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Duquesne Light Seeks Waiver To Use Email As Means Of Sending Eligible Customer List Opt-Out Notice For Larger Group Of Customers

Notes Potential For Higher Customer "Engagement" With Customer List Opt-Out Notice

November 2, 2020

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Reporting by Paul Ring •

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Duquesne Light Company petitioned the Pennsylvania PUC for a waiver to allow it to send the triennial Eligible Customer List (ECL) opt-out notice via electronic means to a larger group of customers than done currently

The next triennial ECL solicitation will occur in the first quarter of 2021. These solicitations provide customers an opportunity to restrict the inclusion of their information in the ECL, which is provided to retail suppliers. Customers who do not respond to a solicitation are automatically included in the ECL unless they otherwise request to be excluded.

Duquesne Light said that EDCs traditionally serve the ECL solicitation on customers via a hard-copy mailing, except for those customers who have opted to receive their bills via electronic means (e-billing customers), whom EDCs are permitted to serve electronically.

Duquesne Light is seeking the Commission's authorization to initially serve the 2021 ECL solicitation via electronic means on customers who have consented to receive electronic communications from Duquesne Light, in addition to e-billing customers

Duquesne Light said that the PUC's ECL Order does not mandate specific means of service for the triennial ECL solicitations, but cited language in the ECL Order which suggests that customers who have not opted to receive e-bills should be served the ECL solicitation via non-electronic means.

Duquesne Light proposes to initially serve its 2021 ECL solicitation via email to all "e-communication customers" in addition to e-billing customers.

E-communication customers are those residential customers who have not signed up for e-billing, but who have otherwise voluntarily provided their emails to the Company and have consented to electronic communications with the Company.

Duquesne Light has approximately 540,000 residential customers. Of these, approximately 115,000 are enrolled in electronic billing. An additional 200,000 are e-communication customers

Duquesne Light uses email to communicate with e-communication customers for several service-related purposes, including: High usage alerts; Weekly usage updates; Energy efficiency tips; Safety tips and storm preparedness; and Energy Assistance program information

"All of the Company's emails to e-communication customers include a link by which customers can unsubscribe from future emails from the Company. In practice, customers seldom unsubscribe; the Company's customer email opt-out rate is currently only about 0.1%," Duquesne Light noted

In terms of the ECL email, Duquesne Light said, "The email will clearly state – in its subject line and in multiple places within the email – that the customer is expected to respond. Additionally, the Company will send a second email to all e-communication and e-billing customers who do not open the initial email. Where the ECL solicitation email to a customer is returned as undeliverable, or where the customer requests a hard-copy ECL solicitation, the Company will send an ECL solicitation to the customer via standard mail."

"The Company's proposal to expand electronic service of the 2021 ECL solicitation advances the public interest because it will (1) better align the ECL solicitation method with customer expectations and preferences; (2) enable enhanced solicitation tracking and messaging; and (3) substantially reduce the costs of the solicitation borne by customers," Duquesne Light said

"Expanded e-service is consistent with evolving customer expectations, particularly for those customers who have already made the choice to engage with the Company via electronic communication. Ninety-one percent of Americans check their email at least daily, and as noted above, more than half of the Company's residential customers have already opted to receive email communications from the Company. Electronic communication is increasingly becoming customers' “default” communication method, particularly during the COVID-19 pandemic, during which many entities (including the Company and the Commission) have largely transitioned to telework," Duquesne Light said

"Electronic service of the ECL solicitation also facilitates customer engagement. All customers, regardless of how they are served the ECL solicitation, have the option of responding via the Company's website, telephone, or mail. For those customers who tend to prefer to engage electronically – such as e-communication customers – it is simpler to respond to the ECL solicitation by clicking a link in an email, rather than typing a URL into their internet browser. The Company therefore expects that increased electronic service may yield a higher overall customer engagement rate," Duquesne Light said

"The Company estimates that serving e-communication customers via email instead of hard-copy mailing will save approximately $100,000 in printing and postage costs, thereby reducing the Company's revenue requirement in future base rate proceedings. Moreover, to the extent expanded electronic service leads to a corresponding shift in how customers respond to the solicitation, it may also reduce the Company's back-office costs of processing hard-copy customer responses," Duquesne Light said

Docket P-2020-3022674

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