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HomeMy WebLinkAbout2020-02-20; Clean Energy Alliance JPA; ; Adopt Resolution Approving Clean Energy Alliance PoliciesClean Energy Alliance JOINT POWERS AUTHORITY Staff Report DATE: February 20, 2020 TO: Clean Energy Alliance Board of Directors FROM: Barbara Boswell, Interim Chief Executive Officer ITEM 6: Adopt Resolution Approving Clean Energy Alliance Policies RECOMMENDATION: Adopt Resolution #2020-### approving Clean Energy Alliance policies related to travel and reimbursement, customer confidentiality and privacy and collections: 1. CEA -001 Travel and Reimbursement Policy 2. CEA-002 Protection of Confidential Information 3. CEA-003 Privacy and Customer Confidentiality Policy 4. CEA-004 Advanced Metering Infrastructure (AMI) Data Security and Privacy Policy 5. CEA-005 -CEA Collections Policy BACKGROUND AND DISCUSSION: As part of establishing its community choice aggregation (CCA) program, Clean Energy Alliance (CEA) it is good business practice to establish policies and procedures for good internal controls and to meet state and CPUC requirements. The policies that are before the Board for consideration have been drafted to meet those requirements. CEA-001 Travel and Reimbursement Policy -California Government Code Section 53232.2 establishes the requirement for a policy to be adopted if a government agency reimburses its officials for expenses incurred in the course of conducting related business. The proposed policy has been drafted based on similar policies of CEA's member agencies, in compliance with government code, and following best practices are recommended by the League of California Cities. The policy as drafted would be applicable to Board Members, future committee members, employees and consultants. CEA-002 through CEA-004 -In anticipation of CEA operating its CCA, policies CEA-002 through CEA-004 are recommended to be approved in compliance with California Public Utilities Commission (CPUC) Decision 12-08-045 established that CCA programs must comply with the same customer confidentiality and privacy rights as all other load serving entities. Once operational, CEA will be subject to further audits and annual reporting related to its compliance with the CPUC decision. Adoption of these policies sets the procedures for ensuring protection of confidential customer information and energy usage. Feb.20,2020 Item #6 Page 1 of 21 February 20, 2020 CEA Policies Page 2 of 2 CEA-02 Protection of Confidential Information establishes procedures for handling confidential customer data and ensures all employees protect the integrity of confidential information. This policy is implemented in conjunction with CEA-03 Privacy and Customer Confidentiality. CEA-03 Privacy and Customer Confidentiality establishes procedures for handling of energy usage information. This policy is implemented in conjunction with CEA-02 Protection of Confidential Information. CEA-04 Advanced Metering Infrastructure (AMI) Data Security and Privacy Policy establishes procedures for handling of energy usage data collected from_systems that measure, collect and analyze energy usage and communicate with metering devices. CEA-OS Collections Policy -Once operational, CEA will work with San Diego Gas & Electric (SDG&E) for the provision of billing and collection services. There will be times, however, when it is recommended that CEA take proactive actions when customer accounts become delinquent, or when SDG&E will discontinue pursuing collection and will return the account to CEA for collection. The recommended policy reflects best practices as established by operating CCAs throughout the state. ATTACHMENTS: Resolution #2020-### Approving Clean Energy Alliance Policies Feb.20,2020 Item #6 Page 2 of 21 CLEAN ENERGY ALLIANCE RESOLUTION NO. 2020-002 A RESOLUTION OF THE BOARD OF DIRECTORS OF THE CLEAN ENERGY ALLIANCE APPROVING TRAVEL AND REIMBURSEMENT AND CUSTOMER CONFIDENTIALITY AND PRIVACY POLICIES WHEREAS, the Clean Energy Alliance (CEA) is a joint powers agency, formed in November 2019, by founding members cities of Carlsbad, Del Mar and Solana Beach; and WHEREAS, Community Choice Aggregation (CCA) authorized by Assembly Bill 117, is a state law that allows cities, counties, and other authorized entities to aggregate electricity demand within their jurisdictions in order to purchase and/or generate alternative energy supplies for residents and businesses within their jurisdiction while maintaining the existing electricity provider for transmission and distribution services; and WHEREAS, CEA Board has approved an Implementation Plan and Statement of Intent and submitted it to the California Public Utilities Commission (CPUC) for certification on December 23, 2019; and WHEREAS, the CEA Board desires to establish administrative policies and customer confidentiality and privacy protections pursuant to CPUC Decision 12-08-045. NOW, THEREFORE, BE IT RESOLVED, by the Board of Directors of the Clean Energy Alliance, as follows: Section 1. The Board of Directors ofthe Clean Energy Alliance hereby approves the following policies: CEA-01: Travel and Reimbursement Policy CEA-02: Protection of Confidential Information Policy CEA-03: Privacy and Customer Confidentiality Policy CEA-04: Advanced Metering Infrastructure (AMI) Data Security and Privacy Policy CEA-OS: CEA Collections Policy CEA Resolution# 2020-002 Approving CEA Policies The foregoing Resolution was passed and adopted this 20th day of February, 2020, by the following vote: AYES: NOES: ABSENT: ABSTAIN: Schumacher, Haviland, Becker None. None. None. APPROVED: ATTEST: fflQ,~(hl~ ~ Cobian, Board Secretary ? Clean Energy Alliance Administrative Policy SUBJECT: EFFECTIVE DATE: Travel and Reimbursement Policy February 20, 2020 POLICY#: SUPERSEDES STAFF CONTACT # OF PAGES: CEA-01 N/A 3 1.0 Purpose To establish a written policy to provide guidance to elected and appointed officials, employees, independent contractors and volunteers on the use and expenditure of Clean Energy Alliance (CEA) resources, as well as the standards against which those expenditures will be measured. 