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ComEd Seeks To Implement Time Of Use Supply Rate Option With More Rate "Certainty"

November 20, 2018

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Copyright 2010-17
Reporting by Paul Ring •

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Commonwealth Edison has filed with the Illinois Commerce Commission proposed tariffs to implement a pilot Time of Use (TOU) electricity supply option that has greater "price certainty" than ComEd's currently authorized real-time supply pricing program.

ComEd also sought revisions to its Integrated Distribution Company ("IDC") implementation plan to allow ComEd to promote, advertise and market its residential TOU pilot program.

ComEd's proposed Rate RTOUPP – Residential Time of Use Pricing Pilot (TOU Pilot) provides for a three-part supply rate with price differentiation between super peak, peak and off peak hours.

"While ComEd has had a real-time pricing program ('RRTP') with hourly pricing in operation for over ten years, some customers who would otherwise benefit from the program indicate that the lack of price certainty is a barrier to enrollment. The residential TOU Pilot will provide the opportunity to understand if a more price certain supply rate based upon the difference in real-time market-based rates is appealing to residential customers. ComEd’s proposed TOU Pilot provides an easy to understand supply option with similar benefits to the residential real-time pricing program, for customers and creates a middle ground between fixed and real-time pricing," ComEd said

ComEd intends to operate the TOU Pilot program for an initial 4-year period.

The tariff sheets are proposed to become effective January 3, 2019 and the rate is proposed to be available for enrollment beginning with the January 2020 monthly billing period after ComEd has had sufficient time to program the billing requirements.

ComEd's RTOUPP (TOU Pilot) proposes fixed supply prices for three separate periods with pricing being the highest from 3 p.m. to 7 p.m. (Super Peak Period) every day. The lowest price period will be from Midnight to 6 a.m. (Off-Peak Period), and the remaining period (6:00 a.m. to 3:00 p.m. and from 7:00 p.m. to 12:00 a.m.) will be the intermediate pricing (Peak Period), with the fixed pricing also differentiated between summer (June, July, August and September) and non-summer periods

The supply prices for the three periods will be developed based upon historical real time supply prices with slight adjustments to create a higher differentiation between the three periods but still remain revenue neutral on average.

RTOUPP customers would also be subject to a monthly capacity charge, a transmission charge (PJM Services), a miscellaneous procurement charge, and a Purchased Electricity Adjustment Factor

ComEd provided illustrative energy charges and other charges under RTOUPP based on historical prices as of the time of its filing, but such prices would be updated based on the effective date of the TOU Pilot

Illustrative RTOUPP Energy Charges 
              Summer   Non-Summer
Super Peak     5.579      4.853 
Peak           3.100      2.972 
Off-Peak       1.694      2.172 

Illustrative RTOUPP Monthly Capacity Charge 

Illustrative RTOUPP PJM Services Charge

Illustrative RTOUPP Miscellaneous 
  Procurement Components Charge 

ComEd is also proposing to treat the Rate RTOUPP (TOU Pilot) participants in the same manner as residential hourly customers served under Rate BESH are treated when a municipality participates in a municipal aggregation program. These customers are excluded from enrollment in the municipal aggregation program due to their participation in an elective supply rate.

"The purpose of the TOU Pilot is to encourage customers to shift load from high demand hours when energy prices may be higher and capacity peak load contributions ('PLCs') are determined to low demand hours in order to research and learn how this could potentially lower supply costs and reduce system demand (i.e. PLCs) for the residential participants and the residential delivery class," ComEd said

Currently, rules governing Integrated Distribution Companies ("IDCs") prohibit IDCs, such as ComEd, from promoting, advertising and marketing any Retail Electric Supply Service, which is defined simply as "the retail sale of electricity, whether bundled or unbundled." However, the IDC Rules do permit ComEd to promote permissible IDC services ("Permissible IDC Services") and to engage in legitimate customer education efforts.

ComEd is proposing to revise its IDC Implementation Plan (as is permitted by Section 452.220(f) of the IDC Rules) for a limited-time to make clear that one of the practices that ComEd will be allowed to engage in are the promotion, advertising and marketing of the TOU Pilot program.

ComEd said that, "RESs [retail electric suppliers] will not be adversely affected by granting this Petition. In fact, the underlying premise of the TOU Pilot program is that it has the potential to provide benefits to retail energy suppliers as well as ComEd. The learnings that this program will generate will help to better understand customers’ appetite for a fixed price TOU rate structure. In addition, the findings on the benefits it has to EV owners will also be available to RESs, who may use these learnings in developing their own marketing and own TOU programs. As ComEd currently does with RRTP, ComEd commits that it will make no effort to prevent customers from signing up with or switching to RES service."

"ComEd also recognizes that this waiver will be limited solely to the marketing of the TOU Pilot program which will primarily target direct marketing materials to Rate BES – Basic Electric Service customers on ComEd’s fixed price supply rate for the duration of the TOU Pilot," ComEd said

Docket 18-1725

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