Draft Order Would Require Customers To Be Dropped To Default Service If Retail Suppliers Do Not Submit Next Month Rate Info To Utilities
Suppliers To Be Charged Costs Of Utility System Upgrades
Draft Would Direct Utilities CSRs To Proactively Discuss Supplier Rate Info With Customers; Share Default Service Rates
October 16, 2018 Email This Story Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
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The Connecticut PURA has issued a draft decision which would require utilities to drop customers to default service if the utilities do not timely receive next month rate information from the customer's retail supplier
The draft states, "In this Decision, the Public Utilities Regulatory Authority (PURA or Authority) finds that licensed electric suppliers have failed to timely submit the residential contract information needed to comply with Conn. Gen. Stat. §16-245d(a)(2). To assure future compliance, the Authority strengthens rules to govern the transmittal of this information and establishes detailed monthly reporting to assist the Authority in its enforcement efforts. Such rules will require that: suppliers provide all Supply Summary Information with each enrollment, which enrollment will be rejected by the EDCs if such information is not supplied; rejected enrollments that are not timely corrected will be placed on Standard Service; the Next Cycle Rate must be submitted no later than 62 days prior to the start of the consumption period in which that rate will be assessed and cannot be changed, and failure to timely submit the Supply Summary information associated with the renewed contract will result in the customer being placed on Standard Service; all enrollments must affirmatively indicate if the contract is a Fixed or Variable rate and existing customer information must be updated with the EDCs; suppliers will bear the cost for changes to EDC information technology (IT) systems to implement such changes and cost to develop the Supply Summary Report; and before enrollment rejection is implemented, EDCs must communicate with customers to ensure they realize Supply Summary Information might be inaccurate."
Further summarizing changes under the proposed order, the draft states regarding new rules and processes, "Such rules will require that: suppliers provide all Supply Summary Information with each enrollment, which enrollment will be rejected by the EDCs if such information is not supplied; rejected enrollments that are not timely corrected will be placed on Standard Service; the Next Cycle Rate must be submitted no later than 62 days prior to the start of the consumption period in which that rate will be assessed and cannot be changed; and failure to timely submit the Supply Summary information associated with the renewed contract will result in the customer being placed on Standard Service; all enrollments must affirmatively indicate if the contract is a Fixed or Variable rate and existing customer information must be updated with the EDCs; suppliers will bear the cost for changes to EDC IT systems to implement such changes; the cost to develop the Supply Summary Report; and the communications program being directed herein."
"The utility data processing systems that were developed in 2015 to enable suppliers to provide the residential contract information to Eversource and UI must now be redesigned to implement these rules and licensed suppliers will bear the cost to do so," the draft states
"In addition, Eversource and UI will incur costs to develop the reporting necessary to monitor the suppliers and inform consumers about the Supply Summary which costs also will be borne by suppliers. The Authority instructs the EDCs, upon completion of all redesigns, to submit a compliance order indicating the total costs to be billed to suppliers," the draft states
"Because this communication was precipitated by supplier non-compliance, as was this docket, and would be unnecessary had suppliers met their statutory obligations, suppliers will bear the costs of this communication made necessary by their failure to timely provide Supply Summary information as required," the draft states
"These costs will be allocated equally to each supplier licensed to serve residential customers as of March 28, 2018, the date this proceeding was initiated," the draft states
Total costs authorized by PURA for all changes under the draft are $886,000 at CL&P and $780,000 at UI
More specifically regarding the new processes described above, the draft would provide that, to assure accuracy in the display of the Next Cycle Rate info, the Authority would require the following:
• EDCs will revise the timeline for accepting changes to the Billing Rate by requiring suppliers to submit any change to a Billing Rate 62 days in advance of that rate being used to assess generation supply costs;
• EDCs will be required to use the Billing Rate to display the Next Cycle Rate on customer bills;
• EDCs will be required to lock in the Billing Rate and use it to assess generation supply costs in the appropriate consumption period; and,
• EDCs cannot change the Billing Rate until it is updated in the subsequent billing cycle.
"The Authority is aware that this change results in suppliers not being able to modify the rate as late as they currently do," the draft states
The draft would also require the submission of various summary bill info, including next cycle rate, at enrollment.
The draft states, "the Authority hereby changes the established process and requires that each supplier submit the Type, Term, Expiration, Cancellation Fee, Next Cycle Rate, and IRA status (as soon as it becomes available) with each enrollment (Complete Enrollment). In addition, the Authority also requires the EDCs to develop a process to reject any residential enrollment that does not include all Supply Summary data (Incomplete Enrollment), if the Billing Rate and Next Cycle Rate do not align, if the Term does not align with the Expiration, or any other inaccurate data."
Furthermore, the draft would require suppliers to submit all Supply Summary data (complete refresh), for contract renewal or extension. If a supplier does not submit this data in a timely manner to ensure the information can be displayed on the appropriate customer’s bill, the customer will be returned to Standard Service and the supplier would need to treat this customer as a new enrollment, subject to all of the requirements associated with a new enrollment, such as obtaining a new TPV, etc.
The draft also directs the EDCs to propose a communications plan for utility customer service reps to proactively probe customers contacting the EDC about their supplier rate information
"EDC customer service personnel regularly interact with residential customers. This interaction should, to the extent possible, be used to inform residential customers about the Supply Summary information, and where a customer has selected a supplier, allow the representative to quickly review the customer’s most recent billing statement to assure that the customer is aware of the Supply Summary and to confirm that the customer is aware that he is taking generation supply from a supplier. EDC personnel should be free to also discuss Standard Service rates and to review other Supply Summary information with the customer," the draft states
The draft sets forth a summary of proposed changes and timeline, as shown in the image below:
Concerning arguments raised by retail suppliers during the case and the need for changes, the draft states, "Throughout this proceeding, suppliers have proffered defenses such as the IRAs insert obstacles into the process or the EDCs do not provide sync lists in the manner they prefer. These are nothing more than excuses for inaction. Suppliers have had three years to address all of the problems discussed herein. Suppliers have had three years to address IRAs, and are the only parties to this process capable of identifying an IRA, yet the Authority sits here today having to impose its own solution to the problem because the problem remains unaddressed. Suppliers have had three years in which to complain that the lack of sync lists have caused them difficulties in addressing these issues, yet they have not filed a single complaint with the Authority. In short, suppliers have had three years to ensure they did not get into the situation we currently face, in which Supply Summary information was not timely and accurately provided to customers. During this time, customers have been making choices about whether to stay on or change their supply rate on the basis of inaccurate information. This false reliance on inaccurate information makes the retail supplier market less fair for customers than if no information about the next rate were included in the monthly bill at all, a result that is contrary to the intention of the 2015 legislative mandate in Conn. Gen. Stat. §16-245d to provide modest additional protections for consumers participating in the retail supplier market."
The draft notes that while incidental residential accounts (IRAs), for which the next rate info is not required, constituted a portion of the total instances in which the info was not provided, "Eliminating IRAs from the Compliance Report reduced the number of instances of reported non-compliance, but it did not reduce the volume of missing information to a level that demonstrates either adequate or full compliance by suppliers."
The draft states that at CL&P, after removing IRAs, the utility still found more than 1,500 customers for which suppliers did not provide Next Cycle Rate information.
While RESA has argued that non-compliance was driven by a single supplier, the draft states, "data supplied by the EDCs indicate that there is more than one instance."