Texas Staff Seeks Commission Guidance on Shorter Reconnection Timelines Applicable to REPs

Staff of the Public Utility Commission of Texas has sought guidance from the Commission concerning potential amendments to rules governing retail electric providers' obligation to submit reconnection requests, including shortened timelines for REPs to submit such requests after a disconnected-for-nonpayment customer has made payment (39926).

Project 39926 was opened to make conforming changes to Subst. R. §25.483 (disconnection of service) in light of changes to other rules and tariffs regarding advanced metering timeliness, and critical care customers.

In response to practices in the market under current rules, Staff sought guidance from the Commission regarding whether changes to the disconnection notice, or reconnection timelines applicable to REPs, are appropriate to ensure that customers making a payment are reconnected as quickly as possible.

Under the current rules, the REP's obligation to send a reconnect notice to the TDU is not triggered until, "a customer's satisfactory correction of the reasons for disconnection."

Staff has learned that many REPs do not consider a payment to have met the conditions of a "satisfactory correction of the reasons for disconnection" at the point at which the customer delivers payment, but rather only after the payment has been delivered by the customer, received by the REP or REP agent, and posted to the REP's payment system.

In addition, Staff has learned that due to vendor relationships a REP may have in place, there can be a time lag between when a customer delivers payment to a vendor and when a vendor submits the payment to the REP. To compensate for this time lag, some but not all REPs ask their customers to call the REP call center to report payment so that the REP can submit the customer's reconnection request in a timelier manner.

Most REPs receive payments from multiple vendors, and depending on individual contract agreements, REPs may receive payments from some vendors quicker than from others, Staff noted. If informed which methods of payment result in a reconnection request being sent the quickest, a customer could choose to select a payment method available to them that will achieve reconnection of service in the most expeditious manner.

Staff proposed two options for Commission consideration to address these concerns, with the understanding that there may be other options to consider

Under Option 1, the Disconnection Notice would be modified to require: (1) the disclosure of what constitutes "satisfactory correction of the reasons for disconnection" (which triggers the REP obligation to submit the reconnect notice), and (2) an explanation of the most expeditious way for a customer to obtain reconnection of service.

Option 2 proposed by Staff would shorten the reconnection timeline. Staff specifically said that the Commission could shorten the reconnection timelines by:

a. Increasing the number of REP reconnection deadlines throughout the week and day; or

b. Requiring REPs to submit each reconnection request within a specified amount of time after payment is made rather than according to pre-determined deadlines.

Staff noted that in response to amendments made in Project 38674, consumer groups opined that the REP reconnection timelines should be consistent with the TDU timelines so that customers can get the maximum benefit from advanced meters. Through discussions with REPs, Staff said that it has determined that some may oppose changes to reconnection timelines for operational reasons.