11. Standardization

As discussed above, we do not elect to standardize the method of outsourcing at this time, but other aspects of standardization have also been suggested in this proceeding. Contractors' Coalition proposes several changes to the utilities' proposed RFP and contract terms that would standardize them across the utilities. Contractors' Coalition also proposes that certain policies and procedures for the utility programs be standardized along the lines of CSD's current practices. LIAB recommends that income verification procedures be standardized, as well as CARE application forms in 2000, when the income guidelines are updated. Latino Issues Forum recommends that the utilities work toward standardization of programs and goals, training procedures, weatherization services, CARE penetration goals, reporting, and complaint resolution processes. ORA recommends that there be standardization among the utilities for the contract term. In addition, ORA believes that the RFP process should be more standardized as the LIEE programs become more standardized.

In D.99-03-056, we directed the utilities to continue movement "toward uniform, statewide program designs and implementation."⁵⁴ We see no reason to retreat from this objective, as some parties suggest in this proceeding. We believe that all low-income customers should be offered a consistent set of services across the state and that contractors participating in the delivery of those services should be working under consistent rules and expectations.

A significant step towards this standardization is in progress. The utilities have met with LIAB and its Advisory Committee, staff, the CSD, and other interested parties to discuss the standardization project mandated by the December 29, 1999, Assigned Commissioner's ruling in R.98-07-037. Under this project, in coordination with the Energy Division, the policy and procedures manuals and weatherization installation standards manuals will be reviewed and standardized statewide. These manuals contain rules on how and when measures are to be installed in low income homes, detailed measure descriptions, material standards, measure installation instructions, and other implementation procedures.

By ruling dated March 22, 2000, in R.98-07-037, the Assigned Commissioner further clarified that the standardization project will cover not only issues relating to installation standards, but also other policies and procedures that differ across programs. These include spending caps, approaches to income qualifications, treatment of rental units, etc. Pursuant to the Assigned Commissioner's ruling we expect the utilities to achieve greater consistency in the area of CAS testing through this review process.

Per the March 22 adopted schedule, recommendations and proposed revisions to the manuals and policies and procedures will be presented to the Commission, after obtaining public input, in early May 2000. We expect this document to serve as the basis for further standardization of program policies and procedures in PY2001. We believe it would be unproductive to address proposals to standardize these same procedures in this forum, in a piecemeal fashion.

In addition, there is need to improve consistency across utilities with regard to inspection policies and procedures for the LIEE program, as evidenced by the information presented in Exh. 73. Per the March 22, 2000, ruling, standardization of inspection procedures will be undertaken as a second (or concurrent) phase of the standardization project already underway. Energy Division will coordinate this effort, in consultation with the Assigned Commissioner's office. We expect that second phase to produce recommendations for the PY2002 planning cycle, or sooner if possible.

It is also apparent from the testimony in this proceeding that the utilities have not sought to develop consistency in RFP language or contract terms for competitively bid outsourcing. Since we do not mandate competitive bidding at this time, we will not instruct the utilities to standardize their competitive bidding procedures. However, we believe that this issue should be revisited during the PY2002 program planning cycle. Between now and then, the utilities that outsource via competitive bidding should obtain additional public input and coordinate with each other, with the objective of developing more consistency in their competitive bid practices for PY2002, including contract language. As part of their PY2002 applications, the utilities should jointly file a report on these efforts.