for test year O&M, A&G, and 17
payroll expenses, as Cal Advocates’ forecasts do not incorporate customer growth factors to 18
increase test year budgets. The use of customer growth factors to increase test year budget 19
forecasts would likely overcompensate GSWC for its costs and should be rejected. 20
21
B. Chapter 2: Low Income Assistance Program 22 The Commission should authorize GSWC to continue its existing California Alternative 23
Rates for Water (“CARW”) low income assistance program. However, the Commission’s final 24
decision in this case should correct an error made in GSWC’s workpapers supporting its 25
proposed credits for its low income assistance program. 26
27
1
CHAPTER 1: CUSTOMER GROWTH FACTOR 1 2
I. Introduction 3
GSWC requests adoption of test year budgets for Operations and Maintenance 4
(“O&M”),1 Administrative and General (“A&G”), and labor expenses in GSWC’s 5
ratemaking areas (“RMAs”) based on historical costs increased by various escalation 6
factors, including customer growth factors. GSWC’s methodology of including customer 7
growth factors assumes that a wide range of expenses increase at the same rate as 8
customer growth, without including support for this assumption. 9
The Commission’s Rate Case Plan does not address use of customer growth 10
factors to increase test year expenses. The Rate Case Plan does allow for the escalation 11
of expenses by customer growth factors in escalation years because, though it likely 12
overcompensates utilities for their costs, this methodology may offset other escalation 13
year simplifications that could undercompensate the utilities.2 14
This chapter contains analysis and recommendations only on the use of customer 15
growth factors to increase the test year expense forecasts. Cal Advocates’ primary 16
testimony and recommendations on O&M can be found in the Public Advocates Report 17
on District O&M Expenses. Cal Advocates’ primary testimony and recommendations on 18
A&G and labor can be found in the Public Advocates Report on District A&G Expenses, 19
District Payroll & New Employees, Conservation Expenses, and Special Request 4. 20
21
II. Summary of Recommendations 22
The Commission should reject GSWC’s O&M, A&G, and labor forecasts that 23
have been estimated using a customer growth factor. GSWC uses a “broad brush” in 24
applying customer growth factors to increase expenses that have tenuous, if any, 25
connection to customer growth and, if adopted, would likely overcompensate the utility 26
1 This report does not address supply expense forecasts, though such expenses are considered O&M expenses. Supply expenses, (e.g., purchased water, pump taxes, chemicals, etc.) are forecast using different methodologies than those used to forecast other O&M expenses and are addressed in the Public Advocates Office Report and Recommendations on Operations and Maintenance and Supply Expenses. 2 D.04-06-018, Interim Order Adopting Rate Case Plan, at p. 11.
2
for its costs. Removal of customer growth factors decreases test year labor and non-labor 1
expense budgets, company-wide, by an estimated $419,000. 2
3
III. Discussion 4
A. The Commission Should Reject GSWC’s Use of Customer Growth Factors 5 to Increase Test Year O&M and A&G Expense Forecasts as Adoption 6 Would Likely Overcompensate GSWC for Its Costs. 7
GSWC requests that the Commission adopt O&M and A&G test year expense 8
budgets for each of its ratemaking areas (“RMAs”), based on a five-year average of 9
historical recorded amounts, increased by an inflation factor, and further increased by a 10
customer growth factor specific to each RMA.3 GSWC’s requests also include 11
adjustments to specific accounts to incorporate additional expenses not captured by the 12
five-year historical average.4 As its only evidence supporting its use of customer growth 13
factors, GSWC states: 14
Operation and maintenance costs are related to both the size and the 15 demand put on the system. Customer growth increases both the size 16 of the system and the demand on the system resulting in increased 17 operation and maintenance expense.5 18 19
GSWC’s use of customer growth factors to increase test year expense forecasts 20
would likely overcompensate the utility for its costs if adopted. GSWC’s methodology 21
applies customer growth factors to all of its RMA O&M and A&G accounts, including 22
accounts with expenses that bear little direct relationship to customer growth or growth in 23
demand. For example, GSWC’s methodology applies a customer growth factor to its 24
Other Operation Expense accounts, which track costs ranging from management 25
consultant fees and public relations council fees to employee uniforms and footwear, 26
3 GSWC Prepared Testimony of Brad Powell (“Testimony of Brad Powell”) at p. 6. 4 See e.g., Testimony of Brad Powell at p. 10, detailing a specific request to increase test year budgets due to increased groundwater production at certain wells, necessitating increased frequency of media change outs for the granular activated carbon treatment facilities at those wells. 5 Testimony of Brad Powell at p. 6. See also p. 14, where GSWC repeats the same justification for A&G expenses: “Administrative and general costs are related to both the size and the demand put on the system. Customer growth increases both the size of the system and the demand on the system resulting in increased administrative and general expenses.”
