21. Response to Comments on ALJ's Proposed Decision

Pursuant to Pub. Util. Code § 311 and to our governing Rules of Practice and Procedure (California Code of Regulations, Title 20, Rules 77 to 77.5.), the proposed decision of ALJ Gottstein was issued before today's decision. California/Nevada Community Action Association, Contractors' Coalition, Latino Issues Forum/Greenlining Institute, LIAB, ORA, PG&E, RHA, SDG&E/SoCal, SCE, and Southern California Agencies filed timely comments to the proposed decision. Contractors' Coalition, ORA, Northern California Associations, PG&E, SoCal/SDG&E, SCE, RHA, and SESCO also filed timely reply comments.

We have carefully considered the comments on the issues addressed in today's decision. We have made certain clarifications and corrections, but do not make any significant substantive changes to the ALJ's proposed decision.

Findings of Fact

1. PG&E's request to move from a once-a-year CARE re-verification period for sub-metered tenants to a process that would allow for re-verification throughout the year would (1) allow for more consistent and less confusing year-round effort and (2) reduce chances for inaccurate billing for master-metered accounts.

2. SCE's request to revise the policy of limiting evaporative coolers to homeowners only would afford renters benefits from one of the few efficient alternatives to refrigerated air conditioning in 2000.

3. The vast majority of LIEE program implementation activities in PY2000 will be outsourced to other market entities.

4. Outsourcing the prime contractor function does not produce clear efficiency benefits, based on the record in this proceeding.

5. Differences in the manner in which administrative costs are accounted for and reported under the utilities' LIEE programs make it difficult to draw conclusions about the efficiency of alternative outsourcing approaches.

6. Quality control is not necessarily compromised if inspections are outsourced, rather than conducted in-house. However, authorizing or requiring the utilities to outsource both the prime contractor function and inspections could severely undermine the utility's ability to maintain quality control over the LIEE program.

7. Both approaches to the training function, i.e., outsourcing the function or training LIEE contractors at utility facilities by utility personnel, can provide effective, quality training. We have no information, however, on the relative cost efficiency of these two approaches.

8. Cost comparisons presented in this proceeding were limited in scope and comprehensiveness.

9. The average unit price for 1995 under SoCal's LIEE program was 17% lower than for 1994. SoCal's LIEE bid pilot gave SoCal price information for negotiating 1996 and 1997 contracts, and the 1996 and 1997 overall average unit cost remained 8% and 7% lower than 1994.

10. Allowing open bidding for PG&E's PY1998 Energy Partners Program reduced the average price per measure 11.7% between 1997 and 1998, even before accounting for inflation.

11. The record does not supply the cost to PG&E of administering the PY1998 bid, with which to compare the resulting reduction in average per measure costs.

12. If measures installed in the SDG&E program in 1997 had been priced at the prices that PG&E paid SESCO for the same measures in 1998, the cost of the SDG&E program would have been 15.89% less. That savings would have enabled the program to treat an additional 548 homes with the same mix of measures installed.

13. For the purpose of comparing the impact of competitive bidding on potential bill savings and program expenditures, the figures presented in Exh. 76 are essentially useless, because:

14. The exhibits presented in this proceeding show that per-home inspection pass rates in PG&E's program are consistently lower than those in SoCal's and SDG&E's programs. They also show that per-home inspection pass rates in PG&E's program dropped significantly between 1997 and 1998. However, the record also indicates the following:


a. PG&E automatically fails a house if a feasible measure is not installed, while SoCal and SCE allow the contractor to correct it without counting it as a fail. An estimated 25.4% of PG&E fails are due to this factor and it is a contributing factor in 45.2% of all fails.


b. SoCal/Edison allow contractors to correct door weatherstripping if it is out of adjustment or light shows around the sides or top. PG&E has failed this in 60% of the instances and provided a correction opportunity in the other 40%.


c. There are several categories for which other utilities either allow the contractor to correct or have the inspectors themselves correct without issuing a "fail," while PG&E provides an automatic fail in the same situation. This includes, for example, minor caulking, weatherstripping, and gasket mistakes.


d. SDG&E tries to inspect all units and, prior to January 1, 1999, if any is missed, it is counted as a "pass," while all other utilities ignore missed units in the pass rate calculations.


e. SDG&E's pass rate covers only "weatherization" measures and not compact florescent lights, porch lights, or refrigerators, which PG&E inspects and counts in its pass rates.

