Electricity – Markets
Direct Energy Regulated Services (“DERS”) filed an application requesting that the AUC enforce Rule 004: Alberta Tariff Billing Code Rules (“Rule 004”) on ATCO Electric Ltd. (distribution) and ATCO Gas (the “ATCO Utilities”).
DERS learned that the ATCO Utilities planned to only migrate three months of pricing data when they complete their data migration to their new Customer Information System (“CIS”). The ATCO Utilities’ CIS is important to retailers in that it houses all the necessary processes to generate the tariff bill file that retailers use to generate bills for customers. Cancel-rebills are market transactions that are required whenever a transaction sent from the distributor to a retailer must be corrected in some manner. The ATCO Utilities notified DERS that after their CIS migration, they plan to utilize a manual solution for cancel-rebill transactions that occur outside of the three-month period of data migrating to the new CIS system.
DERS was concerned with the process proposed by the ATCO Utilities because the process proposed would not meet the requirements of s. 5.4.4 of Rule 004 and would cause significant market harm.
The AUC found that the manual process, as proposed by the ATCO Utilities for cancel-rebills beyond the initial three months of data being migrated over to their new CIS, does not meet the requirements of Rule 004. The AUC directed the ATCO Utilities to report back to the AUC on their automated solution by November 17, 2022.
AUC Rule 004: Alberta Tariff Billing Code Rules, s. 5.4.4.
Under of s. 2.14 of Rule 004 a distributor must retain tariff billing data in its original format to allow for one-time charge records for cancel and rebill transactions for periods beyond two years. DERS raised the concern that the plan proposed by the ATCO Utilities to process cancel-rebill transactions manually does not comply with Rule 004. The ATCO Utilities disagreed with DERS’ assertion that their manual cancel-rebill process will not comply with s. 2.14. The ATCO Utilities also explained that s. 5.4.4 (cancels and rebills of charges spanning extended periods) of Rule 004 expressly allows for one-time charge adjustments for data that is not converted and this is a process currently being performed by market participants. The ATCO Utilities relied on this provision to allow them to have retailers make manual adjustments for cancel-rebill transactions that occur beyond the three months of data that will be migrated to their new CIS, noting that “data retention” is an undefined term in Rule 004.
The AUC found that there is an express link in Rule 004 between s. 2.14 and s. 5.4.4, and that the history of s. 5.4.4 and the policy objectives of Rule 004 all support the view that “data retention” has the same meaning in s. 2.14 and s. 5.4.4.
The AUC recognized that a CIS transition is infrequent and that an exemption from Rule 004 may be appropriate in specific circumstances.