Details for: PGE AL 5457-E.pdf

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Erik Jacobson
Regulatory Relations

Pacific Gas and Electric Company
77 Beale St., Mail Code B13U
P.O. Box 770000
San Francisco, CA 94177
Fax: 415-973-3582

December 28, 2018

Advice 5457-E
(Pacific Gas and Electric Company ID U 39 E)

Public Utilities Commission of the State of California

Information-only Advice Letter on Pacific Gas and Electric Company’s
Progress to Increase Family Electric Rate Assistance Program
Enrollment per Decision (D.) 18-08-013

In compliance with Decision (D.) 18-08-013, issued on August 17, 2018 in Pacific Gas
and Electric Company’s (PG&E) 2017 General Rate Case Phase 2 Proceeding, PG&E
submits this information-only Advice Letter (AL) to report on its progress to increase
Family Electric Rate Assistance (FERA) program enrollment.1
The FERA program (also known as the Lower-Middle Income Large Household Program)
provides rate assistance to large households of lower-to-middle-income customers.2 The
FERA program was designed to assist larger families that are ineligible for the CARE rate
because their income level falls slightly above the CARE program income eligibility limit.
FERA is available for households of three or more people that have a total household
income of between 200 percent plus $1 and 250 percent of the federal poverty guideline
level.3 The income threshold increases with each additional family member over three

D.18-08-013, Ordering Paragraph 15, states, “PG&E shall report to Energy Division by the end
of 2018, 2019, 2020, 2021, 2022, and 2023 on its progress to increase FERA subscription by
filing information-only advice letters that are served on the service list of this proceeding.”
The Commission authorized the FERA program in D. 04-02-057.
D.05-10-044 increased the lower income limits of the FERA Program were raised to 200%+$1
of the Federal Poverty Guideline levels.


