BILL ANALYSIS                                                                                                                                                                                                    Ó






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          |SENATE RULES COMMITTEE            |                       AB 1180|
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                                   THIRD READING 


          Bill No:  AB 1180
          Author:   Cristina Garcia (D) 
          Amended:  6/6/16 in Senate
          Vote:     21 

           SENATE ENERGY, U. & C. COMMITTEE:  11-0, 6/13/16
           AYES:  Hueso, Morrell, Cannella, Gaines, Hertzberg, Hill, Lara,  
            Leyva, McGuire, Pavley, Wolk

           SENATE APPROPRIATIONS COMMITTEE:  5-0, 6/27/16
           AYES:  Beall, Hill, McGuire, Mendoza, Nielsen
           NO VOTE RECORDED:  Lara, Bates

           ASSEMBLY FLOOR:  71-3, 1/25/16 - See last page for vote

           SUBJECT:   Rates and charges for water service:  payment  
                     transaction fees


          SOURCE:    California Water Association
          
          DIGEST:   This bill allows, until January 1, 2022, specified  
          water corporations to establish pilot programs, once approved by  
          the California Public Utilities Commission (CPUC), that evaluate  
          customer interest in using credit cards, debit cards and prepaid  
          cards to pay utility bills, without requiring an individual  
          payment transaction fee.  This bill allows specified water  
          corporations to recover the reasonable expenses incurred in  
          providing its customers with these bill payment options.


          ANALYSIS:  









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          Existing law:


          1)Establishes the CPUC to regulate privately owned public  
            utilities in California.  (Article XII of the California  
            Constitution)


          2)Requires the CPUC to establish the California Alternate Rates  
            for Energy (CARE) program of assistance to low-income electric  
            and gas customers with an annual household income not greater  
            than 200 percent of the federal poverty guideline levels.   
            (Public Utilities Code §739.1)


          3)Requires the CPUC to consider programs to provide rate relief  
            for low-income ratepayers of water corporations.  (Public  
            Utilities Code §739.8)


          4)Authorizes an electrical, gas, or water corporation to offer  
            credit card and debit card bill payment options, if approved  
            by the CPUC, and, upon approval, authorizes an electrical,  
            gas, or water corporation to recover, through an individual  
            customer transaction fee, reasonable transaction costs  
            incurred by the electrical, gas, or water corporations from  
            those customers that choose those methods of payment.  (Public  
            Utilities Code §755)


          5)Establishes the Low-Income Oversight Board to advise the CPUC  
            on low-income electric, gas, and water customer issues and  
            serve as a liaison for the CPUC to low-income ratepayers and  
            representatives.  (Public Utilities Code §382.1)


          6)Exempts from the existing prohibition upon retailers to impose  
            a surcharge on a cardholder who elects to use a credit card in  
            lieu of payment by cash, check or similar means the  
            transaction fee charges of an electrical, gas, or water  
            corporation, and approved by the CPUC, on customer bill  
            payments made by credit card or debit, and related penalties  
            and cause of action.  (Civil Code §1748.1)







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          This bill:


          1)Authorizes, until January 1, 2022, a water corporation with  
            more than 2,000 service connections to seek CPUC approval  
            through its general rate case to operate a pilot program  
            designed to evaluate customer interest in, and utilization of,  
            bill payment options, including, but not limited to, credit  
            card, debit card and prepaid card bill payment options, and to  
            assess the cost-effectiveness of, and customer interests  
            served by, customer access to those bill payment options. 


          2)Limits the pilot program to the duration of the water  
            corporation's rate case cycle, but allows the CPUC to extend  
            the program at the request of the water corporation in its  
            subsequent rate case application.


          3)Requires the CPUC to allow a water corporation to recover the  
            reasonable expenses incurred by the water corporation in  
            providing its customers with these bill payment options, and  
            to allow water corporations to not impose a transaction fee on  
            its customers for using these bill payment options.


          4)Prohibits the costs of a pilot program from being recovered of  
            low-income customers who participate in specified programs,  
            and would require a water corporation that is operating a  
            pilot program to provide certain notifications to its  
            customers. 


          5)Requires the CPUC, in consultation with the Low-Income  
            Oversight Board, by July 1, 2020, to submit a report to the  
            relevant legislative committees regarding the pilot programs  
            operated by water corporations under this bill that includes  
            an assessment of the use of credit cards by low-income  
            customers to avoid service disconnections, an assessment of  
            the impact of use of credit cards for customer bills on  
            household debt burden, and an assessment of data considered on  
            an aggregate basis regarding customer utilization and the  







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            cost-effectiveness of the bill payment options. 


