5. Discussion

The structure of Cal-Am's proposed discount program for low-income customers is consistent with other previously authorized low-income programs (San Gabriel and Park), and with § 739.8. Although Cal-Am now is not requesting a cost recovery mechanism for its Sacramento and Larkfield LIRA programs such as a surcharge on non-eligible customers, its memorandum account will account fully for all program costs, and any cost-recovery structure will be fully reviewed in Cal-Am's GRC. Additionally, the Commission's Water Division shall monitor Cal-Am's LIRA program for conformity with this decision and compliance with related program directives such as those in the Water Action Plan.⁵ Overall, we find Cal-Am's proposed LIRA program for its Sacramento and Larkfield Districts reasonable.

⁵ The Water Action Plan, issued in December 2005, outlines our water policy directives.