California Alternate Rates for Energy (CARE) Program Plan and Budgets Proposal for the Program Cycle

Transcription

1 Application No.: Exhibit No.: Witnesses: A.1-- SCE-0 Jessica Lim Shahana Samiullah Tory Weber (U -E) California Alternate Rates for Energy (CARE) Program Plan and Budgets Proposal for the Program Cycle Before the Public Utilities Commission of the State of California Rosemead, California November 1, 01

2 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle Table Of Contents Section Page Witness I. Introduction...1 T. Weber II. SCE s CARE Program Proposal... A. CARE Program Background History... CARE Program Summary... Program Eligibility Guidelines... SCE s Current Proposal Is Designed To Increase CARE Enrollments... a) b) CARE Program Proposal and Plans... SCE s Proposal Is Designed To Maintain High CARE Penetration... (1) () Increasing New Customer Enrollments... Decreasing Existing Customer Attrition... c) d) e) Household Enrollment Projections... Changes from Prior Years... Consideration of New Strategies and Best Practices... B. CARE Program Goals and Budgets for the 01, 01 and 01 Program Years Program Activities And Participation Goals... Historic CARE Participation... Enrollment Variances and Challenges... -i-

3 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle Table Of Contents (Continued) Section Page Witness.. SCE s CARE Proposal s Alignment with the Commission s 0 Percent Penetration Goal... Details of SCE s proposal and plans for the upcoming program cycle are presented in Section II.B. and in Section II.B..Existing Program Elements and Strategies To Be Continued... a) b) c) d) Outreach...1 Enrollment...1 Recertification...1 Verification New Program Elements To Be Implemented in the Program cycle...1 Proposed Pilots...1 CARE Budget...1 Household Enrollment Forecast...1 Requests For Exemptions...1 C. Program Delivery Existing Strategies...1 J. Lim. Post Enrollment Verification (PEV) Long Term Probability Model...1 S. Samiullah a) b) c) CARE Probability Models...1 Improvements For The Program Cycle...1 Improving CARE Income Verification Request Response Rates...1 -ii-

4 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle Table Of Contents (Continued) Section Page Witness d) e) Customer Factors Indicating CARE Eligibility and Ineligibility...1 Implementation of PEV Procedures...1 (1) () () Random Screening of One Percent of Customers Prior To Model Screening...0 Probability Model Screening of Remaining CARE Customers...0 PEV Screening Forecast Targeting the Rural Population...1 Targeting High Poverty Areas (Income less than 0 percent of federal poverty guidelines)... Other New and Proposed Strategies... New and Proposed Strategies to Reach the Hardto-Reach... Leveraging with California Department of Community Services and Development (CSD)... D. Program Administration... T. Weber E. F. G. H. Other CARE Program Elements Program Delivery... Coordination Between CARE and Lifeline Program... Cooling Centers... Outreach Report Improving Outreach...0 Outreach Efforts To Achieving Program Participation Goals Outreach Spending Comparisons...1 -iii-

5 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle Table Of Contents (Continued) Section Page Witness I. Pilots...1 J. Studies...1 S. Samiullah K. CARE Program Budget... T. Weber CARE Program Budget Strategies Actual Expenditures Actual Average Cost Per Household... Tracking Program Costs... L. M. N. Revenue Requirement and Rate Impacts... AB Marketing, Education & Outreach... General Report Program Accomplishments and Challenges... a) b) Outreach... Challenges.... Customer Complaints And Concerns... Appendix A Witness Qualifications Appendix B CARE Program Excel Templates (Appendix B) Attachment B-1 CARE Proposed Program Budget (Appendix B) Attachment B-1a Authorized Budget and Expenditures (Appendix B) Attachment B- CARE and ESAP Rate Impacts - Gas (Appendix B) Attachment B- CARE and ESAP Rate Impacts - Electric -iv-

6 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle Table Of Contents (Continued) Section Page Witness (Appendix B) Attachment B- CARE Outreach and Penetration Information (Appendix B) Attachment B- CARE Estimated Participation (Appendix B) Attachment B- CARE Low Income Customer Usage Levels (Appendix B) Attachment B- CARE Pilots and Studies (Appendix B) Attachment B- CARE Program Summary of Proposed Changes (Appendix B) Attachment B- CARE Projection of Verifications -v-

7 SCE-0 CARE Program Plan and Budgets Proposal for the Program Cycle List Of Tables Table Page Table II-1 SCE Projected Estimated Eligible and Forecasted Participating CARE Customers... Table II- SCE Historic Estimated Eligible and Participating CARE Customers... Table II- Proposed CARE Budget...1 Table II- 01 and 01 CARE Outreach Budget and Expenditure...1 Table II CARE Program Budgets and Expenditures... -vi-