          6)Requires the report, based on these assessments and an  
            assessment of the customer interests served by providing these  
            bill payment options, to evaluate the usefulness of an  
            individual customer transaction fee and include a  
            recommendation regarding individual customer transaction fees  
            for credit card, debit card and prepaid card payments accepted  
            by water corporations.


          7)Provides that the bill shall remain in effect until January 1,  
            2024 and is repealed unless another statute is enacted.


          Background


          CPUC's regulation of water utilities.  The CPUC has jurisdiction  
          over 113 privately owned water utilities: nine Class A water  
          utilities (10,000 or more connection points); five Class B water  
          utilities (2,000 or more connection points); 25 Class C water  
          utilities (500 or more connection points); and 74 Class D water  
          utilities (less than 500 connection points).  Combined, these  
          utilities deliver water service to roughly 16 percent of the  
          state's population (about six million residents). The CPUC  
          regulates all aspects of the privately owned utilities' service  
          provision, including assessing their rates to ensure they are  
          reasonable, while providing a reasonable rate of return to  
          continue to provide customers service and satisfy shareholders. 


          Credit cards and utilities.  Currently, the CPUC requires  
          electric, natural gas, and water companies it regulates to get  
          approval from the CPUC to offer a credit/debit card bill payment  
          option.  As more and more customers turn to credit or debit  
          cards as their primary payment method, companies must determine  
          how to pay for the transaction cost of each payment.   For the  
          most part, unregulated retail and service providers recover the  
          transaction cost by increasing the price of the good or service  
          sold or absorbing the costs.  In the case of a regulated  
          utility, current law allows investor-owned utilities to recover  
          reasonable transactions cost, but only from those customers that  







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          choose to pay by those payment options.  As a result, some  
          utilities assess a separate fee on top of the monthly bill, when  
          a credit card is used to pay the bill.  According to the CPUC,  
          in the case of water corporations, the fee generally ranges  
          between $1 to $3.  According to the sponsor, this transaction  
          fee frustrates customers.  While other forms of payment such as  
          check processing or cash payments also generate some cost to the  
          utility in order to process the payments, those transactions are  
          not assessed on an individual fee to the user.  Unlike credit or  
          debit card fees, all the other payment transaction fees are  
          spread across the entire customer base and recovered in utility  
          rates.


          Impact on ratepayers.  By allowing water corporations to forgo  
          the individual transaction fee in lieu of recovering the  
          reasonable expenses in the general rate case, ratepayers may  
          experience an increase in rates to cover the costs.  However,  
          it's also likely the increased costs would be fairly minimal and  
          possibly consistent with costs associated with processing other  
          payments.  When a customer may be about to have the service  
          shutoff because of lack of payment, the option to pay with a  
          credit card, depending on the terms of the credit card, may be  
          less costly than the fee to have the service shutoff and  
          restarted. 


          CPUC low-income assistance for water ratepayers.  Of the  
          privately-owned utilities, the CPUC has authorized the largest  
          nine water utilities to offer low-income rate assistance (LIRA)  
          programs similar in concept to those provided to electricity  
          customers through CARE.  However, each program is varied in  
          terms of the amount of the assistance provided to low-income  
          customers and the collection of the surcharge from  
          non-participating ratepayers to cover the cost of the program.  
          Combined, the nine largest utilities serve approximately 1.175  
          million customers.  In CPUC Decision D.11-05-020, the CPUC  
          ordered large water and energy utilities to exchange information  
          about their low-income customers to cross-promote the goal of  
          increasing participation in both programs.  According to the  
          CPUC, the effort has yielded a substantial increase in  
          participation in the programs.  By exempting LIRA and CARE  
          eligible customers from the individual transaction fee, Class B  
          utilities that do not operate a LIRA program will need to  







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          identify eligible customers through a different mechanism. 


