Energy Choice
                            

Matters

Draft Would Modify Customer Notice Communication, Rescission Methods Required From Suppliers, Also Change Start Date Notice Requirement

December 2, 2015

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

The Connecticut PURA issued a draft decision which would, among other things, modify the communication methods retail suppliers are required to offer to customers for receipt of various notices, and the mechanisms through which suppliers must accept rescissions

As previously reported, in the November 2014 decision, PURA ruled that retail suppliers must offer customers the ability to select to receive certain statutorily required notices from the supplier through all of the following methods: (1) United States mail, (2) electronic mail, (3) text message, (4) an application on a cellular telephone, and (5) a third-party notification service, which has been submitted to the Authority for approval.

Retail suppliers had argued that PURA erred in interpreting the statutory language in requiring suppliers to offer customers a choice from all five of the listed methods

The new draft would find that suppliers must still offer customers a choice of communication methods, but would modify the requirement such that suppliers would only be required to offer a choice from at least the following two methods of notification: (a) United States mail, and (b) electronic mail. U.S. mail would be the default method of notification if a customer fails to make a selection.

Suppliers may offer additional options to distinguish themselves in the retail marketplace. Customers would continue to have the option to change the method of notification at any time during their contract, the draft provides

The draft emphasizes that, "Conn. Gen. Stat. § 16-245o(g)(1) expressly states that a customer will have the option to change between multiple notification methods and that the customer will be allowed to change his notification method at any time [emphasis by PURA]. An examination of the legislative history shows that the Legislature intended retail electric customers to have a choice in how they communicate with their supplier."

"The Authority recognizes that not all suppliers offer the other notification methods described in the statute (cellular telephone applications, text messaging or third-party notification systems) which all have underlying development and support costs. The cost of requiring multiple communication methods must be weighed against the potential benefit and customer demand for them. It is unclear whether there is enough consumer interest to warrant requiring each licensed electric supplier to incur costs to make all options available. To strike a balance, the Authority will require that suppliers offer customers a choice between receipt of notification by either U.S. Mail or email. In addition, the Authority will modify its order regarding customer choice of notification method be exclusively in writing," the draft states

Additionally, the draft would permit suppliers to use a Mobile Web Interface (MWI) as a customer notification in lieu of a cell phone app, "so long as each MWI accomplishes the same goal of unique and secure individual customer notifications."

"However, the Authority will require that any method of providing required notification allow for direct two-way communication between the customer and the supplier. Communication only from the supplier to the customer via a particular method might confuse market participants," the draft states

Similarly, the draft would eliminate PURA's prior order that mass market customers must be able to rescind a contract via all of the following methods: email, text, telephone, and United States mail.

"[T]he Authority will not require suppliers to implement the four methods outlined above as options to cancel [rescind] their contract," the draft states, but would require suppliers to accept rescissions through any method through which they provide statutorily required customer notices.

"[A]ll licensed electric suppliers must allow customers to cancel [rescind] service through the same communication method by which they provide required customer notifications," the draft states

"Suppliers may offer text messaging or other methods as alternatives, but will not be required to do so," the draft states

Moreover, "if a supplier provides a notification to its customer through text messaging, its customers should reasonably expect to cancel service through the same means ... Suppliers must make all reasonable efforts to avoid potential confusion, and should not offer text messaging unless they can send and receive communications through this method," the draft states

The draft would also modify the prior directive that each Connecticut supplier, "maintain its own website," such that Connecticut-specific pages on a supplier's national or parent website would now meet this requirement

"[T]he Authority finds that licensed electric suppliers can fulfill the [website] requirements of Conn. Gen. Stat. §16-245(g)(14) by providing Connecticut-specific information through one or more pages within a parent or multi-state website. Through customer selection, zip code filtering, or some other method, supplier must make Connecticut-specific and Connecticut-only information available to the customer," the draft states

"The supplier must construct their page to display Connecticut-specific information, and not information from other states, to Connecticut customers. Suppliers may do this through customer self-selection, zip code filtering, or other best practices adopted by the market," the draft emphasizes

"The Authority notes that customers accessing multi-state websites may be confused if search features are not properly implemented or if the supplier does not maintain the Connecticut-specific information. Customers must be able to locate accurate and up-to-date Connecticut-specific supplier information to sustain a robust retail choice market. The Authority will work with licensed suppliers on website best practices through the periodic meetings of the Supplier Working Group, noticed as Technical Meetings in Docket No. 13-07-18," the draft states

Finally, the draft would modify PURA's prior order that suppliers must include in each written agreement, "the beginning date and expiration date of the contract."

Conceding the difficulties in determining the exact start and end date for purposes of the contract due to meter reading schedules, the draft would instead direct that suppliers inform customers, "that their contract will begin on the meter read date following acceptance of an enrollment by the EDC."

However, the draft would still direct suppliers to have a "meaningful discussion" with customers about the expected enrollment date.

"Suppliers know when each enrollment will be submitted to the EDC for processing and understand the EDC/Supplier Electronic Business Interface process. The EDC’s meter reading schedule can be used to determine the number of business days necessary in advance of a customer’s next scheduled meter reading for an enrollment to be timely submitted. Suppliers therefore should be able to engage in a meaningful discussion to better inform customers about this issue. This dialogue is intended to provide consumers with more information about the process and is meant to improve, not harm, the market," the draft states

Docket 13-07-18RE01

ADVERTISEMENT
NEW Jobs on RetailEnergyJobs.com:
• NEW! -- Director of Commercial Structuring -- Retail Supplier -- Houston
• NEW! -- Customer Account Manager -- Retail Supplier
• NEW! -- Vice President and Regional General Manager -- Retail Supplier
• NEW! -- Program Director - $225K/yr -- Texas
• NEW! -- Staff Accountant, Commissions Analysis -- Retail Supplier -- Houston
• NEW! -- Direct Business Development Manager -- Retail Supplier
• NEW! -- Compliance Manager -- Retail Supplier
• NEW! -- Supplier Services Manager
• NEW! -- Operations Analyst -- Retail Supplier -- Houston
• NEW! -- ERCOT Business Development Manager -- Retail Supplier -- Houston
• NEW! -- Channel Manager -- Retail Supplier
• NEW! -- Marketing/Channel Manager -- Retail Supplier -- Houston
• NEW! -- Supplier Services Account Executive