dbeard@dominionpost.com
MORGANTOWN – West Virginia American Water’s quest to channel most of its customers into paperless billing has failed – with the Public Service Commission this week denying the request WVAW put forth last June.
WVAW wanted to turn its “opt in” paperless billing option to “opt out,” saying it’s convenient, has been successful in other parent company territories and could save lots of money.
But PSC staff said the proposal is unreasonable under state code and could potentially harm customers who are less tech savvy or lack connectivity, by effectively forcing them into a billing method they may not understand or want. An administrative law judge sided with PSC staff and denied WVAW’s request, but WVAW disputed the order.
The PSC said in its Wednesday order, “The commission understands and appreciates the benefits of paperless billing that the company has outlined in this case. … However, paperless billing should continue to be an affirmative or ‘opt in’ choice for utility customers in West Virginia.”
The PSC said WVAW should focus on other methods to encourage customers to choose paperless billing and to promote the benefits it believes come with paperless billing. It should consider incentivizing enrollment in paperless billing by offering a fair discount to customers who enroll.
During the course of the case, WVAW said it has 171,000 customers and 44,000 are enrolled in paperless billing.
It estimated another 65,000 would be eligible to switch over to paperless. Customers eligible to be automatically enrolled would be those who have a valid email or text contact on file and are registered on WVAW’s “MyWater” portal. The company would send several notices to them announcing the automatic enrollment and provide an online link to opt out, followed by a mail notice with another opt-out opportunity.
Low-income customers and those who have a “do not solicit” flag on their accounts would not be included. WVAW said the move could save it $490,000 in annual print and postage costs, if all eligible customers enrolled. In the face of PSC staff opposition, it offered to launch a 12-month pilot program.
PSC argued that the program is unreasonable, flawed and poorly supported. A customer who has a MyWater account doesn’t necessarily use it or ever wants to use it. Many people have secondary email accounts they rarely access. And WVAW has customers without reliable internet.
Staff said it “believes that customers who did not ‘opt in’ should be burdened with the task of having to jump through hoops to ‘opt out’ of a program that they have already rejected.”
Central to the case was a prior case where Frontier wanted to start a similar program and impose a $2.99 monthly paper billing fee, which the PSC determined was unjustly discriminatory to seniors and those unfamiliar with paperless billing. Staff argued that while there is no fee involved in the WVAW case, the principle remains the same and PSC’s Frontier order applies here.
WVAW countered that since no feel is involved, the Frontier case was irrelevant.
The administrative law judge said in his December decision that the Frontier case applied, and utilities should “encourage” customers to opt in, and that WVAW’s automatic enrollment with an opt out was unreasonable, despite the safeguards the company proposed.
In its order, the PSC directed WVAW to file a report in six months indicating how many additional customers have enrolled in paperless billing. And it reminded the company that it may not impose a fee for paper bills.
