Commission in the OCA M.B. at 15. The PECO 2013 Universal Service Plan Order. OCA notes that, in recent Universal Service Plan proceeding, the Parties PECO’s discussed that CAP customers continue to have difficulty achieving affordable PECO’s bills under current CAP rate design. The OCA opines that increasing bills by PECO’s allowing EGS prices to exceed PTC would exacerbate this problem. OCA M.B. PECO’s at 17 (citing OCA St. CAP-1 at 6-7). The OCA explains that allowing an EGS price to exceed the PTC would increase CAP costs for non-participants in two ways. First, it would increase the CAP shortfall which is passed onto other customers through the USFC. Second, by adversely affecting CAP ability to pay, PECO would experience increased credit and customers’ collections costs, working capital and/or bad debt expense. The OCA avers that these increased costs would be borne by all of residential customers through an PECO’s increase in the overall revenue requirement. OCA M.B. at 18 (citing OCA Company’s St. CAP-1 at 10). PECO and the OCA point out that, in DSP II proceeding, the PECO’s Commission has previously imposed limitations on EGS pricing of RME standard offer programs where EGS participation is purely elective, particularly where the Commission seeks to introduce new customers to the competitive market. PECO and the OCA aver that, under the orders, restrictions on EGS pricing in RME programs in Commission’s which EGSs can choose whether or not to participate plainly do not constitute unlawful regulation of EGSs under the Electric Competition Act. PECO R.B. at 5 (citing October at 114-116), OCA M.B. at 9-10 (citing at 114). PECO 2012 Order October 2012 Order states that, under its CAP Shopping Plan, EGSs that choose to serve CAP customers will continue to be able to compete and set their own prices, subject to the requirement that the price for generation supply for a CAP customer does not exceed the applicable PTC. PECO R.B. at 5-6.
Commission in the PECO 2013 Universal Service Plan Order. OCA M.B. at 15. The OCA notes that, in PECO’s recent Universal Service Plan proceeding, the Parties discussed that PECO’s CAP customers continue to have difficulty achieving affordable bills under PECO’s current CAP rate design. The OCA opines that increasing bills by allowing EGS prices to exceed PECO’s PTC would exacerbate this problem. OCA M.B. at 17 (citing OCA St. CAP-1 at 6-7). The OCA explains that allowing an EGS price to exceed the PTC would increase CAP costs for non-participants in two ways. First, it would increase the CAP shortfall which is passed onto other customers through the USFC. Second, by adversely affecting CAP customers’ ability to pay, PECO would experience increased credit and collections costs, working capital and/or bad debt expense. The OCA avers that these increased costs would be borne by all of PECO’s residential customers through an increase in the Company’s overall revenue requirement. OCA M.B. at 18 (citing OCA St. CAP-1 at 10). PECO and the OCA point out that, in PECO’s DSP II proceeding, the Commission has previously imposed limitations on EGS pricing of RME standard offer programs where EGS participation is purely elective, particularly where the Commission seeks to introduce new customers to the competitive market. PECO and the OCA aver that, under the Commission’s orders, restrictions on EGS pricing in RME programs in which EGSs can choose whether or not to participate plainly do not constitute unlawful regulation of EGSs under the Electric Competition Act. PECO R.B. at 5 (citing October 2012 Order at 114-116), OCA M.B. at 9-10 (citing October 2012 Order at 114). PECO states that, under its CAP Shopping Plan, EGSs that choose to serve CAP customers will continue to be able to compete and set their own prices, subject to the requirement that the price for generation supply for a CAP customer does not exceed the applicable PTC. PECO R.B. at 5-6.