Minimum Data Requirements for Utility
General Rate Case Application and Testimony

The Water Action Plan adopted on December 15, 2005 includes four principles: (1) safe high quality water; (2) highly reliable water supplies; (3) efficient use of water; and (4) reasonable rates and viable utilities. In order to ensure that Class A water utilities adhere to the four principles as well as providing sufficient information to promote sound decision-making, the following information must be included in the utility's Results of Operations Report when a GRC is filed. Testimony served concurrently with the GRC application must include data responsive to the specific topics and questions listed below. The application and testimony need not respond to the Minimum Data Requirements in the order presented below, but must include a cross reference that identifies where each topic and question is addressed and the cross-reference document will become part of the formal record. When filing a multi-district GRC, the utility must provide responses both on a company aggregate and individual district basis.

I. General Rate Case Application Requirements

The application must contain the following summary information:

A. Summary of Requested Revenue Requirement and Rate Base Changes

Compare the proposed amounts to the last adopted and last recorded amounts to determine the difference in dollars and percentages. Show the difference, i.e., the proposed change, in a table, as set out below.

Comparison Between Proposed Test Year and Last Test Year Adopted and Last Recorded Year			Proposed Test Year
	Last Test Year	Last Recorded Year17
Total Rev Req $
Rate Base $
Rate Base %
Operating Expenses $
Operating Expenses %
Rate of Return

B. Primary Cost Increases

List the five most significant issues, in dollar terms that the utility believes require a rate change. Identify the cause of cost increases.

C. Issues of Controversy

List the major controversial issues included in the GRC filing. Include the dollar impact of these issues, and a brief summary of the utility's rationale on this subject.

D. Proposed Notice to Customers

Include in the proposed application proposed notices to customers that will be submitted for review by the Commission's Public Advisor upon filing of the proposed application. The proposed notices should describe the reasons for the requested rate change and estimated average bill changes for a typical customer in each district by customer class.

II. Testimony Requirements

A. Basic Information

All significant¹⁸ changes between last adopted figures and recorded amounts shall be explained. Forecasted amounts shall include an explanation of the forecasting method.

1. Number of customers and percentage of customer increase for last authorized test years, last five years recorded data, and proposed test year.¹⁹

2. Total water sales in CCF for the last authorized test year, last five years recorded data, and proposed test year.²⁰

3. Revenue requirement authorized for last test and escalation years and proposed test year.

4. Recorded revenues for last five years and proposed test year forecast.²¹

5. Revenues per customer for last authorized test years, last five years recorded data, and proposed test year.

6. Number of general office employees and percent increase for the last authorized test years, last five years recorded data, and proposed test year.

7. Number of district employees and percent increase for the last authorized test years, last five years recorded data, and proposed test year.

8. List each rate change since the last GRC decision by district, including the date, percentage change to typical residential customer bill, percentage change to revenue requirement, total dollar change, and citations to authority for each increase, and sum to arrive at cumulative rate change by district since last GRC.

B. Revenue Requirement: Operations and Maintenance, Administrative and General, General Office

As part of the Results of Operation Report, all significant changes between last adopted figures and recorded amounts shall be explained. Show results of operation in summary table as specified by the Water Division. Forecasted amounts shall include an explanation of the forecasting method.²² Among other information to support the utility's request, provide the following:

1. Operation and Maintenance (O&M) Expenses for the last authorized test year, last five years recorded data, and proposed test year.

2. O&M expense per customer for last authorized test year, last five years recorded data, and proposed test year.

3. Maintenance expense and percent increase/decrease for last authorized test year, last five years recorded data, and proposed test year.

4. Maintenance expense per customer and percent increase/decrease for last authorized test year, last five years recorded data, and proposed test year.

5. A&G Expenses and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

6. A&G Expense per customer and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

7. Number of district employees per thousand customers and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

8. District employee's total payroll expenses and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

9. District employee's payroll expenses per thousand customers and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

10. District employee's expensed payroll and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

11. District employee's capitalized payroll and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

12. Number of general office employees per thousand customers and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

13. General office payroll expense and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

14. General office payroll expense per thousand customers and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

15. General office expensed payroll and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

16. General office capitalized payroll per thousand customers and percent increase for the last authorized test year, last five years recorded data, and proposed test year.

17. Number of supervisory, managerial and executive employees in General Office for the last authorized test year, last five years recorded data, and proposed test year.

18. Number of supervisory, managerial and executive employees in General Office per thousand customer for the last authorized test year, last five years recorded data, and proposed test year.

19. If general office expenses are shared with other regulated water districts or other unregulated affiliates or functions, describe how these expenses are allocated (a) by the most recent Commission decision (provide citation to decision number and exact page reference) or (b) if these expenses are now subject to allocation by Commission decision (provide citation to decision number and exact page reference), how these expenses have been allocated, in fact, since the last general rate case or general rate adjustment.

