SUBJECT: Southern California Edison Company's Conforming Advice Letter as Ordered in Decision

Transcription

1 STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA December 28, 2017 Advice Letter 3585-E 3585-E-A Russell G. Worden Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, CA SUBJECT: Southern California Edison Company's Conforming Advice Letter as Ordered in Decision Dear Mr. Worden: Advice Letter 3585-E and supplemental 3585-E-A are effective as of May 3, 2017, per Resolution E-4885 Ordering Paragraphs. Sincerely, Edward Randolph Director, Energy Division

2 Russell G. Worden Managing Director, State Regulatory Operations April 3, 2017 ADVICE 3585-E (U 338-E) PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION SUBJECT: Southern California Edison Company s Conforming Advice Letter as Ordered in Decision In compliance with Decision (D) , Southern California Edison Company (SCE) hereby submits for filing its Conforming Advice Letter regarding its California Alternate Rates for Energy (CARE) and Energy Savings Assistance (ESA) Programs. I. PURPOSE This Advice Letter complies with the California Public Utilities Commission s (Commission or CPUC) directive in D (D or Decision) that each utility file a Tier 2 conforming Advice Letter within 60 days of the Decision to conform final program energy savings goals and budgets to the directives herein. 1 In this filing, SCE also provides the updated willingness to participate information and information related to Assembly Bill (AB) 327. II. BACKGROUND On November 18, 2014, SCE filed its application for the Energy Savings Assistance (ESA) and California Alternate Rates for Energy (CARE) Programs Plans and Budgets. Hearings on SCE s Application were held on June 17-18, 2015; and, workshops to discuss SCE s applications were held on June 19, 2015 and August 19, On August 16, 2016, Administrative Law Judge Colbert issued a Proposed Decision (PD) and Commissioner Sandoval issued an Alternate Proposed Decision (APD). 1 D , pp P.O. Box Rush Street Rosemead, California (626) Fax (626)

3 (U 338-E) April 3, 2017 On August 31, 2016, Commissioner Sandoval hosted an All Party meeting to discuss specific issues outlined in the APD. SCE filed comments on the PD and APD on September 6, 2016; and, reply comments on September 12, Prior to issuance of the final decision, there were two versions of the PD issued and four versions of the APD. On November 10, 2016, the Commission approved SCE s Low Income Application (A.) et al, which sets forth the program plans and budgets for the ESA and CARE Programs for Program Years Specifically, D directs SCE to submit a conforming advice letter to reflect program energy savings goals, budgets, costs for approved measures, penetration goals, cost effectiveness values, and any other update factors. 3 SCE is directed to recalculate the number of ESA Program willing and feasible with the new willing to participate factor, ESA and CARE programs budget projections for reflecting the adjustments and new program elements adopted in the Decision, and information related to AB 327, as directed in the Decision. Based on recent direction for ESA and CARE Program audits, SCE has incorporated costs for the ESA and CARE Program audits, and proposed audit budgets for III. SUMMARY The Conforming Advice Letter requirements are extensive with various mandated implementation dates that require thorough coordination and integration of SCE s CARE and ESA Programs with its internal Energy Efficiency (EE), Demand Response (DR), Marketing & Outreach (M&O), Information Technology (IT), and Budget/Finance teams, and coordination between the four investor-owned utilities (IOUs), participating program contractors, Department of Community Services and Development (CSD), California Lifeline, water agencies, and other entities. As directed in D , SCE s conforming Advice Letter includes the following information: ESA and CARE Program budgets for , including the 2017 EE Potential Study, and any updated program costs attributable to measures approved in D ; Technology options by measure which will enable participation in DR and/or alternative tariffs eligible for CPUC energy education requirements and consistent with the requirements of AB 327; 2 D issued on November 21, 2016, p.6. 3 D , pp

