Details for: 3932-E (Part 1 of 1).pdf

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Gary A. Stern, Ph.D.
Managing Director, State Regulatory Operations

January 3, 2019

(Southern California Edison Company - U 338-E)
(Pacific Gas and Electric Company – U 39 E)
(San Diego Gas & Electric Company – U 902 E)

Proposed Methodology to Categorize and Quantify Solar
Complaints Received in Compliance with Decision 18-09-044

In compliance with Ordering Paragraph (OP) 6 of Decision (D.)18-09-044, Southern
California Edison Company (SCE), on behalf of itself, Pacific Gas and Electric Company
(PG&E), and San Diego Gas & Electric Company (SDG&E) (jointly, the investor-owned
utilities, or IOUs), hereby submits a methodology for categorizing and quantifying
customer complaints related to solar that are received by the IOUs.
The purpose of this advice letter is to provide a methodology for categorizing and
quantifying customer complaints related to solar that are received by the IOUs pursuant
to OP 6 of D.18-09-044.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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ADVICE 3932-E (U 338-E) -2- January 3, 2019 BACKGROUND Assembly Bill (AB) 1070 (Stats. 2017, Chap. 662)1 requires, among other things, the Contractors State License Board (CSLB) to receive and review customer complaints and questions regarding solar energy companies and solar contractors, and publish an annual report documenting customer complaints related to solar, beginning July 1, 2019. In OP 6 of D.18-09-044, the Commission directs the IOUs to support these consumer protection measures by submitting a Tier 2 advice letter within 90 days of the issuance of D.18-09-044 proposing a method for categorizing and quantifying customer complaints related to solar on a quarterly basis. The proposed methodology is intended to be used in information-only advice letters submitted quarterly by the IOUs, pursuant to OP 7 of D.18-09-044. The IOUs are also directed to include a category of complaints related to third-party providers, broken down into types of complaints. OP 6 also requires the IOUs to assist the Commission, to the extent requested, in developing a process for collecting data on solar complaints efficiently and accurately, and for providing this information to the CSLB. DISCUSSION The IOUs propose that the scope of complaints categorized, quantified, and reported to the CPUC encompass customer complaints related to customer experience with exploring or adopting solar photovoltaic systems, including complaints regarding third party solar providers. D.18-09-044 does not specify the criteria that the IOUs should use to identify a communication to the IOUs as a “complaint,” and each IOU has different criteria for determining what would be considered a complaint from a customer. For the purposes of complying with the directives in OP 6 and OP 7, the IOUs propose to define a complaint as a negative communication from customers who have or are considering adopting solar photovoltaic systems that can be classified into one of the categories described below. Proposed Method for Tracking Solar Complaints The IOUs can receive complaints via several different channels, including through their call centers and program staff. The IOUs will collect these complaints and aim to standardize categorization of these complaints as much as possible to assist the Commission in identifying statewide trends when examining individual IOU quarterly reports. 1 Full text is available at
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ADVICE 3932-E (U 338-E) -3- January 3, 2019 Complaint Categories The IOUs propose to categorize complaints into the following categories on a quarterly basis. These categories are informed by the IOUs’ records of complaints received and by the regulatory record. In the regulatory record, information on the types of complaints typically communicated by solar customers was available from: • • • • Feedback collected at the October 20, 2016 workshop on consumer protection issues; Party comments responding to the “Administrative Law Judge’s Ruling Seeking Comment on Consumer Protection and Related Issues,” filed December 8, 2016; A workshop and written comments summarized