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Excerpts from Testimony of Robert Garcia of Liberty:

{***} “Pursuant to the Settlement Agreement entered on September 13, 2023, and approved by the Commission in Order No. 27,047 (August 16, 2024) (“Settlement Agreement”), our  testimony submits for Commission approval in phase two of the instant proceeding: (1)  edits to Liberty’s Tariff implementing its Purchase of Receivables (“POR”) Program; (2)  its Energy Service Supplier Agreement (“ESSA”) for competitive electric power suppliers (“CEPS”) and Community Power Aggregators (“CPAs”) (collectively “Suppliers”) acting as load-serving entities, including the interim use of the rules, processes, standards, and procedures of the Massachusetts Electronic Business  Transactions (“EBT”) Working Group and associated Electronic Data Interchange (“EDI”) standards for the implementation of the POR Program; and (3) a proposed timeline for POR Program implementation. This revised testimony reflects modifications made to the proposed tariff revisions and ESSA originally filed on September 24, 2024, based on feedback from the parties to the settlement discussions. In addition, Liberty changed its proposed timeline for POR implementation from fixed dates  to a more fluid timeline based on the number of days from Commission approval of the tariff and ESSA. Liberty extends its thanks to the parties for the productive discussions and feedback.” {***}

1. SUPPLIER AGREEMENT 
2. Does Liberty submit a new supplier agreement incorporating POR for Commission approval?
   A. Yes. Attachment 1 contains the proposed ESSA, (which is referred to as the Electric Supplier Services Master Agreement in the Settlement Agreement). The ESSA implements POR as a condition of Consolidated Billing Service. That is, an entity seeking Consolidated Billing Service must agree to sell Liberty its receivables at the applicable DPR, as set forth in the proposed tariff revisions. The ESSA is applicable to both CEPs and CPAs acting as load-serving entities in ISO-New England.” {***} 

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1. Does the proposed ESSA address the EBT and EDI standards to be followed?
   A. Yes. The New Hampshire EDI (electronic data interchange) guidelines and standards have not been updated in more than twenty years. While the New Hampshire Electronic Business Transactions (“EBT”) Working Group recently reconvened after many years to address the EDI guidelines and standards, the change control process has already proven to be extensive due to its technical nature. Furthermore, two of the NH utilities and many of the current NH suppliers are using the standards and guidelines of the Massachusetts EBT Working Group, which regularly updates their guidelines and standards, has a change control process, and hosts bi-monthly meetings. Utilizing Massachusetts’ EDI  guidelines and standards will provide the framework to move forward with implementing  POR and mitigate delays in the proposed implementation schedule for the utilities and the  suppliers Therefore, Liberty proposes the interim use of the rules, processes, standards, and procedures of the Massachusetts EBT Working Group for the implementation, unless  and until directed otherwise by the Commission with respect to potential adoption and implementation of relevant EDI standards developed specifically for New Hampshire” {***}

Cover Letter
Testimony
Attachments
23-003
Liberty Utilities (Granite State Electric) Corp. d/b/a Liberty Proposed Purchase of Receivables Program