RESA Files Comments On CAP Customer Price Cap At FirstEnergy Pennsylvania EDCs

The Retail Energy Supply Association filed comments on implementation of a price cap on retail electric supplier offers made available to Pennsylvania Customer Assistance Program (PCAP, or CAP) customers at the FirstEnergy Pennsylvania electric distribution companies, in advance of a November 5 collaborative meeting

EnergyChoiceMatters.com was first to report the PUC's adoption of the CAP "shopping program" at the FirstEnergy EDCs, under which CAP customers may only enter into a contract with an EGS for a rate that is at or below the utility’s Price to Compare (PTC) and which does not contain an early termination or cancellation fee. As previously reported, the PUC delegated to the Office of Competitive Market Oversight (OCMO) further discussion concerning mechanics and implementation of the price cap

In its comments, RESA, among other things, addressed the transition of CAP customers on existing retail supply contracts.

In its comments, RESA said, "RESA supports a flexible approach that allows EGSs to manage the notice of contract cancellation process based on their individual company's processes and abilities. Requiring EGSs to continue to send their 'standard' (and Commission required) initial and options notices only to send a third cancellation notice is inefficient and confusing. To be clear, RESA is not advocating that EGSs must be required to cancel these contracts prior to expiration but rather that the Commission provide EGSs the flexibility to manage the customer notice process more efficiently and to minimize customer confusion about shopping. EGSs are best positioned to determine the optimal way to communicate with their customers about changes being necessitated due to new Commission requirements." [emphasis in original]

Concerning the identification of CAP customers, RESA said, "generally RESA supports the use of EDI enrollment responses to communicate both the CAP status of a customer as well as any change in status. Also, RESA generally supports a flag on the ECL [eligible customer list] regarding CAP participation. Finally, EGS supports a regular on-going communication from FirstEnergy to the EGS identifying the CAP status of EGSs' existing customers."

The collaborative will also address scripts for the Standard Offer customer referral program (CRP)

Concerning the customer referral program, RESA said in its comments that, "To effectively analyze why enrollment in FirstEnergy's CRP dropped by an average of 88% following implementation of the prior default service plan ('DSP IV'), RESA recommends that FirstEnergy be directed -- in advance of the collaborative -- to circulate the scripts utilized both before and after they were changed as a result of the DSP IV proceeding. Included with these materials should be the scripts utilized by both FirstEnergy and its third party vendor administering the CRP. RESA would also recommend that this information also specify any changes to FirstEnergy's processes resulting from DSP IV regarding the process and timing of when customers are informed about CRP and then transferred to FirstEnergy's third party vendor. Importantly, a full understanding of the customer's experience is important to help better understand what changes may have led to the decline in CRP enrollments. The customer's experience includes more than the scripting that is utilized. RESA would also respectfully suggest that -- in advance of the collaborative -- other electric distribution companies ('EDCs') with similar standard offer programs be directed to share similar information. Given that these other utilities did not experience the decline in enrollment after implementation of their Commission-approved default service plans around the same time, this comparison would provide useful information for the Commission and stakeholders to consider during this collaborative process."

Docket P-2017-2637855