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RESA Files Proposal For Retail Market Enhancements In Delaware

October 10, 2017

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

The Retail Energy Supply Association recently filed a proposal for implementing various retail market enhancements in Delaware

RESA, at a July workshop, had agreed to develop a proposal to address various proposed enhancements originally proffered for review by the Delaware Electricity Affordability Committee

RESA consulted with WGL Energy concerning the proposal, and WGL generally agrees with the substantive components of each proposal, though WGL does not take a position on certain cost recovery mechanisms for certain items

Under its proposal, RESA continues to recommend approval of a purchase of receivables (POR) program consistent with the existing POR programs maintained by Delmarva’s Maryland and District of Columbia affiliates.

"Regarding implementation costs, RESA would expect Delmarva’s implementation costs to be similar to the $95,265.72, incurred by Delmarva’s affiliate to implement POR in the District of Columbia. Delmarva recovers its implementation costs through the discount rate, meaning that retail suppliers pay for the costs of implementing POR. Typically, the costs are amortized over a certain period of time such as two or five years; depending on the costs, stakeholders will need to discuss an appropriate amortization period," RESA said

RESA continues to recommend implementation of seamless moves and instant connects consistent with RESA’s prior comments. To expand upon RESA’s prior comments, a list of customer eligibility criteria and descriptions of the processes for seamless moves and instant connects were proposed by RESA, as listed below:

Seamless Moves - Customer Eligibility Criteria

1. Residential and small commercial customers

2. New location must be in same rate class and within same service territory

3. Customer must maintain same billing rate, billing option, and tax exemption percentage

4. Customer must provide at least one business day notice

5. Customer must provide move-out and move-in dates at same time with no more than seven days’ gap or overlap

6. Must be an active meter at the new location when customer contacts utility

7. Same-day or back-dated requests are not accepted

8. Supplier must be currently providing service on the customer’s account

9. Any termination of supplier service prior to move will preclude a seamless move

Seamless Moves – Process

1. Customer contacts utility and provides current and new service address with move-out/move-in dates.

2. If a customer is currently enrolled with a supplier, utility automatically processes the move through a move transaction.

3. Utility informs customer that supplier's supply service will move to their new location (if eligibility requirements are met).

4. Utility will transmit usage data to the supplier in the same manner as before the customer’s move.

5. If customer never moves or the account does not become active at new address, utility will send the supplier an EDI drop transaction for the pending account at new premise. In addition, utility may send drop notification in the event that customer enrolls with a new supplier on the current account before connection at new account occurs, customer requests same-day service connect after previously selecting a future date, customer voids or terminates the new account, or customer requests to change the service start date on new account to a date occurring in the past.

6. Supplier will submit a drop request via EDI if it does not wish to continue service at new location.

Instant Connects - Customer Eligibility Criteria

1. All customers

2. Utility may require up to least [sic] three business days’ notice prior to the instant connect to qualify

3. Customers will not be permitted to back-date service

4. Only available for premises with active accounts

Instant Connects – Process

1. Customer contacts utility to request a new connection. Customer is responsible for satisfying all requirements to start service at new location.

2. Utility provides customer with service account number and choice ID at new premise and establishes pending active account. (Utility will accept supplier enrollment requests on both active and pending active accounts).

3. Customer provides new account number/choice ID to supplier.

4. If customer changes move in date, utility will notify supplier of the new move-in date via EDI 814 Change transaction.

"Because seamless moves and instant connects benefit the entire Delaware retail market, RESA proposes that Delmarva recover the costs to implement instant connects and seamless moves from all residential and small commercial customers, regardless of whether they are shopping. This can be accomplished in Delmarva’s next base rate case or through implementation of a tariff rider that is trued-up periodically to ensure that Delmarva does not over- or under-recover its implementation costs," RESA said

RESA also proposed an enroll-with-your-wallet enhancement to facilitate easier customer access to the competitive market. The 814 EDI transaction, which is used to communicate switch requests to the utility, would be modified to allow suppliers to submit the customer’s phone number, matched with a service address. Suppliers would no longer need to submit a 22-digit service number or an account number to effectuate a switch, although they could if they had that information. The 814 transaction is programmed to send 'reject codes,' which would be modified to include reject codes if the information submitted by the supplier (e.g., the phone number) did not match Delmarva’s records.

RESA said that its enroll-by-wallet proposal is in line with Delmarva’s new IVR system that enables customers to obtain their account information necessary for enrollment by calling Delmarva’s automated telephone line. Customers enter the phone number associated with their account and either the phone number or the last four digits of their SSN to access their account information. RESA’s proposal would borrow the IVR functionality and allow a customer to enroll with a supplier using the same information they use to authenticate their accounts in a phone call with Delmarva.

"[B]ecause this [enroll-by-wallet] enhancement will benefit the entire market by making shopping easier for customers, RESA proposes that Delmarva recover the costs to implement the updated EDI functionality from all customers regardless of whether they shop for electricity," RESA said

RESA proposed that the PSC should initiate a separate docket to develop rules for supplier consolidated billing, preceded by a working group of interested stakeholders.

RESA noted that while the Electric Supplier Rules specifically allow for SCB, there are several issues pertaining to SCB that would need to be decided or clarified before a supplier could offer SCB in Delaware. These issues include: (1) qualifications of a supplier to provide SCB; (2) purchasing the utility’s receivables; (3) affording the supplier the same tools as the utility currently uses to manage its bad debt; and (4) customer education

RESA proposes that Delmarva issue a quarterly choice bill insert with information developed and agreed to through a stakeholder workgroup process. Delmarva recently developed and issued a choice information bill insert, which identified active Delaware retail suppliers and included their contact information. RESA recommends a working group to develop the wording and feel of future inserts and to expand the information provided.

In addition to quarterly bill inserts, RESA proposes an annual choice information mailer, to be sent separately from the bill, with more information about customer choice. This annual mailing would identify, among other information, specific offers available from licensed competitive suppliers in Delaware.

For both the quarterly bill inserts and the annual mailer, RESA proposes that the verified incremental costs incurred by Delmarva to provide these items would be recovered pro-rata from participating retail suppliers.

Regarding creation of a PSC-administered electricity supply choice website (rate board), RESA said that it is sensitive to the Commission’s and Staff’s concerns regarding the resources needed to develop and maintain a user-friendly website where Delaware residents and businesses can easily access available offers.

RESA proposes that the Commission issue a Request for Proposals for a third party to develop, operate, and maintain a robust shopping website specific to Delaware. RESA is willing to work with other stakeholders to help develop the specific parameters and criteria for the RFP. Bidders would include fee structures in their proposals to ensure that the website is self-sustaining and does not require use of state funds.

"Generally, RESA would support a reasonable fee charged to suppliers that wish to post information on the shopping website. Because the costs of the website would be recovered from suppliers through user fees, RESA does not anticipate any need for utility cost recovery," RESA said

Docket No. 15-1693

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