File a Complaint at the CPUC

Read: cpa ccas clean up sce snafu affects 100000 customer bills/

Read: SCE Goes Back to Manual Paper Billing After Smart Meter Fiasco for Thousands of Solar Ratepayers

Read:

1. Bradley L. Bartz

President and Founder
ABC Solar Incorporated

Office is in Torrance at 24454 Hawthorne Blvd.

PH: 1-310-993-3240 cell/text
https://abcsolar.com

2. Southern California Edison has failed billing for a 100,000 ratepayers who moved to a competitor and possibly 30,000 solar adopters. SCE billing just happens to be harming two key competitors to SCE and both competitors have no viable legal recourse to stop them. This billing issue is known by SCE and the California Public Utilities Commission. It has been going on for more than a year. The Regulator and the Regulated are too cozy.

SCE has come to learn that solar adoption happens faster when paperwork is smooth. This is the basis for the nefarious SCE billing scandal.

I discovered ABC Solar clients since January of 2019 were in some form of SCE billing failure. 14 of my solar competitors report same issue. Even worse the South Pasadena News reported that 100,000 Clean Power Alliance (CPA) clients are also not being billed correctly.

The CPA reports ratepayers opting out because of the SCE billing failure. For solar clients it creates disdain towards their solar investment and their solar contractor.

It became clear that SCE was doing this billing failure to simply confuse and anger solar adopters and CPA traitors. It seems a shrewd business decision. SCE might have asked the spreadsheet how long it would have to have failed billing to create bitter solar adopters and get CPA ratepayers back. Rule 17.D now comes into play.

Basically Rule 17.D says SCE can only collect for the past three months of bills during a failed billing state lasting more than three months. As this issue is a year old then SCE has 200 million dollars it can not collect. NEM contracts last 20 years for solar electricity generators. CPA traitors last forever.

Finally, it is clearly possible that SCE is deliberately doing this billing failure having made a cost benefit analysis of 200 million dollars versus slowing or killing adoption of solar and/or loss of clients to CPAs.

RESOLUTION SOUGHT

Encouraging SCE Ratepayers to individually call SCE and demand a full bill review and for the bill to be held by Rule 17.D standards. Please post this number 1-800-655-4555. Also each ratepayer needs to file a formal complaint at the CPUC.

https://consumers.cpuc.ca.gov/CABUtilityComplaint.aspx

The CPUC forces individuals to opt-out of SCE bad behavior. The CPUC should be encouraged to fix this problem immediately as they are aware of the size and scope of this issue. This is an easy fixed by repealing immunity granted in BPC17605(a) for SCE from Negative Option Billing among other ruthless laws that SCE and its ilk got passed.

For example, small Churches in SCE territory need to Opt-Out of demand billing imposed by SCE unilaterally. Regularly I have saved churches hundreds of dollars a month by just getting them to switch SCE rate tariff schedule. The CPUC allows SCE to fleece the ratepayer to the maximum it can and only when the ratepayer uses their “Negative Option” can they get bill justice. Please tell your pastor if KW demand is below 20 call SCE immediately. Same is true for Mosques, Buddhist and Jewish temples.

Saving thousands of dollars a year for a church who then uses it for good feels really good. AND that is without selling them solar or anything at all. Just by calling SCE at 1-800-655-4555 and asking for a complete bill review and lower rate schedule. This will be really true now as the Corona Virus will lower their electrical usage.

Since the "Smart Meter" was demanded by SCE and its lobbyists then all future billing to SCE Ratepayers should be automatically set in real time to the best advantage of the ratepayer. No more making the individual ratepayer call to opt-out of profiteering by SCE.

Encourage an Emergency Declaration by Governor Newsom to cease billing to all SCE Ratepayers until the Corona Virus stops circulating. Announce that the power will stay on if you can't pay SCE. Eat first the Governor should state.

Encourage Governor Newsom to break up the CPUC into 22 regional centers and establish full due-process court mechanisms that are now sorely missing.

If it shown that SCE is doing this billing SNAFU on purpose then we demand forfeiture of their license to operate and in the short term hire LADWP to manage the systems until a new publicly owned and operated utility can be established.

