OPERATIONAL BUSINESS RULES AND ELECTRONIC DATA INTERCHANGE STANDARDS

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1 OPERATIONAL BUSINESS RULES AND ELECTRONIC DATA INTERCHANGE STANDARDS I. INTRODUCTION...1 II. BUSINESS RELATIONSHIPS...2 A. CUSTOMER'S RESPONSIBILITIES... 2 B. ENERGY SERVICE PROVIDER'S RESPONSIBILITIES... 2 C. SERVING UTILITY'S RESPONSIBILITIES... 3 III. BUSINESS RULES AND TRANSACTIONS...5 A. PRINCIPLES... 5 B. TRANSACTION SETS... 5 C. BUSINESS RULES... 6 IV. DATA FORMAT...13 V. ELECTRONIC TRANSMISSION...14 VI. INFORMATION SYSTEM ("IS") OPERATIONS...15 A. SCHEDULING B. FILE HANDLING C. ERROR HANDLING D. RECOVERY VII. TRAINING AND TESTING...18 A. TRAINING FRAMEWORK B. TESTING REQUIREMENTS C. COMPLIANCE TEST... 20

2 I. Introduction In order to implement the Retail Open Access Tariff ( R-OAT ) and related Delivery Service tariffs proposed in Docket No., there are many logistical issues that need to be worked out. Central Vermont Public Service Corporation ( CVPS ) and Green Mountain Power Corporation ( Green Mountain ) (together the Companies, singularly the Utility ) have developed a proposed standard for the operational business rules and electronic data interchange ( EDI ) standards that are required to facilitate the transaction of business between Customer s, competitive Energy Service Providers ( ESPs ) and the Companies. In order to develop consensus on the appropriate business rules and EDI standards the Companies recommend establishing a working group that includes representation from all affected stakeholders. The objectives of the working group should be three fold: (1) to develop the required set of business rules and EDI standards required by the ESPs; (2) to balance the needs of the ESPs with the constraints of the Companies current infrastructures; and (3) to meet the short term requirements necessary to implement retail choice while remaining flexible enough to accommodate future adoption of regional and national operational business rules and EDI standards. The working group should leverage the work that has been done in other neighboring states on these business rules and EDI standards and modify them to meet Vermont s unique needs

3 II. Business Relationships In order to establish a set of mutually agreed upon standards, there first must be an understanding of the business relationships to which the standards will be applied. The following represents the Companies current understanding of these business relationships and is intended to serve as a framework for establishing the operational business rules and related EDI standards necessary to provide for competition in the sale of Generation Service as contemplated under the Companies proposed Retail Open Access Tariff. For the purpose of this document the term enrollment means the transaction involving a customer signing up or canceling generation services from an ESP. A. Customer s Responsibilities # Evaluate and secure Generation Services from an ESP. # Select only one ESP for enrollment per Delivery Service account. # Give ESP authorization for enrollment. # Give the serving Utility authorization to restrict the release of historical usage information. # Give the serving Utility authorization to restrict the release of the Customer s telephone number. # Notify the ESP and/or the serving Utility of any concerns regarding energy supply. # Notify the serving Utility of a new Delivery Service connection, move or disconnect. B. Energy Service Provider s Responsibilities # Obtain authorization to sell Generation Service under the R-OAT from the Vermont Public Service Board (the Board ). # Obtain authorization from customers for customer enrollment and the release of historical usage information by the serving utility. # Obtain the applicable information from the Customer, required to enroll the Customer on the serving utility s records as receiving Generation - 2 -

4 Service from the ESP. (Only an ESP can establish Generation Service for a Customer with the serving Utility). # Exchange information electronically with the serving Utility for enrollment, changes or discontinuance of service, etc. # Render bills for Generation Service. # Resolve customer payment problems for relevant ESP Generation Services charges. # Maintain records on customer Generation Service payments and fees. # Participate in electronic systems testing as defined by the serving Utility. # Provide a point of contact to facilitate business and technical communications. # Enter into an Operating Agreement with the serving Utility as required under the R-OAT. # Comply with all applicable rules and other requirements issued by the Board. # Implement and maintain data transmission standards as defined by the Board. # Be responsible for all Value Added Network ( VAN ) charges related to the EDI transactions. # Communicate and resolve customer disputes. C. Serving Utility s Responsibilities # Provide customers with the Board s list of ESP s authorized to sell Generation Service under the R-OAT. # Provide customer information to ESP s when not restricted by customer. # Exchange information electronically with ESP for enrollment, changes or discontinuance of service, etc

