6. LIEE Penetration Levels (Number of Customers Served)

The second key goal of the Plan that we apply to the SMJUs is the number of customers served. If one assumes the SMJUs should reach 100% by 2020, as the Plan does, then the SMJUs should be reaching approximately 25% of eligible customers who have not already received service in the three-year period from 2009-2011.

Southwest: Southwest estimates that it will assist customers in 1,200 homes in 2009 (of 29,306 eligible), 1,350 in 2010 (of 28,644 eligible) and 1,500 (of 27,970 eligible) in 2011. These figures represent approximately 4% in 2009, 5% in 2010, and 5% in 2011, or approximately 14% for the three-year period.

DRA uses slightly different numbers and concludes that Southwest will serve 15% of eligible LIEE customers (of the 25% the Plan sets as a goal) for 2009-2011. DRA urges greater penetration.

Discussion: We agree that Southwest should increase the number of LIEE customers it serves. If Southwest continues with these penetration levels, it will only reach a 60% penetration level by 2020, far short of our goal. Given that Southwest serves the largest number of customers among the SMJUs, we ask the company to increase its penetration so that it assists at least 25% during 2009-2011. We have given Southwest a budget increase to reflect this new level of LIEE penetration.

PacifiCorp: Because PacifiCorp is behind in its 2007-2008 penetration goals, and does not propose increases, DRA proposes that the company work with the Commission and other interested parties to increase its penetration. PacifiCorp projects that it will serve 110 LIEE homes in 2009, 115 in 2010, and 120 in 2011.

Discussion: Assuming 35,300 customers, an estimated 1/3 of which (11,766) are low income, according to the KEMA Report cited below, PacifiCorp should be striving to serve 25% of unserved customers, or approximately 2,941, during 2009-2011. (These numbers should be adjusted downward to reflect customers already served.) This means PacifiCorp should be serving 980 customers per year at the upper extreme. Its proposed figure is far below that, and neither PacifiCorp nor DRA address how to increase PacifiCorp's penetration. It is not realistic for PacifiCorp to increase its numbers to 980 customers annually in one three-year period, but we expect it to begin applying the same successful techniques it has used in its CARE program to LIEE. PacifiCorp shall start by enrolling all CARE customers in LIEE; and reaching out to its customers with high energy use, burden and insecurity. We grant PacifiCorp a budget increase to reflect that it should increase its penetration to 500 customers per year. We direct Energy Division to monitor PacifiCorp's reporting and inform the Commission if PacifiCorp is falling short of this target. We will adjust PacifiCorp's budget downward mid-cycle if it fails to approach the foregoing goal.

Sierra: Sierra treated and weatherized 106 homes in 2006, 176 in 2007, and estimates it will serve 140 homes in 2008, 153 in 2009, 171 in 2010 and 183 in 2011. DRA points out that Sierra provides multiple reasons for its low penetration, including the cost of living in the Lake Tahoe area, a high level of seasonal homes, overly burdensome income documentation requirements for part time/seasonal workers, and limited access to qualified installation contractors. DRA urges the Commission to "work with [Sierra] to overcome their unique challenges and set LIEE penetration goals that better reflect the Commission's programmatic initiative."¹²

Discussion: Sierra has approximately 3,000 low-income customers.¹³ Using the Plan for guidance, it should serve 750 customers with LIEE measures in 2009-2011. This adds up to 250 customers per year. Sierra served 140 customers in 2008 (115 treated; 25 weatherized). Thus, Sierra is somewhat short of the 250-home goal for 2009-2011, and should raise its goal to 250 homes per year.

We will increase Sierra's budget to accommodate this change, but direct Energy Division to monitor Sierra's reporting and inform the Commission if Sierra is falling short of this target. We will adjust Sierra's budget downward mid-cycle if it fails to approach the foregoing goal.

Alpine: Alpine will assist customers in seven homes in 2008, 12 homes in 2009, 15 in 2010 and 16 in 2011. DRA expresses concern that these numbers are too low, and that the company's budgets are questionable in their assumption that it is less expensive to treat a smaller number of homes than a larger number.

Discussion: Alpine should strive to serve more LIEE customers, as DRA proposes. Using Alpine's highest number of customers to be served (16 in 2011), Alpine would be serving only 1% of its customers in a given year (16 customers out of 1,150 total customers is 1% of Alpine's total customer base). As many as one-third of a utility's customers are low-income, according to the KEMA Report cited previously. Thirty percent of 1,150 customers is 345 customers. We expect Alpine to reach 20% of these 345 customers during 2009-2011. This is 68 customers for the three-year period, or 22 customers each year, between 2009 and 2011. We expect Alpine to strive toward this goal, without imposing an absolute requirement.¹⁴

¹² DRA Protest, p. 11. Prior to the Plan's adoption, D.07-12-051 referred to the 100% by 2020 as its LIEE programmatic initiative.

¹³ The proposed decision assumed a much higher figure - 15,000 - based on the assumption in the KEMA Final Report on Phase 2 Low-income Needs Assessment (KEMA Report), dated September 7, 2007, p. 4-2, that one-third of California's residential energy customers are low-income. Sierra and DRA adequately refuted this number in comments on the proposed decision, noting that Sierra's territory is a unique community of few permanent residents and many seasonal vacation home occupants. We accept the reduced figures reflected in Sierra's and DRA's November 20, 2008 comments here. The KEMA Report is available by searching at http://www.liob.org/lib.cfm.

¹⁴ DRA raises no objection to Bear Valley's LIEE penetration; because we find its LIEE penetration level adequate, we do not separately discuss the company here.