TURN's Motion
On November 9, 2005, TURN filed a Motion for an investigation into the billing and collection practices of PG&E. TURN states that an ever-growing number of PG&E customers have contacted TURN with concerns regarding PG&E's billing and collection practices. TURN claims that PG&E appears to be failing to issue timely bills, backbilling customers for periods in excess of the three-month period permitted under Rule 17.1, and requiring customers to provide additional or excessive deposits to ensure continued service. TURN requests that the Commission formally examine whether PG&E's conduct violated Tariff Rule 17.1 and the orders of the Commission. TURN's Motion expresses concern regarding the following three practices:
Delayed Bills - TURN states that PG&E has reported delayed bills reaching as high as 59,000 in a single month, and has ranged between 20,000 and 24,000 per month through August of 2004. However, since under PG&E's practices a bill does not reach the "delayed" category until is has been delayed by more than 30 days from the date it would normally issue, TURN submits that the number of delayed bill would increase if PG&E were required to treat all bills issued after the normal billing date as "delayed" bills.
Estimated Bills - TURN reports that the number of "estimated bills 3each month has reached 179,000 and has ranged between 55,000 and 100,000 in 2004 (through August)." TURN suggests that the numbers reported by PG&E indicate that PG&E may be relying on "estimated" bills for extended, and excessive periods of time even when circumstances permit an actual meter read.
Rule 17.1 - TURN contends that PG&E's collection practices on delayed and estimated bills "violate the plain language of the utility's tariffs,"4 and suggests that PG&E has treated balances from unbilled usage as "unauthorized use of energy" in order to avoid the three month limit on back billing set forth in Rule 17.1.B.2. TURN notes that certain cases, the delayed or estimated billing problems did not cease even after the customer notified PG&E of the missing, incomplete, or incorrect bill.
TURN also expressed concern that PG&E may be requiring customers to provide additional or increased deposits as a result of undercollections associated with delayed or estimated bills.
TURN requests that, at a minimum, the Commission investigate: (1) the scope and cause of PG&E's billing problems, (2) the changes necessary to eliminate those problems; and (3) appropriate remedies for affected consumers. TURN suggests that the Commission seek to identify the impact that PG&E's practices have had on its customers, and require PG&E to "make whole" the customers that have been adversely impacted by PG&E's practices. In addition, TURN requests that the Commission direct PG&E to suspend all service termination for payment delinquencies associated with estimated bills, delayed bills, or other billing error. TURN also requests that the Commission direct that PG&E neither require nor collect any additional deposit for customers whose payment delinquency or service termination was due in part to an undercollection resulting from estimated bills, delayed bills or other billing error.
In addition, TURN suggests that the Commission consider devising a system for tracking information about customers that call with billing or service complaints, particularly the number of service terminations and threatened service terminations, and whether they are due in part and in whole to undercollection on delayed or estimated bills.
TURN recommends that the appropriate vehicle for the Commission's review of PG&E's billing and collection practices is the existing investigation that is a companion proceeding to PG&E's test year 2003 General Rate Case, I.03-01-012.
3 An estimated bill is issued based on the utility's estimate of the customer's consumption, rather than metered consumption.
4 November 9, 2004, TURN Motion, p. 7.
