BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF ...€¦ · LIMS-314-4180 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Application of Southern California

LIMS-314-4180

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U338-E) for Approval of its 2012-2014 California Alternate Rates for Energy (CARE) and Energy Savings Assistance Programs and Budgets.

A.11-05-017

(Filed May 16, 2011)

And Related Matters.

A.11-05-018 A.11-05-019 A.11-05-020

SOUTHERN CALIFORNIA EDISON COMPANY'S (U338-E) OPENING COMMENTS TO THE PROPOSED DECISION ON LARGE INVESTOR-OWNED UTILITIES’ 2012-2014 ENERGY SAVINGS ASSISTANCE (ESA) (FORMERLY REFERRED TO AS LOW

INCOME ENERGY EFFICIENCY OR LIEE) AND CALIFORNIA ALTERNATE RATES FOR ENERGY (CARE) APPLICATIONS

JANET COMBS MONICA GHATTAS

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-3623 Facsimile: (626) 302-1910 E-mail: [email protected]

Dated: May 24, 2012

SOUTHERN CALIFORNIA EDISON COMPANY'S (U338-E) OPENING COMMENTS TO THE PROPOSED DECISION ON LARGE IOUS’ 2012-2014 ESA AND CARE

APPLICATIONS

TABLE OF CONTENTS

Section Page

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I. INTRODUCTION ....................................................................................................................................1

II. CARE ......................................................................................................................................................2

A. Recovery of Unanticipated CARE Expenses Should be Subject to an Ex Post Reasonableness Review and IOUs Should Submit an Implementation Advice Letter .............................................................................................3

B. Income Verification Per Customer Should Be Limited to Every 24 Months .................................................................................................................................4

C. Verification Data Sharing Between IOUs Will Save Customer and IOU Resources .....................................................................................................................4

D. $18 Verification Fee Payment Should be Limited to Successful Verifications .........................................................................................................................4

III. ENERGY SAVINGS ASSISTANCE ....................................................................................................5

A. The PD Directives Impede Implementation of the Strategic Plan’s IDSM Strategy .....................................................................................................................5

1. In Home Energy Education is Essential For Promotion of IDSM........................................................................................................................5

2. The Energy Education Study Should be Funded at $300,000 and Include a Broader Scope ...................................................................6

B. Working Groups...................................................................................................................7

1. Establishing a Separate ESA Integration Working Group Segregates ESA from IDSM Activities and Planning Within the IDSM Taskforce .....................................................................................7

2. All IOUs Should Have Representation on the Cost Effectiveness Working Group ..................................................................................8

3. The Energy Division or IOUs Should Manage the WE&T and Mid-Cycle Working Groups .............................................................................8

C. Evaluations and Studies .......................................................................................................8

1. The Impact Evaluation Timeframe Directed in the PD is Unrealistic ................................................................................................................8

SOUTHERN CALIFORNIA EDISON COMPANY'S (U338-E) OPENING COMMENTS TO THE PROPOSED DECISION ON LARGE IOUS’ 2012-2014 ESA AND CARE

APPLICATIONS

TABLE OF CONTENTS (CONTINUED)

Section Page

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2. The CPUC has not Identified a Viable Timeline or Funding Source for the Multifamily Segment Study .............................................................9

D. The PD Miscalculates SCE’s ESA Budget ........................................................................10

E. The CPUC’s Multifamily Goals Can be Achieved Without Looking to the Faulty 43% Estimate in the KEMA Needs Assessment as a Starting Point ..........................................................................................10

F. The CFL Cap Should not be Reinstated ............................................................................10

G. SCE Requests Increased Funding for the Central Air Conditioner Service Measure .................................................................................................................11

H. SCE Supports Leveraging and Coordination with California Department of Community Services and Development (CSD) .........................................11

IV. COOL CENTERS ................................................................................................................................12

A. SCE Should Operate the 2012 Program With an Increased Budget as Planned and Transition to the PD’s Approach in 2013-2014 ........................................12

B. The CPUC Should Allow the IOUs to Work with Energy Division on Cool Center Reporting ..................................................................................................13

V. SCE REQUESTS EXPLICIT APPROVAL FOR THE FOLLOWING ACTIVITIES..................................................................................................................................13

VI. THE CHANGES PILOT EVALUATION SHOULD INCLUDE IOU INPUT ..................................14

VII. PD FUNDING AND BRIDGE FUNDING .......................................................................................14

VIII. CONCLUSION .................................................................................................................................15

ATTACHMENT A ....................................................................................................................................16

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE

STATE OF CALIFORNIA

Application of Southern California Edison Company (U338E) for Approval of its 2012-2014 California Alternate Rates for Energy (CARE) and Energy Savings Assistance Programs and Budgets.

A.11-05-017

(Filed May 16, 2011)

And Related Matters.

A.11-05-018 A.11-05-019 A.11-05-020

SOUTHERN CALIFORNIA EDISON COMPANY'S (U338-E) OPENING COMMENTS TO THE PROPOSED DECISION ON LARGE INVESTOR-OWNED UTILITIES’ 2012-2014 ENERGY SAVINGS ASSISTANCE (ESA) (FORMERLY REFERRED TO AS LOW

INCOME ENERGY EFFICIENCY OR LIEE) AND CALIFORNIA ALTERNATE RATES FOR ENERGY (CARE) APPLICATIONS

Pursuant to Rule 14.3 of the California Public Utilities Commission’s (CPUC) Rules of

Practice and Procedure, Southern California Edison Company (SCE) comments on the May 4,

2012 proposed decision of Administrative Law Judge (ALJ) Kim, “Decision on Large Investor-

Owned Utilities’ 2012-2014 Energy Savings Assistance (ESA) (Formerly Referred to as Low

Income Energy Efficiency or LIEE) and California Alternate Rates for Energy (CARE)

Applications” (the PD).

I. INTRODUCTION

SCE appreciates the efforts of ALJ Kim in drafting the PD, which addresses many of the

complex issues presented in the record in this proceeding. The PD is the fruition of an

unprecedented level of interest by stakeholders in these vital programs. While SCE appreciates

the difficulty involved in developing policy for the next three years, SCE finds the PD includes

limited errors and omissions that should be corrected or clarified. Therefore, SCE suggests that

the PD be revised to:

Provide for IOUs to submit an Advice Letter within 90 days detailing the scope and

budget of efforts that will be taken to implement that PD’s CARE verification

mandates.

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Limit Income Verification to every 24 months and provide for IOU verification data

sharing.

Limit the verification fee payment to successful verifications, similar to enrollments.

Permit in Home Energy Education to all income eligible homes and allow the IOUs to

broadly study the effects of this education on customers’ behavior.

Adjust PD working group mandates to 1) integrate ESA into the IDSM Taskforce; 2)

allow all IOUs to have representation in the cost effectiveness working group; and 3)

provide that the Energy Division or IOUs should manage the WE&T and Mid-Cycle

Working Groups.

Modify PD directives regarding impact evaluation and multifamily segmentation

study to provide sufficient time and funding. Also, not use the faulty KEMA Needs

Assessment as a starting point for multifamily goals.

Correct an error in the ESA budget calculation in the PD and provide for an

additional $700,000 for the Central Air Conditioner Service measure.

Permit the IOUs to continue leveraging with CSD by providing appliances to CSD

free of charge.

Permit the SCE Cool Centers to fulfill existing contracts with community based

organizations for 2012, then refine the program for the remainder of the program

cycle.

Provide for IOU input into the Changes pilot evaluation.

Explicitly state that the CARE, Cool Center, and ESA authorized budgets are for

three years of funding inclusive of the bridge period, with a minor adjustment for

SCE Cool Centers.

With these changes, which are further discussed below, the 2012-2014 SCE ESA, CARE,

and Cool Center programs will be implemented in a manner that provides resource benefits to

the State of California and vital assistance to customers in need.1

II. CARE

The PD represents a bold departure from self-certification for CARE which has been in

place since the program’s origin. As noted in SCE’s testimony, SCE recognizes the value of the

current self-certification enrollment process in removing as many barriers to enrollment as

1 Pursuant to Rule 14.3(b) of the CPUC Rules of Practice and Procedure, SCE submits in Attachment A its

proposed revisions to the Findings of Fact, Conclusions of Law, and Ordering Paragraphs.

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possible for customers who need assistance.2 The policy change in the PD toward increased

income verification will require practices and procedures that had not been anticipated by SCE

when filing its Application. SCE appreciates the PD’s efforts to acknowledge these issues and

addresses them, and other requests for clarification, in more detail below.