3
from office space janitorial services to the electricity used to power GSWC buildings.6 1
GSWC’s testimony does not explain how a 1 percent increase in customers increases 2
GSWC’s uniform expenses by 1 percent. GSWC’s across-the-board application of a 3
customer growth factor belies this range of expense types and likely overstates actual cost 4
increases. 5
Further, while GSWC ties customer growth and demand together, even these 6
factors have not increased at a direct rate so that one measurement could be used as a 7
proxy for the other. For example, while GSWC’s customer count in Arden Cordova has 8
increased over time, its consumption has decreased, as shown in the chart below.7 9
GSWC’s testimony does not explain why a negative demand factor is not used to forecast 10
Arden Cordova’s expenses, in place of a positive customer growth factor, when it alleges 11
that increased demand increases expenses. 12
Table 1-1: Arden Cordova: Recorded Customers vs. Demand 13
14 GSWC may be able to make a showing that certain expenses do increase because 15
of and in some relation to customer growth and GSWC has the opportunity to make those 16
account- or item-specific adjustments in test year forecasts. As an analogous example, 17
6 Testimony of Brad Powell at pp. 6-7. 7 Data for 2011-2014 extracted from A.17-07-010, GSWC Response to Minimum Data Request Section A, Basic Information: Arden Cordova. Data for 2015-2019 extracted from A.20-07-012, GSWC Response to Minimum Data Request Section A, Basic Information: Arden Cordova.
-
1,000,000
2,000,000
3,000,000
4,000,000
5,000,000
6,000,000
7,000,000
8,000,000
15,600
15,800
16,000
16,200
16,400
16,600
16,800
17,000
17,200
2011 2012 2013 2014 2015 2016 2017 2018 2019
Dem
and
(CC
F)
Cus
tom
ers
Arden Cordova: Recorded Customers vs. Demand
Customers Demand
4
while GSWC does not apply customer growth factors to increase General Office 1
expenses across the board, GSWC increases specific expense accounts related to its 2
General Office postage, bill supplies, payment processing, and bad debt collection service 3
in direct proportion to the expected increase in bills it will send pursuant to Special 4
Request # 6, GSWC’s request to convert from bi-monthly to monthly billing.8 This 5
example indicates that GSWC can make specifically-justified adjustments to test year 6
expense accounts with supporting evidence when necessary. Thus, there is no reason to 7
apply GSWC’s “wide brush” to all district test year expense forecasts when customers 8
could ultimately end up paying for increases in expenses that GSWC is unlikely to incur. 9
The Commission has recognized these and similar concerns with the use of 10
customer growth factors to forecast expense budgets. In its 2004 Interim Rate Case Plan 11
Decision, the Commission replaced its “second test year, with its account-by-account 12
revenue requirement review, with an inflation-based escalation formula” in order to 13
streamline its review of general rate cases (GRCs).9 In discussing what factors should be 14
used to create budgets for escalation years, the Commission noted that while the causal 15
relationship between customer growth and expense increases is “almost certainly not 16
zero,” “utility work requirements and expenses do not necessarily increase in direct and 17
exact proportion to customer growth, and that productivity improvements should be able 18
to address many increases.”10 19
On balance, the Commission found the use of customer growth factors to forecast 20
escalation year expense budgets reasonable, because while this “will tend to 21
overcompensate the utility for increased costs,” overcompensation would offset other 22
escalation year simplifications “that may not fully encompass all possible future cost 23
increases.”11 Thus, while rougher estimating methodologies such as an across-the-board 24
8 See Attachment 1-2, GSWC Response to Public Advocates DR CR8-001, Q.4, Attachment: Bi-Monthly to Monthly Billing Costs Excel. 9 D.04-06-018, Interim Order Adopting Rate Case Plan, at p. 5. 10 D.04-06-018, Interim Order Adopting Rate Case Plan, at p. 11. 11 D.04-06-018, Interim Order Adopting Rate Case Plan, at p. 11. The Commission provided an example of an escalation year budget simplification that could undercompensate utilities - the rolling adoption of rates incorporating General Office allocations for multi-district utilities. As multi-district utilities now file rate
5
application of a customer growth factor could be appropriate in escalation year filings 1
when individual account requests are not considered and other simplifications may offset 2
this over-compensation, test year budgets should be forecast with account-by-account 3
specificity.12 The Commission should reject GSWC’s request to deviate from this 4
