3. Implementation of New Practices
Following the en banc and workshop, the Commission has carefully considered the exchange of information between the utilities and the consumer advocates and has determined that there are some interim practices the Commission can implement immediately that are aimed at addressing the Commission's primary focus: having the utilities work with their customers to address bill arrearages before disconnection. While we recognize that disconnections for non-payment of utility bills will never be completely obliterated, we find that the following procedures are intended to offer immediate help for customers to address bill arrearages and avoid disconnections. Therefore, we direct PG&E, SCE, SDG&E and SoCalGas to immediately implement the following practices no later than five business days after the mailing of this order:
1) All CSRs must inform any customer that owes an arrearage on a utility bill that puts them at risk for disconnection that the customer has a right to arrange a bill payment plan extending a minimum of three months in which to repay the arrearage. CSRs may exercise discretion as to extending the three months up to twelve months3 depending on the particulars of a customer's situation and ability to repay the arrearage. CSRs may work with customers to develop a shorter re-payment plan, as long as the customer is informed of the three-month option. Customers must keep current on their utility bills while repaying the arrearage balance.
2) Once a customer has established credit as a customer of that utility, the utility must not require that customer to pay additional reestablishment of credit deposits with the utility for either slow-payment/no-payment of bills or following a disconnection.
3) Each utility is authorized to file a Tier 1 advice letter to open a memorandum account to track any significant additional costs associated with complying with the new practices initiated with this rulemaking, including the operations and maintenance charges associated with implementing the practices as well as any uncollectables that are in excess of those projected in the utility's last general rate case. As part of this proceeding, the Commission will consider the process for determining the categories and amounts of costs in the memorandum account that should be considered reasonable for recovery, as well as the appropriate methods for recovery.
We recognize two important principles: (1) utility service is a matter of health and safety and we do not have the luxury of time to flush out fully best practices in a long proceeding before we take any action to address the current disconnection rate; and (2) we do not have a complete record to fully and finally determine if the above practices are sufficient to help the Commission meet its goal of reducing disconnections whenever some other method of bill payment can be arranged. Therefore, we direct the utilities and the consumer groups to continue their dialogue and efforts to determine what are the best practices, and to assess whether the interim practices we are establishing today are ones that will ultimately further our goals.
To ensure that the Commission and parties can fully evaluate the efficacy of these interim practices, and to assist the Commission in determining whether to maintain, expand, or modify these practices, and whether or if to sunset them, we will require the utilities to submit monthly reports of specific disconnection-related data including the number of disconnections experienced by each utility. Appendix A contains the additional data to be submitted on a monthly basis by each respondent investor-owned utility.
In addition, it has come to our attention through reports on utility-sponsored focus groups that an anomaly occurs in the billing/accounting departments of the utilities when a customer owes both for an arrearage and a current bill. For illustration purposes, assume a customer owes an arrearage of $150, is on a 3-month re-payment plan whereby the customer pays $50 towards the arrearage, and the customer has a current monthly bill of $100. If the customer makes a payment of $150, representing the $50 arrearage payment and the $100 current bill payment, how does the utility ensure that the proper monies are credited to the appropriate accounts? If all $150 is applied to the arrearage, the customer is delinquent on the current bill, whereas if all $150 is applied to the current bill the customer has a credit, but is in default on the arrearage re-payment arrangement. We request that the utilities propose a uniform billing/accounting methodology that ensures that the customer receives proper credit for monies paid.
3 Each utility may implement a repayment plan schedule that exceeds twelve months, but we are not currently requiring any utility to extend the schedule beyond three months.
