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Duquesne Light Does Not Meet December 15 Accelerated Switching Deadline, Seeks New Waiver

December 17, 2014

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Copyright 2010-14 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

Duquesne Light has informed the Pennsylvania PUC that it was not able to meet the original December 15, 2014 deadline to implement an interim form of three-day accelerated switching, and has again asked for a waiver until January 16, 2015 to implement the interim solution.

Duquesne Light had originally requested that it be granted until January 16, 2015 to implement its Phase I interim accelerated switching solution, which would be applicable to 91% of customers and allow customers to complete one off-cycle accelerated switch, completed within three business days, per billing cycle.

While Duquesne Light had sought until January 16, 2015 to implement the Phase I solution, it had said that it was making every reasonable effort to implement Phase I by December 15, 2014.

The PUC denied Duquesne Light's request to be granted until January 16, 2015 to implement Phase I.

Duquesne Light has now informed the PUC that its new billing system, FOCUS, went live on November 28, 2014.

With such go-live, "[t]he Company has now determined that it will not be able to implement its Phase 1 Solution by December 15, 2014, due to multiple critical system modifications to the original FOCUS design that have been identified as necessary to integrate the OCS [off-cycle switching] application with the FOCUS System."

"These significant code changes cannot now be made to the FOCUS System because of a substantial risk that doing so would destabilize the new system. In this context, destabilization of the FOCUS System means the system is not functioning as designed, which could produce negative effects for all customers, including failures to issue bills as well as the issuance of inaccurate bills," Duquesne Light said.

Duquesne Light currently estimates that it will be able to implement the Phase I solution on January 16, 2015, and sought a waiver of the accelerated switching rules, "until January 16, 2015 or the Company can implement its Phase 1 Solution."

In response to the PUC's prior order denying a January 16, 2015 compliance date, Duquesne Light provided more support for its position that manually effectuating accelerated switches in the interim is unworkable.

"Duquesne Light has evaluated manual solutions and has concluded that there is not a workable solution ... [T]here is no purely 'manual" solution that does not require changes to code in the newly implemented FOCUS System, an entirely 'manual' solution is not possible," Duquesne Light said.

"In the Company's existing automated processes, switches are initiated via automated EDI transactions to and from the Company and EGS. When a request to switch is received via EDT transaction it triggers a series of automated actions throughout the systems, as well as automated letters to the customers. In order to create a workable 'manual' switch process it would be necessary to intercept and stop inbound EDI transactions. This would require significant code changes to the FOCUS System thus requiring regression testing of approximately 40% of the FOCUS code impacting CC&B and MTM transactions which are highly interrelated with each other and other processes in the FOCUS System," Duquesne Light said.

Duquesne Light also sought approval, until January 16, 2015, to offer an accelerated solution only to residential and small C&I customers with variable rate contracts who wish to return to default service (as opposed to an earlier proposal allowing any customer to return to default service on an accelerated basis)

Duquesne Light also makes reference to instances where, "there is a spike in energy prices causing customers to incur increased costs under variable rate contracts," but it does not appear its request to return variable rate customers to default service on an accelerated basis is limited to instances where there is a spike in energy prices.

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