8 I. Introduction In this exhibit, Southern California Edison Company (SCE) provides an overview of its proposed California Alternate Rates for Energy (CARE) Program for the program cycle 01-01, including program goals and budget. During this period, SCE plans to continue its efforts to encourage all eligible and willing customers to participate in CARE while protecting ratepayers from subsidizing ineligible CARE participants. Through continued use of tools such as categorical eligibility, SCE will continue to market opportunities for customers to self-certify their eligibility and enroll into CARE. In order to make it easier to participate while reducing enrollment costs, SCE will encourage eligible customers to use computers or smart-phones to enroll in CARE and recertify eligibility through SCE s website, SCE.com, while continuing to provide a wide variety of traditional channels for customers lacking access to these technologies. (See Section II.A. and Section II.A. for a description of the multiple channels and languages available to SCE customers enrolling in CARE.) In addition to its enrollment efforts, SCE will continue to target high-use CARE customers for income verification in order to make sure only eligible customers continue to participate in the program. SCE s CARE request includes continuation of the Community Help and Awareness of Natural Gas and Electricity Services (CHANGES) pilot in up to a determination of the pilot s effectiveness in reaching limited English proficient (LEP) customers, and activities to support extreme-heat cool centers operated by counties within SCE s service area. The details of SCE s CARE Program proposal are presented in Chapter II of this exhibit. As described in Exhibit SCE-01, SCE s testimony is structured consistent with California Public Utilities Commission (Commission or CPUC) guidance in D , with specific requirements contained in Attachment Q of that decision (hereafter referred to as the Guidance Document) 1 shown in boxes throughout the exhibit below. 1 D , dated August 1, 01, Attachment Q, as modified by the October 1, 01 Proposed Decision in Application (A.)

9 II. SCE s CARE Program Proposal In this section, SCE provides the details of its plans for the CARE Program for the program cycle, including proposed program goals, budget, and implementation planes as specified in the Guidance Document. A. CARE Program Background 1. History Provide a brief history of the CARE Program and how it helps low-income customers, how it is funded and how the program has changed over the years, including any prior guidance given by the Commission. In 1, the Commission issued D.-0-0 and D.-0-0, which adopted the Low- Income Rate Assistance (LIRA) program to provide rate assistance to customers with the greatest need. At that time, the LIRA program provided a 1 percent discount to eligible customers, with program eligibility established at percent of Federal Poverty Guidelines (FPG) using General Order 1, originally written for the Universal Lifeline Telephone Service, as a benchmark. In D.-0-0, the Commission expanded the LIRA program to include qualified group living facilities. In 1, the Commission issued D.--0, which changed the program name to California Alternate Rates for Energy. The Decision also expanded eligibility to housing for migrant farm workers, agricultural employees, and employee housing. In October 1, the California Legislature and Governor partially restructured the electricity industry through the passage and enactment of Assembly Bill (AB). The legislation also established a non-by passable surcharge to enable ongoing funding for public purpose programs that were deemed to be in the public interest in the areas of energy efficiency, research and development, renewable energy, the low-income assistance programs, Energy Savings Assistance (ESA) Program, and CARE. The Commission responded to the legislation with the establishment of the Public Goods Charge (PGC) in 1, which was applied to all rate schedules for the purpose of funding CARE and other programs.

10 In D , the Commission raised the CARE income guidelines from percent to 1 percent of FPG and increased the CARE discount from 1 percent to 0 percent. In 00, the Commission established the current CARE penetration goal of reaching 0 percent of eligible and willing low-income customers. The Commission, in D.0-0-0, ordered that the CARE discount be offered to occupants of migrant farm labor centers. In 00, the Commission issued D.0--0, which increased the upper limit of CARE income eligibility from 1 percent to 00 percent of FPG. In addition, the alignment of CARE and ESA Program income guidelines at 00 percent of FPG created new opportunities to jointly market the two programs. In 00, the Commission directed the utilities to provide the CARE discount to common areas of nonprofit group living facilities without regard to metering arrangements. AB was enacted in 00 and required the Commission to approve a plan for the investor-owned utilities (IOUs) to improve master-metered tenant access to CARE Program discounts by December 1, 00. The Commission, in D , directed the utilities to file affidavits certifying compliance with AB through activities such as directly accepting CARE applications from tenants of a mobile home park or similar complex, and directly notifying and providing renewal applications to such tenants that are existing CARE customers. The utilities were also directed to provide each master-meter customer with a list of tenants who are approved to receive discounts pursuant to the CARE Program and identify those tenants added to or deleted from CARE Program eligibility since the previous billing cycle. In accordance with D , SCE filed its compliance affidavit in January 00. In D.0--01, the Commission directed the IOUs to expand categorical eligibility to programs included in the California LifeLine Telephone Program (CLP). In D.1-0-0, a more stringent income verification process was introduced to CARE participants whose usage is consistently above 00 percent of their baseline allocation. The Commission s intent was to make sure that only qualified customers continue to receive the discounted rate and that the subsidy burden on the non-care customers is maintained at the appropriate levels. Senate Bill (SB), enacted in 01, adopted similar requirements for high-use customers. SCE implemented a soft version of this process in 01 and went live with the systematic version in

