Responses to Post-Workshop Questions Posed by ALJ

CalCCA:

• Supports leveraging existing funding such as the California Housing and Community Development's Emergency Rental Assistance Program (ERAP).

• Strongly urges the Commission to include CCA customers and ensure funding is applied to both generation and transmission and delivery costs, as supported by California Department of Housing and Community Development (HCD’s) program rules.

• Supports HCD’s eligibility requirements, utilizing 80% Area Median Income thresholds instead of Federal Poverty Level.

• Requests that the Commission direct the large utilities to further break out the data provided on total dollar value of arrearages owed to the utility for both bundled and unbundled customers by zip code, similar to data provided for small businesses.

• Equity should be a main criterion when developing relief programs.

• CalCCA supports TURN’s scoping memo comments to open Public Participation Hearings (PPHs).

SDG&E:

• SDG&E is promoting the ERAP as a potential source of debt forgiveness for qualified residential renters.

• SDG&E does not have access to the customer data required (i.e. income) to estimate ERAP enrollment numbers.

• Does not support automatic enrollment into any payment plan.

• Customers may apply for HCD ERAP and subsequently enroll in AMP.

• Customers on payment plans longer than 3-4 months are largely unsuccessful; customers on plans longer than 12 months are successful zero percent of the time.

• Proposes 15-month payment plans with up to 3 deferrals.

SCE:

• SCE estimates 191,000 accounts have arrears of $69.5 million that could be eligible for HCD ERAP. SCE estimated numbers via proxies.

• SCE does not support eligibility of arrearage relief being limited only to renters (per ERAP eligibility).

CalAdvocates

• IOU recovery of forgiven amounts should occur over multiple years.

• Small businesses should be offered payment plans up to 24 months.

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