dbeard@dominionpost.com
MORGANTOWN – West Virginia American Water and state Public Service Commission staff continue to debate paperless billing and whether it should be “opt in” or “opt out.”
WVAW wants to go “opt out” for most of its customers, saying it’s convenient, has been successful in other parent company territories and could save lots of money.
PSC staff say 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 WVAWs request, but WVAW is disputing the order. Both sides now await a PSC decision.
WVAW submitted its request in June. The company said it has 171,000 customers and 44,000 are enrolled in paperless billing. Those customers have opted in – that is, chosen to enroll in the program.
It estimates 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.
PSC staff continues to maintain 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.”
WVAW counters that only those customers who already interact with the company through the MyWater portal will be enrolled. Those who have chosen not to interact electronically or lack the meas to do so will not be enrolled. And customers who were enrolled but want to withdraw can do so by phone if they lack other means.
Both sides discuss a case where Frontier wanted to start a similar program and imposed a $2.99 monthly paper billing fee, the PSC determined that was unjustly discriminatory to seniors and those unfamiliar with paperless billing.
Staff argues that while there is no fee involved in the current case, the principle remains the same and PSC’s Frontier order applies here. WVAW counters, “Unlike the program in the Frontier case, the company’s Paperless Program will not increase any customer’s bill but instead has the potential to produce cost savings for all customers.”
WVAW adds, “customers enrolled in paperless billing often experience increased satisfaction given that paperless billing is secure, convenient, clutter free, easily accessible, and will allow customers to receive their bills 2-3 days sooner. … Other American Water affiliates have implemented similar programs in other jurisdictions without issue.”
WVAW said it is willing to implement a 12-month pilot program. Staff echoed its previous thought that those who want paperless have already opted in and no one should be forced through hoops to opt out.
The administrative law judge, in his recommendation, said he “agrees with staff that a utility program that automatically enrolls West Virginia customers into online billing should be considered an unreasonable practice, notwithstanding the multiple safeguards WVAWC offered. [The ALJ] does not believe that this conclusion would be altered by WVAWC’s offer of a 12-month trial program.”