11 December 01. SCE continues to income and categorically verify customers through its traditional Program Enrollment Verification (PEV) process via its disproportionate stratified random sampling model. In 01, AB was enacted setting the CARE effective discount from 0 percent to percent from the same billed usage for electricity as non-care customers, and setting eligibility for one-person households at the income guideline for two-person households.. CARE Program Summary Provide a summary of the CARE Program, including descriptions of (i) the legal framework of CARE Program, and (ii) the eligible population. The CARE Program provides a monthly energy bill discount to customers that meet the program requirements. Residential customers that meet the program requirements are eligible to receive a discount that reduces bills by 0 - percent. In addition, Group Living Facilities that meet other special program requirements are also eligible for the discount. Legislative Policy guiding the CARE Program goes back years and is embodied in Cal. Pub. Util. Code sections furthered discussed in Exhibit SCE-01, Section I.C. SCE and the other California IOUs use the joint utility methodology adopted by the CPUC in D to determine the eligible population for the CARE Program. This method produces estimates of the total number of households that are technically eligible for the program. Athens Research produces population estimates for the California IOUs based on analysis of census and other data sources. Statewide, percent (. million households) of the population are eligible for the CARE Program.. Program Eligibility Guidelines Provide a summary of the program eligibility guidelines, including income, categorical eligibility qualifications, self-certifications, and the process for getting enrolled. Identify any proposed changes from the framework and implications associated with the recent adoption of AB (Perea 01). The CARE eligibility guidelines allow participation of customers with income up to 00 percent of FPG. The CARE income guidelines are updated annually on June 1 to reflect updates to the

12 FPG. The Family Energy Rate Assistance (FERA) eligibility guidelines allow participation for households with at least three members with a combined income immediately above the CARE limit up to 0 percent FPG. Income guidelines are determined by total number of persons in the household and total combined annual income. The CARE residential rate is available to customers that meet the income guidelines and can only be applied towards a primary residence. The CARE Program is also available to group-living facilities that have tax exemption under Internal Revenue Code section 01(c)(), have a minimum of 0 percent of the energy consumed at the facility used for residential purposes, and, as part of the annual recertification process, are able to explain how the funds were used for direct benefit of the residents. Certain types of agricultural employee housing facilities may also qualify for the CARE rate. SCE residential customers that receive assistance through pre-selected government and community-funded programs are also eligible for CARE through categorical eligibility. These customers are not required to provide income information to determine eligibility; rather, they can demonstrate their eligibility by indicating enrollment into certain means-tested programs which include: Medi-Cal or Medicaid, food stamps or the U.S. Department of Agriculture s Supplemental Nutrition Assistance Program (CalFresh/SNAP, formerly Food Stamp Program), the U.S. Department of Health & Human Services Temporary Assistance for Needy Families (TANF) and Tribal TANF, the U.S. Department of Agriculture s Women, Infants and Children Program (WIC), Healthy Families A&B, the Low Income Home Energy Assistance Program (LIHEAP), Social Security Supplemental Security Income (SSI), National School Lunch program, Bureau of Indian Affairs General Assistance, and Head Start Income Eligible (Tribal Only). In order to qualify for CARE or FERA, the customer account holder or authorized person in the household must self-certify the household s eligibility into the CARE or FERA programs by either meeting specific income guidelines based on household size and household income or, for CARE, indicating their current enrollment in one of the categorical programs indicated above. Customer declaration of program eligibility, or self-certification, is all that is required for program enrollment, in accordance with D.-0-0.

13 SCE offers eligible customers the ability to submit enrollment applications for the CARE/FERA programs through multiple channels, including paper, by phone call to SCE s Customer Contact Center, direct online enrollment on SCE.com, direct marketing campaigns including third-party interactive voice response (IVR) campaigns, and capitation agencies through outreach/community efforts. Customers are also able to enroll in these programs through multi-language applications including English, Chinese, Korean, Cambodian, Spanish, and Vietnamese, and have the option of downloading a large-font applications through SCE s website, SCE.com. All channels include similar processes for enrollment including eligibility through self-certification or categorical eligibility. Per AB, SCE revised the CARE Program eligibility requirements on January 1, 01, to allow one-person households eligibility to be based on two-person household guideline levels. This legislation also required the CARE discount be no less than 0 percent and no more than percent of the revenues that would have been produced for the same billed usage by non-care customers and that the entire discount be provided in the form of a reduction in the overall bill for the eligible CARE customer. Consistent with this requirement, SCE CARE customers currently receive an average discount within the 0 percent to percent range in the form of a reduction in the overall bill. SCE is not proposing any revisions to the CARE eligibility guidelines in Please see Section II.M for SCE s discussion of AB.. SCE s Current Proposal Is Designed To Increase CARE Enrollments a) CARE Program Proposal and Plans Explain your proposal and plans for the CARE Program during the upcoming budget cycle. In the program cycle, SCE will continue to pursue new CARE customer enrollments for all eligible and willing customers by continuing to leverage partnerships with local service providers, energy leaders, local governments and communities, community-based organizations (CBOs), and third parties. SCE will also integrate its CARE/FERA outreach messaging with other demand-side management (DSM) programs and services. In addition to providing outreach to new participants, SCE will also focus on decreasing attrition by enhancing communications to CARE