5 # Maintain an Internet site for access by authorized ESP s that contains generic information necessary to implement the Retail Open Access Tariff (e.g. R-OAT, Delivery Service tariffs, Delivery Service class average load shapes, scheduled cycle meter-read dates, relevant computer operations schedule). # Release the Utility s Delivery Service rate class load profiles to ESP s where available. # Provide required metering and billing information to ESP s. # Maintain records of required data related to the current Customer/ESP services. # Schedule normal cycle meter-read dates and read meters. # Provide a point of contact to facilitate business and technical communications. # Implement and maintain EDI data transmission standards as defined. # Provide beginning and ending meter readings as well as kilowatt-hour consumption, and demand information (if appropriate) to the ESP. # Perform daily and monthly aggregate load estimate for each ESP and report estimates to the Independent System Operation for New England ( ISO-NE ). # Terminate (i.e. physically disconnect) Delivery Service to the Customer (this function can only be performed by the serving Utility). # Communicate and resolve customer disputes. # Notify affected customers of the termination or suspension of their ESP s authority to provide Generation Services in the serving Utility s service territory. # Arrange Transition or Default Service for customers who are not provided service from an authorized ESP in accordance with Board rules, regulations and the R-OAT

6 III. Business Rules and Transactions A. Principles The Companies recommend that the following principles be used in developing the operational business rules and EDI standards necessary to facilitate the Retail Open Access Tariff: # Minimize the number of transactions. # Use automated electronic solutions instead of paper and manual solutions. # Minimize exception processing. # Control costs by leveraging existing infrastructure. # Maximize transaction efficiency, speed and accuracy. # Minimize customer confusion. # Protect the Customer s rights. B. Transaction Sets A Transaction Set is an EDI term for the data required to complete a business transaction. There are four (4) EDI transaction sets proposed to transact business under the Companies Retail Open Access Tariff

7 Standard transaction Function Business Transaction Number Flow Data Format Account Administration Enroll Customer Change Enrollment Detail Change Enrollment Detail Successful Enrollment Customer Move Error Customer Drops ESP ESP Drops Customer Confirm Drop Date NS -> DC ES -> DC DC -> ES DC -> NS DC -> ES DC -> NS, ES DC -> OS ES -> DC DC -> ES I-Enroll I-Change I-Change I-Success I-Move I-Error I-Cust.-Drop I-ESP-Drop I-Confirm Usage/Billing Customer Usage Information - (Standard Option) 10 DC -> ES II-Customer Usage Customer Usage Request Usage History Customer Usage History NS,ES -> DC DC -> NS, ES V-History V- History DC, the serving Utility; ES, Existing ESP; OS, Old ESP; NS, New ESP Electronic-Mail Transaction Settlement Aggregate Load Estimate 13 DC -> ES IV-Load Prior to the submission of any transaction, an ESP must first comply with the Board's certification and/or registration requirements for authorization to sell Generation Service under the R-OAT, participate in training, successfully complete tests of electronic transaction transfer capability, obtain the initial authorization from a Customer for enrollment, and execute an Operating Agreement with the serving Utility. C. Business Rules This section provides a detailed description of the proposed business rules for the electronic transactions that will be used to facilitate retail choice and govern the implementation of the terms and conditions of the Retail Open Access Tariff for ESPs. Transaction Set Function: Account Administration # Enroll Customer: The ESP shall submit customer enrollment after receiving the appropriate authorization for each account and after any rescission period has lapsed. Appropriate authorization can be submitted by the customer in writing, in electronic form, or be given orally to a qualified and independent third party. The ESP notifies the serving Utility - 6 -