reasoning here, reducing test year non-labor O&M and A&G expense budgets by 5
approximately $262,000, companywide. 6
7
B. The Commission Should Reject GSWC’s Use of Customer Growth Factors 8 to Increase Test Year District Labor Expense Forecasts as GSWC’s 9 Methodology Would Likely Overcompensate GSWC for Its Costs 10
For similar reasons, the Commission should reject GSWC’s request to increase its 11
test year RMA labor budgets using customer growth factors. To calculate its test year 12
labor budget request, GSWC begins with its 2020 expense due to employee salaries,13 13
increased by an inflation factor, a 1% “merit adjustment,” and each RMA’s customer 14
growth factor.14 GSWC incorporates the salaries for new positions it requests into this 15
forecast as well. 16
GSWC’s use of customer growth factors to increase test year payroll budgets is 17
illogical and likely overcompensates the utility for its costs. In general, existing 18
employee salaries are not increased due to additions of customers. GSWC’s labor budget 19
request incorporates the salaries of six new employees, including an Operations Engineer, 20
whose new position is justified in part due to the size of the area to which the Operations 21
cases for all districts and the General Office simultaneously, utilities are no longer at risk of under-compensation in this area. 12 Subsequently, in Decision D.14-08-006, the Commission rejected San Jose Water Company’s test year 2013 expense budget requests that had been forecast using a customer growth factor. The Commission stated that “a plain reading of D.07-05-062 shows that the Commission did not apply customer growth to test year expenses but instead applied the customer growth to expenses in escalation years following the test year. Therefore, the Commission has eliminated customer growth as a factor in all test year expenses.” D.14-08-006, Resolving General Rate Case of San Jose Water Company, at p. 26. The Commission ultimately held that “[i]t is unreasonable to include customer growth escalation factors in test year expenses as test year expenses are escalated due to other factors.” D.14-08-006 at p. 120, Conclusion of Law #11. 13 This 2020 figure is comprised of the salaries of 2020 employees and the mid-range of salaries for vacant positions, allocated between expense and capitalized budgets, adjusted for vacant positions, and for stand-by, call-out, and overtime pay. For a more detailed explanation of this methodology, see GSWC Prepared Testimony of Nanci Tran at pp. 5-7. 14 GSWC Prepared Testimony of Nancy Tran at p. 7.
6
Engineer would be assigned as well as to the complexity of additional treatments systems 1
in that operating area.15 Because the need for new employees due to system size is 2
already incorporated in GSWC’s labor forecast, it is unclear exactly what cost increases 3
the customer growth factor represents. 4
In response to Cal Advocates’ request for more information, GSWC elaborated 5
that its use of customer growth factors to increase test year labor expenses is based on the 6
Commission’s logic and reasoning for allowing customer growth factors to increase 7
escalation year expense budgets.16 However, as noted above, the Commission reasoned 8
that while using a customer growth factor to increase expense budgets likely 9
overcompensates utilities for their costs, its use in escalation years was appropriate only 10
because it would offset other escalation year simplifications that could undercompensate 11
utilities for their costs. Because GSWC here uses customer growth factors to increase 12
test year budget requests, rather than escalation year requests, the Commission’s logic 13
and reasoning do not support GSWC’s request. 14
The use of customer growth factors to increase test year labor budgets likely 15
overcompensates GSWC for its costs. GSWC should not be authorized to increase its 16
test year labor budget request by such factors, particularly when it can make specific test 17
year budget requests for new employees based on customer growth, if necessary. This 18
recommendation would reduce test year labor budgets by approximately $157,000, 19
companywide. 20
21
IV. Conclusion 22
The Commission should reject GSWC’s use of customer growth factors to 23
increase test year O&M, A&G, and labor expense budget forecasts. GSWC’s 24
methodology, if adopted, would likely overcompensate GSWC for its costs. The use of 25
15 GSWC Prepared Testimony of Denise Kruger at p. 9. GSWC’s labor forecast incorporates further specifically justified adjustments to payroll, including elimination of positions due to productivity improvements in customer service. GSWC Prepared Testimony of Denise Kruger at p. 5. 16 Attachment 1-3, GSWC Response to Public Advocates DR SLM-005, Q.2.