A. Recovery Of Unanticipated CARE Expenses Should Be Subject To An Ex Post Reasonableness Review And IOUs Should Submit An Implementation Advice Letter

The PD notes the IOUs, may need to seek authorization to augment their budgets to

reflect the increased Post Enrollment Verification ordered in the PD.3 In D.02-09-021, the

CPUC provided balancing account treatment for CARE administrative costs stating, “the

authorized budget is not, by definition, binding under balancing account treatment. Therefore,

cost recovery of actual expenditures is often subject to an ex post (after the fact) review of

reasonableness as well.”4 SCE anticipates significant IT enhancements5 and other operational

expenditures for implementing all aspects of the PD may result in increased expenses for

activities not included in the Application. Also, increased eligible customers may be dropped

from CARE for not responding to verification requests. Unanticipated customer communication

may be required in order to return these dropped eligible customers back to the rate. In order to

protect SCE from ex post reasonableness risk for the new, major activities and expenditures

required to implement the CARE directives in the PD, SCE requests that the CPUC reaffirm its

statements made in D.02-09-021 and permit SCE to file an Advice Letter within 90 days of the

effective date of the decision, requesting a reasonableness determination on the activities and

budgets SCE will implement to achieve the directives in the decision.

2 EXHIBIT #2, Testimony of Southern California Edison in Support of Its Application for Approval of Its California Alternate Rates for Energy (CARE), Energy Savings Assistance and Cooling Center Programs and Budgets for

2012-2014 (dated and served 05/16/2011), p. 103. 3 PD, p. 180. 4 D.02-09-021, p. 8. The Commission reiterated this policy for recording and recovery of CARE related expenses

in CPUC Resolution CSID-004, dated November 19, 2010, Footnote 8 and Ordering Paragraph (O.P.) #5. 5 The PD approves SCE’s 2012-2014 IT budget request of $2.9 million. (PD, p. 180). The PD does not,

however, take into consideration the impact of the policy shift toward income verification on program policies, procedures and reporting. The sheer volume of verifications to be processed requires SCE to examine alternatives to the current process, all the while maintaining confidentiality of customer information. SCE needs time to examine these options and provide cost estimates once the final Decision is issued. Possible recommendations include the use of 1) fax/imaging capabilities for customer submittal of verification documents; 2) use of Tablet PCs by verification agencies to scan and submit income documentation; 3) other necessary system changes to implement changes to SCE’s current verification and recertification processes. SCE plans to submit its detailed implementation plan in the requested Advice Letter to be filed 90 days after the effective date of this decision.

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B. Income Verification Per Customer Should Be Limited To Every 24 Months

The PD directs all Investor Owned Utilities (IOUs) to increase post enrollment

verifications of CARE customers to 25% of enrolled customers per year.6 The PD also requires

the IOUs to: (1) request verifications within three months from all new categorically enrolled

CARE customers; (2) income verify all customers at recertification; and (3) verify all CARE

customers that exceed 400% of baseline. As a result of these policy changes, SCE anticipates

that income verification for CARE may exceed 50% of enrolled customers each year. Moreover,

these mandates may result in customers being verified under the different criteria more

frequently than necessary or desired. Currently, when SCE has successfully verified a

customer’s income eligibility, that customer is exempt from a subsequent verification of income

for 24 months. SCE requests that the PD be modified to continue this practice. Requiring

customers to verify their income on a more frequent basis is not an efficient use of SCE or

customer resources. SCE proposes that once a customer is selected for and passes verification,

regardless of the reason for verification, that customer will be excluded from a verification

request for a 24 month period. SCE also requests that the PD be clarified to include Family

Electric Rate Assistance (FERA) customers in the new income verification requirements.

C. Verification Data Sharing Between IOUs Will Save Customer And IOU Resources

SCE requests that the PD permit IOUs in shared territories to data share customer

program verification information.7 This will ensure that customers are not burdened by

demonstrating program eligibility for each IOU in the same year. Allowing this type of data

sharing also will significantly reduce operational and processing costs incurred by the IOUs in

order to implement the PD verification directives.

D. $18 Verification Fee Payment Should be Limited To Successful Verifications

The PD approves PG&E’s request to allow CARE capitation8 contractors to aid in the

post enrollment verification process for an “up to $18.00” per capita fee, and directs all other

IOUs to institute similar outreach programs. Additionally, the IOUs are directed to develop and

6 PD, p. 179. 7 SCE currently data shares information regarding enrollment and recertification with other utilities. With the shift from self-

certification during the recertification process to income verification, the IOUs will need to revise some forms to implement the new policies. SCE proposes that the income verification forms include language indicating that if customers are unable to successfully verify income eligibility, they may be removed from income-qualified rate discounts provided by other utilities.

8 The PD fails to adopt SCE’s proposal to replace the Capitation name with a new name: “CARE Community Enrollment Program.”

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field a uniform quality control audit protocol for CARE/post enrollment verification capitation

contractors.9 SCE recognizes the value in using capitation contractors to assist CARE customers

in completing the required CARE program verifications, in light of the significant increase in

program verifications that are required by the PD. SCE did not anticipate or budget for these

fees in its Application and projects these expenses could result in significant additional program

dollars beyond SCE’s funding request. Thus, SCE recommends that the PD be clarified to limit

payment of the new capitation contractors post enrollment verification fee to successful program

verifications only,10 because paying for all verification attempts creates an unintended, counter-

productive yet powerful incentive for wasteful excess, the costs of which would be borne by all

customers.

III. ENERGY SAVINGS ASSISTANCE

The PD continues progress toward providing all eligible customers the opportunity to

participate in the ESA program by 2020 as directed in the California Energy Efficiency Strategic

Plan (Strategic Plan). The PD includes critical missteps that will undermine the efficient

provision of services and achievement of integrated demand-side management goals as set forth

in the Strategic Plan.

A. The PD Directives Impede Implementation Of The Strategic Plan’s IDSM Strategy

1. In Home Energy Education Is Essential For Promotion of IDSM

The Strategic Plan directs IOUs to coordinate and communicate between ESA, energy

efficiency and DSM programs to achieve service offerings that are seamless for the customer.11

In-Home Energy Education (Energy Education) is the platform for delivering this

communication to customers in their homes. Only through Energy Education do customers

receive critical appliance safety information, information on the way to read a utility bill,

greenhouse gas emissions, water conservation, and CFL disposal and recycling through the ESA

program. SCE in testimony stated its plans to integrate new Edison SmartConnect-enabled

solutions (i.e., Budget Assistant and Save Power Day Incentive Program) into its ESA program

materials.12 Restricting Energy Education to homes receiving specific measures, and further

9 PD, p. 180. 10 This is consistent with the current capitation agency CARE enrollment fee that is only paid for applications that

result in new CARE enrollments. 11 California Energy Efficiency Strategic Plan, January 2011 Update, p. 27. 12 SCE’s Advanced Metering Infrastructure (AMI) project, also known as Edison SmartConnect, will result in the installation

of approximately 5 million “smart” meters in households and businesses with a demand of less than 200 kW. Budget Continued on the next page

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restricting the content to those measures13 strands low income customers from receiving critical

information to inform their energy use. Energy Education enables IDSM awareness and

adoption of expanded practices that improve financial literacy and help customers manage their

energy usage and bills. While customers may or may not receive specific measures, their homes

consume energy, water, and resources through various end uses, and a comprehensive Energy

Education program provides tools for conserving these resources.

PG&E, NRDC, Energy Efficiency Council, TELACU, and TURN agreed throughout this

proceeding that Energy Education should be provided within all income eligible homes.14 The

Low Income Oversight Board, at its September 26, 2011 meeting, passed a motion requesting the

CPUC approve a change in the Policy and Procedure Manual to allow Energy Education to be

delivered without the three measure minimum rule being met. SCE, though appreciative of the

PD’s effort to clarify direction provided in D.08-11-031,15 maintains denial of Energy Education

as called for in the PD should not stand. This PD would continue a CPUC practice of

highlighting IDSM, while erecting barriers that deny the very tools necessary to ensure

customers are fully aware of all opportunities to access complete IDSM services. SCE requests

the PD be modified to direct that Energy Education be provided to all customers while a trained

ESA assessor is in the home, regardless of whether the CPUC classifies such a home as

“treated”.

2. The Energy Education Study Should be Funded at $300,000 And Include A Broader Scope

While the PD identifies that the IOUs are authorized to spend $600,000 on the Energy

Education Study,16 the budget tables allocate $300,000 for this study. The PD also provides that

“[w]hile the final scope and details of the study must be finalized during the design phase, at a

minimum we direct that the evaluation should test whether the current energy education (or a Continued from the previous page

Assistant is an Edison SmartConnect-enabled program that provides customers with proactive notifications (voice, email, or text messages) regarding how their current costs are aligning with a preselected monthly budget target. The Save Power Day Incentive Program, formerly known as the Peak Time Rebate Program, is an Edison SmartConnect-enabled program designed to encourage residential customers to reduce load during Save Power Day events by providing a bill credit for kWh reduced below the participant’s baseline. SCE will enroll customers into these services after they have received education related to their content.

13 PD, p. 202: “All energy education provided should be “tailored” to cover the measures installed (e.g. proper use of evaporative coolers, information about measure-specific demand side programs, etc.).”

