public utilities commission of the state of california ... · fresno, madera, san bernardino,...

P.O. Box 800 8631 Rush Street Rosemead, California 91770 (626) 302-9645 Fax (626) 302-6396

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations

September 21, 2020

ADVICE 4295-E (U 338-E)

PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ENERGY DIVISION

SUBJECT: Implementation of Emergency Disaster Relief Program in Fresno, Madera, San Bernardino, Tulare, and Los Angeles Counties Due to Wildfires Pursuant to Decision 19-07-015

PURPOSE Pursuant to Ordering Paragraph (OP) 2 of Decision (D.)19-07-015, Southern California Edison Company (SCE) submits this advice letter to implement emergency customer protections for residential and small business customers impacted by wildfires in the Fresno, Madera, San Bernardino, Tulare, and Los Angeles Counties.

BACKGROUND AND DISCUSSION Beginning on September 2, 2020, a significant heatwave brought temperatures over 100 degrees throughout California (Extreme Heat Event) where the National Weather Service issued multiple Excessive Heat and Red Flag Warnings. On September 3, 2020, Governor Newsom declared a Statewide emergency to suspend regulations to create more energy supply and reduce demand on the grid for this Extreme Heat Event, which was expected to continue through September 9, 2020.1 On September 4, 2020, the Creek Fire began burning in Fresno County and spread into Madera County. On September 5, 2020, the El Dorado Fire began burning in San Bernardino County and the Valley Fire began burning in San Diego County. Then on September 6, 2020, Governor Newsom issued an emergency proclamation for the Creek, El Dorado, and Valley Fires.2

1 Governor Newsom’s Proclamation of a Statewide Emergency due to Extreme Heat Event,

available at https://www.gov.ca.gov/2020/09/03/governor-newsom-signs-emergency-proclamation-to-free-up-additional-energy-capacity-amid-heat-wave/

2 Governor Newsom’s proclamation for Creek, El Dorado, and Valley Fires, available at https://www.gov.ca.gov/2020/09/06/governor-newsom-declares-state-of-emergency-in-fresno-madera-mariposa-san-bernardino-and-san-diego-counties-due-to-fire/

ADVICE 4295-E (U 338-E) - 2 - September 21, 2020

In addition to the Creek and El Dorado Fires, which are in SCE’s service territory, the following fires ignited and burned in SCE’s territory:

• The Castle (SQF Complex) Fire ignited on August 21, 2020 in the Sequoia National Forest due widespread lightning strikes that occurred throughout California.3 As of September 14, 2020, the fire has reached the southern boundary of the Sequoia National Park in Tulare County and has burned approximately 100,000 acres, affecting customers in the communities of Springville and Camp Nelson.

• The Bobcat Fire ignited on September 6, 2020 in Los Angeles County, has burned over 100,000 acres and has resulted in evacuation orders for residents in cities that include Arcadia, Sierra Madre, and unincorporated areas of Juniper Hills and Paradise Springs, located in the Antelope Valley.4

Although the Bobcat and Castle (SQF Complex) fires were not included in the Governor’s proclamation, SCE is also extending emergency protections to customers affected by these fires. Pursuant to D.19-07-015, SCE will provide residential and small commercial customers affected by the fires customer protections if the fires have either 1) resulted in the loss or disruption of the delivery or receipt of electrical service5 and/or 2) resulted in the degradation of the quality of electrical service.6 SCE shall provide the following emergency customer protections for up to one year:

1. Waive Service Disconnection, Security Deposit, and Late fees for impacted customers;

2. Expedite move-in and move-out service requests; 3. Stop estimated energy usage for billing attributed to the time when the structure

was unoccupied because of the fires; 4. Implement payment plan options; and 5. Support low-income customers impacted by the fires.

