Utility Asks Regulator For Clarification On Whether Retail Suppliers' Rates Are "Locked In" As Part Of 62-Day Advance Submission Of Next Cycle Rate Info
March 13, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
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United Illuminating has requested that the Connecticut PURA clarify whether retail electric suppliers are permitted to revise their rates after submitting a rate 62 days prior to the consumption period under the Next Cycle Rate information submissions requirements
UI said that PURA had issued the following directives to UI:
To assure accuracy in the display of the Next Cycle Rate the Authority directs 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.
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.
UI said that it has been made aware that a dispute exists within the EDI Working Group as to the interpretation of the Authority’s directives with regard to placing the Next Cycle Rate on customers’ bills.
"The Company understood that the Decision precludes suppliers from requesting any changes to the Billing Rate within the 62 day time period. However, the Company understands that some stakeholders have interpreted this directive to allow suppliers to request multiple changes to the Next Billing Cycle during the 62 day time frame – despite the language in the Decision that 'EDCs will be required to lock in the Billing Rate' and 'cannot change the Billing Rate until it is updated in the subsequent billing cycle,'" UI said [emphasis by UI omitted]
"The Company submits that an interpretation of the Decision that allows multiple Billing Rate changes within the 62 day time frame undermines the entire purpose of the 62 day time frame, namely to ensure that the customer has been provided with sufficient knowledge about an upcoming generation rate change in advance of consumption. Such an arduous interpretation cannot be left to stand without further guidance from the Authority, and PURA should clarify the purpose of this requirement to avoid unintended results," UI said
"[T]he Company respectfully requests the Authority to clarify that suppliers cannot request multiple changes to its Billing Rate during the 62 days prior to the consumption period because those Billing Rates are 'locked in' for that 62 day time period," UI said