C. Revenue Requirement: Water Sales and Production

As part of the Results of Operation Report, all significant changes between last adopted figures and recorded amounts shall be explained. Show results of operation in summary table as specified by the Water Division. Forecasted amounts shall include an explanation of the forecasting method. Among other information to support the utility's request, the utility shall provide the following:

1. Total water production in CCF for the last authorized test year, last five years recorded data, and proposed test year.

2. Total purchased water in CCF for the last authorized test year, last five years recorded data, and proposed test year.

3. Total pumped water pumped in CCF for the last authorized test year, last five years recorded data, and proposed test year.

4. Total treated water in CCF for the last authorized test year, last five years recorded data, and proposed test year.

5. Total surface water in CCF for the last authorized test year, last five years recorded data, and proposed test year.

6. Total raw water in CCF for the last authorized test year, last five years recorded data, and proposed test year.

7. Total recycled water in CCF for the last authorized test year, last five years recorded data, and proposed test year.

8. Sales per customer for different customer classes (in CCF/customer) for the last authorized test year, last five years recorded data, and proposed test year.²³

D. Rate Base

All significant changes between last adopted figures and recorded amounts shall be explained. Forecasted amounts shall include an explanation of the forecasting method.²⁴ All significant capital additions shall be identified and justified, and must include need analysis, cost comparison and evaluation, conceptual designs, and overall budget. Also include a comparison of the forecasted capital additions adopted in the last GRC and actual capital additions.

1. Rate base and percentage of increases for last authorized test years, last five years recorded data, and proposed test year.

2. Rate base per customer and percentage of increases for last authorized test years, last five years recorded data, and proposed test year.

3. Plant-in Service and percentage of increases for last authorized test years, last five years recorded data, and proposed test year.

4. Plant-in Service per customer and percentage of increases for last authorized test years, last five years recorded data, and proposed test year.

5. List the plant improvements authorized in test years but not built.

6. List plant improvements built in last test years but not authorized.

7. List all items in Plant-in Service included in rate base not "used and useful" in the last five years and proposed test year.

8. To the extent not included in a previous GRC application, include a detailed, complete description accounting for all real property that, since January 1, 1996, was at any time, but is no longer, necessary or useful in the performance of the water corporation's duties to the public and explain what, if any, disposition or use has been made of said property since it was determined to no longer by used or useful in the performance of utility duties.²⁵ The disposition of any proceeds shall also be explained.

E. Supply and Distribution Infrastructure Status and Planning

1. Demonstrate compliance with § 10620 of the California Water Code which requires the utility to prepare an Urban Water Management Plan. The utility shall demonstrate compliance by providing a copy of the letter the utility has received from DWR affirming a completed Urban Water Management Plan.

2. Identify unaccounted for water in CCF and percentage of total water production for the last authorized test year, last five years recorded data, and proposed test year amounts.

3. Submit the results of a water loss audit performed no more than 60 days in advance of the submission of the proposed application. The audit report will be prepared using the free Audit Software developed by the American Water Works Association (AWWA) and available on the AWWA website.

4. In connection with the water loss audit described above, the utility shall conduct and submit the results of a cost/benefit analysis for reducing the level of unaccounted water reported in the water loss audit. If unaccounted water is more than approximately 7% for each district or service area, submit a plan to reduce unaccounted water to a specific amount.

5. Identify specific measures taken to reduce unaccounted water in the last five years and proposed test year.

6. Identify number of leaks in the last five years.

7. Describe leak detection program.

8. Provide leak repair time and cost statistics for last five years.

9. Identify specific measures taken to reduce number of leaks in the last five years and proposed test year.

10. Calculate the average age of distribution system.

11. List number of feet of and size of mains replaced for last authorized test years, last five years recorded data, and proposed test year amounts.

12. Concisely list all major water sources, including the permit number or contract, remaining duration of the entitlement, and any pending proceedings or litigation concerning any major source. Location of the source need not be included.

13. Identify water supply (in gpm) added to system for the last three years and proposed test years.

14. Identify storage volume (in million gallons) added to water system for the last three years and proposed test years.

15. Identify treatment volume (in million gallons) added to water system in the last three years and proposed test years.

16. Include a copy of the latest Department of Water Resources Water Management Plan.

17. Provide confirmation of compliance with EPA Vulnerability Assessment and Office of Emergency Services Response Plan.

18. Any water utility filing a GRC on or after July 1, 2008 must submit a long-term, 6-10 year Water Supply and Facilities Master Plan to identify and address aging infrastructure needs. The Plan should be consistent with recommendations and elements of comprehensive asset management identified in the General Account Office's March 2004 Report, GAO 04-461: Water Infrastructure: Comprehensive Asset Management has Potential to Help Utilities Better Identify and Plan Future Investments. This report can be found at http://www.gao.gov/new.items/d04461.pdf.

