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Disconnections and Reconnections
R. 18-07-005
February 11, 2021

Comments on ALJ's Three Questions re PIPP Program

Initial Comments on the PIPP program parameters varied widely in their recommendations for eligibility and other factors. The ALJ put forth three additional questions for parties.

Comments on ALJ's Ruling's Three Questions:

SDG&E

  • A PIPP lacking any tie to customer’s energy use may result in reduced interest in energy efficiency programs conservation.
  • If based on income, implement usage cap to incentivize conservation.
  • Proposes experimentally testing using a randomized control trial.
  • Average of about 50% of SDG&E’s CARE customers have monthly consumption under 100% of their baseline allowance. Hence, SDG&E could potentially leverage baseline usage to support the definition of the subgroups or PIPP eligibility.

CalCCA

  • There’s no evidence to support that PIPP would negatively affect conservation or the achievement of CA’s energy efficiency goals.
  • Pilot needs to test a control group (without an energy usage cap)and an experimental group (with an energy usage cap in the form of a maximum bill credit).
  • PIPP should implement a bill credit for energy usage up to a certain dollar value, instead of a physical “energy usage cap.”
  • PIPP should be capped at a maximum benefit of $8,000
  • M&O materials should clearly advertise the ESA and LIHEAP Weatherization programs and enrollment requirements.

Update Links
SDG&E Comments on Three PIPP QuestionsCalCCA Comments on Three PIPP QuestionsPIPP SCoping Memo and Ruling
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