The Sierra Club
Putting customers first: shaping California’s income verification framework for a fairer fixed charge.
California’s first-ever income-graduated fixed charge promised fairer electricity bills for millions of residents—but only if customers could actually access it. The Sierra Club engaged Hawks Peak Strategies to ensure the income verification processes and procedures being designed by a CPUC stakeholder working group were grounded in behavioral science, practical to implement, and frictionless for customers.
The Challenge
In 2024, the California Public Utilities Commission adopted a new income-graduated fixed charge structure—a three-tier rate design intended to reduce electricity bills for lower-income households and accelerate electrification. With a CPUC stakeholder working group convening to develop income verification processes and a filing deadline of late summer 2025, the Sierra Club needed rapid, rigorous analysis to shape a proposal that was practical, cost-effective, and centered on the customer experience.
Our Approach
Dr. Henderson conducted a deep review of the CPUC rulemaking record and benchmarked income eligibility and verification models for low- and moderate-income customers across multiple jurisdictions. She designed metrics for income verification audit and appeals processes, developed customer journey maps, analyzed Census data, and synthesized findings into rapid insights memos to inform the Sierra Club’s policy positions. She also participated in the monthly stakeholder working group on behalf of the Sierra Club, engaging directly with California investor-owned utilities, environmental justice organizations, and CPUC energy staff.
The Outcome
Hawks Peak delivered evidence and analysis for the Sierra Club to meet its’ advocacy and policy needs on income verification processes designed around customers—not bureaucratic convenience.
- Delivered jurisdictional benchmarking across multiple states and programs, identifying best practices for frictionless, low-barrier income verification
- Developed policy positions and advocacy strategy for the Sierra Club’s working group proposal, with a focus on moderate-income tier design and customer-centered eligibility processes
- Provided ongoing stakeholder support through the CPUC working group, ensuring the Sierra Club’s voice was heard alongside utilities and environmental justice organizations
- Applied behavioral science principles to advocate for low-friction verification methods.
Getting the income verification process right is not a technicality—it is the difference between a policy that works on paper and one that actually reaches the customers it is designed to serve.
Why This Work Is Different
Behavioral science embedded in regulatory design—ensuring income verification policy is built around how customers actually navigate systems, not how institutions assume they will.
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