NEM: Retention of Dual Billing Drop in N.J. Staff POR Proposal Undermines Goal of Program

The retention of a reversion to dual billing for retail supply customers in arrears, as contained in a New Jersey BPU Staff proposal for a revised purchase of receivables program, undermines the goals of improving the POR program to provide mass market customers with more competitive offerings, the National Energy Marketers Association said in comments to the BPU.

As previously reported by Matters, Staff has offered several changes to the POR program (click here for complete details on Staff POR proposal).

Notably, however, Staff would maintain a paradigm under which retail supply customers billed on utility consolidated billing with POR would become ineligible for utility consolidated billing and POR, and would be required to be dual billed, if the customer's account is more than 120 days in arrears (versus the current 60 days). NEM said that this essentially introduces recourse into the POR program.

"The concept of recourse and dropping customers to 'dual billing' have had and will continue to undermine the enormous public interest benefits that New Jersey POR itself provides, and instead operates to the detriment of consumers (particularly low income consumers), utilities, marketers as well as the market itself," NEM said.

"[T]he retention of the recourse and dual billing requirements is fundamentally inconsistent with a properly functioning, non-discriminatory, low-cost and otherwise highly successful POR program," NEM said.

"These provisions individually and collectively actually incent suppliers to return non-paying consumers back to the utility to avoid both bad debt and dual billing," NEM said.

As suppliers will be hesitant to serve customers at risk of being reverted to dual billing, "continuation of the dual billing system unfairly penalizes customers who become delinquent by blocking their ability to select an alternate supplier."

"[D]ual billing in and of itself creates unnecessary confusion for consumers and undermines the functioning of POR," NEM continued.

"[B]y adding on the appendages of recourse and dual billing to POR, it actually incents the marketplace to return payment-challenged as well as the most expensive consumers to serve back to the utility, creates confusion and ill will among the public, and forces the utilities and marketers to both maintain duplicate collections and bad debt billing systems," NEM added.