Details for: SCE's Comments on Draft Resolution E-5169.pdf

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Shinjini C. Menon
Managing Director, State Regulatory Operations

September 13, 2021

Energy Division
Attention: Paul Phillips and Ben Menzies
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Comments of Southern California Edison Company on Draft
Resolution E-5169 Implementing Improvements to Medical
Baseline Programs and Affirming Compliance with SB 1338.

Dear Energy Division,
Pursuant to Rule 14.5 of the Rules of Practice and Procedure of the California Public
Utilities Commission (Commission or CPUC), Southern California Edison Company
(SCE) hereby submits its comments on Draft Resolution E-5169 (Draft Resolution). The
Draft Resolution proposes to approve with modifications SCE’s Tier 3 Advice Letter (AL)
reporting Medical Baseline outreach activities and establishing enrollment goals
pursuant to Decision (D.) 20-06-003 (the Decision).
SCE appreciates the Commission’s thoughtful consideration of the goals for Medical
Baseline enrollment, and seeks to clarify the exact numerical value for each year and to
clarify that goal numbers are based on “patients.” SCE also requests the inclusion of
SCE’s Supplemental AL 4276-E-A in the approval of the ALs within the Draft
On June 16, 2020, the CPUC issued D.20-06-003, adopting rules and other changes to
reduce residential customer disconnections for the large energy investor-owned utilities
(IOUs). Ordering Paragraphs (OP) 36 through 41 of the Decision ordered the IOUs to
submit a Tier 3 AL that:
• Demonstrates coordination with the medical community and county public health
offices to increase marketing and outreach to persons eligible for Medical
• Provides an outline for plans to implement requirements of SB 1338 and includes
plans to allow qualified medical professionals to e-sign Medical Baseline program

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396


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Energy Division Page 2 September 13, 2021 • • Provides Medical Baseline program enrollment goals and metrics; and Contains plans for funding outreach programs and grants to Community Based Organizations who promote public outreach related to the Medical Baseline program. On August 17, 2020, SCE submitted AL 4276-E in compliance with D.20-06-003. On December 22, 2020, SCE submitted Supplemental AL 4276-E-A to correct tables 1 and 3 in the original AL 4276-E. On August 23, 2021, Draft Resolution E-5169 was issued, with comments to be submitted by September 13, 2021. II. DISCUSSION A. The Draft Resolution Should Be Modified to Clarify that Medical Baseline Enrollment Goals Are Based on “Patients” and to Explicitly State the Goal Numbers OP 2 of the Draft Resolution states that “PG&E, SCE, and SDG&E shall establish a goal to increase Medical Baseline enrollment relative to 2019 levels by 7 percent in 2021, 8 percent in 2022, and 9 percent in 2023.”1 In its AL 4276-E and its Supplemental AL 4276-E-A, SCE communicated that as of the end of 2019, SCE had 95,915 household enrollments in Medical Baseline.2 SCE clarifies that this count—along with all counts provided throughout AL 4276-E and its Supplemental AL 4276-E-A (including in tables 1, 2, and 3)—were based on number of “patients” enrolled rather than households. The Draft Resolution seems to use data from the monthly disconnection reports filed in Rulemaking (R.) 18-07-005 to evaluate SCE’s proposal in AL 4276-E and AL 4276-EA.3 However, Medical Baseline figures in the monthly disconnection reports filed in R.18-07-005 are based on number of households enrolled in the program. A single customer account or household may have multiple “patients” with medical devices and receive an allowance for each individual. The Draft Resolution should clarify whether the goal is to be based on household or “patients” with medical devices. To provide a more accurate depiction of how many individuals are receiving medical baseline assistance, SCE recommends that the Draft Resolution be updated to reflect that the enrollment goal is based on number of “patients” rather than households, because the number of “patients” represents a true picture of those individuals who can benefit from the program and who are aware of and enrolling for the benefits. For clarity, the Draft Resolution should also include a table that provides the exact numerical values of the Draft Resolution’s enrollment goals for Medical Baseline. SCE understands the Draft Resolution’s enrollment goal to be to increase seven percent in 1 2 3 Draft Resolution, OP 2. SCE Advice 4276-E, p. 6; SCE Advice 4276-E-A, p. 2. See Draft Resolution, p. 13.
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Energy Division Page 3 September 13, 2021 2021 relative to 2019, and then to increase eight percent in 2022 relative to the 2021 goal, and then to increase nine percent in 2023 relative to the 2022 goal, as shown below—as opposed to the 2021 goal to mean increasing seven percent relative to 2019, the 2022 goal to mean increasing eight percent relative to 2019, and the 2023 goal to mean increasing nine percent relative to 2019. The Draft Resolution should be modified to clarify this approach, and including a table that lists exact goal values would eliminate any potential confusion for how the goal should be calculated. As explained above, these goals should also be clarified to state whether they are based on household or patients; SCE recommends basing the goals on number of patients. SCE proposes the following modifications:4 OP 2 PG&E, SCE, and SDG&E shall establish a goal to increase Medical Baseline enrollment based on patient enrollments relative to 2019 levels by 7 percent in 2021, 8 percent in 2022, and 9 percent in 2023, as shown below for each utility. Annual Medical Baseline Enrollment Goal (by number of patients) Year PG&E SCE SoCalGas SDG&E 2021 102,629 2022 110,839 2023 120,815 B. The Draft Resolution Should be Modified to Include SCE’s Supplemental AL 4276-E-A The Draft Resolution erroneously omits the approval of SCE’s Supplemental AL 4276E-A. Disposition of AL 4276-E should include disposition of Supplemental AL 4276-E-A. SCE requests that the Draft Resolution be modified to include approval of SCE’s Supplemental AL. SCE proposes the following modifications:5 OP 1 PG&E AL 4293-G/5916-E, SCE AL 4276-E and 4276-E-A, SDG&E AL 3589E/2890-G, and SoCalGas AL 5676-G are approved as modified by this Resolution. 4 5 Proposed text deletions are in bold strikethrough (abcd) and proposed text additions are in bold with underline (abcd). Proposed text deletions are in bold strikethrough (abcd) and proposed text additions are in bold with underline (abcd).
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Energy Division Page 4 September 13, 2021 III. CONCLUSION SCE appreciates the opportunity to submit these comments, and respectfully requests that the Commission make modifications to the Draft Resolution as explained herein. Southern California Edison Company /s/ Shinjini C. Menon____ Shinjini C. Menon SCM:el:jm cc: Edward Randolph, Director, CPUC Energy Division Paul Phillips, CPUC Energy Division Benjamin Menzies, CPUC Energy Division Service List R.18-07-005
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