Word Document


Consumer Service and Information Division


Public Advisor's Office

Date: November 10, 2011

Mailed November 15, 2011


Resolution CSID - 005 extends the duration of the pilot program, referred to as Community Help and Awareness of Natural Gas and Electricity Services (CHANGES), which provides education, resolution of needs and disputes, and outreach on energy matters. The program is designed for limited-English proficient consumers to receive this assistance in their preferred language. Services are provided through a statewide network of community based organizations.



On November 19, 2010, the California Public Utilities Commission (Commission) issued Resolution CSID - 004 and approved a one-year in-language pilot program referred to as Community Help and Awareness with Natural Gas and Electricity Services (CHANGES). The CHANGES pilot program provided energy-related (electric and natural gas) education, resolution of needs and disputes, and outreach services for limited English proficient (LEP) consumers in their preferred languages through an existing statewide network of community based organizations (CBOs).

Through CSID - 004, the Commission directed the Consumer Service and Information Division (CSID) to evaluate the effectiveness of the pilot and recommend whether the program should continue. In response to that order, this resolution details the achievements of the pilot through September 2011, and recommends that the pilot duration be extended to allow time for additional data collection and pilot evaluation, as well as time to review and address the appropriate California Alternate Rates for Energy (CARE) funding, if any, in the Commission's current proceeding relating to the four major energy investor-owned utilities'1 (IOUs) 2012-2014 CARE budget Applications (A.) 11-05-017 through A.11-05-0202 (CARE Budget Proceeding). A proposed decision on the CARE funding level for CHANGES is expected in the fall of 2012.

Until the Commission makes a final determination on whether CHANGES should become a permanent program, the pilot will continue to be funded through CARE funds. This resolution sets the funding for this portion of the pilot at a level not to exceed $60,000 per month.

The intent of this pilot extension is to ensure that there will be no gap in pilot authority or funding, and therefore services, while the Commission collects and evaluates data, and considers whether the CHANGES pilot should become a permanent program.

CSID and the Energy Division, along with an independent consultant, should review 12 months of data collected concerning the pilot program to determine its ability to effectively assist LEP consumers and evaluate the benefits of the pilot's use of CARE funds. By July 15, 2012, the independent consultant will submit a report of its findings to CSID, the Energy Division and the assigned Administrative Law Judge in the CARE Budget Proceeding for inclusion and consideration in that proceeding.

Following review of the evaluation, CSID will provide a recommendation, through a resolution to the Commission on whether the pilot program should be approved as an ongoing program, what its budget should be and how it should be funded.


More than six million, or 20 percent3, of California's consumers have limited proficiency in English. California leads the nation in illiteracy; that is, people who cannot read, speak or write English.4 This includes residents who have not successfully acquired reading, writing or speaking skills in English, members of the deaf community who communicate in Sign language and immigrants who have yet to achieve fluency in English5.

Speaking a primary language other than English may create a barrier to learning about and receiving the benefits of consumer programs. State laws require state agencies and corporations to provide services in-language and both the Commission and the energy utilities have acted to provide in-language assistance through bilingual staff, language phone lines and in-language brochures6. LEP consumers benefit from assistance provided by CBOs. The Commission's Consumer Protection Initiative (CPI) for telecommunications, Decision (D.) 06-03-013 states, "We believe that we can improve our complaint resolution efforts by working more with CBOs, which possess unique insights into problems faced by specific communities."7 The Commission's decision addressing the needs of Telecommunications Consumers who have limited English proficiency (D. 07-07-043), also states that, "CBOs play an important role in bridging the barriers to effective communications between carriers and LEP consumers."8 Although both decisions concern the telecommunications industry, those same benefits could be applied to the CHANGES program and, in fact, have contributed to its accomplishments to date.

As a part of the CPI (D.06-03-013), and the Limited English Proficiency (D.07-07-043) decisions, the Commission created the Commission's Telecommunications Education and Assistance in Multiple-languages (TEAM) program which provides telecommunications outreach, education and complaint resolution services to consumers in the language of their choice through a statewide network of CBOs.

