Duquesne Light Company's Default Service Plan

GEN 00001

Question: Do you anticipate any changes in Black Start revenue requirements for the Duquesne service zone?

Answer: Duquesne Light advises potential wholesale suppliers to review all the projected billing line items that will be the responsibility of the supplier.  The Company wants to ensure the projected Black Start zonal revenue requirements for the Duquesne Light zone are considered in any 1 and 2 year offers being made by a supplier.    

GEN 00002

Question: Could you please clarify: if a qualified bidder is currently not serving any small commercial load, are they eligible to bid on a total of 4 small commercial blocks in the March 2017 auction? They would not exceed 50% load share in this case.

Answer: The load cap for Small C&I is 2 tranches.  No bidder can bid on or win more than 2 tranches of the Small C&I products.  Some bidders may have additional restrictions depending on the load currently served.

GEN 00003

Question: What is the Reactive Supply Requirement for Duequesne Zone?

Answer: Please refer to the PJM OATT Schedule 2, Manual 27, Section 3 for more information on the billing Charges and Credits.  The PJM website titled "Billing, Settlements, and Credits" is also a helpful too.

PJM state of the market report, section 10, has some aggregate and DLC specific information.

http://www.monitoringanalytics.com/reports/PJM_State_of_the_Market/2016/2016-som-pjm-volume2-sec10.pdf

GEN 00004

Question: Can you give us the ARR paths that were selected for the ARR nomination at PJM.

Answer:

Stage 2 Round 2 of the 2017/2018 Annual ARR Allocation opened today on Monday, March 20, 2017, and will close at 1700 on Tuesday, March 21, 2017.  The results will not be available until 1700 on Friday, March 24, 2017. 

GEN 00005

Question: Do you know of any Municipal Aggregation activity going on in the Duquesne Zone?

Answer: There are no Municipal Aggregation activities that will impact any of the default service load.

GEN 00006

Question: News media outlets have reported that Pennsylvania regulators are considering a change in the PA Solar RPS that would prohibit the use of out-of-state projects to meet new, aggressive solar targets. Can you explain whether these changes may be adopted without legislation, and whether any resulting change in the price or quantity of required SRECs would be borne by suppliers?

Answer: Duquesne cannot speculate on pending legislative action.  Any requirement that changes the price or quantity of SRECs would be borne by the suppliers.

GEN 00007

Question: Can you clarify how code 1952, Deferred Tax Adjustment, is a charge is handled between the EDU and the Default Service Supplier? It appears that Accumulated Deferred Income Tax is currently collected by Duquesne as part of the Distribution System Improvement Charge.

Answer: The wholesale providers that serve load will not see the Deferred Tax Adjustments on the PJM invoice. That line item is not assigned to wholesale suppliers that are serving load and it will not appear on their PJM invoice.  From a POLR or default service, perspective, Duquesne Light remains the LSE. Duquesne procures the supply needed to serve customers but remains the LSE. Customers themselves are not transferred to the wholesale suppliers. As a result, Duquesne Light remains responsible for the Deferred Tax Adjustment.

GEN 00008

Question: Will Duquesne continue with the ARR selection process for this year rather than turning over the last round to winning suppliers?

Answer: Yes.  Duquesne Light will continue the ARR selection process and complete it throughout the term.  The results of the selections will be shared.  The ARR's will be transferred upon completion and prior to the June start. 

GEN 00009

Question: What is the impact of recent changes in Duquesne's reactive service charges?

Answer: In the past, Duquesne Light's POLR providers were charged a PJM average tariff related to reactive supply.  Effective March 2018, the reactive costs align the charges more closely with actual costs in Duquesne's territory.  The current reactive costs are lower than they had been when it was a system wide average cost.  Please refer to the PJM Website for more information on reactive charges.

GEN 00010

Question: FERC issued an order on EL05-121 that impacts charges and credits to certain billing line items from PJM. What will the impact be for POLR suppliers?

