The only Party to object to PECO’s proposed eligibility rules for the Opt-In Program was RESA, which asserted that small business customers (i.e., those with loads of up to 25 kW) should be allowed to participate. RESA St. No. 2 at 19-20; RESA R.B. at 28, 30-32. PECO argued that RESA’s recommendation should not be adopted for two reasons. First, the small commercial customer base that RESA proposes to include is far less homogenous than PECO’s residential customer base because small commercial customers are served under different tariff rates, each with different line loss factors. PECO St. No. 2-R at 15-16. Consequently, extending the Opt-In Program to these customers would add complexity because different offers with different prices would have to be designed, solicited and marketed to different subsets of customers. PECO M.B. at 52; R.D. at 56. Second, PECO contended that RESA’s argument, that business customers should be included in the Opt-In Program because their shopping level is only slightly higher than the level of residential customer shopping (RESA St. No. 2-SR at 7), is simply wrong. R.D. at 57-58. Contrary to RESA’s assertion, PECO stated that shopping among small business customers is significantly higher than that of residential customers in PECO’s service territory 39% versus 25%. PECO St. No. 2-R at 16; RESA Exh. CHK-2 at 1-2 – (PECO Responses to RESA-I-4 and RESA-I-5). In addition, PECO stated that the Commission considered and rejected RESA’s rationale relating to improving small business shopping levels when it concluded that opt-in programs should not include small commercial customers at this time. PECO M.B. at 52-53, citing at 42; R.D. IWPF Order at 58. RESA also proposed to preclude customers who already are shopping from participating in the Opt-In Program on the ground that EGSs should not face the risk of losing market share as a result of the Opt-In Program. RESA St. Nos. 2 at 18-19 & 2-SR
The only Party to object to PECO’s proposed eligibility rules for the Opt-In Program was RESA, which asserted that small business customers (i.e., those with loads of up to 25 kW) should be allowed to participate. RESA St. No. 2 at 19-20; RESA R.B. at 28, 30-32. PECO argued that RESA’s recommendation should not be adopted for two reasons. First, the small commercial customer base that RESA proposes to include is far less homogenous than PECO’s residential customer base because small commercial customers are served under different tariff rates, each with different line loss factors. PECO St. No. 2-R at 15-16. Consequently, extending the Opt-In Program to these customers would add complexity because different offers with different prices would have to be designed, solicited and marketed to different subsets of customers. PECO M.B. at 52; R.D. at 56. Second, PECO contended that RESA’s argument, that business customers should be included in the Opt-In Program because their shopping level is only slightly higher than the level of residential customer shopping (RESA St. No. 2-SR at 7), is simply wrong. R.D. at 57-58. Contrary to RESA’s assertion, PECO stated that shopping among small business customers is significantly higher than that of residential customers in PECO’s service territory – 39% versus 25%. PECO St. No. 2-R at 16; RESA Exh. CHK-2 at 1-2 (PECO Responses to RESA-I-4 and RESA-I-5). In addition, PECO stated that the Commission considered and rejected RESA’s rationale relating to improving small business shopping levels when it concluded that opt-in programs should not include small commercial customers at this time. PECO M.B. at 52-53, citing IWPF Order at 42; R.D. at 58. RESA also proposed to preclude customers who already are shopping from participating in the Opt-In Program on the ground that EGSs should not face the risk of losing market share as a result of the Opt-In Program. RESA St. Nos. 2 at 18-19 & 2-SR
1194942.docx