SWG-2
Joint Rebuttal Testimony of PacifiCorp, SWG, Liberty, Bear Valley, and Alpine
IN THE MATTER OF APPLICATION OF WEST COAST GAS COMPANY (U-910-G) FOR APPROVAL OF PROGRAM YEARS 2021-2026 LOW-INCOME ASSISTANCE PROGRAM BUDGETS, AND RELATED MATTERS (A.20-03-014, ET AL.)
(Consolidated with A.20-05-014; A.20-05-015; A.20-05-016; A.20-05-017; and A.20-06-004)
JOINT REBUTTAL TESTIMONY OF PACIFICORP D/B/A PACIFIC POWER (U 901 E) (PACIFICORP) SOUTHWEST GAS CORPORATION (U 905 G) (SOUTHWEST GAS) LIBERTY UTILITIES (CALPECO ELECTRIC) LLC (U 933 E) (LIBERTY) BEAR VALLEY ELECTRIC SERVICE, INC. (U 913 E) (BVES) ALPINE NATURAL GAS OPERATING COMPANY NO. 1, LLC (U 909 G) (ALPINE)
(COLLECTIVELY, SMALL AND MULTI-JURISDICTIONAL UTILITIES (SMJUS))
FEBRUARY 16, 2021
1 IN THE MATTER OF APPLICATION OF WEST COAST GAS COMPANY (U 910 G) FOR APPROVAL OF PROGRAM YEARS 2021-2026 LOW- 2 INCOME ASSISTANCE PROGRAM BUDGETS, AND RELATED MATTERS 3 (A.20-03-014, ET AL.) 4 Joint Rebuttal Testimony 5 Table of Contents 6
7 Description Page No. 8 JOINT REBUTTAL TESTIMONY INTRODUCTION ...... 3 9 CHAPTER 1 RESPONSE TO TESTIMONY OF PUBLIC ADVOCATES OFFICE AT THE CALIFORNIA PUBLIC UTILITIES COMMISSION (PAO)...... 5 10 I. PAO ESA PROGRAM PROPOSALS ...... 5 11 A. ADOPTION OF ESA COST EFFECTIVENESS TEST (ESACET) THRESHOLD .. 5
12 B. LIBERTY’S ELECTRIFICATION PILOT ...... 6 C. SMJUS ANTICIPATING SIGNIFICANT INCREASES IN ESA-ELIGIBLE 13 CUSTOMERS DUE TO COVID-19 TO PROPOSE BUDGET CHANGES THROUGH ADVICE LETTERS ...... 6 14 D. ESA QUALIFICATION FOR HOUSEHOLDS WITH ANY MEMBER PARTICIPATING IN PUBLIC ASSISTANCE PROGRAM ...... 7 15 II. PAO CARE PROGRAM PROPOSALS ...... 8 16 A. LIBERTY CARE PENETRATION RATE GOAL ...... 8 B. SMJUS ANTICIPATING SIGNIFICANT INCREASES IN CARE-ELIGIBLE 17 CUSTOMERS DUE TO COVID-19 TO PROPOSE BUDGET CHANGES THROUGH ADVICE LETTERS ...... 9 18 CHAPTER 2 – RESPONSE TO TESTIMONY OF ALLAN H. RAGO ON BEHALF OF THE 19 ENERGY EFFICIENCY COUNCIL AND FREE ENERGY SAVINGS COMPANY LLC (EEC/FES) ...... 10 20 I. EEC/FES ESA PROGRAM PROPOSALS ...... 10 21 A. ESA PROGRAM BUDGET AND GOALS ...... 10 B. MIX OF HOUSING TYPES AND ESA PROGRAM GOALS OF SOUTHWEST 22 GAS ARE REASONABLE ...... 13 C. SMJUS’ PROPOSED ESA PROGRAM DESIGN ...... 13 23 D. ALLOW ESA PROGRAM ADJUSTMENTS VIA SMJU ADVICE LETTER ...... 15 24 E. ALLOW ONE-WAY SHIFTING OF ESA MEASURE FUNDS ...... 15 25 F. AFFORDABLE INTERNET AND OTHER LOW-INCOME PROGRAMS ...... 16
26 -1- 27 1 G. INCORPORATE COVID-19 PANDEMIC IMPACTS BUT MAINTAIN FLEXIBILITY ...... 17 2 H. SOCIAL JUSTICE ISSUES IN ESA PROGRAMS ...... 17 3 JOINT REBUTTAL TESTIMONY CONCLUSION ...... 19
4 Appendix A – Statement of Qualifications of Charity Spires on behalf of PacifiCorp 5 Appendix B – Statement of Qualifications of Elaine M. Prause on behalf of PacifiCorp 6 Appendix C – Statement of Qualifications of Derek Olijar on behalf of Liberty Utilities LLC 7 (CARE Witness) 8 Appendix D – Statement of Qualifications of Breanna Kelly on behalf of Liberty Utilities LLC 9 (ESA Witness) 10 Appendix E – Statement of Qualifications of Nguyen Quan, PhD on behalf of Bear Valley 11 Electric Service, Inc. 12 Appendix F – Statement of Qualifications of Michael Lamond on behalf of Alpine Natural 13 Gas Operating Company No. 1 LLC 14
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1 Application 20-03-014, et al.
