Comments on Low-Income Water Rate Assistance Program Implementation Oct 4, 2018 Comment Letters Agency: State Water Resources Control Board Subject: Implementation of Low-Income Water Rate Assistance Program Letter excerpt: The Association of California Water Agencies (ACWA) appreciates the opportunity to provide suggestions for the State Water Resources Control Board’s (State Water Board) development of a plan for a Low Income Water Rate Assistance (LIWRA) Program pursuant to AB 401 (Dodd, 2015). Recognizing that AB 401 defined “low-income” as a household with income that is equal to or no greater than 200 percent of the federal poverty level (FPL), the legislation asked the State Water Board to look at a number of elements for funding and implementing a LIWRA Program – the level of “low-income” was one specific factor to be evaluated, but the law does not preclude the State Water Board from looking at different income levels. The State Water Board should consider whether or not 200 percent of the FPL is the appropriate criterion for this program. For example, should the program focus instead on severely disadvantaged communities or other measures of poverty? Download comment letter