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Maryland Workgroup Leader Proposes Regulations To Implement Instant Connects, Seamless Moves

Would Also Adopt Regulations Governing Third Party Access To Customer Usage

Proposes New Requirement For Energy Consultants To Register With PSC

February 5, 2018

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

The working group leader has filed a report in PC44, addressing several retail market enhancements and issues, including instant connects, seamless moves, and third-party access to customer usage history, among other issues.

Although consensus was reached on certain items, the report reflects generally the recommendations from the working group leader and not the group overall, and is a non-consensus document.

The report recommends that the PSC initiate a rulemaking to adopt regulations to implement instant connects (electricity only) and seamless moves (electricity and gas)

The proposed rules would provide that, for electricity, instant connect capability shall be made available to all eligible customers in every utility service territory, with the following conditions:

(a) The customer shall not be permitted to back-date the service request;

(b) The utility may require a customer to provide at least three business days’ notice prior to the effective date of the Instant Connect request; and

(c) An Instant Connect is only available on a customer account for which the utility has established metered service.

For electricity, the report recommends that Seamless Move capability shall be made available to all eligible residential and small commercial customers in every utility service territory under the following conditions:

(a) The location of the customer’s new premise must be within the same utility service territory as the customer’s current premise;

(b) The customer must maintain the same rate class, billing rate, billing option, and tax exemption percentage at the customer’s new premise;

(c) The customer shall not be permitted to back-date the service request;

(d) The utility may require a customer to provide at least one business days’ notice prior to the effective date of the Seamless Move;

(e) The customer must provide the move-out and move-in dates concurrent to the utility initiating the Seamless Move, and there cannot be more than three days’ gap or three days’ overlap between the move-out and move-in dates;

(f) The meter at the customer’s new premise must be active at the time the Seamless Move is initiated;

(g) The supplier that is the subject of the customer’s Seamless Move must be currently providing service to the customer’s current premise; and

(h) The billing capabilities associated with the meter at the customer’s current premise must be compatible with the billing capabilities associated with the meter at the customer’s new premise.

A supplier would be prohibited from imposing an early cancellation fee on a residential customer if a customer elects not to pursue a Seamless Move.

The proposed natural gas Seamless Move regulations generally follow those proposed for electricity.

The report does not recommend a specific cost recovery mechanism for implementing seamless moves or instant connects, noting that stakeholders did not reach consensus on the issue.

The proposed regulations would also address electric suppliers' obligation to post offers on the Maryland PSC's online rate board. The report also recommends reminding suppliers that suppliers are required to upload new and updated offers through the Commission’s secure portal within three (3) days of a change to an open offer.

A proposed rule would provide that, in the event of a discrepancy between a supplier’s open offer posted on the Commission’s website and the supplier’s corresponding open offer displayed on the supplier’s website, the supplier shall honor the terms of the open offer on the Commission’s website to the extent that those terms are more favorable for the customer.

The report recommends a third phase of the working group be initiated to further address issues related to the PSC's electric choice website. Specifically, members of the work group requested that Phase III discuss how the Commission’s website could be revised to include, at a minimum, more robust customer educational information, including related to distributed energy resources, products, and customer protection.

The proposed rules would establish requirements for third parties to access customer usage data.

Under the proposal a customer may provide authorization to a Supplier, Curtailment Service Provider, or Energy Consultant to access the customer’s Historical Interval Usage or Interval Usage data and may, via the utility Electronic Interface, identify one or more third-parties that it authorizes to access its data.

Per the proposal, an Energy Consultant or Curtailment Service Provider must obtain a Letter of Authorization from the customer to gain access to that customer’s Historical Interval Usage or Interval Usage data.

Such Letter of Authorization shall, at a minimum:

1) Be in plain language;

2) Be headlined or titled by language telling the customer what it is;

3) Include the name, address, phone number, email address, and website address of the Supplier, Curtailment Service Provider, or Energy Consultant;

4) Include the customer’s name, address and any unique customer identifiers used by the utility to authenticate a customer on the utility’s website;

5) Include a signature line if completed on paper, or equivalent electronic signature;

6) Include telephone and email contact information if provided by the customer;

7) Clearly state the purpose for which the customer’s data will be used;

8) Clearly state the period of time in which the agreement authorizes access and, for which data will be provided;

9) Include steps that need to be taken to cancel access to Historical Interval Usage and Interval Usage data;

10) Include space for a customer to acknowledge that the customer was given the most current version of the Commission approved educational Brochure;

11) State any meter identifiers, if there is more than one meter on the account; and

12) State any cancellation fees and the justification for them.