2 BEFORE THE CALIFORNIA PUBLIC UTILITIES COMMISSION 3 Joint Rebuttal Testimony 4
5 JOINT REBUTTAL TESTIMONY INTRODUCTION
6 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
7 In accordance with the August 13, 2020 Assigned Commissioner’s Scoping Memo
8 and Ruling issued in this proceeding (Scoping Memo), PacifiCorp d/b/a Pacific Power
9 (PacifiCorp), Southwest Gas Corporation (Southwest Gas), Liberty Utilities (CalPeco
10 Electric) LLC (Liberty), Bear Valley Electric Service, Inc. (BVES)1, and Alpine Natural Gas
11 Operating Company No. 1, LLC (Alpine) (collectively, the Small Multi-Jurisdictional Utilities
12 or SMJUs) respectfully submit this joint rebuttal testimony to respond to the prepared direct
13 testimony filed by Janneille Hsu and Augustus Clements, witnesses for the Public
14 Advocates Office (PAO) at the California Public Utilities Commission (Commission), as well
15 as the prepared direct testimony of Allan H. Rago, witness for the Energy Efficiency Council
16 and Free Energy Savings Company LLC (EEC/FES), pertaining to the Applications for
17 Approval of Low-Income Assistance Programs and Budgets for Program Years 2021-2026
18 filed by the SMJUs in the consolidated proceeding, A.20-03-014, et al.2 (Applications).
19 Chapter 1 of this joint rebuttal testimony responds to the prepared direct testimony
20 of PAO, and Chapter 2 responds to the prepared direct testimony of EEC/FES. Each
21 chapter is organized into sections, with rebuttal testimony within each section being offered
22 by the respective witnesses for the specific SMJUs identified therein. The respective
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1 In Decision (D.) 19-12-039, the Commission authorized implementation of a corporate reorganization 24 plan that transferred the electric utility operations of the Golden State Water Company’s Bear Valley Electric Division to Bear Valley Electric Service, Inc. 25 2 Application (A.) 20-03-014; A.20-05-014; A.20-05-015; A.20-05-016; A.20-05-017; and A.20-06-014.
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1 witnesses offering rebuttal testimony on behalf of each SMJU are as follows: PacifiCorp
2 (Charity R. Spires, Elaine M. Prause); Southwest Gas (Melissa M. Porch); Liberty (Breanna
3 Kelly, Derek Olijar); BVES (Nguyen Quan, PhD); and Alpine (Michael Lamond). Summaries
4 of Qualifications for the supporting witnesses are attached hereto as Appendices A, B, C,
5 D, E and F.3 To the extent that this joint rebuttal testimony does not address a particular
6 issue discussed in the testimonies of PAO or EEC/FES should not be construed as an
7 admission by or agreement thereto by the SMJUs.
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3 The Summary of Qualifications for Southwest Gas witness Melissa M. Porch was previously provided 24 with her Prepared Direct Testimony supporting the Application of Southwest Gas Corporation for Approval of ESA and CARE Programs and Budgets for Program Years 2021-2026 filed on May 29, 25 2020 (A.20-05-017).
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1 CHAPTER 1 RESPONSE TO TESTIMONY OF PUBLIC ADVOCATES OFFICE AT THE
2 CALIFORNIA PUBLIC UTILITIES COMMISSION (PAO)
3 I. PAO ESA PROGRAM PROPOSALS
4 A. ADOPTION OF ESA COST EFFECTIVENESS TEST (ESACET) THRESHOLD
5 1. ADOPTION OF ESACET THRESHOLD OF 1.0 AT THE PORTFOLIO
6 LEVEL
7 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES)
8 PAO proposes in its testimony that each of the SMJUs, with the exception of Alpine,
9 be required to meet an ESA portfolio cost-effectiveness threshold of 1.0 as applied to
10 resource-only measures. PAO states that establishing ESACET thresholds aligns with the
11 Commission’s policy objectives, such as delivering cost-effective measures, reducing
12 hardship for low-income households, and creating ESA Program designs that maximize
13 ratepayer funds.4 Southwest Gas, PacifiCorp, Liberty, and BVES are in agreement and
14 support PAO’s proposal adopting an ESACET threshold of 1.0 or greater at the portfolio
15 level applicable to resource-only measures for their ESA Programs.
16 2. ADOPTION OF ESACET TARGET OF 0.30 AT THE PORTFOLIO LEVEL
17 FOR ALPINE
18 (ALPINE)
19 Alpine does not support PAO’s proposed ESACET target goal of 0.30 or greater for
20 its ESA Program. Alpine revaluated its ESACET with the resource measures outlined by
21 PAO and while these are valid suggestions, there are well documented, historical limits to
22 the maximum frequency (or uptake) for a given measure, and it is still unable to achieve the
23 target score of 0.30. For its ESA Program, Alpine recommends an ESACET goal of 0.17 or
24 4 Prepared Testimony of PAO on ESA and CARE Programs and Budgets of SMJUs for Program Years 25 2021-2026, at pg. 1-1 to 1-2.
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1 greater with the measure mix suggested in PAO’s testimony. Alpine believes this is a more
2 achievable goal.
3 B. LIBERTY’S ELECTRIFICATION PILOT
4 (LIBERTY)
5 Liberty disagrees with PAO’s recommendation to reject Liberty’s proposed ESA
6 Electrification Pilot.5 Liberty proposes an ESA Electrification Pilot as it offers low-income
7 customers newer benefits and technologies that will increase customer interest. Some
8 regions within Liberty’s territory do not have a gas utility provider and currently use
9 alternative fuels, such as propane and wood. This pilot program will benefit low-income
10 customers within these regions by offering measures such as heat pump water heaters,
11 ductless mini split heat pumps, inductive ranges, heat pump clothes dryers, and electric
12 panel upgrades. By converting these customers to cleaner and more efficient technologies,
13 Liberty will be supporting California's clean energy goals by greatly reducing greenhouse
14 gas (GHG) emissions.