While participating in the TEAM program, the CBOs noted that consumers that used the TEAM program for in-language assistance also requested help understanding energy services and bills in the language of their choice. LEP consumers requested help understanding and enrolling in consumer programs, avoiding disconnections, getting payment arrangements, and resolving disputes. The realization that the LEP consumers were seeking such broad in-language assistance from the CBOs alerted the Commission that LEP consumers would benefit from an energy assistance program similar to TEAM. Therefore, the CHANGES program was conceived based on the TEAM model of providing in-language assistance through the same statewide network of CBOs in the TEAM program.


On November 19, 2010, the Commission approved a pilot program, through Resolution CSID - 004, to provide LEP consumers with outreach, education, and assistance resolving their energy needs and disputes in-language. Although this program is designed to assist consumers in languages other than English, English speakers seeking assistance through the program will also be assisted.

A workshop was held to receive input from interested parties. With that input, a pilot was jointly developed by the Commission's CSID Public Advisor's Office, the four major energy IOUs and the current TEAM contractor.

The CHANGES program launched in February 2011 and is comprised of four components: outreach, education, needs resolution and dispute resolution. Topics and samples which each component may include are as follows:

The CHANGES pilot program is administered through the same contractor, and performed by the same CBOs which are part of the Commission's TEAM program. TEAM provides the same in-language services for telecommunications issues; therefore, its contractor and CBOs already possessed the skills needed for an accurate and comprehensive test of the CHANGES pilot. The CHANGES pilot program is overseen by the CPUC's CSID. The contractor reports that from February 2011, through September 2011, the 22 CBOs participating in the pilot have achieved the following:

In general, the CBOs in the CHANGES program, as in TEAM, have been successful in communicating with LEP clients because those CBOs have been established as leaders in their communities for many years. Those CBOs' representatives are providing in-language assistance and are often from the same cultures as those they serve. This affinity provides additional insights, trust and confidence necessary for cultural sensitivity and effective communication with these consumers. In addition, the CBOs have been trained on energy services and billing, enabling them to explain issues to consumers and to interact with the utilities on behalf of consumers.

All four components of the CHANGES program complement and support each other. Therefore, each CBO should continue to provide each of the components to their clients. The outreach component brings clients to the CBO workshops where the education component applies to teach consumers about energy services. At the workshops, or as a result of them, clients bring their bills to the CBOs for assistance with the components related to resolution of needs and disputes.

Funding - While the CBOs participating in the CHANGES pilot program provide information when appropriate about the CARE program to the LEP consumers, the CHANGES pilot program is not a utility CARE program. It is an in-language assistance pilot program for non-English speaking and low-English proficient energy customers.

It so happens that the CHANGES pilot program, while serving the LEP communities also seems to be serving the CARE program eligible population. In fact, 92 percent of the clients assisted through CHANGES have reported that they are eligible for CARE service and a significant amount of them are seniors. The CHANGES program also has an education component which includes workshops on payment arrangements, level payment plans, explanation of consumer programs and other measures a person can take to avoid disconnection. Likewise, CHANGES dispute and needs components can assist a consumer to secure payment arrangements, receive referrals to assistance agencies, and other measures to avoid service disconnection.

The California Public Utilities Code, Section 739.4 permits utilizing CARE funds to provide services to help low income utility customers and seniors avoid unnecessary disconnections by providing information about assistance programs, payment arrangements and level payment plans. Because there appears to be a potential for a strong connection between the LEP communities being served and the CARE program population, the CHANGES pilot program was approved for funding through CARE program funds.

