PECO~Legal J)epaJ1m.:nt2.\(11 ;\lnrkct Street I S23-1I'hilaJdphia. PA 1'1103

Direct Dial: 215-X-II·597-1Email: Craig \\ ilhanb!! C\e!llncllrp.nlnl

March 13,2020

VIA OVERNIGHT DELIVERY

Rosemary Chiavetta, SecretaryPennsylvania Public Utility CommissionCommonwealth Keystone Building400 North StreetHarrisburg, PA 17105-3265

Re: Petition of PECO Energy Company for Approval of Its Default ServiceProgram for the Period from June 1,2021 through May 31, 2025Docket No. P-2020-

Dear Secretary Chiavetta:

Enclosed for filing is the original unbound copy of the Petition of PECO Energy Companyfor Approval of Its Default Service Plan for the Period from June 1,2021 through May 31,2025 ("DSP V Petition") with accompanying Direct Testimony and Exhibits. A CD containingsearchable PDFs of the filing contents is also included.

A CD containing the DSP V Petition, Direct Testimony and Exhibits is also being served uponthe persons and in the manner indicated on the Attached Certificate of Service. Hard copies ofthe filing are also being provided to the Office of Consumer Advocate, Office of Small BusinessAdvocate, Bureau of Investigation & Enforcement, PJM Interconnection, LLC., and hardcopies will be made available to those receiving the CD upon request.

PECO respectfully requests that notice of the filing of the DSP V Petition and a date ofintervention be published in the March 21, 2020 issue of the Pennsylvania Bulletin.

Rosemary Chiavetta, SecretaryMarch 13, 2020Page 2

If you have any questions, please do not hesitate to contact me directly at 215-841-5974.

Very truly yours,

~'L-w. Crai~il1iamS

Enclosures

c: Per Certificate of Service (w/encls.)The Honorable Gladys Brown Dutrieuille, Chairman (w/encls.)The Honorable David W. Sweet (Vice Chairman) (w/encls.)The Honorable John F. Coleman, Jf., Commissioner (w/encls.)The Honorable Andrew G. Place, Commissioner (w/enc1s.)The Honorable Ralph V. Yanora, Commissioner (w/encls.)Cheryl Walker-Davis, Director, Office of Special Assistants (w/enc1s.)Paul T. Diskin, Director, Bureau of Technical Utility Services (w/enc1s.)

DB1/ 112774217.1

BEFORE THEPENNSYLVANIA PUBLIC UTILITY COMMISSION

PETITION OF PECO ENERGYCOMPANY FOR APPROVAL OF ITSDEFAULT SERVICE PROGRAM FORTHE PERIOD FROM JUNE 1,2021THROUGH MAY 31, 2025

Docket No. P-2020-

CERTIFICATE OF SERVICE

I hereby certify and affirm that I have this day served a copy of the Petition of

PECO Energy Company for Approval of Its Default Service Program for the Periodfrom June 1,2021 through May 31, 2025 on the following persons in the matter

specified in accordance with the requirements of 52 Pa. Code § 1.54:

BY OVERNIGHT MAIL

Tanya 1. McCloskeyActing Consumer AdvocateOffice of Consumer Advocate555 Walnut Street5th Floor, Forum PlaceHarrisburg, PAl 7101-1923

John EvansSmall Business AdvocateCommonwealth of PennsylvaniaOffice of Small Business AdvocateForum Place555 Walnut Street, First FloorHarrisburg, PA 17101

Richard KanaskieDirector & Chief ProsecutorBureau of Investigation & EnforcementPennsylvania Public Utility CommissionCommerce Keystone Building400 North Street, 2nd FloorHarrisburg, PA 17105-3265

BY FIRST CLASS MAIL

Christopher O'HaraVice President, General Counsel,Law & Chief Compliance OfficerPJM Interconnection2750 Monroe BoulevardAudubon, PA 19403-2497

Elizabeth R. MarxPennsylvania Utility Law Project118 Locust StreetHarrisburg, PAl 710 1Counsellor CA USE-PA

*Charis MincavageMcNees, Wallace & Nurick LLC100 Pine StreetHarrisburg,PA 17108-1166Counsellor PAIEUG

*CD only

*Deanne M. O'DellEckert, Seamans, Cherin & Mellott, LLC213 Market Street, 8th FloorHarrisburg, PAl 7101Counsellor RESA

2

BY FIRST CLASS MAIL

*ELECTRIC GENERATION SUPPLIERS

Accenture LLP 161 North Clark Street Suite 2300 Chicago, IL 60601

Acclaim Energy LTD d/b/a Acclaim Energy Advisors Two Riverway, Suite 800 Houston, TX 77056

Achieve Energy Solutions LLC 4550 Lena Drive Mechanicsburg, PA 17055

ADL High Voltage, Inc. P.O. Box 1569 Keller, TX 76244-1596

Advantage Energy Partners, LLC 2009 Mackenzie Way, Suite 100 Cranberry Twp., PA 16066

Adveen Energy LLC 56 Price Road Presto, PA 15142

Advisors Energy Group LLC P.O. Box 3108 Linden, NJ 07036

Aegean Energy Advisors LLC P.O. Box 770464 Woodside, NY 11377

AEP Energy Inc. 1 Easton Oval, Suite 200 Columbus, OH 43219

Affiliated Power Purchasers International, LLC 112 East Market Street Salisbury, MD 21801

Affinity Energy Management, LLC 220 Cherry Blossom Place Hockessin, DE 19707

Agera Energy, LLC 555 Pleasantville Road, Suite 107-S Briarcliff Manor, NY 10510

Aggressive Energy, LLC 78 Rapelye Street Brooklyn, NY 11231

AGR Group Nevada, LLC 6275 South Pearl Street, Suite 100 Las Vegas, NV 89120-6274

Agway Energy Services, LLC 5793 Widewaters Parkway Syracuse, NY 13214

Albireo Energy, LLC 625 Main Street Avoca, PA 18641

Alfa Energy, LLC 440 North Wells, Suite 640 Chicago, IL 60654

All American Power and Gas PA LLC d/b/a AAP&G 25166 Marion Avenue, Suite 113 Punta Gorda, FL 33950

Alpha Gas & Electric, LLC 971 Route 45, Suite 202 Pomona, NY 10970

*CD only

AlphaBuyer Inc. 1 South Bacton Hill Road, Unit #1 Malvern, PA 19355

3

Alternative Esco LLC 24 Furnace Street Ext., Suite 1E015 McKees Rocks, PA 15136

Alternative Utility Services, Inc. 750 Veterans Parkway, Suite 104 P.O. Box 250 Lake Geneva, WI 53147

Ambit Northeast LLC d/b/a Ambit Energy 6555 Sierra Drive Irving, TX 75039

Amerex Brokers, LLC 1 Sugar Creek Center Boulevard Suite 700 Sugar Land, TX 77478

America Approved Commercial LLC 13451 McGregor Boulevard, Unit 29 Fort Myers, FL 33919

American Power & Gas of Pennsylvania LLC 10601 Belcher Road South Seminole, FL 33777

American PowerNet Management LP 45 Commerce Drive Reading, PA 19601-1038

AOBA Alliance, Inc. 1025 Connecticut Avenue, North West Suite 1005 Washington, DC 20036

AP Gas & Electric (PA), LLC, d/b/a APG&E 6161 Savoy Drive, Suite 500 Houston, TX 77036

Apollo Edison, LLC 310 Nottingham Drive Spring City, PA 19475

Applied Energy Partners, LLC 1 North White Horse Pike Hammonton, NJ 08037

Arcadia Power, Inc. 1121 14th Street, North West 3rd Floor Washington, DC 20005

Arcelormittal USA, LLC 3300 Dickey Road East Chicago, IN 46312

Aspen Energy Corporation 4789 Rings Road, Suite 100 Dublin, OH 43017

Astral Energy LLC 580 Sylvan Avenue, Suite 2J Englewood Cliffs, NJ 07632

Atlantic Energy MD LLC d/b/a Atlantic Energy 4709 30th Street, Suite 400 Long Island City, NY 11101

Atlas Commodities II Retail Energy LLC d/b/a Atlas 3900 Essex Lane, Suite 775 Houston, TX 77027

AUI Associates Inc. 1122 Nottingham Drive West Chester, PA 19380-4055

4

Aurora Energy Advisors LLC 3848 Nostrand Avenue Brooklyn, NY 11235

Avalon Energy Services, LLC P.O. Box 220 Galena, MD 20814

Avangrid Renewables LLC 1125 North West Couch Street Suite 700 Portland, OR 97209

