To: DAWG working groups
From: UCAN
RE: Upstream metering and market rules
Date: June 26, 1996
UCAN RECOMMENDATIONS IN CONFORMANCE WITH
THE TEAM B OUTLINE:
MARKET RULES FOR AGGREGATION,
BILLING, AND DATA USE
3.0 PROPOSED RULES FOR MARKET PARTICIPANTS
UCAN submits that load profiling is feasible for small customers
with the use of upstream metering. Contrary to positions of
others, UCAN believes that at-the-home metering is not
economically viable in the short-term and a mass deployment of
interval meters can not be planned or choreographed at the present
time.
The use of upstream metering will not only make load profiling
feasible, but it will present additional distribution management
benefits as well as improve the quality of customer information for
the nascent competitive retail markets.
3.1 REQUIRE UPSTREAM METERING FOR LOAD
AGGREGATION
3.1.1 Aggregation Problems Without Interval Metering
In the absence of upstream metering, a number of aggregation
problems can be easily anticipated. Non-metered agggregators will
either create a situation where cross-subsidies disadvantage the
aggregator or other customers. Most expect that "someone's ox will
be gored" but all want to ensure that subsidy flow and market
distortions do not harm them or their particular group of customers.
Four primary problems are anticipated with aggregation in
California: shifting costs to other customers, to the PX, greater
peak load costs, accounting error.
First, the problem of shifting costs. The most obvious example is
where customers cause loads to deviate from levels they are
committed to pay for, making someone else to pay for the load
shift. This causes additional costs to meet the peak load and to
settle for the "out of balance condition" -- where power scheduled
does not match demand. Customers who have hourly meters are
held accountable for their load shape and settlements to resolve the
out of balance condition. Thus, the problem of shifting costs will
be driven largely by aggregated customers who do not have interval
(hourly) meters. The UDC's aggregated customers, being in the
identical circumstance, will also create this problem.
Second, is the potential to shift expensive loads onto the PX while
allowing the DA market to serve inexpensive loads. An example is
where a DA customer buys its base-load power from a specific
generator and takes its swing and peaking power from the PX. If
the PX were to increasingly serve only swing loads its MCP would
continue to increase. Small and medium customers who do not
have DA options would be required to pay these higher prices.
This problem will be exacerbated by the UDCs requirement to
aggregate all default customers and purchase all power from the
PX, especially if proper hourly metering is not required.
Third, the problem of greater peak load costs caused by unmetered
customers who consume at peak times. Customers who pay
average rates have distorted incentives to consume too much power
at times when actual (hourly) prices are high. Such customers will
increase the costs of those who must use power at peak times.
Reflecting this, the market clearing price (MCP) in the Power
Exchange (PX) is likely to increase. Thus, where aggregated loads
are not properly metered and accounted for, the resulting increases
in costs are likely to fall on those who have hourly metering and
those who must take power from the PX.
Fourth is the need to properly account for costs of power delivered
to the distribution system. This is necessary in order to define the
costs for power, ancillary services, net losses, and congestion at the
transmission-distribution interface and at points within the
distribution system. This accounting is improved by placing
hourly (interval) meters at points on the distribution system
upstream of customers. Without upstream metering to properly
account for downstream consumption, it is difficult to discern
subsidy shifts caused by unmetered customer consumption. Such
subsidy would be reflected in average costs and allocated to all
customers.
3.1.2 Requirements to Reduce Cross-Subsidy and Gaming
The following principles are offered to guide the development of
aggregation and load profiling:
Aggregation should be performed in a manner that ensures
that other customers and participants in the competitive
market are not made worse off.
Aggregators should take responsibility for payment of power
consumption at discrete points on the distribution system
which are subject to hourly metering.
The system should accurately account for loads and for
settlement of accounts with the ISO and PX.
All UDC aggregated loads should be able to net out the
UDC portion of hourly loads and settlement costs.
3.1.3 The Use of Upstream Metering for Customer
Aggregation
The concept of upstream metering is to use metering points between
a set of individual customers and the transmission system. This
may involve a meter at a transformer serving three customers or
substation serving fifty customers. If a specific load pattern can be
isolated by upstream metering, which may involve one or more
meters, then direct responsibility for this demand pattern can be
attributed to those who use and should pay for this power
downstream.
A set of customers could agree to have their power provided by an
aggregator who uses upstream metering. For those who choose to
remain default customers the aggregator will agree with the UDC or
other aggregators to net out the estimated usage of default
customers based on specific load profiles. The default customer
loads would be "net of" (subtracted from) the upstream metered
load.