What can be done?

“Not much,” said Bradley Bartz, President and Founder of ABC Solar Inc. “The California Legislature gives SCE immunity from the courts and they hide behind the California Public Commission. Basically, unless Governor Newsom orders a Solar Czar to take CPUC power and focus our state towards achieving 100% renewable per SB100, which is already law, we are all stuck with Smart-Alec Meters and greedy monopolies.”

Bartz also was clear when he stated, “I think that every Californian and Federal Agency that has a scant of jurisdiction, including, but not limited to the Securities and Exchange Commission should seek disclosure of any communications around this known to SCE and the CPUC failed billing issue. Either gross incompetency is being hidden or a crime is being covered up.”

3. https://cleanpoweralliance.org/ - clients of the CPA are also getting harmed.

Jennifer Ward - Director at CPA (a harmed party)

https://www.californiadgstats.ca.gov/ you can download all solar clients connected to the grid here. I also have them in a database for easier processing.

Read: cpa ccas clean up sce snafu affects 100000 customer bills/

Read: SCE Goes Back to Manual Paper Billing After Smart Meter Fiasco for Thousands of Solar Ratepayers

Read:

Please see attached a Bulletin from the Solar Consumer Protection Taskforce. This taskforce is aware of the billing failure and does nothing.

Also attached is a summary I am using to recruit a law firm. So far no luck, but some interest.

4. Attached is one picture from this morning... and here a few others I found https://bartz.com/bradley/brad.jpg

I have a beautiful voice and my home in Palos Verdes is a Solar Research & Development dream with a commanding view from Catalina Island to Downtown LA. I am a solar expert with 20 years since founding ABC Solar. I also write solar books which you can see at www.SolarBible.com. And, hoping not to scare you … at htps://www.SolarPanic.com you can see a youtube video of me describing the previous SCE scandal involving Battery Backup Systems.

I am native Californian, 54 years old and started the first internet company in Japan in 1990. I lived in Japan until 2000 and that is when I founded ABC Solar Incorporated. Before moving to Japan I ran a company teaching blind people to sell on the phone in cooperation with Loyola Marymount University.

5. Jennifer Kamphuis Net Metering Department Kathryn Enright - legal team member Alice.Stebbins@cpuc.ca.gov - Executive Director at the Public Utilities Commission


www.SolarPanic.com/RULE21

Contact: Bradley L. Bartz
President
ABC Solar Incorporated
1-310-993-3240
Solar@ABCsolar.com
CCL#914346

Smartass Meters Make IOUs for California IOUs by Taking Solar Power But Not Metering It

February 18, 2020 – Los Angeles, California – Everyday now an ABC Solar client is calling saying that their solar investment is worthless in that they are still receiving bills up to a year after Permission-To-Operate (PTO) was granted by Southern California Edison (SCE). Generally speaking, one billing issue among our solar clients is an anomaly that is dealt with, but when a trend shows itself concern grows.

Permission To Operate is analogous to a Race Car Driver at the starting line getting the green go-go-go flag to start racing from SCE. As racing is a team sport, the solar contractor built the car and the ratepayer is the driver. Once the race starts SCE turns off the TV feed and does not post results. The builder of the car never learns if his client finished the race. And astonishingly the client does not know if they finished the race either.

ABC Solar checked with other Sothern California based solar contractors and they too report billing purgatory for their SCE clients Post-PTO. Each Post-PTO billing error creates an “I OWE YOU” from SCE to the ratepayer. Besides the monetary value of each solar ratepayer who is providing SCE solar power but is not getting credit for it, it is the Smart Meter itself that setup California ratepayers to be abused.

The California Public Utilities Commission via its RULE 21 requires SCE to inform both the ratepayer and the commission in each instance where a ratepayer is granted PTO but SCE has not established Net-Metering billing within 30 days. SCE has told ABC Solar it sent out a generic email in November 2019 attesting to their non-compliance. But, none of my staff, myself or my clients have seen such communication. Further, Rule 21 clearly states SCE must report to the CPUC for each case. And! We have cases after that date.

