James Hunter

Thursday, June 11, 2015

SJWC Letter to Rami Kahlon, Director Division Water & Audits, follow up 6/11/2015

I sent the following letter to the CPUC Public Advisor and raised several issues. Since I'm not a lawyer and I don't have secretarial support, it takes a while to wade through an 8 page letter, as well as following up on references to other documents. I did also copy SJWC Regulatory Affairs as well the CPUC Water Division. A response would take 2-3 days, for me to complete.

I felt several things were going on:

  • The timing is very rushed for ratepayers response, but much less so for a corporation, SJWC.
  • The Advise Letter procedure was designed to prevent or make it more difficult, for ratepayers to protest.
  • From the 35 "customer responses" that SJWC refers to. really understates ratepayers concerns and really says, two things the 350 ratepayers attending the public hearing and the 60 or more who made the effort to speak did not get to make their feelings heard "officially I suppose is a good way to phrase it". The Public Hearing announcement said the purpose was to "explain the rate process and to receive public input". 
  • I just found out a few minutes ago that Juan Estrada's group District 5 United sent almost 600 email petitions to CPUC, as well. That makes the 35 "customer responses" that SJWC refers to a bit ludicrous in my opinion. 
I'll post the response, if any is received, the goal is a decision by CPUC on 
June 15th 2015, next Monday!

_____________copy of email sent to CPUC, Thu, Jun 11, 2015 at 4:00 PM_________________

From: James Hunter <j88hunter882@gmail.com>
Date: Thu, Jun 11, 2015 at 4:00 PM
Subject: SJWC Response Letter to Rami Kahlon, Director, Div. of Water & Audits,June 5, 2015
To: "Public.advisor" <public.advisor@cpuc.ca.gov>
Cc: Regulatoryaffairs@sjwater.comwater_division@cpuc.ca.gov

I have several questions regarding this letter and the dates which are relevant to responding to the assertions made by San Jose Water Company, Stephen Owens, Manager of Regulatory Affairs.

The following is the time sequence leading up to today and the ratepayers/customers participation regarding Advise Letters # 472 and #473: Based on the following points please advise regards the following:
  • The closing paragraph, on page 7 of the letter, indicates the following:

    Inline image 1
  • During the afternoon of 6/11/2015 I re-read the letter researched points and prepared this email, to go to the CPUC Public Advisor.
  • I scanned the letter and the envelope and placed them on my Blog, sjwc-rate-increase.blogspot.com, during the evening of 6/10/2015
  • I read the letter from SJWC at about 4:00 PM on 6/10/2015
  • I received the letter on 6/10/2015, about 2:30 PM, in my mailbox
The following questions are:
  1. May a response be made to this letter challenging some of the assertions made by SJWC?
    If not why not?
  2. If response may be made what is the latest date/time it can be sent to CPUC?
  3. Who would the appropriate CPUC parties this potential response be sent to?
    the SJWC letter was sent to Rami Kahlon, Director, Div. of Water & Audits?
    If a response may be made a copy would be sent to SJWC Regulatory Affairs.
  4. The SJWC letter implies that the closing date was June 1, 2015, which was
    20 days from May 11, 2015, but both Advise Letter #472 and #473 were modified and
    re-filed on June 9, 2015. It should be also noted that the Public Hearing was held on
    May 28, 2015. One of the many concerns did get included in the updates, appeals would
    be considered by SJWC regards the number of people in a residence and appeals regarding
    health issues of residents would be considered.
  5. An independent count of attendees by a Mercury News reporter determined there were
    350 ratepayers attending and over 60 spoke at the hearing,
    in spite of the fact that
    it became apparent that ratepayers comments were not being 
    transcribed or serious notes
    being taken by SJWC. The SJWC letter only references 35 
    responses or 1/10th compared
    to the attendance at the hearing, which would corroborate 
    the assertion the the
    Public Hearing. SJWC did not collect or represent ratepayers comments, 
    and was apparently solely for the purpose, explaining the Drought Response, 
    as required
    in 14.1 and being able to say a hearing was held. 

Thank you for your consideration,

 James Hunter
 Direct phone number (for privacy phone number redacted)

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