PRR759

This PRR is designed to align Section 15, Customer Registration, specifically Section 15.1.4.3, with P.U.C. Subst. R. 25.474(l)(1). This PRR will eliminate the move-in Customer notification.

Currently, P.U.C. Subst. R. 25.474(l)(1) requires a notification only for switches. It states:

“(1) Switches. The registration agent shall send a switch notification notice that shall:(A)be sent in English and Spanish consistent with §25.473(d) of this title (relating to Non-English Language Requirements); (B)identify the REP that initiated the switch request;(C)inform the applicant that the applicant's REP will be switched unless the applicant requests the registration agent to cancel the switch by the date stated in the notice;(D)provide a cancellation date by which the applicant may request a switch to be cancelled, no less than seven calendar days after the applicant receives the notice; and (E)provide instructions for the applicant to request that the switch be cancelled. These instructions shall include a telephone number, facsimile machine number, and e-mail address to reach the registration agent. The registration agent shall take appropriate actions to process an applicant's timely request for cancellation."

The rule does not require that a move-in notification notice be sent.

Currently, Section 15.1.1.1, Notification to Customer of Switch Request, supports the above rule. However, Section 15.1.4.3 goes beyond the rule and provides notices for move-in orders. Under this Protocol, the Customer's only option to cancel the Move-In Request is to contact the submitting Retail Electric Provider (REP). ERCOT cannot process a cancellation for a move-in order as it can with a switch order based on Customer objection.

The original decision to send notices on move-in orders was based on the assumption that it may offer the Customer an opportunity to cancel the move-in order through contacting the submitting Competitive Retailer (CR), or to advise the CR that the order was submitted in error. In reviewing performance measures data, it is apparent that improved performance in processing move-in orders and increased monitoring of the inadvertent gain process has made the move-in notice ineffective and unnecessary.

In 2007, ERCOT processed a total of more than 2,500,000 move-in transactions of which more than 850,000 required that a Customer notification be sent at a cost of more than $450,000.00.

Given the current timing in processing priority move-in orders within two (2) Retail Business Hours and standard move-in orders within one (1) Business Day, it was identified that over 59% of move-ins were completed within four (4) Business Days. Because of the inherent timing of the notification process for move ins, the Customer could not expect to receive the notice until well after the move-in has been processed and completed in the ERCOT registration systems. This 59% amount can also be expected to increase after the new Terms and Conditions move-in process timing becomes effective, which will make the Customer notice process even more ineffective in supporting Customer protection.

It was also determined that in 2007, of the total of 2,500,000 move-in orders processed only 1.08% were cancelled by CR request, and of the move-in orders with notices sent only 00.42% were cancelled by CR request. This indicates that the notice did not have an appreciable effect on the number of cancels submitted by the CR.

In summary, approval of this PRR wouldbetter align the ERCOT Protocols with the PUCT substantive customer protection rules,reduce annual expenses by approximately $450,000.00, andhave virtually no effect on the Customer's ability to dispute move-in orders. Customers will continue to contact the submitting CR to request a cancel or use the inadvertent gain process.