15. There is no factual support to SDG&E/SoCal's argument that the pass rates presented in the exhibits in this proceeding are unrepresentative of pass rates that would have been obtained if every home were inspected.

16. SDG&E/SoCal's method of extrapolating PG&E's pass rate statistics is based on unsupported assumptions and leads to nonsensical numerical results.

17. SDG&E/SoCal's March 16, 2000, comments were beyond the scope of the assigned ALJ's March 9, 2000, ruling.

18. Per-home pass rates do not provide information about the nature of the problem in the installation of measures or minor home repairs, and its impact on home energy savings.

19. Neither per-home or per-measure pass rates indicate to what extent the expected savings per home (based on the type and number of measures being installed correctly) is being achieved by the contractor.

20. SESCO began work as an installation subcontractor under PG&E's program at the end of September 1998, and for the last three months of that year had an overall average per-home pass rate of 66.2%. SESCO, in cooperation with PG&E, took steps during 1999 to increase this per-home pass rate and was successful in making improvements.

21. A number of installation subcontractors working under PG&E's program prior to the PY1998 competitive bid experienced per-home pass rates that were comparable or lower than SESCO's work.

22. PG&E's per-measure pass rates average above 95% both before and after the 1998 competitive bid.

23. Hazard fails being counted under PG&E's program are not being inspected for or reported as hazard fails under the other utilities' programs. In particular, beginning in 1998, PG&E includes as hazard fails infiltration measures that are installed prior to a CAS test, installed after a dwelling fails a CAS test or if a CAS inspection is not performed.

24. Hazard fails on a per-home basis under PG&E's program were 0.4% of homes inspected in 1997, before PG&E CAS testing requirement began, 1.1% from April through December 1998 when SESCO took over and CAS testing was introduced, and 1.7% in 1999. On a per-measure basis, hazard fails were maintained well below 1% throughout the 1997-1999 period, except during the 1997 roll-over period under RHA's program management, when they increased to approximately 2%.

25. For any hazard fail, PG&E, SDG&E, and SCE (all electric) contractors must either reinstall or correct any measures that failed because of a hazardous condition within 24 hours of being notified by the inspector. SoCal inspectors will mitigate hazardous conditions and require the contractor to make permanent corrections within three days.

26. In addition to doing weatherization work, CBOs can also offer job training and access other social services to meet the needs of low-income families. Some CBOs also have access to federal funding for low-income weatherization services (LIHEAP) that is administered by the state. One way to provide access to community-based programs is to directly involve CBOs in the LIEE programs as weatherization contractors. Another way that program participants can have access to the services provided by CBOs is through a referral system, where either program participants are directed to the local CBO, or that CBO is notified that a utility customer could benefit from other services and programs.

27. Since 1995, PG&E's LIEE program has experienced a precipitous drop in direct CBO participation, and as of the end of 1999 has the lowest level of CBO participation among the utilities. The trend of declining CBO participation began well before SESCO assumed the role of PG&E's prime contractor under the PY1998 competitive bid, and can be attributable to factors other than competitive bidding.

28. None of the utilities currently have referral systems that would identify the needs of participants of LIEE programs and direct them over to CBOs and other low-income agencies. Nor do the utilities generate information about the degree to which their contractors have worked with CBOs to leverage non-utility weatherization program funding.

29. Only PG&E satisfies the prerequisites that enables CSD to financially leverage federal funds and increase the total amount of federal dollars for California's LIHEAP program. In particular, only PG&E has an established written and verbal referral system between the CARE and LIHEAP programs.

30. Standardization in LIEE program delivery will ensure that all low-income customers are offered a consistent set of services across the state and that all contractors participating in the delivery of those services are working under consistent rules and expectations.

31. The utilities have not sought to develop consistency in RFP language or contract terms for competitively bid outsourcing.