For the duration of the pilot, the IOUs will continue to fund the program through CARE funds capped at $60,000 per month, using the 30-30-25-159 funding split previously approved for Resolution E-3585 for all of the utilities' pilots, studies and joint efforts. This funding level is based upon current invoices from the CBOs, the administration costs (which were not included in the original budget), ongoing training, and database maintenance. It includes an anticipated increase in needs and dispute assistance during the winter and summer high-use months, which are invariably accompanied by service problems and high bills. Based on data included in the regularly submitted monthly reports, the use of the program by consumers has increased as the program has gained momentum. The increased budget amount includes this growth and the expectation that the momentum will continue. However, the utilities will only be billed for actual services provided. The proposed $60,000 per month funding does not include the costs for an independent third party to evaluate the program.

The Commission's CARE Budget Proceeding will address the level of funding to be allocated from the CARE program funds for a possible ongoing CHANGES program. This approach will provide greater opportunities for comment and evaluation of the funding for the CHANGES program within the context of the overall CARE program framework.

The CHANGES pilot program should continue until the Commission makes a final determination on whether CHANGES should become a permanent program. There should be no gap in CHANGES pilot authorization or funding, and therefore services, while the Commission collects and evaluates data, considers the CHANGES pilot and initiates the ongoing program, if the Commission decides that it should become a permanent program.

During the pilot program, the IOUs have contracted directly with Self Help for the Elderly as the manager for the CHANGES program. The contractor in turn pays the subcontractors for their services. The IOUs will amend their current contracts to reflect the pilot extension period and change in funding.

Program evaluation and report - CSID and the Energy Division will work with an independent third party consultant who will review 12-months of data collected concerning the pilot to evaluate the effectiveness of the pilot program and evaluate the benefits of the pilot's use of CARE funds. The evaluation will be funded through the utilities' CARE Measurement and Evaluation budget. This evaluation funding is in addition to the previously authorized program dollars. The cost of the evaluation has not yet been established, as it will depend on the focus and scope of the evaluation and the selected bid received through the state competitive bidding process. However, the evaluation budget shall not exceed 10% of the total pilot's funding. The focus and scope of the evaluation should be developed collaboratively by CSID staff and Energy Division staff with input from parties through a public workshop. The scope may include, but is not limited to, reviewing the implementation of the pilot program, including review of systems and the quality of tracking data, effectiveness of reaching program objectives and understanding how the program activities supports CARE, CARE eligible recipients, and other low income demand side management programs.

The independent consultant's role will be to evaluate and make recommendations concerning the pilot based on these review elements and additional factors that may be used to consider the effectiveness of the pilot program in assisting LEP consumers and evaluating the benefits of the pilot's use of CARE funds. The independent consultant's evaluation and recommendation should be presented in a final report. By July 15, 2012, the independent third party consultant will prepare, complete, and submit the final report to CSID, Energy Division and the assigned Administrative Law Judge in the CARE Budget Proceeding for inclusion and consideration in that proceeding. Since this review is likely to be after the decision on the other issues in the CARE Budget Proceeding, a subsequent decision will be issued to determine CARE funds for an ongoing CHANGES program. CSID will present a third Resolution recommending whether the pilot should continue as a permanent program.


The draft resolution was e-mailed on October 5, 2011, to parties on the Service Lists for proceedings R.10-02-005 (regarding customers' electric and natural gas service disconnection) and A.11-05-017 (consolidated proceeding for the utilities 2012-2014 CARE and Energy Savings Assistance Programs) and other interested people.

Comments were received October 25, 2011, from the following:

The Greenlining Institute and the Center for Accessible Technology support the draft resolution. They believe that CHANGES advances ongoing efforts to partner with existing institutions and community based organizations in order to improve understanding of utility services by low-income households. They state that they expect that the evaluation of the CHANGES program will confirm the program's usefulness. While the review is pending, they support an extension of the existing pilot program. Because the populations served by the participating CBOs are overwhelmingly CARE-eligible, they support the continued use of CARE program funds to continue with the CHANGES pilot.

