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There are basic steps that Energy Suppliers and Brokers should take when responding to a PUC-provided customer complaint.

Carefully read the PUC Customer Complaint – Read the entire complaint carefully.

 Promptly acknowledge receipt of the PUC investigation notice – You want the Commission Staff to know that responding to customer complaints is a priority.

 Identify the complaint issue(s) raised in the complaint – Identify the issue or issues raised by the customer complaint. Don’t overlook this step.

Investigate Thoroughly – Gather all relevant facts, documents, account records, and relevant information.

Be Factual and Professional – Structure your response by clearly addressing each point raised by the customer.  Focusing on objective information, not emotions. Use the documents you have gathered to support your response.

Propose a Solution – Outline specific steps taken or planned to be taken to resolve the issue, such as correcting a billing error or scheduling service.

Adhere to Deadlines – Submit your response within the time frame specified by the PUC investigator to avoid further scrutiny or worse yet, escalation to further investigation.

Keep Records – Maintain detailed records of the complaint and all communications for potential future review.  This is an incredibly important step that cannot be overlooked.  Develop a customer-specific complaint tracker that includes all relevant information, including customer name/account number, complaint type, agent involvement, steps taken, etc.

Let’s say a customer complaint centers on not receiving the required contract expiration notices.  In preparing a response to this type of customer complaint, the following questions should be addressed by the Supplier when responding to the PUC.  For example, in a contract-expiration complaint, certain issues probably need to be addressed.

• What was the contract expiration date?
• Did the customer opt for electronic notices?
• If so, can you provide proof?
• If the customer did not opt for electronic notices, were email(s) sent to the customer and perhaps additional reminders (that are not required)?
• Have you located the actual contract that was originally provided to the customer?
• What does that contract say about contract expiration notices?
• Does the Supplier have the actual contract expiration notices that were provided to the customer?
• Do the actual contract expiration notices comply with PUC requirements as they relate to the contents of this notice? You want to know this before responding to the customer complaint. If you learn that the contract expiration notices are deficient and do not comply with the PUC rules, you will have to acknowledge and address this in the complaint. Here is a good place to suggest remedial action your company will take after learning of the deficiency.
• If required by PUC rules, did the contract expiration notices state in bold lettering that no termination penalties would apply XX days prior to the date stated as the expiration date in the notice? Does your contract expiration notice comply with the PUC rules?
• Did the contract expiration notice inform the customer that if they terminated the contract more than XX days prior to the contract expiration date, the early termination fee would still apply, and that the amount of that fee?
• Before submitting the complaint response, carefully review it to ensure it fully addresses the customer complaint and includes the necessary supporting documents. Here, it is a great idea to have someone else read the response.

What if a Customer is Not Satisfied with The Supplier/Broker Complaint Response?

 Overview of the Formal PUC Customer Complaint Process

If a resolution is not reached through the informal PUC complaint process, in most jurisdictions, the consumer may pursue the matter by filing a formal complaint for consideration by the Commission.

If requested by a customer,  the PUC will send the necessary forms for filing to the consumer through the Chief Clerk’s office. Once filed with the Commission, the formal complaint will be given a docket number and assigned to an Administrative Law Judge or Hearing Officer.

If the formal complaint proceeds to a hearing, the process is similar to a court hearing. Consumers may use a lawyer’s service, though it is not usually required.

Most PUCs provide reference guides offering information on preparing for a formal hearing. After the hearing, the Administrative Law Judge will consider the testimony and evidence presented and recommend a decision on the case to the Commission.

In accordance with specific PUC laws, most formal complaints must be filed with the Commission within one or two years from the time the product, commodity or service to which the complaint is made was furnished or performed. For example, in Illinois, under 9-252.1 of the Public Utilities Act, a formal complaint regarding an incorrect billing must be filed with the Commission no more than 2 years after the customer first learns of the incorrect billing.