AvidXchange, Inc. 1210 AvidXchange Lance Charlotte, NC 28206

Avion Energy Group, LLC 2654 Lake Park Bend Acworth, GA 30101

Benchmark Services Inc. 308 Maltbie Street, Suite 102 Syracuse, NY 13204

Berkshire Energy Partners, LLC 9 Berkshire Road Landenberg, PA 19350

Best Practice Energy, LLC 24 Salt Pond Road, Unit H-3 Wakefield, RI 02879

BidURenergy, Inc. 4455 Genesee Street, Building 6 Buffalo, NY 14225

Big Bang Energy Group, LLC 26 California Drive Jackson, NJ 08527

Black Diamond Energy Consultants, Inc. 246 South Oak Street Mt. Carmel, PA 17851

Blitz Ventures Inc. d/b/a EnergyBot 1240 Rosecrans Avenue Suite 600 Manhattan Beach, CA 90266

Blue Line Marketing LLC d/b/a Blueline Energy 700 Commerce Drive, Suite 500 Oak Brook, IL 60523

Blue Sky Power LLC 21 Tanner Street, Suite 103 Haddonfield, NJ 08033

Bollinger Energy Corporation 11560 Crossroads Circle, Suite 100 Middle River, MD 21220

Borough of Columbia 308 Locust Street Columbia, PA 17512

Brice Associates, LLC 477 Cafferty Road Erwinna, PA 18920

Broadleaf, LLC 500 Woodberry Way Chester Springs, PA 19425

Broadway Energy Solutions, Inc. 124 Arnold Avenue Scranton, PA 18505

Broker Online Exchange LLC 400 Rella Boulevard, Suite 160 Suffern, NY 10901

5

Brookfield Renewable Energy Marketing US LLC 41 Victoria Street Zip code J8X 2A1 Gatineau, Quebec

Burton Energy Group, Inc. 11675 Great Oaks Way, Suite 350 Alpharetta, GA 30022

C Group Energy Services, LLC P.O. Box 69 118 Lakeview Trail Conyngham, PA 18219

C.I.S. Energy LLC 541 Willow Valley Drive O’Fallon, MO 63366

CA Group USA Inc. 1055 Virginia Drive, Suite 101 Fort Washington, PA 19034

Calpine Energy Solutions, LLC 401 West A Street, Suite 500 San Diego, CA 92101-3017

Capital Energy PA LLC d/b/a Sunrise Power & Gas 1770 St. James Place, Suite 606 Houston, TX 77056

Capital Energy, Inc. 125 Maiden Lane, Suite 3C New York, NY 10038

CBRE, Inc. 321 North Clark Street, Suite 3400 Chicago, IL 60654

CCES, LLC d/b/a Clean Currents 8403 Colesville Road, Suite 310 Silver Spring, MD 20910

Central Energy-North East, LLC 1150 First Avenue, Suite 501 King of Prussia, PA 19406

Champion Energy Services LLC 1500 Rankin Road, Suite 200 Houston, TX 77073-4807

Charity+Power, Inc. 2801 Belden Drive Los Angeles, CA 90068

Choice Energy Services, Retail 5151 San Felipe Street, Suite 2200 Houston, TX 77056-3726

Choice Energy LLC d/b/a 4 Choice Energy LLC 601 South West 9th Street, Suite F Des Moines, IA 50309-4528

Chrislynn Energy Services, Inc. 3416 Babcock Boulevard Pittsburgh, PA 15237

Choose Energy Inc. 1101 Red Ventures Drive Fort Mill, SC 29707

CleanChoice Energy, Inc. 1055 Thomas Jefferson Street Suite 650 Washington, DC 20007

Cima Energy Solutions LLC 100 Waugh Drive, Suite 100 Houston, TX 77007

Clearview Electric, Inc. 901 Main Street, Suite 4700 Dallas, TX 75202

6

Clear Energy Solutions LLC 34192 Spring Brook Avenue Lewes, DE 19958

Commercial Utility Consultants, Inc. 1556 McDaniel Drive West Chester, PA 19380

Click Energy LLC d/b/a Smart Touch Energy 413 Norway Street York, PA 17403

Community Energy, Inc. Three Radnor Corporate Center Suite 300 Radnor, PA 19087

Community Energy Advisors LLC 3725 Medina Road, Suite 112 Medina, OH 44256

Concord Engineering Group, Inc. 520 South Burnt Mill Road Voorhees, NJ 08043

Competitive Energy Services LLC 148 Middle Street, Suite 500 Portland, ME 04101

ConocoPhillips Company 600 North Dairy-Ashford Drive Suite CH-1081 Houston, TX 77079

Connect Energy Resources, LLC 11 Settlement Road Amston, CT 06231

Constellation NewEnergy Inc. 1310 Point Street, 8th Floor Baltimore, MD 21231

Constellation Energy Services, Inc. 700 North Adams Street Green Bay, WI 54301-5144

Convenient Ventures LLC d/b/a Energy Objective 415 Norway Street York, PA 17403

Consumer Energy Solutions, Inc. P.O. Box 2454 Clearwater, FL 33757-2454

CQI Associates, LLC 10729-B Birmingham Way Woodstock, MD 21163

Cost Control Associates, Inc. 310 Bay Road Queensbury, NY 12804

CSD Energy Advisors LLC 2407 Oaks Forks Drive Kingswood, TX 77339

Crimson Power Solutions LLC 110 State Road, Suite 8 Sagamore Beach, MA 02562

Curvin W Martin 322 Hatchery Road Dalmatia, PA 17017

Curago Energy LLC d/b/a Curago Energy 8526 Pitlochry Court Dublin, OH 43017

Definitive Energy Group, Inc. 1375 Hyland Drive Evergreen, CO 80439

7

Daniel J Reith LLC 2 South Hartford Avenue B4 Atlantic City, NJ 08401

Direct Energy Business Marketing LLC 985 Berkshire Boulevard Wyomissing, PA 19609

Destination Energy LLC 309 North Oak Street. Roanoke, TX 76262

Direct Energy Services, LLC Eckert Seamans 213 Market Street, 8th Floor Harrisburg, PA 17101

Direct Energy Business, LLC 1001 Liberty Avenue, Suite 1200 Pittsburgh, PA 15222

Diversegy, LLC 520 Broad Street Newark, NJ 07102

Discount Power, Inc. 6 Armstrong Road Shelton, CT 06484

Dynamis Energy, LLC d/b/a United Energy Services 7328 West University Avenue Suite C Gainsville, FL 32607

Duquesne Light Energy, LLC 411 Seventh Avenue, 15-2 Pittsburgh, PA 15219

Early Bird Power, LLC 1 Adams Street Milton, MA 02186

Dynegy Energy Services (East), LLC d/b/a Dynegy 6555 Sierra Drive Irving, TX 75039

Ecom-Energy of California, Inc. 5322 Vista Montana Yorba Linda, CA 92886

East Coast Power & Gas 340 Jackson Avenue Bronx, NY 10454

Edge Insights, Inc. 3 Park Plaza Wyomissing, PA 19610

EDF Energy Services, LLC 601 Travis Street, Suite 1700 Houston, TX 77002

EGS Advanced Energy Solutions, Inc. 343 North Main Street, Suite 105 Canandaigua, NY 14424

EGP Energy Solutions, LLC d/b/a Atlantic Energy Re 300 East Lombard Street Suite 840 Baltimore, MD 21202

Electricity Ratings, LLC 1502 Sawyer Street, Suite 130 Houston, TX 77007

Electric Advisors, Inc. 5272 River Road, Suite 440 Bethesda, MD 20814

Elite Energy Group Inc. 199 Jericho Turnpike Second Floor Floral Park, NY 11001

8

Eligo Energy PA LLC 201 West Lake Street, Suite 151 Chicago, IL 60606

Emex LLC 11011 Richmond Avenue Suite 500 Houston, TX 77042

Elite Energy Solutions LLC 14100 US Highway 19 N, Suite 132 Clearwater, FL 33764

Employers' Energy Alliance of Pennsylvania Inc. 2171 West 38th Street Erie, PA 16508

Enel X North America Inc. 1 Marina Park Drive, Suite 400 Boston, MA 02210

EnerConnex, LLC 44 Portland Street, 4th Floor Worcester, MA 01608

Energy Advisory Service, LLC 9300 John Hickman Parkway, Suite 902 Frisco, TX 75035-5892

