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California AB 1945: New notice and contact rules before municipal utility shutoffs

Imposes multi-step timing, contact, and notice-content requirements for municipal utility districts before terminating residential service — with special rules for seniors and dependent adults.

The Brief

AB 1945 prevents municipal utility districts from cutting off residential light, heat, water, or power without following a specified notice and contact regimen. The bill prescribes when and how mailed notices must be sent, requires attempted telephone or in-person contact shortly before termination, mandates specific content in termination notices, and creates a voluntary third-party notification option for customers 65 and older and dependent adults.

For municipal utilities and their compliance teams, the bill means changes to billing timelines and recordkeeping, new scripts and outreach procedures for pre-termination contact, standardized notice content (including amortization and assistance options), and an obligation to restore any service wrongfully terminated without a restoration fee. Smaller districts get limited flexibility to use electronic-only notices by customer choice.

These mechanics will affect collections practices, vendor contracts, and customer-assistance workflows.

At a Glance

What It Does

Requires municipal utility districts to follow a specific mailed-notice timeline, attempt live contact before shutoff, include enumerated information in termination notices (amount due, payment deadline, amortization and financial-assistance options, complaint procedures, contact number), and offer a third-party notification option for seniors and dependent adults. It also forbids termination without compliance and requires free restoration when termination is wrongful.

Who It Affects

California municipal utility districts that furnish light, heat, water, or power; residential customers billed by those districts (with special provisions for customers 65+ and dependent adults); billing and collections vendors under contract with districts.

Why It Matters

The bill shifts operational timelines for collections, increases upfront outreach and documentation duties for districts, and creates targeted protections for vulnerable households that can reduce sudden utility loss. Compliance officers will need to update billing systems, notice templates, and field staff procedures.

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What This Bill Actually Does

AB 1945 sets a multi-step pre-termination process municipal utility districts must follow before disconnecting residential service for nonpayment. At its core the bill ties the mailed termination notice to the district’s billing date and delays the start of the 10-day cure period until five days after that mailed notice — a sequencing rule that extends the minimum time between a bill and possible shutoff.

The bill also requires districts to attempt live telephone or in-person contact at least 24 hours before any scheduled termination and, if that attempt fails, to provide a separate mailed, in-person, or posted notice at least 48 hours before shutoff.

The bill prescribes what termination notices must say. For the longer mailed notice it enumerates customer name and address, the delinquent amount, the deadline to avoid termination, how to request amortization of arrears, guidance about financial-assistance sources, and a district contact number; short-notice contacts must include a subset of that information.

All written notices must be clear and legible. For older adults and dependent adults, districts must offer a third-party notification service: customers opt in on a district form and supply written consent from the designee; the designee gets alerted when an account is past due, but that designee does not assume payment responsibility nor does the notification delay termination.If a customer breaks an amortization agreement, the district cannot immediately disconnect; it must provide at least 48 hours’ written notice specifying the conditions the customer must meet to avoid service loss, but it need not reopen any further investigation into the account.

The bill further requires districts to restore any service wrongfully terminated without charging for restoration and to mail a notice to the customer documenting the restoration. Finally, districts that serve fewer than 100,000 customers may — with customer consent — deliver required notices exclusively by electronic mail, text, app notification, or another electronic method, and the bill excludes customers on prepay programs from these rules.

The Five Things You Need to Know

1

The bill delays the start of the 10-day cure period until five days after the mailed termination notice, and it bars mailing that notice earlier than 19 days after the district’s bill — creating a multi-week minimum before shutoff.

2

Districts must make a reasonable attempt at telephone or personal contact at least 24 hours before termination; if contact fails, they must provide a mailed, in-person, or posted notice at least 48 hours before disconnecting.

3

Third-party notification is available only to customers age 65+ or dependent adults and requires the customer’s request on a district form plus the designated person’s written consent; the designee is not liable for charges and the service does not stop termination.

4

If a customer violates an amortization agreement, the district must give at least 48 hours’ notice of the conditions required to avoid termination, but the customer does not gain an entitlement to a new investigation of charges.

5

A district that wrongfully terminates service must restore it without charging a reconnection fee and must mail a notice documenting the restoration; districts under 100,000 customers may allow customers to opt into electronic-only notices.

Section-by-Section Breakdown

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Section 12823.1(a)

Mailed notice timing and deferred 10‑day cure period

This paragraph ties the mailed termination notice to the district’s bill schedule and delays the effective start of the 10-day cure window until five calendar days after the notice is mailed, and it forbids mailing the notice earlier than 19 days from the billing date. Practically, compliance teams must calculate the earliest possible shutoff date for each account and adjust bill runs and notice mailings to meet this sequencing rule; billing systems must log mailing dates and compute cure-period start dates to defend against wrongful-termination claims.

