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RESA Maintains Objection To Utility’s TOU Default Service Product – Utility’s Role Should Be Relegated To Advertising Suppliers’ TOU Options
RESA Letter:
{***} “Please accept this letter on behalf of The Retail Energy Supply Association (“RESA”)1 in response to Duquesne Light Company’s (“DLC”) Tariff Supplement No. 89 filed on February 10, 2025, pursuant to the Commission’s January 14, 2025, Order in the above captioned proceeding (“Commission Order”). RESA was an active party in the litigation involving DLC’s tenth default service plan (“DSP X”) which resulted in a full settlement approved by the Commission (“Settlement”).2 RESA recognizes, however, that DLC’s Tariff Supplement No. 89 is being made in direct response to the directive in the Commission’s Order. As such, RESA has elected not to request that the Commission permit it to further pursue its concerns related to this proposal through a further expedited hearing as contemplated by Ordering Paragraph 5 of the Commission Order. However, RESA does request that the Commission consider the issues discussed further below in reviewing the filing.
Consistent with the testimony of RESA witness Frank Caliva III during the DSP X proceeding, RESA fully supports offering consumers the ability to avail themselves of Time of Use Rates but does not support doing so through the continued expansion of the electric distribution company’s default service product. As Mr. Caliva testified, such expansion “implicates competitive market concerns and creates further pressures on the ability of the competitive market to innovate in response to the ever-changing market demands.”3 For these reasons, RESA recommends that the Commission consider the following suggestions as it reviews DLC’s filing:
- DLC should advise customers in advertising materials/TOU website that additional TOU options may be available in the competitive market.
- DLC should recover all costs associated with the TOU rate from default service customers as they propose.
RESA Letter (02/21/2025)
Rewrite of Opinion & Order (01/14/2025)
P-2024-3048592 (04/19/2024)
(Petition of Duquesne Light Company for Approval of a Default Service Plan.)