8 using the Enroll a Customer function. (See Transaction #1). An ESP must transmit the Enrollment transaction no less than five (5) business days prior to the scheduled cycle meter-read date or the enrollment will be deferred to the following read date. The serving Utility shall process enrollment requests in the order in which they are received at its VAN or alternative transfer mechanism. Multiple Enrollments: In most cases, it is anticipated that a Customer will select an ESP, the ESP will allow the customer rescission period to lapse, and will enroll the Customer with the Serving Utility, as described above. The enrollment period commences four (4) business days prior to the Customer s scheduled cycle meter-read date and ends five (5) business days prior to the Customer s next scheduled cycle meter-read date. In the event that a Customer selects more than one ESP, and those suppliers attempt to enroll that Customer for the same enrollment period the serving Utility shall respond as follows: The serving Utility shall process the first valid enrollment transaction received during the enrollment period. Once received and in force, any other enrollment transaction submitted for the same Customer during the enrollment period will be rejected. Multiple Services: Where more than one Delivery Service is assigned to a Customer account, an ESP may submit one enrollment transaction for all services or one enrollment for each service. When an ESP successfully enrolls a Customer with multiple Delivery Services, a successful enrollment transaction will be transmitted to the ESP for each service enrolled. Because of the nature of these accounts, if one enrollment transaction is rejected due to data error, then the enrollment of the entire account must be rejected. # Change Enrollment Detail: The ESP will notify the serving Utility to change enrollment detail for a specific customer. (See Transaction #2). Changes will be effective within one business day of notification. The serving Utility will also notify the ESP of a change in enrollment detail for a specific customer (e.g. different cycle meter-read date). (See Transaction #3). # Successful Enrollment: The serving Utility will notify the ESP that the requested Enrollment was successful. (See Transaction #4). The notification will include the projected date that the new or changed - 7 -

9 Generation Service will become effective, the account number and the billing address. # Customer Move: When a Customer moves within the serving Utility s service territory they normally will contact a Utility customer service representative. The serving Utility s customer service representative will then initiate a process which enables the Customer to continue to receive Generation Service from its current ESP at the new Delivery Service address, unless the Customer indicates otherwise (e.g. Transition or Default Service). The following transactions are initiated: A Customer is automatically enrolled with its current ESP at the Customer s new Delivery Service address and a Customer Move transaction is sent to the ESP. (See Transaction #5). A Customer Usage Information transaction is sent to the ESP providing Generation Service at the old address. (See Transaction #10). Change Enrollment Detail transaction will be sent by the ESP to notify the serving Utility of the new ESP account number and other pertinent account information changes. (See Transaction #2). Within the Serving Utility s Service Territory Different Supplier: If a Customer moves within the serving Utility s service territory and desires to continue competitive Generation Service (e.g. non-default or non- Transition Service), but with a different ESP, the Customer can authorize the other ESP to Enroll them with the serving Utility. Outside of the Serving Utility s Service Territory: If a Customer moves out of the serving Utility s service territory the ESP will be sent final Customer Usage to allow the completion of the customer accounting process. (See Transaction #10). # Error Transaction: If an Enrollment, Change or ESP Drops Customer transaction is rejected by the serving Utility, an Error transaction will be returned to the ESP identifying the rejected record and the reason(s) for the rejection. (See Transaction #6). # Customer Drops ESP: When a Customer Enrolls with a new ESP and the serving Utility receives the enroll customer transaction this is - 8 -

10 transmitted with the projected effective date, to the old ESP. (See transaction #7). The old ESP would also be sent final Customer usage Information to allow the completion of the customer accounting process. (See Transaction # 10). # Customer Drops ESP without new enrollment: If a Customer desires to drop an ESP other than through enrolling with a new ESP, the Customer can direct its current ESP to submit an ESP Drops Customer transaction to the serving Utility. The current ESP is obligated to immediately transmit the Drop transaction to the serving Utility, which would become effective at the Customer's next scheduled cycle meter-read date if the Customer s drop notification is received at least five (5) business days prior to the Customer s next scheduled meter read date (See Transaction #8). The requirement that the Customer notify its current ESP of its intent to terminate their relationship affords both parties the opportunity to resolve any outstanding issues, and acknowledges that there may be a contractual connection between the two. In this case, if no enrollment is received within the enrollment period, the serving Utility will move the Customer to Default or Transition Service according to the Board's regulations, orders and the terms of the R-OAT. The Customer may have another ESP enroll them on their next scheduled cycle meter-read date. The old ESP would also be sent final Customer usage information to allow the completion of the customer accounting process. (See Transaction # 10). # ESP Drops Customer: An ESP must notify the serving Utility of its intent to terminate Generation Service for a Customer. (See Transaction #8). The termination of the ESP s Generation Service will coincide with Customer s next scheduled cycle meter-read date if the drop transaction is received at least twenty-one (21) business days prior to the Customer s next scheduled meter read date. Following the receipt of such notification, the serving Utility will be scheduled for the Default or Transition Service as applicable pursuant to the Board s regulations, orders and the R-OAT unless the Customer successfully enrolls with a new ESP within that enrollment period

