Parties Submit Comments on Enhancing Community Based Organization Support for Customer Relief

The following questions were posed in the Staff Proposal:

1. What is the most appropriate funding model given resource cost, timing, efficiency and effectiveness concerns?
2. What are reasonable budget levels for alternative funding models and program evaluation contracts?
3. What is the appropriate duration over which these programs should be funded?
4. How should these budgets be tracked and reconciled?
5. Who should be responsible for administering the following: Selection of contracted CBOs for each IOU; Evaluation of CBO and IOU activities; Transmission of payments to contracted CBOs; and Ongoing troubleshooting and program oversight.
6. What should program management plans include to ensure the coordinated development of outreach materials and consistent messaging?
7. What systems should be developed and implemented to ensure program efficiencies such as training and an exchange of best practices between CBOs?
8. How should IOUs and CBOs be evaluated to assess the effectiveness of the program and compliance with program rules?
9. When should the evaluations take place? Should there be an interim evaluation and a final evaluation? Should evaluations occur at fixed time periods, e.g., 6 months, 12 months, etc.?

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The following is a brief snapshot of party comments:

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Cal Advocates:

          Response to Question 1:

• The Ruling includes several funding model options, including the use of a statewide third-party administrator selected by the Commission to coordinate with CBOs rather than IOUs holding direct contracts with CBOs. Cal Advocates does not support use of a third-party administrator in this instance because it has not been shown that third-party administrators are more effective than direct contracts to justify the additional administration fees.
• Instead of spending ratepayer funds on administration fees, Cal Advocates urges the Commission to ensure that a large portion of available funding is allocated directly to CBOs for their efforts. Alternatively, if the Commission approves a third-party administrator in this proceeding, administrative budgets should be significantly lower than the compensation that CBOs receive.
• The Commission should not change current CBO funding agreements and fees that were established through other proceedings.

          Response to Question 4:

• The IOUs should be tasked with tracking CBO budgets, and the IOUs should provide details of the existing accounts used for CBO outreach in this proceeding. This method ensures that the Commission can readily monitor and audit IOU spending should the need arise.

          Response to Question 5:

• The IOUs already have a well-developed structure for selecting and contracting with CBOs, transmitting payments to CBOs and managing CBOs, and should continue this work. A third-party evaluator should be used for determining the effectiveness of IOU and CBO activities, because a neutral observer may provide novel solutions not apparent to the IOU and CBO staff involved in the day-to-day operations.

          Response to Question 6:

• Each IOU currently produces most customer messaging and should continue serving this function to ensure the accuracy and consistency of outreach materials. The IOUs should coordinate efforts to develop a framework for providing consistent messaging across service territories and to different CBOs.

          Response to Question 7:

• Cal Advocates supports the current practice of utilizing IOUs to continue training CBOs and facilitating exchanges of best practices between CBOs since the IOUs have the greatest knowledge and experience with their programs, and can ensure that the CBOs receive the most up-to-date and accurate information to communicate with customers.

           Response to Question 8:

• The Commission could draw on IOU’s existing methods and metrics to measure the effectiveness of CBOs for typical activities, such as to enrolling customers in assistance programs and providing customer outreach. Such metrics may identify, or provide insight into, easily solvable deficiencies in current practices, such as the need for additional CBOs to target certain customer groups.
• Cal Advocates supports using an initial and straightforward set of performance metrics to determine each CBO’s performance. These metrics should focus on desired outcomes, not process.
• The IOUs should also collect information on the different customer segments and territories that each CBO works with to determine if there are groups of customers that are not being reached and avoid unnecessary overlap.
• Lastly, client response surveys should also be used to gauge CBO performance.

          Response to Question 9:

• Cal Advocates supports both interim and final evaluations to assess CBO effectiveness.

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CalCCA:

          Response to Question 5:

• CalCCA recommends that the actual outreach to customers be performed by local CBOs, who often already have established and trusted relationships with the local community and can best ensure the hardest to reach customers are served. Therefore, to the extent a centralized entity selects, evaluates, pays and/or oversees the CBO programs, that entity should be tapping into the already existing CBO local programs to ensure the most effective outreach to customers.
• With respect to selection of CBOs for each IOU, CCAs should be consulted as to the CBOs that can effectively reach vulnerable customers in that CCA’s territory.

          Response to Question 6:

• The CBO program should ensure that the messaging formulated to assist customers accurately and effectively communicates the CCA’s role and programs if a customer is a CCA unbundled customer.

          Response to Question 7:

• CalCCA recommends that written materials for CBOs be developed with CCA input regarding Commission, IOU and CCA programs that can assist customers with arrearages.

