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Retail Suppliers Say, In Misalignment, New Rule Language Requiring Customer Signature Applies To All In-Person Gas Sales, While, For Electricity, New Rule Is Narrowly Limited To Mass Market Sales
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The Retail Energy Supply Association said that revised new rule language adopted by the PUC of Ohio on rehearing creates a misalignment in the types of customers from which retail suppliers must obtain a signature, with the new electric rule applying the signature requirement only to residential and small commercial customers, but with the new natural gas rule containing no such limitation based on customer type
The rule language concerns implementation of a form of enroll-by-wallet, in which a retail supplier may enroll a customer by verifying the customer's identity, using one of the three options below to verify such (electric rule quoted, similar language was adopted for gas):
(D)(1) "Customer account information," as that term is defined in division (A) of section 4928.103 of the Revised Code [Ed. note: 4928.103 states that "customer account information" means a unique electric distribution utility number or other customer identification number used by the utility to identify a customer and the customer's account record];
(D)(2) A valid form of government-issued identification issued to the customer; or
(D)(3) A sufficient alternative form of identification that allows the CRES [retail electric] provider to establish the customer's identity accurately
The process generally allows a retail supplier to use a customer's approved ID as authorization for the supplier to obtain, for the purposes of enrollment, the customer's account number from a utility's eligible customer list, and to then enroll the customer using such account number
See more background here
Under PUCO's rehearing order, retail suppliers were, for "direct solicitations" only, ordered to obtain a customer's signature acknowledging that the supplier verified the customer's identity. This requirement to obtain a customer's signature acknowledging that the supplier verified the customer's identity is not required for telesales or internet enrollments
However, RESA said that, based on the structure of the existing rules and where this new signature requirement was placed, the electric and gas rules differ as to the provision's applicability
RESA said that, for electricity, the new signature language is within a section of the rule limited to residential and small commercial enrollment
However, for gas, RESA said that the applicable section of the rule contains no limitation applying the rule language to only residential and small commercial enrollment. Rather, as inserted into the gas rule, the new signature requirement would apply to all natural gas customer enrollments
RESA said having the applicability of the signature requirement differ based on the commodity which is being sold would create confusion
RESA also said that creating a different requirement based on commodity type is not justified, nor was any intent by PUCO to create such a disparate treatment contained in PUCO's order on the rule
RESA requested that PUCO limit the new gas signature requirement to residential and small commercial enrollments, to mirror the electric rule
RESA, noted, however, that RESA would also not oppose elimination of the new signature requirement in its entirety
Case 25-729-GE-ORD, 25-0729-GE-ORD
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May 29, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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