9. Water Action Plan Checklist
The Commissions' Water Action Plan established certain goals and objectives to ensure that safe, high quality water, and reliable supplies are available from regulated water utilities operating in California. To further these goals, all Class A water utilities were directed to address the four issues listed below in any general rate case.
9.1. Activities Reported in Application
Suburban addressed these four issues in its application, primarily reporting on steps it took in 2007 and earlier to implement the plan, as discussed below:
Suburban detailed in its written prepared testimony the many activities and steps it has taken with respect to water quality issues, including compliance with and implementation of all related federal, state and local environmental, safety and security issues. In its application, Suburban also provided the Water Quality Responses required by the Water Action Plan and no concerns are raised with the water quality. Suburban also is adding four additional Water Quality Assurance Technicians to its Quality Assurance Department to better ensure high quality water for its customers.
As discussed above, Suburban is adding a new Water Quality Conservation Coordinator to its staff. Suburban also addressed the following conservation issues in its application.
· Metered Service - all Suburban customers are metered.
· Membership in the California Urban Water Conservation Council (CUWCC) - and compliance with the council's "Best Management Practices" (BMP). Suburban recently joined CUWCC, in June 2007, and intends to comply with the BMP.
· Increasing Block Rates; Decoupling Sales from Revenues; and, Financial Incentives.
Suburban addressed these issues in OII 07-01-022, the water conservation OII. D.08-02-036 in that proceeding authorized Suburban to institute a two-tier increasing block rate structure, an adjustment mechanism for decoupling sales, and financial incentives for conservation.
· 10% Energy Reduction by 2009-2010.
Suburban states it continues to efficiently manage its energy use, but provides no further details on this issue.
· Amount of Unaccounted Water
Suburban reports the amount of unaccounted water is less than 7%.
· Leak Detection Program / Leak Repair Time.
Suburban has an active detection program that will be enhanced by the addition of the two new three-person leak crews requested in this application. Leak repair time also will be enhanced by the addition of these crews.
9.1.3. Infrastructure Investment
Suburban notes the most recent Department of Water Resources Water Management Plan and the Distribution Improvement Charge in its application and work-papers. Suburban also discussed its Security Plan, compliance with the Environmental Protection Agency's Vulnerability Assessment, and the State Office of Emergency Services' Response Plan in its prepared written testimony.
9.1.4. Low-Income Ratepayer Assistance
Similar to other Water Action Plan issues discussed above (block rates, etc.), Suburban's low-income ratepayer assistance program was adopted in D.08-02-036.
9.2. Report on 2008 and 2009 Activities
As noted, Suburban reported on its past activities, primarily those undertaken in 2007. The reported results were encouraging, but we find that not all activities, and the description of those activities, were fully addressed to the level necessary to allow for a meaningful and full review of Suburban's efforts. In this regard, we direct Suburban to prepare an annual report documenting its progress and the activities undertaken in 2008 and 2009 with respect to its continuing implementation of the Water Action Plan policy objectives. A report on 2008 activities shall be included as an attachment to Suburban's Advice Letter requesting rate increases for the escalation year 2010 (to be filed in 2009); and, a report for 2009 activities shall be attached to its Advice Letter for rates for the escalation year 2011 (to be filed in 2010).
