Summary - California

?ALJ/PD1/mphPROPOSED DECISIONAgenda ID #18705 (Rev. 2)Ratesetting9/24/2020 Item #5Decision PROPOSED DECISION OF ALJ DOHERTY (Mailed 8/17/2020)BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIAApplication of Pacific Gas and Electric Company to Revise its Electric Marginal Costs, Revenue Allocation and Rate Design. (U39M)Application 19-11-019DECISION APPROVING ESSENTIAL USAGE STUDY AND BUDGETTABLE OF CONTENTSTitlePage TOC \o "1-3" \h \z \u DECISION APPROVING ESSENTIAL USAGE STUDY AND BUDGET PAGEREF _Toc47595004 \h 1Summary PAGEREF _Toc47595005 \h 21.Background PAGEREF _Toc47595006 \h 22.Issues Before the Commission PAGEREF _Toc47595007 \h 33.Proposal for an EUS Plan PAGEREF _Toc47595008 \h 34.Party Responses to the Proposed EUS Plan PAGEREF _Toc47595009 \h 75.Discussion PAGEREF _Toc47595010 \h 105.1.Base Deliverable of the EUS PAGEREF _Toc47595011 \h 105.2.Collecting Additional Data from Existing RASS Study Respondents PAGEREF _Toc47595012 \h 115.3.Interviews of RASS Participants to Gain an Understanding of Underutilization of Electricity PAGEREF _Toc47595013 \h 135.4.Added Functionality to Web Tool PAGEREF _Toc47595014 \h 146.Budget and Cost Recovery PAGEREF _Toc47595015 \h 167.Purpose of the EUS PAGEREF _Toc47595016 \h ments on Proposed Decision PAGEREF _Toc47595017 \h 209.Assignment of Proceeding PAGEREF _Toc47595018 \h 21Findings of Fact PAGEREF _Toc47595019 \h 21Conclusions of Law PAGEREF _Toc47595020 \h 22ORDER PAGEREF _Toc47595021 \h 24DECISION APPROVING ESSENTIAL USAGE STUDY AND BUDGETSummaryThis decision approves an Essential Usage Study plan to model the essential usage of electricity by residential customers of the large electrical corporations. This decision approves ratepayer funding for the Essential Usage Study in an amount not to exceed $845,054. This proceeding remains open.BackgroundIn Decision (D.) 18-08-013, the Commission directed Pacific Gas and Electric Company (PG&E) to develop a study plan and budget for a study of what constitutes essential electricity use for its residential customers. The Commission issued a similar requirement for Southern California Edison Company (SCE) in D.18-11-027. During San Diego Gas & Electric Company’s (SDG&E) General Rate Case (GRC) Phase II Application (A.) (A.19-03-002) the Administrative Law Judge ordered SDG&E to join PG&E and SCE’s stakeholder process for developing an Essential Usage Study (EUS) plan consistent with the directions given to PG&E in D.18-08-013. PG&E filed its GRC Phase II Application (A.19-11-019) on November 22, 2019. As part of its application, PG&E submitted an EUS plan on behalf of itself and the other large electrical corporations. The Assigned Commissioner’s Scoping Memo and Ruling (scoping memo) was filed on February 10, 2020. The scoping memo created a bifurcated track of this proceeding for expedited consideration of the EUS plan, and ordered SCE and SDG&E to file for party status and participate in that portion of the instant proceeding. The scoping memo also ordered PG&E to serve and file the final EUS plan on behalf of the large electrical corporations on April 1, 2020. On March 30, 2020, the assigned Administrative Law Judge (ALJ) issued a ruling that granted the request of the large electrical corporations to extend the deadline for the final EUS plan to April 10, 2020. On April 10, 2020, PG&E filed a final EUS plan on behalf of the large electrical corporations. The plan incorporated comments made by other parties at a workshop held in March 2020.Three parties to the instant proceeding filed opening comments on the final EUS plan on May 11, 2020: PG&E, the Public Advocates Office at the California Public Utilities Commission (Cal Advocates), and the Center for Accessible Technology (CforAT). SDG&E filed reply comments on May 26, 2020 on behalf of all the large electrical corporationsIssues Before the CommissionThe issue of whether the proposed EUS plan is reasonable and should be approved is included in the scope of this proceeding by the scoping memo. This decision disposes of that issue.Proposal for an EUS Plan As defined by D.18-08-013, the purpose of the EUS is to allow the Commission to “better evaluate whether PG&E’s residential customers are meeting their basic electricity needs at a reasonable cost.” Later Commission decisions and orders extended this logic to SCE and SDG&E as well. Such an evaluation may help the Commission fulfill its statutory mandate to “designate a baseline quantity of gas and electricity which is necessary to supply a significant portion of the reasonable needs of the average residential customer.” Furthermore, Public Utilities Code Section 382(b) states that electricity is a basic necessity and that all residents of California should be able to afford “essential” amounts of electricity. Evaluating what electricity usage is essential for differently situated customers throughout California will assist the Commission in fulfilling its mandate under Public Utilities Code Section 382(b). The final EUS plan proposes to use, as ordered by D.18-08-013, data from the 2019 Residential Appliance Saturation Survey (RASS) as the foundation for the EUS work. As described by the large electrical corporations, the 2019 RASS is “a large-scale, statewide study that has been conducted periodically over the past few decades to estimate the saturation of typical