Regulator Proposes To Assign Costs Of Utility Implementation Of Retail Supplier Amnesty, Refund Plans To Suppliers

Proposes Method To Assign Costs To Individual Suppliers

Proposes To Further Modify Customer Refund Process For Suppliers Electing Amnesty Program

January 3, 2020

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The Connecticut PURA has issued a draft decision in Docket 18-12-22 to further modify how retail electric suppliers are to provide refunds to customers under an amnesty program, with the draft now also addressing cost recovery for EDC implementation costs to accommodate the plans

As exclusively first reported by EnergyChoiceMatters.com, PURA created an amnesty program under which participating retail electric suppliers are to refund to customers amounts which were overbilled as the result of not providing customers with timely Next Cycle Rate information, in lieu of a civil penalty. See background on the amnesty plans and refunds here

Originally, PURA envisioned suppliers mailing refund checks to customers, but in an October draft decision (story here), proposed that the primary method of issuing refunds shall be through the utility bill, with suppliers directing all refund monies to the electric distribution companies (EDC) with the EDC including such amounts on the bill.

PURA's latest draft order further refines how refunds are to be provided to customers through the EDC bill, and how to address various situations

The new draft also explicitly affirms that purchase of receivables will not be impacted by the refund process.

In the new draft, PURA summarized the proposed refund process as follows:

"In this Decision the Authority modifies the manner in which customer refunds will be distributed. Suppliers will not provide refunds directly to all affected residential customers. Instead, upon approval of an amnesty plan, the supplier will work with each electric distribution company (EDC) to validate current EDC customer accounts. Once the account information is validated, the supplier will forward refund monies for all current accounts to the EDC, which will apply individual refunds as a bill credit to those customers the EDCs are able to locate within their respective billing systems, even if those customers no longer have an active account with the EDC. This will reduce arrearages and, based on the amount of the refund(s) may result in a credit balance for customers. For any inactive accounts where the billing adjustment results in a credit balance to the customer account, the EDCs will follow their current escheatment process. For any account that has been written off, the EDC shall apply the refund to their General Service Charge reserve account for uncollectable funds.

Suppliers will be responsible for the refunds and escheatment process for any customer account the EDCs cannot locate within their respective billing systems. Suppliers also will be required to notify all affected customers."

The draft says that the proposed Implementation Plan begins with the supplier and EDC exchanging customer data on a standardized Excel-based format and transmitted via a secure web-based file transfer process. The EDCs will use this data to determine known accounts and notify the supplier of these accounts. For unidentified accounts, suppliers will resubmit information if the first submission was incorrect. Suppliers will be responsible for the refund and escheatment process for any customer account the EDCs are unable to locate within their respective billing systems.

The draft says the EDCs will process credits to all customer accounts they are able to locate within their respective billing systems, including those where the account is no longer active. For any inactive account with an arrearage, the bill credit will reduce the arrearage. For any inactive account where the bill credit results in a credit balance, the EDCs will follow their current escheatment process. Bill credits will be displayed and identified as a separate line item on customer bills. The bill credit text is limited based on each EDC’s billing platform. The EDCs will send a confirmation to the supplier once the credits have been successfully processed and will notify the supplier if any delays occur.

The draft says that once the account validation process is complete suppliers will transfer the total amount of monies owed by the supplier for the customer accounts the EDCs can locate. The EDCs will provide a credit to these accounts. Purchase of receivables will not be impacted by this process.

The draft says that prior to issuing the bill credits, the EDCs will provide each supplier with the last known mailing address for all customers who are receiving a credit. Suppliers will send a notification letter via first class mail to all affected customers and will work with the EDCs regarding the timing of these letters to assure they are provided in advance of the credits that will be applied to customer accounts.

The draft would accept a form notification letter to be sent to customers, with the addition of the following text at the end of the letter: "Please review the enclosed information". Suppliers must provide the letter in English and Spanish. A sample of the letter is included in the latest daft here

The draft says that for all customers whose letters are returned to the supplier as undeliverable and for whom the EDC was unable to apply a credit or the EDC-provided address may not be correct, the supplier must attempt to phone and email each customer in order to obtain a correct mailing address. If the supplier is unable to contact the customer using the last known telephone number and email address, the supplier must use the National Change of Address database to attempt the identification of a current address for the customer and must resend the letter to any new address found.

The draft provides that retail suppliers will bear the costs incurred by the EDCs to administer an implementation plan to accommodate the refund process

Suppliers will bear the EDCs’ cost to administer the Implementation Plan on a cost per customer basis, the draft states.

The EDCs will be required to submit the estimated per customer cost for PURA approval in a separate filing approximately three weeks after receiving the confidential information from all suppliers.

Docket 18-12-22

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