          Response to Question 8:

• The IOU programs regarding CBO outreach to residential customers should be evaluated to assess all aspects of the program, including but not limited to: (1) the CBOs enlisted to provide outreach to customers; (2) the number of bundled IOU and unbundled CCA customers contacted; (3) CBO success rate in enrolling customers in programs; and (4) the costs of the CBO programs.

          Response to Question 9:

• To ensure that the CBOs are reaching customers effectively, CalCCA recommends frequent evaluations of all program components related to each CBO every six months, with the results provided to stakeholders for review.

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SDG&E:

• SDG&E should gauge CBO interest through an RFP competitive bidding process which allows the CBOs SDG&E has a current relationship with to review the case management requirements and determine their ability and interest in formally engaging in a case management function.
• SDG&E supports utilizing a case management model with one selected CBO starting during 2022 to assess the merits of this level of support. SDG&E suggests pilot period beginning in October 2022, after completion of the RFP, CBO selection and program preparedness, through September 2023, to coincide with the period of the 24-month COVID-19 plans.
• SDG&E will monitor the success of the selected CBO throughout the 12-month pilot period.
• Funding for this additional CBO engagement should be tracked through the COVID-19 Pandemic Protections Memorandum Account (CPPMA).
• The Commission, the utilities, and stakeholders should evaluate the proposed case management engagement pilot after the 12-month period and procedurally file a Tier 2 Advice Letter with recommendations on if and how to continue this type of CBO engagement beyond October 2023.
• If the Commission seeks to further address this type of service by CBOs and funding sources beyond the period covered by the COVID-19 repayment plans (Oct 2023), SDG&E recommends doing so as part of the Disconnection OIR (R.18-07-006).

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TURN:

          Response to Question 1:

• TURN suggests that a combination of the Fee Model Structure and a Small Grants/Regional Hub model would be best suited to address the effectiveness, cost, timing and efficiency concerns related to continuing COVID debt relief. A combined approach to funding CBOs may help expand the IOUs CBO network reach by increasing the diversity of organizations who can participate.

          Response to Question 3:

• These programs should be funded at a minimum for 18 months with an interim evaluation at 12 months in order to course-correct, implement best/better practices and lessons learned, and to consider if an additional year-long extension is merited. This process of re-evaluation should take place annually until the pandemic has reasonably subsided or until the majority of California’s most vulnerable residents have recovered substantially.
• TURN also suggests the programs continue to be funded at least until the World Health Organization re-categorizes the COVID-19 pandemic into an endemic.

          Response to Question 4:

• TURN recommends that the Commission adopt an approach that does not increase rates. To that end, we offer two suggestions. First, the utilities should take advantage of any available non-ratepayer funding source to the extent that doing so will not reduce the funding available for customer arrearage forgiveness -- including but not limited to covering these costs with shareholder funds. Second, the utilities should use existing budgets for ME&O.
• The Commission should investigate the feasibility of using the authorized CARE administrative budgets as another potential source of funding for case management.

          Response to Question 5:

• Transmission of payments to the contracted CBOs should be carried out by the IOUs as they currently transmit payment to their existing network for CBOs.
• TURN suggests the creation of a COVID Debt CBO Network Working Group to be tasked with the identification and selection of CBOs that could be contracted to expand existing CBO networks for the IOUs. This Working Group would also oversee the evaluation and provide guidance to the IOUs with respect to how best to evaluate CBO and IOU activities.

          Response to Question 6:

• The IOUs should incorporate information about additional state and federally -funded program (i.e., CAPP and ERAP) options into messaging and materials provided to CBO networks.
• TURN recommends the Working Group work together on a resource to strategize the best ways to pull together all existing supports in order to: 1) maximize customer protection; 2) minimize further increasing costs to residential ratepayers and 3) decrease uncollectibles.

          Response to Question 7:

• A survey of CBOs engaged in different aspects of outreach and participating in various rate structures could go far to inform best practices as IOUs work to maximize existing CBO networks and expand their network while improving on existing strategies for reaching vulnerable, AFN and other difficult to reach organizations.
• TURN recommends the CPUC to require the IOUs to implement a co-leadership approach such as that outline by Kristen Law, Community Engagement Manager for the Bay Area Air Quality Management District during the R.21-02-014 Energy Debt Relief Workshop on November 9, 2021.

          Response to Question 9:

• The evaluation should take place annually and should be used to decide whether or not these expanded programs of CBO engagement could be improved, should continue, or if recovery and implementation has reached an impact threshold at which CBOs, the Commission, the IOUs and other parties to this proceeding believe the pandemic and recovery from the pandemic have been sufficiently achieved.