7. The Utilities Should Enhance Outreach and Program Delivery to the Disabled Community
7.1. Introduction
The KEMA Report finds that more than 20% of low income customers are disabled. Increasing LIEE outreach and service to the disabled community will enhance program penetration in the low income community.54 For this reason, we approve the IOUs' proposals for increasing and expanding their efforts to target the disabled community to reach those with the greatest need, interest and accessibility.
However, the enrollment of customers with disabilities in LIEE appears to be lagging behind need. We therefore set a goal for the IOUs to increase their enrollment of households containing persons with disabilities for the 2009-11 program years so that customers with disabilities comprise approximately 15% of new LIEE enrollments annually. We also require the IOUs to leverage their LIEE program outreach with the Commission's Deaf and Disabled Telecommunications Program (DDTP) and disability-related community based organizations (CBOs) in California.
Because customers with disabilities may not always self-identify or be obvious, we will allow IOUs to count customers they enroll in LIEE as a result of leveraging with CBOs that serve the disabled community, or with the DDTP, toward the 15% annual enrollment goal. IOUs may also count customers who voluntarily self-identify as disabled or whom the IOUs enroll from the Medical Baseline program. The IOUs should not ask customers if they are disabled, but instead allow customers with disabilities to voluntarily self-identify. They may also count as disabled persons who have an observed disability such as a mobility, vision or hearing disability, and persons who use TTY/TDD or request accessible formats of written materials (i.e., large print and/or Braille).
7.2. Parties' Positions
PG&E's application proposes five pilots aimed at traditionally hard-to-reach low and very low income customers, including customers with disabilities.55 PG&E also plans several ME&O efforts in 2009-11 that target specific populations, including the disabled community. Further, PG&E proposes projects that will help customers with disabilities, including a partnership with Meals on Wheels to provide microwave ovens and other LIEE measures to homebound clients. In conjunction with SCE, PG&E proposes a household segmentation and targeting study to help identify and conduct outreach to potential LIEE customers, including customers with disabilities.56
SDG&E states that it will continue to target customer segments, including the disabled community, based on the extent to which they have high energy use and other characteristics on which SDG&E plans to focus its segmentation strategies. SDG&E will also coordinate its LIEE program promotions with its Medical Baseline program to leverage with agencies that serve persons with disabilities. SDG&E will continue to make program materials available in large print for visually-impaired customers and intends to maintain a working relationship with agencies that serve seniors.
In SCE's application, SCE proposes plans for Cool Center programs, adoption of which will further the Commission's objective of providing assistance to low income, disabled residents living in isolated, extreme climate areas during the hot summer months. SCE adds that even though these cooling measures tend to be less cost effective than other measures such as CFLs and refrigerators, they provide relief from the heat and are essential to the comfort, health, and safety of SCE's low income customers with disabilities.57 In addition, SCE plans to target ME&O efforts by specific population segments, including the disabled community, and to use the Medical Baseline program account to enroll and target persons with disabilities.
SoCalGas proposes to continue to target the disabled community with brochures and applications available in multiple languages and large font and has also designed a brochure, Services for Customers with Disabilities, for customers with special needs. In addition, SoCalGas provides TTY/TTD telephone service 24 hours a day, seven days a week for hearing impaired customers. SoCalGas annotates the accounts of their hearing and vision impaired customers to enable it to generate a list for direct mailing and outbound dialing campaigns. SoCalGas' website is designed to ensure that visually impaired customers have full access to information and its website is compatible with assistive technology such as screen readers.
SoCalGas states that its outreach activities for CARE and special needs customers will be expanded in 2009-11, and future efforts will include direct mailings to senior centers in SoCalGas' service territory. In addition, SoCalGas will advertise CARE and Medical Baseline in local newspapers and medical publications, and participate in local events focusing on persons with disabilities. SoCalGas approximates $35,000 is needed to fund this cost category for each program year.
In its protest,58 DRA asserts that PG&E's application fails to explain what methods it will use to increase participation in the disabled community. DRA recommends that the Commission direct PG&E to work with the Commission's DDTP to help increase participation of persons with disabilities in the LIEE program. DRA also offers to work with PG&E and Disability Rights Advocates (DisabRA) to enhance LIEE service to the disabled community
In its Prehearing Conference Statement, DisabRA states its primary concern is that outreach efforts specifically target persons with disabilities and that information used in such outreach efforts be accessible to persons with disabilities.59 In later comments, DisabRA urges the Commission to require the IOUs to: (1) engage in targeted outreach to persons with disabilities to inform them about and, where appropriate, enroll them in the LIEE and CARE programs; (2) make all ME&O efforts and materials used by the utilities accessible to persons with disabilities; and (3) tailor LIEE customer segmentation to the needs of persons with disabilities.60
7.3. Discussion
The Commission recognizes the needs of persons with disabilities in the context of its low income programs. In D.06-12-038, we stated that structures, information and services related to CARE and LIEE programs must be accessible to and tailored to the needs of customers with disabilities in order for utility programs to be provided on an equal basis to all qualified customers.61
However, there is more that needs to be done than just making LIEE and CARE accessible to the disabled community. Persons with disabilities are disproportionately low income, and serving the disabled community with LIEE outreach and especially measure installation will enhance penetration of the LIEE program in the low income community. Thus, the IOUs should go beyond accessibility to actively target and serve the disabled community with LIEE measures.
