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UI, CL&P Say Mid-Cycle Enrollments Not Feasible
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March 3, 2011
United Illuminating and Connecticut Light & Power said that they cannot accommodate mid-cycle supplier enrollments, contrary to the findings contained in a Connecticut DPUC draft decision concerning supplier marketing (10-06-24).
As only noted in Matters (see 2/21), a draft DPUC decision would require the electric distribution companies (EDCs) to establish procedures that will allow customers to switch suppliers, and begin to be billed under the 'new' supplier's price, within seven business days of receiving the change order from that supplier.
United Illuminating said that the provision for mid-cycle enrollments, "(i) is not capable of being accomplished, (ii) is not supported by the record evidence, and (ii) was, in fact, not a matter that was the subject of this proceeding."
"What the Draft requires simply cannot be performed by the Company. There are no systems in place to accommodate mid-cycle supplier changes. The EDC-supplier relationship functions through the Electronic Data Interchange ('EDI') process. There is no EDI process in place to accommodate mid-cycle enrollments. A manual process would obliterate all of the efforts of the EBT working group that arrived at streamlined EDI transactions and processes that work," UI said.
Likewise, CL&P said that, "the fact [is] that functionality simply does not exist in CL&P’s current system to accommodate mid-cycle enrollments without a substantial and costly overhaul of CL&P’s technological systems, as well as that of EBT transactions and programming."
"For CL&P to manually perform mid-cycle enrollments for almost 500,000 customers is wholly and purely impractical from a resource allocation and programming perspective," CL&P said.
CL&P also objected to mid-cycle supplier price changes (which do not include a change in supplier), stating that, "[m]ultiple mid-cycle price changes would be extremely laborious and would saddle CL&P with an additional expense of resources and administrative time each time a supplier submits a request."
Both UI and CL&P also opposed the draft requirement to require the Standard Service price to be listed on all customer bills.
UI noted that there is no one Standard Service generation price, as customers may elect a time of day rate, and said that listing all Standard Service prices in addition to the competitive supplier's price would be confusing. UI also said that it has not determined if and how it could accommodate listing such Standard Service information on migrated customers' bills.
CL&P called listing Standard Service rates "unnecessary," and said that it, "would only serve to cause further confusion to customers."
Suppliers raised a number of exceptions to the draft decision, most of which were previously raised in initial comments and need not be repeated here. Generally, suppliers object to the application of various marketing standards in the draft to all customer classes, and suggested limiting the application to customers under 50 kW. In particular, suppliers said that the draft would apply a three day right of rescission to all customers, despite the statutory limitation on the right of rescission to customers under 500 kW.
The Retail Energy Supply Association also said that participation on the CT Energy Info rate board should remain voluntary, as requiring all rates to be listed, even complex rates generally not marketed to the mass market, will add more products to the rate board and make it more confusing for customers to navigate.
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