Section 54.182, is to level the playing field for default service and competitive EGS products. The Companies asserted that a level playing field is established by assuring that the costs EGSs bear to purchase generation for delivery to an load zone EDC’s mirror the service the EDC includes in its PTC. In that way, the “default costs” Companies maintained that an accurate comparison can be made between the prices for competitive service offerings and the PTC. The Companies claimed that the NITS Proposal accomplishes the level playing field envisioned by the default Commission’s service regulations by recovering PJM-imposed NITS charges through the Companies’ DSSRs. Companies R.B. at 5-6. Exelon argued that including NITS among those charges collected through the DSSR for all customers will encourage greater competition by reducing risks for default service suppliers, which in turn will promote procurement of the least cost generation supply contracts. Exelon averred that this creates a more competitive backstop service against which EGSs can compete in order to serve shopping customers at the lowest competitive cost. Exelon opined that the collection of costs through the DSSR for all customers will allow for EGSs to more effectively compete on an basis against default service. Exelon M.B. at 10. Exelon explained that the of the Competition Act does not “plain language” prohibit the NITS Proposal as the focus of the Act is on competition for the generation, not transmission, of electricity. 66 Pa. C.S. § 2802(13); Exelon R.B. at 8. Exelon See, opined that there is no prohibition anywhere in the Act. With regard to the IUG’s reliance on the statutory section that requires unbundling to separate the charges for generation, transmission and distribution, 66 Pa. C.S. § 2804(3), Exelon responded that under reading of these sections, if transmission costs are no longer allowed to be IUG’s collected and charged by EDCs, then the EDCs must also be prohibited from collecting and charging for distribution costs, since both of these charges are included, along with generation, in the list of those subject to According to Exelon, the “unbundling.”
Section 54.182, is to level the playing field for default service and competitive EGS products. The Companies asserted that a level playing field is established by assuring that the costs EGSs bear to purchase generation for delivery to an EDC’s load zone mirror the “default service costs” the EDC includes in its PTC. In that way, the Companies maintained that an accurate comparison can be made between the prices for competitive service offerings and the PTC. The Companies claimed that the NITS Proposal accomplishes the level playing field envisioned by the Commission’s default service regulations by recovering PJM-imposed NITS charges through the Companies’ DSSRs. Companies R.B. at 5-6. Exelon argued that including NITS among those charges collected through the DSSR for all customers will encourage greater competition by reducing risks for default service suppliers, which in turn will promote procurement of the least cost generation supply contracts. Exelon averred that this creates a more competitive backstop service against which EGSs can compete in order to serve shopping customers at the lowest competitive cost. Exelon opined that the collection of costs through the DSSR for all customers will allow for EGSs to more effectively compete on an basis against default service. Exelon M.B. at 10. Exelon explained that the “plain language” of the Competition Act does not prohibit the NITS Proposal as the focus of the Act is on competition for the generation, not transmission, of electricity. See, 66 Pa. C.S. § 2802(13); Exelon R.B. at 8. Exelon opined that there is no prohibition anywhere in the Act. With regard to the IUG’s reliance on the statutory section that requires unbundling to separate the charges for generation, transmission and distribution, 66 Pa. C.S. § 2804(3), Exelon responded that under IUG’s reading of these sections, if transmission costs are no longer allowed to be collected and charged by EDCs, then the EDCs must also be prohibited from collecting and charging for distribution costs, since both of these charges are included, along with generation, in the list of those subject to “unbundling.” According to Exelon, the
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