September 5, SoCalGas Advice No (U 904 G) Public Utilities Commission of the State of California

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1 Lee Schavrien Director Regulatory Case Management and Tariff Administration 101 Ash Street San Diego, CA Tel: Fax: Pager: September 5, 2000 SoCalGas Advice No (U 904 G) Public Utilities Commission of the State of California Subject: Augmentation of Southern California Gas Company s Low Income Energy Efficiency (LIEE) and California Alternate Rates for Energy (CARE) PY2000 Program Budgets in Compliance with Commission Decision and Other Commission Directives Sempra Energy, on behalf of Southern California Gas Company (SoCalGas) hereby submits the following Plan Year (PY) 2000 budget augmentation as shown on the enclosed Attachments B and C. Purpose The purpose of this filing is to seek California Public Utilities Commission (Commission) authorization to augment SoCalGas low-income program budgets for: 1) Additional LIEE and CARE studies and reports, including measurement and evaluation studies, as set forth in OP 11 of Commission Decision (D.) dated July 6, 2000, and 2) Energy Division staff costs as authorized in D Background On July 1, 1999, SoCalGas filed Application (A.) requesting approval of its program plans and budgets for the PY2000 low-income programs. In OP 11 in D , the Commission ordered that within sixty days of the decision: the utilities shall file advice letters requesting a budget augmentation sufficient to cover the cost of the new studies and reports specified in this decision. The budget augmentation request shall include a breakout of the cost of each study or report.

2 Advice No September 5, 2000 On December 29, 1999, an Assigned Commissioner s Ruling (ACR) in R was issued which initiated a low-income Weatherization Installation Standardization Project (Standardization Project). This Standardization Project was further clarified in an ACR dated March 2, As the scope of this project has expanded and developed over time, it was necessary for the team to request an additional Phase 2 1 be added to the project. Most recently, on August 25, 2000, the Standardization Project Team requested a Phase 3 be added to the Standardization Project. The Commission s action on the Phase 3 request is still pending. As a result of these standardization efforts, SoCalGas and the other investor-owned utilities (IOUs) are incurring additional costs which were not anticipated or included in SoCalGas PY2000 budget application (A ) and which all the IOUs believe should also be included in this filing. In D (OP 9), the Commission ordered the utilities to reimburse the Commission for Energy Division staffing in the amount of $394,000 for PY2000, for five staff positions and one staff attorney, with confirmation of this funding found in the California Budget Act. At the time of SoCalGas PY2000 program application (A ), these funds for PY2000 were requested as part of the funds requested for the Low Income Advisory Board (LIAB). In Resolution E-3646 (March 16, 2000), the Commission authorized funding in the CARE programs for a statewide needs assessment of low-income customers which was to be completed in two phases. In May of 2000, the Energy Division, utilities, and interested parties began working on Phase 1. SoCalGas did not include Phase 1 funding in its originally filed PY2000 CARE budget and is identifying the expenditures within this filing. Lastly, in D dated May 4, 2000, the Commission adopted the formation of a measurement and evaluation body known as the California Measurement Advisory Council (CALMAC) and created a LIEE Committee to oversee the development of plans for evaluation studies and the procedures and protocols for measurement, evaluation, and reporting of costs and benefits of LIEE programs. The CALMAC LIEE Committee, referred to as the Low Income Measurement and Evaluation Committee (LIMEC) has since met and identified studies (and associated costs) which are included in the augmented budgets of the joint utilities. (See Attachment B.) These measurement and evaluation costs were not included in SoCalGas LIEE program budget filed in A Information SoCalGas, San Diego Gas and Electric (SDG&E), Southern California Edison (Edison), and Pacific Gas and Electric (PG&E) have identified joint utility studies and reports and determined preliminary estimates of costs. The costs were allocated among the utilities according to established allocation procedures found in E-3585 and E The cost estimates developed include: (1) the reports and studies ordered by the Commission in D , (2) the costs of all three phases of the Standardization Project, (3) the costs of the Low-Income Measurement and Evaluation Committee s evaluations and reports, and (4) the Energy Division staff support costs. 1 ALJ Ruling dated May 24, 2000 approved the Phase II Standardization Project.

