Customer Complaint Procedure

1. Purpose

Before enrolling Customers, Power Financial Services LLC (“Power Financial Services”) will publish and provide this procedure to explain how a Customer can file a complaint regarding: (i) Demand Response (“DR”) services, (ii) event participation, (iii) incentives/compensation, (iv) enrollment/termination, (v) customer support, and (vi) privacy and the handling of Customer information.

2. Scope

This procedure applies to all Customers receiving DR-related services from Power Financial Services, including services where Power Financial Services operates as a Distributed Generator / DR service provider and interfaces with program administrators and/or LUMA for event dispatch, measurement, settlement, and incentive processing.

3. Key Definitions

• Complaint / Grievance: Any Customer allegation of error, unfairness, delay, miscalculation, misconduct, service failure, or rights violation connected to Power Financial Services DR services or compensation.
• Determination: Power Financial Services’ written decision resolving a Complaint.
• Business Day: Monday–Friday, excluding Puerto Rico legal holidays.
• Customer Information: Private, personal, confidential, or proprietary information, including usage data, battery/DER data, contact information, identifiers, and any data covered by contract, privacy policy, or applicable law.

4. How Customers File a Complaint with Power Financial Services

4.1 Where to Submit

Power Financial Services will accept complaints through any of the following channels and will publish the current contact details on its website and enrollment materials:

1. Email
2. Phone
3. Online Form
4. Mail/In-Person

4.2 Time Period to Submit

Customers should submit a complaint within thirty (30) calendar days of whichever occurs later:

• The DR event / service issue; or
• The date the Customer receives the relevant compensation statement, report, or notice.

If the issue involves privacy/data disclosure, the Customer should submit the complaint as soon as they become aware of the concern.

4.3 What the Complaint Should Include

• Customer name, service address, and account ID or enrollment reference.
• Preferred contact method.
• A clear description of the issue, including what happened, dates/times, and relevant DR event if known.
• The requested resolution, such as recalculation, payment correction, opt-out, termination, or data deletion.
• Any supporting documents, including screenshots, emails, settlement/incentive statements, or related records.

5. Intake, Tracking, and Acknowledgement

5.1 Case Number and Acknowledgement

• Power Financial Services will log each complaint and assign a case number.
• Power Financial Services will acknowledge receipt within seven (7) Business Days, confirming:
  • Case number.
  • Summary of the complaint.
  • Next steps and expected timeline.
  • Any immediate information needed.

5.2 Urgent Issues

If a complaint alleges:

• Imminent safety risk, equipment hazard, or emergency conditions, the Customer should contact 911 and/or the relevant utility emergency channels immediately.

6. Investigation Process

Power Financial Services will investigate by using information reasonably necessary to resolve the issue, which may include:

• Enrollment records and customer authorizations.
• DR event logs, notifications, and opt-out records.
• Metering/telemetry/battery dispatch records, as applicable.
• Incentive calculations, settlement records, and payment history.
• Communications history, including calls, emails, and messages.

Power Financial Services may contact the Customer for clarification and may request additional documentation. Power Financial Services will keep the Customer reasonably updated if the investigation is delayed.

7. Resolution Timelines

7.1 Standard Resolution Timeline

• Power Financial Services will issue a written Determination within fifteen (15) Business Days after acknowledgement.

7.2 Extended Timeline for Complex Cases

If more time is needed, such as third-party data dependencies, settlement disputes, or measurement issues, Power Financial Services may extend up to thirty (30) Business Days, but must:

• Notify the Customer before day 15.
• Explain why more time is needed.
• Provide a revised expected decision date.

7.3 Payment/Compensation Corrections

If the complaint concerns compensation:

• Power Financial Services will provide the Customer, in plain language, the basis for the calculation, including events included, measurement approach used, any adjustments, and payment timing.
• If Power Financial Services finds an error, Power Financial Services will correct it and issue any owed amount as soon as administratively feasible, typically in the next payment cycle or earlier when practicable.

8. Written Determination

Power Financial Services’ Determination will be provided by email or mail and will include:

• Case number and summary of the complaint.
• Findings and supporting explanation.
• The outcome: approved, denied, or partially approved.
• Corrective actions, if any, including payment correction details and timing.

8.1 Reconsideration

If dissatisfied, the Customer may request reconsideration by submitting a short written request:

• Deadline: Within ten (10) Business Days of the Determination date.
• Required content: What part of the Determination is disputed and why; attach any new evidence.

Power Financial Services will issue a Final Determination on reconsideration within ten (10) Business Days of receiving the reconsideration request, or will provide an updated timeline if the matter is complex.

The Customer has the right to escalate to the Puerto Rico Energy Bureau (PREB) for review under Regulation 8543.

9. External Escalation: OIPC and PREB Contact Information

9.1 Independent Consumer Protection Office (OIPC)

Customers may contact the Oficina Independiente de Protección al Consumidor (OIPC) for guidance:

9.2 Puerto Rico Energy Bureau (PREB / NEPR)

Customers may contact the Puerto Rico Energy Bureau:

10. Right to File with PREB for Review Under Regulation 8543

Any Customer dissatisfied with Power Financial Services’ Determination or Final Determination may file a complaint/claim with the Puerto Rico Energy Bureau for review pursuant to Regulation 8543.

• Regulation 8543 provides that a claim requesting review of a final decision by an electric service company must be presented within thirty (30) days from the date the company issued its final decision.
• Regulation 8543 also states that claims before the Commission are filed via its electronic filing system, subject to the Bureau’s instructions.

11. Recordkeeping and Non-Retaliation

• Power Financial Services will maintain complaint files, including intake, evidence, correspondence, Determinations, and payment corrections, for a reasonable retention period consistent with program and regulatory expectations, and will provide them to PREB upon lawful request.
• Power Financial Services will not retaliate or discriminate against any Customer for filing a complaint with Power Financial Services, OIPC, or PREB.