Commission Approved the Redlined Proposed Decision Implementing PIPP Pilot Programs

CCA Customers

• Participation Cap: SDG&E raised the concern that the new CCA’s proportional share of customers in its service territory will change significantly during the pilot period. SDG&E urged the Commission to replace the CCA pilot participation cap with a flexible “target” and allow the utility and CCA to set this target based on the CCA’s projected share of customers with the recognition that the CCA’s share of customers will change over time. The Commission recognizes these concerns and will replace the CCA participation cap with a target.
• Cost Recovery: We clarify how CCA cost recovery proposals should be designed to be consistent with the AMP Resolution. The utility must remit costs recovered and attributable to CCA customers proportionally to the generation costs for customers of the CCA. Specifically, the CCA cost recovery proposals should identify the percentage of PIPP-enrolled CCA customer bills that will be regularly recovered and remitted to the CCA, which should be equal to the average historical share of that CCA’s CARE customer costs attributable to generation and borne by the CCA. The average historical share should be calculated based on data from a recent 12-month period, such as the period between September 2020 and August 2021. For example, if the historical data indicates that, on average, generation charges comprised 40 percent of a given CCA’s CARE customer bills, then a consistent cost recovery proposal must include regularly remitting 40 percent of costs recovered and attributable to CCA PIPP customers to the CCA.
• Bill Cap Application: The Commission concludes that it is reasonable to apply the PIPP bill cap to a customer’s bill prior to calculating any third-party taxes, charges and fees.

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PIPP Structure

• Participants will receive a monthly bill cap for current electricity and gas charges based on 4% of their household’s monthly income. Monthly bill caps will be standardized for households in two income tiers: 0-100% of Federal Poverty Guidelines and 101-200% of Federal Poverty Guidelines.
• PG&E, SCE, SDG&E, and SoCalGas will enroll up to 15,000 total participants for 48 months to test whether a PIPP program can reduce the number of low-income households at risk of disconnection, encourage participation in energy saving and energy management programs, increase access to essential levels of energy service, and control program costs. The following pilot participation caps will apply by utility: PG&E: 5,000; SoCalGas: 5,000; SCE: 4,000; SDG&E: 1,000. Target enrollment levels for each IOU’s pilot effective six months after pilot enrollment begins: PG&E: 2,500; SoCalGas: 2,500; SCE: 2,000; SDG&E: 500.
• Customers of the large IOUs and participating CCAs are eligible for the pilots if they are enrolled in the California Alternate Rates for Energy (“CARE”) program and are located in zip codes with highest rates of recurring disconnections, or were disconnected 2 or more times during the 12 months prior to the disconnection moratorium.
• The IOUs will contract with community-based organizations (“CBOs”) that conduct Energy Savings Assistance Program (“ESAP”) or Low-Income Home Energy Assistance Program (“LIHEAP”) outreach to perform concurrent PIPP outreach, intake and enrollment. CARE program rules regarding high energy usage will apply to PIPP pilot participants.
• The Commission estimates total pilot bill subsidy costs of around $23 million and total pilot administrative costs of around $15 million over the four-year pilot period.
• The PIPP Working Group will begin to convene within 60 days of the effective date of the final decision. The PIPP working group will advise on CCA implementation, identification of eligible high recurring disconnection rate zip codes, outreach, pilot implementation, the evaluation plan, and the long-term program design, including funding sources for the program.
• IOUs and participating CCAs will recover electric costs through the Public Purpose Program Charge and gas costs through gas transportation rates. Administrative costs will be subject to memorandum account review for reasonableness.
• An independent evaluation contractor will assess the pilots based on the first 18 months of pilot data. The evaluation report will recommend whether to modify the pilots and/or whether the IOUs should file a joint application for a long-term program.

Next Steps

• The IOUs shall each file a Tier 3 Advice Letter within 120 days of the effective date of this decision to implement a PIPP pilot program and establish the PIPP memorandum and balancing account.
• An eligible Community Choice Aggregator (“CCA”) that opts to participate in an IOU’s PIPP pilot program shall: (1) notify the applicable IOU with a copy to the service list within 30 days of the effective date: October 11, 2021 and (2) jointly file with the applicable IOU a Tier 3 advice letter to participate in an IOU’s PIPP pilot program within 120 days of the effective date of this decision.
• The IOUs shall each commence marketing, education, outreach and enrollment for its PIPP pilot within 45 days of the approval of its pilot implementation advice letter.
• The IOUs and each participating CCA shall file and serve to the service list of this proceeding a report with evaluation metrics covering the previous six months of pilot data within seven months after the launch of the pilot and every six months thereafter. The evaluation report for the pilot programs shall be completed and served on the service list of this proceeding within 25 months of the approval of the PIPP pilot program advice letters. If the evaluation report recommends modifications to the pilot programs, the IOUs shall each file a Tier 2 Advice Letter within 60 days of the service of the evaluation report to implement the modifications recommended by the PIPP pilot evaluation report.