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Utilities Ask Regulator For Straw Proposal, Comment Period On Any New Restrictions On Retail Choice, To Allow Robust Review Of Technical Feasibility
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Connecticut Light & Power and United Illuminating, in a joint motion, have asked that the Connecticut PURA, in a proceeding addressing appropriate limitations on customer choice to hardship customers, issue a straw proposal and allow for a comment period prior to adopting any new limitations
See background on the proceeding here
The utilities cited the procedural tenor of the case, and said that parties have not been provided with an opportunity to comment on any proposed supplier contract limitations or other proposed changes in Phase 2 of the proceeding (hardship customers).
While PURA did set an initial and reply comment deadline, the EDCs observed that, for initial comments filed in December 2024, "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."
Only at the deadline for reply comments (and in separate "briefs" due on the same day) did PURA's Office of Education, Outreach, and Enforcement, and the Office of Consumer Counsel, each separately file substantive comments with specific proposals impacting the retail market. See details here
The EDCs stressed that utilities must be provided an opportunity, before a proposed final decision is issued, to address the feasibility, achievability, timeline, and estimated costs to implement any contract limitations or other policies adopted by PURA
"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," the utilities said
The utilities asked that PURA issue a straw proposal, along with a request for written comments and the convening of a technical conference or working group, to discuss any proposed limitations on retail contracts or choice
Citing the various proposals raised for the first time in the reply comments and same-day briefs, the utilities said, "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," the EDCs said
Docket 18-06-02RE02
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February
3, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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