Parties Filed Reply Comments on PIPP Straw Proposal

The following is a brief snapshot of party comments:

CalCCA:

• Adopt the Percentage of Income Payment Plan (PIPP) Straw Proposal’s (Straw Proposal’s) application of the Arrearage Management Plan (AMP) Resolution E-5114 to recover CCA costs for the pilot through the Public Purpose Program Charge (PPPC);
• Direct the investor-owned utilities (IOUs) to utilize existing, or modified, billing methodologies to ensure equitable participation of CCA customers in the PIPP pilot;
• Grant Pacific, Gas and Electric Company’s (PG&E’s) request that the CCA parties provide notice of intent to participate in the PIPP;
• Modify the timeline to submit Advice Letters to ensure that both IOUs and CCAs have adequate time to implement the PIPP pilot;
• Adopt PG&E’s proposal for a single monthly Benefit Cap; and
• Modify the Straw Proposal to ensure that nonpayment by PIPP participants does not result in their removal from the PIPP program.

SDG&E:

• Agrees with the elimination of the energy usage benefit cap for purposes of the PIPP Pilot.
• Alternatively, the benefit cap should be an annual threshold.
• SDG&E supports CARE and PIPP concurrent recertification, but opposes PG&E's recommendation to push out the CARE anniversary date. Pushing out CARE recertification dates will likely result in non-compliance with CARE program rules and potentially cause administrative issues.
• SDG&E supports categorical eligibility for participation in a PIPP pilot (i.e. using proof of participation in another state program that requires income verification as proof of eligibility for the pilot).
• SDG&E agrees that customers on the PIPP pilot should be subject to normal credit, collection, and disconnection processes.
• SDG&E believes PIPP Pilot evaluation criteria and statistics should be developed within the working group.

The link below contains all parties' reply comments.