Energy Auction Exchange LLC 893 West Baxer Drive South Jordan, UT 84095

Energy Auction House Inc. 44 Route 6A Sandwich, MA 02563

Energy Choice Solutions LLC d/b/a EnergyWize LLC 400 Chisholm Place, Suite 411 Plano, TX 75075-6911

Energy Consultants, LLC 209 Plymouth Avenue West Berlin, NJ 08091

Energy Cooperative Assoc. of Pa – The Energy Co-op 1315 Walnut Street, Suite 1000 Philadelphia, PA 19107

Energy Cooperative of America Inc. 1408 Sweet Home Road, Suite 8 Amherst, NY 14228

Energy CX, LLC 3501 Woodhead Drive #5 Northbroook, IL 60062

Energy Deals LLC 33648 St. Francis Drive Avon, OH 44011

Energy Edge Consulting, LLC 9601 Katy Freeway, Suite 450 Houston, TX 77024-1394

Energy Enablement, LLC Foster Plaza 5 615 Holiday Drive, Suite 300 Pittsburgh, PA 15220

Energy For A Cause Inc. 3504 Beaumont Loup Spring Hill, FL 34609

Energy Initiatives, Inc. P.O. Box 479 Chester Heights, PA 19017

Energy Link I LLC 1000 Parkwood Circle, Suite 900 Atlanta, GA 30339

9

Energy Paradigm LLC 6533 Virginia Square Arlington, TX 76017

Energy Procurement Partners, Inc. 4 White Fawn Lane Pittsburgh, PA 15238

Energy Plus Holdings, LLC 3711 Market Street, Suite 910 Philadelphia, PA 19104

Energy Savers Inc. 306 McKnight Park Drive Pittsburgh, PA 15237-6534

Energy Professionals, LLC 1315 Cleveland Street Clearwater, FL 33755

Energy Solutions USA, Inc. 99 West McCanns Boulevard Elmira Heights, NY 14903

Energy Services Providers Inc. d/b/a PA Gas & Electric 535 Connecticut Avenue, 6th Floor Norwalk, CT 06854

Energy Trust, LLC P.O. Box 29914 Baltimore, MD 21230

Energy Transfer Retail Power, LLC 100 North 10th Street Harrisburg, PA 17105

EnerPenn USA, LLC d/b/a Y.E.P. d/b/a YEP Energy 7660 Woodway Drive, Suite 471A Houston, TX 77063

Energy.Me Midwest LLC 555 Pleasantville Road, Suite 109 Briarcliff Manor, NY 10510

ENGIE Resources, LLC 1990 Post Oak Boulevard Suite 1900 Houston, TX 77056

ENGIE Insight Services Inc. 1313 North Atlantic Street, Suite 5000 Spokane, WA 99201

Entrust Energy 1301 McKinney, Suite 1200 Houston, TX 77010

ENGIE Retail, LLC d/b/a Think Energy 1990 Post Oak Boulevard Suite 1900 Houston, TX 77056

Erie Energy Partners LLC 3931 Parkside Avenue Erie, PA 16508

Entrust Energy East, Inc. 1301 McKinney Suite 1200 Houston, TX 77010

Evolution Energy Partners LLC 1 East Uwchlan Avenue, #312 Exton, PA 19341

Everyday Energy, LLC d/b/a Energy Rewards 6555 Sierra Drive Irving, TX 75039

F&P Holdings, LP 1700 North Highland Road Suite 402 Pittsburgh, PA 15241

10

EZ Energy Services LLC 199 Lee Avenue, Suite 317 Brooklyn, NY 11211

FCStone LLC 1075 Jordan Creek Parkway Suite 300 West Des Moines, IA 50266

Fair View Energy Inc. 7782 West Ridge Road Fairview, PA 16415

Finance Guru LLC 525 West Monroe, Suite 900 Chicago, IL 60661

First Point Power, LLC 300 Jefferson Boulevard Suite 104 Warwick, RI 02888

FirstEnergy Solutions Corp. 341 White Pond Drive, B3 Akron, OH 44320

First Point Power, LLC 300 Jefferson Boulevard Suite 104 Warwick, RI 02888

Freepoint Energy Solutions, LLC 3050 Post Pak Boulevard, Suite 1330 Houston, TX 77056

Freedom Logistics LLC 5 Dartmouth Drive, Suite 301 Auburn, NH 03032

Frontier Utilities Northeast, LLC 5444 Westheimer, Suite 1100 Houston, TX 77056

Front Line Power Solutions, LLC 251 Thames Street Bristol, RI 02809

Gateway Energy Services Corporation 12 Greenway Plaza, Suite 205 Houston, TX 77046

FS Energy LLC 622 Third Avenue, Floor 14 New York, NY 10017

Global Vision Energy, LLC 1738 Creekview Drive Fogelsville, PA 18051

Global Energy LLC d/b/a Global Energy E&G LLC 5 Penn Plaza, 23rd Floor New York, NY 10001

Global Energy Solutions Corp. 675 Featherbed Lane Garnet Valley, PA 19060

Goldstar Energy Group, Inc. 5429 Harding Highway Building 500 Mays Landing, NJ 08330

Green Mountain Energy Company 3711 Market Street, Suite 1000 Philadelphia, PA 19104

Gold Star Energy LLC 140 Grand Street, Suite 300 White Plains, NY 10601

Greenstar Solutions, LLC 2188 Jenna Court Bethlehem, PA 18020

11

Great American Power LLC 2633 McKinney Avenue Suite 130 Dallas, TX 75204

Groundswell, Inc. 1156 15th Street North West Suite 840 Washington, DC 20005

Greenlight Energy, Inc. 108-18 Queens Boulevard Suite 401 Forest Hills, NY 11375

H.P. Technologies, Inc. 33648 St. Francis Drive Avon, OH 44011

Grid Energy LLC d/b/a Distributed Grid 1010 Oella Avenue Ellicott City, MD 21043

Health Resource Network, Inc. d/b/a HRNEnergy 201 Columbia Turnpike, Suite D Florham Park, NJ 07932

Gulf Stream Energy Consultants LLC 1225 South Myrtle Avenue Clearwater, FL 33756

Hiko Energy, LLC 12 College Road Monsey, NY 10952

HB Hayes & Assoc., LLC d/b/a Alternative Energy Source 8225 Farnsworth Road, Suite A-10 Waterville, OH 43566

Hospital Energy, LLC 7 Portwalk Place #1523 Portsmouth, NH 03801

HealthTrust Purchasing Group, LP 155 Franklin Road, Suite 400 Brentwood, TN 37027

Hudson Energy Services LLC 6345 Dixie Road, Suite 200 Mississauga, ON L5T 2E6

Homeade, LLC d/b/a Zentility 3111 Riverwalk Drive Annapolis, MD 21043

Hovey Energy, LLC 140 Grant Street, Suite 300 White Plains, NY 10601

Independence Energy Group, LLC d/b/a Cirro Energy 3711 Market Street, Suite 1000 Philadelphia, PA 19104

Inertia Resources, Inc. 361 Newbury Street, 5th Floor Boston, MA 02115

IDT Energy, Inc. 315 North Main Street, Suite 300 Jamestown, NY 14701-5124

Inspire Energy Holdings, LLC 30 South 15th Street #1400 Philadelphia, PA 19120

Independent Energy Consultants, Inc. 215 West Garfield, Suite 210 Aurora, OH 44202

Integrity Comm. of OH, LLC d/b/a Integrity Energy 5711 Grant Avenue Cleveland, OH 44105

12

Infinity Power Partners, LLC 2603 Augusta Drive, Suite 450 Houston, TX 77057

Interactive Energy Group, LLC 5251 Westheimer Road Suite 1000 Houston, TX 77056

Integrated Energy Services, LLC 450 Lexington Avenue, 4th Floor New York, NY 10017

Interstate Gas Supply d/b/a IGS Energy 1379 Butter Churn Drive Herndon, VA 20170-2051

Intelligen Resources, LP 403 Koldin Drive Aledo, TX 76008

Jack Rich, Inc. d/b/a Anthracite Power and Light 617 Altamont Boulevard Frackville, PA 17931

Interstate Gas Marketing, Inc. 2018 South 6th Street Indiana, PA 15701

John Orr d/b/a Energy Management Services 61 Knollwood Lane New Canaan, CT 06840

J.J. Jasmahn, LTD d/b/a Jasmahn Energy 7107 Azalea Dallas, TX 75230

Just Energy Pennsylvania Corp. 6345 Dixie Road, Suite 200 Mississauga, ON L5T 2E6