2.0 Organizations affected Clean Energy Alliance Committees 3.0 4.0 Consultants and Independent Contractors References California Government Code 53232.2 League of California Cities Internal Revenue Service Definitions 4.1 CEA Business Travel -Travel which requires elected and appointed officials, employees, independent contractors or volunteers to conduct specific items of CEA business away from their normal place of business. 4.2 CEA employee -Any person regularly employed by CEA, excluding elected or appointed officials, members of committees and volunteers. 4.3 Member of committee -any person appointed by the CEA Board to an established committee. 4.4 Volunteer -any person donating their time in support of CEA business. 4.5 Out-of-State Travel -includes all costs related to business travel outside the State of California. Policy# CEA-01 4.6 In-State travel -all costs related to business travel within the State of California. 4.7 Miscellaneous Meals/Mileage-all miscellaneous costs not directly attributable to conferences or training. 5.0 Policy 5.1 CEA funds, equipment, supplies (including letterhead), titles and staff time must only be used for authorized CEA business. Expenses incurred in connection with the following types of activities generally constitute authorized expenses, as long as the other requirements of this policy are met: 5.1.1 Communicating with representatives of regional, state and national government on CEA adopted policy positions. 5.1.2 Attending educational seminars designed to improve skill and information levels. 5.1.3 Participating in regional, state and national organizations whose activities affect the CEA's interests. 5.1.4 Recognizing service to the CEA 5.1.5 Attending CEA events. 5.1.6 International travel and expenses which exceed the approved budget require prior approval by the CEA Board. 5.2 Personal expenses that the CEA will not reimburse include, but are not limited to: personal portion of any trip; political or charitable contributions or events; family expenses; entertainment expenses, including theater, movies, sporting events or other cultural events; non-mileage personal automobile expenses; personal losses incurred while on authority business. 5.3 Cost Control -To conserve CEA resources and keep expenses within community standards for public officials, expenditures should adhere to the following guidelines: in the event that expenses are incurred which exceed these guidelines, the cost borne or reimbursed by the CEA will be limited to the costs that fall within the guidelines. 5.4 Transportation -The most economical mode and class of transportation reasonably consistent with scheduling needs and cargo space requirements must be used, using the most direct and time-efficient route. 5.5 Mileage -Automobile mileage will be reimbursed at the Internal Revenue Service standard mileage rates. These rates are designated to compensate the driver for gasoline, insurance, maintenance and other expenses associated with operating the vehicle. This amount does not include bridge and road tolls, which are also reimbursable. 2 Policy# CEA-01 5.6 Airfare -Airfares that are equal or less than those available through the Enhanced Local Government Airfare Program offered through the League of California Cities, the California State Association of Counties and the State of California are presumed to be the most economical and reasonable for purposes of reimbursement under this policy. 5.7 Car Rental -Rental rates that are equal or less than those available through the State of California's website shall be considered the most economical and reasonable for purposes of reimbursement under this policy. Itemized receipts must be submitted with vehicle rental claims, including receipts for fuel. 5.8 Taxis/Shuttles/Ride Shares -Taxis or shuttles fares may be reimbursed at actual cost, including a 20 percent gratuity per fare, with receipts. 5.9 Lodging-Lodging expenses will be reimbursed or paid for when travel on official CEA business reasonably requires an overnight stay. Travelers must request government rates, when available. Lodging rates that are equal to or less than government rates are presumed to be reasonable and hence reimbursable for purposes of this policy. In the event that government rates are not available at a given time or in a given area, reimbursement shall be provided at the rate established by the Internal Revenue Service ("IRS") for the community in which the activity takes place unless there are no lodging facilities in reasonable proximity to the activity which offer that rate at the time of booking. In the event there are no such lodging facilities available at the IRS reimbursement rate, reimbursement shall be at the actual lodging rate as long as the activity has been approved by the CEA Board. 