Change Requested a. CRP Home Comfort Eligibility- PGW states in the Amended Proposed 2017-2020 Plan that only low-income customers enrolled in the CRP program are eligible for LIURP. Proposed 2017-2020 Plan at 21. practice of restricting LIURP services to CRP customers excludes several PGW’s groups of low-income customers. One such group is low-income households already receiving a discounted payment through Senior Citizen Discount (SCD) program, PGW’s who are not eligible to apply for CRP. Other groups that are systemically excluded are those low-income customers who are on budget billing, those who are under the one-year provision of CRP, and those who were unable to make a lump sum payment to “stay-out” reenroll in CRP. The LIURP Regulations at Section 58.10 (a)(1) expressly prioritize Proposed Resolution: eligible LIURP customers based on usage, arrears, and income. The regulations do not designate or require that low-income customers be enrolled in customer assistance programs in order to be eligible for LIURP, so the use of CRP/non-CRP status is not an acceptable criterion for eligibility determination. The Commission has previously required that all low-income customers, who otherwise meet eligibility requirements, be allowed to participate in LIURP, especially if they have high usage. PGW should include known low-income customers when determining LIURP all eligibility, regardless of their enrollment status in CRP or request a waiver of Section 58.10 (a)(1) consist with regulations. This is addressed in greater specificity in the section below. Projected Needs Assessment
a. CRP Home Comfort Eligibility- Change Requested PGW states in the Amended Proposed 2017-2020 Plan that only low-income customers enrolled in the CRP program are eligible for LIURP. Proposed 2017-2020 Plan at 21. PGW’s practice of restricting LIURP services to CRP customers excludes several groups of low-income customers. One such group is low-income households already receiving a discounted payment through PGW’s Senior Citizen Discount (SCD) program, who are not eligible to apply for CRP. Other groups that are systemically excluded are those low-income customers who are on budget billing, those who are under the one-year “stay-out” provision of CRP, and those who were unable to make a lump sum payment to reenroll in CRP. Proposed Resolution: The LIURP Regulations at Section 58.10 (a)(1) expressly prioritize eligible LIURP customers based on usage, arrears, and income. The regulations do not designate or require that low-income customers be enrolled in customer assistance programs in order to be eligible for LIURP, so the use of CRP/non-CRP status is not an acceptable criterion for eligibility determination. The Commission has previously required that all low-income customers, who otherwise meet eligibility requirements, be allowed to participate in LIURP, especially if they have high usage. PGW should include all known low-income customers when determining LIURP eligibility, regardless of their enrollment status in CRP or request a waiver of Section 58.10 (a)(1) consist with regulations. This is addressed in greater specificity in the Projected Needs Assessment section below.