III. Budget Augmentation for SCE

Like SDG&E and SoCalGas, SCE does not seek a budget augmentation. In D.05-04-052, the Commission approved a budget of $27.4 million for SCE's 2005 LIEE program budget. SCE reports having spent approximately $22.6 million of those funds in 2005, leaving a carryover of approximately $4.8 million. In D.05-12-026, the Commission approved SCE's requested budget of $27.4 million for 2006. This, combined with the carryover of approximately $4.8 million, leaves SCE with a total of nearly $32.2 million for 2006. SCE asserts that this amount is more than sufficient to serve at least 5-10% more homes than it had originally expected for 2006. However, SCE also seeks an ongoing program modification, based on recent experience.

SCE requests authority to continue providing CARE enrollment and recertification over the telephone using SCE's Voice Response Unit. SCE used this process through the winter initiative to qualify customers simply and automatically for LIEE refrigerator replacement and compact fluorescent lights. SCE asks to continue this program and use it for all LIEE measures.

The Division of Ratepayer Advocates (DRA) filed a response to SCE's motion. DRA does not object to SCE's request for continuation of the two CARE enrollment and recertification policies. Nor does DRA object to continuation of the automatic eligibility of CARE customers for the two LIEE measures. However, DRA does not support automatic qualification of CARE customers for all measures because that would eliminate any verification that customers are income eligible, posing a risk that non-qualifying customers would receive unneeded subsidies. DRA recommends that SCE either continue its practice of seeking income documentation for LIEE services beyond the two services adopted in D.05-10-044 or apply a census-based targeted method for enrolling LIEE customers, similar to that adopted for SoCalGas and SDG&E.

SCE addresses this issue by noting that it would provide no LIEE services before it receives a signed CARE application. A provision of that application holds the customer at risk for erroneously claiming that it is eligible to receive CARE benefits. SCE states that extending the automatic qualification approach to include all eligible LIEE program measures satisfies the goal of increasing services to qualified customers by simplifying procedures while guarding against installing measures erroneously. Nonetheless, SCE states that it is amenable to DRA's suggestions, and that it can revisit the automatic qualification approach in its next program application, as appropriate. In this context, it appears that SCE is referring to the proposal to allow automatic qualification only for refrigerators and compact fluorescent lights.

We applaud SCE, as well as the other utilities, for their continuing efforts to make the CARE and LIEE programs more effective and efficient. We will allow SCE to continue both its telephonic CARE registration and recertification process, and its automatic qualification of CARE customers to receive refrigerators and compact fluorescent lights. The telephone-based CARE services should speed enrollment and cut costs because after the intake call, there is no need for further review or paperwork. The automatic enrollment procedure facilitates the dissemination of the most energy efficient measures to a greater number of customers. Although the goal is to maximize the availability of funds for qualified low income customers, a modest number of erroneous installations is tolerable if it allows for more rapid implementation and cuts administrative costs. If experience shows that the process results in a substantive number of erroneous installations, we will reconsider this strategy.

SCE's proposal to expand the automatic qualification approach to include all LIEE measures seems promising for at least several reasons. First, it is preferable to treat the whole house when measures are installed, rather than requiring a second visit to some homes at a later time. Second, if the error rate is low, then automatic qualification may make as much sense for other measures as it does for refrigerators and lights. However, reserving judgment on this proposal when we will review the new program applications that the utilities will file in July allows for more measured consideration. We will not approve the expansion now, but will review the proposal if SCE includes it in the next application for the 2007-2008 LIEE budget.