BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Transcription

1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Petition of The Utility Reform Network to Adopt, Amend, or Repeal a Regulation Pursuant to Pub. Util. Code Section Petition (Filed June 19, 2009) RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO THE ADMINISTRATIVE LAW JUDGE S RULING REQUIRING INFORMATION REGARDING CUSTOMER PAYMENT PLANS AND DEPOSITS JENNIFER TSAO SHIGEKAWA MONICA GHATTAS Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) monica.ghattas@sce.com Dated: August 14, 2009 LAW-#

2 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Petition of The Utility Reform Network to Adopt, Amend, or Repeal a Regulation Pursuant to Pub. Util. Code Section Petition (Filed June 19, 2009) RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO THE ADMINISTRATIVE LAW JUDGE S RULING REQUIRING INFORMATION REGARDING CUSTOMER PAYMENT PLANS AND DEPOSITS I. INTRODUCTION Pursuant to the ruling of Administrative Law Judge s Ruling Requiring Further Information dated August 4, 2009, Southern California Edison Company (SCE) herein respectfully submits its response. II. RESPONSES Question 1: Do the terms and conditions of payment plans for residential customers consider the customer s ability to pay? If so, how? SCE Response: SCE considers the customer s ability to pay when establishing payment extensions or payment arrangements based on the customer s representation of his/her ability to pay within the parameters of SCE s Tariff Rules and credit policy guidelines. In late 2008, SCE modified the application of its credit policies for residential customers consistent with Rules 6, 9-1 -

3 and 11 to lengthen the time periods for payment arrangements and extensions to help customers in an arrears situation avoid service termination. Question 2: Do the terms and conditions of payment plans for residential customers require the customer to participate in any programs aimed at low-income customers such as the Low-Income Energy Efficiency Program? If so, which programs are required? SCE Response: SCE does not require residential customers to participate in any income-qualified programs as a condition for payment arrangements or payment extensions. However, when discussing payment arrangements or payment extensions with residential customers, SCE s Customer Service Representatives (CSRs) may provide customers information regarding programs or agencies that could help them manage their utility bills and obtain assistance in paying their bills, as discussed in Response 3 below. Question 3: When customers inquire about payment plans for residential customers, are they offered programs aimed at low-income customers? If so, which ones? SCE Response: Yes, when residential customers inquire about payment plans including payment extensions and payment arrangements, SCE s CSRs generally offer customers information on the following income-qualified programs: California Alternative Rates for Energy (CARE) 1 Family Electric Rate Assistance (FERA) Low Income Energy Efficiency (LIEE) program assistance 2 Other income-qualified assistance programs. Moreover, as of July 2009, SCE now accepts phone enrollment 3 for the CARE program as another way to assist customers and achieve the CARE eligibility enrollment goal of 90 percent by As of June 30, 2009, SCE s CARE enrollment was 1.2 million customers or 85 percent of eligible customers. 2 LIEE measures include installation of free energy efficiency measures such as energy efficient refrigerators, compact florescent light bulbs, weatherization services and cooling measures. SCE expects to assist 80,000 customers with LIEE measures in CARE phone enrollment is a pilot program which began on July 10, 2009 and is already proving successful as evidenced by the 670 customers enrolled from July 10 through July 27,