15 C. SMJUS ANTICIPATING SIGNIFICANT INCREASES IN ESA-ELIGIBLE
16 CUSTOMERS DUE TO COVID-19 TO PROPOSE BUDGET CHANGES THROUGH
17 ADVICE LETTERS
18 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
19 The SMJUs agree with PAO that the COVID-19 pandemic has potentially contributed
20 to increased financial hardship for some low-income customers. The SMJUs also agree
21 that the utilities should be permitted to file an advice letter requesting additional budget
22 funding as needed for anticipated increases in program activity or to meet their ESA
23 Program participation goals during the remaining years of the program cycle. However, the
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25 5 Id. at pg. 1-5 to 1-6.
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1 SMJUs recommend that the Commission allow the utilities to file a Tier 2 advice letter rather
2 than PAO’s proposed Tier 3 advice letter, as a Tier 2 advice letter is a reasonable and more
3 expedient alternative. The Tier 2 advice letter provides for a quicker review process that
4 would allow the SMJUs to be nimble and responsive to future events and customer needs.
5 In contrast, a Tier 3 advice letter, if contested, can take months to resolve and receive a
6 Commission decision; thereby, handcuffing the SMJU requesting the needed budget
7 change.
8 D. ESA QUALIFICATION FOR HOUSEHOLDS WITH ANY MEMBER
9 PARTICIPATING IN PUBLIC ASSISTANCE PROGRAM
10 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
11 The SMJUs are supportive of PAO’s proposed change to the ESA enrollment
12 process that would allow customers to qualify for the ESA Program through use of
13 categorical eligibility. With categorical eligibility, a customer who provides documentation
14 substantiating participation in one of the designated state or federal assistance programs
15 would also qualify for the ESA and/or CARE Programs and would not need to provide
16 additional documentation for enrollment. The SMJUs propose that the assistance programs
17 eligible for use with categorical enrollment for the ESA Program be consistent with the
18 categories currently in use by the four California large Investor Owned Utilities (large IOUs)6:
19 • Medicaid/Medi-Cal for Families A & B
20 • CalFresh (Food Stamps) SNAP
21 • Head Start Income Eligible (Tribal Only)
22 • Bureau of Indian Affairs General Assistance
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24 6 Southern California Gas Company (SoCalGas), San Diego Gas & Electric Company (SDG&E), 25 Pacific Gas and Electric Company (PG&E), and Southern California Edison Company (SCE).
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1 • Women, Infants and Children (WIC)
2 • National School Lunch Program (NSLP)
3 • Low-Income Home Energy Assistance Program (LIHEAP)
4 • Supplemental Security Income (SSI)
5 • CalWORKS (TANF) or Tribal TANF
6 Furthermore, Southwest Gas, PacifiCorp, Liberty, and BVES recommend that
7 categorical eligibility also be permitted for their CARE Programs. As recommended by PAO,
8 Southwest Gas, PacifiCorp, Liberty, and BVES are agreeable to publishing information
9 regarding categorical eligibility on program resources, such as websites and distribution
10 materials to help inform customers. The SMJUs would also train their staff and contractors
11 on implementation of the new categorical eligibility provision for ESA and CARE Program
12 enrollment. However, with respect to reporting on categorical eligibility enrollment, the
13 SMJUs do not support PAO’s proposal for additional reporting on categorical eligibility
14 enrollment. The SMJUs have smaller California operations and greater resource limitations
15 than the large IOUs. As such, the SMJUs would require various system improvements to
16 be able to report on these enrollments in their annual low-income reports as proposed by
17 PAO.
18 II. PAO CARE PROGRAM PROPOSALS
19 A. LIBERTY CARE PENETRATION RATE GOAL
20 (LIBERTY)
21 Liberty, in conjunction with other SMJUs, conducted an Athens study from 2018-
22 2019 to determine estimated eligible customers for CARE in its service territory. The results
23 of the study show approximately 5,144 estimated eligible Liberty customers, a significant
24 decrease from the previous Athens study conducted in 2014. Liberty has been providing 25
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1 monthly updates to the Commission regarding penetration rates and has been consistently
2 above a 70 percent penetration rate when applying the updated estimated eligible
3 customers. With increased outreach efforts, Liberty should be able to meet the ambitious
4 targets required by the Commission and proposed in its Application.
5 Liberty is proposing a two percent increase in its 2020 authorized outreach budget
6 per year. This escalation is reflective of inflation and to cover the costs of doing the business
7 of marketing, education, and outreach. Labor costs for outreach are also included in the
8 proposed budget. PAO refers to actual outreach expenditures of $14,631 during program
9 year (PY) 2018. These expenses did not include labor for outreach, which is tracked in the
10 General Administration category. The program budgets were not approved until D. 18-08-
11 020 increased the outreach budgets at the end of August of PY 2018.
12 B. SMJUS ANTICIPATING SIGNIFICANT INCREASES IN CARE-ELIGIBLE
13 CUSTOMERS DUE TO COVID-19 TO PROPOSE BUDGET CHANGES THROUGH
14 ADVICE LETTERS
15 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
16 The SMJUs acknowledge that the COVID-19 pandemic has potentially contributed
17 to increased financial hardship for some low-income customers and could have an impact
18 on the SMJUs meeting the 90% CARE penetration goal. The SMJUs agree with PAO that
19 the utilities should be permitted to file an advice letter requesting additional budget funding
20 for anticipated increases in CARE Program activity during the remaining years of the
21 program cycle and to allow for each SMJU to meet the CARE penetration rate of 90%.
22 However, for the reasons stated in Section I,C., above, the SMJUs recommend that the
23 Commission allow the SMJUs to file a Tier 2 advice letter rather than a Tier 3 advice letter
24 for such requested budget changes, as a Tier 2 advice letter is a reasonable and more
25 expedient alternative.