residential appliances and energy consumption tied to a wide range of common end uses of energy.” With participation from private and public utilities throughout California, “the targeted completed sample size for the 2019 RASS is approximately 51,500 California households, over 45,000 of which were to be in [large electrical corporation] service territories and is the most comprehensive survey of California residents of its kind.” The final EUS plan reports that the 2019 RASS will “create a bottom-up estimate of each household’s energy consumption profile” and that it is expected to be complete by the fall of 2020.The final EUS plan claims that the 2019 RASS will include customer profiles that ensure the data can be used to draw conclusions about the electricity usage of households meeting the demographic criteria outlined in D.18-08-013. These criteria include a customer’s location in a cool, warm, or hot climate zone, as well as the customer’s household size (in terms of both square footage and number of residents), building features (age, construction materials, insulation, etc…), and appliances (efficiency and usage).The 2019 RASS is being conducted by Det Norske Veritas Germanischer Lloyd Group (DNV GL) under contract to the California Energy Commission (CEC). DNV GL was awarded the contract via a competitive solicitation process. Because the EUS plan leverages the 2019 RASS for its core data, the large electrical corporations propose to issue a direct award for the preliminary design of the EUS to DNV GL. They argue that doing so will reduce the overall cost of the EUS and “ensure the quality of essential energy use estimates.”The final EUS plan proposed by the large electrical corporations contain several modular elements for Commission review. The final EUS plan describes one core module (or “Base Deliverable”) as being necessary, while several other modules are optional. According to the large electrical corporations, the Base Deliverable will address all the fundamental requirements of the EUS established by D.18-08-013 and D.18-11-027. The other optional modules are designed to address questions that arose during the stakeholder engagement process to develop the final EUS plan, and are directed at gathering information additional to the RASS data and providing more tools for public use of the EUS results. A table describing these various modules appears below.ModuleDescription Provided in Final EUS PlanTotal Estimated Cost in Final EUS PlanBase DeliverableProduce final report addressing results of EUS analysis, hold stakeholder meetings, model usage necessary for minimum cooling and heating, create and maintain interactive Web Tool. $490,714 Collecting Additional Data from RASS ParticipantsSupplement RASS data on certain essential uses (e.g., medical equipment usage) by asking 2,000 or 6,000 existing RASS participants up to 10 additional questions.$108,575 for 1,000 completed surveys; or $211,579 for 3,000 completed surveysCollecting Additional Data from Low-Income GroupsConduct additional surveys to increase statistical precision for estimates generated by the Web Tool for certain specific subset(s) of low-income customers. Survey either 6,000 or 12,000 new RASS participants.$286,000 for 2,000 completed surveys; or $458,000 for 4,000 completed surveysQualitative Interviews of RASS ParticipantsHelp identify energy underutilization by low-income customers by conducting at least 75 interviews with customers in different age groups and of different sexes.$85,524Added Functionality to Web ToolAdditional statistical estimate functionality, including calculation of confidence intervals and/or other estimates of accuracy, to be designed and integrated into the EUS Web Tool.$40,000 – 60,000With respect to timing, the final EUS plan estimates that the EUS would be executed in May 2021, with a preparation of a draft EUS report and Web Tool by September 2021, assuming the Commission approves the EUS plan by August 2020. The large electrical corporations estimate a final EUS report would be completed by January 2022. Because this decision is issued in September 2020 instead of August 2020, each of these estimated completion dates will be delayed by one month.Party Responses to the Proposed EUS PlanPG&E, CforAT, and Cal Advocates filed opening comments on the final EUS plan. PG&E reiterated its support for Commission approval of the Base Deliverable as well as the qualitative research and added Web Tool functionality.CforAT broadly supported the final EUS plan, and recommended Commission approval of the qualitative research module to investigate the potential for some customers to “use less electricity than might be appropriate for health and safety out of concern about their ability to pay utility bills” and therefore underreport their true essential usage. CforAT seeks clarification that these qualitative interviews would not be limited to low-income customers, and would instead include customers participating in the California Alternate Rates for Energy (CARE) program, the Family Electric Rate Assistance (FERA) program, and customers not participating in either program. CforAT also seeks to increase the minimum of 75 interviews that is proposed in the final EUS plan in order to “provide meaningful information across three utilities and multiple climate zones in California.”With respect to