Parties Filed Comments on Proposed Decision re: Covid-19 Customer Bill Debt

The following is a brief snapshot of Parties' Opening Comments:

CalCCA:

• CalCCA supports the Proposed Decision’s directive to “automatically provide all residential customers two years over which to pay off energy bill debt, with an opt-out provision.”
• CalCCA urges the Commission to extend the suspension of the “utility first” payment waterfall through the two-year term of the Proposed Decision’s COVID-19 relief payment plan.
• Absent Commission action in this decision, partial payments under the Pacific Gas and Electric Company (“PG&E”) and San Diego Gas & Electric Company (“SDG&E”)tariffs will revert to their pre-pandemic allocation methodology, which prioritizes payments on all arrearages owed the investor-owned utility (IOUs) before commencing payment of arrearages owed to the Community Choice Aggregator(“CCA”).
• CCAs will face disproportional financial risk as payment of their arrearages from residential customers are deferred until the IOUs’ charges have been fully satisfied.
• CalCCA urges the Commission to extend the “pro rata” treatment now to ensure that both IOUs and CCAs enter the post-COVID transition period on equal footing and to prevent CCAs from being exposed to greater risk in terms of revenue recovery.

Cal Advocates:

• Recommends that the Commission clarify whether cost recovery associated with the authorized residential and small commercial customer payment plans or any further debt relief will be addressed in the second phase of this proceeding.
• If not, as an alternative, the Commission should adopt a multi-year amortization of the cost recovery associated with the payment plans and any other costs of the debt relief ordered here.
• Cal Advocates has repeatedly shown that amortizing incremental costs over three to five years would reduce the annual bill increases customers experience compared to recovering additional costs over a single year.

SDG&E:

• SDG&E requests that the Commission clarify that the automatic enrollment in the COVID-19 Relief Payment Plans will occur on a one-time basis for all eligible customers, within 60 days of the decision– i.e. the plans are a one-time offer.
• SDG&E requests that the Commission reconsider allowing two automatic deferrals for all customers enrolled in the COVID-19 Relief Payment Plans.
• If the Commission chooses to require two deferrals for customers enrolled in the COVID-19 Relief Payment Plans, SDG&E requests that those deferrals apply to customers who contact the utility in advance of a missed payment.
• Small Businesses should be eligible for the same24-month payment plans on the same terms as residential customers.
• SDG&E proposes to suspend disconnections for residential low-income CARE and FERA enrolled customers with arrears as of June 30, 2021 through October 31, 2021 to allow for passage and implementation of new debt relief programs and to avoid disconnection of customers who may qualify for relief.
• SDG&E requests that the Commission extend the CPPMA past June 30, 2021 to record the incremental costs.
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SBUA:

• SBUA recommends combining reasonable repayment terms, capped at five years, with debt relief for small businesses.
• Small business customers that are paying for current utility usage should not be subject to disconnection on account of outstanding pandemic-period debt.
• The PD should be amended to require that utilities make direct, live, in-person contact with each Small Business customer eligible for a payment plan to understand the difficulties facing the customer and evaluate opportunities for bill savings.

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See the link below for a summary of parties' opening comments.