Pennsylvania PUC Drops Customer Education Mailing for 2013

The Pennsylvania PUC has officially dropped a customer education mailing about electric choice, consisting of a postcard regarding the PA Power Switch website, for 2013.

The PUC ordered the re-establishment of an annual mailing of the PA Power Switch postcard beginning in 2014. Specifically, the PA Power Switch postcard shall be mailed annually by the EDCs between January 1 and June 30 of each calendar year starting in 2014.

The suspension of the PA Power Switch postcard mailing for 2013 was first proposed in December 2012, and no opposition was filed. The suspension was proposed in light of delays in other PUC-directed customer education mailings, and the presence of other direct mail concerning retail supply that was expected to be received by customers, in order to prevent customer resentment resulting from a potential inundation of retail choice direct mail.

Specifically, the Commission had previously moved back the mailing of a PA Power Switch tri-fold flyer from May 2012 until November 2012, but no later than February 2013 for some EDCs, and the mailing of an EDC choice letter/FAQ from October 2012 until 2013.

However, it should be noted that comments on the suspension of the PA Power Switch postcard mailing were filed prior to the PUC's indefinite suspension of the retail opt-in aggregation programs, which would have consisted of direct-mailed retail supply offers to all default service customers in eligible customer classes (generally, small volume customers). Accordingly, a significant piece of retail choice direct mail expected to be received by customers when the delay of the PA Power Switch postcard was first proposed will no longer be sent out.

The PUC has proposed no timetable for reconsideration of the opt-in aggregation programs. However, now a potential start of the programs in early 2014 would be open to criticism that the customer would be inundated with confusing mailings, and that either the aggregation programs, or PA Power Switch postcard, must be further delayed or suspended.

While such a concern may seem trivial, it's no more invalid than the PUC's adopted reasoning of potential customer confusion in suspending the one-time marketing and June 1, 2013 start of the opt-in aggregation programs due to the start -- some two months later in August -- of the Standard Offer referral programs (whether other reasons justified delay of the opt-in aggregation programs is irrelevant in that the PUC did not cite any reason other than customer confusion in its suspension order).

Docket I-2011-2237952