5.9.1 Conference/Meetings -If such lodging is in connection with a conference, lodging expenses must not exceed the group rate published by the conference sponsor for the meeting in question if such rates are available at the time of booking. If the group rate is not available, see previous section. 5.10 Meals-Reimbursable meal expenses are reimbursable up to a maximum $30 per meal and associated gratuities up to a maximum 20%. The CEA will not pay for alcohol/personal bar expenses. 5.11 Telephone/Fax/Cellular/Internet -Actual telephone, fax and short-term internet expenses incurred on CEA business are reimbursable when not covered under a pre-existing plan or service arrangement. 5.12 Airport Parking -Long-term parking must be used for travel exceeding 24-hours. 3 6.0 Policy # CEA-01 5.13 Other-Baggage handling fees of up to $2 per bag and gratuities of up to 20 percent will be reimbursed. Expenses for which CEA officials receive reimbursement from another agency are not reimbursable. 5.14 Credit Card Use -CEA does not issue credit cards to individual office holders and does not have a CEA credit card. Procedure 6.1 All expense reimbursement requests must be submitted on a Report of Actual Travel Expense report form provided by the CEA. 6.1.1 Expense reports must document that the expense in question met the requirements of this policy. For example, if the meeting is with a legislator, the official should explain whose meals were purchased, what issues were discussed and how those relate to the CEA's a9opted legislative positions and priorities .. 6.1.2 Officials must submit their expense reports within two weeks of an expense being incurred, accompanied by receipts documenting each expense. Restaurant receipts, in addition to any credit card receipts, are also part of the necessary documentation. Inability to provide such documentation in a timely fashion may result in the expense being borne by the official. 6.2 All Expenses are subject to verification that they comply with this policy. 6.3 At the following CEA Board meeting, each official shall briefly report on meetings attended at CEA expense. If multiple officials attended, a joint report may be made. 6.4 CEA officials should keep in mind that some expenditures may be subject to reporting under the Political Reform Act and other laws. All CEA expenditures are public records subject to disclosure under the Public Records Act (and other laws). ~~4 Barbara Boswell Date Interim Chief Executive Officer 4 Clean Energy Alliance Administrative Policy SUBJECT: EFFECTIVE DATE: Protection of Confidential Information February 20, 2020 POLICY#: SUPERSEDES STAFF CONTACT # OF PAGES: CEA-02 N/A 3 1.0 2.0 3.0 4.0 Purpose To establish a policy to protect confidential customer information Organizations affected Clean Energy Alliance All Clean Energy Alliance Member Agencies References Privacy & Customer Confidentiality Policy #CEA-03 Definitions 4.1 Confidential Information Customer information that is not considered public information including but not limited to social security number, taxpayer ID number, San Diego Gas & Electric (SDGE) or Clean Energy Alliance (CEA) customer or service account information including customer name(s), service addresses, billing addresses, telephone numbers, email addresses, account numbers and electricity consumption. 5.0 Policy 5.1 Ensuring Customer Confidentiality is Protected To ensure that all employees protect the integrity of the CEA's confidential information as well as the confidentiality of others, confidential information may not be shared with unauthorized individuals within or outside of the organization and may not be transmitted via email, except where reasonably necessary to conduct CEA's business or provide services to customers as required by the California Public Utilities Commission (CPUC). 5.2 Examples of reasonably necessary business purposes include but are not limited to when such disclosure is necessary to: a) Comply with law, regulation, or court order; b) Enable CEA to provide services to its customers; c) Collect unpaid bills; 6.0 Policy# CEA-02 d) Obtain and provide credit reporting information; e) Resolve customer disputes or inquiries; f) Communicate about demand response, energy efficiency, energy management and conservation programs; or In situation of imminent threat to life or property. Procedure 6.1 Confidential information shall not be transmitted or forwarded to individuals within or outside of the organization who do not have an authorized need to know the information. 6.2 Confidential information shall not be transmitted via email. 6.3 Confidential information shall not be posted on the CEA's website. 6.4 Employees must lock their computers when leaving them unattended for any length of time. 6.5 Passwords may not be shared with any person, including admini$trative assistants, secretaries, managers, co,;.workers, or family members, and shall not be written down or stored physically or digitally. 6.6 Documents containing confidential information must be secured at all times. 