The draft decision of Commissioner Neeper and ALJ Gottstein in this matter was mailed to the parties in accordance with Public Utilities Code Section 311(g) and Rule 77.7 of the Rules of Practice and Procedure. Comments were filed on August 24, 2000 by the Bay Area Poverty Resource Council, the California/Nevada Community Action Association, Community Resource Project, Inc., Latino Issues Forum/Greenlining Institute, ORA, PG&E, SCE, SDG&E/SoCal, Residential Service Companies' United Effort (RESCUE)/SESCO Inc. and Insulation Contractors Association. Reply comments were filed on August 29, 2000 by SCE, SDG&E/SoCal, and PG&E.
We have carefully considered the comments on the issues addressed in today's decision. In response to those comments, we clarify the content and scope of the compliance applications to be submitted by the utilities in response to this decision. In particular, we explain that today's decision adopts the Standardization Project (Phase 1) recommendations and extends the PY 2001 programs and funding levels through December 31, 2001, without further program design modifications. Any future proposals for modifying measure eligibility will be considered during the PY 2002 program planning process, after the Commission has received and reviewed the Reporting Requirements Manual Working Group report on cost-effectiveness standards for measure selection. We also extend the filing dates for certain deliverables required by this decision and correct inconsistencies in due dates that appeared in the draft decision. In addition, we clarify how we intend to apply the standardized methodology for estimating CARE penetration rates to the CARE Outreach Pilot results.
1. LIAB solicited public input on its recommendations in this proceeding, but did not follow the guidelines set forth by the Assigned Commissioner for the content of this filing.
2. For the most part, LIAB's recommendations for PY 2001 are duplicative of efforts underway, premature, lack sufficient clarity, are in conflict with recent Commission determinations, or do not represent high priority modifications of policies or programs for our consideration. In particular, LIAB's recommendations for improving program evaluation and oversight do not acknowledge current and developing reporting requirements for the utilities, the work of existing measurement and evaluation groups in this and other Commission proceedings, or the Standardization Project, Outreach Pilot, Attic Ventilation Pilot and Needs Assessment Study currently underway. None of the parties commenting on LIAB's recommendations proposed additional or alternate high priority modifications to policies, program designs or funding levels for PY 2001 LIEE programs.
3. There is a lack of standardization in CARE application forms and in the calculation of CARE penetration rates. These issues are not currently being addressed in the Standardization Project.
4. Low-income customers who receive assistance via the utilities' CARE and LIEE programs would benefit from receiving a standardized customer "bill of rights," including a description of the consumer complaint process.
5. LIAB's proposal for independent auditing requirements does not present or weigh the costs of that proposal in resources and manpower, or consider alternate approaches for improving program monitoring. The filings in this proceeding also do not describe current utility procedures (audits, process evaluations, polls, etc.) for monitoring program quality, cost-efficiency and customer satisfaction in low-income assistance programs.
6. The results of the Attic Ventilation Pilots will provide information needed for evaluating the cost-effectiveness of attic ventilation as a stand-alone measure.
7. In order to evaluate the results of the Outreach Pilot for PY 2002, the utilities need to have tracking systems in place throughout the pilot period.
8. The Standardization Project is an appropriate forum for considering LIAB's Specific Program Recommendations 20, 21 and 28.
9. By creating a standardized WIS manual and a consistent set of installation and other procedures, we believe that the recommendations contained in the Phase 1 Standardization Report will improve the implementation of LIEE programs.
10. Assigning specific tasks to LIAB and focusing advisory committee activities to those assigned tasks, will help ensure that program and Commission resources are most effectively and efficiently utilized. Transferring the task of nominating Board members and producing annual operating budgets from LIAB to Energy Division is an effective way to further conserve program resources.
11. To accomplish its current assignments, as clarified by this decision, LIAB and its advisory committee should be able to substantially reduce the number of scheduled meetings.
12. Allowing LIAB members to serve on CALMAC, even as non-voting members, could place them in the inconsistent role of becoming a party in Commission proceedings.
13. LIAB can best fulfill its independent advisory role if its Board members do not also serve on other committees or working groups that address low-income assistance issues.
14. No program design changes or modifications to measure eligibility have been recommended to the Commission as part of the Standardization Project (Phase 1) or in comments on that report.
15. There is insufficient time and resources to go beyond the Phase 1 Standardization Report and implement a compliance phase that would consider new proposals for measure eligibility in PY 2001. Delaying the final approval of eligible measures would also create an unacceptable delay for utilities that are in the process of issuing a Request For Proposals to select new PY 2001 program implementors. Moreover, evaluating proposals to add or delete measures prior to our consideration of the Working Group report would undermine (and prejudge) our efforts to standardize evaluation and reporting efforts for the LIEE program.
16. No further Commission action is necessary to extend the current programs through 2001 since that extension was authorized in D.00-07-020.
17. The Working Group report will be available in time for the Commission's consideration of the recommendations (and any nonconsensus positions) during the PY 2002 program planning cycle.
