Golden State Water Comin' at Ya Again

Unhappy with its prospects in the normal rate-setting process, Golden State Water Company has filed an Advice Letter with the California Public Utilities Commission for an immediate unjustified increase of almost $4.5 million on top of the some $95 million it already collects from its territory which includes Claremont.

Notice of Interim Rate Increase by

Golden State Water Company
Region III Service Territory
Advice Letter 1309-W

A notice hit people's mailboxes Saturday afternoon and we here at the Insider have been inundated with an email about it ever since.

But that's how it is with these things--mostly hushed silence. And that is fine with Golden State. The water company wants to make this whole rate-setting deal as opaque as possible. The notice does contain the occasional clause written in more or less simple declarative English: "...company's request to implement an interim rate increase for 2009", "...seeking to increase rates by $4,481,200 or 4.74% in 2009", "...the monthly bill would increase...", "would experience a monthly increase..."

After the cheery news heading page two that "[w]ritten public comment by GSWC customers is very much desired by the CPUC...", we find that one has to be practically a water law attorney to even get started: "A protest objects to the advice letter in whole or in part and must set forth the specific grounds on which it is based..." and then goes on to list six acceptable grounds. See them on page two of the notice, elsewhere in this post. However, the first one seems straightforward enough: "(1) The utility did not properly serve or give notice of the advice letter."

Our guess is that Golden State probably complied with the legal requirement for notice, whatever that may be and wherever that may be found. But who would know? Who among the thousands customers would know this?--those who received this notice more than two weeks after the filing date (November 18) and just two days before the 20-day protest period closes (by our count, close of business on Monday, December 8).

And who among the Golden State customers can just dash off a weekend letter to the Public Utilities Commission protesting that "(2) [t]he relief requested in the advice letter would violate statute or Commission order, or is not authorized by statute or Commission order on which the utility relies"?

And in case you thought, maybe, you could address that issue, be sure to note that "[a] protest shall provide citations or proofs where available to allow staff to properly consider the protest."

To make the whole exercise even more obscure, there is no copy of Advice Letter 1309-W, and we spent the wee hours of Saturday night and most of the day Sunday looking. Not on the Golden State website. Search for it and you get this:

Not on the CPUC website. We'll spare you the search process, but the only CPUC document mentioning Advice Letter 1309-W appears to be the Commission's daily calendar for November 19, memorializing receipt of the aforesaid advice letter the day before (and giving the only clue, if we read it right, of the filing date--it's buried quite far down in a long document).

So how is the protesting customer supposed to protest and object to the advice letter in whole or in part and set forth the specific grounds on which it is based, without knowing what is contained in the advice letter?

We may be forced to rely on the City of Claremont to carry our water--as it were--on this matter. Remember, the City has engaged BBK to work the problem of outlandish rate increase proposals by Golden State Water Company made to the Public Utilities Commission. Maybe this will come up at Tuesday's council meeting, though it's not on the agenda.

Meanwhile, in case you want to dash off your own protest and have lost the notice, here is what Golden State sent that arrived over the weekend (as with all images, click on the image to enlarge):