JMI Consultants, LLC 2809 Wehrle Drive, Suite 9 Williamsville, NY 14221

Josco Energy USA, LLC 200 Route 17 South, Suite 200C Mahwah, NJ 07430

Kevin J Cobb & Assoc. d/b/a Quest Energy Solutions 203 Southbridge Street Auburn, MA 01501

Keytex Energy Solutions, LLC 200 Brush Run Road, Suite C Greensburg, PA 15601

Just Energy Solutions, Inc. d/b/a Just Energy 5251 Westheimer Road Suite 1000 Houston, TX 77056-5414

Kinetic Energy Associates, LLC 100 North 10th Street Harrisburg, PA 17101

Key Energy Consulting LLC 950 Union Meeting Road Blue Bell, PA 19422

KWH Savings, LLC 5693 West Howard Street Niles, IL 60714

13

Kinect Energy, Inc. 500 Cherrington Parkway Suite 400 Moon Township, PA 15108

Lakepoint Energy LLC 140 Grant Street, Suite 300 White Plains, NY 10601

Kobiona LLC 67 West Main Street, Suite 412 Clinton, CT 06413

Liberty Power Holdings 2100 West Cypress Creek Road, Suite 600 Fort Lauderdale, FL 33309-1823

L5E 4545 Fuller Drive, Suite 412 Irving, TX 75038

Lincoln Energy Group, LLC 121 West Wacker Drive Suite 1400 Chicago, IL 60601

Liberty Power Delaware LLC 2100 West Cypress Creek Road Fort Lauderdale, FL 33309-1823

LouElla Enterprises d/b/a Enerchange Power and Gas 322 North Shore Drive, Suite 200 Pittsburgh, PA 15212

LifeEnergy, LLC 2000 West Loop South Suite 2010 Houston, TX 7702

Lower Watt, LLC 12 North Crest Place Lakewood, NJ 08701

Live Energy, Inc. 120 St. Louis Avenue Suite 133 Fort Worth, TX 76104

Lower Electric, LLC 1307 Shermer Road Northbrook, IL 60062

Luthin Associates, Inc. 535 Main Street Allenhurst, NJ 07711

MAA Inc. d/b/a Industrial Energy 175 Strafford Avenue, Suite One Wayne, PA 19087

LSC Communications US LLC 191 North Wacker Drive Suite 1400 Chicago, IL 60606

Management Services Partners LLC 28 Liberty Street, 6th Floor New York, NY 10005

M&L Service Providers LLC 134 Leonard Street Lakewood, NJ 08701

Mariellen Donohue d/b/a Avalon Energy Consultants 401 North Wawaset Road West Chester, PA 19382

14

Make The Switch USA LLC 1209 Via Visalia San Clemente, CA 92672

Maryland Energy Advisors d/b/a PointClickSwitch.com 509 South Exeter Street, Suite 320 Baltimore, MD 21202

Marathon Power LLC 6201 34th Avenue Woodside, NY 11377

Median Energy PA LLC 1 Lethbridge Plaza, Suite 2 Mahwah, NJ 07430

Marketing Systems Group, LLC d/b/a Iion Power 27 North Wacker Drive, Suite 560 Riverwoods, IL 60606

Messer Energy Services Inc. 1 Greenwich Street Stewartsville, NJ 08886

MC Squared Energy Services, LLC 175 West Jackson Boulevard Suite 240 Chicago, IL 60604

Midamerican Energy Services LLC 4299 North West Urbandale Drive Urbandale, IA 50322

Meretz Energy Group, LLC 14 North Madison Avenue Suite 206 Spring Valley, NY 10977

Mitchell Energy Management 16 Carillon Court Wilmington, DE 19803-2900

Mid Atlantic Energy Services LLC 207 5th Street Vandling, PA 18421

Mirabito Holdings, Inc. d/b/a Mirabito Energy Prod 49 Court Street P.O. Box 5306 Binghampton, NY 13902

Mondre Energy Inc. 1800 John F. Kennedy Boulevard Suite 1504 Philadelphia, PA 19103

MPower Energy NJ LLC 24 Hillel Place Brooklyn, NY 11210

Mobilenet Inc. d/b/a Smith Energy Group 1119 Sandstone Road Greensburg, PA 15601

Muirfield Energy, Inc. 425 Metro Place North Suite 550 Dublin, OH 43017

MP2 Energy NE, LLC 21 Waterway Avenue, Suite 450 The Woodlands, TX 77380-3098

My Energy Option LLC 2 Penn Center West, Suite 328 Pittsburgh, PA 15276

15

MSI Utilities, Inc. 425 Metro Place North Suite 330 Dublin, OH 43017

National Auditing d/b/a National Energy Discounter 500 Purdy Hill Road, Suite 4 Monroe, CT 06468

MVE Energy Solutions, Inc. 2010 West Main Street Ephrata, PA 17522

National Energy Cost Services Inc. 1274 49th Street Brooklyn, NY 11219

Nania Energy Incorporated 4200 Cantera Drive, Suite 219 Warrenville, IL 60555

National Power Source, LLC P.O. Box 347 Buffalo, NY 14231

National Energy Advisory, LLC 970 Lake Carillon Drive, Suite 300 St. Petersburg, FL 33716

National Utility Service, Inc. 1 Maynard Drive P.O. Box 712 Park Ridge, NJ 07656-0712

National Gas & Electric, LLC 12140 Wickchester Lane Suite 100 Houston, TX 77079

Nationwide New Energy Management Group, LLC P.O. Box 3077 McKinney, TX 75070

National Utilities Refund LLC d/b/a National Energy P.O. Box 332 Fogelsville, PA 18051

National1 Energy, LLC 101 East Park Boulevard Suite 301 Plano, TX 75074

Navigate Power LLC 2211 North Elston Avenue Suite 208 Chicago, IL 60614

New America Power LLC 41 University Drive, Suite 400 Newtown, PA 18940

Natures Current, LLC 501 Cambria Avenue Suite 389 Bensalem, PA 19020

NextEra Energy Services Pennsylvania, LLC 20455 State Highway 249, Suite 200 Houston, TX 77070

NE Energy LLC 1215 Manor Drive, Suite 202 Mechanicsburg, PA 17055

Nordic Energy Services, LLC One Tower Lane, Suite 300 Oakbrook Terrace, IL 60181

New River Group, LLC d/b/a Scioto Energy 4041 North High Street 202 Columbus, OH 43214

North American Power and Gas, LLC 20 Glover Avenue Norwalk, CT 06850

16

Nittany Energy, LLC 321 North Front Street Philipsburg, PA 16866

Novo Energy Services LLC 156 5th Avenue, Suite 1218 New York, NY 10010

Noresco, LLC 510 Thornall Street, Suite 170 Edison, NJ 08837

nTherm, LLC 1430 Larimer Street, Suite 302 Denver, CO 80202

Northeast Energy Advisors, LLC 10900 Perry Highway, #210 Pittsburgh, PA 15090

Open Market Energy LLC 7625 Wisconsin Avenue Suite 250 Bethesda, MD 20814

NRGing, LLC d/b/a NetGain Energy Advisors 6176 Grovedale Court, Suite 200 Alexandria, VA 22310

Option One Energy, LLC 321 North Clark Street, 5th Floor Chicago, IL 60654

Onix Energy LLC 580 Sylvan Ave, Suite 2J Englewood Cliffs, NJ 07632

Optimum Group, LLC d/b/a Optimum Energy Solutions 34 Ellis Court Morganville, NJ 07751

Our Energy Manager LLC 5515 North West 108th Terrace Kansas City, MO 64154

PAISBOA Services Corporation 301 Iven Avenue, Suite 315 Wayne, PA 19087

Options Consulting Services LLC 7300 International Drive, Suite 200 Holland, OH 43528

Palmer Energy Company Inc. 5577 Airport Highway Suite 101 Toledo, OH 43615

Oxford Energy Services, LLC 2350 North Forrest Road Suite 33B Getzville, NY 14068

Park Power, LLC 17 North 2nd Street 16th Floor Harrisburg, PA 17101

Palmco Power PA LLC d/b/a Indra Energy 1515 Market Street, Suite 1200 Philadelphia, PA 19102

Patriot Energy Group, Inc. 209 Burlington Road, Suite 219 Bedford, MA 01703

Papillon Productions, LLC d/b/a Electricity Club 43 Mistflower Place The Woodlands, TX 77381

PES Brokers, Inc. 1305 FM 359, Suite H Richmond, TX 77046

17

Paragon Advisors, LLC 781 Boston Post Road Box 332 Madison, CT 06443

Pilot Power Group Inc. 8910 University Center Lane Suite 520 San Diego, CA 92122

Patch Energy Services, LLC 11040 Martha Ann Court Fairfax Station, VA 22039

Pennell & Wiltberger, Inc. 165 Township Line Road Suite 2200 Jenkintown, PA 19046

