Debt Due to COVID Opening Briefs

CalCCA:

The Commission should:

• Extend the current “pro rata” application of Partial Payments through the entire COVID-19 transition.

• Ensure that any debt forgiveness plans, new or existing, are funded through the Public Purpose Program Charge (PPPC).

• Make several modifications to AMP including: (1) Expand eligibility for the AMP program by lowering the minimum total arrearage requirement for participation from its current level of $500 to $250; (2) Ensure that AMP enrollment is on a “request to participate” basis, as automatic enrollment could result in customers who miss payments being unintentionally locked out of the program for a year without their knowledge; and (3) Prioritize flexibility in payments, by allowing customers extended payback periods, the opportunity to defer payments, and renegotiation of (payment plans.

• Leverage existing funding such as the California Housing and Community Development’s Emergency Rental Assistance Program (HCD ERAP) and continue to utilize 80% Area Median Income(AMI) as an eligibility threshold, instead of the Federal Poverty Level (FPL)indicator, to allow for increased participation in this statewide program.

• Use metrics based on income and energy burden, not disconnection data, to prioritize geographic areas eligible for relief programs.

• Support the invaluable experiences and work of Community Based Organizations (CBOs) by amplifying on-the-ground stories to shape policy and program design.

• Tie the extension of the disconnection moratorium end date to California’s economic reopening and account for a transition period to allow customers to adjust and stabilize themselves financially.

SDG&E:

SDG&E recommends the Commission issue a decision that:

• Recognizes available federal and state relief funds, including the Emergency Rental Assistance Program (ERAP) and Low-Income Home Energy Assistance Program (LIHEAP), to significantly reduce customer arrearages, and prioritizes use of those funds to reduce customer arrearages before any new programs or relief mechanisms;

• Allows CARE/FERA customers to fully take advantage of the new Arrearage Management Payment Plan.

• Implements reasonable repayment options for residential and small business customers, who do not qualify for AMP but may need assistance during the economic recovery.

• Tailors new payment plan options to the duration of the 15-month disconnection moratorium, and allows flexibility for additional deferrals to address ongoing
• economic uncertainty.

• Recognizes that any shareholder funding for arrearage relief should remain on a voluntary basis, consistent with longstanding Commission and legal precedent.

• Authorizes cost recovery through existing or new balancing account mechanisms.

TURN:

• For CARE or FERA customers, the utilities must forgive all debt incurred during the moratorium and auto-enroll customers who remain eligible as determined by D.20-06-003 into the AMP for remaining arrearages. These customers do not need to proactively choose to participate in this relief program in order to receive arrearage forgiveness.

• For non-CARE/FERA residential customers, the utilities must offer these customers a 24-month payment arrangement for balances accumulated during the moratorium.

• For small business customers, the utilities should provide these customers with up to 24 months to repay their arrears and should work with each customer to determine the best plan for the customer.

• TURN urges the Commission to require utility shareholders to contribute 50% of the costs of the relief program.