Regulator Provides Deadline For Retail Suppliers To Use Newly Mandated Contract Cover Page, Update Other Customer Materials In Light Of New Law

Regulator Rules On Which Customer Rate The Revised 25% Increase Notice Applies To

July 30, 2021

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Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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The Connecticut PURA has issued deadlines for retail electric suppliers to comply with various new provisions under adopted HB 6526

As first reported by EnergyChoiceMatters.com, HB 6526 modifies the current 25% rate increase notice requirement, includes a new renewal contract cover page, and bans early termination fees for residential customers. As previously reported, the new law also makes existing residential variable rate contracts null and void

As previously reported, several retail suppliers asked PURA to provide an October 1 compliance deadline due to the time needed to implement the changes and/or use templates that haven't been created yet (at the time of the request) by PURA (such as the new renewal notice cover page).

PURA denied the sought October 1 compliance deadline

Regarding the need to update contract language and other materials to reflect that no early termination fee may be charged to residential customers (suppliers agreed that no early termination fee may be charged as of the law's effective date and would not do so, but asked that more time be granted to update various customer-facing materials), PURA noted that it already mandates a five-business day timeline regarding similarly scoped updates necessary each time the Authority approves new standard service rates.

"Suppliers have failed to demonstrate that an additional extension through October 1 is warranted," PURA said

PURA ruled that on or before August 15, 2021, suppliers are required to update all of their verbal, recorded, printed and electronic marketing materials, including information contained on their respective websites, to comply with Public Act 21-117 (HB 6526).

"Such timeframe represents more than 45 days since the legislation’s effective date and approximately ten weeks since the bill passed," PURA said

Also related to the matter of early termination fees (ETF), the suppliers further asserted that a complication exists regarding ETF charges that may appear on customers’ bills in July (even though the fee will not be actually charged), contending that restrictions related to the number of daily electronic data interchange (EDI) transactions prevent the timely removal of ETF charges from customer bills.

However, PURA said that, "any such issues could be remedied through coordination and advanced agreement with the utilities, or through the submission of a 'complete EDI transaction for each customer.'"

PURA found that, "submitting any changes to a customer’s ETF immediately, and before August 15, 2021 at the latest, is appropriate, feasible and required to comply with Public Act 21-117."

Regarding compliance requirements that require changes to customer billing done through the electric distribution companies, PURA ruled that suppliers shall, immediately but no later than August 15, 2021, coordinate with the electric distribution companies for suppliers to submit an increased number of EDI transactions, if needed.

On or before August 15, 2021, suppliers shall also submit one or more complete EDI transaction(s) for each customer containing all of the relevant changes needed to comply with Public Act 21-117.

"At this time, the Authority is not ordering the electric distribution companies to make any adjustments to their computer programming systems to accommodate compliance with Public Act 21-117, as no programming changes appear necessary to achieve compliance," PURA said

As noted, the law provides that, "No electric supplier shall charge an electric generation service rate to a residential customer that is twenty-five per cent more than the original contract price, or more than the first price term offered in the contract, without notifying such customer of the rate change thirty days before it takes effect."

PURA ruled on the meaning of the term "original contract price" as follows

"The Authority finds that, based on the plain language and remedial nature of this provision, the original contract price means the most current contract price. If a contract has been automatically renewed, the original contract price is the original price of the latest renewed contract. Therefore, Suppliers shall comply with this provision of Public Act 21-117 by notifying customers at least 30 days before their price is increased by more than 25% above the original price of the most current contract. In the case of a tiered rate contract containing multiple prices throughout the contract term, the customer shall be notified of any price increase that is more than twenty-five per cent above the first price charged in the tiered contract. The Authority finds that Suppliers do not need to make any changes to Form 4 [existing rate increase notice] to make these customer notifications. The Authority directs Suppliers, as of the date of this ruling, to begin notifying customers of any price increases as outlined above," PURA ruled

Regarding the new renewal contract cover page requirement under Public Act 21-117, PURA said that, "Given that a contract cover page template is already provided on the Authority’s website ... a delay is unwarranted. "

"Suppliers must begin using, as of the date of this ruling, the contract cover page template on the Authority’s website," PURA ruled

Docket No. 13-07-18

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