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Illinois Office of Retail Market Development Recommends Price To Compare Be Listed Directly Above Retail Supplier Rate On Bills

Does Not Recommend Including Shadow Billed Default Service Cost

July 1, 2019

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Copyright 2010-19
Reporting by Paul Ring •

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The Office of Retail Market Development (ORMD) of the Illinois Commerce Commission on June 3 filed with the ICC recommendations concerning further revisions to the inclusion of Price to Compare (PTC) information on customer electric bills, including the bills of customers on competitive supply.

Initially the report was submitted to the Commission, but ORMD has now filed the report publicly in Docket 18-0623

Reporting on consensus items from a workshop process, ORMD said that parties generally agreed a more prominent display of the PTC would be achieved by including a short disclosure on page 1 of ComEd’s bill in the "supply" section. This short disclosure would direct customers to the PTC information displayed more fully on page 2 of the bill. ORMD Staff recommends that the following language appear within a readily-visible and identifiable call-out box outlined in red: "For more in formation, see 'Price to Compare' on reverse side."

ORMD also said that the parties agreed that the PTC information on page 2 of ComEd’s bill should be displayed on the right side of the bill, parallel to the "supply" section and outlined in a red box. It was agreed that placing the PTC information parallel to the "supply" section is a prominent location and will assist customers in understanding the information being provided.

Non-consensus items include whether the Price to Compare info on bills for retail supplier customers should include a "shadow billed" amount for what the customer would have paid under default service

"Staff does not recommend including a 'shadow bill' as that calculation interprets the PTC and offers what may be a less-than-accurate comparison, rather than simply disclosing it as useful consumer information," ORMD said in the report

"As ORMD stated in its June 2018 Annual Report, including the PTC information on all bills is intended to 'provide additional transparency regarding costs' and 'increase the PTC visibility to all consumers whether they have already switched to an ARES or are considering making a switch.' This is accomplished by disclosing the PTC amount in the same format as the ARES supply charge, in the same section, without providing further calculation or interpretation," ORMD said

ORMD's recommendation is that a "Price to Compare" box include the supplier rate, with the PTC directly above it, but with no calculation of any amounts

ORMD's recommendation would list the PTC as follows:

- Price to Compare*: 415 kWh X 0.07358

- 123 ARES supply charge: 415 kWh X 0.07051

* The "Price to Compare" is the default rate you would be charged for your electric supply if you received it from ComEd.

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A sample bill showing ORMD's recommendation can be found in ORMD's report here

ORMD does not recommend that information concerning the purchased energy adjustment (PEA), and the manner in which it affects the total supply charge, be included in the PTC info

"It is Staff’s opinion that attempting to describe the PEA might engender customer confusion instead of fostering clarity, especially since ARES customers do not pay the PEA. Accordingly, Staff recommends omitting reference to the PEA in the PTC information," ORMD said in the report

In terms of decimal places for the PTC, ORMD Staff recommends matching the ComEd 5-decimal point format, which is expressed in $ per kWh terms, to achieve consistency and clarity.

As noted, Staff's report was filed on June 3 and only now made public. In such report, Staff noted the passage by the legislature of SB 651, which includes new requirements related to PTC disclosures, and Staff, in such June 3 report, said that it was conducting an analysis of the bill. The bill was only sent to the Governor on June 28 and waits action by the executive branch

ICC Docket No. 18-0623

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