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New York Utilities: Muni Aggregator's Definition of Eligible Customer Is "Over-Inclusive"

Muni Aggregator's Plan, "Flips Opt-Out Process On Its Head," Utilities Say


March 23, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The municipal aggregation implementation plan submitted to the New York PSC by Good Energy, L.P. is "over-inclusive" in defining eligible customers, and, for new customers moving into the municipality, "flips the opt-out process on its head," the joint New York utilities said in comments to the PSC

According to the utilities, Good Energy’s implementation plan defines eligible customers to include electricity and gas customers who receive default service from their utility, except those who have requested not to have their account information shared or have otherwise placed a block on their utility account.

"The Joint Utilities agree that customers currently being supplied by an ESCO would be excluded, along with customers that currently have a block on their account (e.g., a voluntary block indicating they do not wish to be served by an ESCO). However, the Joint Utilities also believe participants in utility programs that require the customer to take supply service from the utility should also be excluded from the list of eligible customers," the utilities said

As an example of such customers, the utilities cited National Grid’s GreenUp REC add-on program, which requires participating customers to take supply service from National Grid.

The utilities further said that the status of customers’ existing power supply option should not be provided to Good Energy

The utilities said that, "In its filing, Good Energy suggests, '[a]fter approval by the Commission and execution of the ESA with an ESCO, the LDC will electronically transmit the name, address, and existing power supply and natural gas option (i.e., basic service or competitive supply) of each Eligible Consumer to the ESCO in order to facilitate the notification and opt-out requirement of the Program.'"

"Utilities should only be required to provide customer-specific information for eligible customers, which would exclude all customers with a block on their account, customers who are currently enrolled with a competitive supplier (other than the CCA), and customers who are participating in a utility program that requires the customer to take supply service from the utility," the utilities said

The joint utilities further alleged that Good Energy’s Implementation Plan, "does not align with the Commission’s approved opt-out process," due to the treatment of customers moving into a municipality.

"The Implementation Plan states that '[w]hen a New Consumer first moves into the participating municipality, the Eligible Consumer will be enrolled automatically in the Program upon initiation of electric distribution service, subject to the customer’s right to opt-out of the Program as described in this Section,'" the utilities said

"This proposal flips the opt-out process on its head, first enrolling the customer with the CCA, then allowing for an opt-out timeframe to occur after the enrollment," the utilities said

"Under the Commission’s CCA Order, '[i]f a municipality chooses to enroll these customers on an opt-out basis, it must mail them an opt-out letter ... providing an opt-out period of at least 30 days before the customer is enrolled.' Indeed, the CCA Order indicates that municipalities can choose to either enroll new customers on an opt-in or opt-out basis, and further, have the option (but are not required) to 'request a monthly list from the relevant utilities of new customers in the municipality.' The Implementation Plan should be modified to reflect these requirements, acknowledging that utilities are only required to provide a list of new eligible customers upon request by a CCA, and that utilities will not automatically enroll a new customer that moves into a municipality in a CCA," the utilities said

The utilities also objected to implementing customer opt outs, after the initial period, through calls to the utility rather than the CCA's supplier

"The Implementation Plan suggests that subsequent to enrollment, a customer may elect to opt-out of receiving service through the CCA by calling their utility 'and requesting to be returned to basic service, in which case the [utility] shall submit a transaction to drop the supplier transaction.' Certain of the utilities do not have such a transaction, which could require substantial Electronic Data Interchange ('EDI') and system programming to implement. Good Energy’s Implementation Plan should be modified to remove this option, instead directing CCA customers to contact the CCA ESCO and request to be dropped," the utilities said

The utilities also said that customer-specific data transferred to the CCA should not include telephone numbers or low income status

"In its filing, Good Energy defines the 'Customer Contact Information' data set used to conduct the opt-out campaign, as including telephone number. However, the Commission previously determined that telephone numbers would not be included in the customer-specific information data set to be used to support the opt-out process. In keeping with the Commission’s Rehearing Order, the Joint Utilities do not intend to include telephone numbers in the Customer Contact Information data set. Similarly, the Commission also determined that '[t]o avoid unnecessarily broaching consumer privacy with regard to low-income status, low-income status will not be included in any of the data transfers.' Again, in keeping with the Commission’s Rehearing Order, the Joint Utilities do not intend to include low income status in the customer-specific data provided to the CCA," the utilities said

Case 14-M-0224

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