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Ohio Staff Make Recommendations on Retail Market Improvements (Instant Connect, Seamless Move, Warm Transfer)

July 17, 2015

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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com

The Public Utilities Commission of Ohio should institute a warm transfer process, but should not move forward with instant connect, seamless moves, or contract portability, PUCO Staff recommended in a retail market improvement report.

"Instant Connect is limited to mercantile customers thus limiting the impact to few customers with considerable system and process changes required as well as a high implementation cost. Contract Portability is limited today as no contract currently allows portability thus all contracts would have to be changed. It is unclear whether the CRES providers would even offer a Contract Portability clause. In addition, customers are not provided education of all their options prior to the transfer. Seamless Move would require the largest degree of system and process changes for the EDUs as well as the most rule changes and may conflict with Ohio contract law," Staff said.

Instant Connect, which is the ability to start CRES generation service on "day one" of new utility service without the customer having to go on the Standard Service Offer (SSO) default service, was not considered for residential and other non-mercantile customers due to the existing 7-day rescission period applicable to such customers. This means the number of eligible customers ranges from only 525 to 1,500 per EDU per year, and the EDUs provided estimates to implement an Instant Connect process per company ranging from $200,000 to $1,500,000

"Based on the high implementation cost and the limited benefit to mercantile customers. Staff is not recommending moving forward with the Instant Connect process at this time," Staff said.

Contract Portability is the ability of a choice customer's contract (terms and conditions) to be applicable to a new service address. Contract Portability relies on a contract provision that allows the customer to apply the terms and conditions of the contract to any premise within an EDU's territory. Unlike a Seamless Move process, neither CRES providers nor the customers receive an opportunity to reject the contract move.

Staff reported that some CRES providers in the working group were not supportive of Contract Portability. "If CRES providers are not willing to incorporate the portability clauses into their contracts, then this option is not viable," Staff said

"Based on the significant difficulty in implementation and the limited support amongst the CRES suppliers and other stakeholders. Staff is not recommending moving forward with Contract Portability," Staff said.

Seamless Move is the ability of a residential choice customer to move their existing contract to a new service address without interruption. A Seamless Move process would allow residential customers to keep their existing contracts and thus maintain their status as a shopping customer assuming the customer and CRES provider accepts the move. The Seamless Move process is different from Contract Portability because the CRES service can start on day one of service with consent from the customer.

The number of residential customers who move varies from 16,000 to 217,000 per EDU territory per year, Staff reported. Taking into account the subset of that customer group actually on competitive supply, Staff reported that the potential annual number of residential Ohio shopping customers eligible for a Seamless Move is 96,244, or 2.2% of all customers.

The high level cost estimates from the EDUs to implement a Seamless Move range from $300,000 to $1,500,000 per EDU

"At this time, staff does not support a Seamless Move program due to the limited number of eligible customers who may agree to remain with their current supplier and contract. Staff notes that the PUCO call center has not seen a demand for a transfer of contracts to a new premise from customers," Staff said.

The only improvement recommended for implementation by Staff was a Warm Transfer process, which is the ability of the EDU to complete a three-way call with the CRES provider and customer to initiate CRES enrollment

Prior to a Warm Transfer the EDU would provide all choice customers with education regarding their supplier options. A workgroup would develop a script for the EDU representative to explain the customer's options, which will include SSO default service, the "Energy Choice Ohio" website, or transfer to their current CRES provider. Warm Transfer allows customers to maintain their status as a CRES customer during a moving situation and educates the customers about all options available in order for the customer to make an informed decision regarding its energy provider, Staff said.

The costs of implementing a Warm Transfer as estimated by two of the EDUs range from $10,000 to $210,000 per EDU, which include IT cost and training of the call center. The upfront costs for a Warm Transfer would be minimal compared to the other three proposals, Staff said.

"The Warm Transfer proposal would be the easiest and least expensive option to implement. All choice customers could take advantage of the process. The estimated timeline for implementation would be 6 months. There would be minimal IT and system changes. There would be no rule change or waivers involved with Warm Transfers. Warm Transfers would encourage customer shopping as well as customer education. Customers would be able to enroll with the EDU and with its current CRES for service at its new service address with one phone call. EDUs are currently performing transfers to third parties and thus have experience with the process. Warm Transfers would require the customer to return to the SSO default service for the first month of electric service. Based on the ease of implementation, low implementation costs, and support by some stakeholders. Staff is recommending moving forward with Warm Transfer," Staff said.

Specifically, Staff said that a statewide operation plan for Warm Transfer would operate as follows:

1. When a customer or a person authorized to act on the customer's behalf contacts the EDU to request new service or new service at a new premise while stopping service at the customer's current premise within the EDU's territory, the EDU shall notify the customer that they may choose to receive their generation from a CRES provider, governmental aggregator, or the default service with the EDU. The EDU shall notify the customer of the "Energy Choice Ohio" website for information on CRES providers' offers.

2. The EDU shall provide the customer all necessary account information to implement a switch.

3. The CRES providers shall ensure that the EDUs have a phone number to reach its customer call center for enrollment purposes. Alternative phone numbers may be provided by the CRES providers to decrease the amount of time an EDU would need to remain on the line.

4. The EDU shall transfer the customer to their CRES provider or governmental aggregator when the customer requests to enroll with a specific CRES provider. The transfer is based upon functionality and limitations of the EDU's network telecom systems.

5. CRES providers are responsible to know if the customer should be enrolled within the same governmental aggregation program.

6. The EDU shall not be required to complete a Warm Transfer if the CRES provider service does not pick-up after 6 rings or the CRES call center representative does not answer the phone call within 30 seconds of connection with the interactive voice response unit.

7. Scripts for the call centers shall be developed by the market development working group (MDWG).

Case No. 14-2074-EL-EDI

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