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1 CHAPTER 2 – RESPONSE TO TESTIMONY OF ALLAN H. RAGO ON BEHALF OF THE
2 ENERGY EFFICIENCY COUNCIL AND FREE ENERGY SAVINGS COMPANY LLC
3 (EEC/FES)
4 I. EEC/FES ESA PROGRAM PROPOSALS
5 A. ESA PROGRAM BUDGET AND GOALS
6 1. THE SMJUS’ PROPOSED ESA PROGRAM BUDGETS AND GOALS
7 ARE REASONABLE AND SHOULD BE APPROVED
8 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
9 In his testimony, Mr. Rago notes that the SMJUs’ ESA Program budgets and goals
10 within their Applications are flawed by reliance upon outdated and no longer valid data.7
11 The SMJUs disagree with Mr. Rago’s flawed conclusion. Even in “normal” circumstances,
12 by the time applications are filed and during the course of the program years at issue, data
13 will be outdated to a certain extent. The SMJUs acknowledge there have been a number
14 of unforeseen changes due to the COVID-19 pandemic, which may have impacted the
15 planning documents; however, the SMJUs were directed in their Guidance Document (D.19-
16 11-005) to consider the relevant findings of the 2016 Low-Income Needs Assessment
17 (LINA).8 Additionally, the 2018 Athens Research Eligibility Report (Athens) was the most
18 recent Athens study available to the SMJUs at the time the Applications were filed. Further,
19 the concern expressed by Mr. Rago is addressed by PAO’s and EEC/FES’s
20 recommendations that the SMJUs be permitted to file an advice letter if they find that an
21 increase in the ESA Program budget is needed to address unforeseen impacts resulting
22 from the COVID-19 pandemic. Finally, if the Commission believes the SMJUs should use
23
7 Testimony of Allan Rago on the 2021-2026 ESA and CARE Program Budget Applications of 24 California’s Small and Multi-Jurisdictional Utilities on behalf of the Energy Efficiency Council and Free Energy Savings Company LLC, at pg. 3. 25 8 SMJU 2021-2026 ESA and CARE Budget Application Guidance Document (D.19-11-005), at pg. 6.
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1 more recent data in developing their ESA Program budgets, the SMJUs suggest that the
2 issue be addressed by revising the Guidance Document on a going forward basis. Revising
3 the vintage of data used in this proceeding would cause an unreasonable and unnecessary
4 delay in effectuating the ESA Program for the current plan years.
5 2. SOUTHWEST GAS’ ESA PROGRAM BUDGET AND GOALS ARE
6 BASED ON REASONABLE PARTICIPATION ESTIMATES AND SHOULD
7 BE APPROVED
8 (SOUTHWEST GAS)
9 In addressing Southwest Gas’ ESA and CARE Programs in his testimony, Mr. Rago
10 makes several flawed and erroneous statements. Specifically, Mr. Rago claims that as of
11 early January 2021, Southwest Gas had about 75,700 CARE participants, and elsewhere
12 in his testimony, he asserts a “current” CARE participation estimate for Southwest Gas of
13 73,700.9 Southwest Gas does not agree with either of these participation estimates.
14 Southwest Gas reports its CARE participants on a monthly basis as part of its Energy
15 Division Data Request on the Impacts of COVID-19 on SMJU Customers. As of December
16 31, 2020, Southwest Gas reported a total estimated CARE participation of 57,957 with a
17 penetration rate of 94%.10
18 Mr. Rago also incorrectly states that 53,100 CARE low-income homes have never
19 been weatherized.11 This calculation appears to be based on the assumption that
20 Southwest Gas had 73,700 CARE participants as of early January 2021 with a correction of
21 an 85% penetration rate, which again is not accurate. Further, this calculation erroneously
22 assumes 31,700 residences were weatherized between 2000 and 2020. Each year,
23
9 Testimony of Allan Rago on behalf of EEC/FES, at pgs. 4 and 5. 24 10 Southwest Gas Response to Energy Division Data Request No. 5 addressing Impacts of COVID-19 on SMJU Customer, submitted January 21, 2021. 25 11 Testimony of Allan Rago on behalf of EEC/FES, at pg. 5.
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1 Southwest Gas reports in its Low-Income Assistance Programs Annual Report the number
2 of treated homes since 2002. In its 2019 Annual Report, Southwest Gas reported 32,371
3 homes treated between 2002-2019 and will be providing updated homes treated for 2020 in
4 its next annual report.12
5 In his testimony, Mr. Rago recommends that Southwest Gas homes treated from 11
6 to 25 years ago be prioritized for retreatment (or “go-back”).13 Southwest Gas agrees that
7 homes that were treated many years ago should be a priority for retreatment along with
8 untreated homes. As Southwest Gas states in its Application, previously installed measures
9 may be beyond their useful lives, and there continues to be a need to provide low-income
10 customers with ESA Program measures that offer important health and safety benefits.14
11 Though Mr. Rago contends that Southwest Gas restricts outreach to customers that
12 have been previously weatherized,15 Southwest Gas has followed Commission guidance on
13 this issue, encouraging the treatment of “first touch” households in the current program cycle
14 (2018-2020).16 In regards to retreatments, the Commission instructed in D.18-08-020 that
15 “go-backs” should be tailored to the specific home, prioritizing households with the highest
16 energy usage that were treated the greatest number of years previously, and be efficiently
17 delivered.17
18 Notably, Southwest Gas developed its proposed 2021-2026 ESA Program goals with
19 a focus on deeper energy savings, high value measures and fewer households treated,
20
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22 12 Southwest Gas Corporation Low-Income Assistance Programs 2019 Annual Report, at pg. 47, https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M338/K276/338276805.PDF 13 23 Testimony of Allan Rago on behalf of EEC/FES, at pg. 6. 14 Application of Southwest Gas Corporation for Approval of ESA and CARE Programs and Budgets for Program years 2021-2026; A.20-05-017, at pg. 13. 24 15 Testimony of Allan Rago on behalf of EEC/FES, at pg. 6. 16 Decision (D.) 18-08-020, at pg. 22. 25 17 Id.
