WRAP revisited, more PG&E info and SJWC practices

We'll re-visit the qualification process or lack thereof, in getting the low income discounts. Which are  provided to PG&E and San Jose Water Company customers (ratepayers), with apparently unsubstantiated or unverified incomes. It starts with apparently PG&E effectively using an "honor" system. San Jose Water Company then accepts participation in the PG&E program as "qualification" and acceptance in the SJWC program. Keep in mind several points:

1. Verifiable low-income families, deserve our help and the help of the San Jose Water Company.
2. Poorly managed, unverified and administered low income programs are an encouragement to abuse.
3. San Jose Water Company has little or no monetary incentive to run a well managed program, since it's our money they are spending, the monthly proposed WRAP surcharge.
4. San Jose Water Company historically seems to exhibit a lack of transparency. This results in little disclosure for public and press to agree with or critique. Removing adverse public opinion for any scenario.

PG&E low income qualification

PG&E accepts unsupported by requests for participation, click to view Application:

• 7. Following enrollment, you may be required to provide proof of qualifying household income, including IRS Tax Return Transcripts, and agree to participate in the Energy Savings Assistance program to remain enrolled in CARE.

It looks like there's little review of applicants by PG&E. To be fair there has been a report of abuse of the low income discount program.  Apparently the abuse was found in Eureka and reported by the Times Standard:

• The program is being widely abused by indoor, off-the-books marijuana growing operations that gobble up huge amounts of electricity.
  
  The utilities commission recently decided that CARE-enrolled homes that exceed 600 percent of a baseline electricity usage will have 90 days to lower usage or be removed and barred from the discount program for two years.

I've researched and tried to find other references, but so far most seem directed towards "marijuana growing operations". It would be interesting to ask PG&E  what percentage of participants in their CARE and other low income programs are actually verified before the discounts are provided.

San Jose Water Company (SJWC) low income qualification

SJWC provides participation based on participation in the PG&E CARE program. This is stated clearly in the Application, click to view Application:

• San Jose Water Company’s program automatically qualifies customers enrolled in PG&E’s rate assistance CARE program.

Demographics and a bit of analysis

Based on the 2012 Annual report SJW Corporation filed with the SEC, SJWC (wholly owned subsidiary) has 227,000 connections, serving roughly 90% of San Jose. SJWC in their filing A 13-06-008, with CPUC, SJWC indicated they are providing discounts for 24,400 low income participants in San Jose.

The current demographic info indicates about 20.3% of families, in San Jose have annual incomes below $34,999. The San Jose estimate of  24,400 / (227,000 x 90%) = 11.03%, of the served San Jose population are participating in the San Jose Water Company WRAP program. 

This raises some questions for San Jose Water Company, since they are spending our (ratepayers) money.

• How many of the SJWC WRAP participants entered the program from the PG&E program?
• What verification does SJWC do to verify WRAP participants income? if so how many each year?
• Does SJWC have a program to prevent abuse of the WRAP program?

Let's back into the amount that ratepayers will pay with the surcharge applied for. The average monthly water bill is about $68.00, so a 15% monthly discount is $10.20. Based on the WRAP surcharge of $1.15 per month, $1.15/$10.20 = 8.9 ratepayers per low income discount. So, 8.9 ratepayers x 24,400 = 217,160. The current surcharge should "barely" cover the cost, of the actual benefit. Ouch! Doh! what happens when we add the 24,400 receiving the discount with the ratepayers supporting the surcharge 217,160 (estimated) we get, 217,600 + 24,400 = 241,560. We have too small a surcharge increase, to few ratepayers paying the WRAP surcharge or too many people claiming the WRAP discount?

Some comments

I'm sitting here a few minutes before midnight thinking of both the good a low income water and electric discount can mean to low income families, as well as the the potential abuse and added expense, for ratepayers, that potentially the present programs may suffer from. The current programs suffer from several apparent failures:

• No real motivation, for the utilities, except "public opinion" and bad press coverage, since the ratepayers pay for the program.
• No apparent real management, by the utilities. of the low income discount programs, to prevent fraudulent applications and abuse of the programs.
• The request for example in San Jose Water Company, to simplify annual adjustments with a "minimum" of CPUC and DRA review.
• There is little apparent incentive not to submit a fraudulent applications basically no penalties. You simply do not collect the discount and have to wait a short period of time to re-apply.

If you are concerned send email to CPUC at:

CPUC Public Advisor,  public.advisor@cpuc.ca.gov  The Public Advisor will insure your email will be sent to all the appropriate CPUC staff members.

District 5 United eForm eMail  Simply click on the "eForm eMail" and you will get a page to fill out the information and specify the reason for your opposition to the SJWC 475% WRAP increase..

Please include the following points in your email:

"I oppose the proposed SJWC Application No. 13-6-008 Requesting a large and dramatic  increase. of 475%, to the Monthly WRAP Surcharge ."

State one or more reasons...............

• I want more information justifying the 475% increase, for the monthly WRAP surcharge!
• I want more information about the major increase of participants, how many did get "grandfathered" into the SJWC WRAP based on data supplied by PG&E!
• I want more information assuring me that, all or nearly all,  this money will go to low income Ratepayers!
• I don't want this to annually renew without CPUC review and justification of the expense! 
• No real motivation, for the utilities, except "public opinion" and bad press coverage, since the ratepayers pay for the program.
• No apparent real management, by the utilities. of the low income discount programs, to prevent fraudulent applications and abuse of the programs.
• The request for example in San Jose Water Company, to simplify annual adjustments with a "minimum" of CPUC and DRA review.
• There is little apparent incentive not to submit a fraudulent applications basically no penalties. You simply do not collect the discount and have to wait a short period of time to re-apply.

Thank you for sending your opinion to CPUC Public Advisor

and using the District 5 United eForm eMail . Let's help our

neighbors that need the discount, but prevent abuse.