customers with medically-necessary electricity usage, CforAT criticizes the existing RASS questionnaire and states that it does not “provide any method for separately quantifying the usage that is medically necessary, [and is] not sufficient to provide information about the essential electricity usage of medically vulnerable utility customers.” CforAT therefore recommends Commission approval of the second module to collect additional data from existing RASS participants that includes customers enrolled in medical baseline, customers who may be eligible for medical baseline but who are not enrolled, and customers whose medical needs may not establish eligibility for medical baseline.Cal Advocates supports the EUS plan’s Base Deliverable and argues for Commission approval of the module adding additional functionality to the Web Tool. Cal Advocates claims that this additional functionality would provide the public the necessary analysis functionality to develop their own essential usage estimates, create confidence intervals, and generally allow for more robust analysis of proposals on essential usage to be considered by the Commission. In their reply comments, the large electrical corporations support the recommendations by Cal Advocates and CforAT to include funding for posing additional questions to 2,000 existing RASS participants, additional qualitative interviews to examine potential underutilization of electricity, and enhanced Web Tool functionality. Specifically, the large electrical corporations propose to increase the number of qualitative interviews from 75 to 125. The large electrical corporations claim that conducting 125 qualitative interviews “will be sufficient to ascertain whether electricity underutilization is associated with such factors as weather conditions, whether it affects more than just low-income customers, or whether customers in one service territory are more affected than another.” They also assert that the 125 qualitative interviews will identify trends and patterns that will provide an adequate basis for adjustments to the calculation of essential usage to account for underutilization.The large electrical corporations also support CforAT’s request to ask additional questions of 2,000 RASS participants in order to distinguish generic RASS usage from usage that is specific to medical equipment.The large electrical corporations agree with Cal Advocates’ request for a Web Tool with enhanced functionality, although they assert that the budget for such work is difficult to estimate at this time. Their concern is that if stakeholders request certain functions be included in the Web Tool, then the costs for the Web Tool could exceed the previously estimated amount. The large electrical corporations therefore propose that the budget for this particular module be uncapped to allow for future adjustments to the scope of work.DiscussionBase Deliverable of the EUSThe final EUS plan asserts that adopting the Base Deliverable will fulfill the requirements of D.18-08-013 and other relevant Commission orders because it will create a study plan and budget for developing a model of what constitutes essential use for residential customers. The final EUS plan also allows the EUS to be carried out as a single statewide study to ensure consistency across the three service territories of the large electrical corporations. The proposal for the Base Deliverable received no opposition from stakeholders. Because the Base Deliverable fulfills the orders of the Commission regarding an essential usage study and promotes efficiency, the Base Deliverable is reasonable and should be approved. The large electrical corporations request the contract for the Base Deliverable be awarded directly to DNV GL, the consultant that administered the 2019 RASS. The consultant has experience in conducting prior versions of household energy consumption pattern studies, as well as access to previous RASS data. A different consultant would be unable to directly access RASS data, increasing study costs and time required to complete the study. While direct awards of contracts to consultants are unusual and not to be approved lightly, this decision accounts for the risks by strictly limiting the budget for the EUS. The budget set by this decision may not be exceeded by the consultant to perform the EUS work. The total budget is calculated and discussed later in this decision. For these reasons, the request to directly award the contract to DNV GL is reasonable and should be approved. SCE shall contract directly with DNV GL on behalf of the large electrical corporations to execute the elements of the EUS plan as approved by this decision.The final EUS plan seeks a total budget of $490,714 for the Base Deliverable. This work would include: project initiation meetings, creation of a stakeholder working group, creation of an EUS report, custom modeling of energy use specific to essential usage, creation of an interactive Web Tool, a guarantee of long-term maintenance of the Web Tool, an interactive Web Tool training workshop, and an annotated training deck for presentation materials. Due to the Base Deliverable’s importance in achieving Commission orders related to the EUS, the $490,714 cost for the Base Deliverable is reasonable and should be approved.The creation of the final EUS report as part of the Base Deliverable