Sometimes more is more, but in this case the client, Mr. More, does not deserve to be lost in the Smart Meter rejection of solar and then SCE out-of-compliance reporting behavior.

To further complicate issues SCE claims blanket secrecy Post-Permission-To-Operate and will only communicate with the ratepayer. This modus operandi of SCE is known as a Negative Option and is illegal both federally and in the State of California. A Negative Option is where SCE can behave in bad faith and gain monetary value with their actions, but the Ratepayer has the onus to report and opt-out of the SCE bad faith behavior. SCE loves them smart meters, but still uses Negative Option Billing to abuse clients. It is clear that with Smart Meters in place the CPUC could order SCE to put ratepayers in the most advantages billing structure in real-time. The CPUC is supposed to protect ratepayers but it just is not the case.

If you are a SCE customer, I would call them immediately and ask for a full rate review of your account. Ask the kind operator at SCE to find the best and most advantageous rate plan for you. Heck, I would call your utility company and ask the same of them, even if not SCE. The fact that CPUC supports SCE ability to continue to use Negative Option Billing by immunity from state laws, in particular PUC 1759, is bad.

Illegal Negative Option Billing is a just reason to breakup the CPUC and remove superior court immunity from SCE and other IOUs.

As a way to help protect ABC Solar clients we have formally filed a Point of Clarification and as required by RULE 21 a Formal Written Notice of a dispute.

The dispute shall be documented in a written notice ("notice")by the aggrieved Party to the other Party containing the relevant known facts pertaining to the dispute, the specific dispute and the relief sought, and express notice by the aggrieved Party that it is invoking the procedures under this Section."

1. Facts

a. SCE has failed in establishing NEM billing thereby not-completing its Permission-To-Operate obligations.

b. SCE claims to have sent notice last year (November 2019) on the issue to ratepayers, but our ABC Solar clients have no knowledge of such correspondence.

c. SCE claims it cannot disclose to ABC Solar whether the ratepayer has NEM billing successfully established "Post PTO".

d. ABC Solar claims that the Permission-To-Operate (PTO) process is not complete until NEM billing is successfully established, therefore, any solar client who has received PTO but has not been set up on SCE NEM is NOT "Post PTO"

e. SCE obligations under Rule 21 show clearly that the internal designation by SCE of "Post PTO" is a term does not exist in RULE 21 Text.

2. Specific Dispute

a. Clients are not being informed per RULE 21 rules and obligations.

b. ABC Solar suspects that the commission is not being informed for EACH case where PTO is granted but SCE has failed to establish NEM billing. We seek verification of notification under RULE 21 per this issue.

c. ABC Solar must be informed when the PTO process is finished. ABC Solar believes that the designation of "POST PTO" can only be claimed by SCE with the successful establishment of NEM billing. To not inform the solar contractor that their process is done is not logical and creates customer service issues for both ABC Solar and SCE.

d. SCE Causing Financial Harm. SCE Billing must stop after PTO is granted. Even if SCE NEM is not established it is very harmful for billing to continue unabated. SCE knowns that NEM Billing setup has failed. This is known within 30 days of PTO as it must be reported by that time. Therefore, SCE Billing must not charge clients during the FAILED SCE MANAGEMENT period. As NEM is annual in its "TRUE-UP" billing, it seem fitting that ratepayers get billing relief immediately after being granted PTO. (Notice I did not say Post PTO. As Post PTO implies SCE completed its obligations under RULE 21 and established NEM billing within 30 days.)

3. Relief Sought

a. Immediate cessation of billing by SCE for ratepayers in the status of granted Permission to Operated but Failed SCE NEM billing establishment.

b. Immediate communication to ratepayers that are in this Failed PTO/NEM Billing status. The obligation is on SCE to disclose, not for ABC Solar to report when clients contact us.

c. Immediate communication to CPUC Commissioners for each and every ratepayer in this Failed PTO/NEM Billing status. SCE Must state that client will get reimbursed for false billing.

d. Immedate order to SCE and other IOUs that they must inform the Solar Contractor when PTO AND NEM Billing setup is successful. No more Purgatory state between PTO and successful NEM billing setup.