in the “Final Report Prepared by Pacific Gas and Electric Company on the Solar Consumer Protection Forum Held in Huron, California on July 10, 2018, Pursuant to the Ruling of ALJ Valerie Kao,” filed August 31, 2018; Party comments on the proposed decision that resulted in D.18-09-044. The IOUs propose the following categories of consumer complaints related to solar: A. Complaints Related to Third Party Solar Providers a. Inappropriate Sales Tactics 1. Use of IOUs’ emergency help line to access customer data 2. Use of customers’ online My/Your Account portal 3. Unauthorized use of IOUs’ name, brand or logo 4. Impersonating an IOU representative or partner 5. Impersonating a government agency representative or misrepresenting governmental requirements 6. Impersonating a customer 7. Vendor unresponsive or no longer in business b. Complaints Specific to Contracts 1. Unclear or misleading contract or lending terms 2. Falsifying customer authorization c. Equipment Complaints 1. Equipment performance 2. Other related property damage
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ADVICE 3932-E (U 338-E) -4- January 3, 2019 No cost information is required for this advice letter. This advice letter will not increase any rate or charge, cause the withdrawal of service, or conflict with any other schedule or rule. TIER DESIGNATION Pursuant to OP 6 of D.18-09-044, this advice letter is submitted with a Tier 2 designation. EFFECTIVE DATE This advice letter will become effective on February 2, 2019, 30 days after this advice letter is submitted. NOTICE Anyone wishing to protest this advice letter may do so by letter via U.S. Mail, facsimile, or electronically, any of which must be received no later than 20 days after the date of this advice letter. Protests should be submitted to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, California 94102 E-mail: Copies should also be mailed to the attention of the Director, Energy Division, Room 4004 (same address above). In addition, protests and all other correspondence regarding this advice letter should also be sent by letter and transmitted via facsimile or electronically to the attention of: Gary A. Stern, Ph.D. Managing Director, State Regulatory Operations Southern California Edison Company 8631 Rush Street Rosemead, California 91770 Telephone: (626) 302-9645 Facsimile: (626) 302-6396 E-mail:
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ADVICE 3932-E (U 338-E) -5- January 3, 2019 Laura Genao Managing Director, State Regulatory Affairs c/o Karyn Gansecki Southern California Edison Company 601 Van Ness Avenue, Suite 2030 San Francisco, California 94102 Facsimile: (415) 929-5544 E-mail: Erik Jacobson Director, Regulatory Relations c/o Megan Lawson Pacific Gas and Electric Company 77 Beale Street, Mail Code B13U P.O. Box 770000 San Francisco, California 94177 Facsimile: (415) 973-3582 E-mail: Megan Caulson Regulatory Tariff Manager San Diego Gas & Electric Company 8330 Century Park Court, CP31F San Diego, CA 92123-1548 E-mail: There are no restrictions on who may submit a protest, but the protest shall set forth specifically the grounds upon which it is based and must be received by the deadline shown above. In accordance with General Rule 4 of GO 96-B, SCE is serving copies of this advice letter to the interested parties shown on the attached GO 96-B and R.14-07-002 service lists. Address change requests to the GO 96-B service list should be directed by electronic mail to or at (626) 302-4039. For changes to all other service lists, please contact the Commission’s Process Office at (415) 703-2021 or by electronic mail at Further, in accordance with Public Utilities Code Section 491, notice to the public is hereby given by submitting and keeping the advice letter at SCE’s corporate headquarters. To view other SCE advice letters submitted with the Commission, log on to SCE’s web site at
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ADVICE 3932-E (U 338-E) -6- January 3, 2019 For questions, please contact Nathanael Gonzalez at (626) 302-5150 or by electronic mail at Southern California Edison Company /s/ Gary A. Stern, Ph.D. Gary A. Stern, Ph.D.