should include stakeholder participation. The large electrical corporations should jointly serve notice of the availability of a draft EUS report on the service lists for the most recent PG&E, SCE, and SDG&E General Rate Case Phase 2 proceedings, and Rulemaking (R.) 18-07-006. The large electrical corporations should provide a minimum of 15 business days for interested stakeholders to review and comment on the draft EUS report, after which the large electrical corporations will share stakeholder comments with DNV GL for consideration and potential inclusion in the final EUS report.Collecting Additional Data from Existing RASS Study RespondentsIn reply comments, the large electrical corporations support the collection of additional data from up to 2,000 existing RASS participants, with up to 10 additional responses to be added to their original RASS survey responses. This would include mail-based outreach with incentives and intensive follow up to increase response rates, estimated to be 50%. The large electrical corporations propose to include questions to gain more information of medically necessary electricity usage requirements. The medical baseline program was established by the Baseline Act of 1976, which directed the Commission to provide larger quantities of power at a baseline rate to customers with specific medical needs. Additional questions concerning the electrical usage by customers with medical needs who depend on electrically powered devices would provide greater insight into a specific but important population. EUS questions specifically meant to identify customers who medically depend on electrically powered devices would allow the Commission to consider the needs of this population while gaining information on medically necessary electrical usage. Additional data made up of 10 additional responses would also increase EUS accuracy. However, the cost of this work if it is to be assumed that 2,000 surveys of existing RASS participants would be completed has not been estimated. The final EUS plan estimated that the cost of this module would total $108,575 if 1,000 estimated surveys were completed. Because the benefit of collecting 1,000 completed surveys of RASS participants versus 2,000 completed surveys of RASS participants is not specifically established, it is reasonable to minimize ratepayer expenditures on this module. The additional work of surveying 2,000 existing RASS participants to collect an estimated 1,000 completed surveys with a total budget of $108,575 is reasonable and should be approved. The additional survey of the 2,000 existing RASS participants shall include but not be limited to customers enrolled in medical baseline, customers who may be eligible for medical baseline but who are not enrolled, and customers whose medical needs may not establish eligibility for medical baseline. One of the aims of the survey instrument shall be to distinguish generic RASS usage from usage that is specific to medical equipment.Interviews of RASS Participants to Gain an Understanding of Underutilization of ElectricityAs discussed previously, the large electrical corporations express support for additional qualitative interviews of RASS participants. This component would require a minimum of 75 in-depth interviews (IDIs) to be completed with the 2019 RASS respondents across the three large electrical corporation territories with customers in different age groups and sexes. It would also include development and pretesting of the interview guide, conducting, and interpreting the interviews, and including the results into the EUS. CforAT supports this module but seeks inclusion of more interviews. The large electrical corporations now propose to interview at least 125 RASS participants to investigate the extent to which electricity customers may be underutilizing electricity.While addressing underutilization of electricity is a laudable goal and will help to put the results of the EUS in context, it is not clear what benefit will emerge from qualitative interviews of 125 individuals versus 75 individuals. The final EUS plan estimated that it would cost $85,524 to conduct 75 qualitative interviews. Because the benefit of conducting qualitative interviews of 75 RASS participants versus 125 participants is not specifically established, it is reasonable to minimize ratepayer expenditures on this module. The additional work of conducting qualitative interviews of 75 existing RASS participants with a total budget of $85,524 is reasonable and should be approved for the purpose of determining the extent to which customers may be underutilizing electricity. The qualitative interviews shall include customers enrolled in CARE and FERA, and customers not enrolled in either program. One of the aims of the interviews shall be to determine if customers avoid using electricity necessary for health and safety, and if so why.Added Functionality to Web ToolThe large electrical corporations and Cal Advocates support the proposal to add additional functionality to the interactive Web Tool; but there is not consensus as to the exact scope of work for this module. The large electrical corporations claim that the “high-level cost estimate for the Web Tool in particular [provided in the final EUS plan] has the greatest uncertainty, and potential variability, due to its dependence on intervenor feedback