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Advice 5457-E -2- December 28, 2018 people. Eligible FERA participants currently receive a 12 percent bill discount for their electric usage.4 In PG&E’s GRC Phase II proceeding, the Commission expressed concern that the FERA program is not highly customer subscribed.5 Noting that PG&E’s CARE customer participation rate is much higher than its FERA participation rate, the Commission ruled: It is appropriate and necessary for PG&E to significantly increase its rate of FERA participation. Ultimately, PG&E should achieve a similar subscription level for FERA as for CARE. At this time, we require PG&E to make significant efforts to increase its FERA subscription level over the next six years, with the aim of achieving a 50% subscription level.6 The GRC Phase II decision prescribed several actions to increase FERA participation, including to focus efforts in the Central Valley, to conduct one or more workshops there, and to file an updated advice letter to inform the Commission of its plan to use unspent CARE marketing funds to increase FERA enrollment.7 Included in these requirements is an order to submit and information-only advice letter to report on FERA participation progress. The advice letter is to be filed at the end of each year through 2023.8 Progress Report Toward Increasing FERA Enrollment In compliance with D. 18-08-013, PG&E hereby reports on its progress toward increasing FERA enrollment from August 1, 2018 (the month the decision was issued) until November 30, 2018. FERA statistics for the month of December are not available at the time of filing this advice letter. PG&E had limited time in 2018 to address the FERA participation concerns raised in the GRC Phase II decision given the Decision’s issuance date, however, PG&E will increase its marketing and outreach efforts in 2019 to yield a more detailed progress report at the end of next year. In D.15-07-001, the Commission changed PG&E’s FERA discount to a 12 percent effective discount as a single line-item on PG&E’s bills. In 2018, Senate Bill (SB) 1135 amended Public Uitlities Code Section 739.12 to increase the FERA discount to 18 percent effective January 1, 2019. 5 D.18-08-013, p. 74. 6 Id., p. 75 7 Id. PG&E filed Advice Letter 3990-G-B/5329-E-B on October 8, 2018 to detail its marketing plans to increase FERA enrollment. 8 Id., OP 15. 4
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Advice 5457-E -3- December 28, 2018 Table 1: FERA Program Enrollment from August 1, 2018 – November 30, 20189 2018 Month FERA Estimated Eligible Customers FERA Enrolled Customers FERA Penetration Rate August September October November 169,219 169,219 169,219 169,219 24,731 25,375 24,364 24,820 15% 15% 14% 15% Discount Provided to FERAEnrolled Customers $642,226 $464,723 $393,945 $329,965 Based on the directives in D. 18-08-013, PG&E developed and submitted the FERA Marketing and Outreach (M&O) Plan via PG&E’s AL 3990-G-B/5329-E-B on October 8, 2018. As outlined in the M&O plan, in August and September the marketing and outreach team performed data and insights review, including examination of attributes in the FERA customer profile and analysis of the marketing universe. This analysis looked at residential customers not enrolled in either the CARE or FERA program in order to evaluate the potential for creating targeted marketing campaigns that would reach those customers who were more likely to be eligible for FERA.10 Using the CARE propensity model as a foundation, additional filters of household income and household size were applied to identify a marketing universe of approximately 89,000 targetable customers. PG&E plans to launch direct mail and email testing in the first half of 2019 using this approach to generate targeted lists. PG&E also plans to optimize existing CARE/FERA campaigns on an ongoing basis as results from the tests become available. In December, PG&E initiated the creative development process to conduct marketing tests in 2019, including web page content, new digital ads, direct mail, email and mailbox inserts. The media strategy was adjusted to include considerations such as “hypertargeting” areas with lower FERA penetration, and increasing digital media weight in the Central Valley. Several immediate changes were made to ongoing tactics, including revising the CARE/FERA bill insert for November to increase the prominence of FERA messaging and place FERA in the first panel headline. In order to make it easier for customers to get enrolled in the right program, PG&E launched a combined version of the CARE and FERA website landing page to simplify 9 Final annual data for 2018 will be reported in the FERA Annual Report, to be filed on May 1, 2019. 10 FERA M&O Plan, Section 2.2
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Advice 5457-E -4- December 28, 2018 program requirement presentation, highlight key program differences and increase FERA visibility. Additionally, a homepage module will go live January 1, 2019 announcing the increased FERA discount amount. Although PG&E increased its marketing and outreach in late 2018, it does not expect to realize the impacts to increased FERA enrollment until early 2019. Until then, there has only been minimal change to FERA enrollment so far from August to November 2018. Next, in compliance with the order to work with community-based organizations (CBOs) in the Central Valley to increase rates of FERA participation, 11 PG&E partnered with Central California Legal Services - a community based organization (CBO) located in Fresno, Merced and Visalia - to hold a FERA workshop together with a community resource fair at the Arambula Resource Fair in Selma, CA on October 25, 2018. Community resource fairs include outreach on health services, immigration, education and financial literacy. At this fair, PG&E and Central California Legal Services set up tables with FERA and other