load and full requirements load are completely different products, with different risk profiles. As a result, including the TOU product with a fixed price default service product could limit supplier participation and/or unnecessarily increase default service prices. While it is understandable for Duquesne Light to try to plan for multiple scenarios and contingencies, its contingency plan as currently reflected in the SMA may compromise its procurements for its standard default service. FES proposes that SMA Section 4.3 be deleted. Alternatively, at the very least, this section should be revised to address the possibility of obtaining TOU from wholesale suppliers through an Addendum to the SMA, rather than combining the TOU load with suppliers' full requirements load. FES recognizes that Duquesne Light’s TOU program is still in the early “pilot” stages of development, but while the current usage is small it may become more robust during the POLR VI time period. FES believes that Duquesne Light’s TOU load should be served by an EGS either through a bid separate from its full requirements products, or as RESA suggests through an EGS solicitation on a less formal basis, after which Duquesne Light would post the information to a clearing house website, and certify the information to the Commission. RESA St. No. 2-R at 21. Constellation suggests an alternative methodology by which Duquesne Light could obtain TOU load from its default service suppliers, in order to obviate the risks of both customer shopping for EGS service and that customers will choose the TOU offering from Duquesne Light. Constellation’s proposal is that Duquesne Light allocate a pro-rata percentage share of TOU load to each tranche (including those awarded in the DSP RFP’s) and not revise the price paid to default service suppliers under their contracts. Duquesne Light would establish the TOU price through a pricing matrix,” and differences between the payments to “retail wholesale suppliers and amounts paid by TOU customers could be dealt with through the reconciliation process. Constellation St. No. 1 at 41-42. While FES’s preference is for TOU load to be separately bid to EGSs, FES believes Constellation’s proposal to be a reasonable
load and full requirements load are completely different products, with different risk profiles. As a result, including the TOU product with a fixed price default service product could limit supplier participation and/or unnecessarily increase default service prices. While it is understandable for Duquesne Light to try to plan for multiple scenarios and contingencies, its contingency plan as currently reflected in the SMA may compromise its procurements for its standard default service. FES proposes that SMA Section 4.3 be deleted. Alternatively, at the very least, this section should be revised to address the possibility of obtaining TOU from wholesale suppliers through an Addendum to the SMA, rather than combining the TOU load with suppliers' full requirements load. FES recognizes that Duquesne Light’s TOU program is still in the early “pilot” stages of development, but while the current usage is small it may become more robust during the POLR VI time period. FES believes that Duquesne Light’s TOU load should be served by an EGS either through a bid separate from its full requirements products, or as RESA suggests through an EGS solicitation on a less formal basis, after which Duquesne Light would post the information to a clearing house website, and certify the information to the Commission. RESA St. No. 2-R at 21. Constellation suggests an alternative methodology by which Duquesne Light could obtain TOU load from its default service suppliers, in order to obviate the risks of both customer shopping for EGS service and that customers will choose the TOU offering from Duquesne Light. Constellation’s proposal is that Duquesne Light allocate a pro-rata percentage share of TOU load to each tranche (including those awarded in the DSP RFP’s) and not revise the price paid to default service suppliers under their contracts. Duquesne Light would establish the TOU price through a “retail pricing matrix,” and differences between the payments to wholesale suppliers and amounts paid by TOU customers could be dealt with through the reconciliation process. Constellation St. No. 1 at 41-42. While FES’s preference is for TOU load to be separately bid to EGSs, FES believes Constellation’s proposal to be a reasonable
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