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State Sen.: Utility Consolidated Bills Should Have "Bold Warning" Informing Customers That "Significant" Number Of Bills Have Supplier Rate Errors

Says Suppliers Should Pay For System Changes, Presses For Refunds

August 17, 2018

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

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In a filing styled as "comments" on briefs filed in a Connecticut proceeding examining issues surrounding the provision and presentation of supplier Next Cycle Rate information on utility consolidated bills, State Senator Len Suzio wrote that, "Until the systems and procedures to assure reliable utility bills are developed and implemented the EDC’s should be compelled to insert a warning (not merely a perfunctory advice) in bold red font proclaiming to utility consumers who purchase electricity from suppliers that a significant number of bills have an above average potential for rate errors and should be scrutinized closely, urging consumers to compare the current generation rate to the 'next cycle rate' in their previous bill and providing clear contact information should they have questions or identify potential mistakes."

Suzio's recommendation, specifically with regards to informing customers of a "significant" number of errors, goes beyond even what the Office of Consumer Counsel had recommended in a brief, in which OCC, recognizing character limitations on bills, had recommended the following phrasing or something similar: "Caution. Do not rely on the next cycle rate shown above." [emphasis by OCC]

"OCC maintains that the word 'caution' or 'warning' is needed so that customers will get the essential message that the Next Cycle Rate is presently unreliable," OCC said

"OCC would prefer that the message also contain (1) the direction to confirm the rate with the electric supplier; and (2) some indication that we are working to fix the Next Cycle Rate, but the above message is probably at or near the character limit," OCC said

The Retail Energy Supply Association said that it supports the implementation of "interim" measures to notify customers about how they can obtain additional information about the Summary Information, "so long [as] those notifications are accurate and designed to be helpful to customers."

RESA said that, "To that end, the Authority should require the EDCs to include, prominently displayed on residential customer bills, a notice or message box encouraging customers to review their contracts and/or to contact their suppliers with questions regarding their rate plan. In that way, the Authority can ensure that customers are aware of the means by which they can ensure the accuracy of the information or have any questions about the Summary Information answered."

RESA said that, "During the proceeding, State Senator Suzio suggested that the bill message indicate that there may be inaccurate Next Generation Rate information on the customer’s bill. However, in the majority of instances, such a statement would be inaccurate. In fact, the evidence in this proceeding establishes that only one supplier has provided inaccurate Summary Information to its customers. It would be inappropriate to require the EDCs to provide customers with a notice that calls into question the data provided by all suppliers based solely on the actions of a single supplier."

Turning to other issues, Suzio wrote, "With respect to the costs to implement the temporary measures and the final billing systems I suggest the EDC’s and suppliers ought to bear the entire costs without passing them on to consumers. The cost of $1 million is a very insignificant amount in comparison to the annual revenues of the EDC’s. Moreover, I suggest the EDC’s as a gesture of goodwill and an effort to restore their good name announce they will absorb the costs to create a system they should have created in the first place."

"When the systems and procedures are in place to assure reliable utility bills the suppliers and EDC’s should be compelled to correct the wrong bills that may have overcharged consumers. This means developing programs to compare the 'next cycle rate' information with the current rate in the next billing cycle, identifying discrepancies, computing the amount of the discrepancy, notifying consumers if they have been overcharged and arranging to remit payment for any such overcharges. This cost should be born by the suppliers who failed to provide timely rate information to the EDC’s. There may be a contention that no one has maintained the data necessary to achieve this important correction for consumers who may have been charged more than what they were advised in their 'next rate cycle' (Eversource in its response to SEU-4 stated it 'does not have a database containing relevant information for comparing next cycle rate and the current cycle rate'. However, this Intervenor recalls that one of the EDC’s may have testified that the data does reside in an inactive file not normally accessed for billing purposes. If this important information is not maintained by the EDC’s and the suppliers, it is the more damming about the irresponsibility of the EDC’s and the suppliers who failed to maintain important historical information regarding rates charged to consumers). I do note however, that the EDC’s do maintain billing statements accessible to consumers on their website. That would suggest the information resides in electronic format somewhere within the files maintained by the EDC’s. Whatever the case may be, there is an above average probability that thousands (even a small percent of EDC accounts constitutes thousands of rate payers) of electricity consumers may have been charged generation rates exceeding what they had been advised in their 'next cycle rate' in their monthly electricity bills. It is unconscionable that the onus for identifying those overcharges should be placed on the backs of Connecticut consumers. The electricity suppliers bear full responsibility for the damaging consequences of their billing practices and should bear the full burden of paying to correct their failure," Suzio wrote

Regarding the alleged breadth of inaccurate rate information, RESA said, "Both Senator Suzio and the Office of Consumer Counsel have claimed that the inaccuracies are more widespread. In support of these claims, they rely on the EDCs’ interrogatory responses indicating that Summary Information was 'missing' from certain customer bills. However, missing information is not the same as inaccurate information. Moreover, the evidence in the record establishes that the majority of bills with missing information are actually associated with IRAs [incidental residential accounts] for which Summary Information is not required."

RESA said in a reply brief that, "the record establishes nothing more than that one supplier provided incorrect Next Generation Rate information, and that only one official complaint has been lodged for inaccurate Next Generation Rate information. Any claim that more Connecticut customers have received incorrect Summary Information is unfounded and based on nothing more than pure supposition, speculation and conjecture; all of which are insufficient to support the Authority’s findings in this proceeding."

"Moreover, the evidence in the record establishes that the majority of bills with 'missing' information are actually associated with IRAs for which Summary Information is not required. For instance, Eversource acknowledged that nearly sixty percent (60%) of the residential bills for which it did not receive Summary Information were likely IRAs. In addition, 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 IRAs that were not captured when Eversource performed its preliminary analysis," RESA said

RESA urged PURA to: (a) require the EDCs to create an EDI indicator (or flag) for IRAs and continue to work toward eliminating other operational issues associated with reporting and displaying Summary Information; (b) require Eversource to provide electric suppliers with up-to-date sync lists more frequently; (c) establish an interim means of notifying customers of their ability to contact suppliers with questions about Summary Information; and (d) create a written guideline to memorialize EBT Working Group protocols pertaining to Summary Information.

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