14 participants who fail to return a CARE application during the recertification process, or do not respond to a verification request. Details of SCE s proposal and plans for the upcoming program cycle are presented in Section II.B.. and Section II.B.. b) SCE s Proposal Is Designed To Maintain High CARE Penetration Discuss how the elements and strategies in the proposed CARE Program are specifically designed to reach the penetration goal of 0%. The Commission in D stated, that 0% is the goal toward which the IOUs shall strive, rather than a hard and fast requirement. During 01-01, SCE will continue to strive for the 0 percent CARE participation goal. However, SCE s CARE penetration rate has declined from percent at the end of 0 to percent as of September 01 due to a large number of customers not responding to requests for income verification. Additionally, compliance obligations with respect to the Telephone Consumer Protection Act of ( ) had an impact on SCE s ability to reach potential customers through automated outbound calling in 01. Obtaining and managing the appropriate permissions under TCPA for calls to customers regarding the CARE Program have required increasingly greater effort and expense. SCE expects these factors to persist in program cycle. To overcome these challenges, SCE plans to use a two-pronged approach to target increased participation, including: (1) increasing new customer enrollments, and () decreasing existing customer attrition. To implement this plan and make progress towards the Commissions CARE participation goal, SCE is seeking increased outreach funding in (1) Increasing New Customer Enrollments One of the primary barriers to new customer enrollments in 01 has been SCE s more cautious approach to outbound calling efforts due to the increased effort and expense D.0--01, p. 1. The Commission established the 0 percent CARE penetration rate for all IOUs in D (Ordering Paragraph ). In D.1-0-0, the Commission retained this goal (see p. ). CFR Part,.0.

15 required to obtain and manage the appropriate permissions under TCPA for calls to mobile phones. The CARE Program has traditionally relied on the outbound calling approach as one of the most costeffective methods to target new customers; however, this more cautious approach has limited SCE s outbound calling campaigns to customers mobile phones in 01. In 01-01, SCE will utilize alternate forms of communication to engage new customers, and previously successful marketing channels, such as digital channel and social media. In addition, SCE will also use traditional communication modes such as print, mail, and return mail. Lastly, SCE will develop a specific marketing plan to target underpenetrated hard-to-reach groups, such as low income customers with higher usage and lower income, customers at 0 percent of Federal Poverty Line Guidelines (FPG) rural populations, non- English speakers, and high poverty areas. See Section II.C. for additional detail. () Decreasing Existing Customer Attrition Attrition has recently outpaced annual CARE enrollments, which poses a significant barrier to reaching penetration goals. This trend is due to increased verifications, as approved in Advice 1-E, and Advice -E-A, and is further compounded by the low response rate of High Usage Post Enrollment Verification (HU PEV) customers. SCE is experiencing a percent drop off for HU PEV verses percent drop off for traditional Post Enrollment Verification (PEV). To reduce attrition, SCE will increase communications to CARE participants that fail to return a CARE application during the recertification process, or do not respond to a verification request. In addition, to address the increased number of HU PEV drop offs, SCE will proactively reach out to customers who are in danger of reaching 00 percent of baseline usage. For additional detail on new program enhancements designed to minimize attrition see Section II.B.. During the verification process, customers that fail to respond to SCE s request for proof of eligibility are subsequently dropped from the program. Advice Letter 1-E established a seven percent maximum CARE income verification rate effective December, 01. Advice Letter -E-A maintained the seven percent cap but indicated high-use verifications are not subject to the seven percent cap, effective October, 01.

16 c) Household Enrollment Projections Provide an estimate of the number of households projected to be enrolled in the program years, along with the overall budget requested to meet this goal. SCE discusses the estimated number of households to be enrolled in the program years in Section II.B.1. and the overall budget requested in Section II.B.. d) Changes from Prior Years Explain how your current proposal has changed from that in prior years, if any. In the upcoming program cycle, SCE will focus on the subgroups of the hardest to reach populations with the use of new data sources. This will provide more creative and robust outreach to low income customers that may have not been specifically targeted in the past. More information is provided in Section II.C.. e) Consideration of New Strategies and Best Practices Based on your review of all of the study findings and working groups recommendations and in light of new technologies and opportunities for partnership and collaboration, are there any new strategies or best practices that could be considered for inclusion in this program that could benefit California customers? A description of any new program elements and strategies to be implemented in is described in Section II.B.. SCE s proposal to leverage partnerships with CLP providers is discussed in Section II.F. B. CARE Program Goals and Budgets for the 01, 01 and 01 Program Years In the CARE Program Goals section of the application, the IOUs must provide a description of the program requests, including: 1. Program Activities And Participation Goals [Provide a] detailed description of all proposed program activities and program participation goals for each year. Include the number of eligible households.

