Prohibition Order 1 Ineligible Customer Lists & Customer Blocks (Update)

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Prohibition Order 1 Ineligible Customer Lists & Customer Blocks (Update) In compliance with Prohibition Order, National Fuel Gas Distribution Corporation ( Distribution or Company ) provides each

1 Prohibition Order 1 Ineligible Customer Lists & Customer Blocks (Update) In compliance with Prohibition Order, National Fuel Gas Distribution Corporation ( Distribution or Company ) provides each ESCO with a list of its customers that it is no longer eligible to serve. These files are updated every Sunday to reflect any additions (ESCO customers that become ineligible for service) and subtractions (ESCO customer deenrollments). Additionally, blocks have been placed on the accounts of ineligible customers. If an ESCO without a waiver to serve ineligible customers submits an EDI enrollment transaction for an ineligible customer, the Company will respond with an EDI enrollment rejection response. The EDI rejection code will be CAB Customer Account Block. The file, Ineligible ESCO Customer Report (file J2), is a semi-colon delimited flat-file ( Web File ) available from the Company s web site on the Services For Marketers, Producers & Suppliers web page at: Access to the file is password-secured; to retrieve the file ESCOs should click on the Supplier / Customer Download Files link (shown below): 1 Case 12-M-0476 et al., Order Adopting a Prohibition on Service to Low-Income Customers by Energy Service Companies (Issued and Effective December 16, 2016) ( Prohibition Order ). 1 Prohibition Order Compliance Plan - October 5, 2017

2 The file layout is as follows: Ratepayer Number (RBA) Ratepayer Last Name Ratepayer First Name Ratepayer Middle Initial Commodity Ineligible ESCO Customer Report (file J2) 9 ch 20 ch 12 ch 1 ch 1 ch In compliance with Ordering Clause 6 of the Prohibition Order: Electric and gas distribution utilities that have tariffed provisions providing for retail access are directed to, on a rolling basis, communicate to each energy service company serving customers who subsequently become assistance program participants which accounts the ESCO is no longer eligible to serve by sending an updated list of such accounts... Distribution will provide each ESCO with an updated list of its customers that it is no longer eligible to serve on a weekly basis unless that ESCO has applied for a waiver to serve low income customers. The Company will make the initial J2 file available on July 26, At this time, the Company will prevent ESCOs from enrolling ineligible customers, in compliance with Ordering Clause 1: Electric and gas distribution utilities that have tariffed provisions providing for retail access are directed to, within 60 days of the effective date of this Order, place a block on all assistance program participant accounts, preventing those accounts from being enrolled with an energy service company. While ESCOs will be prevented from enrolling ineligible customers, the ESCO currently supplying the customer will continue to serve the customer until such time as the customer is de-enrolled by the ESCO and is supplied by the Company s sales service. ESCOs de-enroll customers by submitting an EDI Drop transaction (814D). Consistent with the timing provisions of the Uniform Business Practices, the customer will begin sales service on the next available scheduled switch date corresponding to the customer s billing portion (cycle). 2 Prohibition Order Compliance Plan - October 5, 2017

3 Frequently Asked Questions (FAQs) 1) Will the Company notify ESCO customers that they are ineligible for ESCO service? Yes consistent with Ordering Clause 5 of the Prohibition Order the customers identified in each ESCO s initial J2 file will receive a letter from the Company informing them that they will be returned to utility service. 3 Prohibition Order Compliance Plan - October 5, 2017

4 2) Which customers are included in the J2 file? Current and pending ESCO customers that are no longer eligible for ESCO service in accordance with the New York State Public Service Commission s Prohibition Order. 3) Will the Company automatically switch customers included in the J2 file to sales service? No ESCOs must submit an EDI Drop transaction (814D) to initiate the process of switching the customer to sales service. 4) Will the J2 file be a comprehensive list, i.e. contain a list of all ineligible National Fuel customers? No a separate J2 file will be prepared for each ESCO consisting only of customers served by the ESCO. 5) How often will the J2 file be created? The J2 file will be updated on a weekly basis; available each Monday. 6) How long will each weekly J2 file be available? The J2 file will have a retention period of 93 days from its creation date. 7) How will the J2 file change from week to week; are customers ever removed from the list? As ESCOs drop ineligible customers, they will be removed from the list. Additionally, if a customer included on the list becomes eligible for ESCO service, they will no longer be included in the list. 8) Can ESCO customers be added to the list? If an ESCO customer that was previously eligible for ESCO service becomes ineligible for ESCO service, they will be added to the J2 file. 9) If an ESCO has a pending customer added to the list, can that enrollment be cancelled before ESCO service begins? If so, how is this done? Yes consistent with existing business practices applicable to all customers, the ESCO should submit an EDI Drop transaction. The Company s system will match the drop transaction to the pending enrollment and cancel the switch. 4 Prohibition Order Compliance Plan - October 5, 2017