Philip Harvey 525 South 4th Street Suite 240 Philadelphia, PA 19147

Planet Energy (PA) Corp. d/b/a Riterate Energy 5255 Yonge Street Suite 1500 Toronto, ON M2N 6P4

Power Brokers, LLC d/b/a PB2 Texas, LLC 12700 Park Central Drive Suite 1450 Dallas, TX 75251

Power Management Co, LLC 1600 Moseley Road, Suite 100 Victor, NY 14564

Pinnacle Power, LLC 5847 San Felipe Street, #3700 Houston, TX 77075

Premier Energy Group, LLC 1275 Bound Brook Road Suite 6 Middlesex, NJ 08846

Plymouth Rock Energy, LLC 1074 Broadway Woodmere, NY 11598

Premiere Marketing LLC, d/b/a Premiere Energy Auct 695 Route 46 West, Suite 408 Fairfield, NJ 07004-1568

Power Kiosk, LLC 350 North LaSalle Street 9th Floor Chicago, IL 60654

Progressive Energy Consultants, LLC 2009 Sunnydale Boulevard, Suite 100 Clearwater, FL 33765

Power Target LLC 211 Black Angus Court Millersville, MD 21108

Prospect Resources Inc. 8170 McCormick Boulevard Suite 107 Skokie, IL 60076

Premier Power Solutions, LLC 107 Breckenridge Street Grove City, PA 16127

Prudential Energy Services Corporation 9225 Katy Freeway, Suite 204 Houston, TX 77024

18

Priority Power Management, LLC 5012 Portico Way Midland, TX 79707-3102

Progressive Energy Organization, LLC 2112 West Galena Boulevard Suite 8210 Aurora, IL 60506

Provident Energy Consulting LLC 55 State Road - 1st Floor Media, PA 19063

PSEG Energy Solutions, LLC 80 Park Plaza T4B Newark, NJ 07102

Pure Energy USA PA, LLC d/b/a Pure Energy USA 648 Bay Street Staten Island, NY 10304

Quick Energy Solutions LLC 1975 84th Street, D8 Brooklyn, NY 11214

PRX Energy, LLC 900 State State Erie, PA 16501

Regional Resources Energy Group, LLC P.O. Box 597 Voorhees, NJ 08043

Public Power, LLC 6555 Sierra Drive Irving, TX 75039

Reliant Energy Northeast 1000 Main Street Houston, TX 77002

QFB Enterprises, Inc. d/b/a QFB Energy 4004 Hampton Lane Quincy, IL 62305

Resource Energy Solutions LLC 4 High Ridge Park, Suite 202 Stamford, CT 06905

Reflective Energy Solutions, LLC One University Plaza, Suite 407 Hackensack, NJ 07601

Respond Power LLC 100 Dutch Hill Road, Suite 100 Orangeburg, NY 10962

Reliable Power Alternatives Corporation 400 Garden City Plaza, Suite 450 Garden City, NY 11530

RJT Energy Consultants, LLC 116 Washington Avenue North Haven, CT 06473

Residents Energy 520 Broad Street Newark, NJ 07102

Robindale Retail Power Services LLC 2384 North Old Trail Road Shamokin Dam, PA 17876

Resource Energy Systems, LLC 4 High Ridge Park, Suite 202 Stamford, CT 06905

Richards' Energy Group, Inc. 781 South Chiques Road Manheim, PA 17545

19

RKB Energy Solutions, LLC 487 East Main Street, Suite #114 Mount Kisco, NY 10549

Royal Energy, Inc. 10126 Redbud Lane Lenexa, KS 66220

Rushmore Energy, LLC 54 Sugar Creek Center Boulevard Suite 200 Sugar Land, TX 77478

Sanford Energy Associates, LLC d/b/a Powervine Ene P.O. Box 476 Norwalk, CT 06586

Rosenthal Energy Advisors, Inc. 6244 Preston Creek Drive Dallas, TX 75240

Satori Enterprises, LLC d/b/a Satori Energy 300 South Wacker Drive Suite 800 Chicago, IL 60606-6670

RPA Energy, Inc. P.O. Box 1508 Huntington, NY 11743

School Power, Inc. 315 Fuller Road, Box 686 Dalton, PA 18414

Sable Power & Gas, LLC 10801 Hammerly Boulevard Suite 122 Houston, TX 77043

Secure Energy Solutions, LLC 515 Shaker Road East Longmeadow, MA 01028

Santanna Natural Gas Corp. d/b/a Santanna Energy Serv 7701 San Felipe Boulevard Suite 200 Austin, TX 78729

SFE Energy 100 Milverton Drive, Suite 608 Mississauga, Ontario, Canada L5R 4H1

Save On Energy, LLC d/b/a SaveOnEnergy.com 1101 Red Ventures Drive For Mill, SC 29707

Siemens Industry, Inc. 4401 Fair Lakes Court Fairfax, VA 22033

Search Energy LLC 1760 Hamilton Drive Bloomfield Hills, MI 48302

SmartestEnergy US LLC 333 West Washington Street Suite 140 Syracuse, NY 13202

Service King International Broker db SKI Brokerage 12 College Road, Suite 150 Monsey, NY 10952

Shipley Choice, LLC 100 Kindig Lane Hanover, PA 17331

20

SmartEnergy Holdings LLC 106 Maplewood Drive Hazleton, PA 18202

SourceOne, Inc. (DE) d/b/a SourceOne Energy, Inc. 53 State Street, 14th Floor Boston, MA 02109

South Jersey Energy Co. #1 South Jersey Plaza, Route 54 Folsom, NJ 08037

Southeast Energy Consultants, LLC 2328 US-19 Holiday, FL 34691

Solution Energy, LLC 142 Mineola Avenue, #34 Roslyn Heights, NY 11577

Sprague Energy Solutions, Inc. 185 International Drive Portsmouth, NH 03801

South Bay Energy Corp. 700 Veterans Memorial Highway, #210 Hauppauge, NY 11788

Stand Energy Corporation 1077 Celestial Street, Suite 110 Cincinnati, OH 45202-1629

South Shore Trading and Distributors, Inc. 2937 West Estes Avenue Chicago, IL 60645

Star Energy Partners 3340 West Market Street Akron, OH 44333

Spark Energy, LLC 12140 Wickchester Lane Suite 100 Houston, TX 77079

Statewise Energy Pennsylvania LLC d/b/a Statewise 608-100 Milverton Drive Mississauga, ON

Spring Energy RRH, LLC d/b/a Spring Power & Gas 111 East 14th Street, #105 New York, NY 10003

Stream Energy Pennsylvania LLC d/b/a Stream Energy 3711 Market Street, Suite 1000 Philadelphia, PA 19104

Stanwich Energy Advisors, LLC 9 Greenwich Office Park, 2nd Floor Greenwich, CT 06831

Summit Energy Svc d/b/a Summit Energy Svc of KY 10350 Ormsby Park Place Suite 400 Louisville, KY 40223

Starion Energy PA, Inc. P.O. Box 845 Middlebury, CT 06762

Sunrise Energy Support, LLC 1605 Primrose Lane Kunkletown, PA 18058

Statistical Energy LLC 4967 Countryside Road Lyndhurst, OH 44124

Susquehanna Energy Advisors Inc. 20 Street Broad Street Lititz, PA 17543

21

Summer Energy Midwest LLC d/b/a Summer Energy 5847 Sann Felipe Street Suite 3700 Houston, TX 77057

Sustainable Star, LLC 3060 Mitchellville Road Suite 216 Bowie, MD 20716-1397

Sunlight Energy Group LLC 135 East 57th Street, 6th Floor New York, NY 10022

SYR Solutions, LP 14027 Memorial Drive, #425 Houston, TX 77079

Sunwave Gas & Power Pennsylvania Inc. 100 Cambridge Street 14th Floor Boston, MA 02114

Taurus Advisory Group, LLC 27 Lawrence Road Madison, NJ 07490

Sustainable Energy Services Inc. 24700 Center Ridge Road Suite 390 Westlake, OH 44145

Tenaska Power Management LLC 1701 East Lamar Boulevard Suite 100 Arlington, TX 76006