4 SCE s CSRs also provide customers with information on income-qualified payment assistance programs such as SCE s Energy Assistance Fund (EAF) 5 and the Low Income Home Energy Assistance Program (LIHEAP). Additionally, CSRs provide customers with referrals to agencies that may be able to provide payment assistance, such as the United Way, Salvation Army and Catholic Charities. Question 4: When residential customers seek to re-establish service after termination for non-payment, under what circumstances are deposits required? How is the deposit determined? Are there ways the customer can avoid having to pay a deposit, such as by receiving budget counseling or participation in programs aimed at low income customers, etc.? SCE Response: When residential customers seek to re-establish service after termination for non-payment, each applicant is required to re-establish credit by making a deposit. The deposit requirement is determined in accordance with Tariff Rule 7.A.2 which allows SCE to secure a deposit up to twice the maximum monthly bill for SCE charges during the prior twelve month period. SCE s CSRs have the ability to reduce or waive the deposit amount under certain circumstances after reviewing the customer s account information. Consistent with Rule 7, for customers who are required to pay a deposit, SCE may bill the deposit for reestablishment of credit rather than making the deposit immediately due and payable prior to reconnection. In addition, SCE offers payment arrangements and extensions on these deposits when discussing reconnection of service options. SCE does not offer customers the option to participate in budget counseling programs as a way to reestablish credit. Continued from the previous page 4 The Commission established this goal in Decision (D.) The maximum CARE program enrollment is estimated to be 90 percent of income-eligible customers as approximately 10% of income-eligible customers will never participate regardless of awareness programs and enrollment efforts. 5 EAF is a program funded by donations from SCE employees, customers and shareholders in order to make available an additional $100 in bill payment assistance once every twelve months to income-qualified customers

5 Question 5: Does SCE object to the measures imposed during the 2005/2006 winter timeframe should these requirements [2005/2006 winter initiative] be implemented this winter [2009/2010] and if so, why and under what circumstances would SCE waive its objection? Winter 2005/2006 requirements in Decision : The utilities shall not shut off service during the winter months to customers who continue to make minimum bill payments (at least 50% of the current bill) and agree to participate in a utility-offered payment plan. Utilities shall waive reconnection fees and deposits for California Alternative Rates for Energy customers during the winter months. SCE Response: SCE objects to the imposition of a winter initiative for that replicates the winter initiative because, as stated in SCE's Response and Reply Comments to TURN's Petition, SCE has not experienced an increase in the number of customers in arrears in recent months, primarily due to the immediate and deliberate steps SCE took so that customers in an arrears situation could avoid service termination. Moreover, the 2005/2006 winter initiative was established in response to different circumstances than those experienced today, namely a significant increase in natural gas prices and bills. Additionally, electric bills in the winter are much lower than those in the summer, and therefore there is no reason for such an initiative to be imposed on electric bills in the winter season. Finally, should the Commission consider establishing a winter initiative again, the Commission needs to consider the impact that such action will have on other residential customers, who will bear the cost of any such initiative at a time when they too are struggling to make ends meet. SCE is actively planning a meeting with TURN and DRA to discuss alternatives to the winter moratorium and will collaboratively work with the other investor owned utilities and other interested stakeholders to share program successes and consider additional measures that could be implemented to further assist customers

6 / / / / / / Respectfully submitted, JENNIFER TSAO SHIGEKAWA MONICA GHATTAS /s/ MONICA GHATTAS By: Monica Ghattas Attorneys for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: (626) Facsimile: (626) monica.ghattas@sce.com August 14,

7 CERTIFICATE OF SERVICE I hereby certify that, pursuant to the Commission s Rules of Practice and Procedure, I have this day served a true copy of RESPONSE OF SOUTHERN CALIFORNIA EDISON COMPANY (U 338-E) TO THE ADMINISTRATIVE LAW JUDGE S RULING REQUIRING INFORMATION REGARDING Customer Payment Plans and Deposits on all parties identified on the attached service list(s). Service was effected by one or more means indicated below: Transmitting the copies via to all parties who have provided an address. First class mail will be used if electronic service cannot be effectuated. Executed this 14 th day of August, 2009, at Rosemead, California. /s/ CYNTHIA CHILDS Cynthia Childs Project Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

