Pa. PUC Seeks Further Comment On Accelerated Gas Switching Issues, Including Treatment Of Capacity, Need For Two Elements In Verifying Enrollments

The Pennsylvania PUC has issued a request for additional comments regarding its proposal for accelerating natural gas switching, under which the PUC is proposing that natural gas supplier switches be completed within 3 business days from submission of the switch

The PUC noted that the current rule at 52 Pa. Code § 59.93(1) requires that when a natural gas supplier (NGS) transmits an enrollment to the natural gas distribution utility (NGDC), that the, "NGDC shall verify the accuracy of the information provided by the NGS by matching at least two data elements such as name and account number, or address and account number, with NGDC records."

The PUC noted that this requirement is not found in the analogous electric supplier switching regulation (see 52 Pa. Code §§ 57.172-174)

Further, PECO said in comments that it has not encountered problems using only one data element - the account number. Accordingly, PECO has asked that flexibility be provided to allow the switching of accounts based upon only one element. The PUC invited parties to comment on this issue, "especially concerning any issues with the exchange of account data between suppliers and NGDCs that may be impacted by any change."

Additionally, the PUC noted that parties, in their comments, discussed whether the NGDC should act as a 'clearinghouse' to address capacity assignment in an off-cycle switching environment, with some voicing caution while others believing that the concept is workable. The PUC invited further comments on this matter

The PUC noted that as an alternative to off-cycle switching, National Fuel Gas Distribution proposed that natural gas distribution companies have the option to affect the switch retroactively to the last meter read used for billing.

"We invite parties to comment on this proposal, including any technical or customer-related issues they identify. Additionally, we are interested in the analysis of the costs and possible cost-savings that a 'retroactive' switch procedure may provide in comparison to the possible costs of off-cycle switching," the PUC said

The PUC noted that in the analogous electric switching regulations (see 52 Pa. Code §§ 57.171 – 180), there is no limitation on the number of off-cycle supplier switches a customer may make within a single billing cycle.

"However, for NGS switching, some parties have proposed that if off-cycle switching is required, that it be limited to one off-cycle switch per billing period. We invite parties to comment on the benefits of such a restriction – especially as it relates to costs compared to unrestricted off-cycle switching. Parties are also invited to comment on any possible consequence of such a restriction – especially possible impacts on consumers," the PUC said

Docket L-2016-2577413