PUC Seeks Comment on Waiver Related To Switching Confirmation Letter In Light Of Implementation of Instant Connects (Day One Shopping); Approves UGI Implementation Plan

The Pennsylvania PUC issued a tentative order proposing to change when the EDC confirmation letter is sent in situations of an instant connect (day one shopping).

The PUC noted that regulations require that the EDC switch confirmation letter be mailed by the end of the next business day following the receipt of the notification of the customer’s selection of an EGS or default service provider.

In instant connect situations, however, the customer may not yet be at the service address, and if the letter is sent under the current timeline, the letter may be received by a different customer or be returned to the utility

Therefore, the PUC proposes that in instant connect situations, a waiver be granted such that the EDC confirmation letter shall instead be mailed by the end of the next business day after the start of service at the new account location

While the PUC anticipates modifying its regulations to reflect an environment that includes seamless moves and instant connects, the PUC, "believe an appropriate amount of time must be afforded to implement and review these procedures before establishing a new binding norm," and proposes that the proposed waiver outlined above be adopted for a period of three years

Separately, the PUC adopted, with conditions, an instant connect and seamless move plan at UGI Utilities - Electric Division.

While the order contemplates that UGI shall implement seamless moves and instant connects no later than November 30, 2016, the PUC invited UGI to petition for a delay of such implementation if such implementation will impede implementation of three-day accelerated switching (which the PUC deems a higher priority) or if savings will result from coordinating the seamless move and instant connect implementation with a CIS upgrade

The PUC conditioned approval of UGI's seamless moves and instant connects plan on modifying the plan to be consistent with past PUC orders adopting such seamless move plans at other EDCs, such as requiring that the rate class remains unchanged; that the customer maintains the same supplier billing rate, billing option and tax exemption percentage; and that any gaps or overlap of service will be limited to three days.

The PUC also emphasized that seamless moves will be limited to residential and small business accounts

Regarding instant connect and seamless move cost recovery at UGI, the PUC disagreed with OCA’s primary position that costs should be borne by the EGSs. "While EGSs will obtain some benefit from these processes, customers will also benefit. The seamless move and instant connect functionality will not only benefit current shopping customers, it will be available for all eligible customers. These enhancements are permanent improvements that, to a large extent, are simply correcting an unacceptable status quo due to existing limitations in utility customer information systems. For these reasons, we agree with OCA’s secondary position that these costs be included in base rates. The scrutiny of a base rate proceeding is the appropriate mechanism to ensure that utilities will recover only prudent and reasonably-incurred costs," the PUC said