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Regulator To Penalize Supplier Non-Compliance With Next Cycle Rate, Summary Info Requirements

Utilities To Develop Plan For CSRs To Proactively Discuss Supplier Rate Info With Customers; Share Default Service Rates

Regulator Orders Enrolling, Renewing Customers To Be Dropped To Default Service If Supplier Summary Info Not Provided

Retail Suppliers To Be Charged For Utility System Upgrades

December 19, 2018

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

The following story is brought free of charge to readers by EC Infosystems, the exclusive EDI provider of EnergyChoiceMatters.com

Update, 12/20:

Other highlights from PURA's Supplier Summary Info decision that was first reported yesterday

Next Cycle Rate Process Change

PURA stated that the current process of relying on the supplier to timely update their Next Cycle Rate to comply with Conn. Gen. Stat §16-245d(a)(2) has proven unreliable in providing residential consumers with accurate and timely information. " Although UI attempted to create a backstop for suppliers that failed to update this information by connecting the supplier’s Billing Rate to update the Next Cycle Rate, UI’s process fails to provide the Next Cycle Rate exactly as required. The Eversource process relies entirely on each supplier to update this information. Unfortunately, some suppliers have consistently failed to submit updated Next Cycle Rate data or have submitted inaccurate or untimely data, resulting in many customers receiving inaccurate information," PURA said

"UI’s process demonstrates that connecting the Billing Rate to the Next Cycle Rate and locking in that rate is an effective way to assure that the Next Cycle Rate will display the rate that will be assessed in an upcoming period. However, to ensure that customers receive a timely Next Cycle Rate, a change to the Billing Rate must be submitted 62 days before the start of the consumption period in which that rate will be assessed to allow the EDC to display it as the Next Cycle Rate as required," PURA said

To assure accuracy in the display of the Next Cycle Rate the PURA directed 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.

"These directives are intended to apply UI’s process to both EDCs and to add 30 days to the time under UI’s process in which suppliers must submit a Billing Rate change. The Billing Rate will then serve a dual purpose: proper timing of the display of the Next Cycle Rate and customer billing for generation supply in the second cycle after the rate is displayed on customer bills," PURA said

"The Authority is aware that this change results in suppliers not being able to modify the rate as late as they currently do. This change corresponds with the legislative intent behind Conn. Gen. Stat. §16-245d(a)(2) to furnish the customer with sufficient knowledge about an upcoming change to their generation rate to accurately bargain with a supplier. To assure that suppliers are fully aware of the importance of providing accurate Next Cycle Rate information, the Authority will require that the Next Cycle Rate be provided with each enrollment, as well as timely thereafter, to properly reflect each change to the Billing Rate. An enrollment will be rejected if the Next Cycle Rate is not provided or does not match the Billing Rate. To be clear, each enrollment must include a Billing Rate and Next Cycle Rate that are identical, e.g., if the initial Billing Rate is listed as $0.08, then the Next Cycle Rate must be $0.08," PURA said

Submission Of Supplier Summary Info With Enrollment, Renewals, Rejections For Non-Compliant Info, Penalties

PURA will require each supplier to submit the Term, Expiration, Cancellation Fee, Next Cycle Rate, and IRA status with each enrollment (Complete Enrollment). These will be required fields for all non-IRA residential enrollments.

PURA noted that developing system allowing the submission of such info with enrollments will take time to implement. In the interim, the bills will display "Not Provided" if info is not submitted, as done currently

However, "the Authority will require more detailed reporting from the EDCs and will assess penalties where Supply Summary data is not provided with each enrollment and if 'Not Provided' is displayed on a bill," PURA said

Enrollments with incomplete info will be rejected

"For the benefit of the competitive supply market, the Authority must assure that all information is being provided in a timely manner. To that end, the Authority hereby changes the established process and requires that each supplier submit the 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. The EDC rejection must identify the missing information so that suppliers can quickly resubmit the enrollment ... the EDCs must develop a system to allow suppliers to identify IRAs so that these enrollments are not rejected," PURA said