32. Establishing quotas or set-asides for CBOs or other nonprofit organizations in LIEE competitive-bid RFPs presumes that those types of organizations have a clear superiority in meeting non-cost and cost criteria established for the bid.

33. There are no appreciable differences between participating CBOs and participating private contractors with respect to indicators of quality, comprehensiveness, customer satisfaction, or inspection pass rates.

34. To meet PG&E's 30% CBO participation minimum, PG&E would need to take work away from WMDVBE-certified contractors.

35. The language of PG&E's RFP presents the 30% participation minimum as more than a goal; it could be interpreted as a mandatory provision that can bring penalties upon the contractor for breach of contract.

36. SCE and SoCal's RFP restricts the pool of bidders for their energy education workshops to CBOs or other nonprofit organizations.

37. A requirement that bidders demonstrate a minimum number of years providing weatherization services to low-income communities in southern California would unduly limit the pool of potential bidders to those contractors currently (or in recent past) participating in the southern California LIEE programs. Similarly, excluding from consideration the bidder's experience in providing energy efficiency services in other geographic regions, or to non-low income program participants, would unreasonably limit the pool of potential bidders.

38. Considering non-cost issues in the bid evaluation process, such as the ability to provide services in a multitude of languages or demonstrate knowledge about the local low-income community and local codes and ordinances, is entirely consistent with the intent of AB 1393 and the Commission's goals for the LIEE program.

39. Utilities have been afforded the flexibility to develop their bid evaluation criteria for LIEE programs and contract terms with winning bidders in the past, and there is no evidence in this proceeding to support a change in policy at this time.

40. Presenting scoring and weighting information to bidders prior to receiving bids could better enable bidders to put together a responsive bid package, but could also encourage manipulation of the evaluation process by bidders.

41. LIEE contractors are currently paid based on the number and type of measures installed in each home, as verified by inspections. An approach that pays contractors based on measured savings in the home is an alternative that directly links payment with performance, and is worth exploring.

42. PG&E has long-standing policies with regard to the release of customer information to contractors, which have been approved by the Commission, and are consistent with current Commission policies with regard to energy efficiency programs. Releasing CARE and eligible customer lists to LIEE contractors is also consistent with our goal of improving coordination between the programs.

43. Based on PG&E's experience to date, releasing CARE lists to LIEE contractors does not reduce efforts by contractors to reach eligible customers or result in improper use of that information by contractors. PG&E has demonstrated that appropriate safeguards can be put in place to protect customer confidentiality.

44. Funding carbon monoxide testing with LIEE funds is inconsistent with the policies adopted in Res. E-3515 and D.98-06-063.

45. The issue of whether SESCO bid for, obtained and operated the LIEE program under applicable law is before the Contractors State License Board and the Attorney General's Office.

46. The Commission is currently considering LIAB's proposed PY2000 budget in R.98-07-037.

Conclusions of Law

1. Without evidence that outsourcing the prime contractor function increases program efficiencies, it is unreasonable to impose the PG&E/SDG&E model on the other utilities at this time.

2. It is reasonable for a utility to retain inspection functions for the LIEE program in-house if it is outsourcing the prime contractor function.

3. Utilities should outsource inspections if they do not outsource the prime contractor function, with the following exceptions. SoCal may continue its practice of retaining in-house both the prime contractor function and inspections of furnace repairs/replacements at this time. However, this issue should be revisited during the PY2002 program planning cycle, as discussed in this decision. In addition, we do not expect PG&E to outsource inspection functions during the interim period (e.g., six months) when LIEE administration is temporarily handled in-house. However, should PG&E elect to retain the prime contractor role in-house, and not outsource that function, PG&E should outsource inspections on an expedited basis.

4. As discussed in this decision, the utility's role in training should be revisited during the PY2002 planning cycle with information on the utilities' training costs and requirements.

5. LIEE program costs, including costs per-measure or -home, should be made available to parties in any future Commission proceeding where the cost-efficiency of these programs is being litigated, subject to Commission-approved confidentiality agreements. The Commission, its staff, or LIEE program consultants to the Commission (subject to confidentiality agreements) may obtain this information upon request at any time. This cost information should be presented in a format that allows the Commission and other parties to compare costs in a normalized fashion, e.g., normalized over the types and number or frequency of the measures installed in each home.