14 PG&E, NRDC, Energy Efficiency Council, TELACU - PD, p. 201. See Also EXHIBIT #21-A, Reply Testimony of Cynthia Mitchell Addressing the Opening Testimonies of Other Intervenors (dated and served 12/09/2011), p. 8: “TURN believes that opportunities to educate income-eligible households or to distribute CFLs will continue to go to waste under the three-measure minimum rule.”

15 PD, p. 202. 16 $600,000 is referenced in the PD on pp. 12, 200, 201, Conclusions of Law (C.O.L.) #126, and O.P. #98.

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modified version) results in actual energy savings.”17 The IOUs requested the study to

understand and improve energy education to “identify ways to optimize and/or improve the

educational component of the ESA program and examine the current and potential value of this

energy education.”18 Research findings from multiple studies19 in the prior program cycle

suggested that there may be knowledge gaps within our low income customer base that the IOUs

can better address via education. As noted in the PD, “TELACU makes an excellent point that

some low income customers may not understand the concept of demand response and that could

prove to be a notable barrier to the integration effort....”20 The “value” of education extends

beyond energy savings to also include mitigating safety hazards, understanding program

benefits, raising awareness of other demand side management programs. The results of this

study can assist programs and contractors in understanding and communicating with customers

on issues that are relevant to their needs and knowledge gaps. Therefore, SCE requests the PD

be clarified to include the study’s cost and reflect broader objectives beyond energy savings.

B. Working Groups

1. Establishing A Separate ESA Integration Working Group Segregates ESA from IDSM Activities And Planning Within The IDSM Taskforce

The PD calls for a separate ESA Integration Working Group because of concerns as to

whether the IDSM Taskforce adequately takes into account the ESA program’s concerns. The

PD indicates the ESA Integration Working Group should coordinate with the IDSM Taskforce to

maintain directional alignment with the IDSM Taskforce.21 SCE suggests this conclusion has

been drawn partly because the ESA program has never been integrated into the existing IDSM

taskforce. There would be no need to ensure alignment if all interests were represented on the

IDSM taskforce. A segregated working group for ESA will continue to leave ESA outside the

IDSM mainstream. Full commitment to IDSM would indicate the CPUC instead should direct

full participation by IOU ESA representatives in the IDSM task force.

17 PD, p. 201. 18 EXHIBIT #2, Testimony of Southern California Edison in Support of Its Application for Approval of Its California Alternate Rates for Energy (CARE), Energy Savings Assistance and Cooling Center Programs and Budgets for

2012-2014 (dated and served 05/16/2011), Attachment A-9, p. A9-7. 19 “Impact Evaluation of the 2009 California Low Income Energy Efficiency Program” conducted by EcoNorthwest for the

CPUC (Final Report issued June, 2011); “California Low Income Energy Efficiency Program 2009-2010 Process Evaluation” conducted by Research Into Action for the CPUC (Final Report issued June, 2011), “Low Income Energy Efficiency Program Segmentation Study” conducted by Hiner and Partners for SCE & PG&E (SCE Final report issued December 2011) High Usage Needs Assessment” conducted by Hiner and Partners for SCE (Final Report issued September 2011).

20 PD, p. 34. 21 PD, p. 35 and C.O.L. #38.

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2. All IOUs Should Have Representation On The Cost Effectiveness Working Group

The PD states the Cost Effectiveness Working Group should consist of no more than two

representatives from each segment of the parties. The PD can be interpreted as indicating only

two IOU representatives would serve on this working group. The IOUs have extensive

knowledge of the various cost effectiveness tests and how they are performed for ESA, energy

efficiency, and other programs. SCE requests the PD be clarified to state that all IOUs should

have representation on this working group.

3. The Energy Division Or IOUs Should Manage The WE&T And Mid-Cycle Working Groups

While NRDC has been a valued contributor to the development and advanced state of

energy efficiency in California, the CPUC lacks statutory authority to compel NRDC to solicit

and put together working groups as directed in the PD.22 Energy Division or the IOUs should

manage these working groups and each IOU should have representation on both working groups.

SCE expects NRDC may choose to participate in some of the working groups. Additionally,

SCE has not requested funding, nor has the PD identified funding for working group activities.

SCE can absorb these costs, only if working group activities are carefully managed.

C. Evaluations And Studies

1. The Impact Evaluation Timeframe Directed In The PD Is Unrealistic

The Impact Evaluation can provide a sound basis to examine the ESA program’s cost

effectiveness and modify the program offerings based on the results of this evaluation. SCE

supports the PD’s approval of an Impact Evaluation for the 2012-14 ESA program and

recognizes the limitations caused by the 2009 Impact Evaluation’s delayed results. The August

31, 2013, deadline imposed in Ordering Paragraph 100 to ensure timely results, however, fails to

accommodate methodological requirements and relevant components of research execution to

yield optimal and robust results. Specifically, the PD approves the IOUs’ Impact Evaluation

proposal, as described in SCE’s testimony in Appendix A, Attachment A-9.23 Attachment A-9

describes research steps and recommended strategies to optimize the study and foster high

quality, accurate and reliable savings estimates, including an aggressive estimated schedule

beginning with the awarded contract. The proposed schedule does not include pre-contract

22 PD, pp. 238 - 239, and O.P. #5. 23 PD, p. 214.

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award activities and was based on an assumed final decision by January 2012. For these

reasons, it is not possible to meet the deadlines noted in the PD.24 While the IOUs understand

the importance of obtaining results in time to inform program planning, from an execution,

methodological, and analytical standpoint the proposed time-frame will compromise the research

quality and subsequent findings. SCE anticipates based on its prior experience with Impact

Evaluations and an expected decision date of June 2012, that reliable and valid results are

unlikely to be available prior to April 2014. SCE requests the PD be modified to reflect this

realistic date.

2. The CPUC Has Not Identified A Viable Timeline Or Funding Source For The Multifamily Segment Study

SCE commends the PD for the direction to facilitate better and more successful

penetration of the multifamily segment. As part of this PD, the IOUs are asked to “set aside a

reasonable estimated amount of their measurement and evaluation budget for a Multifamily

Segment Study.”25 Unlike in the energy efficiency proceeding where the measurement and

evaluation budget reflects roughly 4% of the overall program budget and the money is only

partially allocated to specified studies, this PD pre-identifies studies and budgets for these

identified studies are fully allocated. As such, no funds in the measurement and evaluation

budget are available for this new multifamily study. Given the proposed scope set forth in the

PD,26 SCE anticipates a budget of $400,000 will be reasonable for a contractor to execute this

study. SCE further recommends that the proponent contractor capitalize on existing data sources

such as RASS, American Community Survey, and similar data sources to investigate relevant

market characteristics of the multifamily segment.

SCE further recognizes the need to execute such an effort in a timely manner; however

the proposed timeline as outlined in Ordering Paragraphs 71 through 77 does not align with the

time required to execute a project of this scope. The time frame underestimates realistic timing

of some components (e.g., project planning, scheduling and stakeholder vetting, contractual and

legal processes, research execution, analyses and reporting) and does not accommodate other

relevant components of the process (e.g., writing of proposals, review of proposals, etc.).

Therefore, SCE respectfully requests, given the potential value of this effort, that the time frame

be re-defined to accommodate a more realistic process and ensure the research is conducted with

24 PD, pp. 214-215 and O.P. #100. 25 PD, O.P. #70. 26 PD, O.P. #76.

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a level of attention and quality that will yield useful results and direction in understanding and

serving the needs of this population. SCE recommends a minimum of 5 months27 beyond the

expected February 2013 draft report deadline to produce a draft report.

D. The PD Miscalculates SCE’s ESA Budget

Appendix C indicates SCE miscalculated its three-year ESA proposed budget request at

$185.217 million and recalculates the budget at $171.203 million. SCE points out that SCE’s

budget category “General Administration” was inadvertently omitted in Appendix C of the PD.

The PD then arrived at an authorized budget by escalating its inaccurate representation of SCE’s

requested budget to account for an increase in the number of homes treated over SCE’s original

projection in Appendix G. Therefore, using the methodology in Appendix G, SCE’s authorized

2012-2014 ESA budget should be $220.716 million. SCE requests the CPUC correct SCE’s

budget or reduce SCE’s homes treated goal for 2012-2014 to reflect the $204.0 million budget

authorized in Ordering Paragraph 1.28

E. The CPUC’s Multifamily Goals Can Be Achieved Without Looking To The Faulty 43% Estimate In The KEMA Needs Assessment As A Starting Point

The PD looks to the faulty KEMA estimate that 43% of all low income households reside

in multifamily dwelling types. An erroneous starting point creates initial bias in determining

how best to serve multifamily households. The IOUs provided Census based information to

dispel this estimate in Workshop #4. DRA agrees with the IOUs’ position that the 43% estimate

is incorrect.29 The Census based estimates indicate approximately 28.5% of SCE’s low income

households reside in multifamily dwelling types and SCE’s 2012-2014 multifamily homes

treated goal for multifamily dwellings equals the 28.5% estimate. SCE will strive to serve these

customers through the immediate, long-term and comprehensive multifamily segment strategies

that have been identified by the PD.