3 Advice No September 5, 2000 Attachment B, Table 1, of this Advice Letter shows the estimated total cost of each study and report and SoCalGas share of the additional costs split between its CARE program and its LIEE program, if applicable. Also included in Attachment B are the estimated costs for PY2000 Energy Division staff. In D , SoCalGas was asked to complete two feasibility analyses and file reports which SoCalGas believes requires additional, incremental funding to complete: 1. [SoCalGas] shall document their in-house training costs and training requirements for the LIEE program... shall be used as a benchmark for the utility s presentation and review of proposal from other market entities. [SoCalGas] in coordination with the Energy Division, shall jointly conduct public workshops to develop, explain, and obtain feedback on (1) their calculations of current training costs, and (2) how best to obtain comparison cost information from other market entities. These costs are to be presented during the PY2002 program review on a standardized, consistent basis. 2. SoCal[Gas] is directed to explore with interested parties the feasibility of providing specialized training and outsourcing with third parties to provide these [furnace/replacement] inspections. Estimated funding of $100,000 to support these two studies is included in Attachment B as Table 2. Attachment C contains the PY2000 LIEE Budget and Goals Table 1 and CARE PY2000 Program Budget as filed in A revised to include the LIAB budget revisions and augmentation described herein. SoCalGas believes that all LIEE administrative costs described herein should not be included in the cost-effectiveness tests. Nor does SoCalGas include these costs in its shareholder incentive mechanism for PY2000. The joint utilities have estimated the costs of the joint studies and reports ordered by the Commission at $1,951,666. SoCalGas LIEE share is $454,502, which includes a PY2000 M&E Study and two other studies to be completed by CALMAC. SoCalGas CARE program s share of the total cost is $33,415. SoCalGas share of the Needs Assessment is $55,800. The LIGB costs have been reduced based on the LIAB authorized budget of $309,860 (D ). SoCalGas LIEE program share of LIAB funding for PY2000 is $23,400; SoCalGas CARE program share is $23,240. Energy Division Staff funding for PY2000 is planned at $394,000. SoCalGas LIEE program share of staff costs is estimated at $29,550; SoCalGas CARE program share of staff costs is $68,950. Attachment B contains a project breakdown of costs other than the LIAB budget. As the Commission ordered the utilities to provide the total costs of added studies and reports in this filing, SoCalGas has done so, knowing that all the estimated costs will

4 Advice No September 5, 2000 not be invoiced during PY2000. However, it is SoCalGas intent to carry over unspent funds authorized for reports and studies by the Commission in this filing for use in PY2001. SoCalGas is not requesting authority to increase rates to fund the augmented LIEE and CARE program activities requested herein, but instead is seeking the authority to utilize funds from the existing LIEE and CARE balancing accounts. Protest Anyone may protest this advice letter to the California Public Utilities Commission. The protest must state the grounds upon which it is based, including such items as financial and service impact, and should be submitted expeditiously. The protest must be made in writing and received within 20 days of the date this advice letter was filed with the Commission. There is no restriction on who may file a protest. The address for mailing or delivering a protest to the Commission is: IMC Branch Program Manager Energy Division California Public Utilities Commission 505 Van Ness Avenue, Room 4002 A copy should also be mailed to the attention of Energy Division-IMC Branch, Room 4005 (at the address shown above). It is also requested that a copy of the protest be sent via electronic mail and facsimile to Sempra Energy on the same date it is mailed or delivered to the Commission (at the addresses shown below). Attn: Sid Newsom Regulatory Tariff Administration Sempra Energy - GT14D6 555 West Fifth Street Los Angeles, CA Facsimile No. (213) snewsom@sempra.com Attn: C. Richard Swanson Regulatory Tariff Manager Sempra Energy - HQ14C 101 Ash Street San Diego, CA Facsimile No. (619) rswanson@sempra.com

5 Advice No September 5, 2000 Effective Date This advice letter is being filed pursuant to OP 11 of D Therefore, it is requested that this filing become effective on October 15, 2000, which is forty (40) days regular statutory notice. Notice In accordance with Section III.G of General Order No. 96-A, a copy of this advice letter is being sent to the parties listed on Attachment A, to the Low-Income Advisory Board, and to the parties in A LEE SCHAVRIEN Director -- Regulatory Case Management and Tariff Administration Sempra Energy Attachments