6.7 Documents containing confidential information must be shredded when destroyed when no longer used and as per the adopted retention schedule if applicable, except where such documents are required to be retained by law. 6.8 Employees are responsible for any action that is performed under their username and password for any CEA system, network or server. 6.9 Failure to comply with the provisions of this policy and procedure may result in discipline up to and including termination. Barbara Boswell Date Interim Chief Executive Officer 2 Policy# CEA-02 PROTECTION OF CONFIDENTIAL INFORMATION POLICY ACKNOWLEDGEMENT I have read the Protection of Confidential Information Policy and understand its provisions. I understand that to ensure protection of the integrity of the CEA's confidential information as well as the confidentiality of others, confidential information may not be shared with unauthorized individuals within or outside of the organization and may not be transmitted via email. I accept responsibility for any action performed under my user name and password. I understand that handling and use of confidential information in violation of the Protection of Confidential Information Policy may result in employee discipline, up to and including termination. By signing this form, I agree to abide by the Policies currently in place and I agree to review periodically any changes or modifications. I understand that my regular review of policies is required. Employee Name (Print): ______________________ _ Employee Signature: ______________ Date: _______ _ Department Head Signature: __________________ Date: _______ _ (To be filed with Human Resources) 3 Clean Energy Alliance Administrative Policy SUBJECT: EFFECTIVE DATE: Privacy and Customer Confidentiality Policy February 20, 2020 POLICY#: SUPERSEDES STAFF CONTACT # OF PAGES: CEA-03 N/A 3 1.0 Purpose: To establish a Privacy and Customer Confidentiality Policy for Clean Energy Alliance (CEA). 2.0 Organizations affected: Clean Energy Alliance Clean Energy Alliance Board Members All Clean Energy Alliance Member Agencies 3.0 References: CPUC Decision 12-08-045 4.0 Definitions: 5.0 4.1 Aggregate Data -Aggregated customer confidential information must be made up of at least 15 customers and a single customer's load must be less than 15% of an assigned category. 4.2 Confidential Information -has a meaning in accordance with CPUC Decision 12- 08-045, which extends privacy protections to customers of community choice aggregation programs. 4.3 Customer Data -includes individual names, addresses and electricity energy usage data of customers that is collected via San Diego Gas & Electric's (SDGE) metering systems. Policy -Notice of Accessing, Collecting, Storing, Using and Disclosing Energy Usage Information: 5.1 CEA, its employees, agents, contractors, and affiliates shall maintain the confidentiality of individual customers, including name(s), service address(es), billing address(es), telephone number(s), email address(es), account number(s), social security number(s), taxpayer ID number(s), and electricity consumption Policy# CEA-03 information; except as reasonably necessary to conduct CEA's business operations or to provide services to customers as required by the CPUC. 5.2 Examples circumstances constituting reasonably necessary disclosures, sharing, or transmitting of confidential information include, but are not limited to, when necessary to: a) Comply with any law, regulation, or court order; b) Enable CEA to provide services to its customers; c) Collect unpaid bills; d) Obtain and provide credit reporting information; e) Resolve customer disputes or inquiries; f) Communicate about demand response, energy efficiency, energy management and conservation programs; or g) In situation of imminent threat to life or property, or to prevent or resolve service interruptions. 5.3 CEA shall not, under any circumstances, disclose customer confidential information for third-party telemarketing, email, or direct mail solicitation purposes. Aggregated data that cannot be traced to specific customers may be released at CEA's discretion. 5.4 Customer data, including individual customer names, addresses and electricity energy usage data, is collected via San Diego Gas & Electric's (SDGE) metering systems. CEA may share customer data with contractors and vendors for purposes of providing services and operating programs. Contractors and vendors are required to agree to only use customer data for program operational purposes and protect it under the same standards as CEA. CEA retains customer- specific energy usage and billing information for only as long as is reasonably necessary, typically not more than five (5) years unless otherwise required by law or regulation. 5.5 Notice of this policy will be provided when confirming a new customer account, and annually to customers via an on-bill message to guide customers to the most updated version on CEA's website at www.TheCleanEnergyAlliance.org. Any changes to this policy between notification periods will be communicated through CEA's website. Previous versions of this policy can be requested via email at CEO@TheCleanEnergyAlliance.org or by mailed request to Clean Energy Alliance, 1200 S. Carlsbad Village Dr, Carlsbad, CA. 92008. 