The Joint Parties support the resolution and are concerned that the Filipino-American community should be provided with Tagalog language services. The CHANGES pilot includes a CBO which focuses on the Filipino community; and other CBOs in the program have Tagalog-speaking staff available to assist consumers.

Sempra believes the pilot program has the potential to provide a valuable resource to the utilities' hardest to reach customers and supports the draft resolution.

Sempra, SCE and PG&E are concerned about the increased funding in this resolution. It should be noted that the increased funding is intended to cover existing costs, as well as potential anticipated increases in use of the program as it becomes more widely known, and as seasonal increases in energy use may increase needs and dispute resolution. In part, this increase stems from the Commission's past experiences of having received increased consumer complaints during the summer and winter months. In any event, the utilities will only be billed for actual program activity, as supported by the monthly invoicing. In addition, demand for the program in two of the utilities' territories is already at or exceeding the proposed funding level and increased CBO activities planned by the contractor and the IOUs are likely to increase use of the program in those areas as well.

All four IOUs raise concern that there may be some timing issues with regard to the projected proposed decision in the 2012-2014 CARE programs, currently targeted for the spring of 2012. The concern is that the CHANGES pilot program evaluation is not expected to be completed until at least July 2012, and there remains the question of continued CARE funding of the CHANGES pilot after the proposed decision in the spring. To clarify, the proposed decision projected for spring 2012 will continue the CHANGES pilot funding. The spring proposed decision will postpone the CARE funding consideration for any ongoing CHANGES program until the review of the CHANGES pilot evaluation has been completed. The Commission will consider the CARE funding issue in a subsequent decision, expected in the fall 2012. Until a decision is reached regarding CARE funding, the CHANGES program should continue to be funded through CARE funds, as discussed above.

The IOUs also raise concern that a budget for the evaluation had not yet been determined. The evaluation will be funded through the CARE Program Measurement and Evaluation budget at an amount not to exceed 10% of the total pilot budget.

Sempra also comment that the change in funding increases their contribution by 50%. The increase for SDG&E will not exceed $9,000 a month. The increase for SoCalGas will not exceed $15,000 a month. All IOUs will only be billed for actual services provided. Sempra points out a typographical error wherein the contribution ratio included 25% for SCE when it should have been 30%. Sempra notes an omission of a sentence which was in the first resolution which explains that although this is an in-language program, consumers who seek help speaking English will not be turned away. Both those corrections are made in this resolution.

Sempra also suggests a workshop be held to develop the scope of the evaluation and to determine the metrics to be used to evaluate the pilot. The Commission's CSID and Energy divisions are considering the best approach in developing a Request for Proposal to solicit bids through the state contracting competitive bidding requirements and should hold a public workshop for input on the divisions' plan.

SCE comments do not support extending the pilot. SCE recommends that the pilot be stopped and evaluated based on the nine months of data currently available. The Commission believes continuing the program will provide sufficient data to fully evaluate the pilot. SCE comments state that it provided a special telephone number for the CBOs to call for assistance, but the utility only received 15 calls on that line, none of which requested SCE's assistance with dispute resolution. In joint meetings with the contractor and SCE, the project manager asked the contractor to remind the CBOs to call the special 800 number. However, CBO nonuse of this resource does not negate the fact that the CBOs have been contacting the utility about disputes, they have instead called SCE's customer service department (which complies with the measures outlined in CSID-004). The data collected in the CHANGES database indicates that through September 2011, the CBOs resolved 26 disputes and 153 needs in SCE territory. The CHANGES CBOs also educated 1,767 SCE customers in nine languages. These figures are backed up by paper documentation and verified by the contractor. CHANGES is not intended to replace the assistance SCE customers receive through the utility directly, but to help the utility assist the hard to reach, vulnerable, limited English proficient consumers understand their energy utility bills and help them with needs and disputes.