6. Based on the experience with competitive bidding for LIEE programs to date, it is reasonable to conclude that bidding can reduce unit costs appreciably, resulting in more homes being weatherized under the program. However, there is currently no data with which to compare these reductions in unit costs with the utility's cost of administering each bidding process. Nor do we have comparable data on savings-per-measure installed that would translate these unit cost reductions into measurable bill savings to the low-income customer, or to compare the bill savings per dollar of expenditure across utilities. Therefore, our ability to reach conclusions regarding the cost-efficiency of LIEE programs in general, or regarding competitive bidding specifically, is severely limited.

7. Consistent data on LIEE program bill savings, expenditures and cost-effectiveness calculations should be readily available to program evaluators, program implementors, and the general public.

8. PG&E's per-home inspection pass rates do not necessarily reflect a lower quality program or indicate that bidding in general reduces the quality of work. As discussed in this decision, per-home pass rates are not a reasonable indicator of relative performance quality because (1) they have been compiled based on differences in the definition of "fails" and inspection procedures and (2) they do not indicate the impact of a "fail" on energy savings in the home.

9. SESCO's pass rate performance as an installation subcontractor is not an indicator of competitive bidding per say, or limited to PG&E's recent bid experience. SESCO and PG&E recognized a problem with SESCO's performance as an installation subcontractor early on and took steps that improved pass rates.

10. It is unreasonable to conclude from the record that bidding will lead to an unacceptable number of life-threatening situations for low-income customers. Utilities should, however, achieve greater consistency in their inspection and response procedures to protect all LIEE program participants from potentially hazardous situations in the home.

11. The plain meaning of Pub. Util. Code § 381.5 requires this Commission, in evaluating the effectiveness of LIEE programs, to examine the degree to which participants in LIEE programs have access to the programs and services that CBOs make available in their communities.

12. The precipitous decline in CBO participation in PG&E's program has adversely affected PG&E's program with respect to the type of access intended by Pub. Util. Code § 381.5.

13. The utilities should work with CSD to ensure that they meet the prerequisites for maximizing financial leveraging for low-income assistance programs, and report on their progress.

14. Based on the information available at this time, it is reasonable to continue to afford utilities the flexibility to choose how they will outsource LIEE program functions, i.e., via competitive bidding, contract renegotiations, or a combination of both, subject to the policy guidance in this decision. This issue should be revisited during the PY2002 program planning cycle.

15. Movement towards uniform, statewide LIEE program designs and implementation should proceed pursuant to D.99-03-056 and subsequent Assigned Commissioner's rulings regarding the standardization project. Utilities that outsource via competitive bidding should obtain additional public input and coordinate with each other, with the objective of developing consistency in their competitive bid practices for PY2002, including contract language.

16. Competitive bidding for the outsourcing of LIEE programs should not establish quotas or set-asides for any particular type of organizational entity.

17. The utilities should be permitted to establish goals for CBO participation, against which programs will be monitored over time, but no adverse consequences should accrue to the bidder if that goal is not achieved. PG&E or any other utility who chooses to articulate a goal for CBO participation in the RFP should include language to clarify that the goal requires good faith efforts by the contractor, but is not a mandatory provision that can bring upon the contractor penalties for breach of contract.

18. The utilities should not include in their RFPs a requirement that bidders demonstrate a minimum number of years providing weatherization services to low-income communities in a specific geographic location, such as the utility's service territory. The utilities should consider in their bid evaluation process the bidder's experience in providing energy efficiency services outside of the utility's service territory, or to non-low income program participants.

19. In order to ensure that work is spread around among a number of subcontractors, it is reasonable for a utility to limit the number of homes assigned to any one subcontractor.

