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Affiliate Of Choice Utility, Which Newly Made Election To Allow Third Parties To Bill Non-Commodity Services On Utility Bill, Has Entered Into Marketing Agreement With Non-utility Service Provider, Would Allow Third Party To Use Name Which Includes Part Of Utility's Name

Agreement Includes Provision Of "Information" About Third Party's Services Through Various Utility Customer Touchpoints


August 5, 2025

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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The following story is brought free of charge to readers by VertexOne, the exclusive EDI provider of EnergyChoiceMatters.com

Columbia Gas of Pennsylvania, Inc. (Columbia) intends to enter into a Billing Agreement with Pivotal Home Solutions, LLC (Pivotal), which would allow for charges for Pivotal’s warranty service plans and products & services ("Covered Products") to be included on Columbia Gas of Pennsylvania customers’ utility bills

Additionally, such Pivotal service plans and products could use the "Columbia" brand name.

Furthermore, "information" on such Pivotal non-utility products would be provided to Columbia Gas of Pennsylvania utility customers through a variety of utility customer touchpoints, as further described below.

As previously reported, Columbia Gas of Pennsylvania previously ceased offering on-bill billing of non-commodity services on its bills. Columbia Gas of Pennsylvania elected to cease offering the on-bill billing after the Pennsylvania PUC found that Columbia Gas of Pennsylvania's earlier practice in the offering of "on-bill" billing was, "discriminatory." Prior to the cessation, Columbia Gas of Pennsylvania had limited, to only two select third-party providers, the availability of "on-bill" billing

As previously reported, in June 2025, Columbia Gas of Pennsylvania informed the Pennsylvania PUC that Columbia Gas of Pennsylvania will allow third parties, including retail natural gas suppliers, to bill non-commodity services through Columbia Gas of Pennsylvania's utility bill in Pennsylvania. "Columbia will provide such a service to all entities that desire the service on a non-discriminatory basis," Columbia Gas of Pennsylvania has said

See more background on the new change to allow on-bill billing here

An affiliate of Columbia Gas of Pennsylvania, specifically, NiSource Development Company, Inc. (NDC), has entered into a Marketing and Licensing Agreement (M&L Agreement) with Pivotal

Columbia Gas of Pennsylvania said that, under the M&L Agreement, "Pivotal will offer warranty service plans and products and services ('Covered Products') to Columbia customers, and NDC will grant a non-exclusive right and license for service marks to be used to market the Covered Products[.]"

More specifically, under the M&L Agreement, NDC will grant to Pivotal a non-exclusive right and license for the specific service mark "Columbia Service Partners" to be used to market the Covered Products, thereby allowing NDC to receive a revenue share percentage from the purchase of the Covered Products by customers of Columbia Gas of Pennsylvania

The service marks are owned by NiSource Corporate Services Company

Under this Marketing and Licensing Agreement, Pivotal will remit a participation and licensing fee to NiSource Development Company. This fee is calculated based on the number of Columbia Gas of Pennsylvania customers who enroll in Pivotal’s Covered Products

The M&L Agreement has an initial term of five (5) years

Columbia Gas of Pennsylvania intends to enter into a Billing Agreement with Pivotal to provide billing services to Pivotal for Covered Products purchased by Columbia Gas of Pennsylvania customers, in exchange for payment of certain annual and monthly fees by Pivotal for such billing services

Concerning the on-bill billing, Columbia Gas of Pennsylvania said in a filing that, "All third parties, including Pivotal, will be subject to standard terms and conditions for on-bill billing services. Columbia will apply the same fees and fee structures to Pivotal as it will to any other third party seeking to offer similar warranty plans, products, and services."