F. The CFL Cap Should Not Be Reinstated

Conclusions of Law 70 denies the Energy Efficiency Council’s recommendation to lift

the cap of five CFLs per household. The CFL cap was lifted in 2010 when language related to

27 The proposed extension includes public workshop, writing and issuing RFP, proposal writing, reviews of proposals and

contractor selection, issuance of contract, research plan development and vetting, conduct research and analyses, draft report, etc.

28 SCE tracked a higher unwilling and unable factor for customers than the 5% adopted in the PD and further notes the eligible population will be reduced slightly to account for the CPUC’s intent going forward to adhere to 200% of Federal Poverty Guidelines in setting ESA and CARE eligibility.

29 DRA Opening Brief, pp. 20-21.

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the cap was removed in the LIEE Policy and Procedures Manual Sections 2.9 and 7.3.14.

Therefore, there is no statewide cap in place. SCE does not agree a cap should be reinstated.

G. SCE Requests Increased Funding For The Central Air Conditioner Service Measure

As directed by the PD, SCE will retain its Central Air Conditioner Service that offers

ongoing HVAC maintenance to customers who previously received a replacement central air

conditioner/heat-pump through SCE’s ESA program.30 SCE did not provide funding for this

measure in its Application. SCE anticipates that implementing this directive in the PD will result

in $700,000 in increased cost. SCE requests that if this directive in the PD is not altered in the

final decision, the CPUC provide SCE with a $700,000 budget allocation for the Central Air

Conditioner Service Measure.31

H. SCE Supports Leveraging and Coordination With California Department Of Community Services And Development (CSD)

SCE agrees that IOUs should continue to seek coordination and leveraging efforts with

CSD. The PD directs IOUs to focus their leveraging effort with CSD in refining data sharing

activities. Currently IOU data sharing is restricted to the CARE program where CSD provides

client information for debiting their account as part of a CSD bill payment assistance program.

As the PD correctly points out, until a compatible data base system is employed by CSD, data

sharing will be very difficult.32 Currently all IOUs employ compatible data sharing software and

SCE is working with SoCalGas on several enhancements specific to data sharing. A compatible

CSD database could take advantage of this software development and provide the ability to track

ESA/CSD treated homes and measures.

In the interim, SCE will continue to offer ESA appliances to LIHEAP contractors for

installation in ESA eligible homes. With ESA paying for appliance cost and CSD paying

installation cost this is a win-win situation. Additionally, SCE could provide data base access to

LIHEAP contractors to track the treating of LIHEAP homes and measures installed. Given the

benefit of free appliances, CSD should cover LIHEAP contractor costs for input and

administrative duties.

30 PD, p. 93. 31 The PD on page 93, 94 and O.P 55 addresses this issue suggesting that the IOUs file Advice Letters if necessary

“seeking to modify their Central Air Conditioner service offering and budgets or propose new program designs in accordance with the findings of their Final Report and in response to stakeholders’ feedback.” SCE questions the propriety of requesting additional funding in an Advice Letter, and suggests that this would violate customer notice requirements. Therefore, SCE is requesting the funding be added in this decision.

32 PD, p. 44.

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IV.COOL CENTERS

A. SCE Should Operate the 2012 Program With An Increased Budget As Planned And Transition To The PD’s Approach In 2013-2014

As indicated in the PD, SCE has funded its Cool Center program very differently than the

other IOUs.33 The other IOUs leverage existing partnerships with local government entities,

while SCE works primarily with community-based organizations and faith-based organizations

to provide similar services.34 The PD drastically reduces SCE’s 2012-2014 Cool Center

operating budget from a requested $2.3M to the proposed $0.3 million primarily based on a 2009

Cool Center Program evaluation that described instances where cooling centers were found to be

costly to operate, overstaffed, under attended, and lacking actual outreach efforts, concluding

that the utilization of third parties to operate cooling centers increases expenses without

increasing benefits.35 The PD fails to note, however, that SCE implemented several

improvements to its 2010 and 2011 Cool Center program in response to the evaluation which

resulted in significantly increased participation in the program,36 including:

Improved program oversight: SCE performs announced and unannounced visits to Cool Centers and provides feedback based on these visits to improve program performance. SCE also simplified the Cool Center contracts to ease monthly reporting and payment.

More effective training: SCE standardized training criteria so Cool Center staff can better communicate SCE program information to visitors. SCE developed new Customer Resource Guides to increase customer awareness and participation to SCE programs.

Increased Marketing: SCE requires all Cool Centers to promote their Cool Centers within their community through newspapers, radio, television, websites, and newsletters as feasible. To support this effort, SCE provided new customer and event flyers, as well as media press releases that could be personalized. SCE also provided six-foot banners that clearly identify the locations as SCE Cool Centers visible from the street.

Limited staffing levels: SCE limited Cool Center staffing to one-full time coordinator and one part-time support person.

Terminated sub-contracting: SCE eliminated sub-contracting by Cool Centers of program operations to improve SCE program oversight.

Pursuant to CPUC authorized bridge funding of $396,000 for January through June 2012,37

SCE has prepared to operate a 2012 Cool Center program at a funding level consistent with

33 PD, p. 169. 34 PD, p. 170. 35 PD, p. 170. 36 These enhancements resulted in 35,632 visitors to the Cool Center program in 2010, and 45, 174 visitors in 2011. 37 D.11-11-010, O.P. #6. This amount is greater than the $315,250 approved in the PD for the entire 2012-2014 period.

-13-

2009-2011, with the program starting on June 1, 2012. Accordingly, SCE has signed contracts

with 20 community and faith based organizations for the 2012 Cool Center program and

pursuant to these contracts several community and faith based organizations have already

incurred start-up expenses. Therefore, SCE requests that the CPUC fund the 2012 Cool Center

program based on the $768,000 proposed in the application, and fund the 2013 and 2014

programs at the levels indicated in the PD $105,000 for each year. This will allow SCE

sufficient time to modify its program consistent with the Cool Center programs of the other

IOUs. It will also allow SCE to comply with its 2012 contracts with its 20 Cool Centers. If

SCE’s request is denied, SCE will immediately terminate all existing contracts with Cool Centers

in 2012 and determine if sufficient funding remains to offer a program in 2013 and 2014.

B. The CPUC Should Allow The IOUs To Work With Energy Division On Cool Center Reporting

The PD directs the IOUs to, “report on November 15 of each year, 30-days after cooling

center activity concludes on October 15, tracking information by cooling center activity facility

including attendance, low-income program enrollments, and itemized expenses,” in addition to

other new reporting requirements.38 The PD also directs the IOUs to consult with Energy

Division on the format for all reports ordered in the PD.39 SCE requests the PD be modified to

allow the Energy Division-led process to determine the level and scope of required reporting.

SCE also requests the due date for this new reporting be extended by a little over one month

from November 15 to December 21 of each year, and direct this information be reported in the

monthly Low-Income Assistance Programs report. The added month will allow Cool Centers to

close-out their final operating reports, and allow SCE sufficient time to consolidate input.

V. SCE REQUESTS EXPLICIT APPROVAL FOR THE FOLLOWING ACTIVITIES

The PD states to the extent this decision does not explicitly approve certain aspects of the

IOUs’ ESA and CARE Applications, they are not approved.40 SCE requests specific

clarification, and / or approval for the following:

38 PD, p. 170. 39 PD, O.P. #124. 40 PD, p. 254.

-14-

Approve leveraging resources through installation of gas measures on Santa Catalina Island for customers receiving gas service as proposed by SCE.

Approve SCE’s provision of appliances at no cost to LIHEAP providers.

Approve expiration of $6.90 per CFL cap adopted in D.08-11-031 that is no longer feasible in 2012 – 2014.

Explicit approval to use CARE administrative funds for CPUC approved phone center enrollment.41

Approve SCE’s proposed copays of $500 per unit for central HVAC and Heat Pumps.

VI. THE CHANGES PILOT EVALUATION SHOULD INCLUDE IOU INPUT

The PD indicates that the evaluation of the CHANGES pilot program will be completed

consistent with the current Energy Division’s pilot evaluation procedures and cannot exceed a

total of $80,000 collectively from the IOUs’ CARE program Measurement and Evaluation

budget. SCE requests that the evaluation, include input from the IOUs’ staff that regularly

collaborate with the Energy Division to facilitate rigorous and optimal CARE/ESA evaluations.

Moreover, SCE recognizes the benefit of this collaboration as a means to garner the IOUs’

perspective on direct benefit to CARE customers in the form of new CARE enrollments, as well

as other CHANGES program elements.

VII. PD FUNDING AND BRIDGE FUNDING

The CPUC adopted D.11-11-010 authorizing the IOUs to expend an amount not to

exceed 50% of their respective 2011 budget level, from January 1, 2012 through June 30, 2012

to continue their ESA, CARE, and Cool Center programs until the CPUC adopts a final decision

on the IOUs’ ESA, CARE, and Cool Center budget applications for 2012-2014. SCE requests

the PD explicitly include the following points:

The CARE, Cool Centers, and ESA authorized budgets are for three years of funding inclusive of the bridge period.

