Utility: Retail Supplier Interest in Remote Account Number Look-up Tool "Not Overwhelming"; Seeks to Socialize Cost Among All Suppliers

PECO has filed a compliance plan to implement a program allowing retail electric suppliers, with customer authorization, to remotely access customer account numbers to facilitate enrollment in environments in which the customer may not have their bill.

In recently directing the utilities to develop such plans, the Pennsylvania PUC recommended the use of a user-fee structure to recover costs of the program, with the goal of limiting cost recovery from suppliers to only those suppliers who actually use the account-look-up system.

"PECO is greatly concerned with such an approach in that there are no assurances of cost recovery under such a mechanism. As a threshold matter, there is no historical data upon which to analyze a user fee for any system change, thereby providing no guarantee that PECO will fully recover its implementation costs," PECO said in its compliance plan.

"Moreover, supplier interest in the customer account number lookup tool has not been overwhelming. Indeed, the genesis of this supplier tool stemmed from a request by one EGS," PECO said.

"As a result, there is a significant business risk that PECO will not be able to recover its costs from limited users or that EGSs may avoid the account-lookup tool because of the user fee. To offset the risk of low participation in a user-fee recovery methodology, PECO would have to set a very high user fee. A high user fee, in turn, would further discourage participation in the program. Additionally, the user fee would require administrative tracking, invoicing and payment support, which will increase the personnel requirements and costs (including the user fee) of the program," PECO said.

Accordingly, PECO proposed to recover 50% of account look-up tool costs through a Purchase of Receivables discount, with the remaining 50% recovered through the Generation Supply Adjustment. PECO said that this cost recovery structure is consistent with its recovery of other market enhancement costs arising out of the Commission's Retail Market Investigation and the Commission's Final Order in PECO's second DSP case.

PECO said that under this approach, PECO would make adjustments to its GSA tariff rate to include 50% of the total costs amortized over a one-year period, with the remaining 50% of project costs recovered through the POR discount.

PECO currently estimates the total implementation cost of the remote account number access tool to be approximately $300,000 with additional software maintenance fees of approximately $4,000 annually. PECO did not provide a projection of what level of incremental POR discount would be needed to recover such costs.

Docket No. M-2013-2355751