Change Location Transactions

EBT Standards Working Group – Discussion Document

GI 821 – Drop Reason Code Update

DISCUSSION PAPER

OEB EBT WORKING GROUP

This contribution has been prepared by Direct Energy Marketing (DEML), for the purposes of discussion in OEB EBT Working Group and is not to be construed as a binding proposal on DEML. DEML reserves the right to amend or withdraw statements made in this contribution.

Index

I. Document Version Control 3

II. Issues/Activity Log 4

III. Introduction 5

A. Impacts 6

V. Proposed changes 6

VI. Comments 6

VII. Appendix 6

I.  Document Version Control

II.  Issues/Activity Log

III. Introduction

Ontario Electricity market relationships between utility companies and retailers are governed by various standards, rules and codes. It has always been understood that the utility owns and maintains the customer data and is therefore responsible to provide updates to the retailer. This process facilitates account management and allows both the LDC and the retailer to serve the customer in the best possible manner. As such, many market processes and transactions have been developed with this as a basic market understanding.

Retailers have put forth a market request to update the drop transaction to provide more accurate reason codes in the drop transaction in order to better serve customers and establish reliable automated processes. Some LDC’s have argued that this is contrary to privacy laws and do not support any changes.

To support customer information being communicated to the retailer, specific to drop reason codes, the following points are made for consideration.

EBT Standards

The EBT Standards v 4.0 document has been developed to outline transaction flows and market guidelines. Section 1.1 defines ‘Guiding Principals’ established for the market.

Transactions should be developed to:

·  Facilitate Consumer choice and mobility in an open market

·  Lower the requirements for entry into the market for participants

·  Control costs and increase efficiency, speed and accuracy

·  Minimize exception and manual processing

·  Focus on the use of electronic solutions rather than paper based ones.

Section 4 of the EBT Standards outlines the business relationships of the Consumer, Retailer and Distributor. Specifically relating to the issue of providing more specific reasons for customer’s accounts being terminated, the following are noted:

Consumer:

1. Provides appropriate authorization to a Retailer for release of historical consumption and payment history information from the Distributor to that Retailer

4. Provides the appropriate authorization for the Retailer to enroll the Consumer

6. Notifies Retailer to drop from Retailer to Standard Supply Service (SSS); alternatively may contact Distributor to drop to SSS but may incur charge with this option if off-cycle.

7. Notifies Distributor or Retailer of a move, initiation, or disconnect of Distributor service.

Retailer:

3.  Obtains the appropriate authorization from the Consumer for historical consumption information and payment history information to be released by the Distributor to the Retailer.

4.  Obtains the appropriate authorization from the Consumer for Enroll STR.

Distributor:

5.  Maintains records of required data related to the current and active Consumer/Retailer services.

8.  Makes available to the Retailer and Consumer data, including but not limited to meter data, standards documents, meter read schedules, etc.

9.  Is the sole party who can terminate (i.e. physically disconnect) electric service to the Consumer.

10. Processes EBT transactions and updates Consumer account information according to EBT standards, including use of Functional Acknowledgements on all transactions

These defined relationships all point to the intent and understanding that the retailer obtains sufficient consumer authorization to have consumer account information released to them. The distributor defined relationships outlines the fact that the LDC is the ‘owner’ of the account and is responsible for passing information received from the customer to the retailer.

This intent has been further outlined in the development of other market transactions. As examples:

Section 5.1.4 - CCI

Purpose

‘The CCI STR is a transaction for communicating information changes between the parties who service the customer.’ The intent here is for the retailer to receive updated account/consumer information as it relates to the retail relationship/contract.

Flow

‘This request may be sent by either the Distributor to the Retailer or by the Retailer to the Distributor. There is no requirement for the Distributor to match their information to the Retailer. The Distributor is the “owner” of the Consumer information.’

Rules

‘Once a Distributor has sent an Enroll Accept transaction and the Consumer is in a pending enroll state with a Retailer, the Change Consumer Information STR must be used to communicate updated information between the Retailer and the Distributor…’. The intent here is for the retailer to receive updated account/consumer information as it relates to the retail relationship/contract.

Section 5.1.5 - CCL

The intent of the CCL transaction is to maintain the retailer relationship and provide the retailer with updated account and location information as provided by the consumer. The information is received by the LDC and passed onto the retailer in order for the retailer to maintain the account.

Retail Settlement Code

The RSC (Retail Settlement Code) Section 2.4 identifies the requirement for LDC’s to maintain records for all consumers for which it determines settlement costs

Gas Market

The Ontario Gas market currently operates with all but 2 of the suggested reason codes. During the development of GDAR, the OEB advised the participants that gas processes being developed should be synchronized (as much as possible) with current electricity processes. Retailers in the Ontario Electricity market are requesting the same, that the information provided be synchronized with the gas market.

Based on the above points, it is the retailer’s view that the LDC is the owner of account information and is responsible to provide all updates to the retailer. All information provided to the LDC should be transmitted to the retailer in a DCB environment, as it relates to the retail relationship/contract.

A. Impacts

From a consumer perspective, the current limitations of the drop transaction often result in customers being contacted for information already provided to their LDC.

From a Retailer perspective, the current limitations of drop reason codes result in extensive manual processing. As there are currently only 3 valid reason codes which LDC’s should be submitted in the drop transaction, sufficient detail is not provided to allow the retailer to work the accounts correctly and timely.

Retailers are currently receiving numerous variations of the standardized reason codes and are also requesting that the approved values be enumerated to avoid variations. Also, we currently receive detailed information in the Reason Text field, indicating ie: Bankrupt, CCAA protection, Deceased, Move Force Out, Out of Territory, Not responsible at new premise, Unserviceable. Retailers are looking for information currently being provided (mainly in the text field) to be standardized in order to automate processes and provide better customer service through enumerated values.

From Halton Hills – November 26 -2008

“From an LDC perspective, addition drop reason codes would result in a manual process after many of us have moved forward to automateour EBT transactions. Our policies do not include scripted questions for personal information that we do not store in our systems.We already havetime restraints regulated by the Ontario Energy Board to answer our calls. We will not upset a customer by asking personal information that violates their privacy. The retailers may be trying to save time and money by having this information available, however the loss would be to the LDC's for the expenses associated with implementing this GI which only benefits the retailer."

1/16/2009 Page 10 of 10

EBT Standards Working Group – Discussion Document

GI 821 – Drop Reason Code Update

V.  Proposed changes

As reviewed with the EBT working group, the following standardized drop reason codes are being proposed:

VI.  Comments

OEB - Barb Roberston – November 20, 2008

GI 670, which was implemented October 17, 2005, documents the reject reasons and reason codes. The market participant comments attributed to Johanna Raycraft state, in part, "This document does not mean to imply that all participants must use all the following reject reasons. However, if an EBT reject transaction is sent for one of the reasons listed below it must be reported using the associated reject reason text."

It has always been my understanding that the same philosophy applies to the reason codes; that is, there is no requirement that all participants must use all of the reason codes. Rather, they should determine whether or not their own business processes and systems would allow them to store and track the reason codes, and then report the "best fit" reason using the associated reason code text. Because I understand GI 821 to be essentially updating GI 670 with the most current reason codes, I think it is reasonable to apply the same logic that was used in GI 670.

I also believe it would be more appropriate to reiterate this logic in the GI rather than have it buried in action minutes.

Barb Robertson

Project Advisor, Compliance