19. If expected system improvement requirements over next five years exceeds average authorized capital additions over past two GRCs, identify a ratemaking approach (for example, a Distribution System Improvement Charge), to ensure infrastructure renewal.

F. Conservation and Efficiency

1. Specific measures taken to promote water conservation in the last five years and the proposed test years.

2. Submit plan to achieve five percent reduction in average customer water use over three-year GRC cycle.

3. Identify the percentage of metered customers in aggregate and by district and your plan to convert customers to metered service.

4. Confirm membership in the California Urban Water Conservation Council

a) For those companies that are a member of CUWCC, submit a Separate Report that list the company's compliance with the 14 BMPs.

b) For those companies that are not members of CUWCC, submit a Separate Report on the implementation of CUWCC's BMPs.

5. Provide specific measures taken to promote energy conservation in the last five years and the proposed test years.

6. Identify and assess options to improve energy efficiency of water pumping, purification systems, and other energy intensive water processes.

7. Identify options to achieve reductions in energy use related to its water utility operations over the proposed GRC cycle, including a plan to achieve a ten percent reduction in energy use per Ccf.

8. Identify number of water pumps rated in pump efficiency tests as "Low," "Normal" and "High" in the last five years.

9. Identify number of low efficiency pumps replaced for the last authorized test years, the last five years and the proposed test years.

10. Calculate delivery factors (kWh/CCF) for the (1) total system, (2) wells only, and (3) boosters only, for the last authorized test year, last five years recorded data, and the proposed test years.

G. Water Quality

1. Summarize any non-compliance with maximum contaminant levels (MCLs) since the last GRC.

2. Summarize any Treatment Techniques or Action Level exceedances.

3. Summarize any Notification Levels or Response Level exceedances.

4. Provide copy of the distributed Consumer Confidence Report (CCR) for each year not covered by the last GRC.

5. Provide copies of CDHS citations issued to the system, if any.

6. Provide copy of last CDHS inspection report and letters of violation.

7. Provide information on all actions taken to comply with CDHS requests.

8. Provide an explanation as to how regulations expected to be promulgated in the next five years may affect your operations.

9. Provide copy of CDHS State Revolving Funds Needs Survey Documentation.

10. Recommend additional water quality requirements, tests, conditions, protocols, etc. that may be needed in the future to assure water quality and safety, including costs and enforcement.

H. Service Quality

1. Number of customer complaints received in last three years, categorized by major subject areas.

2. Measures taken to reduce the number of complaints in the last three years and plan for GRC cycle.

I. Corporate and Unregulated Activities

1. Identify and explain all transactions with corporate affiliates involving utility employees or assets, or resulting in costs included in revenue requirement over the last five years. Include all documentation, including a list of all such contracts, and accounting detail necessary to demonstrate that any services provided by utility officers or employees to corporate affiliates are reimbursed at fully allocated costs.

2. To the extent the utility uses assets or employees included in revenue requirement for unregulated activities, identify, document, and account for all such activities, including all costs and resulting revenue, and provide a list of all contracts over the last five years.

J. Rate Design

Testimony should describe how the proposed rate design promotes customer conservation and low-income water user affordability. At a minimum, the proposed rate design should include:

1. Conservation rate design (e.g., increasing block rates) for metered customers or otherwise be consistent with industry-wide rules on conservation rate design.

2. Low-Income tariff.

3. Identify opportunities and options for consolidation of district tariffs, where appropriate.

K. Other

1. Describe any adopted mechanism to remove the water utility financial disincentive to promote conservation or adjust for conservation impacts on sale revenues.

2. Propose a method or methods to remove the water utility financial disincentive to promote conservation, if one is not currently adopted.²⁶

3. Identify Class C and D or mutual water companies adjacent to current service territories and opportunities for interconnection or acquisition.

4. List the major policies, programs, plant additions, and improvements proposed in the GRC that promote achievement of the four Water Action Plan 2005 principles.

L. Workpapers

Workpapers are served as described in the Rate Case Plan but are not part of the proposed application. Include all supporting analysis, documentation, calculations, back-up detail, and any other information relied on but not readily available to other parties. Electronic copies of all spreadsheets or other analytical methods necessary to fully calculate the effect of any revenue requirement change on final rates should be included. All workpapers must include a table of contents, page numbering, and cross-references to issues discussed in testimony, and must be arranged in a logical fashion.