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ADVICE LETTER SUMMARY ENERGY UTILITY MUST BE COMPLETED BY UTILITY (Attach additional pages as needed) Company name/CPUC Utility No.: Southern California Edison Company (U 338-E) Utility type: ELC GAS PLC HEAT ELC = Electric PLC = Pipeline WATER Contact Person: Darrah Morgan Phone #: (626) 302-2086 E-mail: E-mail Disposition Notice to: EXPLANATION OF UTILITY TYPE GAS = Gas WATER = Water HEAT = Heat (Date Submitted / Received Stamp by CPUC) Tier Designation: 2 Advice Letter (AL) #: 3932-E Subject of AL: Proposed Methodology to Categorize and Quantify Solar Complaints Received in Compliance with Decision 18-09-044 Keywords (choose from CPUC listing): Compliance, Solar AL Type: Monthly Quarterly Annual One-Time Other: If AL submitted in compliance with a Commission order, indicate relevant Decision/Resolution #: Decision 18-09-044 Does AL replace a withdrawn or rejected AL? If so, identify the prior AL: Summarize differences between the AL and the prior withdrawn or rejected AL: Confidential treatment requested? Yes No If yes, specification of confidential information: Confidential information will be made available to appropriate parties who execute a nondisclosure agreement. Name and contact information to request nondisclosure agreement/ access to confidential information: Resolution required? Yes No Requested effective date: 2/2/19 No. of tariff sheets: -0- Estimated system annual revenue effect (%): Estimated system average rate effect (%): When rates are affected by AL, include attachment in AL showing average rate effects on customer classes (residential, small commercial, large C/I, agricultural, lighting). Tariff schedules affected: None Service affected and changes proposed1: Pending advice letters that revise the same tariff sheets: None 1 Discuss in AL if more space is needed. Clear Form
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Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to: CPUC, Energy Division Attention: Tariff Unit 505 Van Ness Avenue San Francisco, CA 94102 Email: Name: Gary A. Stern, Ph.D. Title: Managing Director, State Regulatory Operations Utility Name: Southern California Edison Company Address: 8631 Rush Street City: Rosemead Zip: 91770 State: California Telephone (xxx) xxx-xxxx: (626) 302-9645 Facsimile (xxx) xxx-xxxx: (626) 302-6396 Email: Name: Laura Genao c/o Karyn Gansecki Title: Managing Director, State Regulatory Affairs Utility Name: Southern California Edison Company Address: 601 Van Ness Avenue, Suite 2030 City: San Francisco State: California Zip: 94102 Telephone (xxx) xxx-xxxx: (415) 929-5515 Facsimile (xxx) xxx-xxxx: (415) 929-5544 Email: Clear Form
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ENERGY Advice Letter Keywords Affiliate Direct Access Preliminary Statement Agreements Disconnect Service Procurement Agriculture ECAC / Energy Cost Adjustment Qualifying Facility Avoided Cost EOR / Enhanced Oil Recovery Rebates Balancing Account Energy Charge Refunds Baseline Energy Efficiency Reliability Bilingual Establish Service Re-MAT/Bio-MAT Billings Expand Service Area Revenue Allocation Bioenergy Forms Rule 21 Brokerage Fees Franchise Fee / User Tax Rules CARE G.O. 131-D Section 851 CPUC Reimbursement Fee GRC / General Rate Case Self Generation Capacity Hazardous Waste Service Area Map Cogeneration Increase Rates Service Outage Compliance Interruptible Service Solar Conditions of Service Interutility Transportation Standby Service Connection LIEE / Low-Income Energy Efficiency Storage Conservation LIRA / Low-Income Ratepayer Assistance Street Lights Consolidate Tariffs Late Payment Charge Surcharges Contracts Line Extensions Tariffs Core Memorandum Account Taxes Credit Metered Energy Efficiency Text Changes Curtailable Service Metering Transformer Customer Charge Customer Owned Generation Mobile Home Parks Name Change Transition Cost Transmission Lines Decrease Rates Non-Core Transportation Electrification Demand Charge Non-firm Service Contracts Transportation Rates Demand Side Fund Nuclear Undergrounding Demand Side Management Oil Pipelines Voltage Discount Demand Side Response PBR / Performance Based Ratemaking Wind Power Deposits Portfolio Withdrawal of Service Depreciation Power Lines Clear Form
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