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REAL’s proposal includes several options for a retail supplier.

From REAL’s proposal:

[ *** ] REAL suggests an alternative to EOE’s proposal that meets the statutory requirements and minimizes these detrimental impacts on the competitive market. REAL’s alternative proposal would allow suppliers more optionality in the circumstances where the standard service rate becomes lower than the supplier price. In those times, the supplier would have the option to (1) OPTION A: continue to serve the hardship customer at or below the standard service rate (similar to EOE’s Motion), or (2) OPTION B: to return the customer to standard service with the mechanisms in place to notify the customer and offer to re-enroll them on the supplier’s price as originally contracted when that supplier price again becomes lower than the standard service rate during the duration of the term (similar to the current process with additional customer notice); or (3) OPTION C: to return the customer to standard service with the agreement and mechanisms in place to re-enroll them on the supplier’s price as contracted when that supplier price again becomes lower than the standard service rate during the duration of the term (similar to Option B, but a seamless re-enrollment of the customer).

In all three options, the customer is getting the benefit of the lower of the supplier price and standard service rate and the supplier is taking care of any necessary dropping and/or re-enrolling (i.e., the EDC does not need to take on this responsibility). The important difference for the supplier is whether the supplier will take a loss and serve the hardship customer when the standard service rate is lower (under Option A), or if that supplier will not continue to serve the customer (under Options B and C), let the EDC serve the customer at the lower standard service rate, and re-purpose the hedged power. 

Fundamentally, EOE’s proposal in the Motion – to force suppliers to serve hardship customers when (1) the population is not known and can change at any time, and (2) generally, the standard service rate is only known for 6 months at a time – acts in contravention to the law and disrupts the robust competitive markets Connecticut has built and, presumably, hopes to continue for years to come.

In sum, not forcing suppliers to serve at a loss and allowing them the optionality to repurpose that hedged power for other customers will address the concerns above regarding legality and constitutionality of the proposal and the price and term length impacts on the market. This would meet the statutory requirement that hardship customers never be served at prices above standard service and would preserve EOE’s goal of providing customers with fewer barriers to accessing supplier prices when advantageous, as they would seamlessly be re-enrolled with the supplier once the standard service rate exceeds the supplier’s price. [ *** ]

As noted in the EOE Motion, there are numerous existing structures in Connecticut that will need to be addressed in order to implement either EOE’s Motion or REAL’s alternative proposal. Both deal with similar topics and challenges. REAL submits that should the Authority, EOE, the EDCs, and stakeholders undertake such a process, all involved would be better served by a more customer and market friendly result yielded by REAL’s alternative proposal. 

Additionally, REAL notes that, in addition to the legal reasons that application of these structures to all residential customers is not authorized, neither model is easily or viably extrapolated to all residential customers. Both models involve suppliers changing their behavior around the affected customers at any point that the supplier price is higher than the standard service rate – either by serving those customers at a loss or by dropping those customers to standard service. Subject to the cautions and suggestions above, this can be viable where there is another segment of the competitive market to help balance these changes. Were either proposal to be applied to all residential customers, suppliers would find themselves facing periods where they either cannot serve or must serve at a loss. Suppliers might choose to exit the market rather than take on such a reality.

For all the above reasons, additional time and process is needed to work out the details of a viable path forward. REAL believes that, if given the appropriate time and consideration, once finished, this process will further enhance Connecticut’s robust competitive market. Therefore, REAL respectfully requests that the Authority not approve the proposal in EOE’s Motion at this time, as EOE itself requests in the Motion, and continue to work with stakeholders on developing and implementing a legally sound solution that will best serve hardship customer and all residential customers in Connecticut. [ *** ]

From Notice: 

[ *** ] The Authority seeks comments from the working group members by Thursday, August 21, 2025, at 4:00 p.m., regarding the following topics: 

Retail Energy Advancement League’s (REAL) alternative proposal (Alternative Proposal) to the Office of Education, Outreach, and Enforcement’s (EOE) proposed supplier contract language referenced in EOE’s Motion No. 30. See REAL Comments, July 8, 2025, pp. 4-5.

The entity best suitable to effectuate and/or administer REAL’s Alternative Proposal. Id. 

Provide specific redline edits to the “Next Cycle Rate Decision” that would need to be adopted to resolve any perceived conflicts. See Decision, Dec. 19, 2018, Docket No. 14-07-19RE05, PURA Investigation Into Redesign of the Residential Electric Billing Format – Review of Summary Information, Implementation, and Display. 

Provide specific redline edits to the “Variable Rate Definition Decision” that would need to be adopted to resolve any perceived conflicts. See Decision, Nov. 5, 2014, PURA Establishment of Rules for Electric Suppliers and EDCs Concerning Operations and Marketing in the Electric Retail Market. [ *** ]

Notice (08/04/2025)
REAL Comments (07/08/2025) 
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))