4 (U 338-E) April 3, 2017 Multifamily Housing Issues, including o Owner or authorized representative affidavit process for buildings in a PRIZM Code, census tract, or federally recognized tribal reservation or zone where 80 percent of households are at or below 200 percent of federal poverty guidelines; and o Establishing technical assistance programs for low income multifamily EE retrofits in the areas affected by the Aliso Canyon State of Emergency; Coordination with CSD, including o CSD LIWP coordination effort; o Coordinate with CSD s Weatherization Assistance Program (WAP) program to develop a referral process; and o CSD access to customer specific usage data and information for CSDtreated households, along with an outline of how this referral process and Green Button/Connect My Data program coordination will work; Revised eligibility estimates for the remaining years of this program cycle; IT enhancements related to mobile devices, customer notification, coordination with LifeLine, and data sharing with LifeLine providers; AB 793, Energy Management Technologies and the My Energy/My Account Platforms CARE customer reports that disaggregate household usage by end-use over time that should be coordinated with SCE s My Account platform; Funding for California LifeLine Mobile Phones; Description of SCE s M&O plans for ; Description of SCE s PCT Pilot Plan; and Description of SCE s water leveraging plan. IV. ESA and CARE Program Budgets for A. ESA Budget Budget based on 2017 approved budget with up to a 2 percent upward adjustment for each year after 2017 SCE s budget for , based on the 2017 approved budget with up to a 2 percent upward adjustment for each year after 2017, is provided in Attachment A hereto. 2. Additional Budget Adjustments ESA will utilize unspent funds for the additional efforts not previously requested in SCE s Program Application. These additional efforts include, but are not limited to, Central ACs in Climate Zone 13; Clothes Washers; CSD Leveraging and Coordination; Multi-family Common Area Measures, and Tier 2 Powerstrips.

5 (U 338-E) April 3, EE Potential Study In compliance with the directives of D , the IOUs are requested to include a provision for analysis and determination of ESA Program potential, please see SCE s EM&V budget, which includes $90,000 for SCE s share of the work associated with establishing savings potential of ESA via the EE Potential Study managed by the Energy Division. The total budget for this work not to exceed $300,000 funded by the 2017 ESA Program budgets co-funded between the four IOUs. 4 The details of the analyses are to be determined in collaboration with the Energy Division, the consultant, and the respective study teams. B. CARE Budget SCE s CARE budget for is provided in Attachment B hereto. To comply with the directives of D , and to ensure that SCE's CARE program continues to provide bill payment relief to qualified low income customers, SCE is requesting additional funding for the program cycle as reflected below: Outreach additional $10.6 million funding for increased marketing and outreach costs as directed by OPs 49,70,89,90,104,105,106 and 108. Processing additional $4.7 million funding for increased verification processing as directed by OP 86. IT Programming additional $6.4 million funding for IT programming which includes mobile versioning, Lifeline data sharing and enhancements to letters and reports as directed by OP s 77, 82, 100,102,84,91 and 93. (Note: additional funding request does not include cost for Smartphone App) Regulatory and Compliance - additional $1.3M funding as directed by OPs 95,96 and 98. The additional amount includes funding for the ESA and CARE audits as well. Cool Center Program additional $175,187 as directed by OP 118 CHANGES Program additional $2,100,000 for CHANGES program as directed by OP 129 SCE is asking for a total increase of $4,715,665 for CARE program years. 4 The Decision directs the following split: Pacific Gas and Electric Company (PG&E) 30 percent; SCE 30 percent; Southern California Gas Company (SoCalGas) 25 percent; and San Diego Gas & Electric Company (SDG&E) 15 percent. D , p. 52.

