Young Energy Seeks Postponement of Prepay Proposal for Publication Filed by PUCT Staff

Young Energy LLC, which offers prepaid service without the use of a customer prepayment device or system, opposed PUCT Staff's draft proposal for publication which would eliminate the offering of prepaid service without the use of a customer prepayment device or system (Project 38675).

As only reported by Matters, Staff recommended that all prepay service should use a customer prepayment device or system to ensure that customers are not harmed by REPs' discretion in estimating usage under estimated prepay (Matters, 10/11/10).

Young Energy LLC requested that the Commission postpone consideration of the draft proposal for publication, "until Commission staff have solicited comment on the need for a rule and potential scope of the rule from industry participants that will be directly affected by the proposed new P.U.C. SUBST. R. 25.498."

Young Energy said that an informal workshop/comment process is required prior to publication given the, "significant economic impact on retail electric providers serving this segment of the market, as well as end use consumers."

Young Energy encouraged the Commission to consider the options that would be available to customers, particularly those without advanced meters, if the current estimated prepay products are prohibited. "What are these options and how do they compare with the up-front cost of estimated prepaid service," Young Energy asked.

Young Energy further requested that the Commission investigate the basis for Staff's argument that it is difficult to ensure that REPs offering estimated prepay service do not abuse their discretion in estimating usage and billing customers.