California Demands ‘Click-Through’ Customer Service for Distributed Energy Aggregators

Getting rid of the forms and “wet ink” signatures standing between customers and grid edge participation.

Everyone knows it's a lot easier to buy a product or service without filling out a lot of forms, even if they're the relatively simple, auto-fillable kind. Now, imagine having to look up an account number you didn’t even know you had, print and fill out a four-page form, sign it in “wet ink,” and send it in every time you signed up for a product or service online.

It’s not a recipe for mass-market adoption, that's for sure -- but it’s the kind of onerous process that utilities impose on customers trying to sign up with third-party energy services providers.

Even in California, with its mandate for distributed energy integration, the state’s big utilities have been requiring customers to jump through these kinds of hoops before enrolling with third parties for the state’s new demand response auction mechanism (DRAM) pilot. 

All that changed this month, however, with a California Public Utilities Commission decision ordering Pacific Gas & Electric, Southern California Edison and San Diego Gas & Electric to drop signature requirements and dreaded customer information service request (CISR) forms.

Instead, utilities are to move to a “click-through” process that begins and ends on the third party’s website or mobile app -- and that's a big deal, according to the smart thermostat and home energy management crowd.

“This is a really boring topic,” said Michael Murray, chief technology strategist with industry group Mission:Data in an interview this week. “But it’s so fundamental to how we get to high-penetration” distributed energy resources -- smart thermostats, behind-the-meter batteries, plug-in electric vehicles and other customer-sited energy assets that can shift and shave energy consumption at times of peak grid demand. 

Simply put, customers used to Mint.com-style banking and instant online purchasing aren’t going to follow through on a process that requires the steps now required by California’s investor-owned utilities, he said.  

“You could have the coolest demand response system or Green Button Connect system in the world, but if the process by which customers sign up is clumsy or inefficient, it doesn’t matter,” he said. “The biggest thing is satisfying customer expectations -- ‘I want an app; I want it now.’”

This observation is backed up by evidence, he noted. For example, EnergyHub, one of the country’s largest smart thermostat-based residential demand response providers, told the CPUC that it has only seen about 3 percent of eligible customers enrolling for its DRAM offering in California, compared to about 40 percent for similar programs it has run in Texas.

That’s due to two main bottlenecks. The first is the requirement for customers to provide their utility account numbers, a relatively obscure piece of data that most people don’t have on hand. Only about 9 percent of customers actually follow through with that requirement, which isn’t needed in Texas, EnergyHub wrote in its white paper. Utilities could get around that by using EnergyHub’s software “to uniquely identify customers as part of the utility's behind-the-scenes enrollment processing." 

The second is the CISR form, or in this case, a special “CISR-DRP” form, along with the DocuSign requirement that PG&E had in place. That winnows out another 5 percent or so, and “aggregators/DRPs have not been allowed to modify the form’s inaccessible language to be more colloquial and comprehensible for customers or anyone who is not a lawyer,” it wrote.

EnergyHub isn’t the only would-be DRAM provider struggling with the procedures California utilities have put in place.

“Unlike the utility, we don’t have millions of customers,” said Cole Hershkowitz, CEO of startup Chai Energy, which has pledged to enroll a megawatt of energy-responsive household load under the DRAM program. “We pay a certain amount of money to get customers interested in Chai, and there’s pretty significant customer conversion funnel in getting them enrolled with the CISR issues we’ve faced.”

Some utilities are further ahead than others, he noted. For example, for every customer Chai signs up under PG&E’s process, which requires a DocuSign-authorized form, it gets eight through SCE’s Green Button Connect platform, which allows third parties and customers to complete enrollments online.

In the long term, the energy services companies want to move away from forms altogether. In a joint filing last year, demand response providers OhmConnect, EnergyHub and Comverge asked the CPUC to push for a “streamlined and fully electronic process” for the DRAM program, which is seeking to get more than 40 megawatts of resources up and running over the next two years.

In its decision, the CPUC dismissed the utility arguments that they needed “wet ink” signatures and outside verification from customers to meet state regulations regarding utility customer consent. It also cut down on various red-tape issues -- PG&E won’t be able to require customers to DocuSign their applications, for example, and SCE won’t be able to require customers to fill out forms independently of the third-party DRAM provider.

The CPUC’s ruling only applies to the DRAM program, at least for now. Even so, smoothing out the enrollment process should help utilities meet the pilot program’s targets, Murray noted. The CPUC set 2017 targets at 40,000 customers for PG&E and 30,000 apiece for SCE and SDG&E, and authorized spending of $5.4 million for PG&E, $2.3 million for SDG&E, and $1.254 million for SCE to get there.

Beyond that, “I think it sets a nice precedent” for guiding customer enrollment issues in other CPUC proceedings that are looking at ways to open up grid markets and services for customers and third-party aggregators, he said. It’s also a helpful model to take to other states, such as Illinois, that are deep into the same issues of customer access, he said.