Introduction

This testimony is presented by Gayatri M. Schilberg, Senior Economist with JBS Energy, Inc. on behalf of Utility Consumers' Action Network (UCAN) and The Utility Reform Network (TURN). Ms. Schilberg has testified on numerous occasions before this Commission. Her qualifications are found in Attachment 1. She has worked on utility service quality issues since 1991 regarding electric, gas, and telephone utilities. Among her many investigations into customer service, she has represented consumers in the creation of service quality benchmarks and standards in incentive ratemaking plans in the United States and Canada. She investigated the erroneous payment collection practices of Pacific Bell in C.91-03-006, and has testified in many of the major electric utility rate cases over the last decade on various issues related to utility revenue requirements and aspects of distribution and customer service operations.

This testimony recommends the following:

For SDG&E's electric distribution revenue:

• We support DRA's disallowance for tree trimming because the number of trees in SDG&E's inventory is decreasing.
• SDG&E should be funded for an intrusive inspection cycle of 15 years for wooden poles. UCAN recommends a disallowance of $929,200 in account 593.9 for excessive intrusive inspections and one-time costs.
• Disallow $108,000 in 2008 in Account 593.0 for raptor protection, because it is already in existing expenses.
• Disallow $205,000 from account 593.0 for sacred sites.
• Disallow $410,000 from account 594.0 for non-recurring expense.
• Disallow $299,000 in account 594.6 based on more recent data.
• Reduce the budget for capital project 229 by $1 million for 2007 onward to incorporate recent data.

Regarding SDG&E's Service quality:

• Retain SDG&E's list of monitor-only service quality indicators. Add two indicators for maintenance, repair and replacement.

Regarding SoCalGas' branch office closure proposal:

• We agree with DRA's disallowance of $494,000 in account 903.1 for personnel and other expenses, $252,000 in account 931.6 for lease cost savings, $52,000 in Account 935.6 for facility cost savings.
• APLs should be contracted and operational within one mile prior to the closing of a branch office.
• SoCalGas should articulate a customer notification program consisting at least of letters to customers of the branch offices within the last 12 months, and posted signs in multiple languages at least 45 days prior to closing.
• SoCalGas should be held to its goal to increase the number of APLs.
• A centrally located 24-hour drop box should be maintained in San Luis Obispo until evidence is provided that customers using the drop box options in SLO have been afforded a reasonable alternative level of service.
• Ring down phones should be provided in new APLs, or a public phone with a toll-free number should be available within one block of the APL.
• SoCalGas should monitor and report the customer satisfaction indicator on APL service.

Regarding the service quality of both SDG&E and SoCalGas:

• Convert the service quality indicators on phone contact satisfaction, field visit satisfaction and call center responsiveness to penaltyonly indicators.
• Redefine the Field Service Order Appointments indicator to include timed appointments on all PBR service order types, and make it monitor-only.
• Begin implementation of a policy to avoid payday loan-type businesses as authorized payment locations for utility payments.
• Implement tariff language consistent with the Commission's recent clarifications about "billing error." Verify that the practices of SoCalGas are consistent with the tariff language.