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PUC Adopts Account Number Look-Up Tool For Natural Gas Market, Sees "Merit" in Allocation Implementation Costs to Suppliers

July 9, 2015

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Reporting by Karen Abbott • kabbott@energychoicematters.com

The Pennsylvania PUC has ordered that the large natural gas distribution companies implement natural gas account number look-up tools to facilitate customer shopping in public venues where customers do not have their bill and account number readily available, similar to mechanisms recently introduced in the electric market.

Despite the lack of use of the account number look-up tools in the electric market (click here for story), the PUC ordered implementation in the natural gas market, noting the differences in the markets and the much lower levels of natural gas migration in the mass market

"Accordingly, we believe a natural gas mechanism could prove to be even more beneficial than the current mechanism in the electric market," the PUC said.

The account number look-up tool may only be used by suppliers marketing in public venues, such as malls, trade shows, and community events, as the PUC tries to encourage suppliers to rely more on such marketing channels with which customers are more comfortable. The tools may not be used in door-to-door sales

"[W]e continue to find it inappropriate to extend the use of the account number access mechanisms beyond their use in public venues, such as shopping malls or fairs. This Commission strongly encourages suppliers utilizing marketing avenues that make customers comfortable with the competitive marketplace. These avenues include the use of public shopping malls, fairs and trade shows because, as the OCA noted, customers frequently are the ones to initiate the transaction," the PUC said

"Furthermore, we do not think it is appropriate to expand the mechanism at a time when door-to-door marketing is on the rise and complaints against energy suppliers are high in nearby jurisdictions," the PUC said.

The PUC further emphasized that suppliers should first utilize the eligible customer list (ECL) to obtain customer account numbers. The account number look-up mechanism, "is intended to be used in public venues to obtain the account number for a customer who has opted out of including any or all of their information in the ECL," the PUC said.

The PUC noted several of the electric utilities reported that more than half of the account numbers obtained through their account number look-up tools were already available on the ECL.

"The Commission will continue to monitor this issue to ensure that the mechanisms are being used in the manner intended," the PUC said.

"We reiterate this Commission’s zero tolerance policy for violations of customer privacy and customer information confidentiality requirements. We stress that any NGS who obtains, uses or discloses a customer account number without customer authorization will be held responsible. Any breach can result in the imposition of civil penalties and the suspension or revocation of the supplier’s license. See 52 Pa. Code §§ 62.113 (relating to license suspension; license revocation) and 62.114 (relating to standards of conduct and disclosure for licensees)," the PUC said.

The PUC did not adopt a final mechanism for cost recovery of the account number look-up tools in its order.

"However, we do see merit in PECO’s proposal, which allocates 50% of the costs to suppliers," the PUC said.

"We encourage the NGDCs to consider, in providing proposed mechanisms within their compliance plans, the possible sharing of the costs with the supplier community," the PUC said.

The PUC noted that when allocating costs to suppliers, splitting costs between POR for supplier costs and the default service rate for costs allocated to customers may not always be appropriate because: 1) POR programs are not in place at all natural gas utilities, 2) there may be no supplier participation in the residential and/or small commercial marketplace, or 3) allocating costs to suppliers in a territory where there currently exists no supplier participation could further deter suppliers from entering that particular market.

Natural gas utilities were directed to implement account number access mechanisms no later than August 31, 2016

Natural gas utilities shall offer a website portal which will 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

The PUC did not mandate that utilities use "wildcard" and/or drop-down box functionalities, which suppliers have said will aid in returning meaningful results from the tool

"[A]s we noted on the electric side, we have concerns about possible effects on customer privacy and protections, especially with the use of wildcards. Accordingly, we will not require the inclusion of these functionalities at this time," the PUC said.

Suppliers must attest that they have obtained a signed letter of authorization from the customer when using the tool. It is not the responsibility of the utilities to monitor and confirm that an NGS has obtained a customer-signed LOA, and utilities may not require suppliers to submit an LOA to the utility, the PUC said. Suppliers must maintain LOAs for at least three years

The LOA must meet the following requirements:

• Must be in plain language and a reasonably-sized font.

• Must be headlined or titled by language telling the customer that it is a document to be used to obtain the customer’s account number. This headlining and plain language must then be repeated and explained further near the signature line.

• Must include the customer’s name and service street address.

• Must be distinct and prominent, but does not have to be a separate document.

LOAs must be in paper or electronic (computer or tablet) format; telephonic LOAs may not be used.

"We also agree with the concerns expressed by Columbia and OCA regarding the use of telephonic LOAs for the mechanism. While we recognize that suppliers frequently use telephonic LOAs when enrolling customers, we believe this is unnecessary for the mechanism attestation as the customer enrollment is being done in person in a public venue. The customer is available in person to review the LOA and provide a handwritten or electronic (in the case of computer or tablet use for LOAs) signature," the PUC said.

Suppliers must attest that the customer has provided a government-issued photo ID or an alternative form of identification that includes the customer’s photograph before querying the account number look-up mechanism. The NGSs do not have to copy the identification; however, the form of ID provided must be documented in a field on the web portal and on the LOA. Due to the sensitivity of recording a customer’s driver’s license number, that information will not be required to be copied

The account look-up mechanism is intended for the residential or small commercial customers.

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