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Regulator Directs Retail Suppliers To Obtain Meter Read Date From Customers, Use Info In Enrollment Process And Communication Of Start Date To Customers

Regulator Calls "Vague" Statement On Service Start Dates (1-2 Cycles) "Unacceptable"

March 29, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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

In addressing a motion from NRG Energy concerning enrollment information to be provided by retail electric suppliers under the Next Cycle Rate information order, the Connecticut PURA directed that retail suppliers must obtain the customer's meter read date from the customer, and use such information in their enrollment submissions, and in communicating the start date of service to customers.

As more fully discussed below, PURA directed that, "Suppliers must inform customers of where meter read information appears on their bills and secure the information from the customer as part of the enrollment process so that the supplier is able to provide the customer with an accurate start date."

As only reported by (see story here), several NRG retail suppliers requested: (a) that the Authority reconsider the requirement that suppliers submit the Expiration as part of the enrollment transaction as currently required by the December 19, 2018 Decision (Decision) in Docket No. 14-07-19RE05; and (b) clarify that both electric distribution companies (EDC) should simultaneously implement the electronic data interchange (EDI) changes required to effectuate the Decision.

The Authority granted the Motion in part and denies the Motion in part.

"In support of its Motion, NRG Retail states the Decision requires that suppliers submit the Expiration at the time of enrollment. If a supplier does not do so or if the Expiration is incorrect (i.e., does not align with the Term), the Decision instructs the EDCs to reject the enrollment once the capability has been developed. The Decision further instructs that if the enrollment is rejected because the Expiration is missing or is incorrect 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. NRG Retail states that 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 many of those customers could be returned to Standard Service simply because suppliers did not have sufficient information to accurately determine the Expiration," PURA said in describing the petition

"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, agree 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. 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," PURA said in describing the petition

"Regarding the simultaneous implementation of EDI processes, NRG Retail requests that the EDCs be allowed to simultaneously implement all EDI changes directed through the Decision. Based on discussions during the EBT Working Group meetings, it is NRG Retail’s understanding that The United Illuminating Company (UI) expects to complete the changes necessary to identify IRAs [incidental residential accounts] by July 31, 2019. However, The Connecticut Light and Power Company d/b/a Eversource Energy (Eversource) does not expect to implement this change until the fourth quarter of 2019. NRG Retail appreciates UI’s efforts to expedite the process to identify IRAs through the EDI process. However, 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," PURA said in describing the petition

PURA noted that, "The Decision requires suppliers to provide the Term and Expiration with each enrollment. The Expiration is based on the number of billing cycles for the offer, i.e. the Term, as well as the cycle in which the enrollment actually occurs. Enrollments that are submitted to an EDC in close proximity to a customer’s meter read date may not be processed in time for that enrollment to become effective for the consumption period immediately following that meter reading. If the enrollment is not immediately processed, it will be held by the EDC and will not be processed until the next scheduled meter reading date. Therefore, in cases where an enrollment is submitted close to the meter read date, the Expiration provided with the enrollment may be incorrect; the supplier may presume that the enrollment will be processed immediately or may presume it will not be processed immediately but instead held until the next meter reading date. Each of these scenarios results in a different Expiration. NRG Retail’s Motion seeks to avoid the potential for a supplier to provide an incorrect Expiration by eliminating supplier guesswork as to when the enrollment will be processed. Since the EDCs will know when the enrollment is actually processed and will have the Term in hand, NRG Retail requests that the EDCs determine the Expiration that will be displayed in the Supply Summary to provide accurate information."

"The Authority grants the Motion with respect to NRG Retail’s request that the EDCs calculate the Expiration date that will be displayed within the Supply Summary subject to the following. Suppliers must submit an Expiration with all non-IRA residential enrollments. The enrollment will be rejected if an Expiration is not provided. The EDC should alter the Expiration date if necessary based on the Term that the supplier provides with the enrollment and the actual enrollment date. The EDC-determined Expiration must be included with the enrollment verification transaction provided to the supplier by the EDC. Suppliers must review this information and, if incorrect, take corrective action through the EDI process. The EDCs will track and report the number of correct and incorrect Expiration dates that are provided by each supplier for non-IRA enrollments. An explanation of this process must be included in the EDI Guidelines," PURA held

"The Authority notes that suppliers could provide an accurate Expiration date if they secured the meter cycle/read information from customers upon enrollment. It is incumbent upon suppliers, in their marketing, to provide more than a vague description of when a customer’s enrollment will process. The Authority has reviewed numerous residential contracts and marketing in which the supplier states that it typically takes one to two billing cycles for service to be switched from the local utility to the supplier, or other similar vague language. This vagueness is unacceptable," PURA said

"Retail choice has existed in Connecticut for almost two decades and is no longer a nascent market. Suppliers must do a better job to support the market by requesting meter cycle/read information when soliciting customers and informing consumers how the meter read date affects enrollment. Securing the meter cycle/date from consumers will inform the supplier as to when an enrollment is likely to be processed and in turn will reduce the guesswork associated with NRG Retail’s Motion," PURA said

"Suppliers must inform customers of where meter read information appears on their bills and secure the information from the customer as part of the enrollment process so that the supplier is able to provide the customer with an accurate start date. From information gained through the EDCs tracking and reporting, the Authority will monitor suppliers’ accuracy of Expiration submissions to assure suppliers are complying with their Supply Summary responsibilities. Suppliers found consistently submitting high volumes of inaccurate Expirations will be subject to investigation and possible penalties," PURA said

"The Authority denies the Motion with respect to NRG Retail’s request to require the EDCs to implement all EDI changes simultaneously. The Authority finds that it will benefit the market to have the processes outlined in the Decision implemented as soon as possible. Implementation of the Decision is already a prolonged process and the Authority will not delay any portion of it, and certainly will not consider delaying all portions of it as NRG Retail requests. UI’s implementation of the process may inform Eversource’s implementation. Furthermore, the Authority does not believe staggered implementation will place a large burden on suppliers. Many suppliers are licensed in multiple jurisdictions and are therefore equipped to deal with varying EDI requirements," PURA said

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