KEMA reports that overall, 23% of low income households contain a member who has a hearing, vision or physical disability, and 15% of low income households have a member who is mentally and/or emotionally disabled. Finally, among all low income households, 22% contain a member who is disabled and also responsible for paying the utility bill. In addition, the results of the KEMA segmentation analysis indicate that households with disabilities demonstrate significant need for the programs' services.62 Because persons with disabilities are so prevalent in the low income population, an IOU that adequately targets the disabled community in its LIEE outreach will end up targeting a large segment of the low income community. Thus, setting a 15% goal for IOUs to strive for in marketing LIEE to the disabled community does not simply target a "niche," but rather focuses on a community that can enhance IOUs' in reaching low income households on the whole.
To meet our penetration goal that 15% of annual new LIEE customer enrollments come from the disabled community, IOUs should pursue new leveraging opportunities with disability rights and service organizations in California.
SoCalGas has a notable existing ME&O program targeted at the disabled community. We encourage the other IOUs to follow suit. However, simply identifying various ME&O efforts for reaching this population segment is insufficient. The benefits of such efforts should be measurable. We thus set a goal that for the 2009-11 program years approximately 15% of the total households enrolled in LIEE should have at least one disabled member. This 15% goal is far below the representation of persons with disabilities persons in the LIEE-eligible population, and thus is reasonable.
We will also require the IOUs, if they are not doing so already, to coordinate with the DDTP to help increase participation among the disabled in accordance with the KEMA Report's recommendations, and as recommended in DRA's protest. In addition, the Commission also encourages the IOUs to leverage with DisabRA, the Disability Rights Education and Defense Fund, and other organizations or CBOs serving the disabled in California to better market to, educate, and target the low income disabled community. We ask the disabled advocates active in this proceeding and DRA to coordinate this work with the IOUs.
We require that the IOUs report the status of this effort in their annual reports to the Commission identifying the level to which their efforts meet the 15% penetration goal. In cases where the participation from the disabled community is below the 15% goal, the IOUs shall provide an explanation. Further, the IOUs shall also describe their efforts to target outreach to persons with disabilities to inform them about the LIEE and CARE programs to make their ME&O efforts and materials accessible to persons with disabilities, and lastly, how their LIEE customer segmentation for ME&O and program delivery takes into account the needs of persons with disabilities. The utilities shall ensure accessible ME&O for CARE and LIEE by providing alternate formats for communications.
Specifically marketing to this community and setting the above 15% disabled household penetration goal supports the programmatic initiative of enrolling all eligible and willing low income customers in the LIEE program by 2020, resulting in home energy benefits to those most in need. Additionally, we encourage the IOUs to continue exploring new and creative leveraging efforts and partnerships with the disabled community and affiliated organizations, and expect an overall increase in the enrollments as well as improved and/or increased customer benefits.
However, based on comments on the proposed decision by DisabRA, the IOUs should not ask customers whether they are disabled, even if the IOUs ask all customers as part of a standard enrollment procedure. However, the IOUs may include as disabled (and therefore, count toward their 15% goal) customers they obtain through disability rights groups, the DDTP, and the medical baseline; customers who voluntarily self-identify as disabled; customers who have an observed disability such as a mobility, vision or hearing disability; and persons who use TTY/TDD or request accessible formats of written materials (i.e., large print and/or Braille).
Finally, we also agree with DisabRA that IOUs shall enroll in CARE all eligible customers they add to the LIEE program as part of the 15% goal for enrollment of customers with disabilities.
54 KEMA Report, p. 4-7.
55 Pacific Gas and Electric Company Testimony in Support of Application for the 2009, 2010, and 2011 Low Income Energy Efficiency Program and the California Alternate Rates for Energy Program, p. 1-5.
56 Id. at 1-49, 1-50.
57 Testimony of Southern California Edison Company in Support of Application for Approval of Low income Assistance Programs and Budgets for Program Years 2009 through 2011, pp. 37-38.
58 Protest of the Division of Ratepayer Advocates to the Application of Pacific Gas and Electric Company, Southern California Edison Company, Southern California Gas Company, and San Diego Gas and Electric Company for Approval of their 2009-11 Low income Assistance Programs and Funding, filed June 19, 2008, pp. 33-34.
59 Prehearing Conference Statement of Disability Rights Advocates, filed June 9, 2008, p. 1.
60 Comments of Disability Rights Advocates Regarding the Utilities' 2009-11 Low Income Assistance Program Application, filed August 1, 2008, p. 3.
61 D.06-12-038, pp. 63-67.
62 Id. p. 7-14.
