Retail Supplier Seeks Extension For Compliance With Next Cycle Rate Enrollment Rejection Directives Due To EDC Implementation Timing, Risk Of Renewing Customers Being Returned To Default Service Due To Inadvertent Non-Compliance

May 22, 2019

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Reporting by Paul Ring • ring@energychoicematters.com

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Constellation NewEnergy, Inc. (CNE) asked the Connecticut Public Utilities Regulatory Authority for an extension of time for the electric distribution companies to comply with Order 7 of the Authority’s December 19, 2018 Next Cycle Rate information decision ('Decision') and for the electric suppliers to comply with Order 8 of the Decision, each with respect to certain residential contract renewals.

Order 7 provides that the EDCs shall an implement enrollment rejection process for enrollments, as well as renewals, which lack Next Cycle Rate information. Suppliers will be required to submit all Supply Summary data (complete refresh), for contract renewal. 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

"In order to avoid customers with renewing contracts being dropped to EDC Standard Service for inadvertent non-compliance during the period immediately following the EDCs implementation of new processes to comply with Order 7, CNE is requesting an extension of time of three (3) months after the enrollment rejection is operational for EDC compliance with Order 7 and electric supplier compliance with Order 8," CNE said

CNE said that as part of the EDCs’ compliance with the Orders, (i) the EDCs will require the Supply Summary information for a contract renewal to be submitted in one EDI transaction (i.e., the Next Cycle Rate must be submitted with the Term, Expiration, and Cancellation Fee) two (2) bill cycles before the Next Cycle Rate will become the billed price, and (ii) Eversource will align with UI and require the EDI transactions to be 'forward-looking' (i.e., submitted before the usage period of the applicable bill).

CNE said that, "As an unintended consequence of these process changes, there will be a period of up to three (3) months after the EDCs implement the enrollment rejection process when the Supply Summary information may be incorrect for contract renewals. This discrepancy will be caused by Eversource’s switch from a backward- to forward-looking process for bill information coupled with both EDCs’ requirement to wait two (2) bill cycles to print the Supply Summary information submitted with the Next Cycle Rate."

"When the EDCs implement their new coding system on December 7, all Supply Summary information will be held for two (2) bill cycles, for the Next Cycle Rate to become the billed price, before that information is printed on the customer’s bill. While this new process should allow accurate bill information for contract renewals starting with the February/March bill cycles (i.e., the first bill cycle that is two (2) months after the new coding is implemented), language of the Orders does not include a grace period for contracts renewing in the December/January or the January/February timeframe," CNE said

To illustrate how these changed processes could adversely impact customer renewals, CNE provides the following hypothetical example where a customer’s term is expiring on December 11, 2019 and the EDCs have implemented the Orders as scheduled on December 9, 2019:

Current Process for Eversource: Given that Eversource currently has a backwards-looking process for bill information, an electric supplier could submit its Supply Summary information (other than the Next Cycle Rate, which would have been submitted in a prior bill cycle) on December 13 for a term that expired and automatically renewed on December 11 for the correct Supply Summary information to show up on the customer’s bill for December usage.

New Process for Eversource: Eversource will align with UI by implementing a forward-looking process for bill information, requiring an electric supplier to submit all Supply Summary information with the Next Cycle Rate prior to the start of that consumption period, which then must be held for two (2) bill cycles. For a customer’s term that expired and automatically renewed on December 9, if an electric supplier transmitted an EDI transaction on December 11, the first time the correct Supply Summary information would show up on a customer bill is the bill for March usage and there would be a mismatch of information on the bills for usage in December (given the switch from backwards- to forwards-looking, a supplier would miss the EDI transaction window), January (the first month on which the Next Cycle Rate appears without the rest of the Supply Summary information related to the renewal) and February (the second bill on which the Next Cycle Rate appears without the rest of the Supply Summary information related to the renewal).

Current Process for UI: UI currently has a forward-looking process for bill information, requiring an electric supplier to submit its EDI transaction at least two (2) business days prior to the consumption period corresponding with the bill. This means that for a customer’s term that expired and automatically renewed on December 11, an electric supplier would need to submit the Supply Summary information (other than the Next Cycle Rate, which would have been submitted in a prior bill cycle) on December 9 for the correct Supply Summary information to show up on the customer’s bill for December usage.

New Process for UI: UI would continue to have a forward-looking process for bill information, but will require that all Supply Summary information be submitted with the Next Cycle Rate and held for two (2) bill cycles. With this requirement, the first time the correct renewal bill information would show up on a customer bill is the bill for usage in February and there would be a mismatch of information on the bills relating to usage in December (the first month on which the Next Cycle Rate appears without the rest of the Supply Summary information related to the renewal) and January (the second month on which the Next Cycle Rate appears without the rest of the Supply Summary information related to the renewal).

"The consequence of an electric supplier inadvertently submitting inaccurate Supply Summary information due to the initial implementation by the EDCs of the Orders, without a grant of this extension, is that customers that want to renew with their current supplier will be returned to EDC Standard Service supply without their consent. However, the electric suppliers do not control the EDC coding for the enrollment rejection process or how that new process is rolled out," CNE said

"CNE proposes that it would hold the customer’s terms, including pricing, for the affected contract renewals until the Next Cycle Rate for those customers becomes the billed price and the rest of the Supply Summary information is correctly displayed on the customer’s bill, unless the customer affirmatively renews sooner, drops to the EDC Standard Service, or selects another supplier," CNE said

"There have been no viable work-arounds proposed in the EBT Working Group meetings to the timing issue of contract renewals in the December/January timeframe," CNE said

CNE requested that the Authority extend the deadline for compliance with Order 7, and by extension Order 8, to three (3) months after the enrollment rejection is operational as it relates to residential contracts renewing during the bill period when the enrollment rejection is implemented and in the bill period after the enrollment rejection is implemented.

Docket 14-07-19RE05

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