2. Background and Procedural History

Utilities currently implement two types of assistance to low-income residents: rate assistance and energy efficiency services. Under the CARE program, eligible low-income households and group living facilities receive up to a 15% rate discount for their electric and gas consumption. Under the LIEE program, direct assistance is provided to low-income customers in the form of energy efficiency education and the installation of energy efficient measures and appliances in the home.

By ruling dated March 26, 1999, the Assigned Commissioner described the program planning process for PY 2001 low-income assistance programs. The Assigned Commissioner directed LIAB, formerly the Low-Income Governing Board (LIGB), to initiate the process, as follows: ³

"Based on public input, LIGB would propose selective changes to policy rules guidelines on programs, budgets and program administrative issues that would apply to low-income assistance programs for PY2001 or longer. LIGB's proposal would be filed in this or a successor proceeding. Interested parties would have an opportunity to respond to LIGB's recommendations, and the Commission would issue a decision in this proceeding addressing any disputed issues. Utilities would follow with applications to implement these changes."⁴

By ruling dated December 29, 1999, the Assigned Commissioner further directed that the PY 2001 planning process include specific proposals for standardizing elements of the low-income assistance program, consistent with the direction Decision (D.) 99-03-056. Specifically, the Assigned Commissioner directed the utilities "to work jointly with any interested participants to develop a joint proposal for standardizing the selection criteria and installation manuals for the utilities' low-income weatherization programs."⁵ To that end, the utilities were expected "to conduct workshops and/or other forums to solicit input from interested participants prior to serving the joint proposal."⁶ On March 22, 2000, the Assigned Commissioner provided further guidance:

"Under this project, the utility policy and procedures manuals and weatherization installation standards manuals shall 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. A single state-wide utility program [Weatherization Installation Standards] manual shall be developed, along with as set of standardized policy and procedure manuals. These policy and procedure manuals shall differ only with respect to differences in climatic conditions, local building codes and ordinances. Where prior Commission rulings allow differences across utilities, I expect participants to consider ways of achieving reasonable consistency.

"The review of [Policy and Procedures] Manuals shall cover not only issues relating to installation standards, but also other policies and procedures that differ across programs. This would include spending caps, approaches to income qualifications, treatment of rental units, etc. I also expect the utilities to achieve greater consistency in the area of carbon monoxide testing through this review process, thus ensuring customer protection.

"In addition, the debate in [Application] 99-07-002 et al. convinces me that there is a need to improve consistency across utilities with regard to inspection policies and procedures for the low-income energy efficiency program. Standardization of inspection procedures should be undertaken as a second (or concurrent) phase of this project."⁷

LIAB filed its initial recommendations for PY 2001 low-income assistance programs on May 10, 2000 with a replacement filing containing Board-approved edits on May 19, 2000. Comments on LIAB's recommendations were filed on June 5, 2000 by SCE and jointly by SDG&E/SoCal. LIAB filed reply comments on June 12, 2000.

Also on May 10, 2000, Pacific Gas and Electric Company (PG&E), SDG&E, SCE and SoCal (collectively, "the utilities") jointly filed a Phase 1 Report on the Low-Income Weatherization Installation Manual Standardization Project ("Standardization Project").

By ruling dated May 24, 2000, the assigned Administrative Law Judge (ALJ) requested clarification from LIAB concerning its PY 2001 recommendations. She noted that there appeared to be considerable overlap between those recommendations and the issues being addressed through the Standardization Project. In addition, she noted that LIAB made recommendations on at least one issue that was being addressed in Application (A.) 99-07-002 et al. The assigned ALJ requested that LIAB clarify where there are still differences between LIAB and the utilities regarding standardization issues.

On June 9, 2000, LIAB filed comments on the Standardization Project joint report and responded to the ALJ's request for clarification. No parties filed a response.

On July 5, 2000, the utilities submitted Phase 1 follow-up recommendations for the Standardization Project which responded to comments received from interested parties during the Phase 1 proposal public review. The assigned ALJ issued a ruling on July 13, 2000 soliciting comments on those additional recommendations. The Office of Ratepayer Advocates (ORA) filed comments in support of the follow-up recommendations.