Upstream metering also makes an aggregator directly responsible
for settlement of accounts on loads scheduled and power used.
This allows aggregators of power to be directly billed for hourly
load flow, accepting the normal errors in metering. Thus, the
settlements process can be resolved without fear of subsidy flowing
to the power exchange or to other aggregators.
When an aggregator takes responsibility for upstream metering, any
issues related to downstream load profiling are circumscribed and
are more easily defined. Most importantly, where parties take
responsibility for payment of power based on upstream metering the
potential for subsidy through load profiling, price averaging, or load
shifting is limited.
This does not, however, diminish the potential for conflict over
subsidy between customers who are downstream of the upstream
metering points used by an aggregator. Upstream metering
facilitates what has been termed "net metering" to determine the
power use of customers who are downstream of points metered
directly upstream. Customers who so choose can still install their
own individual meters. The aggregate power use customers who
are not directly metered is the arithmetic difference between the
upstream metered power use and the individually metered power
use.
With application of upstream metering and net metering,
aggregators and individual customers have the flexibility to install
meters as they wish. This approach then provides the basis for
responsible load profiling and aggregation without the use of
individual meters, while allowing the use of individual metering for
those who so choose.
3.1.4 Hourly Metering Seems Necessary to Protect Against
Subsidy by Load Shifting
There appears to be consensus within the working groups that load
profiling with no metering creates untenable cross-subsidies and
severely skewed price signals. Some degree of hourly metering is
necessary in order to ensure that customers pay for the load shape
they cause and for the settlements they create. UDCs and other
aggregators who offer unmetered load profiling will not be able to
achieve an accurate settlement that reconciles scheduled
consumption with actual consumption. Nor will they be able to
reconcile forecasted load profiles with market prices.
The unresolved difference will be allocated as an average cost (in
the "sweep-up") to all customers of the PX. This suggests that it is
essential for the aggregator(s) of customers who use load profiling
to be directly responsible for all of its power consumption based on
hourly metering. This hourly metering could occur at one or more
points upstream of the agregated load(s).
Upstream hourly metering is necessary to measure the total
consumption of each aggregated set of customers. That is, the
aggregated set of customers below the upstream metering point
must show that they are paying for the load shape they cause to
incur. Otherwise, there will be no end to the conflicts and
regulatory tangles surrounding technical studies to determine billing
responsibility and to justify profile analysis.
Given the need for some degree of metering at the distribution
level, one alternative proposed is to have all customers install
hourly meters. With full metering at the customer level there will
still be questions about the hourly load shape and costs of bulk
power delivered to the distribution system and about distribution
losses. The UDC will be required to compile individual customer
load profiles in order to back-out the power taken at the
transmission-distribution (T-D) interface and the distribution system
losses.
Therefore, upstream, hourly distribution system metering is still
needed, even if hourly customer meters are installed, to ensure
accurate measurement of loads at the T-D interface and proper
settlements for power scheduled and consumed. As yet the
WEPEX group has no plan to accomplish this metering.
Thus, absent upstream metering the following problems are
expected with aggregation and load following:
Subsidy as a result of lack of upstream metering of
aggregated loads.
Higher peak load consumption and prices in the PX.
Inconsistent estimation of the costs for power delivered to
the distribution system and of distribution system losses.
Aggregators who fail to take full responsibility for
consumption and for settlements.
Litigous conflicts over aggregation and load profiling,
requiring regulatory oversight.
3.1.6 Issues Addressed Through Upstream Metering
A set of issues with load profiling have been presented in recent
DAWG meetings by the Division of Ratepayer Advocates,
California Manufacturers Association, and the California Energy
Commission. UCAN proposed the use of upstream metering as a
partial solution to load profiling. Upstream metering resolves a
number of issues raised, to wit:
It ensures that an aggregator's load responsibility reflects its
customers' actual loads as accurately as possible and it
provides for accurate settlements.
Upstream meters, serving one or more aggregators, will
augment and serve to calibrate load profiling analysis.
Comparable customers of aggregators and of UDC
customers would have the same minimum metering
requirements.
Load profiles could be developed and updated for customer
groups downstream of an upstream metering point, with the
cooperation of UDCs and the use of historic data.
The absolute amount of imbalance power that would result,
contributing to average cost increases, could be substantially
reduced and would be allocated without creating cross-
subsidy. This would also provide better information to and
place greater incentives on aggregators and consumers to
reduce the difference between scheduled power and actual
consumption.
