Regulator "Strongly Encourage[s]" Retail Suppliers To Proactively Report Billing, Administrative Errors Before Customer Complaints

The Connecticut PURA recently issued informal data requests to several retail suppliers concerning customer renewal and billing administrative errors which PURA became aware of. While for two suppliers PURA was satisfied with suppliers' responses and is closing the matters without taking formal action, PURA, "strongly encouraged," suppliers to inform PURA when suppliers become aware of such issues, before customer complaints arise.

In one instance, PURA reached out to Public Power concerning a complaint in which a customer alleged they did not receive a renewal letter and were billed an early termination fee. Public Power responded that due to an internal system change, about 900 customers did not receive a renewal letter prior to contract expiration

Public Power explained that upon discovering the error, about a month before PURA reached out concerning the customer complaint, Public Power proactively extended all customer contracts under the same terms to ensure that customers would receive renewal letters 30-60 days prior to the end of their contracts. Public Power also explained that it did not charge any customer an early termination fee as a result of the issue

Public Power also instituted measures to prevent a recurrence in the future.

PURA stated that it found Public Power's response to the matter acceptable.

However, noting that Public Power was aware of the problem about a month before PURA reached out in response to a customer complaint, PURA said, "On a going forward basis, Public is strongly encouraged to inform the Authority of such events as they are discovered."

In another matter, PURA reached out to Spark Energy in response to a customer complaint in which the customer alleged that they did not receive a renewal letter, and that their rate changed without notice. Spark responded that for about 300 customers, the renewal notice was mailed after the date necessary for the customer to receive the notice on time. This delay resulted from a change made to the notice, as Spark said it failed to properly account for the additional time its mail vendor needed to accommodate the changes prior to mailing

As a result, each customer’s account was notated with respect to the delayed notification and Spark made proactive renewal call attempts to extend credit adjustments and enroll the customers on more competitive fixed rate plans.

Regarding inadvertent rate changes, Spark said that it sent the future rate (.1299) to the utility approximately 60 days prior to the current rate expiring; unfortunately, upon contract expiration, the system still sent the default rate (.1499) for this market that existed prior to implementation of new code. Thus, about 500 customers experienced one billing cycle at .1299 cents/kWh, with the subsequent billing cycle at .1499 cents/kWh. Customers were immediately returned to the .1299 cents/kWh rate.

Spark reimbursed the customers that were affected. The average refund amount was $17.74. The total reimbursements issued equaled to $9,989.71.

Spark also took measures to prevent a recurrence of both issues.

PURA stated that it found Spark's responses to both matters acceptable.

Spark was aware of the delayed mailings about 3 months before being notified of a complaint by PURA, and was aware of the inadvertent rate change about four months before being notified of the complaint (although Spark had believed the issue had been resolved at that time)

In response to a question of whether Spark informed PURA of the errors, Spark said, "Spark did not issue a notice to the Authority of such events. However, Sparks regulatory department has now implemented an Authority notification protocol, which requires that events that occur that have a significant customer impact (billing/mailing errors, etc…) will require an Authority Consumer Affairs notification."

In response, PURA said that, "the Authority notes with favor Spark’s plan to implement a PURA notification protocol. Spark’s plan to notify Authority staff in case of an event that could have significant impacts upon customers represents an industry best practice."