Bridge funding authorization for January – June 2012 is replaced by funding authorized

in the PD for CARE, ESA, and Cool Centers with funding adjustments to accommodate drastic

changes in Cool Center program design as discussed in Chapter III. Homes treated, measures

installed, and other performance metrics achieved through ESA in January – June 2012 count

toward the goals and objectives in the PD for 2012 specifically, and 2012 – 2014.

41 D.12-03-054, O.P. #2.i.: “The utilities shall ensure that their customer service representatives (CSRs) offer customers the

option of enrollment in the California Alternate Rates for Energy rate program by telephone discussion with a CSR.

-15-

VIII. CONCLUSION

SCE appreciates the opportunity to comment on this proposed decision.

Respectfully submitted, JANET COMBS MONICA GHATTAS

/s/ MonicaGhattas By: Monica Ghattas

Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 Telephone: (626) 302-3623 Facsimile: (626) 302-1910 E-mail: [email protected]

May 24, 2012

Attachment A

SCE RECOMMENDED CHANGES TO PROPOSED DECISION

A-1

Body of Proposed Decision:

Page 108, 2nd Paragraph. As proposed by SCE, providing CFLs, but no other measures for

homes that fail the modified 3MM Rule, we would simply be touching these homes on the

surface and increasing program costs (effectively lowering the overall programmatic cost-

effectiveness) while simultaneously permitting a household be counted as “treated” even if these

measures deliver little in bill savings. If we are to truly approach the ESA Program as an energy

resource program, we cannot myopically focus on the number of homes treated, while ignoring

bill and energy savings.

Page 129, First Paragraph. The 2007 KEMA Low Income Needs Assessment Report and its

findings, state that 43% of all low income households reside in multifamily dwelling type (with 5

or more units). While some parties dispute the assumptions, scope, methodology and therefore

resulting accuracy of some of the findings, we will look to that estimate as a basic starting point

to begin the discussion, until that figure is updated.

Page 202, Last Paragraph. In the meantime, the IOUs are restricted to provide energy education

only to income-verified customers who have passed the modified 3MM Rule. IOUs are to

provide energy education to all income –verified customers. Moreover, as SCE’s interpretation

of pages 203-204 in D.08-11-031 conflicts with the Statewide Policy and Procedure Manual

(Section 4.4) on when education can be provided, we will make the following clarifications:

At this time, households that receive energy education and no other measures are not to

be defined as a “treated” home.

All energy education provided should be “tailored” to cover the measures installed (e.g.

proper use of evaporative coolers, information about measure-specific demand side

programs, etc.)

Without quantifiable energy savings, energy education cannot (at this time) be considered a

standalone measure.

SCE RECOMMENDED CHANGES TO PROPOSED DECISION (Continued)

A-2

Findings of Fact:

23. The current general IDSM Taskforce efforts, being undertaken in the general energy

efficiency docket pursuant to D.09-09-047, are more broadly focused. [Delete in its entirety]

130. The IOUs’ shared energy education evaluation study will be invaluable in understanding

and communicating with customers on issues that are relevant to their needs and knowledge gaps

and determining whether there are the energy savings associated with ESA Program energy

education and whether this justifies energy education be considered a cost-effective, standalone

measure.

131. Without quantifiable energy savings figures, energy education should not be considered a

standalone measure, at this time. [Delete in its entirety]


A-3

Conclusions of Law:

26. All of the IOUs should institute outreach programs, similar to that proposed by PG&E, to

allow CARE capitation contractors to aid in the Post Enrollment Verification process for an up to

$18.00 per capita fee per successfully completed verification is reasonable.

38. The ESA Integration Working Group should coordinate with the IDSM Taskforce to

maintain directional alignment with the IDSM Taskforce. [Delete in its entirety]

70. The modified 3MM Rule, as modified in D.08-11-031 and clarified in D.09-06-026, should

not be further modified and we should deny: (a) SCE’s proposal to install CFLs at the time a

home is assessed without being required to meet the modified 3MM Rule, (b) SCE’s proposal to

count a home as “treated” with the receipt of only CFLs and energy education, (c) DRA’s

proposal to replace the modified 3MM Rule with a 4% Threshold Approach, (d) EEC’s

recommendation of instituting the policy to install CFLs during the enrollment and education

process as well as lifting the cap of 5 CFLs per household, and (ef) TELACU’s proposal to

eliminate the rule and allow all income eligible customers to receive energy education and CFLs

regardless of the modified 3MM Rule requirement.

92. To better understand the costs and benefits of these efforts and to achieve the goal of actually

providing relief from heat and high energy bills to California residents during extreme heat

conditions while ensuring ratepayer funds are appropriately managed, the IOUs should report on

November 15th December 21st of each year, 30-days after cooling center activity concludes on

October 15, tracking information by cooling center facility including, attendance, low income

program enrollments, and itemized expenses in the monthly Low-Income Assistance Programs

report, cooling center activity as directed by Energy Division.

93. The IOUs reports on cooling centers should also describe the energy education and

marketing materials provided at each cooling center facility. [Delete in its entirety]

97. The IOUs’ proposed cooling center budgets should be reduced from the proposed levels and

should reflect exclusions based on D.05-04-052, although SCE may implement its proposal in

2012 and transition to the new program design in 2013.


A-4

126. The IOUs’ request for a $600,000 $300,000 shared energy education evaluation study is

reasonable and should be approved.

127. In the meantime, the IOUs should be restricted to provide energy education only to income-

verified customers who have passed the modified 3MM Rule. [Delete in its entirety]

145. In the upcoming 2012-2014 program cycle, the IOUs should test the IOUs’ public meetings

as a forum to host the working groups we authorize and order in this decision, including (a) ESA

Integration Working Group; (b) Cost-Effectiveness (CE) Working Group; (c) (b) WE&T

Working Group; and (d) (c) Mid-Cycle Working Group, and other(s) as Energy Division

determines necessary and appropriate for this program cycle.

Add New Conclusion of Law. The IOUs shall not income verify customers more than once every

24-months.

Add New Conclusion of Law. The IDSM Taskforce should include full participation by ESA

program personnel.

Add New Conclusion of Law. CFLs continue to provide low income customers the opportunity

for significant energy savings in a relatively cost effective manner because they are relatively

inexpensive, and we can still capture energy savings by switching low income customers from

high energy use incandescent bulbs to CFLs.

Add New Conclusion of Law. Energy Education should be provided to all income verified

homes regardless of whether the home is treated.


A-5

Ordering Paragraphs:

1. [Replace SCE budget figures to account for PD budget miscalculation and $40,000 per year

for SCE's 30% share of the multi-family segment study and $233,000, in 2012, 233,000 in 2013,

and 234,000 in 2014 for air-conditioner maintenance. The correct figures for the table are:

$74,230,445 in 2012, $73,506,954 in 2013, $73,842,855 in2014, and $221,536,308 in Cycle

Total.]

4. Within 60 days after this decision is issued, the Energy Division or IOUs and the Natural

Resources Defense Council shall form Energy Savings Assistance Program Integration Working

Group, Energy Savings Assistance Program Workforce, Education and Training Working Group,

and Mid-Cycle Working Group to review those components of the Commission’s Energy

Savings Assistance Program and California Alternate Rates for Energy Programs to make

recommendations for refinements to improve, wherever possible, the design, administration,

delivery and ultimate success of these programs.

5. Effective immediately, the Quarterly Public Meetings held by Pacific Gas and Electric

Company, Southern California Edison Company, Southern California Gas Company and San

Diego Gas & Electric Company shall be modified as follows:

a. These utilities shall be relieved of the Quarterly Public Meetings ordered in

Decision 06-12-038.

b. These utilities shall convene a minimum of one public meeting per year, within 60

days of their filing of the annual report, and other public meetings as deemed

necessary by either the utilities, the Energy Division, the ALJ, or the Commission.

c. In the upcoming 2012-2014 program cycle, these utilities shall use these meetings

as a forum to host the working groups concept generally proposed by Natural

Resources Defenses Council (NRDC) and approved here, as modified and set forth

below:


A-6

(i) Within 60 days after this decision is issued, Energy Division or the IOUs and

NRDC are charged with the task of soliciting and putting together the following

working groups;

(ii) Energy Savings Assistance Program Integration Working Group, as outlined

and discussed in section 3.1.4 of this decision;

(ii)(iii) Cost-Effectiveness (CE) Working Group, as outlined and discussed in 3.5.4

of this decision;

(iii)(iv) Workforce Education and Training (WE&T) Working Group, as outlined

and discussed in sections 3.11.5.4 and 3.11.5.5 of this decision; and

(iv)(v) Mid-Cycle Working Group, and other(s) as Energy Division determines

necessary and appropriate for this program cycle.

d. These utilities shall host, notice, facilitate and provide support for public working

group meetings, as needed and requested by each of the working group during 2012-

2013 program years.

