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The EDCs request that Connecticut Public Utility Regulatory Authority (PURA) issue a Straw Proposal with any changes PURA plans to propose in Phase 2, issue a Request for Written Comments on the Straw Proposal and also to hold a Technical Meeting or Working Group to discuss the proposed changes.  

From Motion: 

{***} “The Connecticut Light and Power Company d/b/a Eversource Energy (“Eversource”) and The United Illuminating Company (“UI”, collectively the “EDCs”) respectfully request additional process in Phase 2 of the captioned docket prior to the issuance of a proposed Phase 2 interim decision. Specifically, the EDCs urge the Public Utilities Regulatory Authority (“PURA”) to issue a Straw Proposal with any changes PURA plans to propose in Phase 2, to issue a Request for Written Comments on the Straw Proposal, and to hold a Technical Meeting or Working Group to discuss those proposed changes. Participants have not been given the opportunity to comment on any proposed supplier contract limitations or other proposed changes in Phase 2 of this docket. Implementation of any changes to the proposals in the Working Group Report PURA approved in Phase 1 of this docket or new limitations on contracts between licensed electric suppliers and residential hardship customers (Phase 2) will require work and IT and/or billing system changes on the part of the state’s EDCs. It is therefore imperative that the EDCs be given adequate opportunity to provide PURA with information on the achievability, timeline and estimated costs with the work associated with any proposed approach before PURA issues any final orders imposing changes to the proposals in the Working Group Report or new limitations on contracts between suppliers and customers. The EDCs do not believe that sharing these proposals for the first time in a proposed final decision, with the only opportunity for input being one week in which to provide Written Exceptions, affords the EDCs adequate opportunity to provide PURA with this critical information.

On November 21, 2024, PURA issued a Notice of Request for Written Comments in this docket (the “Notice”) stating, among other things: “The Authority will conduct the remainder of this proceeding in two additional phases. In Phase 2, the Authority will investigate appropriate limitations with which customer contracts between financial hardship customers and electric suppliers are to comply.”  The Notice invited Participants to file written comments on the following topic: “Any additional conditions, not currently required by the State of Connecticut, that should be placed on new customer supplier contracts between licensed electric suppliers and residential hardship customers.”  In response to the Notice, two Participants each filed a Letter in Lieu of Comments and neither letter proposed limitations for customer contracts between financial hardship customers and electric suppliers or included any other substantive proposal.  The time schedule for this docket indicates that the next procedural events in this docket will be the issuance of a proposed Phase 2 interim decision, tentatively scheduled for February 13, 2025; Written Exceptions, tentatively due one week later on February 20, 2025; and a final decision, tentatively scheduled for March 12, 2025.

On January 9, 2025, PURA’s Office of Education, Outreach, and Enforcement (“EOE”) and The Office of Consumer Counsel (“OCC”) each filed a Brief in this docket proposing ideas for limitations on customer contracts between financial hardship customers and electric suppliers. Proposals included changes regarding renewable energy credit (“REC”)-only suppliers, Incidental Residential Accounts (“IRA”), and other proposed limitations on contracts between financial hardship customers and electric suppliers including requiring suppliers to include language in their contracts with hardship customers allowing the supplier to reduce the customer’s rate to equal the standard service rate during the term of the customer’s contract.

A great deal of additional detail is needed to fully understand how each of the proposals suggested in the EOE and OCC Briefs would be implemented and what work would be required of the EDCs to implement each. Depending on if and how PURA decides to implement any of the proposals raised in the EOE and OCC Briefs, the EDCs could potentially be required to perform a tremendous amount of complex, time-consuming and costly IT work. The EDCs want to ensure they are given a sufficient opportunity to (i) understand which proposed changes PURA wants to pursue; (ii) understand the details and mechanics of how PURA would like each proposed change to be implemented from a practical perspective, including the scope of work required by each EDC; and (iii) provide PURA with an assessment of the achievability, timeline and estimated costs associated with all work which each EDC will be required to perform, including the potential impact on other IT and/or billing system work the EDCs are currently in the process of performing. 

A detailed discussion of the changes to the EDCs’ current systems and processes that each of these proposals would entail has not yet occurred in this docket.  It is therefore essential that additional process be provided in this docket before the issuance of the proposed Phase 2 interim decision, to ensure that the EDCs are given sufficient opportunity to provide PURA with critical information on the achievability, timeline and estimated costs with the work associated with any proposal PURA contemplates implementing. To implement the necessary EDC process changes associated with each proposal in the most efficient and cost-effective manner, it is important first to have a process that allows the EDCs, PURA and the electric suppliers to engage in an open dialog about these issues. This will help ensure that any proposal is implemented by the EDCs in the manner desired by PURA and that the most feasible and cost-effective approach for implementation is selected. Such an approach will also ensure that PURA has a clear and complete understanding of the capabilities of the EDCs’ systems and the changes needed for any contemplated approach to achieving implementation of a particular proposal. This cannot be achieved if the only opportunity for the EDCs and other stakeholders to provide input on proposed changes is Written Exceptions due one week after the issuance of the proposed Phase 2 interim decision.

The EDCs stand ready to assist PURA should it decide to consider implementing additional conditions on electric suppliers’ contracts with hardship customers. However, for the reasons discussed above, it is critical that the EDCs be given an opportunity to provide PURA with information on the achievability, timeline and estimated costs associated with the work the EDCs will need to perform to implement any contemplated license conditions or other changes. The EDCs therefore respectfully request PURA provide additional process in this docket by issuing a Straw Proposal with any changes PURA plans to propose in Phase 2, issuing a Request for Request for Written Comments on the Straw Proposal, and holding a Technical Meeting or Working Group to discuss those proposed changes. The EDCs note that the working group process was used successfully in Phase 1 of this docket to identify the most effective approaches to achieve compliance with Conn. Gen. Stat. § 16-245o(m), as amended by Public Act No. 23-102, in a short period of time. The EDCs respectfully request that the remainder of the time schedule for this docket be adjusted accordingly to allow adequate time for this important additional process to occur.

The EDCs also request acknowledgement from PURA that they can recover all prudently incurred costs associated with implementing any proposal ordered by PURA in Phase 2 of this docket.” {***}

Motion (02/03/2025)
18-06-02RE02 (07/03/2023)
(Investigation of Appropriate Limitations on All Customer Contracts with Electric Suppliers Pursuant to Conn. Gen. Stat. § 16-245o(m))