"Customers often switch suppliers to avoid a rate increase with their current supplier. The customer is harmed if an Incomplete Enrollment is rejected, results in the customer missing the switch and remaining with the current supplier and is then assessed the increased rate. To avoid this situation, the Authority will require the EDC to return the customer to Standard Service when an Incomplete Enrollment is rejected and not corrected in time to process it for the switch to occur on the customer’s then-scheduled next meter reading. This will place the customer on Standard Service for the next billing cycle and allow the enrolling supplier to correct the Incomplete Enrollment for the next cycle or for the customer to select another supplier. The Authority believes placement onto Standard Service is the most equitable option for the customer who has expressed a desire to leave their current supplier but cannot enroll with their new supplier because that supplier submitted an Incomplete Enrollment," PURA said

"Pursuant to Conn. Gen. Stat. §§16-1 and 16-245(k), the Authority will impose penalties against suppliers that submit Incomplete Enrollments. In addition, the Authority will direct the EDCs to return a customer to Standard Service if the supplier fails to correct an Incomplete Enrollment in time to process the switch to become effective with the customer’s next meter reading," PURA said

As soon as residential enrollment rejection is in place, within five business days of an enrollment being accepted and confirmed by the EDC as complete, each supplier will be required to provide the following information to all non-IRA residential customers where the enrollment is processed and the switch will occur on the customer’s next meter reading:

• Date on which the customer agreed to enroll with the supplier;

• Date on which the enrollment was submitted to the EDC;

• Date and reason the enrollment was rejected (if applicable);

• Date the supplier submitted a corrected enrollment (if applicable),

• Date that enrollment was verified as being accepted; and.

• Date that the switch will become effective.

As soon as residential enrollment rejection is in place, within five business days of an enrollment being rejected, each supplier will be required to provide the following information to non-IRA residential customers where the enrollment is processed and the switch will not occur on the customer’s next meter reading:

• Date on which the customer agreed to enroll with the supplier;

• Date on which the enrollment was submitted to the EDC;

• Date and reason the enrollment was rejected;

• Date on which the supplier submitted a corrected enrollment (if applicable);

• Date that enrollment was verified as being accepted;

• Date that the switch will become effective; and,

• Notification that the customer will be returned to Standard Service for the interim billing cycle because the switch did not occur on the customer’s next meter reading.

Suppliers will be required to submit all Supply Summary data (complete refresh), for contract renewal or extension even if some of it is the same as the initial contract. For example, a contract with a Term of four cycles, no Cancellation Fee and a Billing Rate of $0.0899 may be renewed by a contract with an identical Term, Cancellation Fee and Billing Rate, but changed Expiration. Despite only the change in the Expiration, all other fields must also be submitted.

Supplier Submission Of Contract Type For Current Customers

Previously, PURA directed the EDCs to display the word "Fixed" on residential bills if a supplier did not identify its offer as being variable. The Authority anticipated that residential variable contracts would decline, and cease to exist, as the result of Conn. Gen. Stat. §16-245o(g)(4) However, suppliers continue to serve residential customers under variable rate contracts that were in place prior to October 1, 2015. As a result, the Authority’s directive to display fixed as the default contract Type can result in the display of inaccurate information when a supplier fails to properly identify each contract Type.

To correct this deficiency, the Authority directed that suppliers must immediately review the contract Type that has been submitted to the EDCs for all current accounts to assure that the contract Type has been accurately reported and to provide the EDCs with updated information where appropriate.

Incidental Residential Accounts

With regards to incidental residential accounts (IRAs), PURA will not require development of an interim EDC system, and will rely on supplier reporting pending adoption of final changes to the EDC systems to identify IRAs, as discussed below:

Although, the identification and tracking of IRA accounts would support PURA’s interim enforcement efforts surrounding Conn. Gen Stat. §16﷓245d(a)(2), to control cost, the Authority will forgo having the EDCs develop an interim system to flag IRAs and instead require the EDCs to incorporate this functionality into the final project. To facilitate interim compliance, suppliers must provide the EDCs with the number of IRAs on a monthly basis and be prepared to support any claim regarding their IRAs when questioned by the Authority.

To be clear, IRA identification and functionality will be implemented in one step and will allow the EDCs to separately process IRAs during enrollment and to modify the bill print for these accounts. IRA identification must be incorporated into the overall project as a required field that must be submitted with all enrollments.

EDC Communication With Customers About Supplier Info, Default Service Rates

PURA directed that the EDCs develop a plan for customer service reps to discuss and inquire of customers, on inbound customers calls and similar customer-prompted interactions, the customer's supplier summary info, and also default service rates

"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," PURA said

EDC System Change Summary

The Authority directed that that the overall system change project to develop solutions for the directives discussed above shall be completed in twelve months.