Section 12823.1(b)

Live contact requirement and fallback notice timing

The district must try to reach an adult at the premises by phone or in person at least 24 hours before disconnection. If a live contact isn’t possible, the district must deliver a notice by mail, in person, or by conspicuously posting it at the premises at least 48 hours before termination. This creates a field‑operations obligation for technicians and contractors and a script/recordkeeping requirement for contact attempts; vendors who perform collections or field disconnections will need written protocols and proof-of-attempt records.

Section 12823.1(c)

Third‑party notification for seniors and dependent adults

Districts must offer an opt‑in third‑party alert service for residential customers age 65 and older and for dependent adults. The customer must sign a district form and obtain written consent from the designee. The notification is informational only — it neither shifts payment liability nor halts termination — so districts must maintain the consent form and the opt‑in registry while ensuring notices are sent promptly when accounts become delinquent.

2 more sections
Section 12823.1(d)–(e)

Mandatory notice content and amortization‑agreement handling

The bill lists the specific items a termination notice must contain (customer ID, delinquent amount, cure date, how to request amortization, where to find financial assistance information, and a district contact number) and requires shorter pre‑termination notices to include a subset of those elements. If a customer defaults on an amortization plan the district must still provide a 48‑hour notice identifying the conditions to avoid shutoff, but the defaulting customer does not gain an automatic right to additional account review — a rule that limits re-litigation of already‑approved payment plans.

Section 12823.1(f)–(h)

Restoration, electronic notice option, and prepay exclusion

Districts must restore service without a restoration charge if they wrongfully terminate and mail a notice documenting restoration. Districts serving fewer than 100,000 customers may offer customers an electronic‑only notice option (email, text, app) when the customer specifies that method. The section also clarifies that customers on prepay programs are not covered by these notice and contact rules, so districts will handle prepay accounts under the separate statutory framework.

At scale

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Older adults (65+) and dependent adults — Gain an opt‑in third‑party alert and longer, clearer notice opportunities that reduce the risk of sudden disconnection and give caregivers time to intervene.
  • Residential customers generally — Receive standardized, legible notices that explain amortization and assistance options and a guaranteed pre‑termination contact attempt, reducing surprise shutoffs.
  • Consumer and legal-aid advocates — Obtain clearer procedural hooks to challenge wrongful terminations because the bill creates definable notice and contact thresholds and mandates free restoration where those thresholds aren’t met.

Who Bears the Cost

  • Municipal utility districts — Must update billing calendars, notice templates, and IT logic to compute the delayed cure period; add staffing or vendor oversight for phone/in‑person contact attempts and recordkeeping.
  • Collections and field service contractors — Face new protocols, proof-of-contact requirements, and potential scheduling changes that increase labor time per shutoff attempt.
  • Ratepayers/taxpayers in small districts — May ultimately absorb higher administrative costs if districts increase staffing or shift collection costs, particularly where districts opt to provide expanded outreach or maintain third‑party notification registries.

Key Issues

The Core Tension

AB 1945 balances preventing sudden, harmful residential utility shutoffs — especially for seniors and dependent adults — against imposing new timing, outreach, and documentation duties on municipal utilities; the central trade‑off is between stronger consumer safeguards and the operational and fiscal burden those safeguards place on districts and their vendors.

The bill introduces operational precision but leaves several practical questions open. The timing language — prohibiting mailing the notice earlier than 19 days after the bill and then delaying the 10‑day cure period until five days after that mailing — creates a nonintuitive minimum interval before termination; utilities will need clear guidance and system updates to compute those dates accurately. "Make a reasonable attempt" to contact an adult at the premises is a flexible standard that will require administrative definitions (number of phone attempts, acceptable time windows, how to document door knocks) to avoid disputes.

The third‑party notification option protects vulnerable customers but raises privacy and recordkeeping obligations (consent forms, opt‑out procedures, timely transmission of alerts) without providing funding for implementation.

The bill also tightens protections in ways that can increase collection costs or delay recoveries. Requiring paid restoration for wrongful terminations creates a financial exposure for districts, and the requirement to include amortization and assistance information may increase calls to district help lines — all predictable administrative burdens.

Finally, excluding prepay program participants leaves a class of customers without these procedural protections; districts and advocates may clash over which customers should be covered and how the differences affect equity of access to utility service.

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