ALJ Issues Phase 2 Post-Workshop Ruling With Questions for Party Comments

The ALJ Ruling includes the following questions for party comments.

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Questions for Party Comments about Payment Plans:

1. Some workshop participants raised concerns about automatic enrollment in long-term payment plans causing confusion for participants. Is automatic enrollment inherently problematic, or is it a matter of how much ME&O is paired with automatic enrollment?
2. A workshop participant asserted that AMP is best for customers who can afford to pay their bills, and the underlying problem is that many AMP-eligible customers can’t afford to pay their bills. Could the design of AMP be modified to better serve customers who can’t afford to pay their bills? Or should utilities not recommend AMP for certain types of customers?
3. In light of COVID and CAPP payment impacts on arrearages and disconnections, should the Commission wait before making changes to the AMP and/or COVID Long-Term Payment Plans? Or should the Commission modify these programs soon to ensure that these programs serve customers at risk of disconnection?

‍Questions for Party Comments about the CBO Pilot Proposal:

1. Do the proposed zip codes for the proposed pilot include Community Choice Aggregation ("CCA") customers?
2. What role should CCAs have in implementing the proposed pilot, if any?
3. The CBO Pilot Proposal recommends comparing pilot participants with a control group that receives standard utility support to reveal the impact of the pilot. Should the pilot evaluation also evaluate the impact of CBO interventions compared with a specific amount of utility engagement? For example, should the control group receive calls from their utility following missed payments to reduce involuntary removal from AMP and long-term payment plans?
4. The CBO Pilot Proposal recommends that the evaluation consider whether the benefits of the pilot program sufficiently outweigh the costs to warrant program expansion. Should the pilot evaluation determine whether specific pilot interventions are effective enough for the benefits to outweigh the costs? How should the pilot design, pilot reporting, or evaluation design provide insight into whether modifying the program eligibility requirements, services, or administration could result in a better ratio of benefits to costs per customer?
5. Tier 1 service in the CBO Pilot Proposal includes energy education. The Energy Savings Assistance program offers energy education to participants, and utilities also provide educational information about energy usage. How is the Tier 1 service different from these energy education offerings and how do all the different types of energy education interplay?
6. What data could the CBO pilot collect to help to identify the characteristics of customers who can benefit from an AMP vs. those who cannot afford to pay their bills and need a Percentage of Income Payment Plan?
7. The CBO Pilot Proposal targets customers in zip codes that meet the Commission’s definition of “affordability area of concern” and who have arrears that are at least 90 days old and may be at risk of disconnection. The proposal does not require participants to meet income eligibility requirements to participate. Should the pilot include income eligibility requirements? Why or why not?
8. The pilot proposal recommends an independent evaluation by a third-party but does not specify how the third-party evaluator should be hired or supervised. Who should conduct the request for proposals, select the evaluator, and supervise the evaluator? What role should the CBO Working group have in these processes?
9. The pilot proposal includes a recommended preliminary scope for the evaluation. What other questions should theCommission require the evaluation to address?
10. The pilot proposal includes separate line-items for administrative costs and education and outreach costs.What is included in the administrative costs line-item, and how do these types of costs differ from education and outreach costs?
11. The pilot proposal notes that the utilities’ administrative costs include Single Point of Contact costs to support CBOs with specific customer account resolution issues. How are these costs additional to costs that would otherwise be incurred by the utilities? What portion of the utilities’ administrative costs for the pilot will serve this purpose?
12. The pilot proposal recommends that, on a monthly basis,CBOs will receive additional payments for each customer enrolled at the end of the preceding month in the case management pilot (enrolled is defined as a customer with a signed agreement to participate in case management). The pilot proposal also recommends tracking the number of customers who unenroll or withdraw from the pilot. How should the Commission define unenrollment or withdrawal from the pilot? Can participants be involuntarily removed from the pilot, and if so, for what reasons?
13. How should the pilot address participating customers who move after enrollment in the pilot?

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