Upstream metering can serve as a bridge strategy between
responsible load profiling and the installation of hourly
metering by customers.
Aggregators and their customers can with greater certainty
evaluate the benefits and costs of moving to hourly customer
metering and more accurate load forecasts. This also places
the decisions to move to hourly interval metering or better
load forecasting in the hands of consumers and their agents,
removing the need to regulate these matters.
3.1.7 Summary of Discussion About Upstream Metering
A set of questions and answers related to upstream metering are
summarized as follows:
Must the distribution company (UDC) provide access for
upstream meters to be placed on their facilities? Yes,
otherwise a barrier could be erected to bar entry of
aggregators.
Would the use of upstream meter information may be
subject to protection to ensure confidentiality? Probably
not because upstream metering provides only imparsonal
data.
Must responsible be established for meter reading,
verification, and data transfer to the ISO/PX? Yes, this
would be the responsibility of the aggregator.
Must customers either "buy into" the choice of upstream
metering or purchase an individual meter? Probably not if
the UDC provides specific load profiles for such customers.
Would the sponsor of an upstream meter gain special rights
to aggregate for related downstream customers? No, other
aggregators could install meters at points upstream or
downstream of the existing aggregator's meter. There would
be no artificial entry barriers.
What risk does an aggregator face in the placement of an
upstream meter? Its customers can choose other
competitive options. Also its customers could consumption
more power than expected, such as at peak periods, which
would reflect in the aggregator's metered usage.
3.2 RESPONSIBLE LOAD PROFILING
A program of responsible load profiling would use upstream
interval metering to achieve the following objectives:
(1) Ensure that an aggregator's load reflects its customers'
actual loads.
(2) Provide for accurate settlements.
(3) Reduce cost shifting.
(4) Enable as many customers as possible to have DA as an
alternative.
(5) Use existing data and UDC capabilities to refine load
forecasts for customer groups.
With these objectives satisfied, the obvious benefit is to enable
competitive access to power without the immediate need to endorse
a monolithic, single vendor, customer meter implementation
strategy.
With this approach, aggregators and customers can obtain essential
market and power delivery information at relatively low costs.
Aggregate load profile data can be examined without privacy or
confidentiality restrictions. And the costs of power delivered to
specific parts of the distribution system can be known with more
certainty. Customers can examine each of their competitive
options, including the benefits of customer specific interval
metering.
Added benefits to upstream metering are the features of voluntary
participation by customers and the lowering of information barriers
for aggregators. The customer has maximum control over market
options and meter selection. At the same time, aggregation should
be easier for aggregators, particularly if historic data and UDC
assistance can be used to better understand customer groups without
concerns about privacy.
3.2.1 Aggregator Accepts Downstream Load Responsibility
Aggregator(s) and UDC would be responsible to pay for scheduling
customer loads, and appropriate settlements, for power delivered to
upstream metering points. This translates to the bearing of risk for
variations in the loads of downstream customers.
Where downstream customers elect UDC procurement of power or
elect to use another aggregator, possible conflicts may arise over
the allocation of responsibility for loads. This may increase the
incentives for aggregators to have particular customers use
individual interval meters. Thus, a set of ground rules for dispute
resolution and an arbitration process seen necessary.
3.2.2 Data Development to Understand Downstream Loads
A valuable role for the UDC is in assisting it and the aggregator to
understand the estimated load pattern and the basis for that load
pattern at various upstream points on the distribution system. The
UDC as aggregator can benefit from specific compilation of data to
better understand how it can forecast specific customer loads. This
data is also of substantial value to other private and public
aggregators who seek DA customers.
The use of upstream meters to verify and calibrate customer load
forecasts is expected to lower the costs to all customers, including
specific customer groups who benefit from superior forecasts.
Without specific upstream metering, the accountability for accurate
forecasts and settlements would be significantly reduced.
3.2.3 UDC Facilitates Location of Upstream Metering
The UDC, being the owner of the distribution assets, is in the best
position to assist in the placement of upstream meters. It has the
critical information necessary and has a direct interest in reducing
the inefficiencies caused by inaccurate load forecasts and cross-
subsidy in settlements. There has not been a lot of discussion about
the exact role of the UDC in facilitating upstream meter placement.
In order for any aggregator to use upstream meters, the UDC will
need to facilitate access to regional load data and to potential sites
for meter placement.
