Balancing and Memorandum Accounts

San Jose Water Company has established balancing accounts for the purpose of tracking the under-collection or over-collection associated with expense changes and the revenue authorized by the CPUC to offset those expense changes. San Jose Water Company also maintains memorandum accounts to track revenue impacts due to catastrophic events, certain unforeseen water quality expenses related to new federal and state water quality standards, energy efficiency, water conservation, water tariffs, and other approved activities or as directed by the CPUC, such as the WCMA or Tax Act memorandum accounts.

Balancing and memorandum accounts are recognized by San Jose Water Company when it is probable that future recovery of previously incurred costs or future refunds that are to be credited to customers will occur through the ratemaking process. In addition, in the case of special revenue programs such as the WCMA, San Jose Water Company follows the requirements of ASC Topic 980-605-25, “Alternative Revenue Programs” in determining revenue recognition, including the requirement that such revenues will be collected within 24 months of the year-end in which the revenue is recorded. A reserve is recorded for amounts SJW Group estimates will not be collected within the 24-month period. This reserve is based on an estimate of actual usage over the recovery period, offset by applicable drought surcharges, if any. In assessing the probability criteria for balancing and memorandum accounts between general rate cases, San Jose Water Company considers evidence that may exist prior to CPUC authorization that would satisfy ASC Topic 980 subtopic 340-25 recognition criteria. Such evidence may include regulatory rules and decisions, past practices, and other facts and circumstances that would indicate that recovery or refund is probable. When such evidence provides sufficient support, the balances are recorded in SJW Group’s financial statements.

Based on ASC Topic 980-605-25, San Jose Water Company recognized a regulatory liability of $752 due to sales in excess of authorized usage accumulated in the 2019 WCMA account for the three months ended March 31, 2019. Since the balance represents an amount due to customers, San Jose Water Company recorded a regulatory liability for the amount with a corresponding reduction to revenues. The amounts have been reflected in the 2019 WCMA balance shown in the table below.

San Jose Water Company recognized regulatory liability of $309 and $708 due to sales in excess of authorized usage accumulated in the 2018 WCMA account for the three months ended March 31, 2019, and 2018, respectively, based on ASC Topic 980-605-25. As of March 31, 2019, a reserve of $80 was recorded which is the estimated amount that will not be collected within the 24-month period, as required by the guidance. The amounts have been reflected in the 2018 WCMA balance shown in the table below.

Cost of capital memorandum account was approved by the CPUC on March 14, 2018. The account tracks the difference between current water rates and the lower rates adopted in the cost of capital decision on March 22, 2018. San Jose Water Company recorded a regulatory liability of $1,165 in the cost of capital memorandum account for the three months ended March 31, 2018, with a corresponding reduction to revenue. Activity for the three months ended March 31, 2019, represents interest activity on the accumulated balance. The amount has been reflected in the cost of capital memorandum account balance shown in the table below.

The CPUC has directed San Jose Water Company to establish a memorandum account to capture the impact of the Tax Act on its regulated revenue requirement. The CPUC has indicated that any benefit from implementing the new law should ultimately be passed on to ratepayers. Accordingly, San Jose Water Company recorded a regulatory liability of $933 in the tax memorandum account for the three months ended March 31, 2018, with a corresponding reduction to revenue. Activity for the three months ended March 31, 2019, represents interest activity on the accumulated balance. The amount has been reflected in the tax memorandum account balance shown in the table below.



	Three months ended March 31, 2019									Three months ended March 31, 2018
	Beginning Balance			Regulatory Asset Increase (Decrease)		Refunds (Collections) Adjustments		Ending Balance		Beginning Balance			Regulatory Asset Increase (Decrease)		Refunds (Collections) Adjustments	Ending Balance

Revenue accounts:
2014-2017 WCMA*	$	7,750		—		(838	)	6,912		$	6,679		375		1	7,055
2018 WCMA*	9,386			(389	)	—		8,997		—			(708	)	—	(708	)
2019 WCMA	—			(752	)	—		(752	)	—			—		—	—
2012 General Rate Case true-up	11,328			95		(1,271	)	10,152		11,319			—		1	11,320
Cost of capital memorandum account	(1,523		)	(9	)	—		(1,532	)	(144		)	(1,165	)	—	(1,309	)
Tax memorandum account	(6,504		)	(41	)	—		(6,545	)	—			(933	)	—	(933	)
All others	5,112			1,707		(570	)	6,249		3,851			400		—	4,251
Total revenue accounts	$	25,549		611		(2,679	)	23,481		$	21,705		(2,031	)	2	19,676
Cost-recovery accounts:
Water supply costs	9,617			(745	)	(655	)	8,217		8,679			(482	)	—	8,197
Pension	(1,843		)	184		422		(1,237	)	(2,459		)	161		—	(2,298	)
All others	1,090			3		(78	)	1,015		—			—		—	—
Total cost-recovery accounts	$	8,864		(558	)	(311	)	7,995		$	6,220		(321	)	—	5,899

Total	$	34,413		53		(2,990	)	31,476		$	27,925		(2,352	)	2	25,575

* As of March 31, 2019, the reserve balances for the 2018 WCMA was $80 which has been included in the balances above. As of March 31, 2018, the reserve balance for the 2017 WCMA was $1,022 which has been included in the balance above.

As of March 31, 2019, the total balance in San Jose Water Company’s balancing and memorandum accounts combined, including interest, that has not been recorded into the financial statements was a net under-collection of $1,276. All balancing accounts and memorandum-type accounts not included for recovery or refund in the current general rate case will be reviewed by the CPUC in San Jose Water Company’s next general rate case or at the time an individual account balance reaches a threshold of 2% of authorized revenue, whichever occurs first.