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Pennsylvania Directs Utilities to Consider Allocating "Fair Share" of Costs of New Account Number Web Portal to Retail Suppliers The Pennsylvania PUC published a written order directing electric utilities to submit compliance plans for the development of a secure web portal allowing customers to access their account numbers remotely (to enable shopping in situations where the customer does not have their bill), and urged utilities to consider allocating a "fair share" of the costs of such portals to retail suppliers.
As noted yesterday, the PUC is requiring the EDCs to develop online, secure web portals which will allow retail suppliers, with customer authorization, to obtain the customer's account number in public marketing situations in which the customer would not normally carry their bill. The PUC declined to allow the seven large EDCs to use interactive voice response systems or other mechanisms in lieu of a secure web portal (though smaller EDCs do not have to immediately comply with the order).
The web portal may only be used to look-up an account number for customers being solicited in a public setting; it cannot be used for door-to-door sales or telemarketing.
"[P]ublic locations are the appropriate venue for the use of the website portal access mechanism," the PUC said, declining a request to make this mechanism available more generally to any marketing other than that used in a public venue (i.e. door-to-door or telephonic solicitations).
The PUC noted that one of the benefits of the program is to remove barriers to the public marketing of retail electric supply, and with such removal it is possible that sales efforts will move away from door-to-door or telephonic methods (which have been controversial) in favor of public marketing efforts, which could enhance the reputation of the market. Allowing the account number look-up tool in non-public marketing channels would be counter to this goal, the PUC said.
EDCs will not be put in the role of policing whether retail suppliers are properly using the secure web portal only for public marketing efforts, however. Retail suppliers will be required to attest to the fact that the enrollment is occurring as a result of a customer-initiated transaction in a public location
The web portal will require the retail supplier to enter the customer's full name, service street address, and postal code (5 digits only) to receive the account number.
The PUC said that the website portal mechanisms should be programmed to provide one of three possible responses – either the customer's account number should be produced; or a "NO HIT" indicating that no data matched the inquiry; or "MULTIPLE HITS" indicating that multiple customer records matched the inquiry. In the case of "NO HIT" or "MULTIPLE HITS," the response should identify the field or fields that caused the search to fail, and an EGS, upon receiving a "NO HIT" or "MULTIPLE HIT" indicator, may resubmit the request for the same customer with corrected information.
The PUC said that EDCs should consider using "wildcards" for street types (allowing variations such as 'Dr' being accepted for 'Drive') unless the EDC can present a compelling reason why this is not feasible.
However, the PUC was less enthusiastic about allowing "wildcards" to be used in the customer name field, though it did not adopt an outright ban on such wildcards in its order and EDCs may justify their use in a compliance plan.
Before accessing the web portal, a supplier must have a signed Letter of Authorization (LOA) from the potential customer that authorizes the supplier to contact the EDC and obtain the customer's account number. The PUC included a form LOA in its order which the supplier's LOA must substantially follow.
"While we are in agreement with NRG that the LOA does not have to be a separate document and can be part of the enrollment materials – we expect the LOA section of the enrollment materials to be distinct and prominent," the PUC said. "We caution all EGSs that any vagueness or ambiguity in the LOA could weigh heavily against an EGS in case of any subsequent dispute. We agree with NEM that the LOA can be in writing, telephonic or electronic, as long as the EGS can comply with retention and customer identification requirements and that copies can be provided to the customer or Commission upon request."
The EDC does not have the responsibility of verifying the existence of an LOA, the PUC said.
Additionally, retail suppliers must verify the identity of the customer before accessing the website portal. "This can be accomplished by having the customer produce one government-issued photo identification. If the customer does not have this available, alternative identification or identifications are permitted as long as one of the identifications has a photo of the customer. The EGS does not have to copy the identification nor retain a copy of the identification. However, the form of identification produced should be documented in a field on the web portal and noted on the LOA" the PUC said.
In their compliance plans, EDCs will submit costs to implement the portals.
"Depending on the level of costs, EDCs should consider having EGSs pay a fair share of the development and maintenance costs for these information sharing systems, given that these systems will be used by EGSs to accommodate their selected marketing model. If the costs justify it, consideration should be given to a user fee structure so that the EGS cost recovery portion is limited to those EGSs that actually use and benefit from the information sharing systems," the PUC said.
The PUC also said that, "the Commission has zero tolerance for violations of customer privacy and confidentiality."
"[A]ny EGS who obtains a customer account number without authorization from the customer and/or uses or discloses an account number inappropriately will be held responsible for such. EGSs will be held fully accountable for any security breach, improper release of data, or any misuse of data. This includes actions by any of its staff, agents, contractors or representatives, pursuant to Commission regulations at 52 Pa. Code § 54.43 (relating to Standards of conduct and disclosure for licensees). Any breach can result in the imposition of civil penalties and the suspension or revocation of their license per Section 54.42 (relating to License suspension; license revocation)," the PUC said.
The PUC said that, in general, the implementation of account access mechanisms should wait until the EDCs have completed any system changes flowing from the Intermediate Work Plan. "However, in no case should the EDC submit a compliance filing as discussed above later than six months from the entry date of this order. The access mechanisms should be in place and operational by the commencement of the 2014 outdoor marketing season; no later than May 2014," the PUC said.
Docket M-2013-2355751
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July 18, 2013
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Reporting by Paul Ring • ring@energychoicematters.com
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