5.6 Customers having any questions or concerns regarding the collection, storage, use or distribution of customer information, or who wish to view, inquire about, or dispute any customer information held by CEA or limit the collection, use or disclosure of such information may contact the Chief Executive Officer of Clean 2 Policy# CEA-03 Energy Alliance via email at CEO@TheCleanEnergyAlliance.org or by mail at Clean Energy Alliance, 1200 S. Carlsbad Village Dr, Carlsbad, CA. 92008. 5.7 Employees of CEA shall be provided a copy of this policy, and it shall be construed and implemented by such employees consistent with Policy CEA-02 - Protection of Confidential Information policy to protect confidential customer information. ·~/&C<A ~-eRL Barbara Boswell Date Interim Chief Executive Officer 3 Clean Energy Alliance Administrative Policy SUBJECT: EFFECTIVE DATE: Advanced Metering Infrastructure (AMI} Data Security and Privacy Policy February 20, 2020 POLICY#: SUPERSEDES STAFF CONTACT # OF PAGES: CEA-04 N/A 5 1.0 Purpose To ensure the privacy and security of AMI data and customer usage information for Clean Energy Alliance (CEA). 2.0 Organizations affected Clean Energy Alliance All Clean Energy Alliance Member Agencies 3.0 References CPUC Decision 12-08-045 4.0 Definitions 4.1 Aggregate Usage Data: Customers' energy usage and usage-related data (such as billing, program participation, or account information) that has been summed, averaged, or otherwise processed such that the result does not contain information at the level of individual customers and an individual customer cannot reasonably be re-identified. 4.2 Covered Information: Any customer energy usage information obtained through the use of the capabilities of Advanced Metering Infrastructure (AMI) when associated with any information that can reasonably be used to identify an individual, family, household or residence, or non-residential customer, except that covered information does not include usage information from which identifying information has been removed or information provided to the CPUC pursuant to its oversight responsibilities. 4.3 Primary Purposes: 5.0 6.0 Policy# CEA-04 The "Primary Purposes" for the collection of storage, use or disclosure of covered information are to: • Provide or bill for electrical power, • Provide for system, grid or operational needs, • Provide services as required by state, or federal laws or as specifically authorized by an order of the Commission, or • Plan, implement, or evaluate demand response, energy management, or energy efficiency programs under contract with a Community Choice Aggregator or an Electrical Services Provider (when providing service to residential or small commercial customers), under contract with the Commission, or as part of a Commission authorized program conducted by a governmental entity under the supervision of the Commission. 4.4 Secondary Purpose: Policy 5.1 Secondary Purpose means any purpose for the collection, storage, use, or disclosure of covered information that is not a primary purpose. CEA shall implement reasonable administrative, technical, and physical safeguards to protect covered information from unauthorized access, destruction, use, modification or disclosure. 5.2 CEA and third parties shall provide reasonable training to all employees and contractors who use, store, or process covered information. 5.3 CEA shall collect, store, use, and disclose only as much covered information as is reasonably necessary or as authorized by the Commission to accomplish a specific primary purpose. Procedure Transparency and Notification 6.1 CEA shall provide customers with meaningful, clear, accurate, specific, and comprehensive notice regarding the accessing, collection, storage, use and disclosure of covered information. However, when CEA is using covered information solely for a primary purpose on behalf of and under contract with utilities it is not required to provide notice separate from that provided by the utility. 6.2 CEA shall provide written notice when confirming a new customer account, and at least once per year shall inform customers how they may obtain a copy of CEA's notice regarding the accessing, collection, storage, use and disclosure of covered information. CEA will also provide a conspicuous link to the notice on 2 Policy# CEA-04 the home page of its website and include a link to the notice in electronic correspondence to customers. • The notice shall be labeled Notice of Accessing, Collecting, Storing, Using and Disclosing Energy Usage Information. It shall be written in easily understandable language and be no longer than is necessary to convey the requisite information. • The notice and the posted privacy policy shall state clearly: (1) the identity of CEA; (2) the effective date of the notice or posted privacy policy; (3) CEA's process for altering the notice or posted privacy policy, including how the customer will be informed of any alterations and where prior versions will be made available to customers; and (4) the title and contact information, including email address, postal address, and telephone number, of an official at CEA who can assist the customer with privacy questions, concerns, or complaints regarding the collection, storage, use, or distribution of covered information. • The notice shall provide an explicit description of: (1) each category of covered information collected, used, stored, or disclosed, and for each category of covered information, the reasonably specific purpose for which it will be collected, stored, used, or disclosed; (2) each category of covered information that is disclosed to third parties, and, for each such category, a description of the means by which customers may view, inquire about, or dispute their covered information; and (3) the means, if any, by which customers may limit the collection, use, storage, or disclosure of covered information and the consequences to customers if they exercise such limits. 