1. For the reasons discussed in this decision, LIAB's May 19, 2000 Recommendations On PY 2001 CARE and LIEE Programs should not be adopted.
2. The joint recommendations for standardizing installation standards and other procedures for the LIEE program, as presented in the Phase 1 Standardization Report, are reasonable and should be approved and the recommendations on cost-effectiveness should be accepted for further consideration by the Working Group, as discussed in this decision. Within 30 days of the effective date of this decision, the utilities should jointly file the new WIS manual in this proceeding which incorporates the follow-up recommendations submitted on July 5, 2000. The utilities should serve a notice of its availability to all appearances and the state service list in this proceeding. This new manual should be used by the utilities in designing their PY 2001 programs, and will be the standard used for all installations in the utility programs beginning January 1, 2001.
3. Within 60 days from the effective date of this decision, the utilities should file compliance applications that present the following:
(a) A joint proposal to standardize the calculation of CARE penetration rates, reflecting any consensus reached by the Reporting Requirements Manual Working Group.
(b) A description of current utility procedures (audits, process evaluations, polls, etc.) for monitoring program quality, cost-efficiency and customer satisfaction and recommendations for improving these procedures or instituting alternative ones, along with the associated costs and manpower requirements.
(c) Recommendations regarding stand-alone attic ventilation based on the results of the Attic Ventilation Pilot, and
(d) A description of how the utilities will be tracking the results of the Outreach Pilot so that those results can be evaluated during the PY 2002 program planning cycle.
4. As discussed in this decision, the utilities should prepare a standardized customer "bill of rights," which includes a description of the consumer complaint process. The utilities should include in their filing a description of how they will disseminate the "bill of rights" to customers. This effort should be coordinated with Phase 2 of the Standardization Project, where policies and procedures are to be standardized across utilities. The utilities should jointly develop this document with public input, and present them for approval no later than the filing of their PY 2002 program applications.
5. The utilities should also work toward the development of a form that requests the same types and categories of data from all customers enrolling in CARE. The utilities should jointly develop such forms with public input and present them in an Advice Letter filing by March 1, 2001.
6. The utilities and other members of the Standardization Project team should explore LIAB's Specific Program Recommendations 20, 21 and 28 during the ongoing development of standardized policies and program procedures. As discussed in this decision, if the utilities are in opposition to conforming qualification guidelines to the state and federal rules, they should describe in detail how they plan to coordinate with other programs so that the low-income customer receives as many of the weatherization measures as are feasible for each eligible low-income dwelling unit.
7. Phase 2 and 3 recommendations by the Standardization Project team should be completed in time for our consideration during the PY 2002 program planning cycle, or sooner if possible.
8. As discussed in this decision, LIAB should meet only when assigned specific tasks by the Commission, which currently are comprised of the following:
(a) filing comments on the proposal of the Reporting Requirements Manual Working Group to standardize the reporting requirements and administrative costs of the low-income assistance programs, and
(b) providing input to the utilities on utility proposals for producing standardized data on bill savings and expenditures for LIEE programs on an overall program and per unit basis, per D.00-07-020.
To address these two issues, LIAB and its advisory committee should be able to substantially reduce the number of scheduled meetings. Based on current assignments, LIAB and its advisory committee should reduce their scheduled meetings to those occurring in October, 2000 and January, 2001. If LIAB desires to meet more frequently or perform additional tasks with the assistance of Commission resources, it must seek and receive approval from the Energy Division. If approval is not given, LIAB shall rely on non-Commission resources to complete any additional tasks or conduct additional meetings other than those directed by today's decision or subsequent Commission order. Such additional tasks or meetings that LIAB elects to undertake must be directly related to the utility low-income assistance programs under our jurisdiction. LIAB should prepare and submit to the Energy Division written minutes of any additional meetings and written reports on any additional activities that are undertaken without the assistance of the Energy Division.
9. LIAB Board members (as individuals) should not serve on CALMAC or on other working groups or committees that address low-income assistance issues.
10. As discussed in this decision, Energy Division should submit recommendations for Board member nominations and LIAB operating budgets.
11. In order to proceed expeditiously with the compliance applications, this order should be effective today.
IT IS ORDERED that:
1. The joint recommendations for standardizing installation standards and other procedures for the LIEE program, as presented in the Phase 1 Standardization Report are reasonable and are approved and the recommendations on cost-effectiveness are accepted for further consideration by the Working Group, as discussed in this decision. Within 30 days of the effective date of this decision, Pacific Gas and Electric Company, San Diego Gas & Electric Company, Southern California Edison Company and Southern California Gas Company, collectively referred to as "the utilities," shall jointly file the new Weatherization Installation Standards (WIS) manual in this proceeding which incorporates the Phase 1 report recommendations and follow-up recommendations submitted on July 5, 2000. The utilities shall serve a notice of its availability to all appearances and the state service list in this proceeding. This new manual shall be used by the utilities in designing their program year (PY) 2001 programs, and shall be the standard used for all installations in the utility programs beginning January 1, 2001.
