6. Comments on Proposed Decision

The proposed decision of the Commissioner in this matter was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were allowed under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments on the proposed decision were filed by PG&E, SCE, and, jointly, by CforAT, Greenlining, NCLC, and TURN. PG&E, SCE, CforAT, DRA, Greenlining, NCLC, and TURN filed replies to the comments. This decision adopts certain revisions that we make in response to the comments and replies, including but not limited to the following:

· This decision continues in effect the requirement adopted in D.10-07-048 that PG&E and SCE shall provide a field person who can collect on a bill during an in-person visit prior to disconnection for medical baseline or life support customers. It also expands the requirement to include customers who certify that they have a serious illness or condition that could become life threatening if service is disconnected. We clarify this requirement to specify that the field representative is not required by this order to accept cash payments. We also provide clarification that customers certifying to an illness or condition that could become life threatening are not required to obtain a physician's statement.

· The proposed decision provided that certain required new practices shall be implemented within 30 days of the date of this order. In response to concerns about the time needed for implementation, we revise the proposed decision to provide that these new practices shall be implemented within 45 days of the date of this order.²⁰

· The proposed decision's requirement that written communications to customers concerning the risk of service disconnection shall provide certain key information to customers in large print is revised to state that the requirement does not apply to billing statements.

· This decision adopts a joint utility proposal regarding uniform timeframes for notices to customers regarding disconnection. We add clarification to the proposed decision's discussion of this issue to confirm that the adopted timeframes are minimum standards and that the utilities may adopt actual practices that are more generous to consumers facing possible disconnection.

A new discussion section (Section 3.15) is added to address comments of consumer groups proposing that the utilities file advice letters to explain how they will implement certain directives in this decision.

²⁰ We reject PG&E's unreasonable and unsubstantiated request to delay implementation of certain measures by more than ten months to January 1, 2013.