6 (U 338-E) April 3, 2017 V. Technology options by measure which will enable participation in demand response and/or alternative tariffs eligible for CPUC energy education requirements and consistent with the requirements of AB 327 A. Central Air Conditioners Customers with central air conditioners (ACs) are potentially eligible to participate in SCE s Summer Discount Program demand response program, which offers bill credits to customers in exchange for allowing SCE to turn off their Central AC compressor during peak energy events. In response to notification of an event, participants on the Maximum Comfort plan option may elect to opt out of up to 5 energy event days a year. B. Smart Room ACs SCE is considering introducing Smart Room ACs with built-in communication capability enabling customers to respond to price or peak demand signals by remotely reducing their temperature settings or turning the unit off. SCE plans on requesting vendor bids for such units as part of its ESA Program bulk purchase Request For Proposal process. Implementation of these units depends on acquisition of independently demonstrated quantifiable benefits. C. Programmable Communicating Thermostats SCE plans on introducing smart programmable thermostats to optimize HVAC settings for efficient and automated energy consumption. However, this measure may be the same type of measure (i.e. occupant controlled smart thermostat) as required under Title 24 of the California Code of Regulations. Specifically, when altered (e.g. replaced) HVAC is unable to comply with airflow, then alternative procedures 5 must be taken to comply provided that system thermostat is an occupant controlled smart thermostat. VI. MULTI-FAMILY A. Owner or authorized representative affidavit process for buildings in a PRIZM Code, census tract, or federally recognized tribal reservation or zone where 80 percent of households are at or below 200 percent of federal poverty guidelines In 2014, SCE developed and proposed an innovative multifamily integration strategy as part of the ESA Program application for the program cycle. The proposed strategy included income qualification of multifamily properties on a geographic level using comprehensive data analysis to identify areas within the SCE service territory with high concentrations of ESA eligible populations. 5 Residential Appendix RA , Alternate to Compliance with Minimum System Airflow Requirements for Altered Systems.

7 (U 338-E) April 3, 2017 The Owner or authorized representative affidavit process for multifamily buildings continues to be refined and will be discussed with the Mid-Cycle group to incorporate the policy and procedures within the Statewide Energy Savings Assistance Program Policy and Procedures Manual. For example, properties residing within neighborhoods (defined by zip7) with at least 80 percent of households at or below 200 percent of federal poverty guidelines will not require ( door to door ) tenant income verification to receive ESA whole building enrollment. The plan is to develop a self-certification affidavit designed to serve as the Property Owner Authorization (previously referred to as Property Owner Waiver or POW) form for ESA and MFEER Program installations. This enrollment approach will also be extended to properties in a Promise Zone 6 as designated by the federal government; or properties registered as low income affordable housing with ESA Program qualified income documentation less than 12 months old, on file. SCE is proposing to use Athens Research s Annual Estimate of CARE/FERA/ESA eligibility Zip-code Analysis optimized to identify low income qualified populations. In this extensive analysis, zip-codes are broken down to the zip+2 or zip7 level and analyzed using US census data, Applied Geographic Solution (AGS) data and American Community Survey data. Since 2001, the IOUs have worked with Athens Research to develop annual estimates of eligibility for the CARE and FERA low income assistance tariffs, and for the low income energy efficiency assistance programs. Estimates of these and other household size-by-income parameters have been developed for unique combinations of utility and fuel type. Estimates are also provided without regard to utility household counts, for a utility called CALIFHH which provides Athens estimates for households projected into the current year from Census sources and a demographic vendor designated by the CPUC (Applied Geographic Solutions). Regardless of utility or vendorbased household source of technical eligibility (the overall residential base of households eligible for given programs on the basis of payer type or service arrangement, of which some are demographically and income-eligible), consistent estimates are provided at a variety of geographical levels of detail: from statewide, to county, to block group, zip+2 or zip7, jurisdictional city, Census place, etc. B. Establish technical assistance programs for low income multifamily energy efficiency retrofits in the areas affected by the Aliso Canyon State of Emergency In 2014, SCE developed and proposed an innovative multifamily integration strategy as part of the ESA Program application for the program cycle. The proposed strategy utilizes a layered program services approach to provide 6 Promise Zones are high poverty communities where the federal government partners with local leaders to increase economic activity, improve educational opportunities, leverage private investment, reduce violent crime, enhance public health and address other priorities identified by the community. See U.S. Department of Housing and Urban Development (HUD), HUD Exchange website, available at

