ALJ Proposes That ICC Approve ComEd's Pilot To Market Utility-Supplied Real-Time Pricing, With No Risk, To Residential Customers Expected To Save Money, Based On AMI Data

August 2, 2019

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Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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A proposed order from an Illinois ALJ would approve a modified program proposed by Commonwealth Edison to establish a short-term pilot program as part of its Residential Real Time Pricing Program utility supply rider (Rider RRTP), to offer first-year bill protection to new real-time pricing participants, with the program marketed to default service customers expected to save money under the program, based on a review of their AMI data (Bill Protection Experiment)

The bill protection will provide that, for the 12 month pilot, customers who would have ended up paying more under real-time pricing than standard default service will be held harmless.

ComEd had initially proposed to market the real-time pricing Bill Protection Guarantee (BPG) to approximately 10,000 customers on default service with an expected response rate leading to enrollment of approximately 1,500 customers.

One change sought by Staff, and agreed to by ComEd, is limiting the number of customers that can accept the Bill Protection Guarantee (BPG) offer to the first 700 customers who enroll

The ALJ would approve the program for 700 customers.

The proposed order would provide that, "The Commission supports ComEd’s continued partnership with Elevate Energy, the RRTP Program Administrator, to market and promote Rider RRTP, including the Bill Protection Experiment. Likewise, ComEd’s continued focus on marketing only to Rate BES [fixed price default service] customers, in order to avoid disturbing customer relationships with RESs [retail suppliers] and those in municipal aggregation programs, is appropriate."

ComEd has stated that Elevate Energy will enroll customers in the BPG during a 12-month period beginning in the spring of 2020, and that this enrollment period will be preceded by a direct mail campaign.

"ComEd’s proposed marketing plan is reasonable and adopted," the proposed order would provide

The Illinois Competitive Energy Association (ICEA) had, in a brief urged the ICC to reject ComEd’s proposed changes to Rate RRTP, "because ComEd is proposing an anti-competitive program whose justifications do not withstand scrutiny."

The ALJ would deny various objections raised by ICEA (which were more fully detailed in EnergyChoiceMatters.com's prior story here)

The proposed order would provide that, "The Commission rejects ICEA’s contention that the Bill Protection Experiment should not be approved because it is anti-competitive. As ComEd points out, RESs [retail suppliers] can access their customers’ interval data within parameters established in prior Commission orders, and that data would enable RESs to develop and market real-time pricing products. To the extent ICEA is requesting the Commission order ComEd to provide RESs with interval data during the billing and settlement process, that request is contrary to prior Commission orders."

The proposed order would provide that, "The Commission also rejects ICEA’s contention that the proposed BPG would be improperly subsidized ... [T]he funding will come from Elevate Energy’s existing budget, and the Act permits ComEd to recover the reasonable costs associated with the RRTP Program Administrator’s activities."

The proposed order would provide that, "The Commission rejects, as contrary to the Act, ICEA’s argument that ComEd should obtain customers’ consent prior to sharing with Elevate Energy data that would assist Elevate Energy in marketing and promoting Rider RRTP."

The proposed order would provide that, "The Commission agrees with Staff and CUB that Elevate Energy is not a RES and is therefore not subject to the requirements concerning RES’ access to customer data. The Commission likewise rejects the argument that it would be improper for ComEd to examine the interval data generated by its customers."

"Finally, the Commission notes that RESs can obtain customer consent to access interval data, as part of the enrollment process, and that RESs could use that data to develop a pilot similar to the one proposed here. For those reasons, the Commission rejects ICEA’s arguments concerning RESs’ inability to provide a similar program," the proposed order would provide

Docket No. 18-1772

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