SCE will use the Emergency Customer Protections Memorandum Account (ECPMA) to record costs related to the emergency customer protections for the fires. The protections will be in effect for one year until September 6, 2021, unless otherwise

3 The Castle (SQF Complex) Fire in Tulare County incident overview is available through the

Sequoia National Forest at inciweb.nwcg.gov/incident/7048/ 4 The Bobcat Fire in Los Angeles County incident overview is available through the Angeles

National Forest at https://inciweb.nwcg.gov/incident/7152/ 5 Defined as when the disaster has resulted in the destruction or damage of a structure, such

that electricity is disrupted voluntarily or involuntarily due to safety concerns or re- construction activities to address the damage from a proclaimed state of emergency event.

6 Defined as when the disaster has resulted in the receipt of inadequate service quality of electrical service.


specified or extended by order of the California Public Utilities Commission (Commission).

Eligibility Requirements for Emergency Customer Protections

SCE will work with each of the Fresno, Madera, San Bernardino, Tulare, and Los Angeles Counties Departments of Building and Safety, and its damage assessment teams, to identify homes and small businesses destroyed or damaged, or had degradation of the quality of electrical service, because of the fires. SCE will place each home or small business in one of the two following eligible categories:

• Homes or small businesses destroyed by the fires – These homes and small businesses will be considered a total loss. The customer’s service account will be flagged in SCE’s Customer Service System (CSS) as eligible for protections outlined in D.19-07-015. These accounts will remain flagged until these customers establish a replacement residence or small business or through September 6, 2021, unless specified or extended by order of the Commission.

• Homes or small businesses damaged by the fires – These homes or small businesses are not considered a total loss. However, they have suffered damage due to the fires. The customer’s service account will be flagged in SCE’s CSS and will be eligible for protections outlined in D.19-07-015. These accounts will remain flagged through September 6, 2021, unless specified or extended by order of the Commission.

Billing and Credit Protections

SCE customers impacted by the fires will have their customer accounts identified or flagged in SCE's CSS as eligible for billing and credit protections for a period of one year or as extended by the Commission. SCE is working with local and county agencies to identify those customers impacted by the fires. All “customer care” measures for those impacted by the fires will be managed directly through dedicated and trained staff to ensure appropriate protections are provided. SCE will provide the following billing and credit protections:

1. Waive deposit requirements and expedite service requests; 2. Stop estimated billing; 3. Implement payment options; and 4. Waive deposits and fees and freeze all California Alternate Rates for Energy

(CARE) eligibility reviews.


SCE will not Collect Deposit Requirements for those Seeking to Reestablish Service and Expedite Move-In/Move-Out Service Requests

Pursuant to OP 1 of D.19-07-015, small business customers who request utility service reactivation and have been identified as impacted by the fires will not be required to provide a security deposit for their account for up to one-year post-event. SCE no longer collects deposits for its residential customers per Decision (D.) 20-06-003. The customers impacted by the fires will be managed directly through SCE’s dedicated representatives in its call center, who have been trained on emergency customer protections available for customers impacted by the disaster. Resources in SCE’s call centers and local planning departments are also available to help facilitate expedited move-in and move-out services provided by SCE for a smooth and accelerated experience during the re-building process. SCE will make sure that enough resources will be available to support these expedited services. SCE has established a dedicated team to help impacted customers, support their expedited utility move-in and move-out services, and to inform impacted customers how they can qualify for other customer protections available per D.19-07-015. However, SCE cannot influence or expedite the processes for other city and regulatory agencies overseeing the rebuilding or redevelopment of the impacted customers’ homes and small businesses. If SCE can assist with expediting external non-utility processes, SCE will do so.

SCE will not Bill Estimated Energy Usage for the Time when the Home/Unit/Business was Unoccupied Because of the Fires

SCE only estimates usage data when actual meter data is not reported or obtainable. For customers whose homes and/or businesses were not destroyed, electricity will continue to be delivered and metered to capture actual energy usage. For those customers away from their residence or business when the fire evacuations were in order, SCE will follow regular business practices. If estimated usage data is present on their statements when evacuations were in order, SCE will work with customers to adjust for those periods. For homes and small businesses destroyed by the fires, SCE will close those customer service accounts in SCE’s CSS. Therefore, there will be no reason to estimate the usage of these properties. However, SCE will maintain the customers’ account information and history to support the customers’ rebuilding effort and will transfer the customers’ information to the new residence or small business and re-establish their credit history. SCE, in its regular business practice, also assesses no disconnection charge for homes or small businesses destroyed by fires. Therefore, these customers will not be charged a disconnection charge. SCE will discontinue billing for these customers’ accounts from the date of the fires on August 21, 2020 for the Castle (SQF Complex) Fire, September 4, 2020, for the Creek Fire, September 5, 2020, for the El Dorado Fire, and September 6, 2020 for the Bobcat Fire.


SCE will Work with Customers to Implement Payment Plan Options

SCE has dedicated resources to handle the customer protections provided in D.19-07-015 to support customers impacted by the fires. These resources will manage credit matters and associated service needs. SCE will work with impacted customers to establish reasonable payment arrangements for a period of one year through September 6, 2021, or later as established by Commission order. Reasonable payment arrangements will be determined based upon the individual customer’s needs, and SCE may recommend agency assistance and programs available to qualifying impacted customers. At a minimum, SCE will work with impacted customers who have prior arrearages to establish:

• Initial payment no greater than 20 percent of the amount due; and

• The remainder in equal installments over at least 12 billing cycles. For those impacted customers with utility service but who go into arrearage after September 4, 2020, SCE will establish:

• Initial payment no greater than 20 percent of the amount due; and

• The remainder in equal installments over at least 8 billing cycles. SCE can identify those customers whose homes or small businesses were destroyed or damaged during the fires but identifying other customers who may have financial difficulties following the fires will be more challenging. SCE has trained its dedicated call center staff to inform and support customers who may experience financial difficulty because of the fires. These resources will also help these customers determine if there are other programs available to provide financial assistance or determine if extended payment arrangements can be made. Further, SCE has resources at Local Assistance Centers (LAC) in the affected counties as appropriate, while these locations are open. Representatives at the LACs are trained and dedicated to assisting customers impacted by disasters and assuring all customer protections are being offered. Upon identification of the impacted customers, SCE will immediately confirm that the customer accounts are flagged, suspend disconnection for non-payment and assure that late fees are waived through September 6, 2021 and that deposit requirements are not collected. SCE also does not report late payments to credit reporting agencies on accounts that are active. SCE will keep the impacted customer accounts active for one year to support the home or small business re-building process for those whose homes or small businesses were damaged.


Low-Income Customer Emergency Protections

SCE will provide additional customer protections and services for customers enrolled in the CARE program by manually identifying, and flagging impacted CARE customer accounts, freezing all CARE program standard and high-usage, post-enrollment verification requests, and preventing the removal of impacted customers with pending requests, effective immediately through September 6, 2021, or as further extended by SCE or the Commission. SCE will partner with United Way of Greater Los Angeles, SCE's Energy Assistance Fund (EAF) administrator, to provide up to an additional $100 in bill payment assistance to all impacted income-eligible customers for the next 12 months. The EAF agencies SCE will work with include 44 agencies in San Bernardino, Tulare, and Los Angeles Counties.7

Energy Savings Assistance (ESA) Program The ESA Program is a direct install program that offers income-qualified customers energy efficiency-related services and measures at no cost. The services and measures offered through the ESA program may include the replacement of appliances in working condition for more energy-efficient models. The ESA program may be beneficial for income-qualified customers impacted by the fires that qualify for replacement of existing appliances. When a customer contacts SCE to self-identify as impacted by the fires, SCE will educate low-income customers about the ESA program and, if interested, SCE can deploy its ESA contractor to their home to confirm ESA Program qualification and assist in the enrollment process. Customer Communication and Qualification Plan SCE continues to communicate with customers impacted by the fires as they contact SCE to inform them about their eligibility for SCE's emergency disaster relief program. Further, upon receiving the notice of the impacted customers from the appropriate Department of Building and Safety, SCE can contact customers through targeted messaging using the preferred method of contact to inform them of the eligibility for customer protections. SCE also informs customers, via a dedicated website, about the eligibility of these protections and provides targeted social media communication to inform customers about SCE’s presence at the LACs. SCE partners with a network of over 100 non-profit community and faith-based organizations across its entire service territory to assist customers in enrolling in income-qualified programs such as CARE, EAF and ESA. Specifically, SCE will immediately mobilize and work with such organizations in or near the areas impacted by the fires to disseminate disaster relief information to impacted customers, and information about additional SCE programs. These organizations include:

