22. Reconnection Fees

SCWC Tariff Rule No. 11, paragraph C, subsection 1, addresses the reconnection fee charged when services have been discontinued for violation of CSWC's rules or for nonpayment of the bill. The existing fee is $10 for reconnection during regular working hours or $15 for reconnection when the customer requests that the reconnection be made at other than regular working hours.

SCWC believes that the current fees do not reflect the true cost of the reconnection, and requests that the fees be raised to $25 for reconnection during regular working hours and $65 for reconnection outside of regular working hours. SCWC indicates that this increase would bring SCWC's reconnection fees in line with the fees California Water Service (CWS) charges its customers for the same service.

In its opening brief, ORA states its opposition to the reconnection fee increase for work done during non-working hours, indicating that the true cost of connection has not been documented. ORA also states that it is not in a position to assess why CWS charges this rate and whether or not it is reasonable.

In response, SCWC states ORA did not submit any testimony opposing SCWC's request to increase its reconnection fee and has no basis to contend that SCWC should not be reimbursed for its actual costs of reconnection.

ORA does not oppose the fee increase from $10 to $25 during working hours, and the increase appears reasonable. We will adopt that increase. Costs for work during non-working hours should be higher, principally for premium pay considerations. While ORA did not submit any testimony on this issue, SCWC still has the burden to demonstrate why its charges are reasonable. In that respect, there is little evidence on the record, other than SCWC's claim that the new charge reflects true costs and is in line with that charged by CWS. The current non-working hour fee is 150% of the current working hour fee, which seems reasonable if overtime pay is necessary. The proposed non-working hour charge is 260% of the proposed working hour charge. The disproportionate increase is questionable and unexplained. We will therefore maintain the current 150% differential in determining the non-working hour charge. Increasing the proposed $25 working hour charge by 150% results in a fee of $37.50. In the absence of true cost documentation, we will adopt $37.50 as the non-working hour reconnection fee.