3.2.4 Aggregator and UDC Share Upstream Meter
Information to Facilitate Competition
The UDC and other aggregators will need certain information from
upstream meters. The question is how will upstream meter
information be shared and used? The preliminary thinking is as
follows:
If aggregators own or have full rights to upstream meter
information, they should have the ultimate control of its use,
subject to an agreed-upon approach to share the information
with the UDC.
If the UDC owns or has full rights to upstream meter
information, it should also have the ultimate control of its
use, subject to requirements to unbundle nonprivate aspects
of the information and to receive a reasonable cost for such
services.
It is difficult to require an aggregator unbundle upstream
meter information for other private aggregators without
subjecting all such aggregators to command-and-control
regulation. Aggregators will always have the options to
install separate meters or to enter into joint agreements with
other aggregators to share information or meter ownership.
One solution is that the UDC obtain regulatory approval to
unbundle information purchases and information availability. This
would allow the UDC to purchase data from upstream meters
owners at a known, regulated price. This would also allow the
UDC to offer for sale its information to aggregators for a regulated,
at cost, price.
3.2.5 Ownership of Upstream Meters Can be by Aggregator
or UDC
With unbundling of the information from upstream metering,
allowing either the UDC or the aggregator to purchase it, the meter
ownership matter seems less important. Comparability of
conditions suggests that both aggregators and UDCs be allowed to
purchase and install upstream meters under like circumstances. The
details of this must of course be better defined.
If the unbundling of upstream meter information and siting access
can be accomplished in an effective way, then the ownership of
upstream meters can be left flexible and voluntary. When the UDC
must obtain regulatory approval to purchase upstream meters it may
have difficulty acting rapidly. Aggregators can act as rapidly as
desired to purchase upstream meters, but would probably need to
first obtain some load information from the UDC and market
information about downstream customers. This makes critical the
UDC's cooperation to share information and facilitate upstream
metering.
UCAN can easily envision a scenario where many, if not most,
upstream meters are owned by a private metering company --
perhaps even a meter-manufacturer. This company would offer
services of data gathering and sharing, thus enabling aggregators to
focus their resources on marketing and customer service. The
metering company could offer its services to multiple aggregators in
the same area, thus facilitating settlements among aggregators.
3.2 ENTRY CONDITIONS
3.2.1 Specific Rules for Entry and Exit
no specific comment proposed by UCAN
3.2.2 Obligation to Serve
The most detailed submittal on this topic is from SDG&E.
According to SDG&E, the absolutely essential UDC obligations to
serve and to be the provider of last resort are as follows:
To connect customers to the distribution system and to
deliver power from the transmission system to customers.
To procure power from the PX and ISO for UDC customers.
To plan, construct, operate, and maintain the distribution
system, including responses to avoid outages and restore
power.
To provide metering for UDC full service customers and
customers who choose UDC hourly metering.
3.2.3 Certification/Registration
Any provider interacting directly with retail customers must
be registered. This includes municipal entities providing energy
services to non-franchise customers.
Registration requires filing of corporate information and
posting a bond with Commission. Upon satisfaction, the provider
receives a license. The Commission is the logical lead agency for
enforcement The Commission can revoke a license if violations of
CPUC rules are proved. The Commission can suspend a license or
curtail solicitation of new customers if the likelihood of violations
is established by staff or customers.
3.2.3.1. Retail Customer Interaction Compels A License
Competition will engender the entry of a number of service
providers. Some will offer brokerage, some aggregation services,
some demand-side services and some will offer services that have
not even been envisioned at the moment. Such is a unfettered
market.
The issue is whether the retail market will be entirely
unfettered. UCAN submits the answer is "no". Any provider
offering services directly to retail customers will be required to
register with the CPUC. That way, if any service provider
interacts with a retail customer, that provider will fall under the
jurisdiction of the CPUC.
Other providers, such as brokers interacting with
aggregators, generators, companies offering ancillary services and
scheduling coordinators are not required to provide a filing or bond
with the CPUC so long as their interaction remains with other
wholesalers. However, these providers may have to fulfill
registration requirements established by the ISO.
The rationales for this licensing and bonding requirements
are as follows:
a. Retail customers must be able to learn about the owners,
location and financial viability of any prospective advisor. In
order to ensure uniformity, that information should be on file with a
clearinghouse. The CPUC fills that role.
b. In order to guard against undercapitalized or fly-by-night
companies, the CPUC must have a means of screening prospective
energy providers.
c. Retail customers, especially residential and small
business consumers, will not have the wherewithal to screen
prospective companies. The abuses of the solar hot water market
and the long-distance telecommunications companies have
graphically demonstrated the need for the ability to screen
providers.