7 The list of EAF agencies is available at

https://www.sce.com/residential/assistance/energy-assistance-fund. Eligible customers can also contact any EAF agency and apply for the bill payment assistance by phone.


EAF Agencies

Los Angeles County County of LA, Altadena Community Services City of Avalon Recreation Department Salvation Army Bellflower The Salvation Army - Compton East Rancho Dominguez Community Center Catholic Charities - San Juan Diego Center Asian Community Service Center Salvation Army Hollywood The Salvation Army Southeast Communities Salvation Army Inglewood Catholic Charities St Margaret's Center Delhaven Community Resource Center Salvation Army Lancaster Chinatown Service Center Los Angeles Central Salvation Army Koreatown Youth & Community Center Salvation Army East Los Angeles Temple Salvation Army - Siemon Family Center West Angeles Community Development Barrio Action Youth and Family Center Catholic Charities - Long Beach Disabled Resources Center Santa Clarita Valley Senior Center Salvation Army Santa Clarita Santa Clarita Valley Community Center Salvation Army Palmdale Catholic Charities -Pomona Community Center APAC Service Center St. Ferdinand Outreach Center Salvation Army San Pedro San Pedro Service Center City of Santa Fe Springs Gus Velasco Neighborhood Ctr. Salvation Army Santa Monica Salvation Army – Whittier

San Bernardino County Catholic Charities - Hesperia Desert Manna Ministries Catholic Charities - Ontario Salvation Army - Redlands Operation Provider Catholic Charities – San Bernardino


Salvation Army San Bernardino Salvation Army – Victorville

Tulare County Salvation Army – Porterville Community Services and Employment Training

CARE Capitation Agencies Los Angeles County

Alpha Enterprises Asian American Drug Abuse Program Asian Youth Center Best Partners (AKA: Energy Conservation Consultants, Inc.) Chinese Christian Herald Crusades CitiHousing Real Estate Services Disabled Resources Center, Inc. Housing Authority of the County of Los Angeles LTSC Community Development Corporation (formerly Little Tokyo Service Center Inc.) Mexican American Opportunity Foundation New Greater Circle Mission, Inc. New Horizons Circle Mission, Inc. Our Community Works Salvation Army, Santa Fe Springs Santa Anita Family Service Southeast Cities Service Center Southeast Community Development Corp. United Cambodian Community, Inc. Volunteers of East Los Angeles Xfiniti Solutions, LLC

San Bernardino County Chino Neighborhood House Desert Manna Ministries, Inc. Family Service Association of Redlands New Hope Village, Inc. Operation Grace Smiles for Seniors Foundation The League of California Homeowners Victor Valley Community Services Council

Tulare County

Parenting Network Visalia Family Resource Center Salvation Army - Visalia


Emergency Customer Protections Memorandum Account

SCE will record costs associated with customers' protections ordered by D.19-07-015 in the ECPMA.8 The costs recorded to this memorandum account will be incurred beginning September 4, 2020, which is the date of the first fire in SCE’s service territory. Pursuant to the Decision, SCE will seek recovery of these costs in its General Rate Case.

Coordination with Community Choice Aggregators

Pursuant to D.19-07-015, SCE will notify Community Choice Aggregators (CCA) in areas impacted by the fires and will share with the CCA(s) a list of affected customers obtained from the applicable Building and Safety Departments, or other sources to provide alignment between any billing changes as a result of the fires. No cost information is required for this advice letter. This advice letter will not increase any rate or charge, withdraw service, or conflict with any other schedule, or rule. TIER DESIGNATION Pursuant to OP 8 of D.19-07-015, this advice letter is submitted with a Tier 1 designation. EFFECTIVE DATE This advice letter will become effective on September 21, 2020, the same date submitted.

