Retail Suppliers Seek Extension To Comply With Part Of Connecticut Next Cycle Rate Order, Citing Technical Limitation Preventing Compliance

The Retail Energy Supply Association asked the Connecticut Public Utilities Regulatory Authority for an extension of time for compliance with the requirement that electric suppliers send the Next Cycle Rate at the time of enrollment until April 2, 2019.

On December 19, 2018, the Authority issued a decision in the above-captioned matter. In the Decision, the Authority required that "[e]ffective the date of this Decision, suppliers must provide all residential Supply Summary information, Term, Expiration, Cancellation Fee, and Next Cycle Rate at the time of enrollment." (“Order 3”)

RESA said that, "When it instituted this requirement, it appears the Authority believed that there was already an electronic data interchange ('EDI') field for the Next Cycle Rate on the enrollment transaction. However, that is not the case. As a consequence, as of today, suppliers cannot transmit the Next Cycle Rate as a part of the enrollment transaction."

RESA said that, in order to establish the capability for suppliers to do so, the EBT Working Group must determine the necessary changes to the EDI enrollment transaction. While the Order 3 requirements have been the subject of discussion at recent EBT Working Group meetings, the group has not yet agreed upon the necessary EDI changes, RESA said

RESA said that, in addition, after the required changes are determined, the electric distribution companies (EDCs), suppliers and EDI vendors must all then develop, implement and test the EDI capability on their systems to ensure that suppliers can successfully transmit and the EDCs can successfully receive the Next Cycle Rate as part of the enrollment transaction. "Accordingly, RESA requests that the deadline for compliance with this requirement be extended in order to ensure the requirement is implemented properly," RESA said

RESA said that, "Moreover, even without the addition of the Next Cycle Rate to the enrollment transaction, the current process will ensure that the EDCs have the Next Cycle Rate for each new enrollment. As the Authority is aware, the EDCs currently rely 'on the enrollment Billing Rate to populate the Next Cycle Rate field for display on a customer’s initial billing statements in their respective systems and [do] not require a separate Next Cycle Rate to process an enrollment.'"

"As the Authority is also aware, '[r]esidential enrollments submitted after October 1, 2015, [can] only reflect a fixed rate contract with a minimum term of four billing cycles.' Thus, the Billing Rate submitted with a residential enrollment will also always be the Next Cycle Rate," RESA said

RESA said that, "In addition, '[t]he EDCs’ current process rejects an enrollment if the supplier does not provide a Billing Rate.' Thus, even without the addition of the Next Cycle Rate to the enrollment transaction, the current process will ensure that the EDCs have the Next Cycle Rate for each new enrollment. Accordingly, RESA requests that the Authority extend the deadline for compliance with the requirement that electric suppliers send the Next Cycle Rate at the time of enrollment until April 2, 2019."

RESA said that, "The Connecticut Light and Power Company d/b/a Eversource Energy and The United Illuminating Company have informed RESA that they have no objection to the requested extension."

Docket 14-07-19RE05