8 (U 338-E) April 3, 2017 comprehensive services for multifamily properties (dwelling and common areas), including financing options to reach deeper energy efficiency results. SCE s strategy focuses on a Single Point of Contact (SPOC) to better connect with property owners/managers and educate them on energy usage, energy savings opportunities and ultimately connect them with programs and services that that will help them reduce their energy consumption. Recognizing that not every property owner will be ready, financially or otherwise, to take on a substantial retrofit project this approach allows for multiple paths and a staggered investment strategy to upgrade a multifamily property(ies) over time. SCE plans on leveraging a common set of multifamily service providers for the ESA/EE multifamily programs to obtain consistency in service and delivery. These service providers will also be trained to fulfill the SPOC function for small to medium multifamily properties and portfolios to reduce barriers of participation. SCE will offer the following Program Support Services or Technical Assistance to participating property owners/managers including those in the areas affected by the Aliso Canyon State of Emergency. Benchmarking Support SCE will encourage property owners/managers to enroll and utilize ENERGY STAR Portfolio Manager along with its benchmarking capabilities to facilitate evaluate, rate and prioritize properties within their portfolio to undertake energy efficiency retrofits. SCE will work with customer prioritize properties and develop a customized portfolio strategy based on identified site energy use and budget. SCE may initiate then energy assessments to identify property needs and investment options at specific sites. Energy Assessments and Consultation The program will perform no-cost walk through energy assessments. The purpose of an energy assessment is to identify site level energy savings opportunities and assist property owners and managers with making informed energy improvement decisions. A program representative will review assessment findings with customers, assist with scope of work development and streamline customer program participation. Program Guidance Based on identified property needs and investment options, the SPOC will guide customers to program(s) that best suits their needs. The SPOC will promote program offerings from the Energy Saving Assistance Program and Multifamily Energy Efficiency Program. Program offerings includes select energy-saving products available to customers at no-cost, as well as a wide variety of incentives for other energy-saving products. SCE will also promote additional complementary programs and services such as On-Bill Financing and Charge Ready Program (EV infrastructure provisioning).

9 (U 338-E) April 3, 2017 For property owners/managers with sites that are good candidates for a wholebuilding retrofit approach, SCE will coordinate with the Southern California Regional Energy Network s Energy Upgrade California Whole Building Multifamily Program. Financing Options When appropriate, SCE will introduce the available financing options to facilitate retrofit activities. SCE s On-Bill Finance Program offers zero percent financing and will be available for multifamily common areas energy efficiency retrofits. VII. Coordination With CSD In D , the Commission seeks new and innovative ways to conduct leveraging in enrollment strategies; utilize data sharing; and marketing of ESA and CARE programs with CSD s program offerings. SCE, with the other IOUs, is well positioned to facilitate discussions with CSD and is already in direct contact with CSD to discuss the directives per the Decision, to develop budget proposals for households treated jointly and the referral process for data program coordination between the involved entities. SCE is also implementing a pathway for tracking and reporting the households treated under the joint Department of CSD, the California Energy Commission (CEC), and/or the California Department of Water Resources (DWR) as ordered in Ordering Paragraph (OP) 32. Recognizing the routes through all the levels to achieve efficiency in tracking and reporting treated households, SCE places greater focus on making sure that existing resources are informed and deployed appropriately. The Decision directs four leveraging and data sharing activities be incorporated in ESA budgets. The four efforts are discussed in greater detail below. A. CSD Low Income Weatherization Program (LIWP) Coordination SCE worked with CSD to develop and forecast installations to project and calculate a funding level for coordinating with CSD s LIWP Multi-family Whole Building efforts. CSD estimated the number of multi-family buildings to be treated in SCE s service area; and, SCE determined a budget based on the projected number of ESA measure installations anticipated through the coordinated effort. SCE s LIWP coordination budget will fund only measures offered by the ESA Program and approved for multi-family households. This will allow CSD to install measures not provided by the ESA Program. B. CSD Department of Water Resources (DWR) Leveraging SCE, and the Statewide IOUs, have had many conversations with CSD regarding coordinating their anticipated drought mitigation and toilet installations. CSD provided clarification that the Decision mischaracterized the amount of drought mitigation funding.

