Retail Supplier Asks PUC To Order Utilities To Cease Use of Separate "Customer Number" for Enrollments in Addition to Account Number

Ethical Electric, Inc. has asked the Pennsylvania PUC to require the FirstEnergy electric distribution companies, "to eliminate the use of the duplicitous [sic] and burdensome 'customer number' and instead use only the customer's account number for EGS enrollment."

Ethical Electric's request was made in comments regarding the addition of a "shopping information box" on utility consolidated bills.

"The customer numbers used by the FirstEnergy Companies are particularly problematic, as the Commission noted in the Tentative Order. These customer numbers are duplicative and anti-competitive, causing customer confusion and frustration, and should be eliminated rather than merely presented in a more conspicuous place on the customer bill," Ethical Electric said.

"The FirstEnergy Companies' use of the customer number instead of the account number convolutes the enrollment process in three ways: (1) customers confuse the customer number with the account number; (2) the customer number is hard for the customer to find - it is located in the middle of the bill in small font, as opposed to the account number, which is bolded and located at the top of the bill; and (3) the customer number is much longer than the account number, increasing the likelihood of human error in communicating the customer number to an EGS for enrollment," Ethical Electric said.

"Ethical Electric has seen significantly lower enrollment levels from FirstEnergy customers relative to other Pennsylvania EDCs over the last seven months that Ethical Electric has been marketing to Pennsylvania's seven major utilities. Despite consistent direct marketing campaigns across all the EDCs, Ethical Electric's enrollment levels for FirstEnergy customers have been significantly lower than for Pennsylvania Power and Light Co., Duquesne Light Co., and PECO. In fact, while Ethical Electric has comparable response rates across all seven EDCs, the enrollment rate for FirstEnergy responders averages a staggering 50% lower than responders from other EDCs. There are two primary reasons for this enrollment rate disparity. First, many customers fill in their account number on their enrollment form and not their customer number. Second, many customers incorrectly transpose one of the digits in the unnecessarily lengthy customer number," Ethical Electric said.

"Ethical Electric's efforts to alleviate these problems have proven unsuccessful. For example, Ethical Electric specifically asks for the customer number and includes twenty boxes on its enrollment form - the exact number of characters in the customer number- for the customer to insert his or her own customer number. The lower enrollment numbers referenced above remain despite these efforts, underscoring the need for the Commission to simplify enrollment by eliminating the use of the customer number," Ethical Electric said.

"Ethical Electric provides a model bill image on its website, highlighting the customer number, for customers to reference when enrolling. Even with this reference, customers still have difficulty distinguishing the customer number from the account number. Ethical Electric frequently receives complaints from potential customers frustrated with the enrollment challenges use of the customer number causes them," Ethical Electric said.

"Compounding the lower enrollment rate problem, Ethical Electric's cost per enrollment for FirstEnergy customers is well over twice that of other EDCs. This is significantly outside of the range of a normal variance. Ethical Electric attributes this immense disparity to the requirement that FirstEnergy customers enroll using their customer number instead of their account number, the norm for other EDCs. Further, many of the responders who fail to successfully enroll are providing their account number and not their customer number, either online or in direct mail. This is a clear indicator of customer confusion," Ethical Electric said.

"[I]ncluding the customer number in a Shopping Information Box will not adequately address the enrollment problems caused by use of the customer number," Ethical Electric said. "Customers are generally not accustomed to having more than [one] account-identifiable number in other commercial transactions that they encounter daily. Customers have one credit card number per account, one bank account number per account and one driver's license number. Logically, customers assume that their account number should be sufficient for a switch because that is their experience in other commercial transactions," Ethical Electric said.

"The ultimate anti-competitive impact of use of the customer number is difficulty enrolling customers without intervention by a sales person through either telemarketing or door-to-door methods. Use of the customer number makes direct mail and Internet sales more difficult. Telemarketing and door-to-door sales methods are consistently the biggest drivers of customer complaints about marketing and increase costs for competitive suppliers. Enhancing the viability of less intrusive and less expensive marketing channels will benefit customers by enabling competitive suppliers to focus on such channels, thereby discouraging alternate channels with higher costs and customer complaint rates," Ethical Electric said.

"If the customer numbers are not eliminated, they will continue frustrating Pennsylvania customers' efforts to access the benefits of competitive retail supply," Ethical Electric said.