6. Discussion

Only a few months have elapsed since the adoption of R.10-02-005 and implementation of the two interim practices intended to reduce customer disconnections. Despite receiving monthly reports from the four utilities, it is too soon to assess the costs of these two interim practices, or whether the practices will ultimately reduce residential disconnections. While the monthly reports show a decrease in the number of customer service disconnections across all four utilities, the reports also show a continuance of two disconcerting trends.

First, the reports show a discrepancy in the number of service disconnections for CARE customers versus those for non-CARE customers. While this disconnection discrepancy has decreased, we are concerned that low income customers continue to experience higher rates of disconnection as compared to non-CARE customers. This decision directs utilities to implement certain measures to limit this difference. Additionally, we will review this anomaly during the second phase of this proceeding to determine the causes and any further corrective measures.

Secondly, the monthly reports show higher rates of service disconnections for PG&E and SCE customers as compared to SDG&E and SoCalGas customers. However, the monthly reports do show improvements for May 2010 and we applaud the utility efforts leading to those improvements. But while we acknowledge the improvements by PG&E and SCE, we look to them to achieve further improvements. We encourage PG&E and SCE to consult closely with the Joint Utilities and implement similar if not exact customer service practices so as to limit significant discrepancies among customer service disconnection rates.

Finally, California's economic problems persist and there is the potential for continued disconnections beginning in the fall as a result of high summer cooling bills. In consideration of all of the above circumstances, it is important that we act now to implement other disconnection practices with minimal cost implications.

We have determined that utilities can implement certain reasonable and low cost modifications to existing customer communications, service, and billing practices to reduce customer disconnections. These measures may not impact all utilities equally since some of the measures are currently used by one or more of the utilities. In this way, this decision adopts certain utility best practices across all affected utilities.

We apply two important criteria in adopting these practices to reduce customer disconnections. First, any changes in customer service practices should have a short implementation period to be effective by winter 2010-2011. Therefore, we will require that these practices be implemented on or before October 1, 2010. Second, in keeping with our stated intent that any solutions that avoid unnecessary disconnections not place an undue cost burden on other customers,⁹ the modifications discussed below consider the estimated costs of implementation and seek to adopt customer service, billing, and communication practices which have minimal cost implications. The utilities may include any significant additional costs of the adopted changes in their memorandum accounts.

The additional practices adopted by this decision as well as a sunset date for these and the two interim practices are discussed below.

⁹ R.10-02-005 at 1.