Parties filed comments on the June 28, 2021 Administrative Law Judge's Ruling seeking comments and posing questions regarding the Percentage of Income Payment Plan ("PIPP") straw proposal.
The Commission has the following remaining questions regarding its PIPP straw proposal:
Do you have program design suggestions for refining the attached straw proposal?
Do you have procedural suggestions for refining the attached straw proposal?
Please provide updated cost estimates for the pilot as described in the attached straw proposal.
Should utilities be required to request approval for exceeding the approved administrative costs for the pilot?
The following is a brief snapshot of party comments on the above questions:
CalCCA:
Recommends clarifying the eligibility rules for customers of CCAs that opt to participate in the PIPP pilot to (1) allow CCAs to designate eligible zip codes within their service territory with high disconnection rates, and (2) allow eligibility for CCA customers more than 90 days in arrears for two or more billing cycles during the year prior to the disconnections moratorium.
Recommends allowing eligibility of FERA customers in the pilot along with CARE customers.
Recommends revising the PIPP Straw Proposal to require a PIPP Benefit Cap for all, rather than only two, climate zones in California.
Recommends requiring IOUs to cooperate with CCAs in their ME&O, including co-branding of materials regarding the PIPP for eligible unbundled customers of CCAs.
Recommends requiring IOUs to facilitate outreach efforts by CBOs for not only bundled customers, but also eligible CCA unbundled customers.
Recommends directing IOUs to request CBO recommendations from CCAs to augment support services already provided by IOU-identified CBOs.
Recommends requiring IOUs to apply the bill cap to the entire customer bill and provide reports to participating CCAs that specify the maximum CCA charges that can be billed to a participating customer.
SDG&E:
The cost recovery mechanism requires an important clarification as to whether: (1) CARE customers will not pay for the PIPP pilot, or (2) All ratepayers, including CARE customers, will pay for the PIPP pilot.
SDG&E believes that other PIPP pilot designs should be considered, including providing PIPP customers with additional baseline usage, as suggested by SDG&E in its Opening Comments.
SDG&E continues to oppose the tiered percentages included in the Straw Proposal and instead supports a bill cap equal to a flat 6-10% of a customer’s gross monthly income.
Directly aligning PIPP pilot eligibility requirements with CARE income limits and introducing additional complicating factors regarding zip code and disconnections may cause customer confusion around qualifications, resulting in eligible customers not enrolling in CARE, the Family Electric Rate Assistance (FERA) program, or PIPP.
SDG&E does not support PIPP eligibility predicated on how often a customer is disconnected, where a customer lives, or how often others in a customer’s community (zip code) are disconnected. SDG&E continues to support a PIPP pilot that targets the most vulnerable customers, which SDG&E believes should include customers with income up to 100% of the Federal Poverty Guidelines (FPG) and permanent, fixed income (such as, social security benefits and permanently disabled customers unable to work).
SDG&E seeks to exclude those customers on a Levelized Payment Plan (LPP) because the calculation would circumvent the proposed PIPP capping mechanism.
SDG&E seeks to clarify whether the PIPP capping mechanism impacts taxes and franchise fees. SDG&E’s recommendation is that the PIPP bill cap only apply to the charges prior to the application of the taxes and franchise fees which would simplify the reconciliation of any capping credits for taxes and franchise fees with the third parties with minimal bill impacts (e.g., $73.62 instead of $72).
SDG&E seeks clarification on the contents of the Independent Evaluation Report included in the Straw Proposal. SDG&E recommends that the Straw Proposal include specific success criteria and analysis of those criteria in the Independent Evaluation Report, including a recommendation as to whether a PIPP beyond the pilot is warranted.
If a PIPP pilot customer moves to a new location within the service territory, SDG&E recommends a requirement that service be re-established by the customer at their new location within 30-days to remain in the pilot.
Given the potential inclusion of Community Choice Aggregators (CCAs) and the coordination that will necessitate, SDG&E seeks additional time to submit the initial advice letter—120 days (about 4 months) as opposed to 90 days (about 3 months).
SDG&E seeks clarification as to the rationale behind the Straw Proposal’s requirement that only 18 months of data be used to evaluate the success of a pilot that will last four years.
SDG&E does recommend the Commission request each IOU to include total estimated cost of the PIPP Pilot in the “Consolidated Advice Letter” to implement its PIPP Pilot within 90 days of the decision. Additionally, SDG&E suggests the Commission require each IOU to update their cost estimate annually throughout the pilot.
SDG&E provides the estimated costs in the table below based on the details in the Straw Proposal.