6.3 CEA shall provide to customers upon request convenient and secure access to their covered information, in an easily readable format that is at a level no less detailed than that at which the covered entity discloses the data to third parties. Use, Disclosure, and Customer Authorization 6.4 CEA may disclose covered information without customer consent to a third party acting under contract with the CPUC for the purpose of providing services authorized pursuant to an order or resolution of the CPUC, or to a governmental entity for the purpose of providing energy efficiency or energy efficiency evaluation services pursuant to an order or resolution of the CPUC. 3 Policy# CEA-04 6.5 CEA may disclose covered information to a third party without customer consent when explicitly ordered to do so by the CPUC, or for a primary purpose being carried out under contract with and behalf of CEA provided that CEA requires, by contract, the third party to agree to access, collect, store, use, and disclose the covered information under policies, practices, and notification requirements no less protective than those under which CEA itself operates. 6.6 Any entity that receives covered information derived initially from CEA may disclose such covered information to another entity without customer consent for a primary purpose, provided that the entity disclosing the covered information shall, by contract, require the entity receiving the covered information to use the covered information only for such primary purpose and to agree to store, use, and disclose the covered information under policies, practices, and notification requirements no less protective than those under which CEA operates. 6.7 When CEA discloses covered information to a third party under this subsection it shall specify by contract, unless otherwise ordered by the CPUC, that it shall be considered a material breach if the third party engages in a pattern or practice of accessing, storing, using, or disclosing the covered information in violation of the third party's contractual obligations to handle the covered information under policies no less protective than those under which CEA operates. 6.8 If CEA finds that a third-party contractor to which it disclosed covered information is engaged in a pattern or practice of accessing, storing, using, or disclosing covered information in violation of the third party's contractual obligations related to handling covered information, CEA shall promptly cease disclosing covered information to such third party. 6.9 Separate authorization by each customer must be obtained for all disclosures of covered information except as provided for herein. 6.10 CEA shall permit customers to cancel authorization for any secondary purpose of their covered information by the same mechanism initially used to grant authorization. 6.11 CEA shall permit the use of aggregated usage data that is removed of all personally-identifiable information to be used for analysis, reporting, or program management, provided that the release of that data does not disclose or reveal specific customer information because of the size of the group, rate classification, or nature of the information. 4 Policy # CEA-04 Barbara Boswell Date Interim Chief Executive Officer 5 Clean Energy Alliance Administrative Policy SUBJECT: EFFECTIVE DATE: Clean Energy Alliance Collections Policy February 20, 2020 POLICY#: SUPERSEDES STAFF CONTACT # OF PAGES: CEA-OS N/A 2 1.0 Purpose To establish a delinquent accounts, collections and write off policy for the Clean Energy Alliance. 2.0 Organizations affected Clean Energy Alliance 3.0 References None 4.0 Definitions 5.0 Policy 5.1 Any CEA customer who has overdue CEA charges that exceeds $250 shown on their SDG&E bill will receive a letter from CEA after 90 days past due, and a second letter at 120 days past due, informing them of their overdue status and the methods available to pay the overdue CEA charges. 5.2 Any overdue CEA charges totaling $20.00 or more which have not been paid by the customer and are no longer being collected by SDG&E may be referred to a collections agency for settlement. 5.3 Any overdue CEA charges totaling $19.99 or less which have not been paid by the customer and are no longer being collected by SDG&E may be considered bad debt and written off. 5.4 Interest will not be charged on any customer account. Policy # CEA-OS 5.5 If a customer has not paid within 180 days following the initiation of the collections process, the collections agency will file credit reporting information on the customer with all applicable agencies. 5.6 The collections agency will be authorized to pursue legal action on any customer with an outstanding balance of $750 or more. 5.7 After a customer has paid all overdue amounts, all collections activity will terminate for that customer. Approved: Barbara Boswell Date Interim Chief Executive Officer 2