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Proposed PPL Settlement Ends Customer Referral Program & Use Of 6-Month SOS Contracts For Mass Market Customers; Also Seeks Mid-Course Correction To Default SOS Rates

Dockets: P-2024-3047290
Category: Uncategorized

PPL Electric Utilities Corporation (PPL), the Office of Consumer Advocate (“OCA”), the Office of Small Business Advocate (“OSBA”), the Coalition for Affordable Utility Services and Energy Efficiency in Pennsylvania (“CAUSE-PA”), and Retail Energy Supply Association (“RESA”), all parties to the proceeding file a “Joint Petition for Approval of Settlement” (“Settlement”) and respectfully request that Administrative Law Judge (“ALJ”) and the Pennsylvania Public Utility Commission (“Commission”) to approve the proposals set forth in PPL Electric’s above-captioned petition subject to the terms and conditions of the Settlement. This Settlement is not contested by any party and represents a full settlement to resolve all issues raised in the instant proceeding.

PPL’s Standard Offer Customer Referral Program (SOP):

The settlement in PPL’s default service proceeding would terminate PPL’s standard offer customer referral program (SOP) and establishing a collaborative to address RESA’s concerns about PPL’s communications to shopping customers concerning choice The termination of the standard offer customer referral program (SOP) would begin June 1, 2025, through May 31, 2029. The end of the SOP for the DSP VI term does not prevent any settling party from proposing an SOP program as part of consideration of any future default service plan.

As background, under the current SOP, interested customers are assigned to a participating retail supplier and receive for 12 months a rate that is 7% below the price to compare in effect at the time of SOP enrollment. At the end of the SOP 12-month term, the customer remains with their assigned retail supplier, at a rate determined by the supplier, absent an affirmative action by the customer to sign a new contract or take service from another supplier or default service.

As previously reported, PPL in its default service petition had proposed various changes to the SOP, including dropping customers to default service at the end of the SOP term absent an affirmative action by the customer, and additional communications to SOP customers concerning their retail supplier and supplier rate. OCA and CAUSE-PA favored ending the SOP.

Excerpts regarding RESA’s support for stipulation:

“RESA struggled with supporting a settlement recommending the end of the last remaining program which encourages customers to shop. As discussed at great length in the testimonies of [RESA’s witness], RESA strongly disagrees with the reasons offered by PPL, OCA and CAUSE-PA in support of ending the SOP. However, reforming the SOP in the manner initially proposed by PPL would have been a costly and time-consuming exercise that would very likely have resulted in the end of SOP due to a lack of EGS participation.”

“Thus, given the inevitability in this service territory of the end of the SOP if PPL’s initial proposals were adopted, RESA worked in good faith with the parties to develop a Settlement that reasonably addresses other concerns raised by RESA. Importantly, as discussed [below], the Settlement provides a process to review PPL’s communications with EGS [retail supplier] customers. In addition, by agreeing to end the SOP, no ‘new’ Commission approved opportunities for PPL to communicate with EGS customers in the context of the SOP or justified by the existence of the SOP will be created. For all these reasons, RESA has reluctantly agreed to support the Settlement’s proposal to end the SOP in the hopes that the collaborative process can productively focus on avoiding future communications from PPL to EGS customers that can be considered misleading or anticompetitive.” 

PPL Communications To Shopping Customers

The settlement requires that a collaborative be established, “to determine the timing, frequency, and content of PPL Electric’s written communications sent directly to shopping customers about their contracts and rates for competitive electric generation supply service.”

During the period in which the collaborative is occurring, PPL agrees to not send “written communications directly to shopping customers” that contain the customer’s generation rate or which include the name of the customer’s retail supplier. This prohibition does not apply to bill messages, postings to PPL’s website, or communications with customers in response to inquiries or complaints and does not apply to PPL’s customer assistance program (CAP) for low-income customers (OnTrack).

The settlement provides that the collaborative shall discuss whether changes are needed on customer bills to ensure that shopping customers are able to make, “a mathematically accurate dollar-for-dollar comparison” between their supplier’s charges and, “the default service rate.”

To the extent the collaborative does not reach consensus, any party to the collaborative may seek a PUC Staff decision on the PPL shopping customer communication matters from the PUC’s Office of 

Shopping & Customer Assistance Program:

Customers participating in OnTrack, PPL’s customer assistance program (CAP), are prohibited from shopping for a retail supplier. Currently, if a shopping customer becomes eligible for CAP and seeks to enroll in CAP, the customer must first, on their own, cancel service with their retail supplier. If this cancellation does not occur, the customer’s CAP enrollment is rejected.

Under the settlement, for customers eligible for CAP, PPL will automatically move currently shopping customers, who seek to enroll into CAP, to default service.

Retail suppliers will be prohibited from charging an early termination fee to customers whose EGS service ends due to enrollment in CAP.

PPL”s Default service Procurements:

The settlement generally approves PPL’s proposed default service procurements and rate setting except for some changes related to block purchases.  The settlement would accept PPL’s proposal to end the use of 6-month contracts, and to introduce 24-month contracts, as part of the fixed price full requirements contracts used in the default service portfolio for non-hourly customers (residential and small C&I)

Under the settlement, 80% of the residential SOS portfolio served under full requirements contracts would be served by laddered 24-month contracts, after a transition period from the current portfolio.

The 12- and 24-month contracts would be laddered in a similar manner to the current DSP, except that the procurement dates would be held earlier.

In addition to the full requirements contracts for residential customers, PPL Electric would procure 150 MW of Long-Term Block contracts for 10-year terms for residential SOS. However, the settlement modifies PPL’s original proposal so that these blocks are for energy only, and will not include capacity as originally proposed. The 150 MW in block energy contracts represents about 15% of residential SOS load.

The block energy would not apply to small C&I SOS, and small C&I SOS would be served 100% by full requirements contracts. After a transition period due to existing SOS contracts, the settlement provides that 80% of small C&I default service would be served under laddered 24-month contracts.

The procurement portfolios and procurement dates for residential and small C&I customers are linked below (the linked schedules are based on PPL’s original filing, which remains accurate except that the reference to a block energy/capacity product has been modified as noted above and will now be blocks of energy only)

Under the stipulation, PPL would move the full requirements procurement dates further away from the delivery date. PPL had cited more favorable results in earlier procurements in proposing such change.

The settlement’s adopted schedule will hold Full Requirements solicitations in February and July of each year, as compared to the April and October solicitation periods in the current default service plan.

For mass market customers, changes in the Price to Compare would continue to be every 6 months.

Hourly pricing would apply to customers over 100 kW.

Joint Stipulation (08/28/2024)
Joint Petition For Approval of Settlement  (08/27/2024)
P-2024-3047290  (03/12/2024)
Petition of PPL Electric Utilities Corporation for Approval of a Default Service Program and Procurement Plan for the Period June 1, 2025, through May 31, 2029