BILL ANALYSIS                                                                                                                                                                                                    �          1





                SENATE ENERGY, UTILITIES AND COMMUNICATIONS COMMITTEE
                                 ALEX PADILLA, CHAIR
          

          SB 656 -  Wright                                       Hearing  
          Date: September 12, 2013        S
          As Amended:              September 6, 2013        FISCAL       B
                                                                        
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                                      DESCRIPTION
           
           Current law  authorizes some retail end-use customers of an  
          electrical corporation (IOU) to purchase electric service  
          directly from non-utility providers (electric service providers  
          or ESPs), a program commonly referred to as Direct Access (DA).   
          Participation is capped as a percentage of total electric load  
          based on a specified formula. (PUC �365.1)

           Current law  requires ESPs to register with the California Public  
          Utilities Commission (CPUC) which is required to make specified  
          information regarding DA service available to the public.  (PUC  
          �394)

           This bill  would require the CPUC to provide information only  
          during certain periods when enrollment in the program grows by  
          five percent each month.

           Current law  requires the CPUC to require gas corporations to  
          provide basic gas service to all customers within its territory  
          unless the customer choses to obtain gas service from another  
          entity. (PUC �328.2) 
           
          This bill  establishes a regulatory framework for core transport  
          agents (CTAs) at the CPUC. The bill would extend various consumer  
          protection provisions currently established for ESP customers to  
          customers of CTAs. 

                                       BACKGROUND
           
          Deregulation - In 1996 the California State Legislature led the  
          nation by deregulating the sale of electricity to non-residential  











          customers and a few residential customers through a program  
          commonly referred to as DA. The reform was historic and intended  
          to transition the state to a more competitive electricity market  
          structure that allowed its citizens and businesses to achieve the  
          economic benefits of industry restructuring, create a new market  
          structure that provided competitive, low cost and reliable  
          electric service, provide assurances that electricity customers  
          in the new market would have sufficient information and  
          protection, and preserve California's commitment to developing  
          diverse, environmentally sensitive electricity resources. Those  
          goals were not achieved.

          The practical effect of the program was that non-residential  
          customers could buy electricity direct from private sector  
          wholesale sellers and use the IOU only for distribution and  
          transmission services. As consequence the vertical monopoly of  
          electricity delivery provided by heavily regulated electric  
          utilities was upended and those utilities were largely required  
          to sell off power plants and transfer management of their  
          transmission systems to the newly created California Independent  
          System Operator. Within a few years the state suffered  
          electricity shortages which resulted in rolling blackouts,  
          skyrocketing prices, and bankrupt or nearly bankrupt utilities.  
          The electricity crisis of 2001 resulted in a suspension of the  
          program but any customer enrolled at the time was permitted to  
          remain with their ESP. In 2009, the cap on DA enrollment was  
          increased but only for non-residential customers.  

          Core Transport Agents - CTAs are analogous to ESPs, but provide  
          gas for customers instead of electricity. In order to provide gas  
          through the utility's distribution lines, the CTAs must enter  
          into a contract with the local utility subject to certain  
          requirements. Through their own rules, the utilities require the  
          CTA to be technically capable and financially viable. PG&E  
          reports that the conditions placed on CTAs include a basic  
          service agreement, credit worthiness, and the ability to share  
          data for billing purposes. The utility reserves the right to  
          terminate service if the CTA is found to be in violation of the  
          utility's policies. PG&E reports that there are 20 active CTAs  
          within the PG&E territory, and it has received 1,200 customer  
          complaints about CTA service between May 2012 and April 2013.  
          These complaints include requests for cancellation of CTA  
          service, unauthorized switches by CTAs, and claims of deceptive  
          and misleading marketing activities. However, the IOUs do not  










          have the authority to investigate complaints of service on behalf  
          of the customers. Therefore, the IOUs typically recommend to  
          customers that they pursue legal action in court.

                                        COMMENTS
           
              1.   Concurrence  . This bill is back in committee after being  
               amended in the Assembly to include language that establishes  
               a regulatory framework for CTAs. The author has identified  
               that many customers of CTAs are presented with a confusing  
               array of service options and bills. Customers currently have  
               no forum to bring complaints against CTAs. CTAs are not  
               utilities, and are not regulated by the CPUC. Some customers  
               call the local utilities to complain about their gas  
               provider, but utilities have no authority to investigate  
               complaints against the CTAs. The author argues that the CPUC  
               should have the authority to regulate CTAs in the same way  
               that they have the authority to regulate ESPs. These  
               regulations establish basic customer protections against  
               possible fraud.

              2.   Direct Access Oversight.  While the CPUC regulates IOUs  
               closely and can investigate customer complaints and fine  
               IOUs for regulatory violations, it does not currently  
               provide any oversight on CTA matters. By comparison, it does  
               provide limited regulation of ESPs. The CPUC does not set  
               rates for ESPs, but does mandate registration and licensing  
               of ESPs and maintains certain enforcement authority to  
               investigate complaints and issue fines. CTAs are very  
               similar to ESPs, except they provide direct access to gas  
               instead of direct access to electricity. PG&E reported 1,200  
               customer complaints against CTAs in a one-year period  
               spanning 2012-2013. This bill would establish a customer  
               protection program at the CPUC to which the IOUs could refer  
               customers who have complaints against CTAs. The CPUC would  
               have the authority to investigate and resolve complaints on  
               the customers' behalf. 

              3.   ESPs and CTAs by analogy  . The language of this bill is  
               largely copied from statutes that pertain to ESPs with the  
               intention that ESPs and CTAs should be treated in the same  
               manner by the CPUC. The bill outlines a regulatory framework  
               to guide the CPUC in oversight of CTAs and includes  
               provisions that:











                           Mandate that CTAs register with the CPUC for a  
                    license to operate, which may be suspended or revoked  
                    if the CTA makes material misrepresentations in the  
                    course of soliciting customers, commits fraud,  
                    misrepresents a material fact in applying for a  
                    license, or if the CPUC finds there is evidence the CTA  
                    is not financially capable; 
                           Authorize the CPUC to collect a $100  
                    registration fee in order to carry out the consumer  
                    protection program;
                           Authorize the CPUC to investigate and resolve  
                    customer complaints;
                           Authorize the CPUC to have its attorney  
                    represent the people of the State of California in  
                    legal action against CTAs;
                           Establish that CTAs are subject to fines if  
                    found to be in violation of regulations;
                           Mandate that the CPUC compile names and  
                    contacts of CTAs and direct the DRA to provide  
                    educational materials regarding CTAs for customers;
                           Outlines minimum standards of operation  
                    including confidentiality, physical disconnects and  
                    reconnects, change in providers, written notices,  
                    billing, meter integrity, customer deposits and  
                    authorizes the CPUC to adopt additional protections;
                           Mandate CTAs provide potential customers with  
                    written notice of the service describing the price,  
                    terms, and conditions of the service;
                           Mandate the CPUC maintain a list of customers  
                    who do not wish to be solicited to subscribe to or  
                    change their CTA; and 
                           Identify entitlements of a consumer damaged by  
                    a violation by a CTA to recover actual damages,  
                    attorney fees, court costs, exemplary damages, and  
                    equitable relief. 

                                       POSITIONS
           
           Sponsor:
           
          Author

           Support:










           
          Division of Ratepayer Advocates
          Pacific Gas & Electric

           Oppose:
          
          None on file. 

          


          Kyle Hiner
          SB 656 Analysis
          Hearing Date:  September 12, 2013