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PPL 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 11, 2020

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Reporting by Paul Ring •

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PPL Electric Utilities Corporation ('PPL', 'PPL Electric', or 'Company') petitioned the Pennsylvania Public Utility Commission’s ('Commission') for a waiver of certain Eligible Customer List ('ECL') solicitation requirements provided under Interim Guidelines for Eligible Customer Lists, Final Order entered October 23, 2014 ('ECL Order'), in order to allow PPL 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 (opt out). Customers who do not respond to a solicitation are automatically included in the ECL unless they otherwise request to be excluded.

As first reported by, Duquesne Light has filed a similar petition with the PUC

Specifically, PPL seeks the Commission’s authorization to initially serve the 2021 ECL solicitation via electronic means on customers who have consented to receive electronic communications from the Company, in addition to e-billing customers.

The PUC's ECL Order does not mandate specific means of service for the triennial ECL solicitations, but language in the order explicitly allows the solicitation to be served electronically to those customers who have opted to receive their bills via electronic means

"By implication, this portion of the ECL Order suggests that customers who have not opted to receive e-bills should be served the ECL solicitation via other means," PPL said

PPL proposes to initially serve its 2021 ECL solicitation via email (or other electronic communication methods according to customer preference) 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 and/or cell phone numbers to the Company and have consented to electronic communications with the Company.

PPL has approximately 1.2 million residential customers. Of these, approximately 400,000 are enrolled in electronic billing. Over one million customers have opted to receive at least one type of electronic communication (email or text) from PPL.

PPL noted that it 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; energy assistance program information; and outage notifications

"All of the Company’s emails to e-communication customers include information how a customer 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%," PPL noted

"The Company proposes to employ the same process for electronically serving e-communication and e-billing customers with the ECL solicitation. Specifically, the Company will email the ECL solicitation to all e-communication and e-billing customers. 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 will also explore sending the ECL solicitation via other methods of electronic communication to match the customer’s preferred method of communication," PPL said

"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," PPL 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. 91 percent of Americans check their email at least daily, and as noted above, 82% 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 businesses (including the Company and the Commission) have largely transitioned to telework," PPL 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 (or other method of electronic communication), 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," PPL said

"Electronic service yields distinct analytical benefits compared to hard-copy service. For example, the Company’s email platform provides real-time alerts when a customer opens an email. These data will help distinguish between those customers who choose not to respond to the ECL, and those who did not receive the ECL solicitation. The data will also help the Company refine its electronic communications to improve customer understanding and engagement," PPL said

"The improved analytics associated with electronic service may also help inform future Commission action, as electronic communication increasingly becomes the norm across industries ... the Company will provide a report to the Commission and stakeholders with an evaluation of electronic ECL solicitation and lessons learned," PPL said

"The Company’s proposal will also produce operational efficiencies and customer savings. The Company estimates that serving e-communication customers via email instead of hard-copy mailing will save approximately $300,000 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," PPL said

Docket P-2020-3022803

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