          Pilot programs already underway.  The CPUC has already approved  
          pilot programs to allow some water utilities to provide their  
          customers the option to pay their utility with a credit or debit  
          card, without an individual transaction fee. However, unlike  
          this bill, those pilot programs would require the utility to  
          absorb any net costs in providing the credit card option.  In  
          August 2014, the CPUC approved a settlement of a 2012 General  
          Rate Case application by the California Water Service Company  
          (CalWater) which includes a pilot program to track costs and  
          savings of processing credit and debit cards  
          [https://www.calwater.com/docs/grc/2012/settlement/Exhibit_A_-_Se 
          ttlement_Agreement.pdf].  CalWater agreed that any costs that  
          exceed the savings would be absorbed by CalWater, instead of  
          ratepayers. In its 2015 General Rate application, CalWater  
          proposed to make the credit or debit card program permanent.   
          According to CalWater's testimony in this case, approximately  
          15,000 LIRA and approximately 43,000 non-LIRA customers have  
          paid their monthly water bills using credit cards.  The average  
          cost of processing each credit card transaction is $1.26 if it  
          is an automated transaction.  Suburban Water Systems, has  
          initiated a pilot program, effective January 1, 2015, and has  
          similar terms as the CalWater settlement, including the  
          provision that any costs exceeding the savings would be absorbed  
          by Suburban Water Systems, instead of ratepayers  
          [http://www.swwc.com/suburban/tariff-preliminary-statement2.pdf]. 
            Additionally, CalWater reports that a growing number of  
          customers are using credit cards to avoid discontinuing service  
          for nonpayment, stating that in 2008 there were 8,814 customer  
          transactions that fell into that category and as of 2014, there  
          were 42,295 credit or debit card transactions over the year to  
          avoid shut-off for nonpayment. 


          Need to assess credit card usage?  This bill attempts to  
          mitigate and better address ratepayer costs by assessing whether  
          the pilot programs create an increase in household debt burden,  
          requiring the utility to assess the pilot program usage, and  
          requiring a report on the cost-effectiveness of the pilots.   
          While well-intended, the reality is that that many consumers  
          have grown accustomed to paying their bills online or by phone  
          with credit cards, prepaid cards or bank accounts.  In general,  







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          consumers in 2016 are likely to appreciate more payment method  
          options, so long as cash and check options are preserved.  The  
          CPUC may not have much expertise in assessing household debt  
          burden and be limited in their ability to access information  
          regarding customer's perspectives on service disruptions as  
          intended by the provisions of this bill. 


          Prior Legislation


          AB 746 (Blakeslee, Chapter 746, Statutes of 2005) permitted an  
          electrical, gas or water corporation to charge a reasonable  
          transaction fee when customers pay their utility bills by credit  
          card and debit card and exempts these fees from an existing  
          exemption on retailers to impose a surcharge for using a credit  
          card for payment. 




          FISCAL EFFECT:   Appropriation:    No          Fiscal  
          Com.:YesLocal:   No
          
          According to the Senate Committee on Appropriations, increased  
          costs of approximately $131,000 per year (Public Utilities  
          Commission Utilities Reimbursement Account) for the CPUC to  
          monitor the rate case, collect and analyze data, and coordinate  
          with the Low-Income Oversight Board. 




          SUPPORT:  (Verified 6/28/16)

          California Water Association (source)
          California American Water
          California Bankers Association
          California Credit Union League
          Central Basin Municipal Water District


          OPPOSITION:   (Verified6/28/16)








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          None received

          ARGUMENTS IN SUPPORT:   According to the sponsor of the bill,  
          California Water Association (CWA): "a 2005 law is discouraging  
          the payment of utility bills online by credit and debit  
          cardholders at a time when more consumers are utilizing the  
          convenience of online bill payment options as their primary  
          method of paying recurring bills." CWA argues that all forms of  
          payment generate some processing costs.  Therefore, residents  
          who choose to use credit or prepaid cards to pay their utility  
          bills should not be penalized with an individual transaction  
          fee.     


          ASSEMBLY FLOOR:  71-3, 1/25/16
          AYES:  Achadjian, Alejo, Baker, Bigelow, Bloom, Bonilla, Bonta,  
            Brown, Burke, Calderon, Campos, Chang, Chau, Chávez, Chiu,  
            Chu, Cooley, Cooper, Dahle, Daly, Dodd, Eggman, Frazier,  
            Gallagher, Cristina Garcia, Gatto, Gipson, Gomez, Gonzalez,  
            Gordon, Hadley, Roger Hernández, Holden, Irwin, Jones,  
            Jones-Sawyer, Kim, Lackey, Levine, Linder, Lopez, Low,  
            Maienschein, Mathis, Mayes, McCarty, Medina, Melendez, Mullin,  
            Nazarian, Obernolte, O'Donnell, Olsen, Patterson, Quirk,  
            Rendon, Ridley-Thomas, Rodriguez, Salas, Santiago, Steinorth,  
            Mark Stone, Thurmond, Ting, Wagner, Waldron, Weber, Wilk,  
            Williams, Wood, Atkins
          NOES:  Travis Allen, Brough, Gray
          NO VOTE RECORDED:  Dababneh, Beth Gaines, Eduardo Garcia, Grove,  
            Harper

          Prepared by:Nidia Bautista / E., U., & C. / (916) 651-4107
          6/29/16 15:56:03


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