Class A Water Utilities

Rate Case Plan

Attachment 2 of 2

Minimum Data Requirements for Utility

Cost of Capital Application and Testimony

Testimony served concurrently with the cost of capital application must include data responsive to the specific topics and questions listed below, among other information necessary to support the request. The application and testimony need not respond to the Minimum Data Requirements in the order presented below, but must include a cross reference that identifies where each topic and question is addressed in the testimony. Provide responses both on a company aggregate and individual district basis as appropriate.

A. List most recent authorized return on equity and rate of return on rate base, with reference to decision number.

B. Report actual return on equity and rate of return on rate base annually for the past five years.

C. Describe the proposed capital structure and rate of return. Identify and explain all significant changes from last adopted capital structure and cost of capital. Report cost of capital information in summary table as set out below:

	Test Year ____ Escalation Years ____ and ____
	Capital Structure	Cost	Weighted Cost
Debt
Preferred Stock
Common Equity
Total	100.00 %

D. Regarding long-term debt:

1. List the sinking fund amounts for each issue, by issue, by year.

2. List the retirements by issue, for the current year.

3. List the interest rates for each issue, by issue.

4. List the terms of each issue, by issue, with issue date and date due.

5. List the cost of issuance for each issue, by issue.

6. List name of lender for each issue, by issue.

7. Provide the formula used to determine the cost of new issues of long-term debt (Example: 30-year Treasury Bond + 100 basis points), as well as the reason for using the particular rate and basis point premium.

8. If company or affiliate is rated by S&P, provide rating. If not rated, what would be rating based on forecast cost of new debt?

E. Are company stocks, bonds, or company as a whole rated or commented on by any organization or agency?

a) If so, provide name(s) and phone number(s) of rating/commenting organization(s) and the ratings/comments received in the past 12 months.

b) Provide this information on an ongoing basis.

F. List actual rate base for the past five years, by year, by district.

G. Workpapers are served but not part of the application and should include:

1. Copies of all publications, articles, book references, regulations, and decisions, referenced in testimony.

2. Supporting documentation for all models used to determine return on equity.

(END OF APPENDIX A)

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¹⁷ Use most recent 12 months of available data; revise with complete calendar year data when available.

¹⁸ A significant expense is equal to or greater than 1% of test year gross revenues.

¹⁹ Forecast customers using a five-year average of the change in the number of customers by customer class. Should an unusual event occur, or be expected to occur, such as the implementation or removal of limitation on the number of customers, then an adjustment to the five-year average will be made. Calculate customer consumption by using a multiple regression (any commonly used multiple regression software could be employed, e.g., Eviews, SAS, TSP, Excel, Lotus), based on the material in the "Standard Practice No. U-2" and the "Supplement to Standard Practice No. Utilities-25" with the following improvements: (A) Use monthly data for ten years, if available. If ten years' data is not available, use all available data, but not less than five years of data. If less than five years of data is available, the utility and DRA will have to jointly decide on an appropriate method to forecast the projected level of average consumption; (B) Use 30-year average for forecast values for temperature and rain; and (C) Remove periods from the historical data in which sales restrictions (e.g., rationing) were imposed or the Commission provided the utility with sales adjustment compensation (e.g., a drought memorandum account), but replace with additional historical data to obtain ten years of monthly data, if available.

²⁰ Forecast water sales for all classes of customers for utilities that are under government-mandated production limitations based on that limitation and consideration of unaccounted for water and historical production reserves while under the imposed limitation. Water sales for customer classes other than residential, multifamily, and business (such as industrial, irrigation, public authority, reclaimed, and other) will be forecast on total consumption by class using the best available data.

²¹ Estimate test year sales revenues based on the test year sales and customer forecast. Estimate other revenues using the best available data.

²² For district and general office expenses, excluding water production related expenses, parties may forecast using traditional estimating methodologies (historical averages, trends, and specific test year estimates). In addition to any other methodology the utility may wish to use, the utility shall also present, in its workpapers, an inflation adjusted simple five-year average for all administrative and O&M expenses, with the exception of off-settable expenses and salaries.

²³ The utility and DRA shall use the "New Committee Method" to forecast per customer usage for the residential and small commercial customer classes in general rate cases.

²⁴ In addition to any other methodology the utility may wish to use, the utility shall derive the test years and attrition year estimates by taking the year-end properly recorded plant balance of the latest recorded year and adding to it the average plant additions of the last five years. The results of this methodology may be included in workpapers.

²⁵ For example, real property subject to Water Infrastructure Improvement Act of 1995 (Pub.Util. Code §§ 789, 789.1, 790, 790.1).

²⁶ May include a water revenue adjustment mechanism, shareholder/ratepayer conservation incentives, or other approaches.