II. Factual Background

The essential chronology of facts is undisputed. Increases in PG&E's delayed and estimated bills beginning in 2000 have been associated with PG&E's customer information systems (CIS). The CIS is the primary computer system for creating customer accounts, tracking and managing customer data, calculating and printing bills, and performing hundreds of other core business functions.¹

The increase in delayed bills in 2000 was attributable to an upgrade to PG&E's legacy CIS system (LCIS) in late 1999. Then in early December 2002 PG&E replaced the nearly 40-year old LCIS because it was outdated, inefficient, and no longer able to keep up with the complexity of the tasks required of it. PG&E's new system is called CorDaptix. As part of the initial CorDaptix roll-out and as stabilization period, PG&E imposed a moratorium on certain credit and collection activities. Nonetheless customers began complaining about delayed bills in early 2002. And when this moratorium was lifted in May 2003 complaint levels increased. Initially the Commission's Consumer Affairs Branch (CAB) staff acquiesced in PG&E's interpretation that such delayed bills did not violate PG&E's tariffs,² but in early 2004 it began to question the correctness of these billing practices.³ The Consumer Protection and Safety Division and our Executive Director then began to take the corrective steps that led to this investigation.

¹ PG&E Opening Brief, pp. 19-20.

² See Exh.34, pp. 4-3 to 4-6.

³ See Exh 18, pp. 8 - 9.