7
customer growth factors is inappropriate for test year forecasts when specific account 1
adjustments can be made and supported by evidence. 2
8
CHAPTER 2: LOW INCOME ASSISTANCE PROGRAM 1 2
I. Introduction 3
This chapter presents Cal Advocates’ analysis and recommendations regarding 4
GSWC’s low income customer assistance program, referred to as California Alternative 5
Rates for Water (“CARW”). GSWC does not request any changes to its CARW 6
program, which provides eligible customers a credit of about 20 percent of the average 7
CARW customer bill in each RMA. Cal Advocates does not oppose GSWC’s request to 8
continue its existing CARW program unchanged; however, adopted credits should 9
correct for a mistake made in GSWC’s workpapers regarding the calculation of proposed 10
CARW credits and surcharges. 11
12 Table 2-1: Comparison of GSWC and Cal Advocates’ Proposed Credits and 13 Surcharges: 14
RMA GSWC Proposed CARW Credit17
Cal Advocates Proposed
CARW Credit
GSWC Proposed CARW
Surcharge (per ccf,
unless “flat”)
Cal Advocates’ Proposed CARW
Surcharge (per ccf, unless “flat”)
Arden Cordova $7.00 $7.00 $0.116 $0.116 Arden Cordova
(flat rate) $19.00 $19.00 $1.593 $1.593
Bay Point $18.00 $18.00 $0.116 $0.116 Clearlake $32.00 $32.00 $0.116 $0.116 Los Osos $30.00 ($25.00*) $30.00 ($25.00*) $0.116 $0.116
Santa Maria $11.00 ($12.00*) $11.00 ($12.00*) $0.116 $0.116 Simi Valley $12.00 $12.00 $0.116 $0.116
Region 2 $17.00 $14.00 $0.207 $0.170 Region 3 $13.00 $13.00 $0.082 $0.082
15
16
17 See GSWC RO Model Workpaper W_Reports_All, tab: CARW for GSWC’s proposed credits and surcharges. Credits marked with an asterisk should be used for Los Osos and Santa Maria if the Commission adopts GSWC Special Request 13 to consolidate those RMAs. GSWC also proposed that non-profit group living facilities, agricultural employee housing facilities, and migrant farmworker housing centers will receive a flat monthly credit of $28.26. Cal Advocates does not oppose this request.
9
II. Discussion 1
Cal Advocates does not oppose GSWC’s request to continue its CARW 2
program. There are two open rulemakings at the CPUC addressing affordability 3
and low income customer credits.18 The State Water Resources Control Board 4
(“SWRCB”) is also exploring affordability and low income assistance for water 5
programs at the State level (related to Assembly Bill 401). Therefore, it is prudent 6
for the Commission to await the outcome of these open CPUC rulemakings and 7
the SWRCB state-wide water CARW activity before making changes to GSWC’s 8
CARW program. However, as described below, the final adopted credits should 9
correct for an error in GSWC’s workpapers. 10
GSWC designs its CARW credits to equal 20 percent of an average CARW 11
customer bill. GSWC develops the average CARW customer bill by finding the average 12
monthly usage for CARW customers in each region, here determined to be 10 hundred 13
cubic feet (or “centum” cubic feet, “ccf”) in each of the three regions.19 While the 14
average usage is based on Region-wide totals, because each RMA has a different revenue 15
requirement and rate design, the CARW discount is calculated separately for each RMA. 16
GSWC calculates what a customer’s bill would be in each RMA, assuming 10 ccf of 17
consumption with a 5/8” by 3/4” meter. GSWC then uses these average bill estimates as 18
the basis for the fixed bill credits, with 20 percent of the bill developed for each RMA set 19
as that RMA’s credit amount, rounded to the nearest whole dollar. This fixed credit is 20
applied to CARW customer bills regardless of actual usage.20 21
