Submitted Comment Name Martin Delson Affiliation N/A Subject How should the value of allowances distributed to utilities be used to maximize ratepayer benefit and protect low-income communities? Message Slide 31 asks for Community Feedback. The third bullet point reads: "How should the value of allowances distributed to utilities be used to maximize ratepayer benefit and protect low-income communities?" But those are contradictory goals. Many in the low-income community are not ratepayers: they may be unhoused; many low-income residents may be living in multi-family households with a single utility bill; many may be renting where the utility bill is paid by the landlord. On the other hand, many wealthy residents may be ratepayers for a vacation home as well as a primary residence. Therefore, the goal of protecting low-income communities from the increased cost of fossil fuel is distinct from the goal of maximizing ratepayer benefits, and should take precedence over maximizing ratepayer benefits. In accord with this view, the policy of distributing allowances to utilities to fund the Utility Customer Protection program should be phased out quickly, and the 38% currently allocated to this program should be redirected to a direct transfer, on a per-capita basis, to all California residents. (This can be done by direct bank transfer, or by distribution of a stored value card to residents without bank accounts, ideally on a monthly basis.) If it is possible to do without undue administrative burden, the most affluent residents might be excluded from the transfer. (This might be done most effectively by subjecting the distribution to California income tax where the percentage taxed rises steeply above a certain income threshold.) But whatever the mechanism, low-income residents should be insulated from rising costs of fossil fuels without concern for ratepayer benefits. File Upload (i.e., Attachments): N/A
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