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Pennsylvania Consumer Advocate Newly Seeks Adoption Of Utility Communications Alerting Customers If They Pay More Than Price To Compare; Shadow Billed Data
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In an electric rate case at UGI Utilities in Pennsylvania, the Pennsylvania Office of Consumer Advocate is seeking changes to various information provided to customers concerning electricity shopping, including the implementation of targeted communications to shopping customers with rates above the price to compare (PTC)
A witness for OCA proposed that UGI develop "targeted" communications to
customers with retail supplier charges that "increase significantly" over the PTC, to alert such customers to compare the retail supplier
price to the PTC.
Such alerts would include a calculation that shows the difference between the PTC and the supplier rate in the customer’s recent
bills (shadow billing).
UGI estimates the IT costs to program such a PTC alert at
approximately $150,000
OCA called this expense a "de minimis amount".
OCA also sought changes concerning shopping information and education presented to customers
OCA said that UGI should eliminate any reference to the potential to "save" in any presentation
of retail choice, "since that is not the actual experience for the vast majority
of residential customers who choose an EDS [sic]."
Shopping information, a witness for OCA said, should, "explain that the risk of higher prices is documented and how to avoid
higher prices and bills."
OCA's witness said, "UGI should explain how to shop and compare EGS
prices during the entire term of the contracts and alert customers to the
potential for a change in the EGS price after any initial promotional price
and how EGS variable rates can reflect volatile changes in the wholesale
market that are not reflected in the more stable PTC."
"This fact-based content
is justified by the actual results of residential customer shopping as
documented both historically and most recently in UGI’s analysis provided
in this proceeding," OCA's witness said
OCA also sought changes to the UGI bill format and language, as OCA argued that the PTC appearing on bills is not sufficiently linked to the supply rate information
UGI identifies the PTC on the first page of its
residential customer bills (in a PUC-required Shopping Information Box), but then, as described by OCA, "identifies default service as 'Generation Charge' in the
itemized list of customer charges."
OCA's witness recommended that UGI, "either specifically reference the PTC in the 'Generation Charge' which is the label
on the bill for the EGS charges or make clear in the Shopping Information Box that the PTC is the
price for 'Generation Charge.'"
UGI in a brief said that a "problematic" aspect of OCA's bill presentation proposal, "is that the change of the PTC to
'Generation Charge' on the bill conflicts with the Commission’s regulations and reflects a
fundamental misunderstanding of the PTC’s components."
UGI said, "Section 54.187 of the Commission’s
regulations specifically requires that a default service customer 'be offered a single rate option, which shall be identified as the PTC and displayed as a separate line item on a customer’s monthly
bill.' Therefore, UGI Electric must display the PTC as a separate line item on the Company’s
bills. Furthermore, the PTC includes more than generation charges, contrary to [OCA witness's]
apparent understanding. Rather, the 'PTC is equal to the sum of all unbundled generation and
transmission related charges to a default service customer for that month of service.' Presenting
this line item as only a 'Generation Charge' would be inaccurate and confusing for customers,
especially since the PTC terminology has been used for many years in the Commonwealth across
the industry."
OCA said that OCA's witness reviewed, based on data from UGI, "calculations of how much customers paid to an Electric Gas [sic] Supplier (EGS)
compared to UGI’s price to compare (PTC)."
OCA said that those calculations show that the total amount
of excess charges over the PTC was $230,291. OCA's brief itself was not explicit as to the period of time over which this comparison applied (which was addressed in pre-filed testimony which is not online)
OCA said that UGI’s data also showed that as of March 2026, 463 residential
customers were enrolled with an EGS at UGI
UGI generally said in a brief that OCA's proposals are unnecessary and costly
UGI noted that the PUC in a recent Columbia Gas rate case order (story by ECM here), rejected similar proposals from OCA as inappropriate for adjudication in a rate case, with the PUC citing, among other things, the lack of retail supplier parties as intervenors in the rate case. UGI noted that no retail suppliers or supplier groups are represented in its electric rate case
R-2025-3059430
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September 11, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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