Illinois 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
Retail Suppliers Had Called Proposed Program Anti-Competitive
September 19, 2019 Email This Story Copyright 2010-19 EnergyChoiceMatters.com
Reporting by Paul Ring • firstname.lastname@example.org
The following story is brought free of charge to readers byEC Infosystems, the exclusive EDI provider of EnergyChoiceMatters.com
The Illinois Commerce Commission adopted an order approving 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 adopted bill protection provides 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 ICC 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 ICC approved the program for 700 customers.
"The Commission believes that the agreement between Staff and ComEd to limit participation in the BPG Group to the 700 customers necessary to achieve a statistically significant result is reasonable, as the sample size will minimize costs while still allowing ComEd to ascertain whether a bill guarantee encourages customers to try hourly pricing, which is the goal of the pilot program," the ICC said
The ICC said that expansion of the bill protection provision may be sought in the future
"As ComEd explained ... in order to determine whether the BPG encourages customers to change their electricity use, a much larger sample size would be necessary. To the extent the Bill Protection Experiment indicates that bill protection encourages customers to enroll in Rider RRTP, ComEd may seek to expand the experiment or make it a permanent feature of Rider RRTP in the future and could at that time conduct a study to evaluate with statistical significance the impact of the guarantee on customer behavior," the ICC said
The ICC said that limiting the size of the BPG Group to 700, "is appropriate to limit any possible impact of the Bill Protection Experiment on competition."
The ICC rejected arguments from the Illinois Competitive Energy Association that the program would be anti-competitive. Among other things, ICEA noted that retail electric suppliers (RESs) cannot access customer interval usage data, to determine customers most likely to benefit from such a program (as ComEd and its third-party administrator will do when marketing the program), without prior customer consent, and therefore can not undertake a similar offering to the ComEd pilot
"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 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," the ICC said
"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 Commission agrees with 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," the ICC said
"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 ICC said
"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 ICC said
"The Commission also rejects ICEA’s contention that the proposed BPG would be improperly subsidized. As noted above, and supported by Staff and CUB, the funding will come from Elevate Energy’s [the real-time pricing program administrator] existing budget, and the Act permits ComEd to recover the reasonable costs associated with the RRTP Program Administrator’s activities," the ICC said
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 will focus on marketing only to Rate BES (default service) customers, in order to avoid disturbing customer relationships with RESs and those in municipal aggregation programs. The ICC generally approved ComEd's marketing plan