Joint Suppliers take no position on this issue. Disposition - Market Enhancement Programs – Retail Opt-In Program – Mailings and Communications I recommend approving OCA’s proposal that Duquesne Light mail an additional notice. There needs to be three mailings or letters provided to customers prior to the end of the program – one should come from Duquesne Light and two should come from the EGS. I agree with Duquesne Light’s suggestion that this third mailing should occur after the list of EGSs participating is known and only if the EGSs are required to pay for the cost of the additional mailing. I agree with CAUSE-PA that the first notice – a 90-day notice – should come from Duquesne Light. This first notice would concern the expiration of the program and should come from the entity (Duquesne Light, herein) through which the customer entered into the program initially. Mailings are an important aspect of consumer education, especially if, as hoped, many participating consumers will not have participated previously in the retail markets. This third notice will ensure these consumers are fully informed about the available options. In addition, I agree with Duquesne Light’s proposal and against RESA’s proposal concerning sending an additional letter prior to the RFP. I disagree with RESA that another letter or communication needs to be sent to potential Opt-In participants, unless the EGSs are ordered to pay for the cost of that mailing. In either case, there is no need to send another mailing prior to the RFP. j. Opt-In Electric Generation Supplier Service Program Request for Proposals and Agreement Between Duquesne Light and Electric Generation Suppliers i. DLC’s Proposal Duquesne Light proposed participating EGSs be required to enter into an agreement with the Company to participate in the ROI Program and also proposed RFP procedures, including providing a proposed agreement and RFP rules and procedures. Duquesne
The Company proposed a SO Program, consistent with the Commission’s directives in the Retail Market Investigation, for customers who call the Company for certain types of transactions. The Company designed the SO Program to balance customer interests and to enhance competition in the Company’s service territory. Duquesne Light proposes to offer the SO program to non-shopping customers who call the company about: (1) initiating or moving service; (2) choice questions; (3) high bill complaints; or (4) the SO Program. The Company avers the SO product should be a 7% reduction off of the PTC at the time of the offer and be a fixed price for a 12-month period. Also, Duquesne Light proposes to create a “choice referral team” to handle SO program calls after the initial customer inquiry has been processed and to implement the SO Program on June 1, 2014. Duquesne Light St. No. 5, p. 10. Duquesne Light proposes the SO product be a 12-month fixed price product, as this provision would be consistent with the Commission’s Intermediate Work Plan Order which provided for a Standard Offer period of four to 12 months. Duquesne Light St. No. 3, p. 34 and Intermediate Work Plan Order at 31. In addition, a 12-month period would be consistent with the Commission’s Order in the FE Companies’ default service proceeding (FE Order at 146.) and with the Commission’s Binding Poll in the PECO default service proceeding. PECO Binding Poll, Issue No. 18. The Company argues the OCA and RESA proposals – to shorten the SO product to a 4-month term – should be denied as inconsistent with the Commission’s approval of a 12month offer in the FE Order and PECO Binding Poll. Moreover, Duquesne Light contends a 12month term is better for customers and more likely to encourage customer participation than a short-term, 4-month program. Duquesne Light St. No. 3-R, pp. 41-42. The Company a 12-month term will alleviate customer concerns about a “bait and switch” offer – whereby a customer is offered a short-term low rate followed by a rate that is above the PTC and/or market prices. In addition, the 12-month SO term is consistent with the 12-month PTC that Duquesne Light proposes to provide residential customers under the
load and full requirements load are completely different products, with different risk profiles. As a result, including the TOU product with a fixed price default service product could limit supplier participation and/or unnecessarily increase default service prices. While it is understandable for Duquesne Light to try to plan for multiple scenarios and contingencies, its contingency plan as currently reflected in the SMA may compromise its procurements for its standard default service. FES proposes that SMA Section 4.3 be deleted. Alternatively, at the very least, this section should be revised to address the possibility of obtaining TOU from wholesale suppliers through an Addendum to the SMA, rather than combining the TOU load with suppliers' full requirements load. FES recognizes that Duquesne Light’s TOU program is still in the early “pilot” stages of development, but while the current usage is small it may become more robust during the POLR VI time period. FES believes that Duquesne Light’s TOU load should be served by an EGS either through a bid separate from its full requirements products, or as RESA suggests through an EGS solicitation on a less formal basis, after which Duquesne Light would post the information to a clearing house website, and certify the information to the Commission. RESA St. No. 2-R at 21. Constellation suggests an alternative methodology by which Duquesne Light could obtain TOU load from its default service suppliers, in order to obviate the risks of both customer shopping for EGS service and that customers will choose the TOU offering from Duquesne Light. Constellation’s proposal is that Duquesne Light allocate a pro-rata percentage share of TOU load to each tranche (including those awarded in the DSP RFP’s) and not revise the price paid to default service suppliers under their contracts. Duquesne Light would establish the TOU price through a “retail pricing matrix,” and differences between the payments to wholesale suppliers and amounts paid by TOU customers could be dealt with through the reconciliation process. Constellation St. No. 1 at 41-42. While FES’s preference is for TOU load to be separately bid to EGSs, FES believes Constellation’s proposal to be a reasonable
2. OCA’s Position OCA no position on this issue. 3. RESA’s Position RESA no position on DLC’s request for waivers. 4. OSBA’s Position OSBA takes no position on this issue. 5. CAUSE’s Position CAUSE takes no position on this issue. 6. Citizen Power’s Position Citizen Power takes no position on this issue. 7. Duquesne Industrial Intervenors’ Position DII takes no position on this issue. 8. EGS Parties’ Position EGS Parties take no position on this issue.