ComEd Seeks Approval to Provide Customer Account Numbers of Shopping Customers to Government Aggregators November 1, 2012 Email This Story Copyright 2010-12 Energy Choice Matters
Commonwealth Edison has petitioned the Illinois Commerce Commission for expedited approval of modifications to ComEd's Rate GAP – Government Aggregation Protocols (Rate GAP), including the provision of the account numbers of customers already on competitive supply to government aggregators.
ComEd's Rate GAP defines the circumstances when, and the terms and conditions under which, ComEd provides retail customer data to a Governmental Authority to allow the Governmental Authority to aggregate retail customer electric power and energy requirements in accordance with Section 1-92 of the IPA Act.
In defining ComEd's obligations, Rate GAP establishes a two-step process for providing the information. First, Rate GAP requires ComEd to provide the names and addresses of residential and small commercial retail customers in the aggregated area at the request of the Governmental Authority. Second, ComEd later provides the account numbers of those applicable customers who have not opted out of an aggregation program or are identified as receiving service from a retail electric supplier (RES) or are supplied under ComEd Rate BESH—Basic Electric Service Hourly Pricing (Rate BESH).
The list of account numbers is provided separately without the associated customer names and addresses in order to help preserve the privacy of customer specific data, because an account number is all that is required to access historic customer-specific usage data on ComEd's website. Furthermore, the account number is the only information that is required to enable a customer to be switched from one supplier to another. Therefore, while the list of names and addresses is organized in a manner to help the Government Authority identify which customers have already affirmatively selected an alternative to ComEd's default fixed-price supply service and address such customers accordingly for proper notification as required under Section 1-92, the list of account numbers provided to the Governmental Authority is limited to those of customers that are not taking service from a RES in order to help avoid disrupting existing supply arrangements and avoid unnecessary release of these account numbers.
Based on stakeholder comments, "ComEd understands that it would increase operational efficiencies if this two-step process were collapsed into a one-step process, whereby all names and addresses and the corresponding account numbers of such customers are provided in a single list, including those of customers that are served by a RES or under ComEd's Rate BESH". ComEd has thus proposed tariff changes to implement such a one-step process
Furthermore, "it is believed that a Governmental Authority and its associated RES could handle the transition process in subsequent aggregation rounds while maintaining customer confidentiality," ComEd said.
ComEd also proposes to delete Rate GAP's provision that the Governmental Authority require the RES (or a participating entity) to delete and destroy customer-specific information within 60 days after the information is provided. "Although this provision was agreed to and uncontested in the Rate GAP investigation, ComEd understands that it presents a conflict for the Governmental Authority and its ability to work with RESs and participating entities to administer municipal aggregation programs and conduct a second round of aggregation," ComEd said.
ComEd's proposed revisions to Rate GAP also include adding appropriate references to township boards, reflecting recent legislation granting townships the same aggregation authority as other municipalities.