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Agreed Tariff Maintains Provision Dropping Customers To Default Service If Retail Supplier Does Not Sign New Agreement For POR
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An updated proposed tariff and supplier agreement to implement purchase of receivables at Granite State Electric (Liberty Utilities) in New Hampshire, averred to reflect an agreement among parties, maintains a provision that a retail supplier's customers will be dropped to default service if the supplier does not execute a new consolidated billing agreement with POR
Under the previously adopted design for POR, POR is required to be used for any accounts served under UCB
However, Granite State Electric had expressed concern that a retail supplier which is party to a current supplier coordination agreement could seek to require GSE to continue UCB, without POR, for existing accounts, by the supplier refusing to sign the new supplier agreement and seeking to enforce the obligations of the old agreement.
GSE argued that the previous POR design settlement does not contemplate that UCB will be offered without POR, either for existing or new customers
The updated, agreed tariff maintains a provision that will drop a retail supplier's customers to default service if the supplier does not sign the new coordination agreement for UCB with POR, with the agreed tariff's language only modified in a non-substantive fashion to reflect the timing of POR implementation
GSE had earlier said that customers of a supplier refusing to sign the new UCB with POR agreement should be dropped to default service because some suppliers may not be equipped to immediately engage in dual billing once UCB without POR ends
Specifically, the agreed tariff states, "In the event that a Supplier who entered a CEPS Agreement [legacy coordination agreement] prior to
a final Commission Order in Docket No. DE 23-003 [the POR case] does not enter into an
ESS Agreement [new coordination agreement] as required by Section 62(iii)(2)(f), the Company [GSE] will
return its Customers to the Company’s Default Energy Service effective on
the scheduled meter read preceding the implementation of POR,
respectively."
Section 62(iii)(2)(f) provides that a retail supplier shall, "Within forty (40) days following the first day of month after Commission
approval in Docket No. DE 23-003 [POR], and thereafter [e.g. for new suppliers], enter an ESS Agreement."
The agreed tariff revises proposed language which could have been interpreted as providing for supplier-specific uncollectible discounts, and thus supplier-specific POR discounts
Specifically, language now says that the uncollectibles component of the POR discount will reflect volumes billed by "suppliers" (plural). Under an earlier proposal, the language had said that the uncollectibles component would be based on volumes billed by, "the supplier", which, in the context of the coordination agreements which are signed by each supplier individually, could have been read as meaning only the specific signing supplier's volumes, not all retail supplier volumes, thus creating supplier-specific discounts
A similar change, affirming that the initial discount rate shall be uniform among suppliers, was also made in language governing the initial discount rate that will be in place through July 31, 2026. This initial discount will also be uniform for all customer classes during this initial period through July 31, 2026, as customer-class-specific uncollectible data is developed
Moreover, this initial discount rate will be based on all volumes from GSE, not only suppliers' volumes
The agreed tariff states, "during the initial period after POR
implementation through July 31, 2026, the single UPcg [uncollectibles component] applicable to
receivables purchased from the Supplier for the Large Customer Group
and Small Customer Group shall be the total amount of net write-offs by
the Company based on actual data for the most recent calendar year,
divided by the total amounts billed by the Company, including late
payment fees, during that calendar year."
The earlier proposed tariff had used language for the initial discount rate which had stated that such initial calculation would use, "total amounts billed
by the Company for Energy Service provided by the Supplier," rather than all amounts billed by GSE
The agreed tariff retains a 15-day cure period for any breaches under the coordination agreement (NRG had proposed a 30-day cure period as is used at Unitil-NH)
Docket DE 23-003
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Eliminates Language Which Had Suggested Supplier-Specific POR Discount Rates
December 23, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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