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Utility Seeks Delayed Start Date For New Purchase Of Receivables (POR) Program
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Granite State Electric (Liberty Utilities) in New Hampshire is seeking a new date for the implementation of a new purchase of receivables (POR) program, stating that the implementation timeline contained in a settlement is not feasible
As more fully discussed below, GSE proposes to more than double the POR implementation timeline, from about 60-75 days after New Hampshire PUC approval, to over 150 days after PUC approval
As previously reported, a settlement established the POR go-live date as two months after the New Hampshire PUC approves tariffs and supplier agreements to implement POR (the PUC already approved general design elements for POR, with a second phase of the proceeding addressing the tariffs and supplier agreements)
While the settlement established such a deadline for POR, GSE states that the PUC, in a Phase 1 order on POR design which addressed the settlement, did not endorse the settlement's POR start date. Rather, GSE said that the PUC, in such prior order, held that the start date for POR would be determined during Phase 2 of the proceeding
GSE said that it now believes that two months, or even two and a half months, is not sufficient time to implement POR upon receipt of a Phase 2 order from the PUC adopting tariffs and supplier agreements
GSE said that, following PUC approval of the POR tariff and supplier agreement, GSE will need to send new supplier agreements to retail suppliers, and have such executed agreements returned
To the extent a retail supplier does not sign the new supplier agreement, GSE would, as previously reported and now under a stipulated proposed supplier agreement not opposed by any party, drop a non-signing retail supplier's customers to default service. Such action would be undertaken since GSE will not offer UCB without POR, and a supplier refusing to sign a new supplier agreement, that limits UCB to UCB with POR, could otherwise hold up POR implementation (see more discussion of the customer drops here
GSE said that the return of such potential shopping customers to SOS, due to their supplier not executing a new supplier agreement, would take "considerably more time" than two and a half months, due to the need to provide customer notice and to allow for such drops to be performed in an, "orderly fashion."
GSE also noted that, while the design of the POR discount rate has been approved by the PUC, the initial discount rate will be based on up-to-date information, and accordingly the initial discount rates can not be included in the pending proposed tariff and supplier agreements. As such, GSE said that time will still be needed for the PUC to formally approve the initial discount rate once filed
GSE proposed that POR start 150 days from the effective date of the revised tariff to implement POR. GSE says that the effective date for the tariff will be the 1st of the month following the date of PUC approval, and thus the time between the PUC's tariff order and the start of POR could vary anywhere from 151 days to about 180 days, depending on the specific date in the month in which the PUC approves the tariff.
During this ~150 day period, GSE would, as needed, inform customers that their supplier did not sign the new supplier agreement, and that the customer will be dropped to default service. As part of this notice process, GSE proposed that customers be provided about two months to shop for a new supplier before the drops start, thus adding time to the POR implementation timeline
GSE expects that PUC approval of the initial discount rate would be provided within 90 days of the tariff's effective date; thus, the driver of the delay beyond ~90 days is the two-month shopping period provided to customers whose suppliers do not sign the new supplier agreement
GSE's sought delay was included in new testimony filed in the POR proceeding
Also of note in the testimony is that GSE stated an intent, when permissible, to provide to all retail suppliers any new services that must, by statute, be offered by GSE to municipal aggregations (or their suppliers), but with no statutory obligation for such services to be also provided to retail suppliers.
Among such services, pending the outcome of a PUC rulemaking on such services, is implementing an option for bill ready billing
GSE said that offering new services to all suppliers, not only CCAs, would, "maintain a level
competitive playing field."
Docket DE 23-003
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January 10, 2025
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Reporting by Paul Ring • ring@energychoicematters.com
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