11 # Confirm Drop Date: When Transaction #8 is used, the serving Utility will notify the current ESP of the date that Generation Service is projected to terminate. (See Transaction #9). Transaction Set Function: Usage/Billing The serving Utility shall perform the billing function for its Delivery Service including the billing and collection of any applicable Competitive Transition Charges ( CTCs ) as are approved by the Board. Only serving Utility specific charges and applicable taxes will be displayed on the Delivery Service bill. The ESPs providing Generation Service to Customers under the R-OAT shall perform the billing functions for the Generation Service and other services provided by the ESPs to customers directly. # Customer Usage Information: After the meter reading data is obtained, the serving Utility will provide the Customer's ESP with the Customer s consumption information. Validated usage information will be transmitted to ESPs by the end of the next business day following the serving Utility s processing cycle. After receiving the data, the ESP can issue a separate bill for Generation Services provided by the ESP. (See Transaction #10). When a Customer moves or is no longer a Customer of record, the serving Utility renders a Final Bill to the Customer, at the Customer s Delivery Service location. At that time the serving Utility sends the ESP the final usage information as appropriate. (See Transaction #10). This process is also followed if the serving Utility discontinues the provision of Delivery Service to a Customer in accordance with provisions set forth in the serving Utility s Delivery Service tariff. Bill Cancellation or Usage Adjustment: If a consumption based adjustment to a customer bill is required and the customer bill is canceled, the serving Utility will notify the ESP(s) of the cancellation of the original bill with a cancellation activity code. If a rebill of the canceled billing is appropriate, the serving Utility will notify the ESP(s) of the corrected consumption amounts being billed with an adjustment activity code. (See Transaction #10). If the cancellation and/or rebill covers a period of historical consumption in which the Customer's information for the ESP(s) is no longer available (i.e. beyond two scheduled bills following the last bill with the ESP, the serving Utility will send only the canceled and/or rebilled usage to the ESP(s). (See Transaction #10)

12 Customer Moves: If the Customer moves, the serving Utility will send a final bill for the old Delivery Service location to the billing address. The serving Utility will also send the ESP final usage information as appropriate. In accordance with computer processing schedules validated usage and billing information will be transmitted to ESPs. (See Transaction #10). Transaction Set: Customer Usage The serving Utility shall provide to appropriately authorized ESP's the most recent twenty-four (24) months of a Customer s usage history if available for that Customer. Appropriate authorization by the customer can be submitted in writing, in electronic form, or be given orally to a qualified and independent party. The data shall be requested and made available electronically and must be treated confidentially by the receiving party. # Request Usage History: The ESP is responsible for securing authorization to receive customer specific usage information. Upon receiving the authorization the ESP will submit a request for usage information transaction. (See Transaction #11). # Customer Usage History: The ESP will receive at no charge and up to twice in any twelve (12) month period, the most recent twenty four (24) months of a Customer s usage history if available for that Customer. The information will be limited to, service classification number, data on metered usage, monthly metered demands (if applicable), and time-of-use usage (if applicable). Any additional information requests will be provided under the Board s regulations, orders and the R-OAT. The information will be electronically provided within five (5) business days of the request. (See Transaction #12). Transaction Set: Settlement In jurisdictions where retail access and the competitive supply of Generation Service is occurring the serving utility is responsible for reporting to the regional Independent System Operator ( ISO ) the aggregate hourly loads (including associated distribution and transmission losses) for each ESP doing business in its service territory. The ISO has established procedures governing this process. The daily reporting of hourly loads, plus subsequent adjustments, must be performed in accordance with these procedures. The daily settlement of ESP accounts by the ISO requires reporting of aggregate hourly loads for each ESP. Load reporting by the serving Utility (with transmission and