6 ATTACHMENT A Advice No General Order 96-A Distribution List Burbank Public Service Department California Manufacturers Association City of Anaheim Public Utilities Department City of Azusa Light and Power Department City of Banning Municipal Utilities City of Lompoc City of Los Angeles City of Riverside, Public Utilities Department City of Vernon, Director, Water & Power Department Colton Bureau of Light & Water General Services Administration, San Francisco General Services Administration, Washington D.C. Glendale Public Service Department Imperial Irrigation District Long Beach Gas Department Los Angeles Department of Water and Power March Air Force Base Naval Facilities Engineering Command, Western Division Pacific Gas and Electric Company Pasadena Water and Power Department San Diego Gas & Electric Company Southern California Edison Company Southwest Gas Corporation The Utility Reform Network Vandenberg Air Force Base

7 Case Id: A Case Description: Low Income Assistance (A /011/012) Page: 1 Daniel W. Meek, Atty. at Law S.W. 4th Ave. Portland, OR Bay Area Poverty Resource Council William F. Parker, President 930 Brittan Ave. San Carlos, CA James Hodges 4720 Brand Way Sacramento, CA CPUC - ALJ Division Meg Gottstein 505 Van Ness Avenue, #5044 Meg Gottstein National Street P. O. Box 210 Volcano, CA CPUC - Analysis Branch Zaida Amaya-Pineda 505 Van Ness Ave., Area 4-A CPUC - CSD Stephen J. Rutledge 505 Van Ness Avenue, Rm CPUC - Energy Division Anne Premo 505 Van Ness Avenue CPUC - Energy Division Donna L. Wagoner 505 Van Ness Ave., Area 4-A CPUC - Executive Division Barbara Ortega 320 West 4th Street, Suite 500 Los Angeles, CA CPUC - IMC Branch Colleen Sullivan 505 Van Ness Ave., Area 4-A CPUC - Legal Division Darwin Farrar 505 Van Ness Ave., Rm CPUC - Legal Division Ira Kalinsky 505 Van Ness Avenue, Rm CPUC - ORA Thomas W. Thompson 505 Van Ness Avenue - Rm 4209 CPUC - Utility Performance&Analysis Josie Webb 505 Van Ness Ave., #4209 Cal/Neva CAA Marty Omoto th St., #200 Sacramento, CA Dept. of Community Services Timothy M. Dayonot 700 North 10th Street, Rm. 258 Sacramento, CA Dept. of Community Svcs. Ulla Maija Wait 700 North 10th St., #258 Sacramento, CA Insulation Contractors Assn. Robert E. Burt 1911 F Street Sacramento, CA Latino Issues Forum Susan E. Brown 785 Market St., 3rd Fl. San Francisco, CA PG&E J. Michael Reidenbach 77 Beale St., Rm. 3127, B30A San Francisco, CA Pacific Gas and Electric Co. Robert B. McLennan 77 Beale Street, Room 3123 San Francisco, CA Perkins, Mann & Everett Jerry H. Mann 2222 W. Shaw Ave., #202 Fresno, CA Richard Heath & Associates Roxanne Figueroa 604 Bancroft Way Berkeley, CA SESCO, Inc. Richard Esteves 77 Yacht Club Drive, #1000 Lake Forest, NJ Sempra Energy Paul A. Szymanski 101 Ash Street San Diego, CA Southern California Edison Co. Jennifer R. Hasbrouck 2244 Walnut Grove Ave. Rosemead, CA Southern California Edison Co. Laura A. Larks 2244 Walnut Grove Ave., Rm. 353 Rosemead, CA Western Mobilehome Park Assn Sheila Day 455 Capital Mall, Suite 800 Sacramento, CA Winegard Energy Wallis J. Winegard 1755 E Huntington Dr., #201 Duarte, CA 91010

