Emerging Issues Forum

 
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Name: Mark Rentz

Comments: The Association of California Water Agencies (ACWA) opposes the public goods charge (PGC) as described in the white paper, "Implementing a Public Goods Charge for Water". In addition to outlining inherent flaws with the proposal, we have provided several reasons why we oppose a public goods charge below: 1) The proposal makes a fundamental error in attempting to “transplant” the public goods charge, as instituted in the investor-owned utility (IOU) sector, into public water agency sector. 2) The proposal might be considered a fee that imposes a general State tax on water use, and consequently would require a two-thirds vote by the Legislature (or the voters) under the recently passed Proposition 26. 3) ACWA does not believe that a public goods charge is warranted; especially given the already significant investments that water agencies are making in conservation programs which provide both water supply and greenhouse gas reduction benefits. 4) A public goods charge could reduce the ability of water agencies to invest in energy efficiency and water conservation programs. 5) The re-distributive component of the proposal would punish agencies that have already made significant investments in energy and water efficiency and conservation and other stewardship efforts. 6) Local water managers are best suited to identify ways to spend locally-generated revenues on projects that will most cost-effectively reduce greenhouse gases at their respective agencies. 7) The proposal ignores significant legal obstacles to the implementation of the public goods charge; broad classes of expenses associated with climate change mitigation and adaptation efforts are not all legally authorized “uses” of water agency ratepayer funds under the California Water Code and Proposition 218. 8) The white paper designates the Department of Water Resources as the entity responsible for implementing this tax; however, the Department has no current authority or organizational structure in place to be able to collect the funds. We appreciate your consideration of our comments. If you have any further questions about our comments, please do not hesitate to give me a call at (916) 441-4545. Sincerely, Mark Rentz Director of Regulatory Affairs
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