Parties Filed Comments Addressing Covid-19 Funding Relief

The following information briefly highlights party comments:

CalCCA:

• CalCCA recommends the removal of the Section 3/Issue 7 questions from the scope of this proceeding as they relate to the CAPP program by granting CalCCA’s Motion to Modify Scope to Conform to Government Code §16429.5 in order to prevent the delay of the CAPP funding for CCA customers in need.
• CalCCA recommend that in the absence of a ruling on, or a denial of, CalCCA’s Motion, grant the requests in CalCCA’s Brief on Scoped Issue 7, Allocation of Payments on Arrearages for CCA Customers, to complete the Commission’s consideration of Section 3/Issue 7 by September 30, 2021, and find that the CAPP allocation and pro rata allocation of partial payments on past due accounts between IOUs and CCAs are in accordance with Government Code sections 16429.5(f) and (g)(4).
• CalCCA recommends refraining from implementing any further COVID-19 arrearage relief programs until the CAPP funding is allocated and the magnitude of remaining arrearages is ascertained.
• CalCCA recommends examining the process of customer data exchanges between CSD and the IOUs after the CAPP Applications are submitted.

Cal Advocates:

• Due to the lack of sufficient data, it’s premature to evaluate whether current relief programs will adequately provide energy customers with sufficient arrearage assistance.
• Given the difficulty in determining the timeline by which arrearage relief will be provided and the types of customers receiving said relief, the Commission should reevaluate remaining arrearage relief as federal and statewide funds are being distributed.
• The Commission should record the total amount of funding delivered to customers from each program (such as ERAP and CAPP) for each IOU and CCA.
• The Commission should compare the total amount of funding with the IOUs’ monthly disconnection data reports, which includes the IOUs’ monthly reporting of residential arrearages, filed in Order Instituting Rulemaking to Consider New Approaches to Disconnections and Reconnections to Improve Energy Access and Contain Costs,R.18-07-005 (Disconnection Rulemaking).
• Based on the recorded arrears covered by the relief programs, the Commission should reevaluate which customers need additional arrearage forgiveness and determine any potential changes to improve coverage, such as directing funds to customers above the 80% AMI threshold who are ineligible for ERAP. The reevaluation should be conducted either on a monthly basis or after the total funding amount from all available relief programs exceeds a given threshold, such as 20% of all available funds in arrearage forgiveness.
• The Commission should consider forgiving the remainder of all residential arrears generated at the beginning of the statewide disconnection moratorium if the current set of arrearage forgiveness programs do not cover all post-moratorium arrears. The Commission should refer to Cal Advocates’ proposal in the March 3, 2021 Opening Comments of R.21-02-014 regarding forgiveness of all residential arrears accrued during the disconnection moratorium and amortized in electricity rates over a period of four or more years.
• The Commission should track energy arrearages for residential and small commercial customers (from IOUs and CCAs) that were accrued during the COVID-19 disconnection moratorium and report the amounts on a monthly basis in the monthly disconnection reports ordered in the Disconnection Rulemaking. Currently, the monthly disconnection reports only track arrearages owed to IOUs from residential customers, and do not track arrearage information for residential CCA customers or small commercial customers.
• The Commission should keep track of disconnection moratorium arrearage totals reported by each IOU and CCA, as well as the funding totals for each relief program administered by the corresponding state agency. The Commission should use this information to compare the current arrearage totals with the amounts of arrearage relief delivered to the IOUs and CCAs to determine if California residents need additional monetary relief and if the state agencies are disbursing relief at a rate efficient enough to keep customers connected to utility service.
• The Commission should apply remaining funds from the existing arrearage relief programs and disburse them directly through the IOUs to recover customer arrearages, rather than having customers apply for the funds themselves.

SDG&E:

• SDG&E believes that existing programs and the newly enacted programs aimed at reliving COVID-19 related arrearages, such as the California Arrearage Payment Program (CAPP), can be effectively leveraged to benefit the customers of water and energy utilities. SDG&E further submits that these programs should be applied to customer groups that are most in need.
• The design of CAPP—which allows utilities to apply for relief funds directly on behalf of customers and directly apply payments to customer accounts—will allow for a more efficient flow of funds to customers in a streamlined and timely basis.
• AB 135 establishes certain data sharing requirements for all CAPP applications, including the need to share account level data for customers deemed eligible for relief. Because of arrangement—which is applicable to the LIHEAP pledge portal—does not adequately protect customer information. SDG&E is committed to pursuing all appropriate measures necessary to obtain CAPP funding in the most efficient way possible while continuing to protect customer information.
• With the various federal, state, and local assistance programs that have recently been approved and implemented, and those still in the process of being implemented, SDG&E believes that it is too soon to determine whether any additional relief mechanisms are necessary. More importantly, SDG&E lacks information necessary for the design of any potential additional relief to address customer debt.
• When CAPP funds are compared to the IOU’s monthly disconnection report that depicts balances owed to the IOU’s it seems that the available CAPP funding will not satisfy all IOU arrearages and funds will likely be exhausted before the commercial (which includes small business) priority group is reached. To better address the needs of small businesses, SDG&E will be part of a Joint IOU Advice Letter filing that will propose a Small Business Pilot Program to address small business customers located in disadvantaged communities that were particularly impacted by COVID. The Small Business Pilot will provide one-on-one energy management coaching on how to best reduce their existing bills and helping them navigate each IOUs’ portfolio of rate options, bill management, load management, and energy savings programs.