6. By December 31, 2012, Energy Savings Assistance Program Integration Working Group and

Mid-Cycle Working Group shall submit to the ALJ their Progress Reports Report of findings and

recommendation(s), if any, and if no agreed upon recommendation(s) is/are reached by then,

those working groups the working group shall submit a progress report nonetheless of its

activities since inception and a detailed description of the status of its efforts in each of the

subject areas it is charged to review in this decision with justification showing good cause for

any additional and estimated time it may require.

7. By March 31, 2013, Energy Savings Assistance Program Integration Working Group and Mid-

Cycle Working Group shall submit their Final Reports the Final Report and Recommendations.

15. The terms of Energy Savings Assistance Program Integration Working Group and term of

Mid-Cycle Working Group shall expire on March 31, 2013, unless further extended by the ALJ

in writing for good cause.


A-7

70. We approve $400,000 for a Multifamily Segment Study ordered in this decision, with costs

to be shared by Pacific Gas and Electric Company, Southern California Edison Company, San

Diego Gas & Electric Company, and Southern California Gas Company shall set aside a

reasonable estimated amount of their measurement and evaluation budget for a Multifamily

Segment Study ordered in this decision.

72. Within 60 75 days after this decision is issued, with the public and stakeholders’ input, the

Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas &

Electric Company, and Southern California Gas Company and Energy Division shall develop

and release the joint statewide request for proposal for a third party Multifamily Segment Study

consultant.

74. Within 90 120 days after this decision is issued, Pacific Gas and Electric Company,

Southern California Edison Company, San Diego Gas & Electric Company, and Southern

California Gas Company and Energy Division shall take all reasonable actions to ensure

award of contract for the Multifamily Segment Study.

76. Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas &

Electric Company, and Southern California Gas Company and Energy Division shall take all

reasonable actions to ensure that at a minimum, the Multifamily Segment Study and related

consultant’s work shall include the following:

(a) Gather data on the state’s multifamily housing stock and ownership profiles,

including a statewide demographic and programmatic assessment of California’s

low-income multifamily housing stock (by each utility’s territory).

(b) Catalogue multifamily energy efficiency programs, including Commission

programs and those administered by other government agencies, utilities and

organizations within the state of California, as well as recent and ongoing

multifamily energy efficiency programs administered in other jurisdictions across

the country.

(c) Evaluate and further examine comments, objections and proposals from parties to

the proceeding in the context of the ESA Program decisions, the current

Commission directions and Strategic Plan;


A-8

(d) Review existing Commission’s multifamily programs within the overall context of

the ESA Program;

(e) Review other recently completed multifamily projects performed under other state

programs.

(f) Conduct field studies, as needed;

(g) Review and investigate the cost and budget implications of a multifamily program

implementation.

(h) Review and investigate coordination concerns related to any new delivery methods

that streamline the ESA process with external financing and energy efficiency

options such as how a single point of contact will be responsible for coordinating

IOU-administered energy efficiency, renewable, incentive, and financing programs

as well as non-IOU- administered, external multifamily efficiency, renewable,

incentive, and finance programs in California

(i) Identify available energy efficiency financing options, and develop a funding and

implementation schema utilizing the variety of energy efficiency programs

available for multifamily housing owner/operators;

(j) Develop overall recommendations for multifamily strategies looking toward 2020

vision of 100% penetration;

(k) Hold public meetings to obtain, document, review and consider all stakeholders’

input;

(l) Deliver a draft report by February July 15, 2013, which will be circulated for

comments; and;

(m) By May October 1, 2013, prepare and ultimately propose a feasible long-term

multifamily treatment strategy, Final Report, for the ESA Program.

77. By May October 1, 2013, Pacific Gas and Electric Company, Southern California Edison

Company, San Diego Gas & Electric Company, and Southern California Gas Company and


A-9

Energy Division shall take all reasonable action to ensure that the Multifamily Segment Study

and related Final Report is submitted to the assigned Administrative Law Judge and shall

summarize all of the key findings, address public and stakeholders’ comments and input,

recommend the proposed multifamily segment strategies and best-practices, taking into account

the utilities’ implementation and any interagency constraints and all operational and fiscal

constraints, for coordination issues with other agencies and programs and overall program

budgets.

82. By November 15 December 21st of each year, Pacific Gas and Electric Company, Southern

California Edison Company, San Diego Gas & Electric Company, and Southern California Gas

Company shall include in the monthly Low-Income Assistance Programs report cooling center

activity as directed by Energy Division. file a report on cooling center facility activities

including, attendance, low income program enrollments, and itemized expenses and describing

the energy education and marketing materials provided at each cooling center facility.

85. [Replace SCE figure in table with 2012 funding as requested by SCE of $768,000 in 2012,

$105,000 in 2013, and $105,000 in 2014.]

91. Southern California Edison Company, Southern California Gas Company and San Diego Gas

& Electric Company shall institute similar outreach programs as Pacific Gas and Electric

Company by allowing California Alternate Rates for Energy Program capitation contractors to

aid in the Post Enrollment Verification process for an up to $18.00 per capita fee per successfully

completed verification is approved.

97. [Add Multifamily Segment Study to table]

98. We approve the request for a $600,000 $300,000 shared energy education evaluation study

proposed by Pacific Gas and Electric Company, Southern California Edison Company, Southern

California Gas Company and San Diego Gas & Electric Company.

98. We approve the request for a $600,000 $300,000 shared energy education evaluation study

proposed by Pacific Gas and Electric Company, Southern California Edison Company, Southern

California Gas Company and San Diego Gas & Electric Company.


A-10

100(e). By no later than April 30, 2014, August 31, 2013, the Final Impact Evaluation Report

must be posted Energy Division's Public Download Area website.

(http://www.energydataweb.com/).

Add New Ordering Paragraph. SCE is authorized to file an Advice Letter within 90 days

requesting a reasonableness determination of its detailed implementation plan to comply with the

income verification provisions and related outreach in this decision.

Add New Ordering Paragraph. The IOUs shall not income verify customers more than once

every 24-months.

Add New Ordering Paragraph. The IOUs shall in overlapping territories data share verification to

save customer and IOU resources.

Add New Ordering Paragraph. Each IOU shall be represented on the Cost Effectiveness

Working Group.

Add New Ordering Paragraph. SCE is approved to leverage resources through installation of gas

measures on Santa Catalina Island for customers receiving gas service.

Add New Ordering Paragraph. We approve SCE’s provision of appliances at no cost to LIHEAP

providers.

Add New Ordering Paragraph. We approve expiration of $6.90 per CFL cap adopted in D.08-11-031 that is no longer feasible in 2012 – 2014.

Add New Ordering Paragraph. We approve use of CARE administrative funds for CPUC approved phone center enrollment.

Add New Ordering Paragraph. We approve SCE’s proposed copays of $500 per unit for central

HVAC and Heat Pumps.

Add New Ordering Paragraph. We approve the CARE, Cool Center, and ESA authorized

budgets for three years of funding inclusive of the bridge period, with an adjustment for SCE

Cool Centers as authorized in Ordering Paragraph 85.


A-11

Add New Ordering Paragraph. Homes treated, measures installed, and other performance metrics

achieved through ESA during the January – June 2012 bridge period count toward the goals and

objectives in the PD for 2012 specifically, and 2012 – 2014.

CERTIFICATE OF SERVICE

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I have this day served a true copy of SOUTHERN CALIFORNIA EDISON COMPANY'S (U338-E) OPENING COMMENTS TO THE PROPOSED DECISION ON LARGE INVESTOR-OWNED UTILITIES’ 2012-2014 ENERGY SAVINGS ASSISTANCE (ESA) (FORMERLY REFERRED TO AS LOW INCOME ENERGY EFFICIENCY OR LIEE) AND CALIFORNIA ALTERNATE RATES FOR ENERGY (CARE) APPLICATIONS on all parties identified on the attached service list(s) A.11-05-017 et al. Service was effected by one or more means indicated below:

☒ Transmitting the copies via e-mail to all parties who have provided an e-mail address.

☒ Placing the copies in sealed envelopes and causing such envelopes to be delivered by

hand or by overnight courier to the offices of the Commissioner(s) or other addressee(s).

ALJ Kimberly Kim 505 Van Ness Avenue San Francisco, CA 94102

Commissioner Timothy Simon 505 Van Ness Avenue San Francisco, CA 94102

☐ Placing copies in properly addressed sealed envelopes and depositing such copies in the

United States mail with first-class postage prepaid to all parties for those listed on the attached non-email list.

☐ Directing Prographics to place the copies in properly addressed sealed envelopes and to

deposit such envelopes in the United States mail with first-class postage prepaid to all parties.

Executed on this Thursday, May 24, 2012, at Rosemead, California.