10 (U 338-E) April 3, 2017 CSD did not receive the anticipated $15M infusion from the CEC to augment CSD s weatherization offerings because the Budget Act of 2016 did not appropriate said funding. CSD s Low-Income Toilet Replacement Program (TRP), funded by the Department of Water Resources (DWR), has been in operation for many months and has nearly exhausted its funding and is scheduled to conclude on June 30, Given the rate of current expenditure for TRP, CSD is expecting a ramp down in local operations over the next few months. Subsequently, the window of opportunity to accomplish any meaningful leveraging of TRP funds and/or services has closed; therefore, no funding has been allocated for SCE and CSD leveraging of drought mitigations funds. C. Coordinate with CSD s WAP program to develop a referral process SCE is coordinating with CSD to determine the most viable approach for a referral process that aligns with existing customer privacy rules and provides a seamless process for customer installations. SCE and CSD s referral process will identify customers with high energy burden, and customers with non-iou fuel sources as appropriate. SCE and CSD will establish an agreement potentially non-disclosure agreement (NDA) to formalize the data sharing process. D. CSD access to customer specific usage data and information for CSDtreated households, including an outline of how this referral process and Green Button/Connect My Data program coordination will work SCE and CSD are collaborating to establish the most efficient process to facilitate the data exchange of customer-specific usage data and information for CSDtreated households. The Decision specifies that the IOUs utilize the Green Button/Connect My Data platform as a means through which to coordinate the data exchanges. However, based on discussions with CSD regarding their data analysis needs and the Green Button process, the proposed Green Button approach is not viable as it only provides data for one customer at a time instead of the preferred multiple customer process. Subsequently, SCE and CSD are evaluating other means, including EDRP, to facilitate the exchange of the expansive data. Regarding data sharing, SCE and CSD have developed an approach to accomplish data sharing per the requirements established on p. 368 of the Decision which states Furthermore, we direct all IOUs to develop coordination plans between the ESA Program and CSD s WAP program to develop a referral process for identified customers with barriers to helping CSD determine their energy efficiency program impacts and meet any reporting requirements, this Decision explicitly authorizes CSD access to customer-specific usage data and information for CSD-treated households. SCE s proposed approach for the referral process encompasses the following: Establish reporting requirements. Use the Energy Data Request Process (EDRP) to provide CSD with an initial request of utility usage data.

11 (U 338-E) April 3, 2017 Identified EDRP system to assist in legal customer information needs. Clarification of additional legal requirements between CSD and SCE to share customer data to eliminate future barriers. Development of data exchange schedule and systematic protocol. Establish a comprehensive engagement and feedback process to ensure data delivery. Additionally, SCE and CSD will enter into an agreement that provides the appropriate protections for the customer-specific data and establishes the parameters for the data exchanges. VIII. Revised Eligibility Estimates SCE s Table VIII-1 provides the remaining homes to be treated by 2020, applying the revised eligibility estimates pursuant to the updated Willingness and Feasible to Participate Factor (WFTP) provided in Attachment C. IX. IT enhancements related to mobile devices, customer notification, coordination with LifeLine, and data sharing with LifeLine providers The Decision directs 7 implementation of a high usage alert system for CARE and non-care utilizing the IOUs upgraded My Energy/My Account systems, text message, as well as through traditional outreach methods. To comply with this directive modifications are being made to SCE s High Usage Charge Pre-Breach automated Letters and My Account Budget Assistant alerts to provide CARE verification details to customers who are close to exceeding 400 percent of their baseline allocation. These updates are scheduled to be released in May 2017 with no expected impacts to CARE budget. If costs are associated with these notifications directives it will be accounted for in the IOUs Rate Reform memorandum accounts. The Decision also directs IOUs to include in their Conforming Advice Letter a data sharing plan 8 with LifeLine providers who opt-in to an agreement to generate bidirectional automatic leads between Lifeline participants and CARE and ESA Program participants. To minimize expenses, SCE will leverage its existing Data Sharing process (SCE data shared with SoCal Gas, PG&E, Water Utilities, etc.). 9 SCE will work through the LifeLine administrators to develop a secure, repeating, file sharing process which will include all CARE enrollments approved by SCE (to include all pertinent information needed to match customers across the different systems). Since SCE s ESAP program data shares with CARE, by providing all CARE enrollments, SCE 7 D , OP 83 & at p D , OP 91 & at p See D , OPs 88 & 89.