3.2.3.2. Registration Includes Licensure and Bonding
The registration process needs to be stringent enough to
protect customers but not so onerous as to create barriers to entry.
The CPUC has developed a non-dominant carrier registration
process for local telecommunications companies that is not overly
burdensome. It requires filing with the CPUC the identities of the
owners and officers of the corporation, a description of services to
be provided and basic financial information to ensure economic
viability.
However, the telecommunications registration does not
require bonding, and this is precaution that is necessary for electric
service for many reasons:
a. Electric service is a necessity and generally is more expensive
than phone service. Thus greater protection is warranted;
b. The upfront costs of entering the electric services market is
fairly low. Aggregators need only a computer and customer leads.
Thus bonding requirement will not put an undue burden on any
prospective new entrant, as its start-up costs are relatively low.
c. Without a bond, it is likely that complainants and their
attorneys/representatives will not be able to recover damages caused
by failed service providers.
d. The bonding process, itself, serves as a useful screen against
companies or individuals with questionable financial pasts who seek
to enter the electricity market. Bonding services will either
decline to bond or require higher deposits of entrants with
questionable records.
The amount of the bond would be established based upon
the prospective number of customers to be served. e.g. a local
community aggregator planning to serve 50 residents could post a
very modest bond whereas a large aggregator planning to serve
customers throughout the state would require a more substantial
bond.
3.2.3.3. Revocation and Suspension of Licenses is Within the
Purview of the CPUC
The CPUC should have the ability to suspend, limit or
revoke licensure depending upon the gravity of provider
malfeasance. Suspension would be invoked only where due
process had been afforded to a provider. However, injunctive
suspension or limits on a license could be imposed upon a showing
that the Commission rules had likely been violated by a service
provider and that significant damage could be caused by a
continuation of service by that provider.
3.3 CONDITIONS FOR AGGREGATION
3.3.1 Codes of Conduct
A preliminary proposal for codes of conduct has been offered by
the CEC and proposed by the Greenlining Institute. This topic is
also covered to some extent in the chapter on consumer protection.
Central to a code of conduct for participants in the competitive
market is the need for the UDC to act in a cooperative manner,
particularly with respect to access to information and the facilitation
of upstream metering. In the telecommunications industry, where
resale of services is an anchor of the anticipated competition, there
has been substantial friction between facilities-based carriers and
resellers. We anticipate the potential for similar friction in the
electric competitive market and believe proactive steps must be
taken to eliminate these friction points.
3.3.2 Availability of Load and Price End-Use Information
Historic upstream load information must published and made
available to all who request. A specific break point must be
defined below which customer information would be considered
private. As a principle, UCAN submits that information from
which customer-specific consumption can be gleaned is private and
should be protected. Where customer-specific information can not
be gleaned, then information should be readily shared. For
example, the load registered of four customers by an upstream
meter may be a suitable break point. Upstream load and end-use
information representing less than four customers may be
considered private and protected by confidentiality.
Thus, UDCs may be required to unbundle all available load and
aggregated end use information representing four or more customers
in the aggregate. This data could be made available by UDCs in a
common format for a reasonable price.
UCAN believes that efficient aggregation can be more rapidly
achieved if the following circumstances are provided:
Data for customers in a specific region could be grouped
into a set of homogenous categories and provided to
aggregators, allowing them to more easily target groups with
similar demands.
A step one assessment could be performed by the UDC
using data on homogenous customer characteristics and then
be made available to aggregators. This could include
lumping customers into categories based on seasonal peak
use further differentiated by amount of total use.
A step two assessment could be performed by the UDC to
define clusters of customers with homogenous characteristics
which could be situated downstream of an upstream
metering scheme. This information would also be available
to aggregators.
3.3.3 Reciprocity As a Condition
The CPUC decision explains that the ISO is to administer eligibility
conditions for retail service. The CPUC invites "the participation
of out-of-state generators for it is our desire that the Exchange and
the transmission grid be maximized in affording competitive entry
into our markets." The ISO is expected to have major problems,
however, with the enforcement of reciprocity conditions outside of
the State.
The CPUC has stated the requirement that municipal and public
entities located in California are not to be afforded direct access to
retail customers in California investor owned (CIOU) service
territories unless these entities extend to the CIOUs reciprocal direct
access to their customers. The major problems are likely to occur
with multiple transactions and when the buying and selling parties
become indistinguishable.