______/s/ Christina Andrea Sanchez____________ Christina Andrea Sanchez Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY

2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

PROCEEDING: A1105017 - EDISON - FOR APPROVA FILER: SOUTHERN CALIFORNIA EDISON COMPANY LIST NAME: LIST LAST CHANGED: MAY 14, 2012

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ALLAN RAGO LYDIA L. FLORES FOR THE ENERGY COUNCIL PRESIDENT QUALITY CONSERVATION SERVICES, INC. AMERICAN INSULATION, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 FOR: THE ENERGY EFFICIENCY COUNCIL FOR: AMERICAN INSULATION, INC. CHARLIE HARAK KIM F. HASSAN STAFF ATTORNEY ATTORNEY NATIONAL CONSUMER LAW CENTER SOUTHERN CALIFORNIA GAS COMPANY 7 WINTHROP SQUARE, 4TH FLOOR 555 WEST FIFTH STREET, GT14E7 BOSTON, MA 02110-1006 LOS ANGELES, CA 90013-1011 FOR: NATIONAL CONSUMER LAW CENTER FOR: SOUTHERN CALIFORNIA GAS COMPANY/SAN DIEGO GAS & ELECTRIC COMPANY JORGE CORRALEJO MONICA GHATTAS CHAIRMAN / PRESIDENT ATTORNEY LAT. BUS. CHAMBER OF GREATER L.A. SOUTHERN CALIFORNIA EDISON COMPANY 634 S. SPRING STREET, STE 600 2244 WALNUT GROVE AVE. / PO BOX 800 LOS ANGELES, CA 90014 ROSEMEAD, CA 91770 FOR: LATINO BUSINESS CHAMBER OF GREATER FOR: SOUTHERN CALIFORNIA EDISON COMPANY L.A. CARL WOOD C. WESLEY STRICKLAND UTILITY WORKERS UNION OF AMERICA BROWNSTEIN HYATT FARBER SCHRECK, LLP 10103 LIVE OAK AVE. 21 E. CARRILLO STREET CHERRY VALLEY, CA 92223 SANTA BARBARA, CA 93101

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5/24/2012http://docs.cpuc.ca.gov/published/service_lists/A1105017_79905.htm

FOR: UTILITY WORKERS UNION OF AMERICA, FOR: NIAGARA CONSERVATION CORPORATION LOCAL 132 BOB CASTANEDA FAITH BAUTISTA DIR. OF MARKET DEVELOPMENT PRESIDENT & CEO PROTEUS, INC. NATIONAL ASIAN AMERICAN COALITION 1830 NORTH DINUBA BLVD. 1758 EL CAMINO REAL VISALIA, CA 93290 SAN BRUNO, CA 94066 FOR: PROTEUS FOR: NATIONAL ASIAN AMERICAN COALITION MITCHELL SHAPSON EDDIE AHN CALIF PUBLIC UTILITIES COMMISSION BRIGHTLINE DEFENSE PROJECT LEGAL DIVISION 1028A HOWARD STREET ROOM 4107 SAN FRANCISCO, CA 94103 505 VAN NESS AVENUE FOR: BRIGHTLINE DEFENSE PROJECT SAN FRANCISCO, CA 94102-3214 FOR: DRA KENT QIAN ALEX JACKSON NATIONAL HOUSING LAW PROJECT NATURAL RESOURCES DEFENSE COUNCIL 703 MARKET ST., STE. 2000 111 SUTTER STREET, 20TH FLOOR SAN FRANCISCO, CA 94103 SAN FRANCISCO, CA 94104 FOR: NATIONAL HOUSING LAW PROJECT FOR: NATURAL RESOURCES DEFENSE COUNCIL HAYLEY GOODSON ROSS NAKASONE THE UTILITY REFORM NETWORK CALIFORNIA HOUSING PARTNERSHIP CORP. 115 SANSOME STREET, SUITE 900 369 PINE STREET, STE. 300 SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94104 FOR: TURN FOR: CALIFORNIA HOUSING PARTNERSHIP CORP. DANIEL F. COOLEY WILLIAM H. BOOTH ATTORNEY AT LAW ALCANTAR & KAHL PACIFIC GAS AND ELECTRIC COMPANY 33 NEW MONTGOMERY STREET, STE. 1850 77 BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 FOR: CALIFORNIA LARGE ENERGY CONSUMER FOR: PACIFIC GAS AND ELECTRIC COMPANY ASSOCIATION JEFFREY LYNG STEVEN MOSS OPOWER, INC. M.CUBED 665 THIRD STREET, STE. 320 2145 18TH ST SAN FRANCISCO, CA 94107 SAN FRANCISCO, CA 94107-2308 FOR: OPOWER, INC. FOR: SAN FRANCISCO COMMUNITY POWER STEVEN R. SHALLENBERGER LEN CANTY SYNERGY COMPANIES CHAIRMAN 28436 SATTELITE STREET BLACK ECONOMIC COUNCIL HAYWARD, CA 94545 484 LAKE PARK AVE., SUITE 338 FOR: SYNERGY COMPANIES OAKLAND, CA 94610 FOR: BLACK ECONOMIC COUNCIL KAT DANIEL MELISSA W. KASNITZ PROGRAM MGR. - COMMUNITIES OF PRACTICE CENTER FOR ACCESSIBLE TECHNOLOGY GREEN FOR ALL 3075 ADELINE STREET, STE. 220



1611 TELEGRAPH AVENUE, SUITE 600 BERKELEY, CA 94703 OAKLAND, CA 94612 FOR: CENTER FOR ACCESSIBLE TECHNOLOGY FOR: GREEN FOR ALL ENRIQUE GALLARDO ERIK S. EMBLEM LEGAL COUNSEL EXECUTIVE ADMINISTRATOR THE GREENLINING INSTITUTE JCEEP 1918 UNIVERSITY AVE., 2ND FLOOR 1809 S STREET, SUITE 101-207 BERKELEY, CA 94704-1051 SACRAMENTO, CA 95811 FOR: THE GREENLINING INSTITUTE FOR: JOINT COMMITTEE ON ENERGY AND ENVIRONMENTAL POLICY JAMES L. HODGES MARCO LIZZARAGA 1069 45TH STREET LA COOPERATIVA CAMPESINA DE CALIFORNIA SACRAMENTO, CA 95819 7801 FOLSOM BLVD., STE. 365 FOR: THE EAST LOS ANGELES COMMUNITY SACRAMENTO, CA 95826 UNION (TELACU), THE MARAVILLA FOR: LA COOPERATIVA CAMPESINA DE FOUNDATION, THE ASSOCIATION OF CALIFORNIA CALIFORNIA COMMUNITY AND ENERGY SERVICES (ACCES)

ALLAN RAGO BARBARA R. BARKOVICH QUALITY CONSERVATION SERVICES, INC. BARKOVICH & YAP, INC. EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 EILEEN COTRONEO GINA GOODHILL PACIFIC GAS & ELECTRIC COMPANY POLICY - LEGISLATIVE ASSOCIATE EMAIL ONLY GLOBAL GREEN USA EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000 HUGH YAO LARA ETTENSON SOUTHERN CALIFORNIA GAS COMPANY NATURAL RESOURCES DEFENSE COUNCIL EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 MAKINI HASSAN MARK MCNULTY CITY OF MARIN EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 RAYMOND THOMPSON TODD NEAL REMS, LLC NEAL CO EMAIL ONLY EMAIL ONLY EMAIL ONLY, CA 00000 EMAIL ONLY, CA 00000 TROY FRANCISCO JESSICA HALPERN-FINNERTY CALIFORNIA PUBLIC UTILITIES COMMISSION CENTER FOR LABOR RESEARCH & EDUCATION EMAIL ONLY DONALD VIAL CENTER ON EMPLOYMENT