12 (U 338-E) April 3, 2017 will share all ESAP leads as well. Likewise, LifeLine will provide all approved LifeLine enrollments to SCE (again with all pertinent customer info). X. AB 793, Energy Management Technologies and the My Energy/My Account Platforms The Decision states we direct, by December 31, 2017, all of the IOUs to develop mobile versioning of the IOU websites and methods easily accessible on a mobile phone to allow for ESA/CARE program enrollment, post enrollment verification, and recertification. 10 SCE s CARE Program has budgeted $2M to implement mobile versioning. The ESA Program currently anticipates lead provision utilizing the existing ESA budget. However, if additional funds become necessary, ESA unspent funds will be utilized. This effort will be funded through the CARE IT and ESA Program General Administration Budgets as directed in the Decision. XI. CARE customer reports that disaggregate household usage by end-use over time that should be coordinated with SCE s My Account platform The Decision directs the IOUs to jointly conduct a statewide Request for Proposal (RFP) to procure a remote disaggregation/non-intrusive load monitoring vendor that will provide the IOUs the ability to generate electric (and gas, if available) end-use profiles for their CARE and ESA-eligible populations. 11 Because there is no currently available technology capable of preparing detailed end-use profiles without individually metering customer end-use equipment, the IOUs have requested modification of this directive in the Joint PFM filed March 24, Specific plans for this effort are being deferred until resolution of the Joint PFM. XII. California LifeLine Smart Phones The Decision provides conflicting direction regarding the provision of funding to LifeLine providers for LifeLine smart phones. The APD initially permitted LifeLine providers to request funding reimbursement for smartphones from IOUs. 12 However, in the Decision, while discussing revisions and clarifications made in response to Comments received to an alternate proposed decision, the Commission unequivocally declares that We eliminate the provision to have LifeLine providers seek reimbursement from the CARE Program. 13 Based on the foregoing, the failure to remove the directive to reimburse LifeLine for smart phones appears to have been in error. Additionally, the IOUs should not be required to reimburse LifeLine providers because California law prohibits the diversion of gas and electric utility funds to 10 D , p D , p D , p D , p. 398 (emphasis added).

13 (U 338-E) April 3, 2017 telecommunication s utilities activities. Public Utilities Code Section 451 provides that an IOU can only demand or receive charges for services or commodities provided by that IOU. Charges to customers for products or services not meeting this definition is unlawful. 14 Because no IOU provides telephone service or smart phones devices to its customers, it is inappropriate for IOUs to reimburse LifeLine providers for telecommunication products or services. This diversion of ratepayer funds also violates Public Utilities Code Section (b) (1), which states that The Commission shall establish a program of assistance to low-income electric and gas customers The IOUs are seeking clarification of this directive in the Joint Petition for Modification (PFM) filed and served on March 24, Therefore, SCE is waiting for resolution of the PFM prior to proposing any approach or funding for this directive. XIII. Marketing & Outreach On March 1, 2017 ALJ Roscow approved the Joint IOUs request to extend the submission date for the Statewide Integrated 5 Year Roadmap filing. The Statewide Integrated 5 Year Roadmap filing is now due April 5, In compliance with the Decision, the IOUs will conduct a Workshop after the new Statewide Integrated 5 Year Roadmap is filed and notice the service list at least 10 days before its occurrence. Within 60 days of the workshop, the IOUs will submit revised, detailed M&O plans, incorporating input gathered from the Workshop. Based on the domino effect of the extension of the Statewide Integrated 5 Year Roadmap filing, and OP 37 which states: Pacific Gas and Electric Company, Southern California Edison Company, San Diego Gas & Electric Company, and Southern California Gas Company shall, if feasible, incorporate their California Alternate Rates for Energy and Energy Savings Assistance Program Marketing and Outreach plans into the Rulemaking mandated Tier 3 advice letter filings for each utility s specific Marketing, Education, and Outreach plans that must be filed by June 1, SCE requests an extension of the CARE and ESA Program Marketing and Outreach plans to mid-july SCE is researching the cost to develop and produce disabled accessible versions of printed material for outreach, enrollment to education and recertification, in large print, Braille, electronic, and audio formats. 14 California Public Utilities Code Section 451 states: All charges demanded or received by any public utility, or by any two or more public utilities, for any product or commodity furnished or to be furnished or any service rendered or to be rendered shall be just and reasonable. Every unjust or unreasonable charge demanded or received for such product or commodity or service is unlawful.

