17. CAS Testing

As discussed in this decision, PG&E, SDG&E, and SoCal have different procedures and requirements for CAS testing under their LIEE programs. LIAB recommends that the Commission standardize this process among the utilities as part of their regular service, and not charge these tests to public purpose funds. In particular, LIAB recommends that PG&E's pre- and post-inspection process become the standard. Contractors' Coalition supports LIAB's position on non-LIEE funding for CAS testing.

SDG&E and SoCal argue against standardization of these procedures. SDG&E contends that its furnace operation inspection program, which is SDG&E's version of CAS testing, is a safe and effective program model that should be retained. (Exh. 44, pp. 9-10.) SoCal argues that the current LIEE program services do not tightly seal the house or otherwise alter the internal air flow within the house to create a carbon monoxide problem. In SoCal's view, PG&E's approach would unreasonably increase the cost and number of CAS tests for LIEE program participants, without a commensurate increase in safety. (Exh. 50, pp. 7-8.)

LIAB is participating in the standardization review process described in Section 11, which we expect will achieve greater consistency in the area of CAS testing procedures and requirements. We will await the recommendations from that process. However, we agree with LIAB and Contractors' Coalition that carbon monoxide testing should not be billed to the LIEE program (or any other public purpose) funds. By Res. E-3515 and D.98-06-063, we made this policy very clear.⁶⁰

SDG&E argues that its furnace operation testing, repair and replacement practices were approved in Res. E-3586 to be funded with LIEE program funds. That may be the case. However, the factual issue of whether or not SDG&E and SoCal are, in effect, proposing to fund carbon monoxide testing activities with LIEE funds (under the aegis of a different program name) is squarely before us in this proceeding. (See Exh. 1, p. 7.) If their current accounting practices result in carbon monoxide testing being funded under the LIEE program, those practices are contrary to our stated policies and should be discontinued.

SDG&E and SoCal are directed to clarify this issue by filing an advice letter within 20 days from the effective date of this order. The advice letter should clearly demonstrate whether or not carbon monoxide testing activities (under CAS or whatever other program name these activities fall under) are being funded in whole or in part with LIEE funds. If any such activities are being funded by LIEE program funds, a revised PY2000 budget removing those costs from program expenditure levels should be submitted with the advice letter. SDG&E and SoCal should recommend a reallocation of those costs to other LIEE budget categories, subject to our approval by resolution.