Payment Avoidance by Location (PAL) Protocol


  • a utility receives a new application for service at a service location;

  • a former customer who was disconnected for non-payment at the same service location still resides at the service location; and

  • the utility has proof that the new applicant for service also occupied the service location during the time the previous customer's debt accrued.


  • Payment avoidance by location shall not include new owners and/or new tenants at a service location.


  • When a utility has proof that PAL is occurring, it may require the applicant to provide a deposit under the following conditions:

    1. A deposit required under this Section shall be equal to ⅓ of the estimated annual charges for the premises.

    2. The utility may require payment of the deposit in full prior to service.

    3. The deposit shall earn interest.

    4. The deposit plus interest shall be refunded.

burden of proof

  • It shall be the sole responsibility of the utility to prove with evidence that PAL has occurred. The person accused of PAL shall have the right to the full evidence possessed by the utility and the opportunity to present information to refute the allegations.

NOtification that pal has been invoked:

  • The utility shall..

    • notify the person of the PAL allegation using the same method of contact by which that person contacted the utility.

    • notify the person of the PAL allegation in writing. The written notification may be sent electronically if agreed upon by the utility and the person receiving the notification.

  • The notice shall...

    • be sent no later than two business days after the utility's decision to invoke the protections available to it under this Section.

    • contain a detailed description of the problem and the facts and evidence that the utility has to support the PAL allegation.

    • contain an explanation of the steps that the person must take in order to dispute or remedy the problem.

    • contain the toll free number and contact information for the utility and the toll free number and contact information for the Commission's Consumer Services Division.

  • A duplicate copy of the notice shall be sent to the Commission's Consumer Services Division at the same time it is sent to the person.