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Pennsylvania Issues Final Guidance on Renewal Notice Requirements Applicable to Customers With Dual Fuel Contracts

October 3, 2014

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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com

The Pennsylvania PUC has issued a final order providing guidance to retail electric and natural gas suppliers regarding the renewal notices required to be sent to customers taking both gas and electric service from the same supplier, given that recent changes to the electric notice rules mean the timelines now vary by commodity.

The notice provisions for natural gas under 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

Agreeing that sending four notices to dual fuel customers may create confusion, the PUC has provided guidance, as outlined below, allowing suppliers to use the longer gas renewal timelines for certain dual fuel customers.

Specifically, in instances where a customer is receiving both electric generation and natural gas supply service from the same competitive supplier and the terms for both services expire within 30 days of each other, the PUC said that:

• It is acceptable to send two contract expiration notices that address both services. The timing of the two notices shall, at a minimum, comply with the timeframes found in the natural gas disclosure regulations at 52 Pa. Code §62.75(g)(1) — one at 90 days and the second at 60 days.

• The notices must clearly make the needed distinctions between the prices and conditions of their electric service and their natural gas service.

• All other aspects of the electric regulations at 52 Pa. Code §§ 54.5 and 54.10 must be applied to the customer’s electric generation service. It is acceptable for suppliers to provide their gas customers with the additional protections found in these electric rules.

• The guidance is limited to circumstances in which a customer contracts for both electric and gas services from one supplier at the same time under contracts that expire within 30 days of each other.

• Suppliers retain the option of providing the four separate notices contemplated by the existing rules if they so choose: two per the natural gas regulations and two per the electric regulations.

The PUC noted that it is examining harmonizing the electric and gas renewal notice requirements in its natural gas retail market investigation.

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