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PSC Accepts Two Retail Supplier Load Shaping Pilots

Pilot To Include Warm Transfer Process From Utility Call Center

January 8, 2020

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Copyright 2010-20
Reporting by Paul Ring •

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The Maryland PSC recently accepted two load shaping pilots proposed by retail electric suppliers

The PSC directed Baltimore Gas & Electric to accept a proposal from Constellation, and directed Pepco to accept a proposal from Inspire Energy Holdings LLC


The PSC directed BGE to accept Constellation’s load shaping pilot proposal, subject to the condition related to customer treatment at the end of the pilot noted below

Details of Constellation's response to the load shaping RFP had been filed under seal

In a letter order accepting the pilot, the PSC described Constellation's pilot as, "offering a supply price matching Standard Offer Service with the potential to earn a 'good user discount.'"

In a prior request for additional information, the PSC noted that, under Constellation's proposal, "Task 2 – Requested Ratepayer Support," Constellation requests BGE’s support in the form of "awareness marketing." The proposal identifies specific marketing channels, including the EmPOWER efficiency programs, 2 bill inserts during the recruitment period, BGE customer portal and the BGE call center.

The PSC noted that it previously sent letters to both BGE and Constellation seeking additional information. In response, BGE provided estimates for the requested ratepayer support for recruitment, including: 1) a webpage banner for minimal cost; and 2) a bill insert for $10,000 when provided to the full service territory. Constellation provided additional information regarding its requested support. Constellation outlined a two-phase approach with web page inclusion and call center support in phase one and a bill insert in phase two, only if necessary, the PSC said

The PSC in a letter order further said that Constellation has stated, regarding treatment of customers at the end of the pilot, that, "Pilot participants will be offered the prevailing fixed price renewal offers available to the general BGE service territory at the end of the pilot, which may also include continued participation in a pilot-like program depending on results and engagement. Constellation currently offers a range of residential products and services which customers may opt into based on their preferences. If pilot customers do not opt into an alternative offer, they will be renewed to a standard 12-month fixed price product."

The PSC said that, "The Commission does not accept this element of the proposal. At the close of the pilot, Constellation must acquire affirmative consent to retain the pilot customers. If Constellation does not acquire a customer’s consent to one of its range of other residential products or services, the customer should be returned to SOS."

"Pursuant to the timeline in the Letter Order, the Commission hereby directs BGE to accept Constellation’s proposal, incorporating the information and assurances provided in both BGE and Constellation’s letters and the limitation on retaining customers at the close of the pilot. The Commission looks forward to seeing Constellation’s final Evaluation Measurement and Verification ('EM&V') plan, as described in Section 3 of the RFP, on January 31, 2020, incorporating any additional feedback from Pepco’s selected EM&V contractor," the PSC said

BGE filed a rehearing request concerning the PSC's letter order accepting the Constellation pilot, expressing concerns with certain support its call center may provide under the pilot (such as facilitating a warm transfer process), and ensuring costs are paid by Constellation and not ratepayers

BGE noted that, "The RFP Statement of Work, which the Commission directed BGE to issue, stated that '[t]he Bidder shall be responsible for any market research, developing marketing and enrollment material, customer recruitment and enrollment, and tracking participants throughout the entirety of the pilot.' Constellation requested in its bid BGE support in marketing program availability through existing communication channels such as marketing as part of the existing Energy Efficiency programs, two bill inserts within BGE bills during the enrollment period, use of the BGE customer portal, and use of the BGE call center."

BGE said that, "Pursuant to the Pilot Timeline in the RFP Statement, the Company submitted comments on the bids received to the Commission on October 15, 2019. In its comments, BGE noted that 'if Constellation’s bid was accepted by the Commission, a waiver of COMAR B (4), which prohibits a utility from engaging in promotions, marketing or advertising with a core or non-core service affiliate, would be required.' In response to a November 13, 2019 Commission letter requesting additional information about the ratepayer support requested by Constellation, BGE explained that Constellation's proposal was unclear to what extent BGE resources would be relied upon and therefore BGE was unable to provide specific cost estimates. However, the Company indicated that there may be certain marketing channels that could be leveraged with minimal costs and resources, but the Company would require further details in order to provide more accurate cost estimates. It was not until after receiving the Commission's December 5, 2019, letter order directing the Company to accept the Constellation's bid submitted that BGE first saw the additional information provided to the Commission by Constellation."

BGE said that, among other things, Constellation clarified its requested support from the BGE call center as follows:

• Constellation proposes to work with BGE to target 25-30 agents that are trained to promote the program to Standard Offer Service customers as part of certain call types.

• Constellation will assist BGE with scripting for the Call Center, highlighting the key benefits of the program.

• Constellation will fund a recognition program for the participating agents that participate and transfer calls. Recognition program design would be TBD based on feedback from BGE so as not to violate employment contracts.

• A warm transfer to Constellation's Call Center team would be initiated for any customers interested in enrolling. Constellation's Call Center team will be responsible for enrolling participants in the program.

BGE again noted that, "The RFP Statement of Work provided that the '[t]he Bidder shall be responsible for ... customer recruitment and enrollment. . .. '"

"BGE is uncertain as to what exactly Constellation intends to ensure compliance with the RFP's requirement and to ensure BGE customers are not negatively impacted," BGE said

BGE said that, "As noted in previous communications with the Commission, the Company believes that certain support can be provided by its call center that would have minimal impacts on its operations and as such the Company has initiated discussions with Constellation to reach agreement on the appropriate level of support to be provided by BGE that complies with the RFP Statement of Work and ensures BGE customers are not negatively impacted. Therefore, BGE is filing this rehearing request to ensure that the Commission can address any issues that it is unable to resolve with Constellation to ensure compliance with the RFP Statement of Work and assurance that BGE customers are not negatively impacted. BGE is not requesting further Commission action at this time, but will update the Commission on the status of its discussions with Constellation by no later than January 31, 2020. At such time, the Company shall also renew its request for a waiver of COMAR"


The PSC also issued a letter order to Pepco directing Pepco to accept Inspire Energy Holdings LLC's proposal, which the PSC described as offering "whole bill, clean energy time varying rates," subject to the conditions below

Inspire's responses to the load shaping RFP were filed under seal, and only a limited description of two options were previously filed by Pepco (see details here)

In a letter order directing Pepco to accept Inspire's proposal, the PSC noted that, "Pepco indicated that creating the customer list Inspire requests in its proposal would cost $25,000 and that Pepco would need to acquire customer consent from all customers to provide customer-specific information to Inspire. Inspire provided additional details regarding their not to exceed request for ratepayer support and committed to providing its whole bill offering within the existing billing structures currently offered by Pepco."

The PSC said that, "Regarding customer consent to provide customer-specific information, the Commission will not require Pepco to seek out customer consent to information."

"Inspire’s proposal indicates that the information it seeks is currently produced and provided yearly. If Inspire needs more detailed customer-specific information that requires consent, Inspire must acquire that consent pursuant to existing Maryland Regulations and furnish that consent to Pepco," the PSC said

"Pursuant to the timeline in the Maryland Public Service Commission’s Letter Order, the Commission hereby directs Pepco to accept Inspire’s proposal, incorporating the information and assurances provided in both Pepco and Inspire’s letters. The Commission looks forward to seeing Inspire’s final Evaluation Measurement and Verification ('EM&V') plan, as described in Section 3 of the RFP, on January 31, 2020, incorporating any additional feedback from Pepco’s selected EM&V contractor," the PSC said

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