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In New Hampshire purchase of receivables proceeding, parties filed position statements on Unitil’s proposed trading partner agreement (TPA) and Terms and Conditions (T&C).

On September 16, 2024, the Commission issues a Procedural Order that cancels the October 1, 2024, hearing and reschedules this matter to October 23, 2024 at 9:00 a.m.

On September 18 parties filed comments on c on Unitil’s proposed trading partner agreement (TPA) and Terms and Conditions (T&C).

Community Power Coalition of New Hampshire (CPCNH), DOE, and NRG argued that “The proposed Terms & Conditions do not fully reflect the terms of the settlement agreement,” which only approved use of Massachusetts EBT standards and procedures “unless and until the Company is directed by the Commission to adopt and implement Electronic Data Interchange (‘EDI’) standards developed for New Hampshire”; 

DOE recommended revision of the proposed TPA and T&C to align with the “agreement that all competitive suppliers opting for consolidated billing with the Company must enroll all of their Unitil customer accounts in consolidated billing”; and (3) NRG objected that Unitil “has proposed the following changes to the TPA that are unrelated to POR and that are not of a housekeeping nature“: (i) “adding the word “immediate” before termination in the event a supplier’s registration is revoked or not renewed,” which fails to account for the possibility of seeking review of such decisions; (ii) “adding a sentence to the TPA that would allow it to change the vehicle for transmission of electronic transactions upon the providing of at least seven (7) days’ notice to the supplier,” which does not provide “sufficient time for suppliers to modify their own systems”; (iii) adding language regarding “consolidated bills that include supplier charges… that would relieve it of the obligation to undertake bill investigations, respond to customer inquiries regarding collection activities, or settle billing disputes”; (iv) “removing its obligation to include the supplier’s telephone number on the customer bill,” an amendment also opposed by CPCNH and DOE; and (v) making “various changes to its obligations regarding load reporting… [that] have no relationship to the implementation of a POR program,” and could undermine “, the ability for suppliers to obtain information from the Company about the load reported to ISO New England [which] is essential for suppliers to ensure that the information is accurate and that suppliers have sufficient opportunity to find and correct errors through the ISO New England Requested Billing Adjustment (‘RBA’) process”

As background, Unitil proposed to implement a purchase of receivables (POR) program in its territory. Unitil estimates a four- month timeframe for implementation at an initial cost of $5,250 (for EDI testing, as it plans to implement using existing technology). 

Key elements include:

• Unitil proposes to make a single monthly payment on the last business day of the calendar month to each participating supplier for all POR customers;
• Available to all competitive suppliers that have selected utility consolidated billing;
• The discount rate will comprise (1) an Uncollectible Percentage (i.e., actual uncollectible expense data for all customers in the applicable class, for the most recent period for which such data is available, divided by the total amounts billed for the applicable customer class for the same period, including late payment fees, if included in uncollectible expense); (2) an Administrative Cost Percentage (i.e., the cost to implement the POR program and the estimated costs to administer collection efforts), and the Past Period Reconciliation Percentage (i.e., true-up mechanism that reconciles actual and estimated uncollectible and administrative expenses);
• Unitil intends for two class-specific discount rates to be calculated (one for the Residential Class and one for the General Service Class);
• Unitil estimates a Residential discount rate of 0.97% and General Service discount rate of 0.32%. The utility proposes that the DRP be set annually for effect on 4/1 for a 12-month period. The utility will make an annual reconciliation filing around 2/1, providing the NHPUC with a calculation of the discount rate for the forthcoming year and documentation supporting that calculation.

As background, a state law enacted in 2021 requires each electric utility to propose to the NHPUC a program for purchase of receivables (POR) from suppliers. New regulations promulgated by the NHPUC in 2022 required each utility to file an implementation proposal by January 1, 2023

DE 23-002 (Opened 01/10/2023)
Unitil Energy Systems, Inc. Proposed Purchase of Receivables Program