ComEd Seeks Declaratory Order Concerning Ability To Post Default Service Price To Compare On Bills Issued To Retail Supplier Customers

Commonwealth Edison has petitioned the Illinois Commerce Commission for a declaratory order affirming that ComEd is not prohibited from including on bills a bill message setting forth "Price to Compare" information on the customer bills for the majority of residential and commercial accounts that have the premises attribute of 15,000 kWh or less annual usage (excluding only those on the Single Bill Option or the summary bill option).

ComEd intends to place the following bill message within the bill message section of the customer bills for residential and commercial accounts that have the premises attribute of 15,000 kWh or less annual usage (except for those on the Single Bill Option or the summary bill option).

PRICE TO COMPARE: The ComEd electric supply price to compare is x.xxx cents per kWh. For more information and supplier offers visit https://www.pluginillinois.org. This price does not include a monthly purchased electricity adjustment factor that may range between +$0.005 and -$0.005 per kWh. For more information on ComEd bill line items go to ComEd.com/UnderstandBill.

In its petition, ComEd noted that the Commission’s rules provide that Integrated Distribution Companies (IDCs), such as ComEd, "shall not promote, advertise, or market with regard to the offering or provision of any retail electric supply service."

However, ComEd noted that the rules explicitly authorize IDCs to meet the obligations set forth in Section 16-117 of the PUA (requiring utilities to include on the bill a link to the ICC's customer education site), and authorize IDCs to, "otherwise engag[e] in legitimate consumer education efforts."

ComEd sought a declaratory ruling that the proposed bill message as set forth above is the type of "legitimate consumer education effort" expressly authorized by the Commission rules, rather than the types of promotion, advertising, and marketing in which ComEd is not permitted to engage.

ComEd said in its petition that it is ComEd’s intent that the proposed bill message concerning the PTC function, "to even-handedly inform customers regarding their supply options." The bill message will appear on all customer bills for residential and commercial accounts that have the premises attribute of 15,000 kWh or less annual usage (except for those on the Single Bill Option or the summary bill option), regardless of whether the PTC is higher or lower than the price each customer pays for supply.

"The bill message does not make any comparison between the PTC and the price the individual customer pays for supply, instead allowing customers to draw their own conclusions nor does the bill message make a comparison between the PTC and the value of any supply services provided (e.g. green offering product, term of contracts, gift card, etc.)," ComEd said in its petition

ComEd is prepared to place the proposed message on customer bills as noted in this Petition in time for such message to be placed on the December 2018 customer bills.

Docket 18-1623