PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

ENERGY DIVISION				RESOLUTION E-3642
							DECEMBER 16, 1999

RESOLUTION

E-3642.  Pacific Gas and Electric Company requests approval of sample billing forms submitted under General Order 96-A section II.C. (5).  Rejected.

By Advice Letter  2180-G/1913-E filed September 15, 1999.
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SUMMARY

This resolution rejects Advice Letter (AL) 2180-G/1913-E based on non-compliance with General Order 96-A Section II.C. (5).

PG&E is ordered to file a new advice letter within 30 days of the date of this resolution.

BACKGROUND

General Order 96-A, Section II.C.(5) states:  

“Sample copies of printed forms that are normally used in connection with customers’ services such as applications for service, regular bills for service, contract forms, delinquency notices, disconnect notices, deposit receipts, and similar forms shall be considered a part of a utility’s tariff schedules.  Each form should be mounted on a regularly numbered tariff sheet showing the name or title of the form.  Such forms shall be maintained currently up-to-date in the same manner as rates, charges and rules, insofar as changes therein affect rates and conditions of service.  Forms used by governmental agencies may be used in lieu thereof when not in substantial conflict with provisions of this Order.”

AL 2040-G/1697-E, effective April 22, 1999, stated: “The revised Energy Statement form will provide PG&E the flexibility to quickly accommodate business and customer needs by moving to a two-page billing format and to provide our customers with more information about their account beginning 1/1/98.”  
AL 2040-G/1697-E included updated billing statements with a page showing a blue strip across the top with the PG&E logo and form name.  The center portion was blank to accommodate standard computer generated billing information.  The bottom notes: “This bill is now due and payable” along with the recycled paper notation, the form number and last revision date.  

In a conference of March 10, 1999 with PG&E, the Energy Division explained that the blank pages were not acceptable.  PG&E provided details separately and did not include them in the tariff.  PG&E promised to provide new tariff sheets containing the energy statements with all the necessary detail in a new filing within 6 months.

On September 15, 1999 PG&E filed AL 2180-G/1913-E accompanied by a blank sheet with the PG&E logo and a blue bar at the top and an added phrase reading: “WE DELIVER ENERGYTM” and the Recycled Paper notation at the bottom.  Samples of 12 electric and 4 gas billing statements were included. 

NOTICE

Notice of AL 2180-G/1913-E was made by publication in the Commission’s calendar and by mailing copies of the filing to adjacent utilities and interested parties.  

PROTESTS

No protests to AL 2180-G/1913-E were filed.  

DISCUSSION

A review of PG&E’s tariff shows 48 gas and 58 electric tariff schedules in PG&E’s tariff book.  The billing formats submitted with AL 2180-G/1913-E are only samples of those tariff schedules filed in PG&E’s tariff book.  PG&E did not submit sample bills for any of the traffic control or standby service tariff schedules, nor for tariff schedules E-SEG, E-14, A-11, or E-26 still in Commission files.  

The blank portion of the sheet that accommodates computer printouts accompanied by sample billing formats for some of the bills is not sufficient to show compliance with Section II.C. (5).  For each billing format submitted, PG&E should show which tariff schedule is being

 billed by that format.  If a number of tariff schedules are billed under one format, PG&E should so note that format.  Each form should be mounted on a regularly numbered tariff sheet showing the name or title of the form and maintained up to date in the same manner as rates, charges and rules.  

In Res. E-3596 we said:

“This AL appears to be a simple form revision intended to keep pace with information requirements of energy service unbundling.  Although the proposed tariff pages appear to be blank, through staff’s discussions with PG&E, we are convinced that PG&E intended to include the information in the AL’s Attachment II as part of its tariff.  We caution PG&E to be more explicit in future revisions to its standard forms.”  Page 2.

We will order PG&E to file billing formats for each and every tariff schedule, including Residential, Commercial/Industrial, Agricultural Power, Lighting, Traffic Control, Standby Service, Competition Transition Charge Exemption, Bypass Deferral Rate, Incremental Sales Rate, Rate Reduction Bonds Bill Credit, Net Energy Metering Service, End User Services as well as tariff schedules applicable only to direct access customers; and Gas Transportation, Procurement, Aggregation, Compressed Natural Gas, Storage, Parking and Lending services.

We recognize PG&E’s need for flexibility to quickly accommodate business and customer needs, but compliance with G. O. 96-A is also important.  Filing a blank page suggests that PG&E can place any computerized format in the blank space of the page at PG&E’s discretion.  We remind PG&E that the billing formats are part of the tariffs and cannot be revised without Commission authority.

COMMENTS

The proposed resolution of the Energy Division in this matter was mailed to the parties on October 18, 1999 in accordance with PU Code 311(g).  Comments were filed by the PG&E and by Southern California Edison Company on November 24, 1999.  

On November 16, 1999 PG&E informed the Commission that it had not received draft Resolution E-3642 and requested that the Commission hold this item over until PG&E had opportunity to comment.  Item E-2 was held.

