RRB's Initial Rate Design Position

In pre-served direct testimony, RRB initially took an ambiguous position with respect to CalAm's Application-proposed per capita rate design. On the one hand, it faulted it as unneeded because the current rate design has achieved its conservation goals and kept CalAm within SWRCB's Carmel River production limits for the past two water years; its per capita allocations would place hardship on many customers and prove very difficult to implement; the household survey raises privacy concerns and would be very difficult to verify; and the program would be difficult to administer and enforce. RRB also suggested both general and specific revisions to the allocation formulas and a possible summer/winter allowance adjustment. On the other hand, it acknowledged, "In principle, CalAm's proposals for revised rate design would promote greater conservation and meet the requirements of MPWMD Ordinance No. 92, which mandates that CalAm prepare a per capita based tariff." And, RRB concluded, "The proposed changes could be introduced on a trial basis for a year."