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1 resulting in a lower annual budget.18 This approach differs from the current and previous
2 ESA Programs which included focus on the quantity of homes treated. Southwest Gas
3 recognizes that there have been a number of COVID-19 impacts since the filing of its
4 Application on May 29, 2020, and as mentioned above, agrees with PAO’s recommendation
5 that the SMJUs be permitted to file advice letters requesting additional budget funding for
6 any anticipated increases in ESA Program activity during the 2021-2026 program cycle.
7 B. MIX OF HOUSING TYPES AND ESA PROGRAM GOALS OF SOUTHWEST
8 GAS ARE REASONABLE
9 (SOUTHWEST GAS)
10 Mr. Rago questions Southwest Gas’ proposed multifamily goal for its ESA Program
11 suggesting that it may not be obtainable without changes in the current ESA Program
12 enrollment requirements and procedures.19 In its Application, Southwest Gas projected an
13 ESA Program housing mix based on its rate schedule mix of customers enrolled in the
14 CARE Program. Since the ESA and CARE Programs have the same income eligibility
15 requirements, Southwest Gas believes this to be a realistic estimate of the type and number
16 of households that may be eligible for the ESA Program based on current ESA Program
17 enrollment procedures. The SMJUs discuss the changes proposed by EEC/FES in ESA
18 Program procedures in Section II.C., below.
19 C. SMJUS’ PROPOSED ESA PROGRAM DESIGN
20 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
21 In his testimony, Mr. Rago notes that certain ESA Program procedures should be
22 modified, including the removal of Property Owner Waivers, the removal of limitations on
23
24 18 Application of Southwest Gas Corporation for Approval of ESA and CARE Programs and Budgets for Program years 2021-2026, at pg. 16. 25 19 Testimony of Allan Rago on behalf of EEC/FES, at pg. 9.
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1 go-backs20, and changes to the income eligibility requirements.21 The SMJUs are not
2 opposed to improvements that may enhance the effectiveness of the ESA Program;
3 however, the SMJUs also believe it is important to be aligned with the large IOUs on ESA
4 Program eligibility and procedural requirements when practicable and appropriate.
5 Consistency in ESA Program eligibility and procedural requirements between the large IOUs
6 and the SMJUs allows for less customer confusion. For example, Southwest Gas overlaps
7 with SCE in its southern California service territory. Customers may seek ESA Program
8 services from both utilities but potentially be faced with differing eligibility and procedural
9 requirements.
10 Additionally, Section 2.5 of the Statewide Energy Savings Assistance Program and
11 Procedures Manual provides that “[t]he legal owner or authorized agent must sign the
12 property authorization form.”22 Section 2.6 of the California Statewide Energy Savings
13 Assistance Program and Procedures Manual addresses rental units.23 Further, the ESA
14 Program income eligibility requirements for the SMJUs of 200% of the federal poverty
15 income level are set forth by various Commission decisions.24 To the extent that the
16 Commission deems it advisable to revise these ESA Program requirements, it should
17 consider doing so in a separate proceeding where all affected parties can participate.
18 . . .
19 . . .
20 …
21 20 Pursuant to D.18-08-020, Ordering Paragraph 2, Southwest Gas is directed to implement the ESA 22 Program retreatment target of 100 households a year for Program Years 2018-2020, D.18-08-020, at pg. 80-81. 21 23 Testimony of Allan Rago on behalf of EEC/FES, at pgs. 10-19. 22 Statewide Energy Savings Assistance Program and Procedures Manual 2017-2020 Cycle Policy and Procedures Manual, Section 2.5, see, https://www.cpuc.ca.gov/iqap/ 24 23 Id., at Section 2.6. 24 The 200% federal poverty income level was set in D.05-10-044, D.06-12-036, D.08-12-019 and D.14- 25 05-004 for Southwest Gas, PacifiCorp, BVES and Liberty, respectively.
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1 D. ALLOW ESA PROGRAM ADJUSTMENTS VIA SMJU ADVICE LETTER
2 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
3 The SMJUs are supportive of Mr. Rago’s proposal that would allow for ESA Program
4 adjustments via advice letters and regulatory reports. The SMJUs support filing a Tier 2
5 advice letter to request additional ESA Program budget funding as discussed above in the
6 SMJUs’ response to PAO’s proposal in Chapter 1, Section I.C. of this testimony.
7 E. ALLOW ONE-WAY SHIFTING OF ESA MEASURE FUNDS
8 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
9 Mr. Rago presents in his testimony several fund shifting proposals, including one-
10 way shifting of ESA measure funds and “borrowing” from future years’ budgets to continue
11 operations during the current year.25 In D.14-05-004, the Commission outlines the
12 requirements and restrictions for fund-shifting, which were re-affirmed in D.18-08-020. For
13 example, under D.14-05-004, the SMJUs are currently authorized to shift funds into or out
14 of different program categories by filing a motion and may “borrow” from proceeding budget
15 cycles.26
16 The SMJUs do not support Mr. Rago’s proposal of requiring the SMJUs to provide
17 more frequent, interim progress reports similar to the reporting required of the large IOUs.
18 A requirement for the SMJUs to file more frequent ESA Program progress reports similar to
19 the large IOUs is neither warranted nor practicable. Currently, the SMJUs provide an annual
20
21 25 Testimony of Allan Rago on behalf of EEC/FES, at pg. 26. 26 Pursuant to D.14-05-004, the SMJUs are authorized to “(3) [s]hift and ‘borrow’ from the next budget 22 cycle, without prior approval, if the next cycle budget portfolio has been approved by the Commission and such fund shifting is necessary to avoid interruptions of those programs continuing into the next 23 cycle (and for start-up costs of new programs)…(5) file a motion pursuant to Article 11 of the Commission’s Rules of Practice and Procedure and obtain an Administrative Law Judge’s prior written approval for any: (a) shifting of funds into or out of different program categories; (b) shifting of funds into 24 or out of the Education subcategory; (c) shifting of funds between electric and gas programs; and/or, (d) shifting of funds totaling 15% or more of the total current annual ESA program budget….” D.14-05-004, 25 at pgs. 49-52.