Sycamore Insurance Agency Inc. 550 West Merrill Street Birmingham, MI 48009

Texas Retail Energy, LLC 2608 South East J Street. Bentonville, AR 72716-5530

Talen Energy Marketing, LLC 835 Hamilton Street, Suite 150 Allentown, PA 18101

TFS Energy Solutions, LLC d/b/a Tradition Energy 8 West Broad Street Stamford, CT 06902

Telco Pros, Inc. d/b/a TPI Efficiency 2020 Center Street Cleveland, OH 44113

The Eric Ryan Corporation 1 Early Street, Suite A Ellwood City, PA 16117

TES Energy Services, LP 17480 Dallas Parkway, #200 Dallas, TX 75287

Texzon Utilities, Ltd. 202 North I-35, Suite C Red Oak, TX 75154

The Energy Alliance, LLC 5 Colgate Street Closter, NJ 07624

The O.E. Group, Inc. 5314 16th Avenue, Suite 187 Brooklyn, NY 11204

Titan Energy - New England, Inc. 2275 Silas Deane Highway Rocky Hill, CT 06067

TMGES, Inc. 6580 Berrywood Lane Downers Grove, IL 60516

22

The Legacy Energy Group, LLC d/b/a Legecy Energy 58 Winchester Street Warrenton, VA 20186

Tomorrow Energy Corp. 3151 Briarpark Drive, Suite 100 Houston, TX 77042

The Pennsylvania State University 135 East Nittany Avenue, Suite 414 State College, PA 16801

Town Square Energy East LLC 3950 East Riggs Road, Suite 1 Chandler, AZ 85248

Titan Gas LLC d/b/a Titan Gas and Power 3355 West Alabama, Suite 500 Houston, TX 77098

Transparence Energy Services LLC 1440 East Fort Avenue Baltimore, MD 21230

Tobelmann Energy Brokers, Inc. 15 Kiloran Wynd Road Glenmoore, PA 19343

TriEagle Energy LP 6555 Sierra Drive Irving, TX 75039

Tomorrow's Utilities, Inc. 920 West Sproul Road, Suite 204 Springfield, PA 19064-1241

Trusted Energy, LLC 5478 Wilshire Boulevard, #303 Los Angeles, CA 90036

Trane Energy Choice, LLC 2790 Mosside Boulevard Suite 840 Monroeville, PA 15146

Tybec Energy Management Specialists Inc. 12 Royal Drive Lititz, PA 17543

Trianglenergy LLC d/b/a Bid Energy Group 2 Shenandoah Drive Lakewood, NJ 08701

TruEnergy Services, LLC 8222 Douglas Avenue Suite 200 Dallas, TX 75225

Trustees of the University of Pennsylvania 3101 Walnut Street Philadelphia, PA 19104

UGI Energy Services, LLC 835 Knitting Mills Way Wyomissing, PA 19610

Unified Energy Alliance, LLC P.O. Box 211 Arendtsville, PA 17303

United Power Consultants, Inc. 2001 North Federal Highway Suite 316 Pompano, FL 33602

U.S. Power Trade LLC 1636 North Cedar Crest Boulevard Suite 210 Allentown, PA 18104

Unity Electric Discount LLC 5040 Overbrook Avenue Philadelphia, PA 19131

23

Ultimate Energy Advisors, LLC 6922 Flint Cone Drive Dallas, TX 75248

US Energy Bidders LLC 382 Main Street East Aurora, NY 14052

Unified Energy Services, LLC 2625 Greenbriar Drive Houston, TX 77098

US Energy Solutions of NJ, Inc. 300 West Somerdale Road Suite 5 Vorhees, NJ 08043

Unitil Resources, Inc. d/b/a Usource 6 Liberty Lane West Hampton, NH 03842-1720

Usource, L.L.C. 1 Liberty Lane East, Suite 220 Hampton, NH 03842

URA Inc. a/k/a Utility Rates Analysts d/b/a SDEP 3602 Rosemont Avenue Camp Hill, PA 17011

Utility Answers, LLC 695 Route 46 West, Suite 408 Fairfield, NJ 07004

US Energy Consulting Group LLC 4711 66th Street North St. Petersburg, FL 33709

Vanguard Energy Services, LLC 850 East Diehl Road, Suite 142 Naperville, IL 60563

US Grid Energy, LLC d/b/a US Grid Wholesale 18 Abbott Road Hamilton, NJ 08690

Utilities Marketing Group, LLC 9701 International Court North Suite #A St. Petersburg, FL 33716

Utiliz LLC 175 Strafford Avenue Suite One PMB 112 Wayne, PA 19087

Verdigris Energy, LLC 1711 Bur Oak Drive Allen, TX 75002

Viridian Energy PA, LLC 655 Sierra Drive Irving, TX 75039

WattB, Inc. d/b/a WattBuy 1641 Nagle Place, Apartment 318 Seattle, WA 98122

Verde Energy USA, Inc. 12140 Wickchester Lane Suite 100 Houston, TX 77079

WGL Energy Services 8614 Westwood Center Drive Suite 1200 Vienna, VA 22182

Vervantis Inc. 1334 East Chandler Boulevard Suite #5 A-29 Phoenix, AZ 85048-6268

Worthington Energy Consult LLC 445 Hutchinson Avenue, Suite 840 Columbus, OH 43235

Vista Energy Marketing, L.P. 4306 Yoakum Boulevard Suite 600 Houston, TX 77006

Western Reserve Energy Services LLC 3867 West Market Street Suite 268 Akron, OH 44333

Winstar Solutions, LLC 6009 Mendota Drive Plano, TX 75024

Xencom Green Energy, LLC 1609 Precision Drive Plano, TX 75074

Yolon Energy LLC 1 Hartfield Boulevard, Suite 100 East Windsor, CT 06088

XOOM Energy Pennsylvania, LLC 11208 Statesville Road, Suite 200 Huntersville, NC 28078

Yes Energy Inc. 1139 Red Barn Lane Quakertown, PA 18951

Your Choice Energy, LLC 672 Litchfield Lane Dunedin, FL 34698

Yardi Systems, Inc. to East 42nd Street, Suite 2130 New York, NY 10165

/Kenneth M. Kulak (Pa. No. 75509) Anthony C. DeCusatis (Pa. No. 25700) Catherine G. Vasudevan (Pa. No. 210254) Brooke E. McGlinn (Pa. No. 204918) Morgan, Lewis & Bockius LLP 1701 Market Street Philadelphia, PA 19103-2921 215.963.5384 (bus) 215.963.5001 (fax) ken.kulak@morganlewis.com anthony.decusatis@morganiewis.corn catherine.vasudevanamorganlewis.com brooke.mcglinn@mor_ganlewis.corn

Dated: March 13, 2020 Counsel for PECO Energy Company

DB1/ 112775421.1 24

BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION

PETITION OF PECO ENERGY COMPANY FOR APPROVAL OF ITS DEFAULT SERVICE PROGRAM FOR THE PERIOD FROM JUNE 1, 2021 THROUGH MAY 31, 2025

: : : : :

DOCKET NO. P-2020-

PETITION OF PECO ENERGY COMPANY

Pursuant to 66 Pa.C.S. § 2807(e) of the Pennsylvania Public Utility Code (“Code”), the

Default Service Regulations1 of the Pennsylvania Public Utility Commission (the

“Commission”) and the Commission’s Policy Statement on Default Service,2 PECO Energy

Company (“PECO” or the “Company”) hereby petitions the Commission for approval of its fifth

Default Service Program (“DSP V”), as set forth herein. PECO files this Petition in accordance

with its responsibilities as the default service provider for its certificated service territory for the

period from June 1, 2021 through May 31, 2025, following the expiration of its current default

service program (“DSP IV”).3 PECO requests that the Commission: (1) approve DSP V,

including its procurement plan, implementation plan, contingency plan, and associated

procurement documents and agreements for default service supply for all PECO customers who

do not take generation service from an alternative electric generation supplier (“EGS”) or who

contract for energy with an EGS which is not delivered; (2) approve the Company’s proposal to

1 52 Pa. Code §§ 54.181-54.190; see also Rulemaking Re Elec. Distribution Companies’ Obligation to Serve Retail Customers at the Conclusion of the Transition Period Pursuant to 66 Pa.C.S. § 2807(e)(2), Docket No. L-00040169 (Order entered May 10, 2007) (“First Default Service Rulemaking Order”); Implementation of Act 129 of October 15, 2008: Default Serv. and Retail Elec. Mkts., Docket No. L-2009-2095604 (Order entered Oct. 4, 2011) (“Second Default Service Rulemaking Order”) (collectively, the “Default Service Regulations”).

