10. Suburban's Customer Outreach and Education, Data Collection, and Reporting Settlement
Suburban, DisabRA, LIF, NCLC and TURN reached a settlement on customer education, outreach, data collection, and reporting. The settlement includes methods for creating and distributing conservation rate customer notices, LIRA customer notices, and conservation and LIRA outreach methods. The settlement includes a summary of data collection and reporting.
10.1. Customer Outreach and Education
Suburban will inform its customers about conserving water, the benefits of water conservation on the ecosystem, and the changes to the bill in light of the water conservation effort. Included in the written material will be an explanation about how rates are changing and how the changes will impact the bill, what the average change will be, and when the change will become effective. Outreach will include a phone number to request a notice written in Spanish. Key information will be provided in large type. Finally, contact information, such as website and a TTY number, also will be provided.
Suburban will provide a separate notice to all customers about LIRA: who is eligible, how to apply, the renewal process and the discount amount. This notice will be summarized in Spanish and include a number to call for a complete notice in Spanish. The notice will also contain key information in large type and include contact information such as website and TTY number.
In addition to including the separate notices with the monthly bill, the notices will be posted on Suburban's website in a clear and conspicuous manner in both Spanish and English. Targeted flyers will be distributed throughout the Spanish-speaking communities within Suburban's service territory. A phone message system will be deployed to provide abbreviated statements on conservation rates and low income assistance and will allow a customer to leave a request for materials in Spanish.
CFC supports the settlement, with a few modifications, as an example that also can be applied to CalWater and Park. CFC recommends that the notice also instruct customers on how they can reduce their water bill.33 CFC also would like to see a forum for customers to employ in communicating with Suburban. In the current plan, customers can request further information but are inhibited by the one way nature of the flow of that information. CFC states that interactive conversation is a valuable tool to encourage conservation.
10.2. Data Collection and Reporting
Suburban will provide an annual report on the conservation rates and WRAM as a supplement to its Annual Report filed with the Commission. The conservation rates report will include usage data.34 Suburban also will provide an annual report on the LIRA program as a supplement. The LIRA Report will include data to assess participation in the program and the impact of conservation on LIRA customers.35
The settlement is a comprehensive education and monitoring program. CFC's suggestion that notice include education about reducing water bills is well taken. The communications we have received from customers on the proposed settlements show that the information provided in bill inserts has not completely clarified the impact of conservation rates. Customers are concerned that their rates will increase; therefore, many oppose conservation programs. Educating customers about the impact of conservation rates should include information on reducing bills in light of the new rates. We will not direct Suburban to provide an additional forum for educating customers about conservation. The proposed education and outreach efforts appear to be sufficient.
The settlement promotes conservation and advises customers of the benefits of conservation and the impacts on their bill in light of the conservation rates. The settlement is reasonable in light of the whole record, consistent with the law, and in the public interest. Thus, we shall adopt the settlement.
10.3. Applicability to CalWater and Park
CalWater and Park have objected to adopting the Suburban settlement as a model for customer education and outreach and for data collection. Despite its objection, Park agrees in principle with the recommendations of the Joint Consumers. Park has agreed to continue to work with the Joint Consumers on customer outreach and education, especially in areas where Park has limited or no experience. These areas include outreach to Spanish speaking customers in areas with a small population of limited English literacy. Park has reached an agreement on data collection and reporting with the Joint Consumers and CFC.
CalWater objects to the application of the settlement to its customer education and outreach efforts and to its data collection. CalWater serves a much larger population and geographic area, both of which are diverse and spread out compared with Suburban's smaller customer base and contiguous, homogeneous geography. CalWater already has in place a billing and data collection system which is not flexible and would require a major and expensive overhaul to accommodate some of the features that Suburban is attempting to implement in its revamped system.
In response to the Joint Consumer's assertions that CalWater does not have a plan in place to educate Spanish-speaking ratepayers in areas where they constitute a low percentage of the population in general, CalWater states it already has made plans to provide Spanish-speaking representatives at its new call center. CalWater does not believe it should be made to incur the additional expense of setting up an 800 number or voicemail to accommodate this small population in the interim.
