Details for: SCE Reply to PAO Protest to Advice 3968-E.pdf

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

April 10, 2019
Energy Division
Attention: Tariff Unit
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102


Southern California Edison Company’s Protest Response to Public
Advocates Office’s Protest to Advice 3968-E

Dear Energy Division Tariff Unit:
Pursuant to General Rule 7.4.3 of the California Public Utilities Commission’s
(Commission’s or CPUC’s) General Order (GO) 96-B, Southern California Edison
Company (SCE) hereby submits its response to the Protest of the Public Advocates
Office (PAO) regarding SCE’s Advice Letter (AL) 3968-E, Payment Office Closure
I. Background
On March 14, 2019, SCE submitted AL 3968-E, “Payment Office Closure Proposal.” In
this AL, SCE requested the Commission approve SCE’s plan to close its eleven
payment offices in the following rural districts: Arrowhead, Barstow, Bishop, Blythe,
Catalina, Kernville, Mammoth, Ridgecrest, Shaver Lake, Tehachapi, and Yucca Valley.
SCE’s payment offices in these regions only conduct in-person payments, but due to
the decline in usage of these payment offices, and in light of other in-person and
numerous self-service payment options to available to customers, SCE proposed to
close the payment offices, and return the cost savings associated with the closures to
customers. In AL 3968-E, SCE demonstrated that it complied with the directives in
Decision (D.) 98-07-077, which established the criteria to close payment offices. In that
AL, SCE also described in detail the other numerous payment options available to
On April 3, 2019, PAO submitted a protest to AL 3968-E. Specifically, PAO:
1. Supported the closure of the Arrowhead, Blythe, Catalina, Mammoth, and
Shaver Lake payment offices no sooner than 60 days following a Resolution as
SCE proposed;


AL 3968-E, pp. 1-2, and 4-5.