4. ABC Solar and its Producer Ratepayers are filing this Express Notice of the Aggrieved Party and we are invoking the procedures under this Section K. DISPUTE RESOLUTION PROCESS 2. Procedures (a) Sheet 160

Basis: Rule 21 seems to make clear that SCE has specific timelines to establish billing for solar systems granted PTO, Permission-To-Operate. It is a false statement that SCE cannot give information about the establishment of billing as SCE defines this as "Post PTO". In a clear and somber reading of RULE 21 nothing states SCE can withhold this NEM Billing Establishment information. This is because the establishment of billing under NEM is included in the PTO responsibilities of SCE.

This means "Post PTO" cannot be claimed until NEM Billing is established.

I sincerely believe that my job, as mandated by the State, is to bring a client to the PTO, Permission To Operate, and successful NEM billing state.

It seems disingenuous that ABC Solar cannot be informed or engage SCE when the PTO and NEM billing establishment process has failed.

Failed. That is the correct word. The SCE NEM process failed.

For example. Permission To Operate is analogous to a Race Car Driver at the starting line getting the green go-go-go flag to start racing from SCE. As racing is a team sport, the solar contractor built the car and the ratepayer is the driver. Once the race starts SCE turns off the TV feed and does not post results. The builder of the car never learns if his client finished the race. And astonishingly the client does not know if they finished the race either.

Unfortunately, SCE has stated: Due to customer privacy issues, we are unable to discuss any post PTO billing details with any party other than the customer or parties with an approved CISR form.

NOTE: Over 20 years in this solar business ABC Solar has steadfastly avoided this CISR and similar forms. SCE NEM Staff can confirm this. ABC Solar feels very strongly about client privacy and security. We feel that the ratepayer can provide billing data if they see fit.

But, this does not relate to being informed of successful NEM billing establishment.

We agree with this statement. Any Post PTO billing details should not be discussed with anyone but the ratepayer and their legal proxy, e.g. cisr form, etc.

But, This situation is not POST PTO. This is Failure to establish SCE NEM Billing means that PTO has failed. Achieving both operational status and NEM Billing is the true sense of what Permission to Operate means.

Further, our request is not about billing details. It is to inform SCE that the ratepayer has not received any communication from SCE and is in the "dark" regarding their light based solar system.

Again, I quote Rule 21:

b. For NEM-1 and NEM-2 Generating Facilities with a capacity of 1 MW or smaller, Distribution Provider approval for Interconnection (i.e., Permission to Operate) shall normally be processed not later than thirty (30) Business Days following Distribution Provider's receipt of 1) a completed Net Energy Metering Interconnection Request including all supporting documents and required payments; 2) a completed signed Net Energy Metering Generator Interconnection Agreement; and 3) evidence of Applicant's final electric inspection clearance from the Governmental Authority having jurisdiction over the Generating Facility. If the 30-day period cannot be met, Distribution Provider shall notify Applicant and the Commission of the reason for the inability to process the Interconnection Request and the expected completion date.

At this time, we suspect multiple clients that have FAILED in NEM billing setup.

COMMISSIONERS: ABC Solar believes that SCE KNOWS 100% to which of our clients granted PTO but failed to establish SCE NEM. This Notice requests each ratepayer and ABC Solar be notified and that the Commission be notified of each instance.

It is my understanding that SCE has to provide in the correspondence the reason for their delays in establishing SCE NEM billing, a confirmation that any wrong billing will be corrected and reimbursed, and SCE course of action for correcting the situation.

This applies to each instance, individually. A blanket letter not addressing each ratepayer (Producer) to that ratepayer and commission is not acceptable.

Further, to address each Producer Ratepayer SCE knows the system size per the NEM Agreement and its monthly production per www.csi-epbb.com and affiliated solar kwh generation calculation resources. Therefore, each letter needs to address to the Producer Ratepayer to the comparison of the SCE Bill being sent (e.g. the not-set-up-NEM billing) and the estimated solar production. Commissioners, please note the Producer Ratepayer and SCE sign a NEM agreement that states SCE estimated kWh production of their system.

