EnergyChoiceMatters.com

Pa. PUC Proposes Further Accelerated Switching For Natural Gas

December 23, 2016

Email This Story
Copyright 2010-16 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The Pennsylvania PUC has issued an advanced notice of proposed rulemaking to implement accelerated switching for natural gas supply service

The PUC is adopting the natural gas supplier switches be completed within 3 business days from submission of the switch (the same timeline as adopted for electricity)

"We recognize that this will require, in most cases, off-cycle switching but we agree with those parties that pointed out that there are options available if an off-cycle switch is needed and advanced metering is not available – special meter reading, estimated meter readings and customer-supplied meter readings," the PUC said

"It is also important to keep in mind that from the consumer’s perspective, it is not 3-day switching ... [I]n most cases, the supplier will hold the customer’s enrollment until the expiration of the customer’s § 62.75(d) 3-day rescission period. It is only after this initial 3-day period expires and the NGS [natural gas supplier] forwards the enrollment to the NGDC [utility] that the 3-business day clock to switch the account starts ticking. So from a consumer’s perspective, even under the accelerated procedure being proposed, the switch will likely take up to six days (if not longer in the case of intervening holidays or weekends)," the PUC said

The current switching timeline, where switches only occur at scheduled meter reads, can take up to 45 days

"We also recognize that off-cycle switching will necessitate a change in NGDC billing procedures. We will not specify the billing procedure changes that may be necessary, but point to the fact that in the electric industry, different EDCs have handled this differently, and we expect to maintain the same flexible approach for the NGDCs. Some EDCs maintain the regular monthly bill, placing multiple suppliers on the same bill if a switch is performed off-cycle. Another EDC instead issues a new bill each time a supplier is switched regardless of what point in the billing cycle the switch occurs," the PUC said

The PUC proposed that accelerated switching be implemented within one year of a final regulation appearing in the Pennsylvania Bulletin.

The PUC's proposal would eliminate the (currently in rule) 10-day waiting period required before switches occur during which time the customer receives a notice of the switch (meant as an anti-slamming provision, note the period was shortened to 5 days via waivers).

The PUC stressed its "zero tolerance" policy against slamming.

The PUC sought comments on its regulations regarding refunds under slamming, asking whether, in addition to refunds for supply charges, should this policy be broadened, "to include refund and reimbursement for things like early cancellation fees or enrollment fees that the customer may have been charged as a result of a slam?"

The PUC also noted operational changes which may be required to implement accelerated switching

"First, it is important to note that capacity and, to a lesser extent, the nomination schedule for the customer follows the customer at all NGDCs. This structure eliminates a hurdle but sets a rigid requirement that purchased commodity (i.e., natural gas) must align with in order to serve the customer. However, we know that the previous supplier would have already contracted for the commodity (at least until the end of the contract term) that perfectly aligns with that customer’s capacity and nomination. Therefore, we know that there is at least one option capable of serving the customer on a quick timescale," the PUC said

"Naturally, any interface would need to be market driven (i.e., based upon cost, spot price, hub price, etc.) but the current NGS commodity could be established as a right of first refusal to the selected NGS supplier for a specified period of time after the switch in order to serve the customer. For instance, the commodity or services from the current NGS could be offered for a period of no more than 10 days unless both parties agree to a longer term. Meanwhile, we could marry this right of first refusal to the 3 day customer right of rescission where the selected NGS would need to let the current NGS know their intent of using the right of first refusal. This dynamic would necessitate real time communication between all parties involved and in the case of an NGS to NGS switch would also require NGDC involvement. For these reasons, the NGDC would likely have to serve as a clearinghouse for these dynamics on their individual systems and foster this real time communication between all parties. In addition, these types of features may require NGSs to become more creative with their products to compensate for any costs for accelerated switching. If done properly this sort of clearinghouse could aid further competition within the marketplace, ultimately leading to more shopping opportunities or lower costs for consumers," the PUC said

"These types of marketplace changes may necessitate corresponding regulations. We have not proposed those here as the above discussion may be just one way to accelerate switching. Therefore, we invite interested parties to propose regulation changes consistent with such mechanisms that would accelerate switching," the PUC said

"We also note that, unlike the electric industry where Electronic Data Interchange (EDI) is used uniformly, various NGDCs use different electronic protocols in communicating customer information with NGSs. Nothing in our proposed rule changes nor is intended to alter this. We prefer, as we did with the electric industry, not to prescribe the mechanics of the switching process – and instead leave that up to the discretion of the NGDCs and NGSs," the PUC said

The PUC proposes that customers be permitted to return to default service by contacting the supplier of last resort (currently the utility). Currently, customers must contact their supplier for such a drop.

In such drop cases, the supplier of last resort shall notify the customer that there may be a cancellation penalty to cancel service with the current NGS.

The PUC also proposes to eliminate from the rules a provision regarding, "Persons authorized to act on behalf of a customer."

This section currently reads as follows: "A customer may identify persons authorized to make changes to the customer’s account. To accomplish this, the customer shall provide the NGDC with a signed document identifying by name those persons who have the authority to initiate a change of the customer’s NGS."

"We propose to eliminate this section in its entirety. As we discussed in the Working Group, we propose its elimination since it is not relevant to current NGS switching protocols. When this provision was originally promulgated, it was envisioned that NGDCs might have more of a role in "policing" the switching process. However, as the switching process evolved, NGDCs do not "police" the switching process – they simply act on the directions they receive from NGSs via electronic protocols. They are not expected to, nor do they, screen supplier enrollments for "authorization." This is not even possible, given that the electronic data submitted by the NGS to the NGDC does not include who the NGS talked to at the customer’s household (and with enrollment transactions that do not involve person-to-person contact, such as direct mail or online enrollments, the NGS has no way of knowing who actually submitted the written or online enrollment form). We fear that retaining this section risks giving too many the false impression that NGDCs police the switching process – or that NGDCs are obligated to police the process," the PUC said

Docket L-2016-2577413

Email This Story

HOME

Copyright 2010-16 Energy Choice Matters. If you wish to share this story, please email or post the website link; unauthorized copying, retransmission, or republication prohibited.

Archive

Daily Email

Events

About/Contact

Search