2. Background
This rulemaking was opened to determine whether sharing of qualifying low-income customer information between regulated water and energy utilities should be required and whether sharing of this information between regulated water and municipal energy utilities should be encouraged to increase enrollment in water and energy low-income assistance programs. The rulemaking requested comments on those issues and asked whether the rules adopted in this proceeding should be based on the existing data sharing program between regulated energy utilities and other energy utilities, including municipal utilities.2 The schedule was suspended by Administrative Law Judge's (ALJ) electronic mail rulings, and a February 17, 2010 ruling set a workshop to address low-income information sharing programs. A workshop was held on March 3, 2010 to inform workshop participants about low-income data sharing programs among the regulated energy utilities, to discuss the applicability of these programs as potential models for data sharing among water and energy utilities, and to identify guidelines governing data sharing among water and energy utilities. Pacific Gas and Electric Company (PG&E), Southern California Edison Company (SCE), and Southern California Gas Company (SoCalGas) representatives participated in a panel discussion on their low-income data sharing programs. A discussion on the applicability of these programs and proposed guidelines on data sharing among energy and water utilities followed the panel discussion.
The April 1, 2010 ruling and scoping memo requested comments on low-income customer information sharing among water and energy utilities, including the use of categorical eligibility, and proposed guidelines.3 Comments were submitted on April 23, 2010 by California Water Association4 (CWA); Division of Ratepayer Advocates (DRA); Joint Consumers (National Consumer Law Center, Disability Rights Advocates and The Utility Reform Network); two sets of Joint Utilities, one set is SCE and PG&E, and the other set is San Diego Gas & Electric Company (SDG&E) and SoCalGas; PacifiCorp d.b.a. Pacific Power (PacifiCorp); Park Water Company (Park); and Southwest Gas Corporation (Southwest).
A January 18, 2011 ALJ ruling requested comments on several issues and proposed outcomes, including consistent guidelines between low-income energy and water assistance programs, a data sharing plan, procedures for cost recovery, and monitoring of the low-income data sharing program. On February 1, 2011, CWA, DRA, Joint Consumers, PG&E, SDG&E/SoCalGas and Southwest submitted responses to the ruling.
2 Proposed rules were attached as Appendix B.
3 Proposed guidelines were attached as Attachment A.
4 CWA members supporting those comments are Alisal Water Company (dba Alco Water Service), California American Water Company (California American), California Water Service Company (CalWater), Del Oro Water Company, East Pasadena Water Company, Golden State Water Company (GSWC), San Gabriel Valley Water Company, San Jose Water Company (San Jose), Suburban Water Systems, and Valencia Water Company.