13 distribution losses included) will be based either on actual telemetered data (collected daily) or estimated hourly loads (calculated daily) using the load profiling process approved by the Board. Estimated ESP loads will be reconciled each month using actual metered usage data, and the adjustments will be reported by the serving Utility to the ISO. In addition to the ISO reporting the serving Utility will report aggregate hourly loads to each ESP as follows: # Aggregate Load Estimate: The serving Utility shall provide an individual ESP, on request, their aggregate hourly loads. These loads will be posted to the ESP electronic mailbox using the Daily Supplier Aggregate Results transaction. (See Transaction #13). Telemetering ESPs authorized to participate in the RR-OAT may elect to have the serving Utility install telemetering equipment at a Customer s location in order that the Customer s hourly usage for ISO settlement purposes will be based on metered data rather than estimated data. ESPs who elect telemetering in lieu of estimation must arrange for the installation, initialization, and commissioning of the necessary telemetering and communications equipment with the serving Utility and shall be responsible for all associated installation, operation, data collection, and maintenance costs. The serving Utility or its metering agent must notify the ESP that telemetering and communications installations have been completed, and provide the necessary information to communicate with the recording devices. The ESP must notify the serving Utility or its metering agent when it is able to communicate successfully with the recording device. The serving Utility will own all telemetering equipment which it installs, and is responsible for making timely repairs should the telemetering or communications equipment malfunction. The serving Utility or its metering agent must notify the ESP that repairs have been completed. The ESP will notify the serving Utility or its metering agent if it is unable to access or collect data from the recording device. Until such time as repairs are made, the Customer's historic load profile (if available) or the class average load profile will be used to estimate the Customer's load for settlement purposes

14 IV. Data Format In order to facilitate implementation of the Companies Retail Open Access Tariff, electronic standards for the transaction of business between ESPs and the serving Utility need to be developed. To develop this proposal, the Companies reviewed the current technologies and services available for transaction sets and data format standards. The Companies also considered what is being used in neighboring New England states as well as other regions of the country that have implemented retail access and customer choice in the sale and purchase of Generation Service by ESPs. Based on this review the Companies recommend that transaction formats should be standardized so that all parties can develop the business rule framework and automated systems for timely and efficient processing of the business transactions required for the operation of retail access under the R-OAT. The standards the Companies recommend adopting are the ASC X12 Electronic Data Interchange Standards supported the Utility Industry Group ( UIG ). EDI is the computer to computer exchange of business documents in standard, machine-readable formats. The X12 standards are electronic transactions that provide a common, uniform business language for computers to communicate and were developed by the Accredited Standards Committee ( ASC ). The American National Standards Institute ( ANSI ) chartered the ASC to develop these uniform standards for inter-industry electronic interchange of business transactions. The use of standard formats will allow all participants to develop the business processes and automated systems required to facilitate the exchange of business information in the restructured electric industry. The benefits of EDI include: # Automatic notification of transaction file receipt. # Uniform communications with ESPs. # Reduced errors and improved error detection. # Date and time stamping mechanisms allowing better audit capability. # More timely communications facilitating a quicker exchange of business information. # Reduced manual intervention and paper work. # One time data entry

15 # On-line data storage. V. Electronic Transmission Data transfer methods should meet certain minimum criteria in the following key areas: # Security/encryption of transactions and Customer information. # Proof of transmission and receipt. # Positive identity of sender and recipient (non-repudiation). # Reliability. # Data and file integrity. # Network performance and availability. # Recoverability and archiving of data. Successful implementations that include both the Value Added Network and Internet file transfer systems are presently in use in New Hampshire, Massachusetts and Rhode Island. In addition, other methods, such as dedicated, leased phone line connections, dial-up phone connections, and other computer-to-computer file transfer mechanisms are available, and could be practical and economical data transfer mechanisms. The Companies recommend initially using a VAN as the default communication protocol for under the Retail Open Access Tariff. CVPS developed some operating knowledge and successfully used this communication methodology during its New Hampshire subsidiary s participation in the New Hampshire Retail Access Pilot Program. VANs provide reliable and proven technology for business data transfers, an audit trail, and they specialize in providing services in the key areas identified above. The Companies recommends that the allocation of the transaction costs associated with the VAN be shared between the serving Utility and the ESPs participating under the R-OAT. This means the party sending or picking-up from their own mailbox on the VAN will pay only those transaction charges. The Companies realizes that other data transport mechanisms may be deemed practical and provide possible financial and operational efficiencies (i.e. Internet file transfer systems). The Companies will consider the use of one of the other

