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Pennsylvania Issues Proposal to Address Different Renewal Notice Timelines for Customers Receiving Electric, Gas Service from Same Supplier
The Pennsylvania PUC has issued a tentative order to address the timing differences under the PUC's rules for the issuance of electric contract renewal notices and natural gas renewal notices, which are now no longer aligned as the PUC moved to accelerate electric customer switching.
As first reported by EnergyChoiceMatters.com, the timing issue was raised by NRG Energy's Independence Energy Group LLC d/b/a Energy Rewards (the brand used for the current trial offers to certain Comcast customers), which told the PUC that it intended to offer combined electricity and natural gas products, but that it was concerned about the different timing required for renewal notices for each commodity
Specifically, Energy Rewards said that the notice provisions for natural gas in 52 Pa. Code § 62.75.(g)(1) require two notices to be sent -- one at 90 days and the second at 60 days -- prior to the expiration of a natural gas contract to explain the customer's contract renewal options.
In contrast, the Commission's recently adopted electricity rules in docket L-2014-2409385 (52 Pa. Code § 54.10.(a)(1) and (2)) require an initial notice to be sent 45-60 days prior to an electric contract expiration and an options notice to be sent at least 30 days prior to contract expiration.
Energy Rewards raised concern that issuing four notices to bundled electric/gas customers may create confusion.
In its tentative order, the PUC agrees with the problem identified by Energy Rewards, and would allow suppliers serving electric and gas customers whose contract expire within 30 days of each other to follow the natural gas renewal notice timeline, but stressed that all other aspects of the recently adopted renewal rules for electricity (52 Pa Code §§ 54.5 and 54.10) must still be applied.
The PUC said that it proposes to adopt the longer gas renewal timeline for such combined gas/electric customers because gas switching has not been accelerated, and the new, shorter electric renewal notice timelines would not give gas customers sufficient notice to switch given this longer switching process.
"[W]e emphasize that the other provisions of the relevant electric regulation, 52 Pa Code § 54.10, still apply," despite the use of the gas renewal timelines, the PUC said. "This means that when presenting notice information for the customer’s electric generation service, the contents of the notice and how the customer’s non-response is treated, must comply with Section 54.10. We acknowledge that this means that the customer will have certain rights regarding their electric service that technically do not apply to their natural gas service. To maintain consistency and minimize customer confusion, we recommend the following: if a supplier wants to make the terms of the customer’s electric and natural gas service more similar, the supplier is free to provide the customer with the same rights for the natural gas service that apply to the electric service (generally, it is acceptable to provide a customer with a greater level of protection than required by a regulation – it is not acceptable to provide a lesser level of protection than required)."
"We also note that this guidance is the same regardless of whether the customer receives both electric and gas distribution service form [sic] the same utility or two different utilities. In instances where natural gas and electric service is distributed by two different utilities, it is very unlikely that the customer’s electric and gas expiration dates will align. In the notices, suppliers are obligated to clearly communicate the differing expiration dates for each service. The two notices, initial and options, must always be provided as the contract nears expiration, regardless if terms and conditions are changing. The notices need to clearly make the needed distinctions between the prices and terms of the customer’s electric service and their natural gas service," the PUC said.
Docket L-2014-2409385
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July 10, 2014
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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com
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