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1 low-income report and monthly COVID-19 CARE reporting to the Commission. Additionally,
2 the SMJUs have smaller California operations and greater resource limitations than the
3 large IOUs and would require various system improvements and additional resources to
4 allow for more frequent reporting.
5 F. AFFORDABLE INTERNET AND OTHER LOW-INCOME PROGRAMS
6 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
7 Mr. Rago recommends that the ESA Program be utilized to educate and enroll low-
8 income families in the Commission’s affordable internet program.27 The SMJUs do not
9 oppose providing ESA participants with resources on other available programs, such as the
10 affordable internet program or the other programs that Mr. Rago recommends. For
11 example, the SMJUs would not be opposed to including other programs’ URLs on ESA
12 Program outreach materials as there is no incremental cost and this type of information
13 would not detract from outreach on the ESA Program. Mr. Rago additionally recommends
14 that any additional costs associated with his proposal come not from ESA budgets but from
15 those other programs.28 However, the SMJUs believe they lack the authority to utilize funds
16 from other programs or entities without further direction from the Commission.
17 Mr. Rago also discusses ESA contractors being involved in the Technology and
18 Equipment for Clean Heating (TECH) Initiative, which is part of California’s Building
19 Decarbonization Rulemaking.29 As the SMJUs understand Mr. Rago’s testimony, he
20 proposes that any efforts by ESA contractors to provide TECH-related services to ESA
21 customers should be funded from Building Decarbonization funds and not from ESA
22
23 27 Testimony of Allan Rago on behalf of EEC/FES, at pg. 27. 28 Id., at pg. 28. 24 29 R.19-01-011, This Rulemaking establishes framework for CPUC Commission oversight of Senate Bill (SB) 1477 for two building decarbonization pilot programs designed for the purpose of decarbonizing 25 California’s residential buildings in order to achieve the state’s zero-emissions goals.
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1 budgets.30 The SMJUs do not oppose reasonable cooperation between the ESA Program
2 and the Building Decarbonization initiatives when appropriate and feasible. However, this
3 rulemaking is still in progress, and TECH bidders within the proceeding are encouraged to
4 submit their proposals on how to layer or stack incentives with various programs, including
5 the ESA Program.31 The SMJUs recommend that the Commission not implement new
6 processes within this proceeding while the rulemaking is ongoing.
7 G. INCORPORATE COVID-19 PANDEMIC IMPACTS BUT MAINTAIN
8 FLEXIBILITY
9 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
10 The SMJUs recognize that the COVID-19 pandemic has created significant and
11 ongoing impacts, as noted in Mr. Rago’s testimony. However, the SMJUs do not believe it
12 would be appropriate to spread the economic impacts over a 10-year ESA Program span.
13 The SMJUs believe it would be difficult to estimate the economic impacts of the COVID-19
14 pandemic. Without knowing the economic impacts, it is difficult to determine the appropriate
15 time span over which to spread such costs. Rather, the SMJUs support the approach of
16 filing a Tier 2 advice letter to adjust ESA and CARE Program funding budgets as needed in
17 order to address the economic impacts of the COVID-19 pandemic.
18 H. SOCIAL JUSTICE ISSUES IN ESA PROGRAMS
19 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
20 Mr. Rago recommends that the ESA Program should use the Socioeconomic
21 Vulnerability Index (SEVI) as defined by the Commission Resolution to identify communities
22 that deserve and need adjustments to the ESA services eligibility requirements.32 Mr. Rago
23
24 30 Testimony of Allan Rago on behalf of EEC/FES, at pg. 29. 31 See D.20-03-027, at pg. 85. 25 32 Testimony of Allan Rago on behalf of EEC/FES, at pg. 32-33.
26 -17- 27
1 asks that all homes within the worst SEVI communities and all homes within a designated
2 Disadvantaged Community (DAC) be declared eligible for ESA improvements.33 If the
3 Commission decides that it will not provide this service to DAC families, Mr. Rago argues
4 that the SMJUs, at minimum, allow the DAC families and those living in extreme SEVI
5 communities to self-certify that they meet program income qualifications to receive service.34
6 The SMJUs appreciate Mr. Rago’s proposal, but believe his recommendation is outside the
7 scope of this proceeding. The proposal requires a policy change that should be evaluated
8 in a proceeding in which all affected parties can opine on such a recommendation for a
9 change to the ESA program.
10 Mr. Rago further recommends that ex-offenders should not be prohibited from ESA
11 employment. The SMJUs cannot dictate the hiring practices of the community-based
12 organizations that they use in the ESA program. Again, if the Commission would like to
13 consider Mr. Rago’s proposal, the SMJUs suggest that it should do so in a comprehensive
14 proceeding that includes input from all affected parties.
15
16
17
18
19
20
21
22
23
24 33 Id., at pg. 32. 25 34 Id., at pg. 33.
