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RESA Raises More Implementation Concerns About PPL CAP-SOP Program, Identification Of Impacted Customers, Assignment Of Responsibility To Suppliers To Drop Customers To Default Service

May 15, 2017

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Copyright 2010-17 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The Retail Energy Supply Association opposed PPL Electric Utilities' motion to withdraw PPL's earlier request to delay the start date for the CAP-SOP program from June 1, 2017 to September 1, 2017, as RESA raised more concerns about implementation of the program

PPL recently said that a delay is no longer needed as it can make needed IT changes by June 1, 2017

As first reported by EnergyChoiceMatters.com, the PUC ordered that, at PPL, Customers Assistance Program (CAP) customers may only shop through a CAP-specific Standard Offer Program (CAP-SOP), under which the EGS must serve the customer at a 7% discount off the Price To Compare at the time of enrollment, with such EGS price fixed for 12 months (see story here)

"For the most part, PPL appears to have focused its attention on the operational protocols for the CAP-SOP and has provided no meaningful opportunity to receive and consider constructive input from suppliers about the development of these protocols. Notwithstanding the fact that the Commission's final order authorizing the CAP-SOP was entered January 26, 2017, PPL only communicated with suppliers -- for the first time -- during a [sic] April 25, 2017 supplier conference. At that time, PPL announced to suppliers its unilateral determination that EGSs will be required to 'drop' their current PPL CAP customers. The decision of PPL to force this requirement on EGSs means that EGSs need to determine how to honor existing customer contracts (particularly any cancellation provisions), how to maintain compliance with the Commissions regulations (particularly the contract renewal provisions), and how to operationalize all of these processes for existing PPL CAP participants who are EGS customers. PPL, however, has still not provided to EGSs the names of their specific customers who are participants in PPL's CAP. PPL indicated this morning that this information will be provided on May 22, 2017 and has refused requests from some RESA members to provide this information sooner. PPL also announced earlier today [May 12] that it will communicate with suppliers when their then-existing customers enter PPL's CAP program via a list updated on a quarterly basis. PPL has made it clear that there is no opportunity for further dialogue and supplier input on these issues," RESA said

"By waiting until April 25, 2017, to announce these determinations and then taking no responsibility for managing the transition of existing EGS customers who participate in PPL's CAP (beyond processing EGS drop notices) and not providing EGSs the names of their current customers participating in PPL's CAP program until a few days before implementation of the CAP-SOP, unnecessary confusion and lack of direction has been created. Each supplier will need to make an individual determination about how to cancel existing contracts and the communication that is provided to existing customers who will no longer be eligible to receive service from the EGS. A lack of direction from the Commission about its expectations and PPL's removal of responsibility for transitioning these existing EGS customers has the potential to lead to unnecessary customer confusion and dissatisfaction with the competitive retail market," RESA said

RESA also raised concerns regarding PPL's limitations on the billing mechanisms for CAP-SOP.

"The primary focus of the April 25, 2017 supplier conference call was for PPL to explain the already implemented operational protocols for the CAP-SOP. As just one example, PPL made the unilateral business decision to limit the new CAP-SOP to rate ready billing -- an operational requirement that was not directed by the Commission. This decision is significant and supports delaying implementation because there may be suppliers that are interested in participating in the CAP-SOP who only [sic] utility bill ready billing. There is no way for such suppliers to become operationally ready by June 1 as new billing options require more extensive EDI testing and utility coordination. However, PPL is only allowing expedited EDI testing for the CAP-SOP for suppliers currently set up for rate ready billing. Unfortunately, it appears that because PPL has already determined and implemented its processes, it is unwilling to make any modifications to what it had already developed to implement the CAP-SOP notwithstanding suggestions from suppliers during the conference call," RESA said

RESA suggested delegating various implementation issues, including the CAP-SOP effective date, to the Commission's Office of Competitive Market Oversight

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