Current Standing
Subsequent to the Energy Division October 19th report, Energy Division continued to work with the three SMJU. The following sections summarize what these SMJU have achieved so far, and summarizes their proposals for utilizing SBx1 5 funds to improve their programs.
Status of West Coast Gas Company
West Coast Gas Company (West Coast Gas) has an existing CARE program with participating customers. In D.01-08-065, the Commission allocated West Coast Gas $2,077 in SB (X1) 5 funding for CARE subsidy costs.
West Coast Gas subsequently submitted to Energy Division a CARE Outreach Proposal for SBx1 5 funds, in the amount of $2,230.96. West Coast Gas' proposal is included in this update as Attachment A.
West Coast Gas' proposal includes amounts for preparing, printing and mailing CARE outreach materials. Included in West Coast Gas' proposal are amounts for installing voice-messaging equipment on its phone system to give CARE information when customers are "on hold," and preparing and printing a CARE application form to be included in each new application for service.
West Coast Gas did not include any regulatory or administrative costs associated with participating in Commission proceedings, and submitting advice letters or applications, necessary components for maintaining low-income assistance programs for its customers. West Coast Gas also did not include any cost projections for providing written and voice materials in multi-lingual formats, if it is ascertained a multi-lingual format is necessary.
Status of Alpine Natural Gas Operating Company
Alpine is willing to provide the CARE subsidy to any customer who requests it and is eligible. However, Alpine has never developed a CARE customer application form and thus, has never sent CARE applications to their residential customer base. Alpine does not currently have any CARE customers.
Alpine has been working with Energy Division to get its CARE program up and running. Alpine submitted a draft of a CARE application form for Energy Division to review. Alpine requested to be exempted from the requirement that they file an Advice Letter to request approval for their CARE customer application form. Alpine asserts that the associated costs with doing so are prohibitive. Energy Division informed Alpine that the CARE application form needs to be a part of their tariffs and that they will need to file an advice letter, as well as the yearly advice letters to update their tariffs for increases in the income guidelines. Energy Division's letter to Alpine is included with this update as Attachment C.
Alpine Utilities submitted a proposed budget of $2,150 for the one-time costs of printing, assembling, and mailing CARE notices, and assembling and mailing energy conservation brochures. Alpine is requesting that these proposed costs be funded by SBx1 5 CARE funds. Alpine's proposal is attached to this update as Attachment B.
Alpine's proposal does not include the cost of developing, printing and mailing a customer CARE application form, nor does it include the developing, printing, mailing or regulatory costs associated with filing advice letters or applications with the Commission. Alpine also does not propose to provide CARE applications or outreach materials in multi-lingual formats.
Alpine recently informed Energy Division that 17 customers are requesting to be put on Alpine's CARE program. Alpine requested permission to use the draft CARE application form to enroll these eligible customers. Energy Division believes their draft application form is appropriate as it mirrors that of San Diego Gas and Electric's. Energy Division informed Alpine that Alpine may temporarily use the draft application form to enroll customers into their CARE program until Alpine is able file an advice letter and receive formal approval for their draft customer CARE application form. Energy Division's letter to Alpine is included with this update as Attachment C.
Status of Mountain Utilities
Pursuant to the recommendation of Energy Division, Mountain Utilities indicated that they mailed the "Flex Your Power" brochure to all of its residential customers of record. Mountain Utilities asserts that they did not receive any customer communications about low-income assistance programs after mailing the "Flex Your Power" brochure to their residential customers.
Mountain Utilities did not propose a budget to implement a CARE or a LIEE program. However, similar to their comments on Energy Division's report, Mountain Utilities asserts that the costs of implementing a CARE program could exceed the annual subsidy that would be provided, if one or two of its customers did happen to qualify for CARE, by 100 or more times. Mountain Utilities indicated that it would cost even more to implement a LIEE program.
Indeed, if a utility has qualified low-income customers in its service area, there are many legislated requirements associated with ongoing CARE and LIEE program operations that would need to be complied with. Some of these requirements for CARE alone include, but are not limited to, in multi-lingual format: placing an outgoing message on the utility's phone system; providing a toll-free number service for customers to call to subscribe or to request further information; and mailing quarterly notifications of the CARE program to its customers. In addition, there would be other requirements, including, but not limited to, developing CARE penetration goals, complying with various reporting requirements and setting up and maintaining a balancing account for CARE administrative costs.
Energy Division does not believe that the costs of implementing a CARE program for Mountain Utilities would approach the estimate cited by Mountain Utilities. However, Energy Division estimates the costs would be significant.
For example, Alpine estimates that it will cost $2,150 as a one-time cost for printing, assembling, and mailing CARE notices, and assembling and mailing energy conservation brochures. This does not include the cost to develop, print, or provide CARE application forms to its customers. It does not include costs for developing and implementing the CARE phone outreach message. Nor does it include regulatory or administrative costs associated with participating in Commission proceedings or submitting advice letters or applications, necessary components for maintaining low-income assistance programs. Alpine also did not include any cost projections for providing written and voice materials in multi-lingual formats, if it is ascertained that a multi-lingual format is necessary.
West Coast Gas estimates it will cost $2,231 to conduct CARE outreach similar to that proposed by Alpine. Included in West Coast Gas' proposal are amounts for installing voice-message equipment on its phone system to give CARE information when customers are "on hold," and preparing and printing a CARE application form to be included in each new application for service. West Coast Gas did not include regulatory or administrative costs associated with participating in Commission proceedings, and submitting advice letters or applications, necessary components for maintaining low-income assistance programs for its customers. West Coast Gas did not include any cost projections for providing written and voice materials in multi-lingual formats, if it is ascertained a multi-lingual format is necessary.
Energy Division believes the costs mentioned above that the utilities did not provide estimates for will far exceed the costs of the expenses they did provide estimates for.