NOTICE Anyone wishing to protest this advice letter 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 letter. Protests should be submitted to:

CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: [email protected]

Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above).

8 See D.19-07-015, OP 4, p. 66.


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:

Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770

Telephone (626) 302-9645 Facsimile: (626) 302-6396 E-mail: [email protected] Diana S. Gallegos Sr. Advisor, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: [email protected]

There are no restrictions on who may submit a protest. However, the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B, R.18-03-011, R.10-02-005, and R.15-05-006 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to [email protected] or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Commission's Process Office at (415) 703-2021 or by electronic mail at [email protected]. Further, in accordance with Public Utilities Code Section 491, notice to the public is given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at https://www.sce.com/wps/portal/home/regulatory/advice-letters.


For questions, please contact Diana Valle at (626) 302-5666 or by electronic email at [email protected].

Southern California Edison Company

/s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D.

GAS:dv:jm

ADVICE LETTER S U M M A R YENERGY UTILITY

Company name/CPUC Utility No.:

Utility type:Phone #:

EXPLANATION OF UTILITY TYPE

ELC GAS

PLC HEAT

MUST BE COMPLETED BY UTILITY (Attach additional pages as needed)

Advice Letter (AL) #:

WATERE-mail: E-mail Disposition Notice to:

Contact Person:

ELC = ElectricPLC = Pipeline

GAS = GasHEAT = Heat WATER = Water

(Date Submitted / Received Stamp by CPUC)

Subject of AL:

Tier Designation:

Keywords (choose from CPUC listing):AL Type: Monthly Quarterly Annual One-Time Other:If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #:

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 NoIf 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: No. of tariff sheets:

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:

Service affected and changes proposed1:

Pending advice letters that revise the same tariff sheets:

1Discuss in AL if more space is needed.

CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx:Facsimile (xxx) xxx-xxxx:Email:

Name:Title:Utility Name:Address:City:State:Telephone (xxx) xxx-xxxx: Facsimile (xxx) xxx-xxxx:Email:

Zip:

Zip:

mailto:EDTariffUnit%40cpuc.ca.gov?subject=

ENERGY Advice Letter Keywords

Affiliate Direct Access Preliminary StatementAgreements Disconnect Service ProcurementAgriculture ECAC / Energy Cost Adjustment Qualifying FacilityAvoided Cost EOR / Enhanced Oil Recovery RebatesBalancing Account Energy Charge RefundsBaseline Energy Efficiency ReliabilityBilingual Establish Service Re-MAT/Bio-MATBillings Expand Service Area Revenue AllocationBioenergy Forms Rule 21Brokerage Fees Franchise Fee / User Tax RulesCARE G.O. 131-D Section 851CPUC Reimbursement Fee GRC / General Rate Case Self GenerationCapacity Hazardous Waste Service Area MapCogeneration Increase Rates Service OutageCompliance Interruptible Service SolarConditions of Service Interutility Transportation Standby ServiceConnection LIEE / Low-Income Energy Efficiency StorageConservation LIRA / Low-Income Ratepayer Assistance Street LightsConsolidate Tariffs Late Payment Charge SurchargesContracts Line Extensions TariffsCore Memorandum Account TaxesCredit Metered Energy Efficiency Text ChangesCurtailable Service Metering TransformerCustomer Charge Mobile Home Parks Transition CostCustomer Owned Generation Name Change Transmission LinesDecrease Rates Non-Core Transportation ElectrificationDemand Charge Non-firm Service Contracts Transportation RatesDemand Side Fund Nuclear UndergroundingDemand Side Management Oil Pipelines Voltage DiscountDemand Side Response PBR / Performance Based Ratemaking Wind PowerDeposits Portfolio Withdrawal of ServiceDepreciation Power Lines

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