Briefs filed on Covid-19 Debt Relief

On April 23, 2021, thirteen parties submitted Opening Briefs and and twelve parties submitted Reply Briefs on April 30, 2021. The following is a snapshot of some of the relevant parties' comments. Please use the link below to access the folder containing all parties' comments.

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Opening Briefs:

     CalCCA:

• Recommends extending the current pro rata application of Partial Payments through entire COVID-19 transition.
• Modify the AMP program: $250 minimum arrearage eligibility requirement; AMP enrollment by customer request; provide for flexible payments (extended payback periods, payment deferral, payment plan renegotiations).
• Proposes use of metrics based on income and energy burden, not disconnection data, to prioritize geographic areas eligible for relief programs.

     SDG&E:

• A new Arrearage Assistance Program ("AAP") should target customers not already eligible for forgiveness and should address arrearages that remain after federal and state aid has been exhausted to reduce ratepayer impacts.
• Proposes any incremental implementation costs related to the program be recorded to the COVID-19Pandemic Protections Memorandum Account ("CPPMA:) and recovered through the PPPC.

     Cal Advocates:

• Proposes to forgive 100% of all residential customer arrears accrued during the disconnection moratorium and amortize the cost recovery over 3-5 years.
• As an alternative proposal, a reduction of residential customer arrearages by at least 50% or $500 and adoption of automatic enrollment.

Reply Briefs:

    CalCCA:

• Requests more information on how Cal Advocates’ opening brief proposal will impact unbundled customers.

    SDG&E:

• Recommends the AMP eligibility threshold remain at $300 or above, if the Commission wants to expand AMP eligibility.
• Does not agree with Cal Advocates’ proposal to forgive all debt accrued, but supports a modified AAP, consistent with Commission straw proposal A.

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