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State Proposes To Prohibit Retail Suppliers From Bundling Renewable Energy With Electric Plans Billed Through Utility Consolidated Billing

November 27, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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The Connecticut PURA has issued a proposal that would prohibit retail electric suppliers from providing to customers an electricity plan that includes in a bundled price renewable energy that exceeds the state's RPS if such plan is billed through utility consolidated billing (UCB).

Instead, all renewable energy products billed through UCB would be REC-only plans, at certain standard percentage levels and which meet state requirements (including local sourcing). Suppliers wishing to offer any renewable energy plans that do not meet these requirements would have to use dual billing for such plans

PURA said that the current practice of bundling renewable energy with generation lacks transparency, in that suppliers do not disclose, and consumers therefore cannot identify, the cost of the renewable component. Additionally, it is difficult for consumers to readily identify the source of the RECs that are used to support the voluntary renewable component.

Specifically, PURA proposes that voluntary renewable offers (VRO) may not be combined or bundled with a generation supply offer that is billed under utility consolidated billing.

VROs could be offered as stand-alone REC add-on plans billed under UCB, and the EDCs would include a separate line item on a customer’s bill for the VRO, identified as Renewable Energy Certificates. The line items would reflect the number of kWh for the billing cycle, VRO cost per kWh, and total amount billed.

PURA proposed that the program function similar to the existing Connecticut clean energy options program, under which a customer may select a REC marketer other than their supplier. What isn't clear is whether suppliers could market both their RPS-only generation supply plan, with an unbundled rate, and a VRO, with a rate specific for the VRO RECs, to a customer simultaneously (provided each has a distinct rate) and whether the supplier could enroll a customer in both a supply plan and a VRO simultaneously.

Moreover, while PURA's proposal does address renewable content disclosures, it was unclear if the VRO levels, noted below, either include, or are in addition to, the RPS, though PURA does suggest that the quoted VRO levels reflect the "total" (RPS-inclusive) renewable energy content, but this raises issues when another provider (the LSE) is responsible for (and charges for) the RPS portion of such supplies

A sample label suggests that RPS would be included in the total VRO level (a sample label for a 75% VRO lists only 46% of the green energy as 'voluntary', with the rest RPS); however, since the VRO marketer may not be the customer's supplier, while the customer, in aggregate, may receive 75% renewable energy, to the extent the VRO offers are not in addition to RPS, the VRO marketer may only be contributing 46% to such customer, and it seems odd for the VRO provider to market such plan as "75%" renewable

VROs offered through UCB would be limited to two content levels: 75% total renewable, or 100% total renewable.

RECs used to satisfy the VRO would be required to be:

a. less than two years old,

b. from a Class I, Class II, or Class III renewable energy source, as defined by Conn. Gen. Stat. § 16-1, and;

c. from a renewable energy source that is interconnected to the ISO-New England transmission grid serving Connecticut; and

d. properly retired under, GIS rules.

"Any generation supply offer billed through consolidated billing would not be allowed to exceed the then-current minimum RPS," PURA's proposal states

"The VRO would be separately marketed, and as noted above, separately billed as a line item on customer bills. Furthermore, any VRO billed as a separate line item through consolidated billing could include only RECs that satisfy the above requirements so as to comply with Connecticut laws and policies," PURA's proposal states

"All supplier generation offers under consolidated billing would be identical to EDC Standard Service supply as it relates to their renewable content in that all offers would be at the then current minimum RPS," PURA's proposal states

"This would allow consumers to accurately compare their generation supply options. Separately identifying unbundled VROs would provide greater transparency regarding the RECs used to support renewable energy and allow consumers to choose among clearly identified and priced renewable options," PURA's proposal states

EDC billing of VROs would be open to all qualifying suppliers. This mechanism would replace the current Connecticut clean energy options program, under which two selected marketers offer add-on RECs via UCB

"Suppliers would be free to market non-local RECs, e.g., Green-e certified, Texas wind, or those supported from other nationally sourced generation resources; however, the supplier would need to directly bill the customer for the VRO supported through these types of RECs and inform the customer that the RECs do not meet Connecticut standards," PURA's proposal states

"Because all VROs would be unbundled and separately identified as a line item on the electric bill, the cost of the unbundled VRO would be identified and recovered through the customer’s bill. The EDC would collect the funds associated with the VRO and remit said funds only after the supplier demonstrated that it retired the appropriate number of RECs for the associated load. The number of RECs would be based on billed sales, and therefore readily tracked. The Authority understands that this structure is similar to the manner in which CEOP [clean energy options] currently is administered," PURA's proposal states

Docket 16-12-29

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