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EMAIL ONLY, CA 00000 EMAIL ONLY EMAIL ONLY, CA 00000-0000 TRACY GEZELIN-PANZARELLA RACHEL GOLD NIAGARA CONSERVATION CORP. OPOWER 45 HORSEHILL ROAD 1515 N. COURTHOUSE RD., STE. 610 CEDAR KNOLLS, NJ 07927 ARLINGTON, VA 22201 CAMERON BROOKS KRISTIEN TARY TENDRIL STATE REGULATORY AFFAIRS 5395 PEARL PARKWAY, SUITE 100 SOUTHWEST GAS CORPORATION BOULDER, CO 80301 5241 SPRING MOUNTAIN ROAD LAS VEGAS, NV 89150 HOLLY LLOYD CYNTHIA K. MITCHELL SOUTHWEST GAS CORPORATION ENERGY ECONOMICS INC. 5241 SPRING MOUNTAIN ROAD 530 COLGATE COURT LAS VEGAS, NV 89150-0002 RENO, NV 89503 ANDREW STEINBERG GILLIAN WRIGHT SOUTHERN CALIFORNIA GAS COMPANY DIRECTOR-CUSTOMER PROGRAMS & ASSISTANCE 555 W. FIFTH STREET, MAIL STOP GT-19A5 SAN DIEGO GAS & ELECTRIC COMPANY LOS ANGELES, CA 90013 555 W. FIFTH STREET, SUITE 1400 LOS ANGELES, CA 90013 RON GARCIA PAT WATTS RELIABLE ENERGY MANAGEMENT, INC. PRESIDENT / CEO 7201 ROSECRANS FCI PARAMOUNT, CA 90723 3850 E. GILMAN LONG BEACH, CA 90815 CASE ADMINISTRATION JOHN FASANA SOUTHERN CALIFORNIA EDISON COMPANY SOUTHERN CALIFORNIA EDISON 2244 WALNUT GROVE AVENUE, RM. 370 2244 WALNUT GROVE AVENUE ROSEMEAD, CA 91770 ROSEMEAD, CA 91770 LARRY R. COPE ANNLYN MA. FAUSTINO ATTORNEY SDG&E/SCGC SOUTHERN CALIFORNIA EDISON COMPANY 8330 CENTURY PARK COURT (CP31E) 2244 WALNUT GROVE AVE. / PO BOX 800 SAN DIEGO, CA 92123 ROSEMEAD, CA 91770 CENTRAL FILES JOY C. YAMAGATA SAN DIEGO GAS AND ELECTRIC CO. REGULATORY MGR. 8330 CENTURY PARK COURT, CP31E SAN DIEGO GAS & ELECTRIC/SOCALGAS SAN DIEGO, CA 92123 8330 CENTURY PARK COURT, CP 32 D SAN DIEGO, CA 92123-1550 YVETTE VAZQUEZ RICHARD SHAW SAN DIEGO GAS & ELECTRIC ASSERT 8326 CENTURY PARK COURT, MC CP62E PO BOX 469 SAN DIEGO, CA 92123-1569 FILLMORE, CA 93016



LES LO BAUGH FLOYD E. WICKS BROWNSTEIN HYATT FARBER SCHRECK, LLP HZOPTIONS, INC. 21 EAST CARRILLO STREET 1647 POSILIPO LANE, UNIT F SANTA BARBARA, CA 93101 SANTA BARBARA, CA 93108 VANESSA ANDERSON SUSAN L. WYNNE RHA, INC. RESEARCH DIR. - NEW BUSINESS DEVELOPMENT 590 W. LOCUST AVE., STE. 103 HIGHLANDS ENERGY SERVICES FRESNO, CA 93650 5114 E. CLINTON WAY, SUITE 101 FRESNO, CA 93727 ORTENSIA LOPEZ ROBERT GNAIZDA EXECUTIVE DIRECTOR COUNSEL EL CONCILIO OF SAN MATEO COUNTY 1758 EL CAMINO REAL BULINGAME AVE., STE. N SAN BRUNO, CA 94066 BURLINGAME, CA 94010 SHALINI SWAROOP JAMES R. GROW COUNSEL NATIONAL HOUSING LAW PROJECT NATIONAL ASIAN AMERICAN COALITION ET AL 703 MARKET STREET, STE. 2000 1758 EL CAMINO REAL SAN FRANCISCO, CA 94103 SAN BRUNO, CA 94066 MARYBELLE C. ANG BRETT SEARLE STAFF ATTORNEY BUSINESS ANALYST - PRICING PRODUCTS THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 115 SANSOME STREET, STE. 900 77 BEALE STREET, RM 559A, MCB5K SAN FRANCISCO, CA 94104 SAN FRANCISCO, CA 94105 KAREN TERRANOVA MARDI WALTON ALCANTAR & KAHL, LLP SR. REGULATORY ANALYST 33 NEW MONTGOMERY STREET, SUITE 1850 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94105 77 BEALE STREET, MC B9A SAN FRANCISCO, CA 94105 MARY O'DRAIN NORA SHERIFF PACIFIC GAS AND ELECTRIC COMPANY ALCANTAR & KAHL, LLP 245 MARKET ST., MC N6G 33 NEW MONTGOMERY STREET, SUITE 1850 SAN FRANCISCO, CA 94105 SAN FRANCISCO, CA 94105 WADE GREENACRE JANINE L. SCANCARELLI REGULATORY CASE COORDINATOR CROWELL & MORING LLP PACIFIC GAS AND ELECTRIC COMPANY 275 BATTERY ST., 23RD FLOOR 77 BEALE ST., MC B9A SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94105 CALIFORNIA ENERGY MARKETS CASE COORDINATION 425 DIVISADERO ST. STE 303 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CA 94117-2242 PO BOX 770000; MC B9A SAN FRANCISCO, CA 94177 KYLE JEFFERY CHARLIE TOLEDO



RHA, INC. DIRECTOR 1151 HARBOR BAY PKWY., STE. 205 SUSCOL INTERTRIBAL COUNCIL ALAMEDA, CA 94502 PO BOX 5386 NAPA, CA 94581 ANN GRESSANI MICHAEL RAWSON CONSULTANT THE PUBLIC INTEREST LAW PROJECT 3428 JORDAN ROAD 449 - 15TH ST., STE. 301 OAKLAND, CA 94602 OAKLAND, CA 94612 WENDY SOMMER PETER HOFMANN PRINCIPAL PROGRAM MANAGER BO ENTERPRISES STOPWASTE.ORG 43-B EAST MAIN STREET 1537 WEBSTER STREET LOS GATOS, CA 95030 OAKLAND, CA 94612 FOR: BO ENTERPRISES STEPHANIE BORBA STEVEN HEIM WESTERN INSULATION, L.P. WESTERN INSULATION, LP 2400 ROCKEFELLER DRI VE 2400 ROCKEFELLER DR. CERES, CA 95307 CERES, CA 95307 WILLIAM JULIAN II MICHAEL MOYNAGH UTILITY WORKERS UNION OF AMERICA WESTERN CENTER ON LAW & POVERTY 43556 ALMOND LANE 1107 - 9TH ST., STE. 700 DAVIS, CA 95618 SACRAMENTO, CA 95814 DAVE BARNES DAVE STEPHENSON EMPIRE INSULATION, INC. RATE REGULATION MANAGER - WESTERN REGIO 845 NORTH MARKET BLVD. AMERICAN WATER WORKS SERVICE CO. SACRAMENTO, CA 95834 4701 BELOIT DRIVE FOR: EMPIRE INSULATION, INC. SACRAMENTO, CA 95838 ROSS VAN NESS CAROL ZABIN ALCANTAR & KAHL IN THE GREEN ECONOMY 1300 SW FIFTH AVE., STE. 1750 THE DONALD VIAL CENTER ON EMPLOYMENT PORTLAND, OR 97209 2521 CHANNING WAY, STE. 5555 BERKELEY, CA 97720-5555

JOSE ATILIO HERNANDEZ AVA N. TRAN IDEATE CALIFORNIA CALIF PUBLIC UTILITIES COMMISSION 1901 LANDIS STREET DEMAND SIDE PROGRAMS BRANCH BURBANK, CA 91504 AREA 4-A 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 BERNARD AYANRUOH HAZLYN FORTUNE CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION UTILITY AUDIT, FINANCE & COMPLIANCE BRAN DEMAND SIDE PROGRAMS BRANCH AREA 3-C AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE

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SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 KAREN CAMILLE WATTS-ZAGHA KIMBERLY KIM CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM DIVISION OF ADMINISTRATIVE LAW JUDGES ROOM 4104 ROOM 5117 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 LOUIS M. IRWIN RADU CIUPAGEA CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ELECTRICITY PRICING AND CUSTOMER PROGRAM ELECTRICITY PRICING AND CUSTOMER PROGRAM ROOM 4209 ROOM 4104 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 RAHMON MOMOH RASHID A. RASHID CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION EXECUTIVE DIVISION LEGAL DIVISION ROOM 5206 ROOM 4107 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214 SYREETA GIBBS JASON WIMBLEY CALIF PUBLIC UTILITIES COMMISSION LIOB VICE CHAIR DEMAND SIDE PROGRAMS BRANCH DEPT. OF COMMUNITY SRVCS. & DEV. AREA 4-A 2389 GATEWAY OAKS DRIVE 505 VAN NESS AVENUE SACRAMENTO, CA 95833 SAN FRANCISCO, CA 94102-3214 ZAIDA C. AMAYA LOUISE A. PEREZ CALIFORNIA PUBLIC UTILITIES COMMISSION COMMUNITY RESOURCE PROJECT, INC. 180 PROMENADE CIRCLE, STE. 115 250 HARRIS AVENUE, SUITE 6 SACRAMENTO, CA 95834 SACRAMENTO, CA 95838

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PROCEEDING: A1105018 - SOCAL GAS - FOR APPR FILER: SOUTHERN CALIFORNIA GAS COMPANY LIST NAME: LIST LAST CHANGED: MAY 14, 2012




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PROCEEDING: A1105020 - SDG&E - FOR APPROVAL FILER: SAN DIEGO GAS & ELECTRIC COMPANY LIST NAME: LIST LAST CHANGED: MAY 14, 2012




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