P.O. Box 800

8631 Rush Street

Rosemead, California 91770

(626) 302-9645

Fax (626) 302-6396


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Energy Division California Public Utilities Commission April 10, 2019 Page 2 2. Recommended that the Kernville, Tehachapi, and Yucca Valley payment offices be closed no sooner than six months from a Resolution; and, 3. Opposed the closure of the Barstow, Bishop, and Ridgecrest payment offices noting a relatively modest level of customer usage. PAO also noted that some customers voiced concerns with safety, privacy, and service quality concerns with some Authorized Payment Agency (APA) locations, and that some APAs charge additional fees.2 II. Discussion A. SCE Supports PAO’s Recommendation to Stagger the Closure of its Payment Offices. First, it is important to note that SCE and PAO agree that eight out of eleven offices should close. SCE also agrees with PAO’s acknowledgement that “the immediate closure of [the Arrowhead, Blythe, Catalina, Mammoth and Shaver Lake] payment offices should not have an unduly adverse impact on customers.”3 SCE also has no objection to PAO’s suggested approach to allow six months after the issuance of the final Resolution before closing the Kernville, Tehachapi, and Yucca Valley payment offices. SCE agrees that “6 months will provide a reasonable transition period toward permanent closure.”4 SCE commits to use that additional time as an opportunity to continue to provide customer outreach and education at these payment offices in regards to other available payment options, including available in-person options at SCE’s authorized APAs. B. SCE Opposes PAO’s Recommendation to Keep Three Payment Offices Open Because the Protest Lacks Support for this Recommendation. 1. The in-person customer traffic at these three offices is small and expected to decline. SCE does not agree with PAO’s recommendation to keep the Barstow, Bishop, and Ridgecrest payment offices open because the determination that these payment offices “still have a relatively modest level of customer usage”5 is not supported by the record. 2 3 4 5 PAO Protest, pp. 1-2. PAO Protest, p. 1. PAO Protest, p. 2 PAO protest, p. 2.
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Energy Division California Public Utilities Commission April 10, 2019 Page 3 In fact, the usage level is quite small relative to the number of customers served by those district offices. Table II of AL 3968-E provided data showing that only 2.4 percent of customers in the Ridgecrest district use that local office. As of April 5, 2019, the Ridgecrest district now has three available APA locations. Table II of AL 3968-E provided data showing that only 3.3 percent of customers in the Barstow district use that local office and there are currently two available APA locations. SCE’s data also indicates that only 250 customers use the Bishop payment office every month, which equals 4.5 percent of the total service accounts in that area. SCE contends that 250 customer visits is not “significant continued in-person traffic” warranting the continued cost to SCE and its customers to keep the Bishop office open. Moreover, PAO’s Protest acknowledges that these three offices have “limited hours of operation”6 in contrast to the APA alternatives which provide greater hours of operation and the same service (i.e., accepting payments by check, money order or cash). SCE notes that the recorded payment volumes at these offices as shown in AL 3968-E supports SCE’s expectation that the declining trend in customer usage will continue at these offices as customers continue to use SCE’s other payment options.7 Further, due to this continued low usage, payments accepted at SCE’s payment offices are significantly more expensive than those collected at APAs (i.e., $4.71 per transaction versus $0.60). All these factors support SCE’s proposal to close all of the payment offices and return the cost savings to customers. 2. SCE addressed the limited customer concerns expressed in the in-person customer surveys and is committed to continuing its outreach to ensure quality service is provided by the APAs to all SCE customers. In its protest, PAO references the concerns expressed by a small number of customers about the possible privacy concerns, preferences for in-person interaction and service concerns with using APAs.8 For those survey results regarding APA safety, privacy or service quality concerns, SCE addressed those concerns directly with the APA to the extent a specific APA was identified in the survey comments. Further, as noted in AL 3968-E, when SCE receives any customer complaint about a specific APA location, SCE sends representatives to directly investigate and address customer service or operational concerns (including safety and privacy concerns). SCE will continue to do so for its entire APA network. In other words, while a small number of customers have expressed concerns with the use of APAs, those concerns can be and are being resolved through additional customer education on the actual services provided by 6 7 8 PAO Protest, p. 2. See AL 3968-E, p. 3. SCE has experienced a 45 percent decline in usage from 2016-2018 at its payment offices. PAO protest, p. 2.
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Energy Division California Public Utilities Commission April 10, 2019 Page 4 APAs (i.e., APAs do accept cash payments) and ongoing commitment by SCE to ensure that its APAs provide convenient and quality in-person service. As SCE described in AL 3968-E, SCE has been educating its payment office customers that they can continue to receive personal interaction and service at the APAs, which are open longer hours, and conduct the same transactions as SCE’s payment offices (accepting payments in cash, check or money order) with no fee to conduct those payment transactions. 3. APAs in SCE’s APA network are not permitted to charge additional fees, thus PAO’s concern about a potential impact on low-income customers is unwarranted. PAO’s remaining opposition to the closure of certain offices appears to be based on a misunderstanding of how APAs function, namely an erroneous perception that APAs are allowed to charge usage fees.9 Specifically, PAO’s Protest states that the results of SCE’s in-person customer surveys indicated that some APAs charge additional fees and that such additional fees at APAs would be a burden for low-income ratepayers especially those who pay their bill with cash.10 All of the APAs in SCE’s APA network are prohibited from charging fees to take payments and will be removed from SCE’s APA network if SCE determines that a customer was charged an unauthorized fee. Moreover, all of the APAs accept cash payments and are not allowed to charge any type of fee for cash transactions. Thus, there is no additional cost burden to any customer making a cash payment at an APA. It is possible that in some instances, certain businesses that are not a part of SCE’s authorized network (or have been removed from that network) charge fees, but SCE has no control over these third-party practices and keeping open SCE offices will in no way remediate third-party behaviors; it will only impose additional costs on SCE customers. 4. SCE recommends the Commission approve SCE’s proposal to close the Barstow, Bishop and Ridgecrest offices consistent with AL 3968-E, and permit SCE six months after issuance of the final Resolution to do so. Given the low usage and expected continued decline in usage, availability of reasonable payment alternatives (including cash transactions), and protections from unauthorized charges to make a payment at an APA, SCE recommends that the Commission approve SCE’s proposal to close the Barstow, Bishop, and Ridgecrest payment offices. 9 10 PAO protest, p. 2. PAO Protest p. 2.
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Energy Division California Public Utilities Commission April 10, 2019 Page 5 SCE commits to ensuring the closure of these three offices does not pose a discriminatory impact for the customers using the payment offices on a monthly basis, consistent with the requirements in D.98-07-077, and therefore, SCE would be amenable to also staggering the closure of the Barstow, Bishop and Ridgecrest payment offices in six months consistent with PAO’s recommendation for the Kernville, Tehachapi and Yucca Valley payment offices. A six month transition period to close the Barstow, Bishop, and Ridgecrest payment offices will allow sufficient time to continue more targeted outreach to notify customers of the closures, continue to provide additional education on other available payment options (including in-person options at APAs), address any customer concerns that arise related to specific APA locations, and provide SCE with time to continue its efforts to place additional APA locations within these districts in particular. III. Conclusion SCE appreciates the opportunity to provide this response to PAO’s Protest of AL 3968E, and recommends the Commission approve SCE’s proposal to close all eleven offices, and permit SCE to stagger the closing of the Kernville, Tehachapi, Yucca Valley, Barstow, Bishop, and Ridgecrest payment offices to no sooner than six months from the issuance of a final Resolution. Sincerely, /s/ Gary A. Stern Gary A. Stern, Ph. D. GAS:ey:cm cc: Edward Randolph, Director, CPUC Energy Division Franz Cheng, CPUC Energy Division Robert M. Pocta, Public Advocates Office Truman Burns, Public Advocates Office
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