26 -18- 27
1 JOINT REBUTTAL TESTIMONY CONCLUSION
2 (SOUTHWEST GAS, PACIFICORP, LIBERTY, BVES, ALPINE)
3 The SMJUs have submitted CARE/ESA programs for Plan Years 2021 to 2026 that
4 are compliant with Commission guidance and recommend that the Commission approve
5 their Applications as amended by the various proposals that each have agreed to in this
6 joint rebuttal testimony. The SMJUs recognize that the impacts of the COVID-19 pandemic
7 have not been reflected in their Applications; however, the most efficient method to address
8 these impacts for program years 2021-2026 would be to allow the SMJUs to file a Tier 2
9 advice letter to address any needed budget changes. Also, in considering the proposals by
10 the intervenors, the SMJUs ask the Commission to consider that the SMJUs operate on a
11 significantly smaller scale in California, with smaller program budgets, smaller customer
12 bases for recovery of program costs and different reporting requirements in comparison to
13 the large IOUs. Further, the SMJUs suggest that many of the proposals made by EEC/FES
14 are broader policy decisions relating to the ESA program that should be evaluated in a
15 proceeding that includes all utilities and affected parties.
16
17
18
19
20
21
22
23
24
25
26 -19- 27 APPENDIX A STATEMENT OF QUALIFICATIONS OF CHARITY SPIRES ON BEHALF OF PACIFICORP 1 PACIFICORP
2 WITNESS QUALIFICATIONS OF CHARITY R. SPIRES
3 Q. Please state your name, business address, and present position with PacifiCorp
4 d/b/a Pacific Power (PacifiCorp or company).
5 A. My name is Charity R. Spires and my business address is 825 NE Multnomah Street,
6 Suite 2000, Portland, Oregon 97232. I am currently employed as Low Income
7 Project Manager. I am testifying for PacifiCorp d/b/a Pacific Power (PacifiCorp or
8 the company).
9 Q. Briefly describe your responsibilities at PacifiCorp.
10 A. I currently manage a variety of programs available to PacifiCorp’s customers with
11 limited incomes including low income weatherization, bill assistance discounts, and
12 fuel funds (donation) program such as Project HELP in California.
13 Q. Briefly describe your education and business experience.
14 A. I received an Associate of Arts degree from Portland Community College in 1992 and
15 continued my education at Portland State University. I joined the Company in
16 October 1996 and have held positions in the Customer Service, Regulations, and
17 Energy Assistance Programs. I began managing low income programs in all of
18 PacifiCorp’s six states in March 2019.
19 Q. Have you testified in previous regulatory proceedings?
20 A. No.
21 Q. What is the purpose of your testimony?
22 A. The purpose of my testimony is to respond to the prepared testimony of the
23 California Public Advocates Office and the prepared testimony of Energy Efficiency 1 Council and Free Energy Savings Company LLC filed in this proceeding.
2 Q. Does this conclude your statement of qualifications?
3 A. Yes.
APPENDIX B STATEMENT OF QUALIFICATIONS OF ELAINE M. PRAUSE ON BEHALF OF PACIFICORP
1 PACIFICORP
2 WITNESS QUALIFICATIONS OF ELAINE M. PRAUSE
3 Q. Please state your name, business address, and present position with
4 PacifiCorp d/b/a Pacific Power (PacifiCorp or company).
5 A. My name is Elaine M. Prause and my business address is 825 NE Multnomah
6 Street, Suite 2000, Portland, Oregon 97232. I am currently employed as a
7 Senior Planning Manager within Customer Solutions. I am testifying for
8 PacifiCorp d/b/a Pacific Power (PacifiCorp or the company).
9 Q. Briefly describe your responsibilities at PacifiCorp.
10 A. As Senior Planning Manager I am responsible for the identification,
11 quantification, valuation and development of demand side resource opportunities.
12 In this role I provide analysis and information critical for consideration in
13 integration resource planning and resource acquisition of the Company’s demand
14 side management programs. I am responsible for the technical analysis and
15 cost/benefit analysis of new programs or changes to existing programs,
16 maintaining relevant measure performance assumptions, and making necessary
17 measure assumption changes due to program evaluation information, changing
18 market conditions and/or advancing codes and standards.
19 Q. Briefly describe your education and business experience.
20 A. I earned a Bachelor of Science degree in Mechanical Engineering from Lehigh
21 University and a Master of Science in Environmental Management from Portland
22 State University. My experience spans twenty three years in roles ranging from
23 Hydro Operations Engineer and Integrated Resource Planning Lead Analyst at
24 PacifiCorp, to Senior Manager of Planning at Energy Trust of Oregon, to Deputy 1 Director of Staff at the Public Utilities Commission of Oregon and now as Senior
2 Planning Manager of Customer Solutions at PacifiCorp.
3 Q. Have you testified in previous regulatory proceedings?
4 A. No.
5 Q. What is the purpose of your testimony?
6 A. The purpose of my testimony is to respond to the prepared testimony of the
7 California Public Advocates Office and the prepared testimony of Energy
8 Efficiency Council and Free Energy Savings Company LLC filed in this
9 proceeding.
10 Q. Does this conclude your statement of qualifications?
11 A. Yes.
APPENDIX C STATEMENT OF QUALIFICATIONS OF DEREK OLIJAR ON BEHALF OF LIBERTY UTILITIES LLC
1 LIBERTY UTILITIES (CALPECO ELECTRIC) LLC
2 QUALIFICATIONS AND PREPARED TESTIMONY
3 OF DEREK OLIJAR
4 Q. Please state your name and business address for the record.
5 A. My name is Derek Olijar and my business address is 701 National Avenue, Tahoe Vista,
6 California 96148.
7 Q. Briefly describe your present responsibilities at Liberty Utilities (CalPeco Electric) LLC.
8 A. I am a Rates Analyst. I manage the CARE Program as well as perform other regulatory
9 duties as assigned.