5 10) Will the Company notify ESCO customers added to the list that they are now ineligible for ESCO service? Yes consistent with Ordering Clause 8 of the Prohibition Order, the Company will send a letter to customers added to an ESCO s J2 file informing them they are no longer eligible for ESCO service. 11) Will the Company notify ESCO customers removed from the list that they are now eligible for ESCO service? No the Prohibition Order does not direct or address such notification. Further, the Company believes it more appropriate for the ESCO to notify such customers directly. 12) Will the J2 file contain only the customers with changed eligibility status? No the J2 file is a status report; ESCOs may determine which customers become eligible or ineligible by comparing the accounts included in consecutive weekly files. 13) Will the J2 file contain information the ESCO can use to contact customers? Not directly the ESCO may relate the account number in the J2 file to customer contact information in its own databases or to the J0 file. 14) Will the Company provide notification when a new J2 file is created? No since the J2 file will be prepared on a scheduled basis (prepared each Sunday), the ESCO is expected to check for a new file each week. 15) Will the J2 file change every week? Not necessarily while a new J2 file will be created each week, it is possible that the list will be unchanged in consecutive weeks. 16) Will ESCOs always receive J2 files? So long as ESCOs are serving ineligible customers, J2 files will be prepared. ESCOs should continue to check these files on a weekly basis because it is possible that previously eligible customers may become ineligible for ESCO service. 5 Prohibition Order Compliance Plan - October 5, 2017

6 17) Will the J2 file contain Pennsylvania customers? No the Prohibition Order only applies to National Fuel s New York service territory. 18) Why would pending enrollments for ineligible customers be included in the J2 file? Ineligible customers would be included in the J2 file if an enrollment transaction is received before the customer becomes ineligible, i.e. while the customer was eligible for ESCO service. 19) What will happen when an ESCO attempts to enroll an ineligible customer? The enrollment will be rejected; an EDI Rejection Response will be provided to the ESCO with the code CAB Customer Account Blocked. 20) Will the Company inform the customer that the enrollment was rejected? No. 21) Will the EDI Rejection Response identify the customer as ineligible for ESCO service? Yes but the rejection response does not necessarily mean that the customer is ineligible due to reasons specified in the Prohibition Order. 22) Will the EDI Rejection Response differentiate between an enrollment block due to customer ineligibility and a customer-initiated enrollment block? Yes. A customer-initiated block will be rejected with the code CAB. If, however, an ineligible customer has a customer-initiated block, the response the rejection code ANE will be provided. 23) How can an ESCO find out if the if the enrollment block is due to customer ineligibility or customer-initiated? The ESCO may contact the customer directly. If the block is customer-initiated, consistent with current procedures, the customer may ask the Company to remove the enrollment block and resubmit the enrollment request. Do not call the Company; to protect customer privacy the reason for the customer block will not be divulged. 24) If the enrolling ESCO contacts the Company, will the Company tell the ESCO if the enrollment block was due to customer ineligibility or a customer-initiated enrollment block? No. 6 Prohibition Order Compliance Plan - October 5, 2017

7 25) Will the J2 File include customers with customer-initiated enrollment blocks? Not specifically. A customer might have an enrollment block because it is ineligible for ESCO service and a customer-initiated enrollment block. 26) If a customer with enrollment block because it is ineligible for ESCO service and a customerinitiated enrollment block has customer-initiated enrollment block removed, can the ESCO enroll the customer? No. The enrollment block in place because the customer is ineligible will remain in place. 27) What is the process for the Company to reclassify a customer that is ineligible for service as eligible? Each November, the Company reviews the status of customers in its low income programs to verify that that the customer received a HEAP grant for the prior HEAP plan year. For example, in November 2018 the Company will check to see if a HEAP payment was posted to an account from November 1, 2017 through October 31, A customer who did not receive a HEAP during the prior HEAP Plan Year will be removed from the program and the enrollment block will be removed because the customer will be eligible for ESCO service. Note that if a customerinitiated was in place for the customer s account, that enrollment block will remain in place. 28) What is the process for the Company to reclassify an eligible customer as ineligible for ESCO service? The Company reviews bills on an ongoing basis to see if HEAP payment was posted to the account. If so, and the customer was not already ineligible, the customer will reclassified as ineligible, an enrollment block will be placed on the account and the account will be added to the J2 file. 29) When an ESCO submits an 814 EDI Drop for a customer included in the J2 file, how long before the customer is switched from ESCO service? The Drop will be processed consistent with the timing specified in the UBPs so generally between 15 and 45 calendar days. If the EDI Drop is received more than 15 calendar days before the next scheduled switch date, the switch will occur on that date. Otherwise, the customer will remain with the ESCO for one more month and begin utility sales service on the scheduled switching date following the additional month of ESCO service. 30) Will J2 files for the ESCOs that have waivers to serve low income customers be prepared? Yes. ESCOs with waivers should us the J2 file to determine which customers must be served subject to a price guarantee. 7 Prohibition Order Compliance Plan - October 5, 2017

Table of Contents. Section E: Inspection and Acceptance

Table of Contents. Section E: Inspection and Acceptance Table of Contents Section E: Inspection and Acceptance Section Page E.1 52.252-2 Clauses Incorporated by reference (Feb 1998) 1 E.2 Cutover and Acceptance Testing of Services and Systems 1 E.2.1 Cutover