assistance program materials displayed. As customers passed through the fair, PG&E and Central California Legal Services staff educated customers on the FERA program. PG&E also had a safety demonstration table set up and to showcase safety tips with customers. The exact number of customers that attended the fair was not tracked. Looking ahead to 2019, PG&E has identified 10 key strategic CBO partnerships in geographic areas with high FERA eligible population, especially in the Central Valley, to conduct performance based outreach on PG&E’s behalf. These 10 CBOs will conduct grassroots outreach through community events (including resource fairs where appropriate), workshops, faith-based outreach, door-to-door campaigns as well as via one-on-one case management where applicable. Protests This is an information-only advice letter submittal. Pursuant to General Order 96-B Section 6.2, PG&E is not seeking relief through this advice letter and is not subject to protest. Instead, PG&E is reporting progress to increase FERA program enrollment. Effective Date PG&E requests that this information-only advice submittal become effective December 28, 2018, the date of submittal. 11 D.18-08-013, Ordering Paragraph 15, PG&E should work with community-based organizations (CBOs) in the Central Valley to increase rates of FERA participation. PG&E should hold one or more workshops in the Central Valley in 2018 with local CBOs toward this effort.”
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Advice 5457-E -5- December 28, 2018 Notice In accordance with General Order 96-B, Section IV, a copy of this advice letter is being sent electronically and via U.S. mail to parties shown on the attached list and the parties on the service list for A.16-06-013. Address changes to the General Order 96-B service list should be directed to PG&E at email address For changes to any other service list, please contact the Commission’s Process Office at (415) 703-2021 or at Send all electronic approvals to Advice letter filings can also be accessed electronically at: /S/ Erik Jacobson Director, Regulatory Relations cc: Service List A.16-06-013
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Pacific Gas and Electric Company (ID U39E) Utility type: ELC GAS PLC ✔ HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Yvonne Yang Phone #: (415)973-2094 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: N/A Advice Letter (AL) #: 5457-E Subject of AL: Information-only Advice Letter on Pacific Gas and Electric Company’s Progress to Increase Family Electric Rate Assistance Program Enrollment per Decision (D.) 18-08-013 Keywords (choose from CPUC listing): Compliance AL Type: Monthly Quarterly Annual ✔ One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: D.18-08-013 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: No Summarize differences between the AL and the prior withdrawn or rejected AL: Yes Yes ✔ No ✔ No 12/28/18 No. of tariff sheets: N/A Estimated system annual revenue effect (%): N/A Estimated system average rate effect (%): N/A When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: Service affected and changes proposed1: N/A Pending advice letters that revise the same tariff sheets: N/A 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Erik Jacobson, c/o Megan Lawson Title: Director, Regulatory Relations Utility Name: Pacific Gas and Electric Company Address: 77 Beale Street, Mail Code B13U City: San Francisco, CA 94177 Zip: 94177 State: California Telephone (xxx) xxx-xxxx: (415)973-2093 Facsimile (xxx) xxx-xxxx: (415)973-3582 Email: Name: Title: Utility Name: Address: City: State: District of Columbia Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx: Email: Zip: Clear Form
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PG&E Gas and Electric Advice Filing List General Order 96-B, Section IV AT&T Albion Power Company Alcantar & Kahl LLP Alta Power Group, LLC Anderson & Poole Atlas ReFuel BART Barkovich & Yap, Inc. Braun Blaising Smith Wynne P.C. CalCom Solar California Cotton Ginners & Growers Assn California Energy Commission California Public Utilities Commission California State Association of Counties Calpine Casner, Steve Cenergy Power Center for Biological Diversity City of Palo Alto City of San Jose Clean Power Research Coast Economic Consulting Commercial Energy County of Tehama - Department of Public Works Crossborder Energy Crown Road Energy, LLC Davis Wright Tremaine LLP Day Carter Murphy Dept of General Services Don Pickett & Associates, Inc. Douglass & Liddell Downey & Brand East Bay Community Energy Ellison Schneider & Harris LLP Energy Management Service Evaluation + Strategy for Social Innovation GenOn Energy, Inc. Goodin, MacBride, Squeri, Schlotz & Ritchie Green Charge Networks Green Power Institute Hanna & Morton ICF International Power Technology Intestate Gas Services, Inc. Kelly Group Ken Bohn Consulting Keyes & Fox LLP Leviton Manufacturing Co., Inc. Linde Los Angeles County Integrated Waste Management Task Force Los Angeles Dept of Water & Power MRW & Associates Manatt Phelps Phillips Marin Energy Authority McKenzie & Associates Modesto Irrigation District Morgan Stanley NLine Energy, Inc. NRG Solar Office of Ratepayer Advocates OnGrid Solar Pacific Gas and Electric Company Pioneer Community Energy Praxair Regulatory & Cogeneration Service, Inc. SCD Energy Solutions SCE SDG&E and SoCalGas SPURR San Francisco Water Power and Sewer Seattle City Light Sempra Utilities Southern California Edison Company Southern California Gas Company Spark Energy Sun Light & Power Sunshine Design Tecogen, Inc. TerraVerde Renewable Partners Tiger Natural Gas, Inc. TransCanada Troutman Sanders LLP Utility Cost Management Utility Power Solutions Utility Specialists Verizon Water and Energy Consulting Wellhead Electric Company Western Manufactured Housing Communities Association (WMA) Yep Energy
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