Details for: Joint Protest Response to Advice 4620-E et al.pdf


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Shinjini C. Menon
Managing Director, State Regulatory Operations

November 24, 2021
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re:

Joint Utilities’ Reply to Protest of California Community Choice
Association’s Protest of Joint Submittal regarding Small Business
Customer Outreach Pilot for Disadvantaged Communities

Dear Energy Division Tariff Unit:
In accordance with Section 7.4.3 of General Order (GO) 96-B, Southern California
Edison Company (SCE), Pacific Gas and Electric Company (PG&E), Southern
California Gas Company (SoCalGas), and San Diego Gas & Electric Company
(SDG&E) (collectively, the “Utilities”) hereby reply to the California Community Choice
Association (CalCCA) protest to Southern California Edison Company’s Advice 4620-E,
Pacific Gas and Electric Company’s Advice 6381-E/4517-G, Southern California Gas
Company Advice 5888, and San Diego Gas & Electric Company’s Advice
3884-E/3033-G.
On October 28, 2021, pursuant to Ordering Paragraph (OP) 9 of Decision
(D.)21-06-036, the Utilities jointly submitted Advice 4260-E et al seeking California
Public Utilities Commission (Commission or CPUC) approval of its proposal for a Small
Business Customer Outreach Pilot for Disadvantaged Communities. The purpose of
the Advice Letter (AL) was to provide the implementation parameters, cost recovery,
and timeline for a Small Business Customer Outreach Pilot targeted at Small Business
Customers in disadvantaged communities (DAC). CalCCA submitted its protest to
Advice 4260-E et al on November 17, 2021. Consistent with GO 96-B, Section 7.4.4,
the Utilities reply within five business days from November 17, 2021.
THE COMMISSION SHOULD APPROVE THE UTILITIES ADVICE 4260-E ET AL
A. Proposed Small Business Outreach Pilot Allows for Participation from
Community Choice Aggregators

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-3377

Fax (626) 302-6396





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Energy Division Tariff Unit Page 2 November 24, 2021 In its protest of Advice 4260-E et al, CalCCA claims that the AL “does not explicitly provide for CCA SBC participation.”1 The Utilities refute this claim as the AL clearly states that “in addition to the Utilities’ programs, any CCA would be welcome to also provide their own respective programs as offerings so that the customer is provided with a full view of all applicable programs.”2 In addition, the Utilities deliberately recommended the use of third-party Energy Ambassadors to allow for inclusion of “any programs administered by applicable Community Choice Aggregators (CCA) of which the Utilities are not aware”3 and requests that each utility or CCA “be responsible for creating its own outreach materials and messaging, as well as providing the information to the statewide implementer for inclusion in the one-on-one counseling with the Small Business Customers.”4 Furthermore, the Utilities included a requirement that the thirdparty implementer “present relevant utility, CCA, and any applicable third-party offerings equally and not provide a recommendation for why a customer should select one over the other.”5 As proposed the Small Business Customer Outreach Pilot not only allows for CCA participation but also includes requirements that CCA programs be presented equally alongside the utility administered ones. CalCCA’s claim that the AL does not explicitly allow for CCA participation is without merit and no changes are necessary. B. Third-Party Implementer Should Not be Predetermined and Selected via a Competitive Bidding Process as Proposed In its protest, CalCCA recommends the “Commission should require the IOUs to select a ‘single statewide implementer’ from CBOs with existing relationships in local communities.”6 CalCCA reasons that “[t]he existing relationships CBOs have with small businesses can be leveraged to ensure that customers most in need are located and provided assistance.”7 The Utilities proposed the use of a single statewide implementer to allow for customers across different utility service areas to receive consistent messaging from the Energy Ambassadors. This also allows for operational efficiencies for utilities with overlapping service areas to provide the Small Business Customer with information for both utilities simultaneously. The Utilities welcome competitive bids from any community-based organization (CBO) and stress the importance of using a competitive bidding process without predetermining which entities may provide the optimal solution to reaching Small Business Customers. In addition, it would be against the overall spirit of the pilot to assist Small Business Customers by eliminating their ability to bid on becoming the 1 2 3 4 5 6 7 CalCCA Protest to Advice 4260-E et al, p. 2. Advice 4260-E et al, p. 9. Id., p. 6. Id. Id., p.7. CalCCA Protest to Advice 4260-E et al, p. 2. Id.
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Energy Division Tariff Unit Page 3 November 24, 2021 statewide implementer for the pilot. The Utilities look forward to the competitive bidding process for the statewide implementer and the potential for unique approaches from the market. Thus, the Utilities recommend that the Commission reject CalCCA’s proposal that would require Energy Ambassadors be chosen only from local CBOs. CONCLUSION The Utilities appreciate the opportunity to submit this reply to CalCCA’s Protests. For the foregoing reasons, the Utilities recommend that the Commission approve SCE’s Advice 4260-E et al. Sincerely, /s/ Shinjini C. Menon Shinjini C. Menon SCM:el:cm cc: Edward Randolph, Director, CPUC Energy Division Paul Phillips, CPUC Energy Division Benjamin Menzies, CPUC Energy Division Evelyn Kahl, California Community Choice Association Service List for R.21-02-014
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