See more background here on Columbia Gas of Pennsylvania newly electing to allow third parties to bill non-commodity services on the utility bill

However, "[a]s part of the billing services to be provided," Columbia Gas of Pennsylvania will make "information" concerning Pivotal's services available through a variety of utility customer touchpoints

"As part of the billing services to be provided, Columbia will also make Pivotal's service warranty plan information available through IT interfaces such as the web portal, mobile app, interactive voice response ('IVR'), and the Start/Stop/Move process," Columbia Gas of Pennsylvania said in a filing

As also applicable to any third party using the on-bill service, the Billing Agreement will require Pivotal to pay an annual fixed fee for billing services, and monthly volumetric billing fees to Columbia Gas of Pennsylvania. Additionally, Pivotal will also pay setup and maintenance fees for IT related interfaces, as well as a monthly customer list fee, which are applicable to any third party using such service at Columbia Gas of Pennsylvania

Columbia Gas of Pennsylvania said in a filing that, "The Marketing and License Agreement is not an affiliated interest agreement, as Pivotal and NDC are non-affiliated entities." Pivotal is not affiliated with Columbia Gas of Pennsylvania or any NiSource company, Columbia Gas of Pennsylvania said in a filing

However, Columbia Gas of Pennsylvania did seek approval from the Pennsylvania PUC for an affiliated interest "arrangement" between Columbia Gas of Pennsylvania, Inc. ("Columbia" or "the Company") and its affiliate NiSource Development Company, Inc. ("NDC").

"Columbia is seeking Commission approval of its affiliate arrangement with NDC, whereby the Company will provide and be compensated for certain billing services related to NDC's Marketing and Licensing Agreement ('M&L Agreement') with Pivotal Home Solutions, LLC ('Pivotal'), a non-affiliated third party," Columbia Gas of Pennsylvania said

In terms of billing the non-commodity charges, Columbia Gas of Pennsylvania would include on its bill the following in its own section on the bill:

Optional Services Non-Utility Charges

These charges are service plan fees which are provided to you by the third party service provider(s) referenced below. The third party service provider(s) is not affiliated with Columbia Gas. The charges appear on your utility bill per your request. Any questions about Optional Services should be directed to the service provider, not Columbia Gas. Optional Services are not regulated utility services and are not provided or guaranteed by Columbia Gas or its affiliates. Your participation in a service plan in no way affects the utility service you receive from Columbia Gas. These service plans are intended for homeowners. Failure to pay Optional Service charges will not result in the interruption or termination of your utility service by Columbia Gas.

The Pivotal products and services would include service plans for the repair and maintenance of heating and cooling systems, water heaters, appliances, pipes, wires, or other infrastructure.

The Pa. Office of Consumer Advocate filed a protest concerning both Columbia Gas of Pennsylvania's plan to implement "on-bill" billing for third parties, and the affiliated interest "arrangement" between Columbia Gas of Pennsylvania, Inc. and its affiliate NiSource Development Company, Inc. ("NDC").

OCA said that Columbia Gas of Pennsylvania's election to implement third-party on-bill billing should be filed as a formal petition for approval, subject to answers, rather than the notice filed by Columbia Gas of Pennsylvania

OCA expressed various concerns with the affiliated interest "arrangement", as well as the inclusion of Pivotal charges on Columbia Gas of Pennsylvania bills, with OCA asking whether customers would bear additional costs due to the offering of "on-bill" billing, and whether a proposed third party’s inclusion on a Columbia Gas of Pennsylvania bill will be clear and easy to understand for consumers.

OCA also asked how the Pivotal products will be marketed by Columbia Gas of Pennsylvania, including how or whether a third-party’s services will be offered on Columbia Gas of Pennsylvania's website

"The OCA believes this matter warrants the full scope of litigation, including formal discovery, hearings, expert witnesses, and briefing," OCA said of the affiliated interest "arrangement"

Prior to the OCA filing its protest, the PUC had already extended the time for consideration of the affiliated interest "arrangement" until further order of the Commission. Such extensions, which prevent automatic approval due to inaction by the PUC, are not uncommon

Docket G-2025-3056022, R-2018-2647577

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