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Citing "Inaccurate" Data, RESA Seeks Stay Of Regulator's Newly Adopted Requirement To Publish Retail Supplier's Compliance Metric In Monthly Migration Reports

August 7, 2018

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

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The Retail Energy Supply Association requested that the Connecticut Public Utilities Regulatory Authority stay implementation of its directive that Connecticut Light and Power Company (Eversource) and United Illuminating include certain information about electric suppliers' provision of summary billing information in the EDCs' monthly migration reports until PURA concludes an investigation into these reporting requirements, including the accuracy of the information, in one of the other proceedings in which these issues are already currently being explored.

As first reported by EnergyChoiceMatters.com in July, the Authority directed that the EDCs, by July 25, 2018, include, in their monthly migration reports, the number of all residential accounts served by each supplier and the number of such residential accounts for which the following data have not been provided (next rate info): the term of the supplier’s rate in billing cycles, the expiration date of the rate, the cancellation fee (if applicable), any change to the rate effective for the next billing cycle, and notification that the rate is variable (if it is).

RESA said in its motion that, "The Authority is currently evaluating various matters related to the Summary Information, including the appropriate reporting by the EDCs of the types of information they have or have not received each month from electric suppliers, in two other dockets. The evidence in those proceedings has revealed that the information the EDCs previously reported is not accurate. Moreover, responses to interrogatories issued by the Authority to various electric suppliers in their individual licensing proceedings have revealed further deficiencies in the accuracy of the data that the EDCs have been reporting."

Thus, RESA said in its motion that, "the Authority should stay the requirements of the Directive until it has completed its investigation of the accuracy and reliability of the information being reported. While RESA recognizes that the EDCs did include the information required in the Directive in the migration reports filed in July, given that the Directive is beyond the scope of this proceeding and because of the inaccuracies in the information being reported, RESA requests that the Authority stay future reporting until these issues are resolved."

Concerning the inaccuracy of the data, RESA said in its motion that, "First and foremost, the information is inaccurate because it includes incidental residential accounts. As the Authority is aware, its August 12, 2015 decision in Docket No. 14-07-19RE01 explicitly 'exempts incidental residential accounts from the Summary Information required under Conn. Gen. Stat. §16-245d(a)(2).'"

"Without a clear understanding of which accounts are incidental residential accounts and, thus, not subject to the Summary Information reporting requirements, the EDCs cannot accurately report the information necessary for the Authority to track 'compliance with Connecticut General Statutes §16-245d(a)(2).' Nevertheless, despite repeated requests from suppliers, there still is no way for them to identify incidental residential accounts for the EDCs. As a consequence, the information being reported by the EDCs is inherently inaccurate. For instance, when Eversource responded to Interrogatory SEU-7 in Docket No. 14-07-19RE01, it acknowledged that nearly sixty percent (60%) of the residential bills for which it did not receive Summary Information were likely incidental residential accounts. Moreover, on further review, Eversource admitted that, some portion of the remaining approximately forty percent (40%) of residential bills for which Summary Information had not been provided, may also be incidental residential accounts that were not captured when Eversource performed its preliminary analysis," RESA said in its motion

"In addition, in recently filed interrogatory responses, several suppliers disputed the information previously reported by the EDCs. For example, even though the EDCs reported that Champion Energy Services, LLC ('Champion') had not timely provided certain Summary Information, Champion noted that the only residential accounts that it serves are incidental residential accounts; thereby, making the requirement that it provide Summary Information to the EDCs inapplicable. Similarly, Direct Energy Business, LLC indicated it does not serve residential customers so the information reported by the EDCs is inaccurate," RESA said in its motion

RESA said in its motion that, "Further, other interrogatory responses filed by suppliers revealed additional deficiencies in the information reported by the EDCs, including the following:

• "At times, without any explanation or any reason of which DES is aware, bill print information appears one month and the next month it is listed as 'not provided' even if the information was provided and present in the prior month.

• "When an account is reinstated after being cancelled, bill print information is shown as 'not provided' even if the information was provided and present prior to cancellation.

• "When an account goes delinquent, bill print information is shown as 'not provided' during and after the delinquency is resolved even if the information was provided and present prior to the delinquency.

• "If the EDC rejects the transaction, the bill print notification disclosure fields will not be updated for that bill cycle."

RESA said in its motion that, "the continued reporting of inaccurate information by the EDCs could lead consumers to believe that suppliers are not complying with statutory requirements when, in fact, they are; thereby, resulting in the potential loss of customers to the detriment of those suppliers. Accordingly, rather than perpetuating the reporting of this inaccurate information, the Authority should stay the requirements of the Directive until it has resolved the deficiencies in the EDC reporting processes."

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