Answer: This order will result in changes to PJM line items 1108 and 1115. However, Duquesne suppliers will not see any of these changes on tehir invoices from PJM related to their supplire share of Duquesne's POLR load.  All EL05-121 related credits and charges are internal to Duquesne Light since they are considered transmission related.

GEN 00011

Question: Will there be any AEC credits provided for the December 2018 MC&I Auction?

Answer: AEC credits will not be provided by Duquesne Light Company for the December 2018 MC&I Auction.  Duquesne Light Company will request suppliers transfer their AEC requirements in accordance with the schedule in item (2) of Appendix E - DS Supplier's Obligations for AEPS Compliance of the Supply Master Agreement.

GEN 00012

Question: Can you detail the math employed to transform PJM Settlement-level load to Retail-level load as used in the calculation of a supplier's AEC requirement? As I understand the matter, Retail-level load can be calculated as (PJM Settlement-level load) / (1- Deration Factor) / (1+ Distribution Loss Factor + Transmission Loss Factor). Can you confirm?

Answer: Duquesne calculates the retail load using the settlement load without a deration factor applied minus the line losses and UFE.

GEN 00013

Question: Notice to participants regarding the reclassification of C&I customers starting with the June 1, 2019 delivery period:

Answer: On May 2, 2016, Duquesne Light Company filed a petition for approval of their DSP-VIII Default Service Program with the Pennsylvania Public Utility Commission under Docket No. P-2016-2543140. The approved DSP-VIII included a provision that set the threshold for customers to qualify under the hourly priced product (Large C&I) at 300 kW. That threshold was set to decline from 300 to 200 kW starting with the June 1, 2019 delivery period. As a result, certain customers qualifying under the lower threshold will be classified as Large C&I starting with the March 2019 supply auction. Reclassified customers taking service as Large C&I will continue to take service under the same distribution rate class as they did when classified as Medium C&I customers.

GEN 00015

Question: Can you give us the ARR paths, associated with Medium C& I, that were awarded by PJM for PY 19/20?

Answer: All ARRs are awarded by zone or aggregate (e.g. sinking in a zone/aggregate), so it is not possible to tell the load a specific path is associated with beyond a zonal or aggregate level.

GEN 00016

Question: For DSP-VIII, Default Service Load will be divided into identical units called tranches, each representing a defined percentage of Default Service Load. For example, if there are 25 tranches for a given customer class, then each tranche equals 1/25 = 0.04 = 4%, or four percent of that class’s load. For the March 2020 Auction. There are 12 Tranches of Residential available that make up 25% of the total load. Using the example above 1 tranche would equal 1/12 = .0833 or 8.33%. However, since this only represents 25% of the total load. the total number of tranches would be 48, so it would be 1/48 which equal .0208 or 2.08. Which is the correct answer?

Answer: 25% of the load correspond to 12 tranches, so 1 tranche is (25%)/12 = 2.0833% of the load. 

The load is divided in 48 tranches, so each tranche is (100%)/48 = 2.0833% of the load.

GEN 00017

Question: Is there something wrong with the 2019 SCI historical data (POLR + EGS)? When you compare it all the historical years it is the highest. For example, Jan 2019 is the higher than Jan 2011, Jan 2012, Jan 2013, Jan 2014, Jan 2015, Jan 2016, Jan 2017 and Jan 2018. Same goes for February 2019, March 2019, April 2019, May 2019, June 2019, July 2019, August 2019, Sept 2019 and Oct 2019. And it is higher than any other historcal year by 10% to 20%

Answer: The observed pattern is most likely the result of rate class changes for accounts that occur at the beginning of the year.  

GEN 00022

Question: In the current Historic PLC – NSPL Data - Large C&I file, can you clarify which loads are served under the Large Commercial and Industrial Class Hourly Price Transaction? In some classes, the POLR PLC (5CP MW-DAY) and NSPL (1CP MW-DAY) values are considerably larger than the historical load data. As an example, the HVPS value starting 10/31/2019 is 32.4 MW, while the load maxes out at 0.4 MW on February 9, 2020. For all other classes, the PLC and NSPL values are somewhat comparable to usage. If the PLC data is correct, then is the hourly load data in the Hourly Loads 2015-2019 - Large C&I (HPS) file incorrect?

