Regulator Clarifies Whether Retail Supplier Rate "Locked" During Submission Process For Next Cycle Rate Info

The Connecticut PURA, in response to a request from United Illuminating, has affirmed that a retail electric supplier's rate is "locked" for billing purposes once submitted to UI 62 days in advance of the consumption period as part of the Next Cycle Rate information

Stating that some stakeholders have interpreted PURA's recent Next Cycle Rate directive as allowing suppliers to request multiple changes to the Next Billing Cycle during the 62 day time frame, UI had sought clarification as to whether suppliers can request multiple changes to its Billing Rate during the 62 days prior to the consumption period, or if those Billing Rates are "locked in" for that 62-day time period.

In response, PURA said, "PURA’s ruling is straightforward: once the supplier submits its Next Cycle Rate (NCR), the NCR is locked and must be used to bill for consumption in the appropriate billing period. The supplier cannot amend the rate until the billing period subsequent to when the NCR was submitted, which rate would again be locked and used to bill for consumption in the appropriate billing period. As identified from the Decision below, UI’s system does not allow the supplier to change the Billing Rate once it is submitted until the next billing cycle."

PURA noted that its December 19, 2018 Decision in this proceeding stated:

As noted, UI’s [then current] system requires that suppliers submit a change to the Billing Rate 32 days before the start of the consumption period in which the rate will be assessed. UI’s system also does not allow the supplier to change the Billing Rate once it is submitted until the next billing cycle. Suppliers are accustomed to these long-standing UI requirements that effectively lock in the supplier’s Billing Rate to that which was provided to UI 32 days before the billing cycle in which the rate is assessed. UI stated that it could easily change this process to require that suppliers submit a change to the Billing Rate 62 days before the rate is billed and display that value as the Next Cycle Rate in compliance with the Authority’s directives. However, requiring it to further modify the process and allow changes to the Billing Rate once it is submitted, i.e., unlock the rate, would require additional cost and time to implement. Decision, p. 18,

"The Authority’s use of '62 days' was intended to explain that UI’s then-current process was being modified to add 30 days to it (32 days + 30 days = 62 days)," PURA said

"The NCR is intended to show each customer the rate that will be assessed in an upcoming (i.e., not yet begun) consumption period, not to inform the customer about a change in his generation rate after he begins incurring that rate in a consumption period that has already started. To achieve this outcome the NCR must appear on the customer’s bill before the rate is incurred by the customer to allow time to negotiate a lower rate or opt out. The 62-Day Standard was implemented to assure the intended result," PURA said

Docket 14-07-19RE05