In its comments PG&E explained that the sample forms filed with Advice Letter 2180-GG/1913-E are its revised gas and electric Standard Form 01-6630-Energy Statement-Central Mailing, a preprinted form that PG&E revised to include the phrase “WE DELIVER ENERGYTM”.  PG&E further explained that because its bills are computer-generated, revised Standard Form 01-6630 is the “printed form…normally used in connection with…regular bills for service.”  

PG&E explained that the twelve samples filed illustrated the most frequent customer bills now being printed.  Because changes often occur in the many types of computer-generated bills, PG&E further committed to updating the samples as appropriate.  

PG&E contends that G.O 96-A requires utilities to file samples of “printed forms normally used in connection with customers’ services”; it does not require public utilities to file “billing formats” for all of their tariff schedules.  

Southern California Edison (SCE) submits that G.O. 96-A, Section II.C.(5) requires “sample copies of printed forms” to be considered part of a utility’s tariff schedules.  When this section was adopted, according to SCE, a “sample form” consisted of the following information:  (1) the utility’s logo, (2) the color banner, and 3) the “Update,” “Summary” and “Detail” portions of the customer bill with numerical information left blank.  Today, SCE says, due to the use of electronic bill production and new printing equipment available to utilities, a customer’s bill is no longer pre-printed.  The only information on the bill paper stock is the utility’s logo and the color banner.  This is the only pre-printed “form” used by the utility, says SCE.  All other information, including the entire “Update”, “Summary” and “Detail” portions of the customer bill, is printed at the time the bill is processed.  

The issue here is definition of “sample” as used by G.O. 96-A, 
Section II.C. (5).  The sample should be extensive enough to demonstrate compliance with G. O. 96-A and should not be limited to show only the appearance of the bills.  The purpose of sample forms for filing is to include in the tariff the layout of utility bills and show the information the utility shall provide its customers in the bills.  PG&E’s and SCE’s proposals to provide letterhead paper stock do not meet this purpose.  Utilities should include sample billings for all tariff schedules.  The draft states: “If a number of tariff schedules are billed under one format, PG&E should so note that format.”  If one format is used for several different tariff schedules, PG&E can show the one format and denote which tariff schedules it represents.  

SCE explains that its current bills have a “message” section, which varies by customer group and is updated periodically to convey current information.  Prior to electronic bill production, SCE would convey such information through bill inserts, which were not filed as part of SCE’s tariffs.  SCE says that the “Message” section of the bill is not displayed on the sample.  SCE is concerned that the Draft Resolution would require the utilities to file 300 different bill samples, time consuming and costly to produce.  SCE also says that requiring SCE to pre-file information conveyed in the “Message” section of the bill would prevent SCE from updating its messages and prevent customers from receiving timely information regarding their electric accounts.    

We note that G.O. 96-A does not require utilities to file for authority to change messages on bills.  However, the space for such messages should be shown on the bill sample and labeled.  

SCE interprets the “Sample Forms” section of G.O 96-A to mean that the utilities are required to file the blank paper stock with the logo and color banner only.  SCE then points to one of the issues of G.O. 96-B of how to update the “Sample Forms” section of G.O. 96-A, based on the fact that pre-printed forms have become obsolete.  

Based on its interpretation of G.O. 96-A, section II.C. (5), SCE requests that issues relating to sample bills be addressed in the G.O. 96-B proceeding.  PG&E considers Res. E-3642 as a revision of G.O. 96-A that should be addressed in Rulemaking 98-07-038 to provide all public utilities proper notice and opportunity to comment.  

Our interpretation of G.O. 96-A does not consider this action as a revision of, but as compliance with G.O. 96-A, section II.C. (5).  Therefore we deny PG&E’s request.

FINDINGS

1.	G.O. 96-A requires sample copies of regular bills for service to be considered a part of a utility’s tariff schedules and maintained up-to-date in the same manner as rates.

2.	PG&E failed to include billing formats for all tariff schedules in Advice Letter 2180-G/1913-E.

3.	PG&E’s proposed blank billing sheets do not comply with General Order 96-A Section II.C. (5).

4.	None of the billing formats submitted were mounted on a regularly numbered tariff sheet showing the name and title of the form.  

5.	PG&E should include billing formats for all tariff schedules in its new advice letter.  PG&E can show one format to represent a number of tariff schedules.

6.	AL 2180-G/1913-E should be rejected for non-compliance with General Order 96-A Section II.C. (5).

7.	G.O. 96-A does not require that the utilities file to revise messages on the bill.  However, bill samples filed should show and label the space for messages.  

8.	PG&E’s and SCE’s requests to address billing format issues in R.98-07-038 are denied.

THEREFORE IT IS ORDERED that:

1.	Advice Letter 2180-G/1913-E is rejected.

2.	PG&E shall file a new Advice Letter in compliance with General Order 96-A Section II.C. (5) within 30 days of the effective date of this Resolution.

3.	This resolution is effective today.

I certify that the foregoing resolution was duly introduced, passed and adopted at a conference of the Public Utilities Commission of the State of California held on December 16, 1999; the following Commissioners voted favorably thereon:

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							WESLEY M. FRANKLIN
							    Executive Director

							RICHARD A. BILAS
							       President
							HENRY M. DUQUE
							JOSIAH L. NEEPER
							JOEL Z. HYATT
							CARL W. WOOD
							    Commissioners