SCE also urges the Commission to review the funding source for the CHANGES pilot since the relationship between CHANGES and enrolling new CARE customers has not been established. While CHANGES does not include enrolling new CARE customers, the pilot provides education and assistance to non-and low-English speaking consumers, which includes helping low-income consumers and seniors control their utility bills and avoid disconnections, as specified in the California Public Utilities Code, Section 739.4. However, all of the CHANGES CBOs are also CARE capitation agencies and as such, the CBOs also provide the IOUs another way to approach and enroll hard to reach consumers into the CARE program. Over 92% of the customers served by CHANGES are eligible for CARE. Therefore, it is an opportunity for the CBOs to enroll customers in CARE, in addition to providing the CHANGES program services.

PG&E's comments request that there be a comment period following the issuance of the evaluation report and that the Commission hold a workshop prior to the decision reviewing the report and addressing the longer term composition of the CHANGES program. The Commission will be providing many opportunities to comment throughout this process; therefore, will not be scheduling a workshop about the report, funding or pilot. The Commission will provide an opportunity to comment on the report, on the proposed decision regarding utilizing CARE funds for the program, and on the draft resolution determining whether the pilot should be made an ongoing program.

Findings of Fact

Conclusions of Law


This Resolution is effective today.

I hereby certify that the Public Utilities Commission adopted this Resolution at its regular meeting on November 10, 2011. The following Commissioners approved it:

Attachment A

California Public Utilities Code, Section 739.4

739.4. (a) Any natural gas customer who enrolls in the CARE program after the effective date of this section, but before October 1, 2001, shall receive the same one-time bill credit based on the amount of each gas corporation's average CARE customer discount applied for each month in October 2000 to March 2001, inclusive. The credit does not apply to a customer who initiates service with a gas corporation after the effective date of this section, and who has no prior history of service with the gas corporation. CARE program funds shall be used for the purpose of providing these credits. The commission shall adjust CARE program income requirements annually to reflect the increased cost-of-living due to inflation.

   (b) The commission shall require all electrical and gas utilities through which CARE program rates are available to do all of the following, in multilingual formats to the extent printed and recorded information is provided, to facilitate better penetration rates for the CARE program and to protect low-income and senior households from unwarranted disconnection of necessary electric and gas services:

   (1) Provide an outgoing message on all calls, where the customer is seeking to establish service or is put on hold, to customer service lines that briefly describes the CARE program in standard language approved by the commission, and that provides a toll-free phone number for customers to call to subscribe to the program or for further information.

   (2) Provide information to customers about the CARE program and facilitate subscription to CARE, on all calls in which customers are making payment arrangements, on all collections calls, and on all calls for reconnection of service.

   (3) (A) Provide information about the CARE program and other assistance programs, and attempt to qualify customers for CARE, and provide information about individual payment arrangements that allow customers to pay the amounts due over a reasonable period of time, not to exceed 12 months, and attempt to enroll customers in a payment arrangement program, before effecting any disconnection of service for nonpayment or inability to pay energy bills in full.

   (B) (i) Offer individual payment arrangements to customers so that the customer is able to pay amounts due over a reasonable period of time, not to exceed 12 months.

   (ii) Prohibit the disconnection of customers that have made, and are in compliance with, payment arrangements offered by an electric or gas utility pursuant to this subparagraph.    (C) Prohibit the disconnection of a delinquent residential customer for amounts due in which the electric or gas utility receives a commitment pledge, letter of intent, purchase order, or other notification that a provider of energy assistance is forwarding payment sufficient to prevent disconnection.

   (D) (i) Advise residential customers facing disconnection or who contact the utility to make payment arrangements of the levelizing payment program that allows them to pay a monthly average bill based on 12 months usage.

   (ii) Advise residential customers about enrollment in the levelizing payment program in conjunction with completion of payment arrangements, payment under terms of subparagraph (B), or at the customer's request absent those arrangements.

   (E) Nothing in this paragraph is intended to reduce the revenues of any utility extending payment arrangements subject to the terms of the paragraph.

