8. LIEE/CARE Income Eligibility Level - Bear Valley

Bear Valley asks that we raise the income eligibility level for the LIEE and CARE programs from 175% to 200% of the federal poverty line. Bear Valley asserts that this change will place its program on par with Southwest's, and thus make it more efficient since the two SMJUs serve the same customers and exchange data to enhance program penetration. If both SMJUs have the same eligibility guidelines, they may both serve the same customers (one SMJU with gas service and the other with electricity).

DRA initially objected in its protest that more analysis was needed to demonstrate the effect on nonparticipating customers of increasing the number of LIEE customers, and thus the surcharge on nonparticipating customers' bills. In reply comments, Bear Valley furnished that analysis,¹⁶ and DRA in its October 7, 2008 brief dropped its objection. Bear Valley's basic contention is that an increase in the program eligibility level to 200% will not affect ratepayers in the 2009-2011 period because it will not serve more customers during that period. Bear Valley states the following in this regard:

If the eligibility were changed to 200%, it would not have any rate impact over the [Bear Valley] LIEE/CARE Application time period (2009-2011) on the LIEE program because [Bear Valley] would not propose to increase the total number of customers it would serve in 2009-2011 as indicated in its LIEE/CARE Application. The result would be that the LIEE program would be on a slightly more accelerated course to reach full LIEE penetration after the 2009-2011 period.¹⁷

As for CARE, Bear Valley asserts that an increase in income eligibility from 175% to 200% will render 500 more customers eligible for CARE, 309 of whom (the company estimates) will participate in the program. It will also bring the eligibility requirements in line with those of Southwest Gas, the natural gas supplier in Bear Valley's service area. The impact on nonparticipating Bear Valley ratepayers will be 14 cents a month in 2009 and 27 cents a month in 2012, based on impact figures of $.00033/kWh for 2009 and $.00062/kWh for 2012.¹⁸

We are satisfied that the bill impacts are small enough to warrant granting Bear Valley's request as to the CARE program. We are also concerned about Bear Valley's low level of CARE penetration (55% of those estimated to be eligible as of December 31, 2007), and agree that this increase will deliver an increase in penetration.

We also grant the request as to LIEE, but will require Bear Valley to increase the number of LIEE customers it serves. Since it will increase its CARE penetration by 309 customers, and LIEE customers will follow the same income guidelines, we expect Bear Valley to serve at least 150 new LIEE customers during 2009-2011. We grant Bear Valley an increase of $41,550¹⁹ to its LIEE measures budget to serve these customers.

¹⁶ Bear Valley also supplemented its reply comments in response to an ALJ request for further data, and amended its response in a filing made on October 16, 2008.

¹⁷ Amendment To Application Of Golden State Water Company For Approval Of Its 2009-2011 Low-Income Energy Efficiency (LIEE) And California Alternate Rates For Energy (CARE) Plans and Budgets for Bear Valley Electric Service, filed September 30, 2008, p. 6.

¹⁸ Amendment to the Opening Brief et al., filed by Bear Valley on October 16, 2008, p. 3.

¹⁹ This figure is $831 (Bear Valley's average cost to serve each customer) x 50 customers/year. See Bear Valley's November 20, 2008 Opening Comments on Proposed Decision, p. 6.