Updated: PUC Authorizes Sharing Of Customer Phone Number, Email Address Of PPL Customer Referral Program Customers With Selected Retail Supplier, With Customer Consent

December 18, 2020

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Reporting by Paul Ring • ring@energychoicematters.com

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Updated, 12/18:

The Pennsylvania PUC issued a written order in a proceeding addressing PPL Electric's default service proceeding for the period June 1, 2021, through May 31, 2025

As exclusively first reported by EnergyChoiceMatters.com yesterday, the PUC in its order rejected a change in the treatment of customers who reach the end of their Standard Offer Program (SOP) term at PPL, and such customers will remain with their designated retail supplier, with pricing determined by the supplier, unless the customer takes affirmative action to the contrary.

The written order confirms that the PUC is modifying the SOP process to allow the opportunity for retail electric suppliers (EGSs) to receive the SOP customer's phone number and email addresses, to facilitate the marketing of EGS plans at the end of the SOP term and to avoid rollover pricing

The PUC noted, "While we are unable to determine from this record that harm is occurring as a result of the existing SOP program, we share in the concerns expressed by all the Parties in this proceeding as to the reasons why certain SOP customers show inertia in making an affirmative choice between one to four months following the expiration of their SOP contracts and instead automatically renew with the EGS on a month-to-month variable price contract."

As such, the PUC adopted in part a proposal from Starion Energy. Starion noted that, under the current SOP, the only contact information EGSs receive from PPL Electric for customers enrolled via the SOP program is the customer’s billing address. The EGS does not receive a customer's phone number or email address.

Starion noted that the lack of access to a customer's phone number or email address hinders the ability of the EGS to more directly contact their customers

Starion proposed that PPL Electric would request permission from the customer being enrolled in the SOP program to have his or her contact information shared with the SOP EGS. Specifically, Starion proposed that a simple question to the consumer during the SOP enrollment process asking whether he or she is willing to share his or her personal contact information -- i.e., the customer’s phone number or email address -- to the SOP EGS ensures that the customer is given the right to decide whether or not to share his or her information.

The PUC adopted Starion's proposal in this respect

The PUC directed parties to address details as part of a broader process addressing SOP contractor & customer service representative (CSR) scripts and guidelines (discussed further below as part of a settlement in the case)

The PUC directed that the SOP scripts shall include an explanation to the SOP customer during the customer’s SOP enrollment process that sharing the customer’s information with the SOP EGS will enable the EGS to contact the customer by phone, text, or email prior to the contract term expiration and to inform the customer of the EGS offerings post contract expiration. Also, the CSRs should include a simple question asking the customer whether the customer consents to the release of such contact information to the SOP EGS for this purpose, the PUC said. Should the customer consent to the release of such information, the SOP EGS should be provided such contact information when the customer is enrolled with the EGS. If the customer does not consent to the release of such information, the SOP EGS shall not be provided such contact information when the customer is enrolled with the EGS.

"While currently there is no requirement for a SOP EGS to call, text, or email its SOP customers prior to the expiration of the fixed duration contact, we would expect that, after receiving a SOP customer’s phone number and/or email address, and to the extent an EGS has existing marketing methods in place for its non-SOP customers utilizing calls, texts, and/or emails, that the EGS would attempt to contact the SOP customer prior to the expiration of the SOP contract, via the same methods as it would a non-SOP customer, to inform the SOP customer of the expiring SOP contact and of the new offerings available from the EGS. Such notices would be in addition to the required notices the EGS must send under Section 54.10 of the Commission’s Regulations and the final guidelines of the RMI IWP Final Order [Retail Electricity Market: Intermediate Work Plan, Docket No. I-2011-2237952, Order entered March 2, 2012]," the PUC said

As first reported yesterday, the PUC did order that PPL Electric's separate Customer Assistance Program (CAP) Standard Offer Program (CAP-SOP) shall be ended, and Customer Assistance Program (CAP) customers shall be required to receive default service at the Price to Compare.

The PUC also approved without modification a settlement addressing other aspects of PPL's default service program

Regarding other aspects of the SOP program, the adopted settlement provides that PPL will work with OCA, OSBA, and other interested parties in revising the guidelines used by CSRs and scripts used by the SOP contractor employees. Any such revisions will be completed within 90 days

PPL agrees to increase its monitoring of the SOP contractor employees to ensure that the complete conversation accurately reflects the SOP contract terms and required disclosures. PPL further agrees to take any necessary actions, including, but not limited to, additional training of the SOP contractor employees, or terminating the Company’s contract with the SOP contractor, as may be necessary.

As previously reported, the approved settlement largely adopts the default service supply procurement and rate designs as proposed originally by PPL (see full details here), except on certain discrete issues that were withdrawn or reserved for litigation. Unless otherwise noted, PPL's originally described proposals from our prior story are approved under the settlement

With respect to PPL's proposed use of AEC auctions to acquire AECs for AEPS compliance for default service load (rather than AECs being procured solely and initially by the wholesale default service suppliers as part of the full requirements contract), the adopted settlement authorizes such mechanism on a pilot basis

Concerning the AEC auction, the adopted stipulation provides that, "The Company agrees to operate this program as a pilot program for the DSP V program period; provided, however, this proposal is contingent on full recovery of all costs of the program through the GSC-1 rate. Full-cost recovery in the GSC-1 rate will be subject to the determination that the costs are prudent and reasonable in the filing(s) in which PPL proposes recovery."

