Estimating Eligibility for ESA and CARE Programs

1. Estimating Eligibility for ESA and CARE Programs Low Income Oversight Board Rialto, CA September 20, 2018

2. Regulatory Background • IOUs have been required to submit annual estimates of the number of customers eligible for the CARE and ESA Programs since 2001. • D.01-03-028 adopted a methodology for calculating CARE penetration rates. • The CPUC conducted a Workshop on Penetration Rates for CARE and ULTS Programs on February 6, 2002 to discuss the method for calculating CARE Penetration. • D.02-07-033, OP.4b authorized improvements to the methodology: • “Order and utilize the special tabulations of 2000 Census data as soon as they are available in Fall 2002 to update CARE penetration rates…. As described in this decision, [the IOUs] shall update the number of eligible customers in their service territories using the 2000 Census data required under (b) above with their January, 2003 status report. The report should present a calculation of penetration rates that reflects this updated information and the new enrollments due to automatic enrollment, to date.” • The Commission modified the directives of D.02-07-033 OP.4b in the December 27, 2002 ACR: • “The utilities shall include with their February 2003 rapid deployment status reports, due February 21, 2003, updated numbers of CARE-eligible customers in their service territories using 2000 Census data from Summary File 3. The utilities shall include a detailed calculation of the updated penetration rates, along with a narrative describing any differences between the updated and current penetration rates.”

3. Current Regulatory Mandate • The IOUs are required to update eligibility estimates annually, and to file them by December 31, per Decision 12-08-044. • The IOU-filed tables show-by county- total HHs, demographic eligibility rates for the year, eligible HHs for the year, participating CARE HHs as of December of the year prior, and estimated CARE penetration rates based on the new eligibility estimates and December 31 participation. • The 2018 Annual Eligibility Estimates were filed on February 9, 2018 by PG&E on behalf of the Joint IOUs. • DHHS publishes the Annual Update of the Health and Human Services Poverty Guidelines annually in the Federal Register. • DHHS Poverty Guidelines used to be published at the end of the year, but these are currently published in mid-January (in 2018, this was published on Jan.18). • The IOUs file a motion each year requesting an extension to February to enable Athens Research to incorporate US Department of Health and Human Services poverty guidelines in the estimates. IOUs will request a regular February filing date in their 2021+ Application filings.

4. Purpose of Penetration Estimates • Annual Estimation of CARE, FERA, and ESA Eligibility: • Supports robust and accurate IOU reporting of “penetration” (enrollment ratios) for CARE and ESA. Tracking penetration in small areas is used for targeting marketing and recruitment. It is also used for LINA studies and other LI research for verification sampling plans. • Estimates are produced by Athens Research and released to IOUs for filing purposes in early February. • Estimates of the proportion of CARE, FERA, and ESA-eligible by utility and county are used to establish the denominators for reporting IOU penetration throughout the year.

5. annual estimation Methodology • Based on small area demographic estimation/forecasting techniques (such as iterative proportional fitting) developed for Southern CA Assn of Governments in 2001. • Uses a combination of data sources (at first, primarily Applied Geographic Solutions block group data, and utility zip level counts) andmethods. • Includes approximately 114 income-related parameters released at each geographical level. • Techniques, geographical coverages, and data sources have been updated as improvements became available or to meet additional requests/needs.

6. Changes and improvements to Estimation Methodology • 2001: CARE and ESA eligibility increased to 175% of Federal Poverty Level (1-2 person HHs bundled at 2-person limit), with 200% FPL for households with elderly heads. • 2005: Applied flat 200% FPL to all HHs, regardless of age. • 2009: Began providing an ‘ACS-PUMS’ block group income raking adjustment to overcome timing issues (demographic vendor releases precede the late autumn release of the American Community Survey). • 2009: Incorporated a model to include mid PY to Q3 Current Year labor market changes in response to Great Recession job separation (changes were outstripping vendor and/or ACS data sets). • Eligibility estimates based upon current year income, rather than previous year income. • Method uses Current Population Survey, IPUMS, ACS PUMS and medium-level geography California EDD data in modeling these changes, and distributes them among households in block groups, applying a CPS-based multinomial logit model.

7. Changes and improvements to Estimation Methodology (con’T) • 2009: Began adding estimates of categorical and net categorical eligibility. • Net categorical eligibility: households that are eligible for CARE or ESA based on categorical program participation, regardless of income-eligibility. • 2012-2015: additional geographies added to annual estimates. • Includes Public Use Microdata Area, CBSA, Tribal Lands, various water related geographies.