Definitions:

Commercial Operation: The status of a Generating Facility that has commenced generating electricity, excluding electricity generated during the period which Producer is engaged in onsite test operations and commissioning of the Generating Facility prior to Commercial Operation.

Commercial Operation Date: The date on which a Generator at a Generating Facility commences Commercial Operation as agreed to by the Parties.

D. GENERAL RULES, RIGHTS AND OBLIGATIONS 13. Special Provisions Applicable to Certain Net Energy Metered Applicants (c) c. Unless Net Generator Output Metering is required, Metering Equipment necessary to obtain service under NEM-1 or NEM-2 shall be installed and operational within the timeframe required to complete Interconnection.

D. GENERAL, RULES, RIGHTS AND OBLIGATIONS Sheet 25 4. Compliance with Laws, Rules, and Tariffs A Producer shall ascertain and comply with applicable Commission-approved tariffs of Distribution Provider; applicable FERC-approved rules, tariffs, and regulations; and any local, state or federal law, statute or regulation which applies to the design, siting, construction, installation, operation, or any other aspect of Producer's Generating Facility and Interconnection Facilities

K. DISPUTE RESOLUTION PROCESS 1. Scope Sheet 160 In addition to the informal procedures for timeline-related disputes set out in Section F.1.d, the following procedures will apply for disputes arising from this Rule: 1. Scope The Commission shall have initial jurisdiction to interpret, add, delete or modify any provision of this Rule or of any agreements entered into between Distribution Provider and Applicant or Producer to implement this tariff ("Implementing Agreements") and to resolve disputes regarding Distribution Provider's performance of its obligations under Commission-jurisdictional tariffs, the applicable agreements, and requirements related to the interconnection of Applicant's or Producer's Generating Facility or Interconnection Facilities pursuant to this Rule.

K. DISPUTE RESOLUTION PROCESS 2. Procedures (a) Sheet 160 2. Procedures Any dispute arising between Distribution Provider and Producer (individually referred to in Section K as "Party" and collectively "the Parties") regarding Distribution Provider's or Producer's performance of its obligations under its tariffs, the Implementing Agreements, and requirements related to the interconnection of Producer's Facilities pursuant to this Rule shall be resolved according to the following procedures: a. The dispute shall be documented in a written notice ("notice")by the aggrieved Party to the other Party containing the relevant known facts pertaining to the dispute, the specific dispute and the relief sought, and express notice by the aggrieved Party that it is invoking the procedures under this Section. The notice shall be sent to the Party's email address and physical address set forth in the Generator Interconnection Agreement or Interconnection Request, if there is no Generator Interconnection Agreement. A copy of the notice shall also be sent to the Energy Division, Office of the Director, at the Commission. The receiving Party shall acknowledge the notice within five (5) Calendar Days of its receipt. Upon the aggrieved Party notifying the other Party of the dispute, each Party must designate a representative with the authority to make decisions for its respective Party to review the dispute within seven (7) Calendar Days. In addition, upon receipt of the notice, Distribution Provider shall provide the aggrieved Party with all relevant regulatory and/or technical details and analysis regarding any Distribution Provider interconnection requirements under dispute within twenty-one (21) Calendar Days. Within forty-five (45) Calendar Days of the date of the notice, the Parties' authorized representatives will be required to meet and confer to try to resolve the dispute. Parties are expected to operate in good faith and use best efforts to resolve the dispute.

K. DISPUTE RESOLUTION PROCESS 3. Performance During Dispute Sheet 161 Pending resolution of any dispute under this Section, the Parties shall proceed diligently with the performance of their respective obligations under this Rule and the Implementing Agreements, unless the Implementing Agreements have been terminated. Disputes as to the Interconnection Request and implementation of this Section shall be subject to resolution pursuant to the procedures set forth in this Section.

About ABC Solar

ABC Solar was founded in 2000 in response the Enron being allowed by the CPUC to rip off California ratepayers. Over the years ABC Solar has been a steadfast advocate for the rule-of-law in the solar business. This includes calling out bad players and continually holding the CPUC and its IOUs to account. Learn more at www.ABCsolar.com