5. Parties' Comments

Opening and reply comments were filed by PG&E, SCE, the Joint Utilities, TURN, DRA, Greenlining and Disability Rights Advocates (DisabRA) (Joint Comments), The City and County of San Francisco (the City), and the National Consumer Law Center (NCLC), on March 12, and April 2, 2010, respectively.

Non-utility parties recommend that utilities adopt changes in contacting customers including, automated calls, language options, outreach proposals, training for CSRs, and improvements in communications with disabled customers. Non-utility parties also recommend changes in customer deposit requirements, use of remote service disconnections, incorporation of best practices used to work with community and faith-based organizations, and billing practices. DRA and TURN recommend that the two interim customer service disconnection practices adopted in R.10-02-005 be continued into 2011.

Utility comments explain the customer service practices currently employed by each utility and how these practices notify customers of the potential for disconnection due to arrearages in unpaid bills. Utilities contend that they provide numerous notices to customers and that they desire to avoid disconnections when possible. Utilities recommend various cost mechanisms resulting from changes in current customer disconnection practices, and request that any modifications to current practices identify sunset dates.

Although the comments provided a significant number of recommended practices for addressing customer disconnections, with few exceptions, the comments did not provide the costs of implementing changes. Therefore, on April 16, 2010, the Assigned Administrative Law Judge (ALJ) issued a ruling (ALJ Ruling) which requested utility information necessary to analyze the complexities and costs of new and proposed practices affecting customer disconnections. The utilities provided responses on April 28, 2010.