Interim Project Changes include, among other things:

• The EDCs will implement a process to allow suppliers to report their IRAs

• UI will modify its process to require that suppliers submit a change to a Billing Rate no later than 62 days before the rate is billed and display that value as the Next Cycle Rate

• The EDCs will provide two updated sync lists per month

• The Authority will begin spot checking customer bills for compliance with the Supply Summary requirements

Final Project Changes include, among other things:

• The EDCs will develop an enrollment rejection

• The EDCs will return a customer to Standard Service as discussed in our story yesterday (see below)

Misc.

EDCs will, as part of the monthly competition report, include a report on supplier compliance with the Summary info requirements

A summary of the changes and timeline is below:

Earlier:

The Connecticut PURA issued a final decision in its review of Supply Summary Information issues, ordering that customers enrolling or renewing with a retail electric supplier will be transferred to standard service if the supplier does not timely provide the Supply Summary Information

The Supply Summary Information includes, among other things, the supplier’s electric generation service rate; the term and expiration date of the supplier’s rate; any change to the supplier’s rate effective with the next billing cycle; the cancellation fee; and notification that such rate is variable, if applicable PURA's final decision states:

A customer will be returned to Standard Service under the following conditions.

A customer is receiving service from Supplier A and wishes to switch to Supplier B. The EDC receives an Incomplete Enrollment from Supplier B. Supplier B fails to correct the enrollment in time for the switch to occur at the customer’s next meter reading. The customer is returned to Standard Service. Supplier B can resubmit the enrollment in the next cycle only.

A customer is receiving service from Supplier A and is nearing the end of the contract term. Supplier A fails to provide all Supply Summary for the contract that is being renewed, i.e., a complete refresh of all Supply Summary data; Term, Expiration, Cancellation Fee, Next Cycle Rate and IRA status, so that the information can be displayed on the customer’s bill. The customer would be returned to Standard Service. Supplier A would need to treat this customer as a new enrollment and would be subject to all of the requirements associated with a new enrollment.

PURA's final decision also allocated to retail suppliers any utility system upgrade costs to comply with PURA's order concerning the Supply Summary Information order

Generally, PURA summarized its order as follows, "In this Decision, the Authority finds that information needed to comply with Conn. Gen. Stat. §16-245d(a)(2) has not reached the EDCs in a manner to allow competitive supply customers to benefit from the Supply Summary portion of their bills. Review of this matter leads the Authority to find that it would benefit the competitive supply market as a whole for the Authority to strengthen rules governing the transmittal of this information and establish 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; existing customer information regarding contract type (Fixed or Variable) must be updated with the EDCs; suppliers will bear the cost for changes to EDC information technology (IT) systems to implement such changes, costs to develop the Supply Summary Report, and communications costs; and, the EDCs must communicate with customers to increase awareness about the Supply Summary."

Regarding cost recovery, PURA said, "Licensed suppliers will bear the cost of these redesigns because such redesigns support the competitive supply market, of which licensed suppliers are the largest beneficiary. Connecticut’s competitive supply market is no longer in its infancy and licensed electric suppliers can now provide cost support for EDC IT system upgrades needed to assure compliance with suppliers’ statutory requirements to provide information to customers. The Authority instructs the EDCs, upon completion of all IT redesigns, and development of compliance reporting and communications, to submit a compliance filing indicating the total costs to be billed to suppliers. After suppliers have been given the opportunity to review the costs, these costs will be allocated to each supplier licensed to serve residential customers, and serving one or more residential customers, as of the date of the reopened docket to address cost reimbursement to the EDCs."

Concerning allocation of costs to specific retail suppliers, PURA said, "The Authority will attempt to balance equity with feasibility when allocating costs among suppliers in the reopened docket. Allocations based on the number of kWh sold by a supplier or the number of customers served may be preferable to ensure equitable contribution, but pose certain feasibility problems at the present date due to the current inclusion of IRAs in residential account information. The Authority expects this difficulty to be overcome as a result of the changes made in this decision, and reserves the right to consider these and other allocation methods in its reopening decision."

The estimated costs of the system changes are about $900,000 at each utility, (CL&P and UI)

This is a breaking news story. A full analysis of PURA's decision will follow

See PURA's final decision here

Docket Number: 14-07-19RE05

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