20. At this time, it is reasonable for utilities to retain flexibility in developing their cost and non-cost bid evaluation criteria for the LIEE program, and in determining the relative weights of these criteria, as long as they are consistent with the program goals articulated by this Commission and the Legislature. Similarly, it is reasonable to continue the practice of allowing utilities flexibility in negotiating final contract terms with LIEE contractors. Should we determine that the costs or non-cost performance of the programs are out of line with these goals, it may be appropriate to take a more hands-on approach to the competitive outsourcing process in the future. As described in this decision, the cost and non-cost aspects of the LIEE programs should be monitored closely.

21. Utilities should provide the scoring and weighting applied to the LIEE bid evaluation to bidders, upon request, after the bid selection process has been completed.

22. Utilities should negotiate final contract terms with all LIEE contractors in good faith. No contract provision or utility action should restrict a contractor from discussing in a public forum (e.g., workshop, hearing, LIAB meeting) any aspect of the LIEE program that is non-proprietary and non-confidential. The utilities should clearly state in their RFPs that proposed changes to their sample contracts will not be considered in the bid evaluation process, up to the selection of a short-list of highest ranking bidders.

23. LIEE programs should be expected to achieve measurable bill savings to low-income customers. To this end, paying LIEE contractors on the basis of savings achieved for low-income households may be an improvement over the current practice of paying contractors based solely on the number and type of measures installed in each home. This approach should be explored on a pilot basis, as described in today's decision.

24. Utilities should provide LIEE contractors with lists of eligible (including CARE) customers, subject to confidentiality agreements. This information should be provided to the contractor, at cost, provided that: (1) the contractor has documented its need for such records based on the specifics of its program implementation or marketing plan and (2) appropriate security arrangements have been made that will protect the confidentiality of these records. The utilities shall negotiate with contractors the specific procedures for (1) releasing customer records (without prior customer consent), (2) contacting the customer with program information, and (3) ensuring confidentiality of customer-specific information. Utility customer information received through this process may be used only for PGC-funded programs and purposes. The use of utility customer information for purposes other than PGC-funded programs and purposes may result in penalties. Including, but not limited to revocation of contractor's or subcontractor's ability to participate in PGC-funded efforts.

25. As described in this decision, SDG&E and SoCal should clarify whether or not carbon monoxide testing activities (under CAS or any other program name) are being funded in whole or in part with LIEE funds, and should remove these costs from the LIEE program budgets immediately.

26. The Commission does not have jurisdiction over contractor licensing issues.

27. Consistent with the provisions of Pub. Util. Code § 327(b)(5), all bidders and LIEE contractors in general should be in good standing with the CSLB. As discussed in this decision, the utilities should file a report that demonstrates compliance with California's licensing requirements.

FINAL ORDER

IT IS ORDERED that:

1. Pacific Gas and Electric Company (PG&E), San Diego Gas & Electric Company (SDG&E), Southern California Edison Company (SCE) and Southern California Gas Company (SoCal), collectively referred to as "the utilities," shall outsource their low-income energy efficiency (LIEE) program functions during Program Year (PY) 2000 and PY2001, and prepare for the PY2002 planning cycle as follows:

2. The utilities shall implement and evaluate a pay-for-measured savings pilot for their PY2002 LIEE programs, as described below:

a. The pilot size shall be limited to no more than 10% of the utility's program in terms of the number of units treated.

b. The pilot may be conducted in conjunction with a competitive bid or may be proposed in conjunction with a different outsourcing approach. As one approach to the pilot design, the utility may estimate the savings per home it expects to achieve under the program, and allow contractors the opportunity to bid (or negotiate) a price for which they would get paid on the basis of savings achieved. Other requirements may be added in the pilot design, as appropriate.

c. The utility and contractor shall agree on measurement protocols that are consistent with those we have already adopted in the Annual Earnings Assessment Proceeding (AEAP), or with modifications thereto that we approve for the purpose of this pilot. Any proposals to modify the AEAP measurement protocols for this pilot shall be discussed in the public workshops described below prior to submission to the Commission. Proposed modifications that have been discussed in the public workshops may be presented in the utility pilot program applications and parties' responses to those applications.