2 52 Pa. Code §§ 69.1801-1817; see also Default Serv. and Retail Elec. Mkts., Docket No. M-2009-2140580 (Order entered Sept. 23, 2011) (“Default Service Policy Statement”).

3 See Petition of PECO Energy Co. for Approval of Its Default Serv. Program for the Period from June 1, 2017 through May 31, 2021, Docket No. P-2016-2534980 (Order entered Dec. 8, 2016) (“DSP IV Order”).

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solicit new ten-year contracts for Solar Alternative Energy Credits (“Solar AECs”) to satisfy the

requirements of Pennsylvania’s Electricity Generation Customer Choice and Competition Act

(the “Competition Act”),4 as amended by Act 129 of 2008 (“Act 129”), and Alternative Energy

Portfolio Standards Act, 73 P.S. § 1643.1 et seq. (“AEPS” or “AEPS Act”); (3) approve NERA

Economic Consulting, Inc. (“NERA”) to continue as the independent third-party evaluator for

PECO’s default supply procurements; (4) approve PECO’s proposed default service rate design,

including PECO’s proposed time-of-use (“TOU”) rate options, and affirm PECO’s right to

recover all of its default service costs in accordance with 66 Pa.C.S. § 2807(e)(3.9); (5) grant a

waiver of the rate design provisions of 52 Pa. Code § 54.187, to the extent necessary; (6) find

that DSP V includes prudent steps necessary to negotiate favorable generation supply contracts;

(7) find that DSP V includes prudent steps necessary to obtain least-cost generation supply on a

long-term, short-term and spot market basis; (8) find that neither PECO nor its affiliates have

withheld from the market any generation supply in a manner that violates federal law; (9)

approve continuation of PECO’s existing EGS Standard Offer Program, including the associated

cost recovery mechanism approved in PECO’s prior default service proceedings; (10) approve

PECO’s proposed plan to facilitate shopping by low income customers enrolled in the

Company’s Customer Assistance Program (“CAP”) (the “CAP Shopping Plan” or “Plan”); and

(11) approve PECO’s proposed revised uniform Supply Master Agreement (“SMA”) and both

forms of the proposed Solar AEC Purchase and Sale Agreement as affiliated interest agreements

under 66 Pa.C.S. § 2102.

This is PECO’s fifth proposed program for default service under the Competition Act.

Under DSP IV, PECO continued to meet its default service obligations while fostering

4 66 Pa.C.S. §§ 2801-2812.

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competition in retail electric markets by implementing hourly-priced default service for PECO’s

former “medium” commercial customers (100 kW to 500 kW peak demand), modifying cost

recovery mechanisms, and continuing certain retail market enhancements. In DSP V, PECO is

proposing to continue the existing and successful products and programs approved by the

Commission in DSP IV.

In accordance with the Competition Act, the Commission’s Default Service Regulations,

and the Default Service Policy Statement, DSP V is designed to enable PECO to obtain a

“prudent mix” of procurement contracts and thereby ensure that default service customers have

access to an adequate and reliable supply of generation at least cost over time. PECO therefore

requests that the Commission approve DSP V as requested herein and grant all other approvals

necessary so that PECO can implement DSP V on a timely basis for the benefit of its customers.

I. INTRODUCTION

1. PECO is a corporation organized and existing under the laws of the

Commonwealth of Pennsylvania with its principal office in Philadelphia, Pennsylvania. PECO

provides electric delivery service to approximately 1.6 million customers.

2. As a Pennsylvania electric distribution company (“EDC”), PECO serves as

default service provider to retail electric customers within its service territory in accordance with

its obligations under Section 2807(e) of the Code (66 Pa.C.S. § 2807(e)). As a default service

provider, PECO provides electric generation service to those customers who do not select an

EGS or who return to default service after being served by an EGS that becomes unable or

unwilling to serve them. PECO’s current Commission-approved default service program expires

on May 31, 2021.

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3. Under Sections 2807(e) (3.1) - (3.2) and (3.4) of the Competition Act, PECO is

required to obtain, through competitive procurement processes, a “prudent mix” of default

service supply contracts designed to ensure “adequate and reliable service” at the “least cost to

customers over time.” 66 Pa.C.S. § 2807(e)(3.7).

4. The AEPS Act requires default service providers like PECO to obtain specified

percentages of electricity sold to retail customers from alternative energy sources as measured by

alternative energy credits (“AECs”) and defined by the AEPS Act. The AEPS Act also includes

a “set-aside” that requires some of those AECs to be derived from solar photovoltaic (“PV”)

facilities. Under Act 40 of 2017 (“Act 40”), PECO must meet its future solar AEPS

requirements using Solar AECs generated from solar energy facilities in the Commonwealth of

Pennsylvania. During DSP V, PECO’s solar AEPS requirement will be 0.5% of its total default

service load.5

5. Section 54.185 of the Commission’s Default Service Regulations provides that a

default service provider should file a default service program with the Commission no later than

twelve months before its current default service program will expire. Pursuant to the Default

Service Regulations, such a default service program must include, inter alia: (1) a default

service procurement plan, which sets forth PECO’s strategy for procuring generation supply and

AEPS compliance; (2) an implementation plan identifying the schedule and other details of

PECO’s proposed competitive procurements for default supply, with forms of supplier

documents and agreements and an associated contingency plan; and (3) a rate design plan to

recover all reasonable costs of default service, which includes rates, rules and conditions of

service and revisions to its tariff. 52 Pa. Code § 54.185.

5 73 P.S. § 1648.3(b)(2)(xv).

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6. In promulgating the Default Service Regulations and Policy Statement, the

Commission provided the following guidance for default service providers in designing a default

service program:

“In implementing default service standards, Act 129 requires that the Commission

be concerned about rate stability as well as other considerations such as ensuring

a ‘prudent mix’ of supply and ensuring safe and reliable service. See 66 Pa.C.S.

§§ 2807(e)(3.2), (3.4) and (7). In our view, a default service plan that meets the

‘least cost over time’ standard in Act 129 should not have, as its singular focus,

achieving the absolute lowest cost over the default service plan time frame but,

rather, a cost for power that is both adequate and reliable and also economical

relative to other options.”6

“The ‘least cost’ standard must give the [default service provider] sufficient

latitude to select contracts that constitute a ‘prudent mix’ which includes a

sufficient variety of products that adequately take into consideration price

volatility, changes in generation supply, customer usage characteristics and the

need to assure safe and reliable service.”7

7. In its Investigation of Pennsylvania’s Retail Electricity Market at Docket I-2011-

2237952, the Commission directed PECO and other default service providers to undertake a

6 Second Default Service Rulemaking, pp. 11-12.

7 Second Default Service Rulemaking, p. 38; see also id. at 56 (expressing preference for use of full requirements contracts in provision of default service).

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variety of retail market enhancements and issued its proposed end state model for default

service.8

8. On February 26, 2019, the Commission entered an Order at Docket No. M-2019-

3007101 to initiate an investigation of potential opportunities to better reflect wholesale cost

causation in default service rates and incentivize customer behavior to lower peak demand. In

that proceeding, the Commission subsequently requested that EDCs address several topics in

upcoming default service program (“DSP”) filings.9 As described in PECO Exhibit JJM-2, those

topics include wholesale capacity and transmission cost allocation methodologies, TOU rates in

the context of electric vehicle expansion, intervals of adjustment of default service rates, CAP

customer shopping for generation service, and Standard Offer Program (“SOP”) scripting.

9. PECO is proposing three principal changes to its default service program and the

products previously approved by the Commission in DSP IV. First, PECO is proposing to

procure new Solar AEC contracts to replace PECO’s existing ten-year Solar AEC contracts

previously approved by the Commission that will have expired by the end of DSP IV. Second,

PECO is introducing new TOU default service rate options for eligible customers in PECO’s

Residential and Small Commercial procurement classes (the “TOU Rates”) to comply with

PECO’s obligation under Act 129 to offer TOU and real-time rates to all default service

customers with smart meters.10 Finally, PECO is proposing to permit CAP customers to shop for

8 See generally Investigation of Pennsylvania’s Retail Elec. Mkt.: Intermediate Work Plan, Docket No. I-2011-2237952 (Final Order entered Mar. 2, 2012); Investigation of Pennsylvania’s Retail Elec. Mkt.: End State of Default Serv., Docket No. I-2011-2237952 (Order entered Feb. 15, 2013) (“End State Order”).

9 Investigation into Default Serv. and PJM Interconnection, LLC Settlement Reforms, Docket No. M-2019-3007101 (Secretarial Letter issued Jan. 23, 2020) (“January 2020 Secretarial Letter”).

