IV. Commonwealth's Response to CSD's Initial Allegations

Commonwealth represented that, for a variety of reasons, many of its bills for electricity were understated during the last half of 1998. Often, this was due to the difficulty that Commonwealth was experiencing in calculating the Power Exchange credit of the UDCs, given the information that was made available by the UDCs. The credit was the base from which Commonwealth calculated discounts. In addition, there were lags in charges by the California Independent System Operator for ancillary services. As a result, customers often received inaccurately low bills. In some cases, customers were overbilled.

After informing the Commission's Energy Division of the situation, Commonwealth sent a notice to customers advising them that they would receive supplemental bills to correct previous misbillings. In February 1999, supplemental bills were mailed. This triggered an unprecedented number of customer complaints that overwhelmed the four Commonwealth service representatives who were trained to handle customer inquiries. As a result, customers complained to CAB.

Commonwealth stated that since the supplemental billing event, complaints at Commonwealth have dropped to nearly zero. At the same time, the number of customers has grown from approximately 42,000 in February 1999 to over 60,000. Commonwealth's ability to respond to customer concerns has grown as well. In February 1999, there were only 22 call center employees. The number of employees in Commonwealth's call center has expanded to over 60 employees and is expected to increase to over 100. Six call center employees are specifically assigned to customer service, with other employees being trained so as to be able to augment the efforts of the six.