considering their role in the switching process. Ideally, we would like to have regulations in place so that these new metering capabilities can be used to their best advantage soon after their deployment. Current EGS procedures were also examined by OCMO to determine if changes could be made to shorten the switching timeframe. Some supplier practices may adversely affect the switching process timeframes. For example, the practice of batching enrollments before sending them to the EDC instead of sending enrollments to the utility one at a time may unnecessarily delay account transfers. As noted above, the Commission has waived the provision of 52 Pa. Code § 57.173 that requires the EGS to notify the EDC of the selection the end of the next business day following customer’s “by the customer in instances where the service is not to start until some contact” customer’s distant, future date. Docket No. M-2011-2270442. See October 2012 Interim Guidelines, However, under the color of that waiver, EGSs may be holding enrollments for reasons other than future service dates. Additionally, some EGSs hold enrollments and do not submit them to the EDC until the last day of the 3-day right of rescission period provided for in 52 Pa. Code § 54.5(d). exploration of these issues culminated in a November 10, 2011 Tentative OCMO’s Order, which proposed several options to accelerate switching timeframes. Interim Guidelines Regarding Standards For Changing a Electricity Generation Customer’s Docket M-2011-2270442 (Order entered Nov. 14, 2011). In the Tentative Supplier, Order we declared that changing the 3-business day rescission period at 52 Pa. Code § 54.5 is not feasible because it reflects existing Pennsylvania consumer contract law. Id. at 9; 73 P.S. §§ 201-1 see Unfair Trade Practices and Consumer Protection Law, Federal law also requires a 3-business day for door-to-door “cooling off period” transactions. Rule Concerning Cooling-Off Period for Sales Made at Homes or at 16 CFR Part 429. Further, we saw no point in changing the Certain Other Locations, feasible billing language in 52 Pa. Code § 57.174 unless we first changed “first period”
considering their role in the switching process. Ideally, we would like to have regulations in place so that these new metering capabilities can be used to their best advantage soon after their deployment. Current EGS procedures were also examined by OCMO to determine if changes could be made to shorten the switching timeframe. Some supplier practices may adversely affect the switching process timeframes. For example, the practice of batching enrollments before sending them to the EDC instead of sending enrollments to the utility one at a time may unnecessarily delay account transfers. As noted above, the Commission has waived the provision of 52 Pa. Code § 57.173 that requires the EGS to notify the EDC of the customer’s selection “by the end of the next business day following the customer contact” in instances where the customer’s service is not to start until some distant, future date. See October 2012 Interim Guidelines, Docket No. M-2011-2270442. However, under the color of that waiver, EGSs may be holding enrollments for reasons other than future service dates. Additionally, some EGSs hold enrollments and do not submit them to the EDC until the last day of the 3-day right of rescission period provided for in 52 Pa. Code § 54.5(d). OCMO’s exploration of these issues culminated in a November 10, 2011 Tentative Order, which proposed several options to accelerate switching timeframes. Interim Guidelines Regarding Standards For Changing a Customer’s Electricity Generation Supplier, Docket M-2011-2270442 (Order entered Nov. 14, 2011). In the Tentative Order we declared that changing the 3-business day rescission period at 52 Pa. Code § 54.5 is not feasible because it reflects existing Pennsylvania consumer contract law. Id. at 9; see Unfair Trade Practices and Consumer Protection Law, 73 P.S. §§ 201-1 Federal law also requires a 3-business day “cooling off period” for door-to-door transactions. Rule Concerning Cooling-Off Period for Sales Made at Homes or at Certain Other Locations, 16 CFR Part 429. Further, we saw no point in changing the “first feasible billing period” language in 52 Pa. Code § 57.174 unless we first changed
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