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Balancing and Memorandum Accounts
 9 Months Ended
Sep. 30, 2019
Regulated Operations [Abstract]  
BALANCING AND MEMORANDUM ACCOUNTS
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 that do not meet the criteria established in ASC Topic 980-605-25. For other balancing and memorandum accounts, 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.
On October 4, 2019 the CPUC issued two proposed decisions for Advice Letter No. 532, which was filed for the recovery of the 2018 WCMA balance. The first proposed resolution was an approval for the collection of the 2018 WCMA balance and the second proposed resolution denied recovery. Both proposed decisions are expected to be presented to the CPUC decision meeting on November 7, 2019. Due to the conflicting proposed decisions, San Jose Water Company believes it no longer meets the probability criteria under ASC Topic 980-605-25 for the 2018 WCMA and has fully reserved the balance as of
September 30, 2019. San Jose Water Company recognized regulatory assets of $4,660 and $8,070 due to lost revenues accumulated in the 2018 WCMA account for the three and nine months ended September 30, 2018, respectively.
As a result of the current status of the CPUC filing for the 2018 WCMA above, San Jose Water Company also fully reserved the 2019 WCMA as of September 30, 2019.
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 $8 and $1,371 in the cost of capital memorandum account for the three and nine months ended September 30, 2018, with a corresponding reduction to revenue. Activity for the three and nine months ended September 30, 2019, respectively, 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 $459 and $5,955 in the tax memorandum account for the three and nine months ended September 30, 2018, respectively, with a corresponding reduction to revenue. Activity for the three and nine months ended September 30, 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 September 30, 2019
 
Three months ended September 30, 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*
$
5,315

 
—

 
(2,397
)
 
2,918

 
$
7,277

 
128

 
1

 
7,406

2018 WCMA*
8,958

 
(8,958
)
 
—

 
—

 
3,003

 
4,064

 
—

 
7,067

2019 WCMA*
557

 
(557
)
 
—

 
—

 
—

 
—

 
—

 
—

2012 General Rate Case true-up
7,731

 
(1
)
 
(3,631
)
 
4,099

 
11,324

 
—

 
2

 
11,326

Cost of capital memorandum account
(1,540
)
 
(7
)
 
—

 
(1,547
)
 
(1,507
)
 
(8
)
 
—

 
(1,515
)
Tax memorandum account
(6,585
)
 
(33
)
 
—

 
(6,618
)
 
(5,496
)
 
(459
)
 
—

 
(5,955
)
All others
7,192

 
281

 
(1,630
)
 
5,843

 
4,675

 
(34
)
 
—

 
4,642

Total revenue accounts
$
21,628

 
(9,275
)
 
(7,658
)
 
4,695

 
$
19,276

 
3,691

 
3

 
22,971

Cost-recovery accounts:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Water supply costs
5,912

 
1,049

 
(1,871
)
 
5,090

 
9,387

 
2,366

 
—

 
11,753

Pension
(233
)
 
199

 
1,208

 
1,174

 
(2,137
)
 
161

 
—

 
(1,976
)
All others
870

 
2

 
(223
)
 
649

 
—

 
—

 
—

 
—

Total cost-recovery accounts
$
6,549

 
1,250

 
(886
)
 
6,913

 
$
7,250

 
2,527

 
—

 
9,777

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total
$
28,177

 
(8,025
)
 
(8,544
)
 
11,608

 
$
26,526

 
6,218

 
3

 
32,748

 
Nine months ended September 30, 2019
 
Nine months ended September 30, 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

 
—

 
(4,832
)
 
2,918

 
$
6,679

 
723

 
4

 
7,406

2018 WCMA*
9,386

 
(9,386
)
 
—

 
—

 
—

 
7,067

 
—

 
7,067

2019 WCMA*
—

 
—

 
—

 
—

 
—

 
—

 
—

 
—

2012 General Rate Case true-up
11,328

 
95

 
(7,324
)
 
4,099

 
11,320

 
—

 
6

 
11,326

Cost of capital memorandum account
(1,523
)
 
(24
)
 
—

 
(1,547
)
 
(144
)
 
(1,371
)
 
—

 
(1,515
)
Tax memorandum account
(6,504
)
 
(114
)
 
—

 
(6,618
)
 
—

 
(5,955
)
 
—

 
(5,955
)
All others
5,112

 
4,019

 
(3,288
)
 
5,843

 
3,851

 
787

 
4

 
4,642

Total revenue accounts
$
25,549

 
(5,410
)
 
(15,444
)
 
4,695

 
$
21,706

 
1,251

 
14

 
22,971

Cost-recovery accounts:
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Water supply costs
9,617

 
(754
)
 
(3,773
)
 
5,090

 
8,679

 
3,074

 
—

 
11,753

Pension
(1,843
)
 
582

 
2,435

 
1,174

 
(2,459
)
 
482

 
1

 
(1,976
)
All others
1,090

 
8

 
(449
)
 
649

 
—

 
—

 
—

 
—

Total cost-recovery accounts
$
8,864

 
(164
)
 
(1,787
)
 
6,913

 
$
6,220

 
3,556

 
1

 
9,777

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total
$
34,413

 
(5,574
)
 
(17,231
)
 
11,608

 
$
27,926

 
4,807

 
15

 
32,748

*    As of September 30, 2019, the 2019 WCMA and 2018 WCMA balances were reserved in full. As of September 30, 2018, the reserve balances for the 2018 WCMA was $1,003 which has been included in the balance above. As of September 30, 2018, the reserve balance for the 2017 WCMA was $985 which has been included in the balance above.
As of September 30, 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 $1,183. 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.