10 Q. Briefly describe your educational and professional background.
11 A. I am currently pursuing a Bachelor of General Studies degree at University of Nevada,
12 Reno. I have an Associate of Arts degree from Truckee Meadows Community College. I
13 have worked in the utility industry for over 12 years. I have certificates in Energy
14 Management and Solar design and Installation. Before working in the utility industry, I was a
15 California licensed Roofing Contractor.
16 Q. What is the purpose of your testimony in this proceeding?
17 A. The purpose of my testimony in this proceeding is to provide information regarding the
18 CARE Program.
19 Q. Was this material prepared by you or under your supervision?
20 A. Yes, it was.
21 Q. Insofar as this material is factual in nature, do you believe it to be correct?
22 A. Yes, I do.
23 Q. Insofar as this material is in the nature of opinion or judgement, does it represent your best
24 judgement?
25 A. Yes, it does.
A-1
1 Q. Does this conclude your qualifications and prepared testimony?
2 A. Yes, it does.
A-2
APPENDIX D STATEMENT OF QUALIFICATIONS OF BREANNA KELLY ON BEHALF OF LIBERTY UTILITIES LLC
1 LIBERTY UTILITIES (CALPECO ELECTRIC) LLC
2 QUALIFICATIONS AND PREPARED TESTIMONY
3 OF BREANNA KELLY
4 Q. Please state your name and business address for the record.
5 A. My name is Breanna Kelly and my business address is 933 Eloise Ave, South Lake Tahoe,
6 CA 96150.
7 Q. Briefly describe your present responsibilities at Liberty Utilities (CalPeco Electric) LLC.
8 A. I am an Energy Efficiency Coordinator. I manage the Energy Efficiency Programs and the
9 Energy Savings Assistance (ESA) Program.
10 Q. Briefly describe your educational and professional background.
11 A. I am currently pursuing a Bachelor of Science, Business Management Degree. I have
12 worked in the utility industry for over 4 years.
13 Q. What is the purpose of your testimony in this proceeding?
14 A. The purpose of my testimony in this proceeding is to provide information regarding the
15 Energy Savings Assistance (ESA) Program.
16 Q. Was this material prepared by you or under your supervision?
17 A. Yes, it was.
18 Q. Insofar as this material is factual in nature, do you believe it to be correct?
19 A. Yes, I do.
20 Q. Insofar as this material is in the nature of opinion or judgement, does it represent your best
21 judgement?
22 A. Yes, it does.
A-1
1 Q. Does this conclude your qualifications and prepared testimony?
2 A. Yes, it does.
A-2
APPENDIX E STATEMENT OF QUALIFICATIONS OF NGUYEN QUAN, PHD ON BEHALF OF BEAR VALLEY ELECTRIC SERVICE, INC.
APPENDIX E
Nguyen Quan, PhD
Statement of Qualifications
My name is Nguyen Quan and my business address is 630 East Foothill Blvd, San
Dimas, CA 91773. I am an economist with more than 25 years of experience in teaching, technical studies, project management, executive level consulting and regulatory compliance.
Presently, I am a Regulatory Affairs Manager at Golden State Water Company, San Dimas,
California. Prior to joining Golden State Water Company, I co-founded Digital Safetynet, Inc., a management and economic consulting firm. Through the years, I have conducted economic analysis for various industries including professional sports, airlines, consumer electronics, manufacturing, electric and gas, environmental, insurance, telecommunications, health care, public health and have performed antitrust analysis in mergers and acquisitions. I have also managed large federally funded projects for public health state agencies associated with environmental health risks and epidemiology. I have delivered numerous economic expert testimonies and support studies at proceedings, including environmental damages, postal rates, electric utility mergers and alleged anti-competitive behaviors on behalf of clients before federal and various state regulatory agencies, and have numerous publications. In addition to working at the California Power Exchange in its Compliance Unit, earlier in his my career I was Principal at Putnam, Hayes & Bartlett Economic and Management Counsel and a
Consultant at National Economic Research Associates. I have taught at Case Western
Reserve University, and the University of Detroit. I am currently teaching at UCLA Extension.
I hold a B.S. in Chemistry from the University of California, Los Angeles, an M.A. in Economics from University of Detroit and a Ph.D. in Economics from Michigan State University.
I am the author of numerous journal articles on applied statistics, regulation, electricity, public finance, the economics of labor unions and the economic development of countries. I have published in The Electricity Journal, Public Utilities Fortnightly, Energy Power Risk
Management, The Journal of Business and Economic Statistics, The Journal of Development
Economics, The Journal of Behavioral Economics, Industrial Relations, Southern Economic
Journal, Weltwirtschaftliches Archiv, and elsewhere.
APPENDIX F STATEMENT OF QUALIFICATIONS OF MICHAEL LAMOND, ON BEHALF OF ALPINE NATURAL GAS OPERATING COMPANY NO. 1 LLC APPENDIX F TO JOINT REBUTTAL TESTIMONY ALPINE NATURAL GAS OPERATING COMPANY NO. 1, LLC STATEMENT OF QUALIFICATIONS OF MICHAEL LAMOND
Q 1 Please state your name and business address. A 1 My name is Michael Lamond, and my business address is 15 St. Andrews Road, #7, Valley Springs, CA 95252. Q 2 By whom are you employed and what is your job title. A 2 I am the Administrator/CFO of Alpine Natural Gas Operating Company No. 1, LLC (“Alpine”) Q 3 Please briefly describe your job responsibilities. A 3 I am responsible for all operations of Alpine. Q 4 Please summarize your educational background and relevant business experience. A 4 I have a Bachelor’s Degree and have operated Alpine since its inception in 1999. Q 5 Have you previously testified before any regulatory commission? A 5 No Q 6 What is the purpose of your testimony? A 6 The purpose of my testimony is to respond to the prepared testimony of the California Public Advocates Office and the prepared testimony of Energy Efficiency Council and Free Energy Savings Company LLC filed in this proceeding. Q 7 Does this conclude your statement of qualifications? A 7 Yes.