2. As discussed in Section 6 of this decision, the Low-Income Advisory Board (LIAB) and its advisory committee(s) shall be assisted by Energy Division and other Commission resources only to accomplish the specific tasks assigned to LIAB by the Commission. If LIAB desires to meet more frequently or perform additional tasks with the assistance of Commission resources, it must seek and receive approval from the Energy Division. If approval is not given, LIAB shall rely on non-Commission resources to complete any additional tasks or conduct additional meetings other than those directed by today's decision or subsequent Commission order. Such additional tasks or meetings that LIAB elects to undertake must be directly related to the utility low-income assistance programs under our jurisdiction. LIAB shall prepare and submit to the Energy Division written minutes of any additional meetings and written reports on any additional activities that are undertaken without the assistance of the Energy Division.
3. After LIAB completes its current assignments, LIAB should consider disbanding its advisory committee and convene workshops or working groups when LIAB receives further assignments from the Commission.
4. Within 60 days from the effective date of this decision, the utilities shall file compliance applications that present the following:
(a) A standardized method for calculating California Alternate Rates For Energy (CARE) penetration rates, presented jointly by the utilities and reflecting any consensus reached by the Reporting Requirements Manual Working Group.
(b) A description of current utility procedures (audits, process evaluations, polls, etc.) for monitoring program quality, cost-efficiency and customer satisfaction and recommendations for improving these procedures or instituting alternative ones, along with the associated costs and manpower requirements.
(c) Recommendations regarding stand-alone attic ventilation based on the results of the Attic Ventilation Pilot, and
(d) A description of how the utilities will be tracking the results of the Outreach Pilot so that those results can be evaluated during the PY2002 program planning cycle.
5. In coordination with Phase 2 of the Standardization Project, the utilities shall jointly develop a standardized customer "bill of rights" for low-income assistance programs, which includes a description of the consumer complaint process. The utilities shall describe how they will disseminate the "bill of rights" to customers. They shall develop this document with public input, and present them for approval no later than the filing of their PY 2002 program applications.
6. The utilities shall develop forms that request the same types and categories of data from all customers enrolling in CARE. The utilities shall jointly develop such forms with public input and file them in an Advice Letter filing by March 1, 2001.
7. As discussed in this decision, the utilities and other members of the Standardization Project team shall explore LIAB's Specific Program Recommendations 20, 21 and 28 during the ongoing development of standardized policies and program procedures. Phase 2 and 3 recommendations shall be completed in time for our consideration during the PY 2002 program planning cycle, or sooner if possible.
8. By September 1 of each year, the Energy Division shall solicit and submit nominations for LIAB membership and prepare and submit the LIAB's budget for the upcoming year. The Energy Division shall file its recommendations in the form of a report and serve all appearances and the state service list in this proceeding (or successor proceeding). Interested parties and the LIAB may file comments within 20 days thereafter.
9. All filings required by today's order shall be filed in the Commission's Docket Office and served on the appearances and state service list in this proceeding, or successor proceeding.
This order is effective today.
Dated September 7, 2000, at San Francisco, California.
LORETTA M. LYNCH
President
HENRY M. DUQUE
JOSIAH L. NEEPER
RICHARD A. BILAS
CARL W. WOOD
Commissioners
ATTACHMENT 1
************ APPEARANCES ************ |
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Ron Knecht |
Tim Tutt |
Evelyn Kahl Elsesser |
Karen Mills |
Michael Alcantar |
Ronald Liebert |
Glynnis Jones |
Neal A. Johnson |
Barbara R. Barkovich |
Kevin Smith |
William F. Parker |
Christopher S. Taylor |
Maurice Brubaker |
Joy Omania |
Richard Shaw |
Eileen A. Koch |
Michael Yamada |
Jon S. Silva |
Rita Norton |
Renee H. Guild |
Edward B. Lozowicki |
Lynn M. Haug |
Ray Czahar |
Dan Kirshner |
Mark J. Berman |
Beth Dunlop |
Norman J. Furuta |
Charles J Hahn |
Carolyn A. Baker |
Jan Smutny-Jones |
Robert E. Burt |
William H. Booth |
Carl Robert Aron |
Emilio E. Varanini, I I I |
James Hodges |
Marc Mihaly |
Norman A. Pedersen |
Sara Steck Myers |
Tim Krause |
Sheryl Carter |
Luis Arteaga |
Thomas J. O'Rourke |
Susan E. Brown |
A. Y. Ahmed |
Richard Sperberg |
Doug Grandy |
Robert B. Mclennan |
Don Wood |
Blueley I. Anderson |
Yole Whiting |
Dennis Dobkowski |
James F. Walsh |
Bryan Griess |
Roberto Haro |
Roxanne Figueroa |
Steven R. Schiller |
Robert Mowris |
Jeff Schlegel |