3. The utilities shall file applications describing their proposed pay-for-measured savings pilots no later than February 1, 2001, and serve them on the appearances and state service list in this proceeding and R.98-07-037 or successor proceeding. Between now and then, the utilities, in coordination with the Energy Division, shall jointly hold public workshops to discuss pilot design. In particular, the utilities shall obtain input from those contractors and utilities in other states that have implemented a pay-for-measured savings approach. The utility proposals shall include a schedule for pilot program evaluation, and the evaluation criteria to be used. They shall also include the estimated cost of each pilot, including measurement and evaluation necessary to pay contractors. In their applications, the utilities shall describe how the proposed pilot design considers the issues raised by LIAB in this proceeding. The utilities shall coordinate closely with each other in developing the pilots, so that the pilot designs and evaluation approaches are standardized. At their option, the utilities may file a joint application rather than separate applications in submitting their proposals.

4. The utilities shall provide LIEE contractors with lists of eligible (including the California Alternate Rates for Energy (CARE)) customers, subject to confidentiality agreements. This information shall be provided to the contractor, at cost, provided that: (1) the contractor has documented its need for such records based on the specifics of its program implementation or marketing plan and (2) appropriate security arrangements have been made that will protect the confidentiality of these records. The utilities shall negotiate with contractors the specific procedures for (1) releasing customer records (without prior customer consent), (2) contacting the customer with program information, and (3) ensuring confidentiality of customer-specific information. Utility customer information received through this process may be used only for LIEE programs and purposes. The use of utility customer information for purposes other than LIEE programs and purposes may result in penalties, including, but not limited to revocation of contractor's or subcontractor's ability to participate in LIEE programs.

5. Within 20 days from the effective date of this order, SDG&E and SoCal shall file an advice letter that clarifies whether or carbon monoxide testing activities (under a combustion appliance safety (CAS) program or another program name) 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 shall be submitted with the Advice Letter. SDG&E and SoCal shall recommend a reallocation of those costs to other LIEE budget categories, subject to our approval by Resolution.

6. PG&E, SCE, SDG&E and SoCal shall individually or jointly submit a report that demonstrates the good standing of all of their current LIEE contractors and subcontractors with California State Licensing Board's licensing requirements at the time the contractor or subcontractor (1) submitted a bid (if applicable) to win the initial or current contract with the utility or prime contractor, or (2) commenced work under a negotiated contract that was not subject to competitive bidding.

The utility's report shall clearly describe what those licensing requirements are and certify that they have been met by including copies of licenses or other documentation. The reports are due no later than 120 days from the effective date of this decision, and shall be filed at the Commission's Docket Office in R.98-07-037. Copies of the reports shall be served on the state service list and appearances in R.98-07-037 (or any successor proceeding) and in this proceeding.

7. With input from interested parties and the LIAB, the utilities shall jointly develop standardized methods for producing data on bill savings and expenditures for LIEE programs on an overall program and per unit basis, by utility. The methods used to produce this information shall be consistent with the methodologies used to evaluate energy efficiency costs and savings in the AEAP. The utilities shall coordinate with Energy Division on all aspects of methodology design and implementation.

The utilities shall file a joint report no later than February 1, 2001, presenting the proposed standardized methods and explain how the methods are consistent with cost-effectiveness methods and calculations utilized in the AEAP. In this report, the utilities shall apply the proposed methods to calculate bill savings and expenditures for their PY1997, PY1998, and PY1999 LIEE programs, or explain why a study of a particular program year would be duplicative of what has already been done in the AEAP. In that event, the results of the AEAP study shall be presented. All assumptions and workpapers shall be presented. To the extent that data has been compiled for PY2000 programs, the report shall provide bill savings and expenditure calculations for that PY (or portion thereof) as well.

The joint report shall be filed and served on appearances and the state service list in this proceeding and in R.98-07-037, or any successor proceeding. Comments on the report are due 30 days thereafter. Responses to the comments will be due within 15 days.

8. As part of the PY2002 program planning process, PG&E shall prepare estimates of the one-time administrative costs associated with the competitive bidding process, based on its experience. Other utilities may present information on this issue as well in their PY2002 LIEE program applications. In addition, PG&E, SDG&E, SoCal, and SCE shall provide the information prepared by SDG&E and PG&E in Exhibits (Exhs.) 35 and 36, which was used to compile comparison Exh. 66 in this proceeding, so that this comparison can be duplicated across utilities for their PY1998--PY2001 annual program results. This information shall be provided by the utilities in their PY2002 LIEE program applications, together with all relevant workpapers.