during the system design phase as well as the challenges inherent to development and implementation of sophisticated and new technology.” The enhanced Web Tool could provide parties with data to create their own Essential Usage Estimates under different scenarios. The Web Tool could be used to provide additional statistical estimate functionality, including calculation of confidence variables, and other estimates of accuracy. The Web Tool could also function as an easily replicable way and cost-effective method for updating the estimated of essential usage intermittently. The Web Tool could allow users to download tables of raw anonymized RASS data to confirm and independently verify DNV GL’s analyses. However, there is no agreement that the scope of work for this module should include these elements. In particular, the large electrical corporations argue against adding anonymized respondent level data as the time required to anonymize respondent data is difficult to quantify. While the Commission agrees with parties that it is reasonable to approve work in support of an enhanced Web Tool in order to increase the ability of parties to utilize the EUS results, it is not possible to approve a precise scope of work at this time without greater certainty as to the costs involved with each element of work. Ultimately, the intervenors and the large electrical corporations need to agree on a scope of work for this module.In light of these uncertainties, this decision simply doubles the original high-end cost estimate of an enhanced Web Tool from $60,000 to $120,000. In the absence of any guidance provided by the parties as to the agreed scope and budget for the work, a budget of $120,000 is reasonable to account for the unknown scope of work at this time. This decision holds that the Commission should not lightly revisit this determination, and parties should therefore work to contain the scope of this work to a degree that ensures the adopted budget is sufficient.For these reasons it is reasonable to approve the module for an enhanced Web Tool with a budget not to exceed $120,000. The large electrical corporations shall meet and confer with interested parties to determine the precise scope of work for this module and the parties should work to ensure that the expenditures on this module do not exceed $120,000. Parties should agree on a scope of work no later than 60 days after the effective date of this decision to ensure the expected timelines for the EUS work are maintained. The large electrical corporations should jointly serve on the service list of this proceeding a status report on the results of these meet and confer efforts no later than 75 days after the effective date of this decision.Budget and Cost RecoveryThe final EUS plan requests that the Commission authorize budgets for each of the approved EUS modules, which include a 10% overage for potential cost overruns. It further seeks Commission approval of a cost recovery mechanism by authorizing each large electrical corporation to file a Tier 1 advice letter that will establish an EUS cost recovery balancing account for tracking each large electrical corporation’s respective share of the actual costs associated with the EUS, with a cost allocation of: PG&E, 45%; SCE, 43%; and SDG&E, 12%.Cal Advocates argues that the EUS budget should be fixed and cover all required deliverables, so that DNV GL would be responsible for performing all contracted obligations without passing the risk to ratepayers. Cal Advocates believes that the Commission should not authorize incremental funding for completion of the approved deliverables in the EUS, given that DNV GL is receiving a direct award contract with a proposed budget that already includes an overage cushion of 10% to account for potential cost overruns. Cal Advocates also recommends that the Commission require recovery of the EUS costs through a one-way balancing account that is “capped” at the Commission-authorized fixed budget for the EUS, and which tracks the difference between the authorized budget and actual costs of the EUS. Cal Advocates claims that such a balancing account “provides an incentive mechanism for the utilities to manage spending within the authorized budget for this study and protects ratepayers from imprudent spending.” Cal Advocates argues that the large electrical corporations should use a Tier 2 advice letter when requesting establishment of the EUS balancing accounts.The large electrical corporations oppose Cal Advocates’ proposal for a capped budget for the EUS work, citing uncertainties in the scope of work to be included in the EUS and the specific functionalities to be included in deliverables. The main concern seems to center of the development of the Web Tool, which parties agree should be designed to include additional, and undetermined, functionalities. With respect to the cost recovery mechanism, the large electrical corporations do not support a one-way capped balancing account as proposed by Cal Advocates. They continue to advocate for a two-way balancing account, which they claim would ensure that ratepayers are charged for only actual costs and refunded any overcollections.This decision adopts a cap on EUS expenditures. The cost estimates provided by the final EUS plan and adopted by this decision are used as a basis for the cap, as described below.The Base