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Despite Concerns Regarding Lack of Use In Electric Market, Pa. PUC Orders Gas Utilities To Implement Account Number Look-Up Tool To Assist Shopping

April 10, 2015

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Reporting by Karen Abbott • kabbott@energychoicematters.com

Dismissing concerns raised about the lack of use of the mechanisms since being implemented in the electric market, the Pennsylvania PUC has proposed in a tentative order requiring natural gas utilities to offer a mechanism to allow a retail natural gas supplier to look-up a customer's account number, to facilitate shopping in public settings in which the customer does not have their bill (such as mall kiosks, etc.).

The PUC noted that the electric utilities have provided the following information regarding use of their account look-up mechanisms:

• As of March 22, 2015, PECO had received 35,301 requests to the mechanism from five EGSs

• Since June 1, 2014, PPL's tool has sustained 2,247 queries

• At the FirstEnergy utilities, two EGSs have used the tool to attain 79 successful hits since the mechanism's implementation.

• Duquesne does not have any EGSs registered to use the account number look-up mechanism.

However, the PUC was not convinced such history augurs against adoption of a similar too in the natural gas market.

"While we understand the feedback provided by some of the parties with regard to the costs of the electric account look up tool in comparison to its actual usage, we do not find such an argument to be persuasive. As noted by many of the NGDCs, as well as EAP, the natural gas market is different from the electric market. If a similar mechanism is introduced in the retail gas market, we have no reason to believe it will not outperform that being utilized for electric competition. Moreover, we find that utilizing such a tool for natural gas shopping is even more critical, as we have determined that competition in the natural gas supply market is lagging in Pennsylvania," the PUC said.

"The goal of this Investigation is to determine ways to encourage participation by both suppliers and customers in a robust natural gas supply market while maintaining consumer protections. We believe this tool is a fairly simple and reasonable way to encourage customers to shop for their gas supply. Therefore, we propose that the NGDCs implement a tool similar to that being implemented by the EDCs," the PUC said.

The PUC specifically proposes the natural gas utilities offer a website portal which would allow the retail supplier to look-up a customer's account number upon providing: 1) the customer's full name, 2) service street address and 3) postal code

Supplier must attest that they have authority from the customer, via a letter of authorization or similar mechanism, to look-up the customer's account number

"While we do not propose requiring the LOA to be a separate document and can instead be a part of the enrollment materials, we do expect the LOA to be distinct and prominent. We propose the allowance of telephonic or electronic LOAs, in addition to the use of written LOAs, as long as the NGS can comply with retention and customer identification requirements and that copies can be provided to the customer or Commission upon request," the PUC proposes.

The PUC proposes that the suppliers require that a customer provide government-issued or alternative photo identification (ID), and that suppliers must attest to having been provided with such photo ID when using the mechanism. However, the PUC does not propose that the supplier be required to copy the ID.

As in the electric market, the PUC proposes that natural gas suppliers may only use the account number look-up tool for, "marketing efforts in public venues, such as shopping malls, fairs, trade shows and other community events." The tool would not be permitted to be used in door-to-door sales.

"We would like to make it clear that NGSs should first utilize the ECL [eligible customer list] to obtain customer account numbers. The account number access mechanism proposed herein is intended to be used in public venues to obtain the account number for a customer who has, for whatever reason, opted out of including any or all of their information in the ECL," the PUC said.

Regarding cost recovery for implementation of the tools, the PUC said, "We request that the parties include in their comments proposed mechanisms for the potential allocation and recovery of the costs associated with the account number access mechanism. We will not make a determination as to the reasonableness or prudence of the costs associated with the development, implementation or maintenance of a proposed account number access mechanism through this Tentative Order, however, reasonably and prudently incurred costs would be recoverable and determined by the Commission in a future proceeding."

The PUC proposes that the natural gas utilities be required to have their account number access mechanisms available for suppliers to use no later than August 31, 2016.

Docket M-2015-2468991

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