18 R.17-06-024 (“OIR Evaluating the Commission’s 2010 Water Action Plan Objective of Achieving Consistency between Class A Water Utilities’ Low-Income Rate Assistance Programs, Providing Rate Assistance to All Low-Income Customers of Investor-Owned Water Utilities, and Affordability”) and R.18-07-006 (“OIR to Establish a Framework and Processes for Assessing the Affordability of Utility Service”). 19 GSWC used 2019 data to estimate the average monthly CARW usage, totaling the total CARW customer usage from 2019 and dividing by the total usage by the total number of monthly CARW bills. Attachment 2-1, GSWC Response to Public Advocates DR EO2-003, Q.2. 20 An additional amount hovering around 10 cents is added to the CARW credit to offset the cost of GSWC’s Credit Card Payment Pilot Program, which is intended in part to determine whether a credit card payment option benefits low income ratepayers by helping to prevent service disconnections, though this amount is not included in the credits or surcharges discussed in this report. See A.20-07-012 at p. 25; see also Public Advocates Office Report on District A&G Expenses, District Labor Expenses, Conservation
10
A. Correcting an Error in CARW Credit Calculation 1 GSWC’s workpapers21 contain a mistake when calculating the CARW credit for 2
Region 2, in which the “average bill” basis is calculated using 12 ccf, rather than the 3
average 10 ccf.22 This leads to a proposed discount for Region 2 representing 23.6 4
percent of the average CARW customer bill, rather than 20 percent. 5
Table 2-3: Effects of Use of 12 ccf Rather than 10 ccf Consumption on Region 6 2 CARW Credit 7
GSWC Estimated 2022 Bill23
20% Credit
Region 2, 12 ccf $84.05 $17.00 Region 2, 10 ccf $72.17 $14.00 8
The Commission’s final adopted CARW credits should correct this mistake so that 9
CARW credits across GSWC’s service territory all represent a 20 percent credit to a bill 10
for 10 ccf of consumption. 11
12
III. Conclusion 13
The Commission should allow GSWC to continue its CARW program. The final 14
adopted surcharges and credits for the CARW program should reflect the noted 15
correction to GSWC’s workpapers and should incorporate the final adopted rates in this 16
proceeding. 17
18
19
20
21
22
Expenses and Special Request 4 for Cal Advocates’ recommendation regarding the Credit Card Payment Pilot Program. 21 GSWC Workpaper W_Report_All.xlsx, tab: CARW Consolidated, cell: L52. 22 Attachment 2-1, GSWC Response to Public Advocate DR EO2-003 CARW, Q.2. 23 Each average bill is calculated assuming a 5/8” x 3/4” meter, consistent with GSWC’s current methodology, and GSWC’s proposed rates and rate design.
12
Witness Statement of Qualifications: 1
Q1. Please state your name, business address, and position with the CPUC: 2
A1. My name is Eileen Odell and my business address is 505 Van Ness, San Francisco 3
CA, 94102. I am a Public Utilities Regulatory Analyst V in the Communications 4
and Water Policy Branch of the Public Advocates Office. 5
Q2. Please summarize your education background and professional experience. 6
A2. I received a Bachelors’ Degree in Political Science from the University of 7
California, San Diego in 2007. I earned a Juris Doctor degree from the University 8
of California, Hastings College of the Law in 2011. I am admitted to the 9
California State Bar. 10
I have been with the Public Advocates Office – Communications and Water Policy 11
Branch since June 2014. Prior to joining the Public Advocates Office, I held a 12
legal fellowship with the Office of Sonoma County Counsel, where I assisted in 13
representing county agencies including the Sonoma County Water Agency. 14
Q3. What is your responsibility in this proceeding, GSWC Test Year 2022 General 15
Rate Case, A.20-07-012? 16
