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Duquesne Light Company filed a Petition For DSP – DLC  with the Pennsylvania Public Utility Commission for approval of its default service plan for the period from June 1, 2025 through May 31, 2029 (“DSP X,” “Default Service Plan that also includes: (1) an Electric Vehicle Time-of-Use Pilot Program (“EV-TOU”), (2) a Green Tariff Pilot, (3) continuation of the Standard Offer Program (“SOP”), (4) continuation of the Solar Purchase Power Plan provisions approved in DSP IX to the extent that the Company is not able to enter into a contract during the remainder of the DSP IX period, and (5) minor amendments to the Company’s Supply Master Agreement (‘SMA”).

Proposed Default Service Procurement Plans And Rates –  “The DSP X Plan largely continues the procurement approaches and rate terms that are currently in effect under DSP IX, with certain modifications to the Medium Commercial & Industrial customers group under 200 kW and Large Commercial & Industrial (“Large C&I”) customers (collectively (“HPS-Eligible”)). 

Proposed Medium C&I Default Service Customers Under 200 kW – “In Duquesne Light Statement No. 2, Duquesne Light witness John Peoples explains Duquesne Light’s proposal to switch from the current approach of soliciting three-month FPFR products in quarterly solicitations to a new approach for the Medium C&I <200kW customer class.  Under the new approach, all of the default service supply for the Medium C&I <200kW customer class still will be procured in the form of FPFR products, but half of the default service supply for the Medium C&I <200kW customer class will be procured in the form of 12-month FPFR products and half will be procured in the form of six-month FPFR products, with 3-month pricing terms.

For the half of the supply that is procured in the form of 12-month FPFR products, 50% of that supply (i.e., 25% of the total supply for the customer class) will be procured in each solicitation; therefore, the 12-month FPFR product delivery periods will overlap on a semiannual basis. 

For the half of the supply that is procured in the form of six-month FPFR products with 3-month pricing terms, 100% of that supply (i.e., 50% of the total supply for the customer class) will be procured in each solicitation; therefore, there will be no overlap of these FPFR supply products across the solicitations.

Rates for Medium C&I customers will continue to be reset quarterly, and Duquesne Light proposes to continue to reconcile costs for these customers on a semi-annual basis.

Duquesne Light said that the proposed change for Medium C&I supply procurement, “will provide greater price stability for Medium C&I <200kW customers, which is especially important given the higher underlying wholesale market volatility experienced recently.”

Duquesne Light further said that the change is designed, “to better encourage greater supplier participation and better ensure successful solicitations.”

Duquesne Light said that the current use of three-month contracts for Medium C&I default service results in two procurements annually that are solely for Medium C&I supplies (since other customer classes have longer contracts and no tranches to be filled in these auctions).

“This may discourage some supplier participation because, all else equal, suppliers may be less likely to be interested in investing time and resources in a solicitation if the amount of supply that they can be awarded is small.”

Duquesne Light does not propose any changes to the procurements for Residential & Lighting; Small C&I; and hourly customers.

As done currently, for the Residential & Lighting class, and the Small C&I (under 25 kW) class, Duquesne Light will procure default service supply through overlapping twelve-month (50% of the portfolio) and twenty four-month (50% of the portfolio) full requirements contracts.

Rates for the Residential & Lighting class, and the Small C&I class, would change every six months.

See:  Testimony Of John A. Peoples Exhibit JP – 1: Overview of Supply Portfolio by Customer Class at the docket link:  Petition For DSP – DLC 

Green Tariff For Non-Shopping Customers:
Duquesne Light is also proposing a pilot for an optional Green Tariff for residential customers who are served under default service.

Under the Green Tariff, an additional 7% of the participating customer’s annual consumption would be matched with carbon-free electricity (CFE) sourced within Pennsylvania.

Duquesne Light proposes to use the U.S. government’s definition of CFE, where CFE is electrical energy produced from resources that generate no carbon emissions. Among other sources, this includes nuclear as well as electrical energy generation from fossil resources to the extent there is active capture and storage of carbon emissions that meets the EPA’s requirements.

To acquire the additional CFE, Duquesne Light proposes to conduct an auction, and retail suppliers (electric generation suppliers, or EGSs) and other third parties will be allowed to bid for the right to provide energy attribute certificates (EACs) to serve Green Tariff customers.   

Note that a copy of the tariff was not included with the Duquesne Light’s default service plan filing.

In the proposal, Duquesne states that “[t]he supplier who bids the lowest price ($ per EAC) in this [Green Tariff] solicitation will be selected to provide the additional EACs.”

“The winning Green Tariff provider of EACs will be determined solely on price and will be paid the per unit price that they bid.” 

“The third set of administrative costs would cover contingency costs if the winning supplier were to default, and the Company would have to provide the balance of the EACs through spot market purchases until such time that a new supplier was selected.”

“The Green Tariff will allow EGSs and/or third-party suppliers to offer green services to default service customers who may be reluctant to leave utility default service.” This statement uses suppliers (plural) when it could have been phrased differently if only a single provider will be selected (either stating “EGSs will be provided an opportunity to bid for the right to offer green services” or that the Green Tariff will allow, “the selected EGS and/or third-party supplier…”)

“Duquesne Light will list the name of the EGS or provider on customer bills who participate in the Green Tariff.” 

“The Green Tariff will allow EGSs and/or third-party suppliers to offer green services to default service customers who may be reluctant to leave utility default service. … The Company’s Green Tariff will allow EGSs and/or third-party suppliers and aggregators an opportunity to reach customers that they may not otherwise be able to serve.”

Standard Offer Customer Referral Program:
Duquesne Light proposes to continue its Standard Offer Customer Referral Program (SOP) without any changes, although Duquesne Light said in its filing that, “the Company believes that the Commission should revisit the SOP program given that over ten years has passed since its inception and Duquesne Light has experienced disruptions in the ability to offer SOP during a seven month period of elevated prices and price volatility.”

New EV-TOU Default Service Rate:
Duquesne Light proposes a new EV-TOU supply rate for non-shopping customers with the TOU rates applied only to EV charging.

The new EV-only EV-TOU supply rate would be limited to 500 residential customers at a time.

Currently, Duquesne Light offers a whole house EV-TOU supply rate for non-shopping customers, and Duquesne Light would continue to offer this whole house EV-TOU supply rate.

Duquesne Light would use supplies from its standard default service procurement for the EV-TOU supply rates (no separate procurement for EV-TOU customers).

EV-TOU rates would be set by applying a rate factor to the standard supply rates to establish the TOU rates.

Any mismatches between revenues from EV-TOU supply rates and supply costs paid to default service suppliers would be recovered/refunded within the existing bypassable Rider No. 8 – DSS 1307(e) customer class reconciliation.