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NRG Retail Seeks Reconsideration Of Requirement To Include Contract Expiration Info As Part Of Info Transmitted To EDCs At Enrollment

March 21, 2019

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Reporting by Paul Ring • ring@energychoicematters.com

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Several NRG retail suppliers have petitioned the Connecticut PURA for reconsideration of the requirement that retail suppliers submit information regarding the expiration of a contract as part of the enrollment transaction as currently required by PURA's December 19, 2018 Decision regarding Next Cycle Rate issues

NRG Retail also sought clarification from PURA that both electric distribution companies should simultaneously implement the electronic data interchange (EDI) changes required to effectuate the December 19 Decision.

PURA's Decision requires that, "suppliers must provide all residential Supply Summary Information, Term, Expiration, Cancellation Fee, and Next Cycle Rate at the time of enrollment."

However, NRG said that, "because suppliers have no control over the processing of an enrollment request once it is sent to the EDC, they do not know at the time that they submit enrollment transactions when service will commence. Since the date on which service commences ultimately determines the Expiration, suppliers also do not know the Expiration at the time enrollment transactions are submitted to the EDC."

Thus, NRG Retail requests that the Authority remove the requirement that each supplier submit the Expiration at the time of enrollment as currently required by the Decision and require that the EDCs calculate the Expiration based on the date the customer is enrolled with the supplier and the Term provided in the enrollment transaction.

NRG noted that, under the process in place prior to the December decision, the Supply Summary info could be sent after enrollment, thereby allowing the enrollment date, and thus Expiration information, to be known when submitting the information.

"Pursuant to the Decision, however, suppliers are required to submit the Expiration at the time of enrollment. If a supplier does not do so or if the Term is not accurate, once the capability has been developed, the EDCs will reject the enrollment. If the enrollment is rejected because the Expiration is missing or does not align with the Term and the supplier fails to correct the enrollment in time for the switch to occur at the customer’s next meter reading, the customer will be returned to Standard Service. Since suppliers will not know the Expiration at the time they submit the enrollment, the likelihood that the Expiration will not align with the Term is high. As a consequence, a large percentage of enrollments could be rejected and a percentage of those customers could be returned to Standard Service simply because suppliers did not have sufficient information to accurately determine the Expiration," NRG said

"In order to remedy this situation, NRG Retail requests that the Authority reconsider the requirement that each supplier submit the Expiration at the time of enrollment and, instead, require the EDCs to calculate the Expiration based on the Term and the enrollment date. This solution has been discussed at the EBT Working Group and, it is NRG Retail’s understanding that the EBT Working Group members, including the EDCs, are in agreement with this requested change. Additionally, because the EDCs are already required to confirm that the Term and Expiration align, this change should not increase the burden on the EDCs’ in processing enrollments. As part of its decision on reconsideration, NRG Retail also requests that the Authority clarify that, as a result of this change, the EDCs would not reject an enrollment if the Expiration is missing or the Term does not align with the Expiration," NRG said

Regarding the EDI changes required by PURA, based on discussions during the EBT Working Group meeting, it is NRG Retail’s understanding that The United Illuminating Company expects to complete the changes necessary to identify incidental residential accounts by July 31, 2019. However, The Connecticut Light and Power Company does not expect to implement this change until the fourth quarter of 2019.

"While NRG Retail appreciates UI’s efforts to expedite the process to identify IRAs through the EDI process, since the Authority has established an interim process by which suppliers can identify IRAs for purposes of reporting and the EDI change will not be necessary for other purposes (e.g., ensuring that IRA enrollments are not rejected due to missing Supply Summary Information) until the final project changes are instituted, there is no benefit to having UI implement this EDI change earlier than Eversource. Moreover, having two different EDI data requirements for the two EDCs increases the likelihood that errors may occur as suppliers are required to use one process for UI and another process for Eversource to identify IRAs. Thus, NRG Retail requests that the Authority clarify that both EDCs should simultaneously activate the EDI process to identify IRAs. In addition, to avoid future inconsistencies in the EDI data requirements and processes at the two EDCs, NRG Retail also requests that the Authority clarify that, except as otherwise expressly required by the Decision, the EDCs also simultaneously activate the other EDI changes necessary to effectuate the Decision," NRG said

Docket 14-07-19RE05

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