participants to this collaborative who were not parties to the proceeding. CAUSE-PA Petition at 6. CAUSE-PA opines that the Commission may have overlooked the fact that by opening up the collaborative to the issue of whether a CAP customer should pay a price higher than the PTC at any point while enrolled in the program, it unintentionally undermined its finding that the harm occurring as a result of unrestricted CAP shopping is caused by shopping at or above the PTC. CAUSE-PA Petition at 6-7. maintains that the Commission may have overlooked critical pieces of the record evidence in determining the issue of whether the EGS price could exceed the PTC at any point. CAUSE-PA notes that there was substantial and unrefuted evidence that allowing CAP customers to shop for electricity at prices which exceed the PTC causes significant financial harm to CAP and non-CAP customers. CAUSE-PA Petition at 7. CAUSE-PA notes that this evidence formed the evidentiary basis of the ALJ’s Recommended Decision and the Commission’s decision that, to stop the harm, CAP customers must be prevented from paying prices higher than the PTC. CAUSE-PA Petition at 9 (citing Order at 58). CAUSE-PA explains that allowing EGS rates that are above the PTC at some point after the initial contract would not solve the identified harm, a fact that the Commission appears to have overlooked. CAUSE-PA asserts further that the more than $18 million in harm that necessitated the restrictions in the first instance was caused by EGS contracts with CAP customers that exceed the PTC over long periods of time not just at the initiation of the contract. CAUSE-PA Petition at 9. CAUSE-PA notes that within the competitive market, EGS prices are often though not always lower than the PTC at the time of the initial contract. CAUSE-PA – – expresses that this is how customers are enticed to switch. Therefore, CAUSE-PA notes, a mere prohibition on contracting for EGS-supplied generation service at prices higher than the PTC at the start of the contract is unlikely to solve the problem of CAP
participants to this collaborative who were not parties to the proceeding. CAUSE-PA Petition at 6. CAUSE-PA opines that the Commission may have overlooked the fact that by opening up the collaborative to the issue of whether a CAP customer should pay a price higher than the PTC at any point while enrolled in the program, it unintentionally undermined its finding that the harm occurring as a result of unrestricted CAP shopping is caused by shopping at or above the PTC. CAUSE-PA Petition at 6-7. maintains that the Commission may have overlooked critical pieces of the record evidence in determining the issue of whether the EGS price could exceed the PTC at any point. CAUSE-PA notes that there was substantial and unrefuted evidence that allowing CAP customers to shop for electricity at prices which exceed the PTC causes significant financial harm to CAP and non-CAP customers. CAUSE-PA Petition at 7. CAUSE-PA notes that this evidence formed the evidentiary basis of the ALJ’s Recommended Decision and the Commission’s decision that, to stop the harm, CAP customers must be prevented from paying prices higher than the PTC. CAUSE-PA Petition at 9 (citing Order at 58). CAUSE-PA explains that allowing EGS rates that are above the PTC at some point after the initial contract would not solve the identified harm, a fact that the Commission appears to have overlooked. CAUSE-PA asserts further that the more than $18 million in harm that necessitated the restrictions in the first instance was caused by EGS contracts with CAP customers that exceed the PTC over long periods of time not just at the initiation of the contract. CAUSE-PA Petition at 9. CAUSE-PA notes that within the competitive market, EGS prices are often – though not always – lower than the PTC at the time of the initial contract. CAUSE-PA expresses that this is how customers are enticed to switch. Therefore, CAUSE-PA notes, a mere prohibition on contracting for EGS-supplied generation service at prices higher than the PTC at the start of the contract is unlikely to solve the problem of CAP