16 technologies as they evolve in the market place and develop a proven track record of meeting the key criteria identified above. IV. Information System ( IS ) Operations The first part of this document addresses the business rules and EDI standards for electronic business transactions, data formats and transmission of data proposed by the Companies for deployment in conjunction with the implementation of the R-OAT. This section deals with the IS infrastructure and operational issues (both manual and automated) required to provide for efficient and consistent business processes required to facilitate customer choice and retail access. The Companies identified the following principles that should govern information system infrastructure and operations: # Processing of data must be reliable, predictable, accurate and efficient. # Transaction processing must be equitable and verifiable. # Trading partners daily operational schedules should be accommodated. # The entire process must be designed to detect and report errors without intervention. # There must be a clear assignment of responsibility. IS operations issues can be categorized into the following topics: A. Scheduling B. File Handling C. Error Handling D. Recovery A. Scheduling Each trading partner will have daily schedules that should be accommodated to the extent possible. Operating schedules cannot be standardized because of differences in daily transaction volumes, processing techniques, technology, etc. At the same time, there should be a baseline schedule that all trading partners can rely on and that does not place an undue burden on any trading partner. The Companies proposes the following baseline schedule for a normal business day:

17 # ESP transactions must be received ready for the serving Utility s processing by noon each workday. # Transactions received by noon of the current business day will typically be responded to by noon the following business day. # Validated billing and usage transactions will be transmitted to ESPs by noon of the day following the corresponding serving Utility s bill issuance date. # The serving Utility output transactions should be transmitted to ESPs by noon each business day. The serving Utility will publish its daily operation schedule as a guideline to ESPs. The schedule should include cycle reading and billing dates, processing work days and non work days (i.e., holidays and weekends). B. File Handling The recommended operational guidelines pertaining to file handling are outlined in the transaction standards and data transmission sections of this document. Any changes to these recommendations may impact file handling. It is recommended that the following rules apply to file handling operations: # The serving Utility will attempt to process all files sent by an ESP unless specific action is taken by the ESP to avert processing (i.e., delete files, replace files). Refer to the Error Handling section for additional information. # The recipient of a file (ESP or the Utility) is responsible for reviewing (editing) file contents to prevent adverse impact on the recipient s operations or systems (data errors, duplicate files, illogical conditions, etc.). The recipient of a file has the right to reject the file in whole or in part due to content or protocol errors. In the event that a file is rejected, the detail transactions will not be processed. # The creator of a file is responsible for the accuracy and authenticity of the contents

18 # All data exchanges will be accomplished in a pre-established manner to ensure data security and integrity (refer to Electronic Transmission section). # Each file will have one recipient, and should contain transactions intended only for that recipient. A file may contain multiple transactions of the same or different type for the same customer account. # Files will be processed by the recipient according to the recipient s operating schedule. The serving Utility will sweep the input queue at least once each business day and will process all files that are available by the cut-off and up to the time of the last collection from the queue. # Files will be processed in chronological order based on their receipt date/time stamp. Errors and confirmations (e.g., Successful Enrollments) will be returned to ESPs no later than the first business day following the processing of the transactions by the serving Utility. # Daily transaction exchange between ESPs and the serving Utility will generally not be limited in terms of the total number of files or transactions processed daily. C. Error Handling The Companies recommend that each trading partner establish two points of contact for problem resolution: (i) one for operations problems; and (ii) another for business issues. Each trading partner should establish appropriate procedures to ensure problems are identified, documented, properly classified and resolved in a timely manner. Because access to and manipulation of data must be controlled, the creator of a file is responsible for correcting any errors in the data. Transactions that contain errors will not be accepted, and recipients will not make alterations to received transactions containing errors. D. Recovery No matter what specific transmission method is used, the originator needs procedures so a file can be recreated and/or retransmitted or simply omitted from the job stream (unreadable data, invalid header, file control error, etc.). ESPs will have to coordinate with the serving Utility in order to omit a file (dictated by the Utility s operational schedules). Other conditions are addressed in the File Handling section. The Companies maintain that it is the responsibility of the originator of a file to maintain the ability to recover or recreate the data. In lieu of regulations that may specify data

