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PUCT Staff Draft Proposal for Adoption Would Retain Rescission Period, Extend Reconnect Deadlines
September 22, 2011
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A PUCT Staff recommended proposal for adoption would retain the rescission period for all enrollments of customers under 50 kW, and also provides a later deadline than originally proposed for the submission of an AMS reconnect for it to be completed on the same day.
The rulemaking, Project 38674, addresses several new operational timelines due to advanced metering. As first reported by Matters, one of the most notable provisions of a proposal for publication was the proposed elimination of the rescission period, except where required by federal law, to facilitate same-day switching of retail electric providers (4/22).
However, elimination of the rescission period was opposed by the Texas Energy Association for Marketers, which cited several operational issues. In particular, if the rescission period were eliminated, but the customer regrets their switch and quickly returns to their original REP, the customer's new REP would become responsible for TDU and wholesale charges for the period of time it served the customer. Collecting these charges for only a few days of service would be difficult, TEAM said.
Currently, if a REP serves a customer who later rescinds their switch, the "new" REP is not responsible for any of these costs, which are allocated to the customer's original REP which retains the customer (see 6/22 for discussion)
Elimination of the rescission period except where federally required was also opposed by consumer groups.
In its recommended proposal for adoption, Staff was persuaded to maintain the rescission period for all small volume enrollments as currently required. Staff noted that a same-day switching process can still be implemented with the rescission period in place.
Staff said that retaining the rescission period for all forms of enrollment, "is particularly important for telephonic enrollment where a customer receives oral disclosures but is not provided the Terms of Service (TOS) or Energy Facts Label (EFL) prior to entering into the transaction."
In 2010, 3.5% of all switches were cancelled by either a customer exercising the right of rescission, or to correct a situation where a customer was accidentally switched by the REP. Over half of these switches were cancelled using the manual MarkeTrak process. The remainder were cancelled by an automatic method that can be used before a switch has been completed.
Staff noted that implementing same-day switching with a three-day right of rescission will likely increase the number of switches cancelled using the manual MarkeTrak method, but found that the increased burden is outweighed by the benefits of the right of rescission which inure to customers as well as new REPs who briefly gain but then lose those customers back to the original REP (since the new REP will not be assigned TDU and wholesale costs for this brief period).
Regarding reconnects, for customers with provisioned advanced meters, Staff's proposal, for customers not on prepaid service, would require that the TDU complete the reconnect on the same business day on which it was received, if the reconnect was submitted before 4 p.m., regardless of whether communication with the meter is successful.
For customers on prepaid service with advanced meters, Staff's proposal would require the TDU to complete the reconnect request on that business day if the request is received before 5 p.m., regardless of whether communication with the meter is successful.
Six months after implementation of TX SET 4.0, each TDU would be required to file with the PUCT for a review of these AMS reconnect order deadlines to determine if the success rate in meter communication supports extending the deadlines for submission of the reconnect requests.
Staff would reject the TDUs' proposal to re-introduce a Priority Move-In charge for customers with advanced meters (for those circumstances in which the meter is not communicating with the TDU), with Staff finding that any costs of completing a Priority Move-in during times of meter communication failure can be recovered through other avenues.
Staff would adopt the joint recommendation of TDUs and REPs to include a 7 p.m. deadline for submission of an AMS switch request for the switch to be completed on the same day. This deadline is required because TDUs shut their registration systems down at night for batch processing.
Staff would reject consumer advocates' recommendation to prohibit REPs from charging their own fees in addition to the TDU fee for various discretionary services such as disconnection, Move-In, etc.
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