17 Details of SCE s proposal and plans for the upcoming program cycle are presented in Section II.B.. and in Section II.B.. Given the recent trend of declining CARE participation over the cycle, SCE must increase its enrollment goals to compensate for customer attrition by the end of the cycle. SCE s CARE participation goals are provided in Table II-1 below. Table II-1 SCE Projected Estimated Eligible and Forecasted Participating CARE Customers Line No. Description Year End Participants 1,0, 1,,0 1,, Year End Estimated Eligible 1,0,01 1,,1 1,0, Year End Penetration Rate % % % 1. Historic CARE Participation [Provide a] summary of actual participant data from 01 and 01, including CARE participant counts and percentage rates for program enrollment. Also provide estimated participation data for 01 and provide a comparison to the benchmarks established by the Commission. As seen in Table II-, actual participant data from 01 through 01 illustrates the continued trend of decreasing participation and penetration that SCE is seeking to reverse in the upcoming program cycle. Table II- SCE Historic Estimated Eligible and Participating CARE Customers Line No. Description * 1 Year End Participants 1,0,0 1,,0 1,, Year End Estimated Eligible 1,,1 1,1, 1,0, Year End Penetration Rate % % % *Projection Enrollment Variances and Challenges [Provide a] discussion of any significant variations in enrollment from year to year and unique issues, if any, of your service area that presents challenges toward reaching the penetration goals of enrollment established by the Commission. See Table II-1 above for a projection of annual CARE enrollments for

18 Given the higher rates of attrition due to increased verification, SCE is seeking to increase enrollment rates in the cycle as described Section II.A..b).. SCE s CARE Proposal s Alignment with the Commission s 0 Percent Penetration Goal [Provide a] discussion of how the utility s CARE Program goals for the CARE Program align with Commission directives of reaching the penetration goal of 0%. The Commission in D retained the 0 percent CARE penetration goal but set the main focus on improving strategies to maintain and increase current penetration rates wherever feasible, and to maintain the integrity of the program with the new high-use verification rules. SCE is requesting increased funding in for outreach with the goal of increasing CARE enrollment. The increased funding will increase administrative costs at a modest level, but should be sufficient to offset most of the expected attrition due to the increased verifications and high-use verifications. SCE will continue to align with Commission directives that have been successful in the past, such as direct marketing and local community outreach to under-penetrated areas, such as hard-to-reach. Please see Section II.C... Details of SCE s proposal and plans for the upcoming program cycle are presented in Section II.B. and in Section II.B..Existing Program Elements and Strategies To Be Continued [Provide a] description of your utility s existing program elements and strategies to be continued. SCE will continue strategies that have been historically successful in the past into the program cycle. D.1-0-0, Conclusion of Law (COL) #1: For the budget cycle, we should retain the 0% CARE penetration goal; however, the IOUs main focus for this cycle should be to update their activities to focusing and improving their strategies to (1) aggressively carryout outreach efforts to maintain and increase the current penetration rates, wherever feasible, and () ensuring the integrity of the CARE Program with the new rules being set forth in this decision.

19 a) Outreach SCE will continue outreach strategies that experienced success in 01 01, with a strong emphasis on hard-to-reach subgroups. SCE further discusses how it will reach this subgroup in Section II.C.. SCE will also continue digital marketing tactics, creative use of data analytics, multi-cultural digital and print media campaigns, and social media as presented in Section II.N.1. Historically SCE has also participated in community events to provide customers with information on the CARE and ESA Programs. SCE plans to continue these efforts into SCE s goal when feasible is to interact with CARE customers in the language of their choice for all program communications after program enrollment (i.e., recertification and PEV notices). SCE will continue to translate program letters into multiple languages so that customers may receive follow-up communications in their preferred languages as the Commission has historically recommended. SCE displays the total CARE savings in the customer s SCE bill to identify for CARE customers the total amount they saved as a result of being enrolled in CARE. Increased recognition within the bill of the CARE discount value can help reduce program attrition by increasing program visibility and associated savings. Through annual bill inserts and other strategies described elsewhere in this exhibit, SCE will continue efforts to increase awareness among non-participating customers that are CARE-eligible. In 01, new customer program phone call alerts for HU PEVs were implemented to improve customer communications and reduce program attrition. These alerts will continue through the program cycle. In addition to letters used to notify customers that they are required to verify their eligibility, new IVR alerts were implemented advising customers of the importance of replying to the PEV request by the requested due dates to remain enrolled in the CARE Program without interruption. SCE will continue to support the special needs of its hearing and visually impaired customers using the following processes: Providing customers who are identified as visually impaired, with CARE applications in large font. 1

20 Contacting customers who are identified as hearing impaired in SCE's billing system through a teletypewriter or text telephone (TTY) device for all SCErelated customer phone calls. Providing a direct link to the Deaf and Disabled Telecommunications Program (DDTP) website on SCE.com. DDTP provides telephone communications access for all deaf and disabled Californians. Utilizing SCE.com, which has been designed to follow Web Content Accessibility Guidelines (WCAG), which removes technical barriers that prevent access to websites by people with disabilities b) Enrollment In the program cycle, SCE will continue to provide customers the opportunity to enroll into the CARE Program through multiple channels, such as paper, online (via SCE.com), and third-party IVR contractors. SCE will continue to leverage its Customer Call Center by allowing representatives to assist customers in submitting applications, or sending out paper applications if requested. SCE will also continue to partner with external entities to increase enrollment into the CARE Program. SCE will continue the Capitation Fee program, as authorized by the CPUC in D , which takes advantage of the opportunity to enroll eligible customers in the CARE Program while they are receiving other services from entities that assist low-income clients. Also, SCE will continue to collaborate with Southern California Gas Company (SoCalGas), Southwest Gas Company, Pacific Gas and Electric Company (PG&E), and local water utilities as directed in D to share CARE participant data electronically to assist customers to enroll in each utility s program. c) Recertification SCE proposes that customers continue to self-certify their eligibility based on meeting the CARE income guidelines or through participation in a categorical eligibility program. Customers are requested to recertify eligibility every two-years. The recertification process matches the self-certification process for enrolling into CARE. 1

21 SCE will continue to provide customers the opportunity to recertify enrollment in the CARE Program through multiple channels. Customers can recertify through: (1) an online form or () SCE s IVR system (in the language which they submitted their original enrollment application). SCE can also recertify a customer through data sharing with SoCalGas. d) Verification To maintain the integrity of the CARE Program, SCE will continue its verification process that, to date, has resulted in more than $ million in cost savings. SCE will continue to select up to seven percent each year of customers for PEV using SCE s Disproportionate Stratified Random Sampling (DSRS) model that was approved in Advice 1-E. Customers selected for PEV can provide income documentation or evidence of participation in an approved categorical eligibility program. SCE will continue to verify eligibility for High Usage (HU) customers according to the procedures in statute and adopted by the CPUC in D (SCE s HU PEV are not subject to the seven percent maximum established in Advice Letter E-A.) SCE currently focuses on the HU customer with usage at or above 00 percent of baseline in any billing cycle and those who have had usage at or above 00 percent of baseline in consecutive billing cycles. SCE requests continuing flexibility to address HU customers according to SCE s methodology as granted by the Commission in D New Program Elements To Be Implemented in the Program cycle [Provide a] description of any new program elements and strategies to be implemented, including estimates of budgets for these new approaches. During the program cycle, SCE plans to enhance its customer communications to decrease program drop offs. Enhancements include: D , p. : Moreover, although D requires ESA participation within days of notice following a PEV, the rule does not specify other required timelines including the timeline for the IOUs to provide notice to high usage customers. Thus, the rule allows each utility to flag and address high usage households according to their individual business models, including staffing resources and IT programming capabilities. 1

22 Development of a PEV page on SCE.com that will provide customers additional information on completing the process and allows customers to upload the required documents directly to a secured server. Outreach to a portion of customers that do not respond to PEV request through a direct mail survey asking customers to provide specific reasons why they chose not to respond to the request. The findings will be used to understand (and reduce) the high volume of PEV drop offs. Notifications to HU customers by contacting them with their usage information that may help them stay within the prescribed usage limits to avoid removal from the CARE Program. SCE expects to gain additional information in the program cycle on how these new outreach strategies perform and whether they are effective in enrolling and retaining CARE customers. Use of billing system data to support the HU PEV processes based on lessons learned and IOU best practices. SCE is exploring opportunities to provide personalized usage information related to CARE HU letters. Implement data analytics by leveraging SCE s own databases and customer intelligence which includes data from SmartConnect, program participation, communication channels, credit scores, payment history, and pertinent Census data (e.g., dwelling type) along with other external information sources to identify key customer attributes and segments to find the typically hardest to reach subgroups per the recommendations in the 01 Needs Assessment. Leveraged enrollments, recertifications and possibly verifications with the CLP. Please see Section II.F. for additional detail. Increased use of digital channels such as , outbound calling campaigns, text messaging, and social media for program-specific communications. To obtain customer permissions in compliance with state and federal consumer protection laws, 1

23 SCE will provide several ways for customers to opt-in, including SCE.com, SCE s Customer Communication Center interaction, and hard copy applications. SCE is also considering potential enhancements for implementation during the upcoming program cycle. Potential enhancements include: Explore other opportunities to improve HU PEV procedures based on lessons learned during the program cycle as well as from IOU best practices. SCE is currently conducting a thorough review of the HU PEV process (with Customer Call Center, Consumer Affairs, Marketing, Processing and other impacted internal organizations). Partnering with non-profit organizations to reach the hardest to reach subcultures (as identified in the 01 Needs Assessment). SCE is exploring opportunities to partner with.org to leverage CLP participants and create awareness of SCE s CARE and ESA Programs. Tracking multi-cultural outreach efforts utilizing landing page hits and source codes. SCE also plans to enhance the customer service system (CSS) to streamline CARE High Usage processes, in an effort to reduce end-to-end cycle time Exploring the opportunity to use its Customer Call Center to recertify customers over the phone. Please see Section II.E. for additional detail Proposed Pilots [Provide a] detailed description of any proposed pilots and/or studies to be conducted, including detailed proposed budgets. SCE is not proposing any pilots or studies during the program cycle.. CARE Budget [Provide your] utility's total requested budget of the portfolios for each year, and for the entire budget cycle. 1

24 To offset attrition due to increased verification, SCE will require additional resources in than the funding provided in D SCE s total requested budget is summarized in Table II- below. Table II- Proposed CARE Budget Line No. Description Total 1 CARE Administration $,0, $,1,0 $,1, $,,001 Subsidies & Benefits $ 1,, $,, $,, $ 1,,1, Total $,,1 $,0, $ 0,1,1 $ 1,0,, Budget. Please see Appendix B, Attachment B-1 for more details on SCE s Proposed CARE. Household Enrollment Forecast [Provide] Estimates of the total number of households to be enrolled for each year, and for the entire budget cycle. SCE s estimate of new CARE enrollments is approximately 0,000 annually in Requests For Exemptions [Provide] Requests for any exceptions, as necessary. SCE is not requesting any exceptions from its existing strategies and/or proposals within this Application. C. Program Delivery 1. Existing Strategies Discuss the mechanics of the program and provide a brief description of the strategies employed during that will be continued through 01-01, including a description of all activities performed by third-parties and other stakeholders. SCE discusses strategies employed during the program cycle that will be continued through in Section II.B.. 1

25 Post Enrollment Verification (PEV) Long Term Probability Model a) CARE Probability Models Discuss the results of both the interim and long term CARE probability models implemented during the program cycle. The results of SCE s Disproportionate Stratified Random Sampling (DSRS) Model show that it is very efficient at selecting customers who are less likely to be eligible for CARE or less likely to respond to PEV. Prior to implementing the DSRS Model (0), SCE removed only percent of the customers selected for PEV. Once implemented, the removal rate increased to percent in 01, 1 percent in 01 and 0 percent (estimated) in 01. b) Improvements For The Program Cycle Identify the factors used, any identifiable best practices, and explain how the results will be incorporated into the program cycle. At the end of each month, all individually metered CARE households are part of a population sampling frame with the exception of those with less than 0 days in the last billing period, those who have been verified within the previous two years, and those currently engaged in the PEV process. Factors used are: (1) electric usage level (mandatory selection of HU customers per SB & D.1-0-0); () estimated median neighborhood income level based on the proportion of CARE eligible households; () household size; () CARE enrollment channel (how the customer enrolled/recertified); and () length of time on CARE Program (< months on CARE, at least months on CARE). As a best practice, SCE is considering Proportional Hazards Modeling (Survival Analysis) for PEV. Survival Analysis will include customers who are currently engaged in the PEV process (which are not included in the existing Logit Regression Modeling approach). This will give a more holistic view of the CARE population, customer attrition, and ultimately give the model more information in predicting those customers who are more likely to fail PEV. Additionally, SCE will compare and contrast the results of both the Survival and Logistic Models to find points of convergence or divergence in the statistical findings. By doing so, 1

26 SCE hopes to gather a more complete profile of the patterns and trends in CARE customer attrition specifically as it relates to the PEV process. SCE requests flexibility to implement adjustments to the model in pursuit of the CPUC s verification objectives. c) Improving CARE Income Verification Request Response Rates Discuss the efforts and strategies your IOU will be implementing in the budget cycle to learn more about this customer segment and to decrease the number of CARE customers who fail to respond to income verification requests during the PEV process. SCE plans to follow up with the non-response customer segment to gain a better understanding of why customers do not respond to PEV requests. Additionally, SCE will mine available data to develop a basic socioeconomic and demographic profile that may eventually be used towards the development of a more scientific, systematic and targeted inquiry. d) Customer Factors Indicating CARE Eligibility and Ineligibility Describe how these [eligibility and ineligibility] factors relate to the findings in the Low Income Needs Assessment. Discuss whether these factors need to be updated to correspond with the Needs Assessment findings. Discuss the process your utility will employ to conduct this update. SCE is open to exploring other factors that can be used to enhance its DSRS PEV model. Upon review of the 01 Needs Assessment, SCE identified that the incidence of extreme/high poverty (at or below FPL) may be a factor that can be included in the sampling design in the future. SCE will examine this factor as it relates to geographic location, penetration rates by socioeconomic variables, and other relevant predictors of CARE eligibility to determine if this new factor would enhance the verification sampling in its ability to identify those who have a greater propensity to fail the eligibility verification process. SCE requests flexibility to implement any changes in a manner that is compatible with SCE s specific model. e) Implementation of PEV Procedures The IOUs long-term probability model advice letters illustrated some variation in the application of these tools, and some best practices are identified as well. Discuss how quickly, and at what cost, your utility would be able to implement the following PEV procedures: 1