Deliverable budget of $490,714 is not contested by the parties, and the scope appears to be well-defined. This budget amount was previously authorized by this decision. The collection of additional data from existing RASS participants was originally estimated to cost $108,575 for 1,000 participants, and this decision previously authorized that amount for the additional data collection.As held earlier in this decision, the original plan for 75 qualitative interview participants should be adhered to in order to reduce cost exposure for ratepayers and in light of the fact that the relative benefit of surveying 125 participants versus 75 participants is unknown. Therefore, the original cost estimate of $85,524 may be relied upon for this work.Finally, there is the module related to enhanced Web Tool functionality. As held previously in this decision, it is reasonable to pursue the work even if the scope and budget for the work is not certain at this time. Because of the uncertainties, this decision simply doubles the original high-end cost estimate of $60,000 to $120,000. Summing all of the estimated budgets for EUS work approved by this decision leads to a figure of $804,813. Because the work may not be finalized until 2022, it is reasonable to apply an escalator for 5% to that figure to account for inflationary effects that may arise in 2021 and 2022. This leads to a final cost estimate of $845,054. This is the cap adopted by this decision for the EUS work.The cost allocation among the large electrical corporations was unopposed and is reasonable. Therefore, EUS costs shall be divided among the large electrical corporations such that PG&E is responsible for 45% of the costs, SCE is responsible for 43% of the costs, and SDG&E is responsible for 12% of the costs.The one-way capped balancing account proposed by Cal Advocates is a reasonable approach given the discrete nature of this work, the existing estimates for EUS costs that include a 10% overage in the event of unforeseen costs, and the fact that a cost cap is adopted by the Commission in this decision. Such a balancing account only allows the large electrical corporations to recover their actual EUS expenditures in rates up to the cap imposed by this decision. If the one-way capped balancing account records EUS expenditures in excess of the cap established by this decision, then those expenditures may not be recovered in rates.Each of the large electrical corporations shall file a Tier 2 advice letter no later than 30 days after the effective date of this decision establishing the EUS expenditure balancing accounts as described in this decision.Purpose of the EUSThe large electrical corporations state that they primarily intend to use the EUS results to assess whether the data shows that the existing baseline quantities approach in Public Utilities Code Section 739 continues to be reasonable. They cite to a Commission staff proposal released in a rulemaking examining the affordability of essential utility services (R.18-07-006) which stated that the EUS “should provide more accurate determinations of essential energy service that eventually replace baseline quantities for that purpose. Until more robust determinations of essential service quantities made through essential use studies, staff considers baseline quantities the best estimate of essential service quantities.” CforAT strongly disagrees with the characterization of the large electrical corporations of the primary use for the EUS results, arguing that the EUS should not be used to assess the reasonableness of the existing baseline quantity allocation for electricity. CforAT contends that the EUS should be used to obtain information about the usage needs of residential customers and provide a review of what electricity usage is for different subgroups of electricity utility customers. CforAT advocates for the Commission to expressly decline the Joint IOUs statement of intent, and instead “indicate that the purpose of the study is to obtain information about the usage needs of residential customers along a broad range of factors.” The large electrical corporations disagree to some extent with CforAT, expressing a desire to address baseline policy using the results of the EUS work. However, they also state that the Commission could also “expressly state that the results of this EUS survey can be used by interested parties in other proceedings to make other types of assessments and proposals that go beyond the subject of the baseline methodology.”At this time the Commission holds that it is reasonable to pursue the EUS work approved by this decision in order to help the Commission meet its statutory duties. This may involve using the EUS results to consider changes to baseline pricing policy, and it could also involve many other uses (e.g., for use in R.18-07-006 to help determine an essential amount of electricity service for residential customers). This decision’s approval of the EUS work does not prejudice any application of the results of the work by the Commission in the ments on Proposed DecisionThe proposed decision of ALJ Doherty in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission’s Rules of Practice and Procedure. Comments were filed by CforAT on September 4, 2020, and by Cal Advocates, PG&E, SCE, and SDG&E on September 8, 2020. Reply comments were filed on September 