April 1, 2022
Mr. Jeffrey R. Gaudiosi, Esq.
Public Utilities Regulatory Authority
10 Franklin Square
New Britain, CT 06051
Re: Docket No. 20-07-01, PURA Implementation of Section 3 of P.A. 19-35, Renewable Energy Tariffs and Procurement Plans – Compliance Order No. 20
Docket No. 21-08 02, Annual Residential Renewable Energy Tariff Program Review and Rate Setting - Correspondence
Dear Mr. Gaudiosi:
In compliance with the Public Utilities Regulatory Authority (“PURA” or “Authority”) Interim Decision dated February 10, 2021, The United Illuminating Company (“UI” or “Company”) hereby submits its response to Order No. 20 in the captioned docket.
Order No. 20 states:
Pursuant to Conn. Gen. Stat. § 16-244z(b)(2), the EDCs shall begin accepting applications for the Residential Tariffs authorized herein on January 1, 2022, with the EDCs’ billing systems ready to accommodate renewable energy projects interconnected and energized under the Residential Tariffs on or before April 1, 2022. The EDCs shall undertake all reasonable efforts to make their billing systems ready to accommodate renewable energy projects taking service under the Residential Tariffs interconnected and energized before April 1, 2022, so long as it does not significantly increase administrative costs. The EDCs shall notify the Authority once their systems are ready to begin interconnecting and energizing projects under the Residential Tariffs.
The Residential Tariffs /Residential Renewable Energy Solutions (RRES) continues to be a significant undertaking, impacting multiple functional areas, including customer service, meters engineering, power procurement, billing, and Information Technology (IT). The launch of RRES required a new online application portal to be developed while the entire interconnection application process was redesigned. The most complex components of the program implementation involve changes to the secure billing system to accommodate on-bill credits to customers.
Pursuant to Order No. 20, UI met PURA’s requirement to “begin accepting applications” for RRES on January 1, 2022 with the launch of its updated on-line Application Portal. UI continues to make iterative enhancements to its billing systems to accommodate renewable energy projects interconnected and energized on or before April 1, 2022. As of today, UI has developed an interim process to meet PURA’s requirement to “interconnected and energized” by April 1, 2022; however, the full suite of UI’s billing system changes is not yet ready to go live. This project to enable such changes proved to be extremely complex, requiring significant changes to UI’s SAP system across multiple business areas and functions in order for the system to accommodate customer credits on bill, as well as off bill direct payments. Based on the complexity of these changes, all system changes are anticipated to go live by April 30, 2022.
UI has been working diligently on this complex project since March of 2021. Early in the project, it became evident that all the required system changes that were required to implement the RRES program involved changes that were significantly more expansive than simply updating its billing system. In order to minimize administrative costs while engaging the appropriate technical expertise, UI secured two external resources with expertise in rates and SAP programming, engaged a cross functional team of subject matter experts representing eleven UI business areas and shifted two additional internal resources to support the project. The business areas and functions directly involved in the integrated processes to bring a solar PV project from interconnection through meter data management and ultimately to billing include Distributed Generation, Wholesale Power Contracts/Power Procurement, Customer Care, Meter Engineering, Meter Data Management, Standard Field, Rates, and Billing. Each of these areas is impacted by the IT systems changes being implemented.
The project to implement all required system functionality for RRES entailed a process of requirements gathering, functional specification development, technical specification development, system build and user acceptance testing (system testing and validation by the business), and then moving the system changes into production (go-live). As of this filing, the requirements gathering, functional and technical specification development, system programming, and functional unit testing are all 100% complete. The final remaining project components are user acceptance testing by the business. The user acceptance testing phase is the phase in which the business users test and validate system functionality. The testing is very complex because it touches so many business areas and functions. It is critical that time and care is taken at this testing stage to ensure that the system roll out is as smooth as possible and that technical issues and adverse impacts to customers are minimized. Although not anticipated, if testing exposes any significant issues, it is possible that the go-live date may extend past April 30, 2022.
So as not to delay the ability for projects to be installed, UI has defined an interim process to ensure that projects can be interconnected and energized by April 1, 2022. For customer projects that are interconnected and energized prior to April 30, these customers’ bills will be held by UI until the SAP system changes are live. This bill delay will be communicated to these customers when they are set up on the new rate. Once the changes go live, meter data will be captured and customers should begin receiving applicable credits in their May billing cycle UI anticipates that this process could impact less than one hundred customers with 2022 projects, because UI believes that the majority of projects achieving approval to energize through the month of April will be under the 2021 net energy rate and would therefore not be impacted by these billing delays.
UI has pursued all aspects of this project in good faith with the goal of providing a positive customer service, minimizing program costs and meeting PURA’s requirements.
I hereby certify service of this filing upon all parties and intervenors of record in this proceeding.
Very truly yours,
Manager, Regulatory Services
UIL Holdings Corporation
As Agent for The United Illuminating Company
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