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RESA: PPL's Comments Show "Uncertainty" Over Treatment Of Existing Customers Once PUC Restricts Shopping For CAP Customers To CAP-SOP Program, Would Welcome PUC Clarification

May 18, 2017

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

The Retail Energy Supply Association said that a May 16 letter from PPL Electric Utilities (PPL) regarding the new Customer Assistance Program Standard Offer Program (CAP-SOP), which will be the only vehicle for CAP customer shopping at PPL starting June 1, shows that there is uncertainty concerning the applicability of the program to existing shopping customers, as RESA said it would welcome further clarity from the PUC

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)

Among other things, the CAP-SOP order provides in relevant part:

(a) Effective June 1, 2017, the CAP-SOP is the only vehicle that a CAP customer may use to shop and receive supply from an EGS.

(g) All CAP customer shopping fixed-term contracts in effect as of the effective date of the CAP-SOP will remain in place until the contract term expires and/or is terminated.

(h) Once the existing CAP customer shopping contract expires or is terminated, the CAP customer will have the option to enroll in the CAP-SOP or return to default service, but in any event will only be permitted to shop through the CAP-SOP.

RESA has expressed concerns with what it believes is a requirement to "drop" currently shopping CAP customers to default service if they do not meet the exemption set forth in the CAP order, (e.g. "fixed-term contracts in effect as of the effective date of the CAP-SOP"); namely, those customers on month to month contracts or those whose contracts are scheduled to renew on or after June 1.

However, in its May 16 comments (see story here), PPL had said that the order, "unequivocally provides that all existing CAP shopping contracts will remain in place and effective until the contract term expires and/or is terminated."

"Consistent with the requirements of the Commission-approved CAP-SOP, PPL Electric is not and will not require any suppliers currently serving CAP customers under existing shopping contracts to 'drop' their current PPL Electric CAP shopping customers as repeatedly and incorrectly suggested by RESA," PPL had said in its May 16 comments

Indeed, PPL went so far as to state in its May 16 comments that, "RESA's contention that the existing CAP shopping contracts will be terminated is patently false and a complete mischaracterization of the CAP-SOP."

RESA noted that PPL's comments reveal uncertainty regarding the treatment of CAP customers that are currently shopping

"RESA's May 12 Letter and PPL's response clearly indicate that there is uncertainty in the market about how the new CAP shopping restrictions should be implemented for certain groups of existing EGS customers, namely those on month to month contracts or those whose contracts are scheduled to renew on or after June 1," RESA said

"In its letter PPL appears to be taking the view that EGSs are not required to 'drop' these existing CAP customers and return them to PPL's default service. If PPL's assertion is correct and it is the intent of the Commission to not require EGSs to 'drop' these existing CAP customers, then RESA would welcome specific clarity in this regard from the Commission. Additional clarity that EGSs are not required to 'drop' existing customers would serve to address many of RESA's concerns expressed in the May 12 Letter and provide a reasonable opportunity for EGSs to undertake the operational work necessary to comply as existing EGS CAP participant customers would continue to be served under the specific renewal terms in the customer's contract," RESA said

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