14, 2020 by SDG&E, SCE, and PG&E. Changes were made throughout the decision in response to party comments.Assignment of ProceedingGenevieve Shiroma is the assigned Commissioner and Patrick Doherty is the assigned Administrative Law Judge in this proceeding.Findings of FactThe Base Deliverable fulfills the orders of the Commission regarding an essential usage study and promotes efficiency.DNV GL administered the 2019 RASS, has experience in conducting prior studies of household energy consumption patterns, and has access to previous RASS data. A consultant other than DNV GL would be unable to directly access RASS data, increasing study costs and time required to complete the study.The medical baseline program was established by the Baseline Act of 1976, which directed the Commission to provide larger quantities of power at a baseline rate to customers with specific medical needs. EUS questions specifically meant to identify customers who medically depend on electrically powered devices would allow the Commission to consider the needs of this population while gaining information on medically necessary electrical usage. Additional data made up of 10 additional responses would increase EUS accuracy.Addressing underutilization of electricity is a laudable goal and will help to put the results of the EUS in context.It is not clear what benefit will emerge from qualitative interviews of 125 individuals versus 75 individuals. There is not consensus as to the exact scope of work for adding functionality to the interactive Web Tool.Conclusions of LawEvaluating what electricity usage is essential for differently situated customers throughout California will assist the Commission in fulfilling its mandate under Section 382(b).The Base Deliverable is reasonable and should be approved.The budget set by this decision may not be exceeded by the consultant to perform the EUS work. The request to directly award the contract to DNV GL is reasonable and should be approved.The $490,714 cost for the Base Deliverable is reasonable and should be approved.Because the benefit of collecting completed surveys from 1,000 RASS participants versus 2,000 participants is not specifically established, it is reasonable to minimize ratepayer expenditures on this module. The additional work of surveying 2,000 existing RASS participants with a total budget of $108,575 is reasonable and should be approved. Because the benefit of conducting qualitative interviews of 75 RASS participants versus 125 participants is not specifically established, it is reasonable to minimize ratepayer expenditures on this module. The additional work of conducting qualitative interviews of 75 existing RASS participants with a total budget of $85,524 is reasonable and should be approved for the purpose of determining the extent to which customers may be underutilizing electricity. It is reasonable to approve work in support of an enhanced Web Tool in order to increase the ability of parties to utilize the Essential Usage Study results.The intervenors and the large electrical corporations should agree on a scope of work for adding functionality to the interactive Web Tool within the confines of the budget established by this decision.It is reasonable to approve the module for an enhanced Web Tool with a budget not to exceed $120,000. This decision adopts a cap on total costs for the EUS work of $845,054. The cost allocation among the large electrical corporations was unopposed and is reasonable. EUS costs shall be divided among the large electrical corporations such that PG&E is responsible for 45% of the costs, SCE is responsible for 43% of the costs, and SDG&E is responsible for 12% of the costs.The one-way capped balancing account proposed by Cal Advocates is a reasonable approach for tracking EUS costs given the discrete nature of this work, the existing estimates for EUS costs that include a 10% overage in the event of unforeseen costs, and the fact that a cost cap is adopted by the Commission in this decision.ORDERIT IS ORDERED that:Southern California Edison Company shall contract directly with Det Norske Veritas Germanischer Lloyd Group on behalf of the large electrical corporations to execute the elements of the Essential Usage Study plan as approved by this decision.Southern California Edison Company, San Diego Gas & Electric Company, and Pacific Gas and Electric Company shall meet and confer with interested parties as soon as practicable to determine the precise scope of work for an enhanced Web Tool. Southern California Edison Company shall file a Tier 2 advice letter no later than 30 days after the effective date of this decision establishing an Essential Usage Study expenditure balancing account as described in this decision.San Diego Gas & Electric Company shall file a Tier 2 advice letter no later than 30 days after the effective date of this decision establishing an Essential Usage Study expenditure balancing account as described in this decision.Pacific Gas and Electric Company shall file a Tier 2 advice letter no later than 30 days after the effective date of this decision establishing an Essential Usage Study expenditure balancing account as described in this decision.Application 19-11-019 remains open.This order is effective today.Dated , at San Francisco, California ................
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