Commission would require more detail regarding the speed and accuracy with which information will be passed along to EDCs. If customers make a payment, enter into a payment plan at the last minute, or present a medical certification, then the EGSs must ensure that the information is transmitted to the EDCs quickly so that termination can be avoided entirely or reconnection of service can begin immediately. Next, NRG recommends that EDCs provide required termination notices to customers and physically terminate service, while EGSs handle all other communications with customers. The prudency of this system of communications is not substantiated in the Petition. Rather, NRG fails to explain the merit of having customers receive a termination notice from their EDC, while then expecting customers to follow up on such notice with their EGS of record. Additionally, important details are lacking, such as whether or not an EDC sending a termination notice to a customer must include the EGS’s contact information on the notice. Customers are presently accustomed to directing distribution service related complaints and inquiriesincluding those for billing, payment, and termination issues—to their EDCs. Under NRG’s proposal, customers’ bills would come from their EGSs and payment arrangements would be made with their EGSs, but termination notices and actual termination would be handled by their EDCs. This division of responsibility could confuse customers. In addition to potentially being confusing for customers, the process could be unwieldy. A customer making a payment or providing a medical certification to prevent a threatened termination of service would have to communicate with the EGS. The EGS would then have to take that information and provide it to the EDC. This extra to the current situation where the EDC would be in direct contact with the customer—could cause communication delays, increasing the risk that customers would be subjected to an improper termination of service or delay in reconnection.
Commission would require more detail regarding the speed and accuracy with which information will be passed along to EDCs. If customers make a payment, enter into a payment plan at the last minute, or present a medical certification, then the EGSs must ensure that the information is transmitted to the EDCs quickly so that termination can be avoided entirely or reconnection of service can begin immediately. Next, NRG recommends that EDCs provide required termination notices to customers and physically terminate service, while EGSs handle all other communications with customers. The prudency of this system of communications is not substantiated in the Petition. Rather, NRG fails to explain the merit of having customers receive a termination notice from their EDC, while then expecting customers to follow up on such notice with their EGS of record. Additionally, important details are lacking, such as whether or not an EDC sending a termination notice to a customer must include the EGS’s contact information on the notice. Customers are presently accustomed to directing distribution service related complaints and inquiriesincluding those for billing, payment, and termination issues—to their EDCs. Under NRG’s proposal, customers’ bills would come from their EGSs and payment arrangements would be made with their EGSs, but termination notices and actual termination would be handled by their EDCs. This division of responsibility could confuse customers. In addition to potentially being confusing for customers, the process could be unwieldy. A customer making a payment or providing a medical certification to prevent a threatened termination of service would have to communicate with the EGS. The EGS would then have to take that information and provide it to the EDC. This extra to the current situation where the EDC would be in direct contact with the customer—could cause communication delays, increasing the risk that customers would be subjected to an improper termination of service or delay in reconnection.