CalWater acknowledges the Joint Consumers', and the Commission's, desire for information on arrearages and shutoffs to monitor and establish the effectiveness of the new rate design. CalWater asserts that there is no evidence to support the Joint Consumer's contention that the proposed rate design may present a hardship on consumers. CalWater states it has demonstrated that the rate design would not increase rates for indoor usage even for large households.
We decline to require CalWater and Park to adhere to the Suburban agreement with the Joint Consumers. Although we directed parties to address customer education, monitoring and reporting in the settlement agreements or motions proposing them, we did not intend to adopt uniform standards. Further, it is not necessary to require Park to adhere to the letter of the Suburban settlement. Park has agreed to work with the Joint Consumers on an ongoing basis on areas where the Joint Consumers have expertise and has entered into a separate data collection settlement. CalWater has agreed to some customer education and reporting requirements.36 CalWater has not agreed to provide information on past due accounts and disconnections and subsequent restorals of service. CalWater's efforts may be sufficient; however, we note that a number of CalWater's customers, including low-income and senior citizens, have contacted our Public Advisor with concerns about or opposition to the settlement. It would be prudent for CalWater to coordinate its customer education, outreach and reporting efforts with those of the other utilities in order to provide comparable information to its customers. In coordinating its efforts with community based organizations, CalWater should assess whether it needs to augment its outreach to Spanish speaking customers by providing more materials in Spanish pending the establishment of its call center and access to Spanish speaking customer service representatives. While we will not require CalWater to undertake major modifications to its billing and data collections system at this time, providing some data on disconnections would assist us in monitoring the impact of conservation programs on CalWater's customers.
33 See, e.g., Exhibit 19, Exhibit 1.
34 Usage date will include: monthly customer usage in billing units by Blocks I and II separated by meter size, by zone, by service area and by customer class and the number of customers in each sub-grouping; monthly customer usage in billing units by Blocks I and II separated by meter size, by zone, by service area, for LIRA customers and the number of customers in each sub-grouping; monthly usage for current month of the current year vs. prior year, using average customer profiles; the number of customers in each customer class, with residential and commercial customers broken out; monthly number of reconnections, with LIRA customers broken out; total number of disconnections per month; total number of 48-hour shutoff notices per month; and total revenue collected under new rate design vs. calculated revenue under the adopted uniform standard rate design, by month.
35 The LIRA data will include: number of customers participating by month; annual penetration rate (compared to estimate of low-income population in the service area); change in participation rate after the notices, to measure effectiveness of notice methods; costs and expenses of the LIRA program if not already tracked by the balancing account; monthly customer usage in billing units by Blocks 1 and 2 separated by meter size, by zone, by service area, for LIRA customers; monthly number of reconnections, with LIRA customers broken out; total number of residential disconnections per month; and total number of residential 48-hour shutoff notices per month.
36 CalWater has agreed to provide notice regarding new conservation rates on customer bills and bill inserts; to use its current customer notice procedures to reach Spanish speaking customers, including procedures that provide varying levels of notice in Spanish depending on the percentage of Spanish speaking customers in the district; to refer Spanish speaking customers in districts with low numbers of those customers to its call center to obtain information in Spanish once the call center is implemented; to contact community based organizations to seek assistance in communicating with customers about conservation rates and to combine education on conservation rates with its LIRA education program when feasible; to take steps that will improve its communication with customers with disabilities, including requesting TTY service company-wide as part of its request for a call center, providing website accessibility for vision impaired customers, and prominently displaying amount due, contact number and due date on its bill; to provide data regarding bill payment history, including annual number of customers in each class and monthly number of residential customer accounts; and to provide data regarding usage, including monthly usage in billing units by tier/blocks separated by meter size and customer class (same for LIRA), monthly customer usage for current month of the current year versus prior year, using average customer profiles at different usage levels (with a separate LIRA profile), and weather normalized monthly usage data made available to intervenors upon request during each GRC proceeding.
