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PUC Approves Seamless Move, Instant Connect Implementation Plan At Duquesne Light

September 4, 2015

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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com

The Pennsylvania PUC approved Duquesne Light's plan to implement seamless moves and instant connects by July 1, 2016

Under the plan for seamless moves:

• Seamless moves will be available to all residential customers as well as commercial and industrial customers that use less than 300 kW of demand as defined in the Tariff.

• The customer's new location must be in the same rate class (i.e., Residential Service (RS), Residential Service Heating (RH) or Residential Service Add-on Heat Pump (RA)) as the prior location, and the customer must maintain the same supplier billing rate, billing option and tax exemption percentage.

• The EGS must submit a drop request via electronic data interchange (EDI) if it does not wish to continue service to the customer at the new service location. However, the EGS will still have to maintain supply service to this customer until a three-business day switch can occur at the new address.

• Large commercial and industrial customers will not be included for seamless moves based on the potential problems that may arise due to PJM Interconnection, LLC (PJM) scheduling.

In adopting Duquesne Light's plan, the PUC rejected FirstEnergy Solutions' position that an EGS should have the right and opportunity to reject a seamless move which meets the requirements set forth in Duquesne’s Plan. The PUC also rejected Citizen Power’s position that EGSs should have the ability to set as a "default" the rejection of seamless moves

"We find that Duquesne’s express eligibility requirements, including maintaining the existing rate class for seamless moves and restriction to residential and low-demand business customers (less than 300kW), are responsive to concerns about the potential impact on EGSs. These safeguards are sufficient to prevent customers from materially changing their contracts with EGSs simply by moving to a new location. We reiterate that these safeguards include limiting seamless moves to accounts that use less than 300 kW of demand; requiring that the rate class remains unchanged; and that the customer maintains the same supplier billing rate, billing option and tax exemption percentage. We are convinced that these robust safeguards will prevent a customer from significantly changing the characteristics of their service with an EGS as a result of a move to a new location. In addition, Duquesne’s stated approach – that a supplier is always able to submit a drop if they do not wish to serve the customer at a new location – is also responsive to concerns regarding the impact on EGSs. We emphasize that any EGS which processes a customer drop in a seamless move environment should be doing so per the terms and conditions of their existing agreement with the customer. Ideally, this should be addressed under the cancellation provisions of the disclosure or contract the EGS has with the customer. Existing supply agreements should not be adversely impacted by implementation of seamless moves with all of the foregoing protections in place," the PUC said

"We also note that seamless moves will not be available until July 2016. This should provide EGSs with time to consider these matters when entering into new contracts with new customers. To the extent that an EGS desires to expressly recognize the possibility of seamless moves in future contracts, they are free to do so. In addition, EGSs may pursue modification of existing contracts, with customer agreement. Regardless of the foregoing, it is the desire of the customer to retain the current supply terms and conditions that should control, subject to the EGS’s ability to drop that customer as provided in Duquesne’s proposed Plan and consistent with the terms of the existing contract as mutually agreed to by both parties," the PUC said

The PUC rejected assigning implementation costs for recovery from retail suppliers, and said that costs should be addressed in base rates.

Docket M-2014-2401127

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