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Retail Supplier Seeks Temporary Waiver Of Certain Recently Adopted Disclosure Rules

March 29, 2018

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

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Stream Energy Illinois, LLC, petitioned the Illinois Commerce Commission for a temporary waiver of certain requirements of recently revised 83 Ill. Admin. Code Section 412.110, relating to disclosure form requirements and variable rate history

"Stream requests a temporary waiver until June 15, 2018, of the following provisions of Section 412.110, Minimum Contract Terms and Conditions, which now requires certain disclosures in 12-point font in the order set forth in the provision, and Section 412.115, Uniform Disclosure Statement, which implements a new customer disclosure document to be provided to residential and small commercial customers and also requires the posting of a 12-month history for variable rate products. Stream will not be able to implement those provisions until June 15, 2018, for the following reasons: Even prior to the Commission's passage of its new and amended regulations on October 19, 2017, Stream had been (and still is) in the process of implementing a new vendor for printing and document management, not only in Illinois, but in all the states in which its affiliate companies conduct business. The new vendor has signaled that it cannot create the documents in its system by the May 1, 2018, deadline. Stream's web developer is in the process of developing the structure for the variable price history, but the item will require a maintenance update to Stream's existing web page to house the content," Stream said

"The provisions from which the temporary waiver would be granted are unreasonable or unnecessary [sic] burdensome because, for the reasons explained above, Stream and its vendor have been working diligently to migrate existing documents - including the new changes mandated by the Commission's rules, but the changes are substantial and require the new vendor to significantly modify the structure of Stream's existing Terms and Conditions for residential and small commercial customers and to implement a brand new document, the Uniform Disclosure Statement. The process is not as simple as updating the documents in a word processing program; rather, it requires the documents to integrate with Stream's IT and CIS systems to ensure that any dynamic fields in the documents are correctly populated when generated and issued to a customer as required by the regulations. While Stream is implementing a new vendor to make this process quicker and more efficient in the future, the cut-over to the new vendor will not take place until mid-May. Stream will then need additional time to test post development. Posting of variable price history will require additional development to Stream's website in order to house the content. A maintenance ticket has been submitted, but the vendor has signaled a need for more time given that Stream is not its only client," Stream said

Docket 18-0672

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