Ruling Setting Joint Status Conference and Ordering Comments

The purpose of the joint status conference is to review the Phase III issues in R.17-06-024, the Phase II issues in R.21-02-014, and to identify any other related common issues in the two proceedings, with the goals of (1) efficiently leveraging federal and state funding sources available to relieve energy and water utility customer debt associated with the COVID-19 pandemic, and (2) strengthening inter-industry coordination to support utility bill relief and affordability.

The following contains instructions to designate a speaking representative and instructions on party comments:

• The joint status conference will be held remotely on the WebEx platform and is open to all interested stakeholders. Parties should designate a speaking representative prepared with video and audio access and notify Julie Lane (julie.lane@cpuc.ca.gov) by August 10, 2021, of their party’s speaking representative, title, phone number, and email address.
• Unless specified otherwise, this ruling also directs parties to R.17-06-024 and R.21-02-014 to serve and file, in both proceedings, comments responsive to the questions set forth below in Sections 1, 2, 4 and 5 of this ruling by September 13, 2021.
• This ruling directs parties to R.21-02-014 to serve and file briefs responsive to the questions set forth below in Section 3 of this ruling by August 27, 2021.

Section 1: COVID-19 Arrearage Relief

1. Can CAPP, Water and Wastewater System Payments, Small Business Grants, ERAP, HAF, and LIHWAP be leveraged to the benefit of the customers of water and energy utilities? What specific steps, if any, should water and energy utilities take to facilitate the flow of funds to their customers?
2. Can the established data sharing relationship between energy utilities and the California Department of Community Services and Development (CSD) be leveraged to: (a) Enhance the distribution of COVID-19 relief funding administered by CSD? (b) Support the development of LIHWAP and a statewide low-income water rate assistance program? In answering this question, please also take into consideration the requirement for energy utilities to share low-income customer data with public water systems statewide.
3. In light of the arrearage relief available through CAPP, Water and Wastewater System Payments, ERAP, HAF, and LIHWAP, what need, if any, remains for water and/or energy utility customer arrearage relief? (a) Does the remaining need vary by customer classes and within customer classes, by customer segment, and specifically for Small Business customers? On what basis? What data support this? (b) For customer classes and/or segments identified in response to Question 3.a. directly above, what is the extent and scale of need for arrearage relief?
4. If it is not yet possible to determine the remaining need for water and/or energy utility arrearage relief, what specific information and steps, if any, must be taken in order to answer this question? If information or action from other entities and organizations is required to answer this question, specify: (a) By entity, which information is required? (b) By entity, which actions are required? (c) Any time estimates before such information will be produced or action taken, and the impact to this proceeding.
5. How should the remaining need for arrearage relief be funded? (a) How is your funding recommendation reasonable and applicable?
6. Is any transfer of personal customer data necessary to secure the relief funding? (a) If the transfer of personal customer data is necessary, have protocols to protect the privacy of personal customer data been established and implemented? (b) Do any barriers remain with regard to the transfer of personal customer data? If barriers remain, please describe in detail each barrier and the timeline and steps you will take to address such barriers.

Section 2: Application of Relief Funding to unpaid Energy bills Associated with COVID-19 and Disconnection (Water Stakeholders Only)

1. If any, what ambiguities exist with the adopted pandemic buffer, and clarification(s) do you recommend?

Section 3: Allocation of Payments on Past-Due Utility Bills Between Community Choice Aggregators (CCAs) and Utilities (Energy Stakeholders Only)

1. Should arrearage relief be applied to Community Choice Aggregator (CCA) customers? If so, how? (a) To the extent that customers are not at risk of disconnection for failure to pay their CCA charges, does this change the need for arrearage relief of CCA charges? (b) To what extent does Public Utilities Code Section 779.2 require utilities to allocate partial payments first to disconnectable charges?

Section 4: Inter-Industry Coordination to Support COVID-19 Relief and Affordability

1. Regarding a central repository of customers qualifying for low-income programs: (a) What are potential costs and benefits of switching to a central model? (b) What are potential impacts of, if any, on qualifying low-income customers of a central repository? (c) Identify potential entities, if any, that could administer such a central repository, and explain the advantages of each entity identified.
2. Describe any and all coordination among your overlapping utilities with regard to ERAP.
3. Has your utility received payments from ERAP to relieve customer utility bill debt? (a) If yes, provide the number of utility customers for whom ERAP funds have been credited to their account, (b) If yes, provide the total amount of ERAP funds received and credited to all customer accounts itemized in Question 4.a. above, and the aggregate percentage of debt reduced for all customer accounts itemized in prior Question 3.a. directly above.
4. Will resumption of Customer Assistance Program (CAP)and CARE program renewal, certification and verification activities occur at the same time and if not, are any adjustments needed to align the timing?
5. Should energy and water companies work together to retain low-income customers in the CAP and CARE programs when renewal activities resume?
6. Some water companies report that the exchange of data pertains only to enrollment data, and not renewal and recertification data. Should data exchanges include exchanges of low-income customer renewal and recertification results? Why or why not?

Section 5: Statewide Coordination over Affordability and Low-Income Assistance Program

1. Is bill delinquency a function of the amount of the utility bill?
2. Is bill delinquency a function income and other socio-economic (equity) indicators?
3. Is any further process or protocol necessary for sharing of low-income utility customer data between energy utilities and CSD to support 1) disbursement of COVID-19 arrearage relief funds, 2) LIHWAP, or 3) preparation for a statewide low-income water rate assistance program?
4. Beyond the monthly data reporting working sessions beginning for Class A water utilities, is additional coordination with the State Water Board necessary?
5. In the interim while the state develops a statewide low-income water rate assistance program, should the Commission pursue changes to the CAP surcharge? In response, parties should refer to Attachment C showing which water utilities offer the CAP program, how the program discount is structured, and how the surcharge to fund the program is structured. (a) What are the impacts on affordability of a volumetric vs. flat surcharge? (b) What are the impacts on affordability of assessing the surcharge across the service territory vs. assessing the surcharge by district or region? (c) What are the impacts on affordability of assessing the surcharge only on water billed at Tier 2 or higher rates? (d) What are the different impacts on environmental and social justice communities, of changing the structure of the CAP surcharge? (e) Would changing the structure of the CAP surcharge change or impact the benefits received by CAP participants? (f) Would changing structure of the CAP surcharge affect the eventual participation of Commission-regulated water utilities in a statewide low-income water rate assistance program?