27 (1) Random Screening of One Percent of Customers Prior To Model Screening Prior to probability model screening, require random selection of 1% of all CARE customers for post-enrollment verification? SCE does not view random selection of one percent of all CARE customers as a best practice. SCE s DSRS verification model applies random sampling to specified strata with probability of selection varying by stratum. All customers have some chance of being sampled through SCE s model, however, customers that are not eligible for CARE have a higher probability of being sampled. As with pure random sampling, in any month, all individually metered CARE households become part of a population sampling frame through SCE s DSRS model and are subject to selection. The costs for implementing one percent random selection are minimal and consist of a one-time modification to SCE s model. Implementing this practice, however, would reduce SCE s DSRS sampling in order to conform to SCE s seven percent verification cap. SCE s model is very efficient at covering the relevant predictive factors for verification failure. It is scientific, systematic, and efficient in its methodology. The model builds upon a solid base of empirical evidence on which hypotheses are tested in a logical fashion. The CPUC should not adopt one percent random verification as a best practice. () Probability Model Screening of Remaining CARE Customers Subject all remaining CARE customers (not including those on CARE Program for 0 days or less, or passing verification in the last months, or users with electric usage above 00% baseline who must undergo PEV separately per D.1-0-0) to your utility s individual probability models? As described in Section II.C..e)(1), SCE's current DSRS verification model subjects all individually metered CARE households as part of the population sampling frame with the exception of those with less than 0 days in the last billing period, those who have been verified within the previous two years, and those currently engaged in the PEV process. 0

28 () PEV Screening Forecast Using all past program data, project/estimate the total number of CARE customers that would be selected (by month, and by percentage of total CARE population) that would be required to undergo the PEV process using the above procedures as well as the projected administrative costs to facilitate implementation. Please see Appendix B, Attachment B- for the verification selection projection and the verification cost category in the budget table.. Targeting the Rural Population Identify specific underserved rural areas (by ZIP code or county, tribal area, or appropriate area), as discussed in the latest Needs Assessment or as additional analysis to assess rural population needs, and discuss what new strategies your utility will employ to better target and enroll those households. Include a discussion on your utility s strategies will be carried out in each area, if different. Similar to its outreach for ESA described in Exhibit SCE-0, Section B..b), SCE s ME&O will focus on community outreach through partner utilities and internal organizations, as well as a combination of mass and targeted marketing efforts. SCE will identify rural areas for targeted marketing with a focus on those ZIP codes and geographies with high potential but low penetration by leveraging customer intelligence, including internal usage data, credit scores, pertinent Census data, and other external data sources, coupled with advanced analytics (as described in greater detail in the previous section of this chapter). SCE will then develop targeted communications, such as direct mail, , and outbound calling to provide more customized messaging around CARE that will address specific barriers to participation and to encourage program enrollment. In particular, SCE will strongly consider direct mail (while maintaining cost), as this channel was identified as the most preferred by low-income individuals across segments. Information will also be provided in multiple languages to help extend the reach to language-dependent customers. Additionally, SCE s Local Public Affairs group (LPA) will continue its outreach to the Native American community and leadership within the SCE territory. LPA currently participates in weekly and monthly tribal outreach forums and will consult with SCE Marketing and ESA program 1

29 administration on Native American-specific materials and outreach activities to assist the low income segment on tribal lands.. Targeting High Poverty Areas (Income less than 0 percent of federal poverty guidelines) Identify the very high poverty areas within your service territory that are underserved (by ZIP code or county), and discuss what new strategies your utility will employ to increase CARE penetration in these areas. SCE plans to continue to use internal customer data and other external data sources, such as low-income eligibility estimates provided by Athens Research, to identify specific high poverty populations that should be exposed to both broad and targeted ME&O approaches. This information is subject to change as new data becomes available. SCE will increase efforts to target high-poverty areas through the use of mass media channels, such as bill messaging, digital advertising, search engine marketing (SEM), SCE.com, and social media to reach high poverty areas for general awareness. SCE plans to use internal customer data and other external data sources to identify specific high poverty populations that should be exposed to both broad and targeted ME&O approaches. To the extent needed for direct messaging, SCE will segment this data by ZIP code, tribal area, or other identified area. SCE will also consider coordinating with CLP providers, CBOs and faith-based organizations (FBOs), local government agencies involved in high poverty areas, and other relevant internal and external to develop marketing and outreach strategies. Ultimately, SCE is committed to finding and enrolling those most in need of the CARE discount.. Other New and Proposed Strategies Discuss the mechanics of the program and provide a brief description of new strategies that will be employed, including a description of activities performed by third-parties and other stakeholders. Marketing and outreach strategies will continue to be implemented through the program cycle to help enroll eligible customers. To reach customers, SCE will use a mix of delivery channels such as bill inserts, grassroots outreach, outbound calling, call center, , text messaging, SCE.com, media relations, targeted direct mail, educational initiatives and multi-culturally-