8 CPUC - Service Lists - P Page 1 of 2 8/14/2009 CPUC Home CALIFORNIA PUBLIC UTILITIES COMMISSION Service Lists PROCEEDING: P PETITION OF THE UTIL FILER: THE UTILITY REFORM NETWORK LIST NAME: LIST LAST CHANGED: AUGUST 5, 2009 DOWNLOAD THE COMMA-DELIMITED FILE ABOUT COMMA-DELIMITED FILES Back to Service Lists Index Parties JON HOWAT MONICA GHATTAS NATIONAL CONSUMER LAW CENTER SOUTHERN CALIFORNIA EDISON COMPANY 7 WINTHROP SQUARE 2244 WALNUT GROVE AVENUE BOSTON, MA ROSEMEAD, CA FOR: NATIONAL CONSUMER LAW CENTER FOR: SOUTHERN CALIFORNIA EDISON COMPANY KIM F. HASSAN RASHID A. RASHID ATTORNEY AT LAW SAN DIEGO GAS & ELECTRIC COMPANY LEGAL DIVISION 101 ASH STREET, HQ-12 ROOM 4107 SAN DIEGO, CA VAN NESS AVENUE FOR: SAN DIEGO GAS & ELECTRIC COMPANY, SAN FRANCISCO, CA SOUTHERN CALIFORNIA GAS FOR: DRA HAYLEY GOODSON DANIEL F. COOLEY ATTORNEY AT LAW ATTORNEY AT LAW THE UTILITY REFORM NETWORK PACIFIC GAS AND ELECTRIC COMPANY 115 SANSOME STREET, SUITE BEALE STREET, B30A, PO BOX 7442 SAN FRANCISCO, CA SAN FRANCISCO, CA FOR: THE UTILITY REFORM NETWORK FOR: PACIFIC GAS AND ELECTRIC COMPANY STEPHANIE CHEN MELISSA W. KASNITZ LEGAL ASSOCIATE ATTORNEY AT LAW THE GREENLINING INSTITUTE DISABILITY RIGHTS ADVOCATES 1918 UNIVERSITY AVENUE, 2ND FLOOR 2001 CENTER STREET, FOURTH FLOOR BERKELEY, CA BERKELEY, CA FOR: THE GREENLINING INSTITUTE FOR: DISABILITY RIGHTS ADVOCATES Information Only

9 CPUC - Service Lists - P Page 2 of 2 8/14/2009 HOLLY LLOYD KRISTIEN TARY SOUTHWEST GAS CORPORATION STATE REGULATORY AFFAIRS 5241 SPRING MOUNTAIN ROAD SOUTHWEST GAS CORPORATION LAS VEGAS, NV SPRING MOUNTAIN ROAD LAS VEGAS, NV CASE ADMININSTRATION CASSANDRA SWEET SOUTHERN CALIFORNIA EDISON COMPANY DOW JONES NEWSWIRES 2244 WALNUT GROVE AVENUE 201 CALIFORNIA ST., 13TH FLOOR ROSEMEAD, CA SAN FRANCISCO, CA CALIFORNIA ENERGY MARKETS MICHELLE L. WILSON 425 DIVISADERO ST., SUITE 303 ATTORNEY AT LAW SAN FRANCISCO, CA PACIFIC GAS AND ELECTRIC COMPANY PO BOX 7442, LAW DEPT. SAN FRANCISCO, CA MARK TUCKER MICHELLE MISHOE REGULATORY MANAGER PACIFICORP PACIFICORP 825 NE MULTNOMAH STREET, SUITE NE MULTNOMAH STREET, STE PORTLAND, OR PORTLAND, OR State Service JEFFREY P. O'DONNELL LEE-WHEI TAN DIVISION OF ADMINISTRATIVE LAW JUDGES CARRIER OVERSIGHT AND PROGRAMS BRANCH ROOM 5111 AREA 3-D 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA MATTHEW DEAL TORY FRANCISCO EXECUTIVE DIVISION ENERGY DIVISION ROOM 5215 AREA 4-A 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA SAN FRANCISCO, CA TOP OF PAGE BACK TO INDEX OF SERVICE LISTS