MORGANTOWN — State Public Service Commission staff has concluded that a request from West Virginia American Water to transfer nearly all of its customers to paperless billing is unreasonable and unjustly discriminatory and has recommended that the PSC deny the request.
Utilities Division staff, legal staff and financial staff all agreed, with financial staff saying, “Financial staff believes forcing people into a program that may not be aware that it has taken place is an unreasonable practice, and, based on the commission’s [order in a separate case] is considered unjustly discriminatory.”
Staff issued its recommendation on Monday. WVAW submitted its request on June 7. The company said it has 171,000 customers and 44,000 are enrolled in paperless billing. It initially estimated another 60,000 would be eligible to switch over, then increased that to 65,000.
Based on the initial number, WVAW said the move could save it $490,000 in annual print and postage costs, if all of them enrolled.
WVAW said, “The Paperless Program … will facilitate, provides a cost-efficient means of bill delivery and offers conveniences for both customers and the company.” According to WVAW’s parent company’s most-recent customer feedback survey, 70% of customers experienced increased satisfaction by receiving electronic bills.
The parent company, American Water, has similar programs in other states, WVAW said. “Paperless billing is a robust, effective program as evidenced by the company and its affiliates having enrolled over 1.2 million customers currently on paperless billing already.”
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.
Staff noted several problems with the proposal. One, when 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.
Two, having a MyWater account doesn’t mean the customer uses it regularly. They may have registered to pay a late bill or avoid termination. Having the account and an email doesn’t mean someone wants to always do business that way.
And three, many people have secondary or multiple email addresses and use the secondary addresses to avoid ads and spam in their main accounts. “Customers may supply an email address, but it could be an email address that is only used when necessary and never looked at for months on end. Utilities staff also notes that most people, unless it is a bill, will not give mail from a utility the necessary attention it may need, but rather just glaze over it, or not open the mail at all.”
Utilities staff said some WVAW customers are not technologically savvy to understand the email and be able to follow the directions to opt out. And customers have been given ample opportunity to opt in but some have chosen not to.
The proposal now awaits the PSC’s decision and order.
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