Direct Energy RFIs Start to Deconstruct AEP Retail Energy Survey Results

The Direct Energy REPs have submitted Requests for Information to AEP Texas Commercial & Industrial Retail Limited Partnership, concerning AEP Texas Commercial & Industrial Retail Limited Partnership's recent direct testimony supporting AEP Texas Commercial & Industrial Retail Limited Partnership's sought REP certificate amendment to serve mass market customers (39509).

Though testimony from intervenors is not due until December 19, the RFIs give a glimpse at some of the initial points intervenors will seek to rebut.

As part of its expansion to serve mass market customers, AEP Texas Commercial & Industrial Retail Limited Partnership is also seeking to add the trade name AEP Retail Energy to its REP certificate.

As first reported by EnergyChoiceMatters.com, AEP Texas Commercial & Industrial Retail Limited Partnership's direct testimony included results from a survey concerning customer understanding of and attitudes towards various REP and TDU names, conducted by the Guild Group and supported by testimony from Will Guild, CEO of the Guild Group (see 11/11).

In his testimony, Guild cited data which shows, "Respondents overwhelmingly identify AEP Retail Energy as a REP, not a TDU." Specifically, some 52% of respondents said that AEP Retail Energy is a retail electric provider, although the company has not yet, as AEP Retail Energy, undertaken any operations or activity in Texas.

Give this, the Direct Energy companies submitted the following RFIs:

- "Regarding the statement on page 10 of Mr. Guild's testimony that 'Respondents overwhelmingly identify AEP Retail Energy as a REP, not a TDU', please identify whether and how this statement supports Mr. Guild's conclusion on page 10 of his testimony that the name AEP Retail Energy will not cause confusion among customers and is not misleading."

- "Please reconcile Mr. Guild's statement on page 10 of his testimony that the name AEP Retail Energy 'does not confer a competitive advantage' with the survey result demonstrating that at least 52% of survey respondents identify that the company AEP Retail Energy exists before such company has spent any money to advertise its existence and the survey result demonstrating that as many as 10% of the customers served by AEP Texas believe there is a service benefit to purchasing retail electric power from AEP Retail Energy while being served by the AEP TDU when no such benefit is legally permissible."