14 (U 338-E) April 3, 2017 On February 21, 2017 the statewide M&O team reviewed the Joint IOU M&O Plan template with Energy Division. The Joint IOU M&O Plan template is provided below. Additional detail regarding the specific ESA and CARE ME&O plans will be provided following the ESA and CARE M&O Workshop to be held in second quarter Joint IOU M&O Plan Outline Common Format and Standardized Information I. Executive summary This section will provide a brief overview of the plan, what is included in the document and key priorities for the plan. II. III. IV. Program Background This section will include an overview of the CARE and ESA Programs, program priorities and goals, and applicable regulatory context based on D Low Income Market Situation and Customer Insights This section will include an overview of the state of low income customers in California and the current conditions of the market including barriers to enrollment (including barriers identified by IOU s, Low Income Needs Assessment (LINA) Study, and SB350 CEC Barriers), which will inform the marketing plans. Overall Marketing Plan This section will specify IOU marketing objectives, goals, target audiences (including hard-to-reach segments), segmentation strategy, messaging strategy and tactics. V. Integration This section will describe how low income messaging will be integrated into ME&O strategies for other key initiatives such as: Residential Rate Reform, Statewide ME&O, Energy Efficiency and Demand Response Programs, AB793 (Energy Management Technologies), and Aliso Canyon efforts in Southern California. VI. Measurement and Metrics This section will describe how IOUs will track impacts of outreach conducted by contractors, IOUs and capitation agencies. Metrics will include participation rates for under-enrolled communities.

15 (U 338-E) April 3, 2017 VII. VIII. Budget This section will include a budget estimate for the ME&O activities based on the plan developed. Appendix This section will include any related documents for reference. XIV. PROGRAMMABLE CONTROLLABLE THERMOSTAT (PCT) PILOT PLAN The Decision orders the IOUs to propose the same PCT Pilot at two different times in the Conforming Advice Letter 15 and also in the Mid-cycle Update Advice Letter. 16 The Decision also includes a draft proposed PCT pilot implementation plan in Attachment A that the IOUs could use as a basis for the pilot. The time needed to discuss and consolidate research currently underway for this pilot supports the request of the Joint IOUs PFM 17 request to present the PCT Pilot in the Mid-cycle Update Advice Letter. Since the time the Decision s Attachment A was written, the original pilot design has become outdated. The IOUs and external parties have conducted additional research, and new products are available. With the Decision s adoption in November 2016, any pilot plans in the March 2017 Conforming Advice Letter would not be well-considered or ready for implementation by Summer Additional time would allow IOUs to design a better study incorporating new research and collaboration opportunities. For this reason, SCE is awaiting Commission resolution of the PFM before proposing a PCT Pilot plan and budget. XV. Water Leveraging Plan SCE partners with water agencies to coordinated multi-utility offerings. SCE works with SCG and retail water agencies to deliver our Multi-Family Pilot. There is significant coordination and leveraging of customer data to provide a one stop shop for customers and utilities. The new Residential Direct Install (DI) Program aims to provide a targeted approach to the residential sector with water agencies. Residential DI was proposed in the 2017 Advice Letter based on lessons learned with previous programs trying to reach customers in the residential sector who face many of the same barriers as our low-income customers such as renters who face a split incentive or struggle with making energy efficiency improvements due to upfront cost. There is an opportunity to coordinate and leverage external existing partnership. Several programs are coordinated 15 D , Conclusion of Law (COL) 196, p D , Ordering Paragraph (OP) 146, p PG&E, SDG&E, SCE, and SoCalGas Joint Petition for Modification of Decision , filed March 24, 2017.