   (4) Provide information on customer bills, presented in a conspicuous manner on a front facing page that indicates that a customer may be eligible for the CARE program. This notice shall be provided quarterly on customer bills.

   (c) The commission shall conduct targeted outreach about the program using census block data to effectively target low-income and senior households throughout the state.

   (d) CARE program funds shall be used for the purposes of paragraph (3) of subdivision (b) and outreach pursuant to subdivision (c). The commission's costs for outreach pursuant to subdivision (c) may not exceed five hundred thousand dollars ($500,000) above the amount that the commission currently expends on similar activities related to the CARE program. Energy corporations may recover all reasonable costs from the CARE program funds of implementing this section.


Attachment B

Service lists

Service lists are located on the CPUC website docket at cpuc.ca.gov or at the links below.

Service list for R.10-02-005


Service list for A.11-05-017


CPUC Staff

Loreen McMahon - lm3@cpuc.ca.gov

Karen Miller - knr@cpuc.ca.gov

Kyle DeVine - kyl@cpuc.ca.gov

Karen Clopton - kvc@cpuc.ca.gov

Frank Lindh - frl@cpuc.ca.gov

Ramon Momoh - rmm@cpuc.ca.gov

Kimberly Kim - kk2@cpuc.ca.gov

Hazlyn Fortune - hcf@cpuc.ca.gov

Carmen Best - cbe@cpuc.ca.gov

Ava Tran - atr@cpuc.ca.gov


Linda Fontes - LCF2@pge.com

Rommel Riemedio - RBR8@pge.com

Monica Tell - M1T2@pge.com

Kevin Koch - KRK9@pge.com

Rick Hobbs - RHobbs@semprautilities.com

Eustolia Castillo - ECastillo@semprautilities.com

Eleanor Tamayo - ETamayo@semprautilities.com

Hugh Yao - HYao@semprautilities.com

Rosa Wise - RMWise@semprautilities.com

Sandra Williams - SMWilliams@semprautilities.com

Maria Farries - MFarries@semprautilities.com

Monica Freymiller - MAFreymiller@semprautilities.com

Aida Velasquez - AVelasquez@semprautilities.com

John Fasana - John.Fasana@sce.com

Flor Tolley - Flor.Tolley@sce.com

Gina Sanchez - Gina.Sanchez@sce.com

Angelica Baldwin - Angelica.Baldwin@sce.com

Bobbie CaoBass - Bobbie.Caobass@sce.com

Kari Gardner - KariGardner@sce.com

Linda Yamauchi - Linda.Yamauchi@sce.com

Maricela Carlos - Maricela.Carlos@sce.com


Anni Chung - annic@selfhelpelderly.org

Casey McFall - milestonecasey@yahoo.com

1 The four major investor-owned energy utilities in California are: Pacific Gas and Electric Company (PG&E), San Diego Gas and Electric (SDG&E), Southern California Edison (SCE), and Southern California Gas Company (SoCalGas).

2 A.11-05-017, A.11-05-018, A.11-05-019, and A.11-05-020, Applications of the Large Investor Owned Utilities for Approval of 2012-2014 Budget for their respective California Alternate Rates for Energy and Energy Savings Assistance Programs.

3 The U.S. Census reported how many people responded to the census by indicating that they spoke English "less than very well." Both the federal government and California's define this as limited English proficient.

4 According to the U.S. Department of Education study in 2003, California's illiteracy rate is 23%.

5 The U.S. Census reports that California remains the primary destination for immigrants in the United States.

6 The CPUC provides brochures in 18 languages as follows: English, Spanish, Chinese, Tagalog, Vietnamese, Korean, Japanese, Thai, Hmong, Khmer, Portuguese, French, Armenian, Arabic, Farsi, Russian, Burmese and Laotian.

7 D.06-03-013, p.101

8 D.07-07-043, p. 94

9 The breakdown for the utilities follows: PG&E - 30%, SCE - 30%, SoCalGas - 25%, and SDG&E - 15%.

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