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Pennsylvania ALJs Recommend Requiring Utility To Send Letters To Low-Income Shopping Customers Who Have Rates Exceeding Default Service Price
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In a recommended decision in a Columbia Gas of Pennsylvania rate case, two Pennsylvania ALJs have recommended that Columbia Gas be required to send letters to low-income customers who are served by a competitive retail supplier at a price which exceeds the default service rate
The policy was proposed by CAUSE-PA [Coalition for Affordable Utility Services and Energy
Efficiency in Pennsylvania] and the Office of the Consumer Advocate
OCA during the proceeding had provided a report which OCA said showed that, from January 2022 through March 2025, approximately 48,000 residential customers at Columbia paid $35,332,095 more than the price to compare. In only two months was there even a slight benefit from retail supplier prices, OCA said
As summarized by the ALJs, "CAUSE-PA raised concerns that residential and low income shopping
customers are consistently charged commodity rates that, on average, substantially
exceed the applicable default service price, adding hundreds of dollars to bills each year
and exacerbating the negative consequences of high energy burdens on low income
customers. CAUSE-PA further expressed its concerns for the customers explaining
these consistently high commodity prices are driving up collections, termination, and
universal service program costs, and exacerbating distribution costs which fall to other
residential ratepayers."
Columbia opposed the proposal from the consumer advocates, stating that Columbia's existing customer education materials comply with the PUC's rules and law. Columbia noted that it already provides a calculator that allows customers to
compare shopping costs based on their actual consumption and the retail supplier's actual quoted price
No retail energy supplier or supplier representative appears to have intervened in the proceeding
As summarized by the ALJs, Columbia had argued that it would be improper for the
Commission to impose additional communication requirements related to competitive
supply rates in the rate case because supplier interests are not adequately represented
in the proceeding
The ALJs would find that, "OCA and CAUSE-PA identified an issue and proposed a solution to
address a concern that that affects a number of Columbia customers. OCA and CAUSE-PA further provided proposals to address and potentially resolve these issues for the
benefit of Columbia customers."
The ALJs would find that, "the standard in
addressing such consumer related issues is not whether the Company [Columbia] is doing that which
is required by law to address customer issues, where a problem clearly exists and the
Company’s approach has not resolved the issue."
The ALJs would find that, "Further, there was no credible evidence
presented that the issue raised by OCA and CAUSE-PA did not exist or that their
proposed resolution would be unduly costly or burdensome to Columbia or that the
proposed remedy would run afoul of any Code provision or Commission Regulation."
The ALJs would notably find that, "It is well established that a base rate case is the proper venue for hearing the
customer service issues raised in the proceeding."
The ALJs would find that requiring Columbia to send the letter concerning the customer's retail supply rate would be consistent with 66 Pa.C.S. § 1501 which
requires the utility to provide safe, adequate and reasonably continuous service
The ALJs said that OCA's and CAUSE-PA's proposals would be adopted, consistent with the recommended decision's ordering paragraphs
In the proposed ordering paragraphs, the ALJs would order Columbia specifically to, "develop a targeted letter for low-income
shopping customers that are enrolled with a supplier at a rate which exceeds the
applicable default service price."
"The letter shall inform these customers of the
availability of CAP [Customer Assistance Program] and other universal service programs, including the benefits of each
program and how to enroll," the ALJs would order
Columbia would be required to send such a letter at least once every 6 months.
Due to the proposed ordering paragraphs not specifically including the following provision, the ALJs did not appear to accept part of OCA's proposal which would have required that targeted educational messages sent to these low-income shopping customers shall explain how to compare retail supplier charges per therm to the Price to Compare, and shall "urge" customers to compare rates
on a monthly basis.
Separate from the specific low-income customer letters, the ALJs recommended that, "[a]t a minimum, the Commission should require Columbia to target educational messages to the choice customers to emphasize how to compare NGS [retail supplier] charges." While this adopts some of another OCA proposal separate from the low-income customer letter, the ALJs do not specifically endorse any language that would "urge" customers to compare rates monthly
The ALJs would also order that Columbia shall revise its tariff language concerning the Eligible Customer List (ECL)
The ALJs would order Columbia, in the ECL tariff language, to strike
references to third parties, and to restrict release of the Eligible Customer List (ECL) to
Natural Gas Suppliers (NGS) that are licensed by the Commission to operate within
Columbia’s service territory.
During the proceeding, the ALJs said that a witness for Columbia testified that Columbia interprets its current
ECL tariff as permitting Columbia to share ECL data with any third party,
regardless of whether the third party is licensed as a retail supplier
As previously reported, Columbia Gas of Pennsylvania, Inc. previously stated that it 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.
See more background here
Issues concerning certain affiliate arrangements related to the Pivotal Billing Agreement, as well as "on-bill" billing issues, would not be adjudicated in the rate case's recommended decision, and remain pending in separate PUC proceedings (Pivotal is not an affiliate of Columbia, but Columbia Gas of Pennsylvania has sought approval from the Pennsylvania PUC in a separate proceeding for an affiliated interest "arrangement" between Columbia Gas of Pennsylvania, Inc. and its affiliate NiSource Development Company, Inc. as part of implementing the intended Pivotal marketing)
Docket R-2025-3053499
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October 3, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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