CalCCA comments on IOUs' Pilot for Small Business Customer Outreach

Introduction

As proposed, the Small Business Pilot would allow the Joint Utilities to provide one-on-one energy management coaching to eligible small business customers on how to best reduce their existing bills, by utilizing IOUs’ portfolio of rate options, bill management, load management, and energy savings programs. The Joint Utilities propose that third-party Community Based Organizations (CBOs) would be hired as “Energy Ambassadors” to conduct the pilot. Community Choice Aggregator (CCA) small business customers are eligible to participate in the pilot.

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CalCCA Comments:

• CCAs and CCA programs should be incorporated into the Small Business Pilot. CalCCA has concerns regarding the Small Business Pilot only providing counseling regarding utility programs, to the exclusion and detriment of CCA programs. The Energy Ambassadors could be trained in both IOU and CCA programs in that service territory, in order to benefit both bundled IOU customers, and unbundled CCA customers.
• Pilot eligibility should extend beyond the CalEnviroScreen definition of a DAC to include small business customers with the highest rates of arrearages over the past 12 Months as designated by IOUs and CCAs.
• The joint utilities should provide estimated size and cost information to stakeholders regarding the Small Business Pilot.
• CalCCA has concerns with CCA customers receiving counseling regarding IOU or CCA programs from an IOU employee. Pilot outreach should only be conducted by third party Energy Ambassadors with equal knowledge of IOU and CCA programs benefitting small business customers.

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