19 retention requirements, the specific recovery guidelines are left up to each trading partner. The minimum recovery criteria based on the normal file creation schedule is recommended to be: # Files created daily, recover or recreate up to 10 files # Files created weekly, recover or recreate up to 5 files # Files created monthly, recover or recreate up to 3 files VII. Training and Testing Among other requirements, ESPs and the serving Utility must have the capability and readiness to participate in the retail marketplace using the standard electronic transactions and business rules described in this proposal. To assist in the solution of this potential problem, the Companies propose the following training and testing framework for testing the electronic data transfer and processing systems of the Companies and authorized ESPs. The purpose of the testing is to verify that the Companies and ESPs are capable and ready to comply with the EDI data transfer standards specified in this document. The Companies recommend that the completion of the training and testing programs requirements be part of the Board s ESP certification and/or registration processes and that the successful completion of the programs be a prerequisite to the submission of their first Customer enrollment or any other electronic business transaction. In an effort to provide an orderly and expeditious transition to competitive market operations, the Companies will, prior to the effective date of the Retail Open Access Tariff provide testing time frames, testing lead times, and anticipated dates when the Companies will be prepared to post a test schedule with ESPs. A. Training Framework Given the importance of understanding the operation and communication requirements of the new market infrastructure, the Companies strongly recommends that attendance at an introductory training session (i.e., ESP Workshop) be made part of the authorization process for ESPs that seek to seel Generation Service under the R-OAT. The cost of providing this training should be recoverable from the participating ESPs. The Workshops will be offered at scheduled intervals and be open to ESPs that have initiated or completed the certification process with the Board, at least one week prior to their scheduled authorization effective date. Each Workshop will be staffed by

20 representatives from the Board, Department of Public Service and the effected Utility. This will help provide consistency between different training sessions as well as reduce the burden on the Board and Department as well as the Companies. These Workshops will be structured to provide an introduction to the regulatory and operational requirements for participation in the Companies Retail Open Access Tariff. In addition to the Workshops an ESP Guide should be created that provides ESPs with the necessary information to compete for the sale of Generation Service under the R- OAT. B. Testing Requirements Prior to providing energy services to Customers under the R-OAT, an ESP must demonstrate its capability to electronically send, receive, and process data with the Utility in whose service area the ESP intends to offer Generation Services. Successful testing must be completed prior to the first enrollment transaction or customer usage history request being submitted to such Utility. The purpose of the testing is to verify that the ESP is capable of complying with the operational business rules and EDI standards specified in this document. Testing will also determine whether the ESP has the necessary IS infrastructure required to send, receive, translate and process the standard transactions required to engage in the sale of Generation Service under the R-OAT. Compliance testing will be accomplished by the ESP exchanging a standard set of test transactions with the host Utility. The Utility will typically require at least two weeks notice to set up a test with an ESP. The test will utilize transactions from the standard transaction set described in this document, and verification of 100% error free transmission, receipt, translation and processing of the data by both ESP and the Utility should be required. An approved data transfer system will be used for the data exchange tests. Prior to the effective date for the Retail Open Access Tariff, the Companies must also demonstrate their its capability to send and receive the specified transactions without modification to format or data elements

21 C. Compliance Test The following is an overview of the proposed compliance test. # The host Utility will provide test scripts or data files for interface testing and ESPs will process these scripts and provide evidence of successful testing. The compliance test shall require the complete and error-free transmission, receipt, translation and processing of the full set of test transaction sets described in this document. # The ESP shall contact the host Utility to arrange for the exchange of test transactions. The host Utility will provide test procedures, the set of standard test scenarios, and any differences from the standard test plan to the ESP. # The ESP will initiate the test by creating the test transaction files with its software and post the files to the host Utilities Value Added Network. The Utility will retrieve and translate the test transactions and verify the accuracy of the received data. # This test will be repeated until satisfactory results are attained prior to proceeding with the Utility to the ESP phase of testing. # Once the former test is satisfactorily completed, the Utility will send a set of test transactions to the ESP s VAN. The ESP will retrieve and translate the test transactions and verify the accuracy of the received data. # The Utility and the ESP will work to resolve any discrepancies in transmitted or received data and confirm correctness by repeating the test data exchanges described above until both parties are satisfied that consistently error free results can be accomplished. # Upon successful completion of ESP Board certification and/or registration and the EDI testing, the host Utility will activate the ESP on its production business system

22 STATE OF VERMONT PUBLIC SERVICE BOARD Docket No. Petition of Central Vermont Public Service ) Corporation and Green Mountain Power ) Corporation Requesting an Investigation into ) The Establishment of Retail Access ) Polices and Procedures ) OPERATIONAL BUSINESS RULES AND ELECTRONIC DATA INTERCHANGE STANDARDS Dated November 23, 1999 CENTRAL VERMONT PUBLIC SERVICE CORPORATION 77 Grove Street Rutland, Vermont GREEN MOUNTAIN POWER CORPORATION 153 Acorn Lane Colchester, Vermont 05446

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