The recently released FERC Rule 888 presents a different approach
to reciprocity. FERC's policy states "that the reciprocal service be
limited to the transmission provider." It concludes as follows:
"Any public utility that offers non-discriminatory open access
transmission for the benefit of customers should be able to obtain
the same non-discriminatory access in return."
This suggests that open access to transmission be based on the
reciprocal agreement to offer open access services in return.
Expanding its rule, FERC states that the "reciprocity requirement
will also apply to any entity that owns, controls or operates
transmission facilities that uses a marketer or other intermediary to
obtain access." There is need of an approach to reconcile these
two regulatory policies in a way that achieves California's goal of
obtaining access to all possible in-state and out-of-state generation.
SDG&E's views in reciprocity are summarized as follows:
Reciprocity would not be required of out-of-state utilities
who sell into the wholesale market but not into the state
jurisdictional retail market.
Reciprocity should be required of out-of state retail service
providers with affiliates, unless such providers disclose their
affiliate status to customers.
ADDED: 3.6 RETAIL CUSTOMER RULES
While retailers will be responsible for developing their
individual customer policies, there are certain policies that should
be uniformly offered by any energy retailer in California. They
include free or low-cost and neutral access to redress, voluntary
mediation and ready access to third-party compiled market conduct
data.
3.6.1. Consumers must have free or low-cost access to redress
Where complaints by consumers can not be readily resolved
by a service provider, an individual consumer must be afforded
access to regulatory redress at no cost to that consumer. This is
the status quo and it should be preserved during the transitional
years, at the least. Access to no-cost regulatory relief means that
the consumer should not be charged any filing fees or assessed any
costs for pursuing regulatory relief. It does not mean that the
time spent pursuing a case or travel and out-of-pocket costs will be
necessarily recovered by the complainant regardless of the outcome.
However, where an individual prevails in a regulatory
complaint, the damages awarded should include reimbursement of
costs incurred in pursuing an action in addition to restitution
normally awarded by the CPUC. This no-cost redress is essential
if the Commission is to encourage consumers to bring complaints to
their attention. It is also necessary to level the playing field
advantage enjoyed by better -resourced providers.
3.6.2. The forum must be neutral
The forum in which complaints are resolved must be neutral.
The arbitrators need not be Commission ALJs, but they can not be
representatives of or affiliated with energy service providers.
Ideally, the CPUC could enlist the use of trained, but local
arbitrators, to conduct formal hearings and render recommendations
that would be reviewed by the CPUC. An evidentiary record
should be kept, but it can be taped, rather than transcripted.
The Commission's current expedited complaint process is an
adequate process by which formal complaints can be cost-
effectively heard and decided.
3.6.3. Mediation must be voluntary
Mediation and other alternative dispute resolution tools
should be encouraged. However, they can not be compulsory.
Nor can a consumer be penalized for not submitting to mediation.
As a means of encouragement, local mediation should be
made available to an individual complainant within two weeks of
filing a complaint. If mediation is chosen by both parties, the
individual consumer should have made available the presence of a
CPUC staff advocate or a qualified intervenor advocacy group
representative at the mediation to assist on behalf of that individual.
If the parties do not choose mediation, then the expedited complaint
process should be made available to the complainant.
3.6.5. Complainants must have access to third-party compiled
market conduct data
As part of its on-going market conduct oversight
responsibilities and as part of its customer education duties (as
discussed under "Consumer Education) the CPUC staff will be
compiling data about the complaint records, financial viability,
prices and service quality of any and all service providers licensed
to do business in California. Much of this data will be made
available to consumers who are shopping for energy services.
However, all of this data should be made available to complainants
that have filed formal complaints about an energy provider(s).
This data could be exclusively compiled by the CPUC, but UCAN
believes additional data should also be compiled by independent
third-parties as well. Energy service companies should create a
self-policing entity to collect such data, and neutral third-party
entities should be created to serve this function.
In assessing a complaint against an energy provider, the
arbiter must consider not only an individual isolated complaint but
also whether a pattern of inappropriate business practices is extant.
Complainants must have access to such data and must be able to
enter it into an administrative record in order for the data to be
fairly adjudged by the arbiter.
Michael Shames - mshames@ucan.org
Utility Consumers' Action Network
1717 Kettner Blvd. Suite 105
San Diego, CA 92101
619-696-6966