A customer’s Supplier may obtain customer authorization to access that customer’s Historical Interval Usage and Interval Usage data through their contract and/or enrollment authorization without a separate Letter of Authorization, pursuant to the utility’s supplier coordination tariff and COMAR 20.53.03 and COMAR 20.53.07.02 [for electricity, or the corresponding natural gas enrollment authorization regulations].

Energy Consultant is a newly defined entity under the proposal, and would be required to register with the PSC to access customer usage data from the utilities.

Among other things, an Energy Consultant that accesses customer Historical Interval Usage or Interval Usage data shall maintain a website that contains:

a) Customer service contact information;

b) The firm’s privacy policy;

c) How the customer may confirm that the Energy Consultant has a current and valid authorization in place for data sharing;

d) A clear description of how to cancel the authorization, including any applicable fees for any associated service agreement;

e) A simple, plain statement of the purpose for which the Energy Consultant will use customer data; and

f) provide a copy of the standard educational Brochure.

Under the proposed rules for electricity, a Utility shall maintain a standardized electronic process to provide a Supplier that has obtained a customer’s consent electronic access to that customer’s interval usage data via a batch, comma-separated value file, spreadsheet or other electronic format that includes at a minimum, a rolling ten days’ worth of interval usage data and is refreshed daily. The interval usage data shall be made available within 48 hours after the customer’s daily meter read.

Under the proposal, an electric Utility shall also:

1) maintain an Electronic Interface to allow a customer to select a Supplier, Curtailment Services Provider, or an Energy Consultant to receive the customer’s Historical Interval Usage and Interval Usage data for a designated purpose and specified period;

2) provide an Electronic Interface to allow a Supplier, Curtailment Services Provider, or a Energy Consultant access to a customer’s Historical Interval Usage and Interval Usage data, or other data specified in this Subsection, for a designated purpose and specified period of time, if the Supplier or Curtailment Service Provider, or Energy Consultant, warrants that it has properly obtained the customer’s Letter of Authorization.

Furthermore, under the proposal, for electricity:

C) A Utility shall maintain and make available at least 24 months of Historical Interval Usage data for customers with meters enabled by advanced metering infrastructure.

D) A Utility shall establish a simple, automated process for a Supplier, Curtailment Service Provider, or Energy Consultant to apply to the Utility to receive data from the Electronic Interface.

Per the proposal, at a minimum, an electric Utility shall make the following data available in the Electronic Interface for its electric service customers:

1) service point ID;

2) account number or Electric Choice ID;

3) time stamp for each meter reading;

4) an identifier of the quality of the data (estimated, billable, etc.);

5) Interval usage as registered by the meter;

6) Peak Load Contribution (Capacity and Transmission);

7) Rate code (residential, small commercial, etc.); and

8) Historic Interval Data used for billing purposes.

The proposed requirements relating to natural gas historic usage requirements are generally similar to those for electricity

Finally, the work group Leader respectfully requests that the Commission provide guidance related to the implementation of online look-up tools as initially contemplated in the January 31, 2017 Notice convening PC44.

"While the Work Group spent many hours over the course of several meetings discussing options ranging from enhanced customer lists to electronic look-up tools that would provide “smart responses” to invalid input data, the majority of suppliers actively participating in the CMCC Work Group expressed the desire to move beyond online look-up tools altogether and instead eliminate the underlying customer choice ID or service number requirement that served as the initial justification for the request. An online look-up tool would allow retail suppliers to access a secure online web portal, with customer consent, to determine the customer’s choice ID or service number that is required as a prerequisite to process the customer’s enrollment with a supplier. Conversely, the elimination of the customer choice ID or service number would allow licensed suppliers to pursue a policy generally referred to as 'wallet enrollment' that would allow customers to enroll with a supplier using information typically available to the customer in his or her wallet," the work group leader said in the report

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