16 (U 338-E) April 3, 2017 with SoCalGas who also partners with large wholesale agencies such as Metropolitan Water District. SCE looks forward to leveraging existing and exploring new partnerships with water agencies to provide more complete offerings to our customers. To support coordination across agencies, the Water-Energy Nexus (WEN) proceeding is seeking to better integrate the embedded energy calculator tool with the Commission approved cost-effectiveness tool to better streamline, integrate and evaluate multi-utility offerings. As requested by the WEN proceeding, an action plan on how to best integrate the tools in under development and is likely to be completed by the end of Integrating the tools and leveraging our experience with partnerships for multi-utility offerings, including water agencies, will provide guidance on how to assess multi-utility offerings across SCE s EE and low-income portfolios. SCE will utilize its lessons learned from the programs/pilot and any development from the WEN proceeding to help inform decisions such as measure mix and scale of the partnerships that would take place during the mid-cycle application. XVI. ESA and CARE Audits As directed by Public Utilities Code Section 900, the Commission has the authority to conduct audits to ensure compliance with any Commission order relating to the implementation of programs. In 2016, the Commission initiated on audit of the ESA and CARE Programs for Program Years facilitated by the State Controller s office. Per Energy Division direction, the total audit cost of the audit will be $625k and is to be funded from the IOUs Regulatory Compliance budgets using the traditional split (30 percent-pg&e; 30 percent-sce; 25 percent SoCalGas; and 15 percent-sdg&e). SCE s portion of the audit cost is $187,500 which is split equally between ESA and CARE. Therefore, SCE is requesting an additional $375,000 to cover current and future audit expenses. The ESA portion of the audit funding will be paid from unspent funds. The audit budget is reflected in Attachments A and B respectively. XVII. Conclusion Based on the information provided herein, including the attachments, SCE submits CARE and ESA Program budgets for reflecting the adjustments, new updated willingness to participate, program elements adopted in the Decision, and information related to AB 327. Additionally, SCE requests funding for the ESA and CARE Audits, as well as any future audits during the funding cycle.

17 (U 338-E) April 3, 2017 TIER DESIGNATION Pursuant to D , pp and COL 61, this advice filing is submitted with a Tier 2 designation. EFFECTIVE DATE SCE respectfully requests this Advice Letter be approved May 3, 2017, which is 30 calendar days after the date filed. NOTICE Anyone wishing to protest this advice filing may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice filing. Protests should be mailed to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California EDTariffUnit@cpuc.ca.gov Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this Advice Letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) AdviceTariffManager@sce.com

18 (U 338-E) April 3, 2017 Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415) Karyn.Gansecki@sce.com There are no restrictions on who may file a protest, but the protest shall set forth specifically the grounds upon which it is based and shall be submitted expeditiously. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice filing to the interested parties shown on the attached GO 96-B and A et al. service list. Address change requests to the GO 96-B service list should be directed by electronic mail to AdviceTariffManager@sce.com or at (626) For changes to all other service lists, please contact the Commission s Process Office at (415) or by electronic mail at Process_Office@cpuc.ca.gov. Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by filing and keeping the advice filing at SCE s corporate headquarters. To view other SCE advice letters filed with the Commission, log on to SCE s web site at For questions, please contact Sheila Lee at (626) or by electronic mail at Sheila.Lee@sce.com. Southern California Edison Company RGW:sl:jm Enclosures /s/ Russell G. Worden Russell G. Worden

19 CALIFORNIA PUBLIC UTILITIES COMMISSION ADVICE LETTER FILING SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/cpuc Utility No.: Southern California Edison Company (U 338-E) Utility type: Contact Person: Darrah Morgan ELC GAS Phone #: (626) PLC HEAT WATER Disposition Notice to: EXPLANATION OF UTILITY TYPE ELC = Electric GAS = Gas PLC = Pipeline HEAT = Heat WATER = Water (Date Filed/ Received Stamp by CPUC) Advice Letter (AL) #: 3585-E Tier Designation: 2 Subject of AL: Southern California Edison Company s Conforming Advice Letter as Ordered in Decision Keywords (choose from CPUC listing): Compliance AL filing type: Monthly Quarterly Annual One-Time Other If AL filed in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/access to confidential information: Resolution Required? Yes No Requested effective date: 5/3/17 No. of tariff sheets: -0- Estimated system annual revenue effect: (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: N/A Service affected and changes proposed 1 : Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed.

20 Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this filing, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California Russell G. Worden Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California Telephone: (626) Facsimile: (626) Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California Facsimile: (415)