A3. In addition to serving as Project Lead, I am responsible for the preparation of the 17
Executive Summary and I jointly sponsor the Results of Operations (“RO”) tables 18
with our RO witness, Chris Ronco. Finally, I am the author of Cal Advocates’ 19
recommendations regarding GSWC’s use of customer growth factors to forecast 20
test year expense and labor budgets, and for Cal Advocates’ recommendations 21
concerning GSWC’s low income program, California Alternative Rates for Water. 22
Q4. Does this conclude your prepared direct testimony? 23
A4. Yes, it does. 24
14
Conversion from Bi-Monthly to Monthly Billing - Remaining AccountsCost Estimations for 2022 to 20242020 General Rate Case
Total Estimated Annual Cost to Move Remaining Bi-Monthly Accounts to Monthly Billing Cycle: $799,225
Postage - General Office (9012), WUDF 773.25
RMA/CSA REMAINING BI-MONTHLY ACCOUNTS
ADDITIONAL MONTHLY BILLS
PER YEAR
PAPER BILLS e-BILLS REMINDER NOTICES
SHUT OFF NOTICES
Total
73.69% 26.31% 21.74% 6.73%$0.49 $0.00 $0.49 $0.49
ARDEN CORDOVA 16,231 97,386 $35,165 $0 $10,375 $3,211 $48,751LOS OSOS 3,287 19,722 $7,121 $0 $2,101 $650 $9,873SIMI VALLEY 12,866 77,196 $27,874 $0 $8,224 $2,546 $38,644PLACENTIA 15,426 92,556 $33,421 $0 $9,860 $3,052 $46,333LOS ALAMITOS 27,848 167,088 $60,333 $0 $17,800 $5,510 $83,643BARSTOW 8,987 53,922 $19,470 $0 $5,744 $1,778 $26,993SAN GABRIEL 12,470 74,820 $27,016 $0 $7,971 $2,467 $37,454
97,115 582,690 $210,401 $0 $62,074 $19,215 $291,691
Percent of Additional BillsCost per Transaction
15
Bill Supplies - General Office (9012), WUDF 773
RMA/CSA REMAINING BI-MONTHLY ACCOUNTS
ADDITIONAL MONTHLY BILLS
PER YEAR
PAPER BILLS e-BILLS REMINDER NOTICES
SHUT OFF NOTICES
Total
73.69% 26.31% 21.74% 6.73%$0.08 $0.00 $0.08 $0.08
ARDEN CORDOVA 16,231 97,386 $5,741 $0 $1,694 $524 $7,959LOS OSOS 3,287 19,722 $1,163 $0 $343 $106 $1,612SIMI VALLEY 12,866 77,196 $4,551 $0 $1,343 $416 $6,309PLACENTIA 15,426 92,556 $5,456 $0 $1,610 $498 $7,565LOS ALAMITOS 27,848 167,088 $9,850 $0 $2,906 $900 $13,656BARSTOW 8,987 53,922 $3,179 $0 $938 $290 $4,407SAN GABRIEL 12,470 74,820 $4,411 $0 $1,301 $403 $6,115
97,115 582,690 $34,351 $0 $10,135 $3,137 $47,623
Percent of Additional BillsCost per Transaction
Payment Processing - General Office (9012), WUDF 773
RMA/CSA REMAINING BI-MONTHLY ACCOUNTS
ADDITIONAL MONTHLY BILLS
PER YEAR
MAILED CHECKS
ONLINE BANK OR
RECURRING
WALK-IN PAYMENTS
ONE-TIME EZ-PAY
Total
31.91% 46.82% 11.59% 9.62%$0.00 $0.07 $0.00 $1.45
ARDEN CORDOVA 16,231 97,386 $0 $3,192 $0 $13,584 $16,776LOS OSOS 3,287 19,722 $0 $646 $0 $2,751 $3,397SIMI VALLEY 12,866 77,196 $0 $2,530 $0 $10,768 $13,298PLACENTIA 15,426 92,556 $0 $3,033 $0 $12,911 $15,944LOS ALAMITOS 27,848 167,088 $0 $5,476 $0 $23,307 $28,783BARSTOW 8,987 53,922 $0 $1,767 $0 $7,522 $9,289SAN GABRIEL 12,470 74,820 $0 $2,452 $0 $10,437 $12,889
97,115 582,690 $0 $19,097 $0 $81,279 $100,377
Percent of Additional BillsCost per Transaction
Bad Debt Collection Service - General Office (9012), WUDF 781
RMA/CSA REMAINING BI-MONTHLY ACCOUNTS
ADDITIONAL MONTHLY BILLS
PER YEAR
BAD DEBT COLLECTION
SERVICE0.06%$44.20
ARDEN CORDOVA 16,231 97,386 $2,583LOS OSOS 3,287 19,722 $523SIMI VALLEY 12,866 77,196 $2,047PLACENTIA 15,426 92,556 $2,455LOS ALAMITOS 27,848 167,088 $4,431BARSTOW 8,987 53,922 $1,430SAN GABRIEL 12,470 74,820 $1,984
97,115 582,690 $15,453
Percent of Additional BillsCost per Transaction
16
Additional Temporary Customer Service Representatives (CSRs) - General Office (9012), WUDF 781
Approximately 6.5 Temporary CSRs at $52,000/year $336,018Additional Phone Service Fees $8,064
Total $344,082 1
1 These costs are temporary and not anticipated to be necessary after 2024 as customers fully adjust to monthly bills.
top related