Utilities Propose Alternatives To Enroll-By-Wallet Mechanism
January 8, 2021 Email This Story Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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During a technical session, the Massachusetts electric distribution companies offered several proposed alternatives that would allow customers to enroll "on the go" while still relying on use of the account number for enrollments, instead of personal data contemplated under "enroll by wallet" proposals
As exclusively first reported by EnergyChoiceMatters.com, DPU Staff are interested in an approach that reduces a reliance on door-to-door and telemarketing, and Staff believes that the current approach to enrollments, which relies on the account number, may "force" suppliers to rely on such marketing. Staff seeks an approach that allows suppliers to market in public settings (kiosks, etc.).
As previously reported, Staff believes that, "Improvements in market efficiency cannot be achieved at the expense of consumer protections against slamming," Staff cautioned
"One outcome that these principles would preclude is allowing successful enrollments to be based on information that is included in the distribution companies’ Customer Information Lists," Staff has said
During yesterday's session, the EDC stated that they are opposed to eliminating the customer account number for enrollments because it:
"(1) will almost certainly result in increased unauthorized enrollments;
"(2) would require costly utility billing system upgrades and additional administrative and overhead costs; and
"(3) will produce questionable benefits that would be outweighed by harm to customers.
"(4) data security concerns with maintaining customers’ personal identifying information"
The EDCs said that using alternate forms of verification such as a customer’s street address, last four digits of social security number (SSN), phone number, and birthday are inadequate for a variety of reasons, including the fact that the EDCs may not have this information, that the information may not be sufficiently unique, or the risk of storing the information that is otherwise not needed to open an EDC account (e.g. a full SSN may not be required by the EDCs for an account)
The EDCs offered three alternative proposals that they said would facilitate out-of-home enrollments
The EDCs said that one option may be for customers to retrieve their account number via the EDC's mobile application or through the EDC website. Of this, the EDCs said:
• "Less costly than other options and does not require adjustments to current process
• "Allows for on-the-go access of account number
• "Companies do have different levels of online adoption"
A second alternative offered by the EDCs is to change EDI to use something other than the account number as the primary key on enrollments. Of this, the EDCs said:
• "Costly and time consuming (EBT working group changes are time consuming and difficult to develop)
• "Potential for mismatched information on new identifiers, such as typos (e.g., Johnson v Jonson, Ash St. v Ashe St., etc.)
• "LDCs may have different reliability/consistency with other identifying information available.
• "High probability of increase in rejected transactions for inaccurate data
A third alternative would be a web portal whereby customers can look up account number using other personal information, i.e., enter last 4 of social and address into website lookup, website returns back the account number or necessary identifier for use in EDI enrollment. EDCs would leverage two-factor authentication to increase security. Of this, the EDCs said:
• "Example - Customer provides Supplier Representative with last 4 of social, last name, and cell phone number or email. Supplier visits website, chooses correct utility, and enters information provided by customer. Customer receives automated email or text message with link to click to authenticate. Customer receives back account number via email or text message to provide to Supplier rep for enrollment.
• "Costly and time consuming, with unknown benefits
• "Potentially outsourced to 3rd party vendor for single interface for Suppliers and Companies
The technical sessions also discussed various DPU Staff proposals regarding price caps for low-income customers as well as for variable rates, auto-renewal limits and rules, a new "interactive" TPV process, and DPU "real-time" or enhanced access to recordings of sales calls and TPVs