Answer: HVPS POLR had only one customer with usage in February 2020. This POLR customer had the HVPS rate class assigned to them based on anticipated future usage and was a relatively new account. The HVPS 5CP and 1CP cited for October 2019  was calculated for usage in June 2018 to Sep 2018 when there were more POLR customers on HVPS. HVPS is very volatile.

GEN 00023

Question: On slide 11 of the Bidder Information Session presentation, you state that "There are ongoing discussions at the PA Commission related to PA Act 40 and that may affect the solar SREC requirements for suppliers." Could you please clarify what the nature of these discussions are? Is this with respect to Senate Bill 600, which was introduced in the Pennsylvania General Assembly in 2019?

Answer: The Final Implementation Order for Act 40 was adopted April 19, 2018 and is available at http://www.puc.state.pa.us/pcdocs/1565100.docx.

There were a few suppliers who filed petitions for reconsideration in regards to the Act 40 Final Implementation Order. However, the Commission issued an Order August 2, 2018 regarding those petitions (http://www.puc.state.pa.us/pcdocs/1579428.doc). DLC  is not aware of outstanding issues related to Act 40.

GEN 00024

Question: Does the definition of PLC vary across the MCI and SCI customers? I've noticed that, in the context of the January reclassification between SCI and MCI customers, the eligible counts seem to be moved from one customer class to another, but the PLCs don't. They can be very different. For example, from Dec 19 to Jan 20, eligible counts for SCI change +1,936, while MCI -2,010, which is very close. However, for the same period, the change in eligible PLC for SCI was +7.66 MW while for MCI it was -2.82 MW. Does the PLC definition play a role in here?

Answer: The NSPL changes on 1/1 but the PLC identified by PJM changes on 6/1.  DLC will does a re-analysis of the customer classes in Q4 every year and changes the rate class identity of customers that do not meet the defined kW value of their class (IE: Customer was a MD C&I last year but are now S C&I reclassified on 1/1 because their total demand was not high enough to meet the M C&I classification) .  What the supplier is seeing is the shift that can take place when customers are re-allocated.  But the PLC value for the customers is not changed until 6/1.

GEN 00025

Question: In our review of the initial summer load data and Coincident Peaks to-date, we note that the Residential default service load averaged 900MW during the Coincident Peak periods. This volume is approximately 10% higher than the average of the previous three years, after adjusting for number of customers. Does the utility have any plans to address and account for this unique peak shift in their PLC calculation methodology in order to mitigate the impacts to Residential customer bills?

Answer: DLC does not anticipate mitigating the impact to the Residential customers’ bills to reflect the 10% increase.

GEN 00026

Question: In the load data you provide, there is a "lost power" column. What lost power does that include? Transmission loss, etc?

Answer: Lost power is the difference between system load and what DLC billed to customers.

GEN 00027

Question: What is the reason behind change in the Total 5CP MW-DAY , 1CP MW-DAY each month. Shouldn't that be the same for a class of customers each month?

Answer: The Total 5CP MW-DAY and 1CP MW-DAY change month to month due to changes in the customer counts and migration between customers across rate classes.  The bulk of the change happens in January for 1CP and in June for 5CP. 

GEN 00029

Question: If Alternative Energy Portfolio Requirements change such that there are new Tiers or Classes of Alternative Energy Credits other than Solar, Tier 1 and Tier 2, will suppliers or Duquesne be responsible for those Alternative Energy Credits?

Answer: The Supplier is responsible for any changes or modifications to the AEPS requirements. This would include any new tiers or classes of credits. As noted in Appendix E of the SMA, “If Alternative Energy Portfolio Requirements change by law or any other reason, DS Supplier shall be responsible for providing the credits at its expense in order to comply with its obligations under Full Requirements Service."