8 SO CAL GAS COMPANY PY2000 LIEE AND CARE BUDGET AUGMENTATION Attachment B Advice No Page 1 of 2 Table 1.1--Joint Utility Studies and Reports Budget--SoCalGas Allocation Total Utilities' SoCalGas Cost 25% Total Budget Augmentation for Studies and Reports $ 1,951,666 $ 487,917 CARE $ 133,660 $ 33,415 LIEE $ 1,818,006 $ 454,502 PROJECT PLANS For CARE and LIEE $ 15,000 $ 15, Development of Customer Bill of Rights $ 15,000 $ 3,750 CARE $ 10,500 $ 2,625 LIEE $ 4,500 $ 1,125 Note: Costs for this study have been removed from Standardization Team Budget. For LIEE $ 1,813,506 $ 453, LIEE Standardization Project $ 714,850 $ 178, Redesign of Inspection Pass Rates to identify alternative $ 23,656 $ 5,914 methods of judging LIEE contractor performance and propose best method. 3. Standardization of LIEE Bidding Guidelines $ 350,000 $ 87, Pay for Measured Savings Program Development $ 150,000 $ 37, LIMEC Responsibilities Pay for Measured Savings M&E $ 150,000 $ 37, Development of Standard LIEE Bill Savings Reporting $ 75,000 $ 18, LIMEC Cost Effectivness Study $ 150,000 $ 37,500 8 LIMEC Statewide M&E of PY2000 $ 200,000 $ 50,000 For CARE $ 123,160 $ 30, Development of Standardized CARE Data Collection/Form $ 38,160 $ 9, Development of Standardized CARE Penetration Methodology $ 85,000 $ 21,250

9 SO CAL GAS COMPANY PY2000 LIEE AND CARE BUDGET AUGMENTATION Attachment B Advice No Page 2 of 2 Table 1.2 Joint Utility Needs Assessment Total Utilities' SoCalGas Cost 25% Needs Assessment--Phase % CARE $ 223,200 $ 55,800 Table 1.3 Joint Utility Energy Division Budget Total Utilities' SoCalGas Cost 25% CPUC Energy Division Staff Costs PY2000 $ 394,000 $ 98,500 CARE $ 275,800 $ 68,950 LIEE $ 193,060 $ 29,550 Table 2--SoCalGas Unique LIEE Study and Report Budget SoCalGas 100% Total Budget Augmentation $ 100,000 PROJECT PLANS 1. Outsourcing of Furnace Repair/Replacement Inspections $ 50, Study of LIEE Training Cost $ 50,000 1 It is uncertain at this time, what, if any, further efforts may be required in standardizing the data collection of CARE cutomer information is believed the utilities are currently collecting the same data.

10 SOCALGAS' 2000 BUDGET AND GOALS FOR DIRECT ASSISTANCE PROGRAM-- REVISED AUGUST 31, 2000 LIEE Services Weatherization Program $12,638,420 Weatherize 25,000 Units Energy Education and Assessment $848,750 Educate 39,400 Customers Training Center $225,531 Train 450 Contractor Employees Furnace Program $4,156,121 Repair/Replace 3,500 Furnaces Table 1 BUDGET AND GOALS Attachment C.1 Advice No DAP Programs 2000 BUDGET (1999 $) GOALS Non-Program LIGB 2000 Operating Budget $23,240 n/a Energy Division Support Staff PY2000 $29,550 M&E Studies $125,000 Regulatory Oversight, Reports and Studies $429,502 TOTAL REVISED BUDGET $18,476,113

11 Attachment C.2 (2nd Revision) SoCalGas Advice No Substitute Sheet REVISED CALIFORNIA ALTERNATE RATES FOR ENERGY PY2000 PROGRAM BUDGET CARE Outreach, Operations Processing $ 2,050,000 LIGB PY2000 Operating Expenses $ 54,226 Energy Division Staff PY2000 $ 68,950 Jt. Utility Statewide Outreach Pilot $ 138,542 Regulatory Oversight, Reports and Studies $ 33,415 Needs Assessment--Phase 1 $ 55,800 Total Administrative Expenses$ 2,400,933 Estimated CARE Rate Subsidy $ 23,242,000 Estimated CARE SEC Credit $ 1,908,000 Total Subsidies and Credits$ 25,150,000 TOTAL PY2000 REVISED CARE BUDGET $ 27,550, Revised based on LIAB budget authorized in D , dated June 8, Pursuant to Resolution E-3601, dated June 3, (Total authorized is $237,500 for June 1, 2000 through May 31, 2001). (Breakdown is as follows: $138,542 for PY2000 and $98,958 for PY2001). 3. Pursuant to Resolution E As authorized in BCAP Decision , dated 4/20/00