9. In their PY2002 applications, the utilities shall propose alternatives to the per-home pass rate as an indicator of relative performance quality, as discussed in this decision.

10. As discussed in this decision, the utilities shall report on the access of their low-income program participants to programs provided by community service providers, consistent with the intent of the Legislature. (Pub. Util. Code § 385.1(a).) The report shall indicate the number of CBOs participating in the program as contractors or subcontractors, as well as the percentage of units treated by CBOs. Comparable information on non-CBO participants shall be presented as well. The report shall describe the utility's referral system between the CARE and Low-Income Home Energy Assistance Program, and whether or not that utility has met the requirements for the state to qualify for financial leveraging of federal funds. In addition, the report shall describe the systems in place to identify the needs of participants in low-income energy efficiency programs and direct them over to the CBOs and other low-income community agencies. An initial report with this information shall be filed no later then October 1, 2000, with an update report due by April 1, 2001 in R.98-07-037 or any successor proceeding. The report shall be served on the appearances and state service list in this proceeding and in R.98-07-037. Comments on the report are due 30 days thereafter, and replies are due within 15 days.

11. The utilities proposed PY2000 program plans and funding levels for low-income assistance programs, as presented in Attachment 4, are reasonable and shall be adopted. However, the amounts contained in Attachment 4 for LIAB PY2000 activities are placeholders only, pending the Commission's final determinations in R.98-07-037. In addition, within 60 days from the effective date of this order, the utilities shall file advice letters requesting a budget augmentation sufficient to cover the cost of the new studies and reports specified in this decision. The budget augmentation request shall include a breakout of the cost of each study or report. The Advice Letter shall be served on all appearances and the State Service list in this proceeding.

12. Consistent with Decision 99-03-056, the programs and funding levels adopted today shall continue through December 31, 2001, unless and until subsequent program and budget changes are approved by the Commission.

This order is effective today.

Dated July 6, 2000, at San Francisco, California.

See CPUC Formal Files For Attachments 1, 3, and 4.

ATTACHMENT 2

Acronyms and Abbreviations

(Two Pages)

NAMES

ACRONYMS AND ABBREVIATIONS

Administrative Law Judge

ALJ

Annual Earnings Assessment Proceeding

AEAP

Assembly Bill

AB

Bay Area Poverty Resource Council, Community Resource Project, Inc., Proteus, Inc., California/Nevada Community Action Association, and the Northern California Indian Development Council, Inc.

Northern California Associations

California Alternate Rates for Energy

CARE

California Board For Energy Efficiency

CBEE

California State Licensing Board

CSLB

combustion appliance safety

CAS

community-based organization

CBO

Decision

D.

demand-side management

DSM

Department of Community Services and Development

CSD

direct assistance program

DAP

East Los Angeles Community Union, Maravilla Foundation and the Association of Southern California Energy and Environmental Programs

Southern California Agencies

Exhibit

Exh.

Independent Program Administrator

Administrator

Investigation

I.

Low-Income Advisory Board

LIAB

low-income energy efficiency

LIEE

Low-Income Home Energy Assistance Program

LIHEAP

Megawatt

MW

Office of Ratepayer Advocates

ORA

Pacific Gas and Electric Company

PG&E

petition to set aside submissions, suspend the current filing dates, and reopen the proceeding for the taking of further evidence

Petition

NAMES

ACRONYMS AND ABBREVIATIONS

Program Year

PY

public goods charge

PGC

requests for proposal

RFP

Resolution

Res.

Richard Heath and Associates

RHA

Rulemaking

R.

San Diego Gas & Electric Company

SDG&E

Senate Bill

SB

SESCO Inc.

SESCO

Southern California Edison Company

SCE

Southern California Gas Company

SoCal

Women, Minority, or Disabled Veteran Business Enterprises

WMDVBE

(END OF ATTACHMENT 2)

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