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Retail Supplier Opposes "Unprecedented" Extension of Switching Timeline Sought By Utility

March 21, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

Choice Energy, LLC objected to the, "unprecedented," application of National Grid in Massachusetts to extend the number of days that a competitive electric supplier must submit a switch, from two to four days prior to the scheduled meter read date, for the switch to occur at the next meter read

In a brief, Choice Energy noted that the two business day rule has been in place continuously in the Commonwealth since the onset of competition, more than 15 years ago.

"Consequently, all Massachusetts suppliers and municipal aggregators have been working with the current two business day standard for as long as they have operated in National Grid's territories in the Commonwealth and, presumably, have devoted time and resources to developing internal processes to accommodate the longstanding two business day period. These processes would need to be changed by all National Grid suppliers and aggregators if this proposal is approved," Choice Energy said

Choice Energy further said that if National Grid's petition were granted, "Suppliers would either have to face disallowance, and at least a one month delay, of an extra two business days of enrollment and termination requests submitted to National Grid or seek to implement new procedures specific to National Grid orders to minimize the potential for running afoul of the additional two business day disallowance period for enrolling and terminating orders in the same month's meter read. Moreover, as was elicited in questions from Department staff, certain enrollments, including enrollments through the Department shopping website, are not amenable to expedited treatment that would allow the supplier move up an order before the extended disallowance period."

As a result of moving the switching deadline forward, Choice Energy said that more customers would have to wait until the next month for their switch to take effect. "This almost-certain increase in the number of customers with delayed enrollments and terminations likely will exacerbate customer dissatisfaction issues with meter reading-based delays that have led the Department in the Docket 14-140 retail rules investigation to seek to add transparency measures in terms of service and electric supplier labels," Choice Energy said

Choice Energy, citing testimony at a hearing, said that National Grid implemented the software changes driving the change for its own reasons without consideration of impacts on customers or suppliers. A National Grid witness testified the software change was made to increase flexibility for National Grid's own staff resources.

"The end result would be to free up additional money for the National Grid shareholders," Choice Energy alleged.

National Grid described the reason for the change as follows.

"Prior to a December 2015 process change, all meter readings could be processed only once during the 'window'. To maximize the number of meter reads posted for billing, the meter reading department held all reads until late in the window ...the process was cumbersome, inefficient and had the potential to affect the timing of customer payments," National Grid said

"To improve the overall meter reading and billing processes, the Company implemented a system change that allows meter reads to be posted for billing the same day a meter is read which in turn allows for multiple postings resulting in increased efficiency. Subsequent to implementing this change, the Company’s Supplier Services team determined that this change created the unintended consequence of allowing meter readings on or ahead of competitive supplier enrollment and drop transactions. To alleviate this situation, the team determined that tariff changes were necessary. Therefore, to ensure timely and efficient enrollment and drop transaction processing, the Company submitted its proposal requesting Department approval to revise the tariff provisions governing notice from suppliers from two to four business days," National Grid said

National Grid said in its brief, "Moreover, the change in timing of two days will not impose a burden on competitive suppliers or customers, nor will it impede the further development of the competitive supply market in the Commonwealth. In addition, no competitive supplier providing service in the Company’s service territory has objected to the proposed extension of the notice."

However, Choice Energy countered National Grid's characterization concerning the lack of supplier objections, arguing that an initial notice from National Grid to suppliers indicated that National Grid was "recommending" that suppliers submit enrollments 4 days before a switch, but gave no indication that the longer lead time would be required

Docket DPU 16-193

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