Under the adopted settlement, the Company will reconcile 12 months of over/under collections over a 12-month period consistent with its other Section 1307 surcharges. In the event the GSC-1 E-factor exceeds 10 percent of the Price-to-Compare for Small C&I GSC-1 customers, the Company agrees to consult with the OSBA regarding the causes for this variance and steps being taken to reduce GSC-1 variances.

Docket No. P-2020-3019356

Earlier, 12/17:

The Pennsylvania PUC today adopted an order in a proceeding addressing PPL Electric's default service proceeding for the period June 1, 2021, through May 31, 2025

As first reported by EnergyChoiceMatters.com, an ALJ had recommended modifying PPL's Standard Offer Program (SOP) such that customers shall be returned to default service at the end of their Standard Offer Program (SOP) contracts, unless the customers affirmatively elect to continue service with the EGS (retail supplier) or chose another EGS.

The PUC rejected this recommendation

For the regular SOP program, the PUC ordered that there will be no change, from the current program, in the treatment of customers at the end of their SOP term. Customers will remain with their SOP retail supplier at the end of the SOP term unless and until the customer takes an affirmative action to no longer do so

PUC Vice Chairman David Sweet emphasized consistency with how non-SOP customers are treated at the end of a contract term, in declining to require that SOP customers be dropped to default service at the end of their SOP term

"I recognize that the issue of customers being rolled into month-to-month contracts has been discussed at length over the course of litigation surrounding the implementation of the now over-20-year-old Competition Act. While I would probably not have supported the use of rollover contracts initially, they have become an ingrained feature of shopping. As such, I do not believe that it is wise to create inconsistencies in how the end-of-contract process is handled between SOP and non-SOP shopping," Sweet said

However, Sweet emphasized that, "I strongly encourage EGSs to work with all customers as much as possible to avoid these rollover contracts."

Chairman Gladys Brown Dutrieuille likewise stated, "Of particular interest to me was PPL’s proposal to modify the Standard Offer Program (SOP) design. PPL seeks to return customers, who have not affirmatively re-enrolled in SOP, to default service at the expiration of a contract term. PPL references the experiences of customers under current SOP design who do not affirmatively take action at the expiration of the SOP term and sometimes end up on month-to-month products with a generation price higher than the price-to-compare. While I am sympathetic to the proposal of the Company, I am also cognizant that the current SOP design has worked to enroll thousands of customers onto a generation rate at a discount to the PTC, and, that consistency among SOP program designs across the Commonwealth may prove beneficial. Finally, I find it persuasive that the existing design is consistent with the Commission’s present Regulations at Pa. Code § 54.10(3)(i)(A)-(B). To that end, I am comfortable retaining the existing design. I encourage PPL to continue to educate customers about the shopping options available to them at the end of the SOP. Finally, I urge PPL to continue to retain information and data related to its SOP to inform this Commission in future proceedings."

The PUC did adopt the ALJ's recommendation that PPL Electric's Customer Assistance Program (CAP) Standard Offer Program (CAP-SOP) shall be ended, and Customer Assistance Program (CAP) customers shall be required to receive default service at the Price to Compare.

The PUC previously prohibited CAP customers from shopping outside of the CAP-SOP; thus the final decision prohibits customers at PPL from being served by an EGS if they are receiving CAP benefits

Sweet said that his vote to end CAP-SOP was made "begrudgingly," and stressed that PPL has stated that, to the extent the PUC later addresses CAP shopping in a different manner, PPL will comply with any such PUC policy (as previously reported, a proposed CAP policy statement remains pending, which would allow a modified CAP-SOP with the CAP-SOP rate from an EGS never exceeding the price to compare)

Sweet stated, "I am voting to approve PPL’s CAP shopping request [to end the CAP-SOP program], albeit begrudgingly. I agree with PPL and other stakeholders that the existing CAP SOP is not working well. The Commission proposed, in 2019, a new policy statement regarding CAP shopping, but that proposal has not yet been finally adopted. I would have preferred that PPL propose a program more along the lines of our proposed policy statement. However, because the policy statement has not yet been adopted, I am willing to support the recommendation approving PPL’s request to drop CAP shopping for the time being. In doing so, I am relying on the fact that PPL has expressed throughout this proceeding that, 'should the Commission issue a future order directing differently than what PPL Electric is proposing in this proceeding, PPL Electric will seek to amend the DSP V with respect to CAP shopping so that it is in compliance with the Commission’s directives.' I personally intend to carefully monitor this issue as matters unfold."

A written order was not immediately available. However, other than the SOP, other default service issues (procurement, pricing) were proposed to be resolved through a non-contested settlement (see details on the settlement here)

P-2020-3019356

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