NRG Proposes Pennsylvania Supplier Consolidated Billing Be Limited To Suppliers With 5 Years Experience In Billing, Serving Customers; Recommends Security, LOC Requirements

As part of a Pennsylvania PUC rulemaking addressing utility billing, payment, and termination rules, NRG Energy has made specific recommendations regarding eligibility requirements for electric suppliers to engage in supplier consolidated billing, as NRG urged the PUC to formally adopt rules authorizing the use of SCB through the rulemaking.

As previously reported, NRG last December petitioned the PUC to implement SCB for electricity. The petition remains pending before the PUC

NRG's latest comments were made in a rulemaking addressing Chapter 56, relating to standards and billing practices for residential public utility service, and which was opened to implement Act 155 of 2014, related to collections and related measures

NRG proposed that a new section authorizing electric SCB be added as part of the rulemaking.

NRG proposed that for electric suppliers to be eligible for supplier consolidated billing, they must:

• Have at least five (5) years of experience serving customers, "in Pennsylvania and other competitive electricity markets."

• Have at least five (5) years of experience or the equivalent with billing/credit and collections.

• Have experience of serving at least 25,000 residential electric customers

• Have at least five (5) years of experience or the equivalent with call center/complaint handling functions

• Post security naming the electric distribution utility as the beneficiary in the event of nonpayment of delivery charges, in an amount that is set on the basis of two months of distribution charges, using the highest two months in the most recent twelve-month period, which amount is reviewed and adjusted quarterly.

• Provide and maintain an irrevocable stand-by letter of credit payable to the Commission with a face value of $500,000 for the purpose of maintaining certification.

• Pay an annual fee of up to $150,000 if the Commission determines that additional monitoring activities are necessary as a result of an EGS being a billing entity.

Apart from its specific electric SCB proposal, NRG proposed various additional changes to harmonize the rules with any implementation of SCB (generally by replacing the term "utility" with "billing entity" to reflect that an EGS, or perhaps even NGS, may serve in such function)

Docket No. L-2015-2508421