history of Commission Orders addressing PECO’s CAP programs over the past 12 years during which the Commission has directed PECO to make improvements to its CAP Rate application. PECO’s pilot CAP used a PIP plan design starting in 1984. In 1996, the Commission approved a CAP Rate design as part of a settlement. Shortly thereafter, the electric Competition Act became effective. On September 29, 2000, in PECO’s USECP for 2001-2003, Docket No. M00001418, the Commission expressed concern with a potential lack of compliance with Section 2802(10) of the energy Competition Act and Section 69.265(2) of the CAP Policy Statement. PECO was directed, inter alia, to analyze the cost of extending the CAP Rate discount to the entire bill of CAP Rate R (base load) customers with income below 50% of FPIG whose usage exceeded 500 kWh per month. On March 9, 2001, PECO petitioned for amendment of the September 29, 2000 order, asserting that PECO did not maintain the information necessary to perform the analysis the Commission had requested and, further, that some of its payment rate data was less reliable than other payment rate data. On September 27, 2001, PECO was directed to perform the requisite analysis with its reliable data. On April 8, 2003, in PECO’s Petition for Expedited Approval of Consensus Modifications to PECO’s USECP for 2001-2003 and Associated Tariff Changes, Docket Nos. R-00027870 and M-00001418, the Commission found that customers do not understand CAP Rate bills but concluded that the consensus modifications to the USECP were “steps toward” making CAP budgets consistent with the Commission’s CAP Policy Statement. That order documented, inter alia, PECO’s agreement to submit to a third-party analysis of energy burdens expressed as a percentage of income, as well as rate design and payment plans. PECO also agreed to review termination procedures. PECO was directed to implement budget billing for CAP customers. PECO’s CAP Rate A was formulated to address special needs customers and modified discounts for CAP Rate B and C customers were approved. PECO was directed
contracted vendor administers LIURP. PECO should reevaluate this level of support to consider any further training necessary for the program changes ultimately directed through this Final Order and employ sufficient staff to operate its programs efficiently. PECO provided through comments and testimony that if the Final Order requires program changes, it will reevaluate its training and staffing to ensure that new programs operate efficiently. PECO Direct at 57 (18-20). Staff would be needed to continue outreach to CAP B customers to determine eligibility for CAP A. Peach suggested that PECO increase its CARES workforce to 10 to assist in preventing under-enrollment of customers in the lowest income CAP tiers. CARES staff could work with neighborhood agencies to find, talk with and move eligible customers into the CAP Rate A. TURN, et al., note in their Brief at page 33 that PECO should insure that its customer service representatives have the requisite training to be aware that customers with special circumstances may be eligible for enrollment in CAP rate A and to enroll them in Cap Rate A as appropriate. TURN, et al., Rebuttal at 12-13. Resolution: As PECO stated it would if the Final Order required program changes, it should reevaluate its training and staffing to ensure that new programs operate efficiently. Accordingly, the Commission directs it to do so. V. Conclusion Consistent with the discussion above, we shall direct PECO to amend and file a Second Amended USECP for 2013-2015, and perform the following: