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PSC Staff: Suppliers Should Be Compelled to Include State's Choice Comparison Site on Certain Ads, Contracts; Site Should Not Include Historic Supplier Prices
Michigan's to-be-developed natural gas choice comparison website should be promoted by alternative natural gas suppliers on certain pre-enrollment marketing materials, and should not include historic supplier price data, according to "primary" recommendations from Michigan PSC Staff.
A working group report concerning the website contains several consensus items regarding the site's design and operation. Two non-consensus items are promotion of the site, and the posting of historic prices on the site.
Concerning site promotion, Staff, in a "primary recommendation," said that an alternative gas supplier should be required to list the site's address, "in its contracts and on any printed advertising flyers, handouts and direct mailers for residential and small commercial customers. (Excludes: radio, TV ads, billboards, telemarketing and door-to-door marketing scripts, confirmation letters, TPV scripts, and AGSs website, social media or texts)"
Staff said that its primary recommendation, "would require pre-sale disclosure of the website which will help customers make an informed decision."
Staff opposes utility recommendations which included post-sale references to the site on confirmation letters. "Staff fears that post-sale references on enrollment materials would lead to customer confusion and customer complaints."
However, Staff also offered a "secondary recommendation" under which AGSs would be required to reference the site in residential and small commercial contracts, but not ads.
Staff said that it is neutral to any recommendation that would require (a) an AGS to reference the Compare MI Gas website on the AGSs website or (b) a utility company to reference the website on the customer bill or as a bill insert.
Regarding the posting of historic prices on the shopping website, Staff's primary recommendation is that only 12-month historical GCR information for each individual utility is posted, with no historic AGS prices included.
Staff noted that after launching the new Ohio Apples to Apples site without historical information, "the PUCO received feedback asking for this information. Subsequent to those requests, the PUCO incorporated the historical information into their website."
However, Staff's secondary recommendations regarding historic pricing data are either:
(a) Posting historic GCR data plus snapshots of the Compare MI Gas website AGS offers would be used to populate historical information going forward. "This would involve Staff saving and posting a snapshot of the actual Compare MI Gas website at least quarterly, dating back 24-months. This would allow customers to have access to historical information, and to do so in the same format as they are reviewing current offers," Staff said.
(b) Posting no historical data for AGSs or any utility company
Consensus items regarding the shopping comparison site include a recommendation, "that any AGS that is actively marketing and/or enrolling customers will be required to submit pricing information for the website."
Another consensus recommendation is that, "each AGS be allowed to post up to five offers per offer type within each utility service territory."
Participants reached consensus that, "AGSs [should] be allowed to offer products in the marketplace that reflect lower prices than those posted on the website, but in no instance be allowed to offer products in the marketplace that reflect higher prices than those currently posted on the website."
Case No. U-17580
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July 24, 2014
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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com
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