Proposed Order Would Grant Utility Authority For CSRs To Discuss Retail Supplier's Rate, Price To Compare Information During Customer Calls

May 13, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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A proposed decision from an Illinois ALJ would grant a petition for a declaratory order from Commonwealth Edison that would find that ComEd's proposed policy of directing its customer service representatives (CSRs) to discuss certain Price To Compare (PTC) information during customer calls is permitted under applicable regulations

ComEd's proposal for CSRs to discuss Price to Compare information during customer calls had been first exclusively reported by EnergyChoiceMatters.com

As more fully discussed in our prior story, ComEd proposes that CSRs discuss the following information with customers (referred to as 'Paragraphs 13-15' in the proposed order)

• ComEd plans to inform customers of frequently asked questions that may be helpful to discuss with ARES [alternative retail electric suppliers], providing information akin to what is already available on the Commission’s website for customer choice: www.pluginillinois.org/FAQ.aspx. In addition, ComEd will also direct its CSRs to inform customers that they should contact their ARES for specifics about their particular contract, including any special offers received that may have impacted their supply charge. ComEd will instruct CSRs to limit their discussion to specific facts, e.g. the specific supply price the customer is paying as reflected on the customer’s bill, if known, and the PTC. ComEd will instruct CSRs not to provide any recommendation to the customers on whether they should or should not switch to an ARES or discuss the quality of service of the ARES.

• The communications will be made to all customers who call in to ComEd’s call center to inquire about the PTC or to complain about supply charges, regardless of whether the PTC is higher or lower than the price each customer pays for supply. As stated above, the communications will not make any recommendations or reach any conclusions on the data provided regarding the PTC and the price the individual customer pays for supply. Instead, they will assist in allowing customers to draw their own conclusions and make informed decisions.

ComEd had said that allowing CSRs to discuss the PTC is necessary to further remove ongoing confusion from the market. "Since January 1, 2019, ComEd has received more than 1,300 calls where customers inquired about or discussed the PTC. Moreover, ComEd contemplates moving the PTC to a more prominent position on the bill. As ComEd implements this change, ComEd expects customer inquiries to increase," ComEd had said

In the proposed decision, the ALJ recommends, "Commonwealth Edison Company’s Verified Petition should be granted, and Commonwealth Edison Company’s proposed communications as set forth above and described in Paragraphs 13-15 of the Verified Petition are the type of 'legitimate consumer education efforts' expressly authorized by Part 452 of the Commission’s Rules and the Public Utilities Act."

The ALJ noted, "RESA objects to ComEd’s Petition on the grounds that without having any idea of the specific language ComEd’s CSRs will use with customers, and without knowledge of the training ComEd’s CSRs will undergo, there is no certainty that Part 452 will not be violated. RESA fears that interactions with ARES customers will stray from legitimate consumer education into marketing in favor of ComEd as a supplier, or at least will discourage customers from enrolling with an ARES. RESA also worries that CSRs will not understand specific ARES products and therefore, their PTC explanation will not consider those differences."

The proposed decision states, "The Commission does understand RESA’s concerns but notes that the record indicates that ComEd has received a significant 1,300 customer calls with questions about the bill language from January to April of this year. It is not reasonable for ComEd to be unresponsive to these customers, and this flies in the face of the ORMD Report’s recommendation that customers receive PTC information. The Commission also agrees that ComEd’s CSRs should not tailor their communications to a strict script but be responsive to each customer’s specific question. There are sufficient quality assurance safeguards in the process to ensure that the CSRs’ communications are limited to the types of communications that ComEd outlines in Paragraphs 13-15 which are permissible and do not violate Part 452. It is correct that ComEd CSRs cannot, nor should they be expected to, understand and describe the different products of all ARES operating in Illinois. To that end, ComEd explained that CSRs will direct questions to the customer’s ARES, and the Commission agrees that this is appropriate."

Docket 19-0386

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