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PSC Staff Recommend Change in Utility Enrollment Letter to Reflect Customers Assignment, Suggest Generic Investigation
Staff of the Maryland PSC have recommended that the Commission direct Baltimore Gas & Electric to change the language of a customer notice triggered by a change in a customer's electric supplier which currently is written as if the change is a new enrollment, but is still being produced and sent in cases of the assignment of existing customer contracts from one supplier to another.
As only reported by EnergyChoiceMatters.com, NRG Residential Solutions has asked that BGE be directed to not send the enrollment letter to electric customers it is acquiring from Dominion Retail, citing the confusion and resulting increased attrition the notice would create, as these customers have not recently selected a new supplier.
While Staff is not opposed to granting NRG's request to suppress the letter, Staff's preferred recommendation is that the Commission require BGE to modify its notice to customers to accurately reflect the assignment of those customers to NRG.
As described by Staff:
"NRG is concerned that if BGE sends a Notice of Enrollment to the customers assigned to NRG by Dominion, BGE's Notice will cause customer confusion, which may result in relatively high rates of contract cancellation, and diminish the value of the assigned accounts. NRG cites tests it conducted in Pennsylvania, which found that customers who received a notice of new supplier from their utility were substantially more likely to cancel their supply contracts than customers who did not receive such a notice. NRG also argues that COMAR does not require a Notice of Enrollment for customers who are assigned from one supplier to another, because the relevant provisions only address the situation where a customer enters into a new agreement. Upon reviewing the relevant COMAR sections, Staff concurs with NRG's opinion that COMAR does not require the utility to send a Notice of Enrollment to customers whose supplier has changed as a result of the assignment of those customers from one supplier to another. In the current instance, the affected customers have not entered into an agreement, but have only had their existing agreement assigned to a new supplier."
Staff continues:
"The filing includes a sample of the New Enrollment Letters BGE sends to customers who have entered into new agreements with suppliers. Staff has reviewed this letter. The letter is appropriate for a situation where a customer has entered into a new supply agreement, but it could very easily cause customer confusion in a situation where the customer's contract has been transferred to a new supplier via assignment. The letter is essentially an unembellished statement that BGE has received notice that X is the customer's new supplier. In a situation where a customer has not taken affirmative action to change suppliers, this could easily lead a customer to think that they have been slammed."
"Staff would not object to the Commission granting NRG's request. However, Staff notes that the filing's sample notice from Dominion and NRG to the affected customers states that they will receive confirmation from BGE. Moreover, as a general matter, Staff prefers that customers be provided with more relevant and accurate information than less," Staff said.
Staff suggested including the following modified language on the letters:
"BGE has received notification that Dominion Energy Solutions, your current electricity supplier, is discontinuing service in Maryland and has assigned your account to NRG Residential Solutions."
"Our records indicate that you will continue to receive one bill from BGE that will show both your electric generation supplier's and BGE's charges."
"You should already have received notification from Dominion Energy Solutions and NRG Residential Solutions regarding the assignment of your electricity supply contract. You do not need to take any action as a result of this change. If you have a question or concerns about the assignment, please contact NRG Residential Solutions at 1-855-500-8703."
Finally, Staff noted that this situation is likely to recur with some frequency. "The Commission may want to consider the appropriate notifications as a generic issue, possibly in the context of the ongoing PC 35 on consumer protection," Staff suggested
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July 7, 2014
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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com
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