10 66 Pa.C.S. §§ 2807(f)(5). The hourly-priced default service rate for the Consolidated Large Commercial and Industrial (“C&I”) Class already meets Act 129 requirements.

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generation service in accordance with the Commission’s proposed Policy Statement on Electric

Customer Assistance Program Participant Shopping.11

10. This Petition summarizes PECO’s proposed DSP V and, in so doing, identifies

and describes the DSP V procurement plan, implementation plan, contingency plan and

mechanisms to recover all reasonable costs on a full and current basis. This Petition also

incorporates the following statements, which are attached hereto:

PECO Statement No. 1 – Direct Testimony of John J. McCawley

Mr. McCawley is PECO’s Director of Energy Acquisition. He provides an overview of PECO’s DSP V, including PECO’s proposed litigation schedule for these proceedings and customer notice, and describes PECO’s proposed default service procurement, implementation, and contingency plans for DSP V.

PECO Statement No. 2 – Direct Testimony of Joseph A. Bisti

Mr. Bisti is a Principal Regulatory and Rates Specialist for PECO. Mr. Bisti describes PECO’s existing Generation Supply Adjustment (“GSA”) and Transmission Service Charge (“TSC”), new TOU default service rate options, DSP V and CAP Shopping Plan cost recovery, and proposed changes to PECO’s Electric Service Tariff.

PECO Statement No. 2 – Direct Testimony of Carol Reilly

Ms. Reilly is PECO’s Manager of Energy Acquisition Operations. She describes the design of PECO’s CAP Shopping Plan, including Plan costs and proposed changes to PECO’s Electric Generation Supplier Coordination Tariff (“Supplier Tariff”), and discusses continuation of PECO’s Standard Offer Program.

11 Elec. Distribution Company Default Service Plans – Customer Assistance Program Shopping, Docket No. M-2018-300658 (Proposed Policy Statement Order entered Feb. 28, 2019) (“Proposed Policy Statement Order”). In the January 2020 Secretarial Letter (p. 9), the PUC acknowledged that its proposed CAP shopping policy statement was “unlikely to be final and effective in time for some upcoming DSP proceedings.” The Commission therefore directed all EDCs to consider the Commission’s prior guidance in the Proposed Policy Statement Order and recent decisions in previous default service proceedings in developing CAP proposals for upcoming DSP filings. Id., pp. 9-10.

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PECO Statement No. 4 – Direct Testimony of Scott G. Fisher

Mr. Fisher is a Principal of the NorthBridge Group, an economic consulting firm. Mr. Fisher provides an expert evaluation of PECO’s proposed procurement plan as well as a review of “lessons learned” under the Company’s prior default service programs, which includes a quantitative analysis of the prices obtained in PECO’s previous default service supply solicitations.

11. In order to have sufficient time to undertake the competitive procurement process

to obtain default generation supplies for service on and after June 1, 2021 as described in this

Petition, PECO requests approval of DSP V by December 2020. Accordingly, PECO

respectfully requests that the Commission act upon this Petition on or before its scheduled

December 3, 2020 public meeting date.

II. PECO’S DEFAULT SERVICE PROCUREMENT AND IMPLEMENTATION PLANS

A. Procurement Classes, Program Term And Supply Portfolio

12. Under DSP IV, PECO conducts competitive procurements of wholesale power

and associated services for three different default service customer classes: (i) Residential

customers, (ii) Small Commercial customers with up to and including 100 kW of annual peak

demand and lighting customers; and (iii) Consolidated Large C&I customers whose annual peak

demand is greater than 100 kW. For DSP V, PECO is proposing to maintain the same

procurement groups, and thereby continue to reflect the nature of the load requirements of each

customer class and other factors, including the evolution of competitive markets and rate

stability.12

12 The Commission’s Default Service Regulations and Policy Statement provide that customers should be divided into three classes based upon peak load contributions of 0-25 kW, 25-500 kW, and 500 kW and above. See 52 Pa. Code §§ 54.187 & 69.1806. As Mr. McCawley explains in his testimony, the Commission has previously granted PECO a waiver from these regulations to implement a lower customer segmentation threshold for the Consolidated Large C&I class and appropriately separate smaller commercial customers from larger C&I customers who receive hourly-priced default service. In accordance with 52 Pa. Code § 54.185(g), PECO again

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13. PECO’s DSP V encompasses default service procurement for the above classes

for the period beginning June 1, 2021 through May 31, 2025. A four-year term for default

service programs is permitted under the Commission’s Default Service Policy Statement, which

states that default service programs should be for two-year periods unless the Commission

directs otherwise.13 In the DSP IV Order (p. 35), the Commission noted that a four-year term

would minimize future litigation expenses and reduce administrative costs.

14. In light of its favorable experience to date, PECO proposes to maintain the

procurement strategy established in prior default service programs, which utilizes full

requirements, load-following products, as well as short time periods between the solicitation and

delivery of supply products.

15. A full requirements, load-following contract requires a supplier to provide energy,

capacity, ancillary services, and all other services or products necessary to serve a specified

percentage of default service load continuously over the term of the contract. Because the

contract is load-following, the amount of energy and other services and products a supplier must

provide will vary depending upon PECO’s actual default service load.

16. For the Residential Class, under DSP V, PECO proposes to continue to procure a

mix of one-year (approximately 38%) and two-year (approximately 61%) fixed-price full

requirements, load-following products. The remaining Residential Class load will be supplied

directly by PJM’s spot energy, capacity and ancillary service markets (approximately 1%).14 As

requests a waiver of the applicable provisions of the Default Service Regulations to continue combining default service procurement for PECO’s former “medium” commercial customers (101 kW to 500 kW peak demand) and “large” C&I customers (over 500 kW).

13 52 Pa. Code § 69.1804.

14 As explained by Mr. McCawley, PECO also receives an allocation of five megawatts of low-cost hydropower from the New York Power Authority (“NYPA”) for residential customers in PECO’s service territory under a

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in DSP IV, each of the Residential Class products will be procured approximately two months

prior to the beginning of the applicable delivery period.

17. PECO proposes to continue to serve the Small Commercial class with equal

shares of one-year and two-year fixed-price full requirements products procured approximately

two months prior to delivery of the energy. As Mr. Fisher explains in PECO Statement No. 3,

this procurement strategy for the Small Commercial class provides price stability benefits for all

small non-residential customers who may not have the knowledge or resources to elect a

competitive EGS offering that provides the price stability they seek.

18. With respect to the Consolidated Large C&I class, PECO proposes to continue to

procure all default service supply through hourly-priced full requirements products on an annual

basis.

19. DSP V includes some Residential and Small Commercial class supply products

with delivery periods that extend beyond May 31, 2021 (the end of the DSP V period). The

extension of contracts beyond the term of a default service program is permitted by the

Commission’s regulations and is consistent with the procurement design approved by the

Commission in DSP II, DSP III and DSP IV. See 52 Pa. Code § 54.186(b)(4) (“Procurement

plans may include solicitations and contracts whose durations extend beyond the program

period.”). The laddering of contract delivery periods (extending beyond May 31, 2021) will

better ensure that customers are not fully exposed to the potential wholesale price volatility

associated with replacing a large portion of default service supply in a short period.

multi-state agreement administered in Pennsylvania by Allegheny Electric Cooperative, Inc. This amount corresponds to 0.2% of PECO’s Residential default service load. Under DSP V, PECO will continue to use the NYPA allocation to offset the amount of Residential default service supply provided by wholesale suppliers.

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20. During PECO’s first two default service programs, load serving entities (“LSEs”),

including EGSs, were responsible for transmission costs charged by PJM Interconnection, L.L.C.

(“PJM”), including Generation Deactivation/Reliability Must Run (“RMR”) charges, Expansion

Cost Recovery charges and Transmission Enhancement (a/k/a Regional Transmission Expansion

Plan or “RTEP”) charges. In approving PECO’s third default service program, the Commission

concluded that certain PJM transmission-related charges should be recovered from customers on

a non-bypassable basis.15 Consistent with that finding, on June 1, 2015, PECO implemented a

Non-Bypassable Transmission Charge (“NBT”) to recover the following PJM charges from all

distribution customers in PECO’s service territory: Generation Deactivation/RMR charges (PJM

bill line 1930) set after December 4, 2014; RTEP charges (PJM bill lines 1108 and 1115); and

Expansion Cost Recovery charges (PJM bill line 1730). During DSP V, PECO will also

continue to be responsible for and will recover Network Integration Transmission Service and

Non-Firm Point-to-Point Transmission costs through its unbundled, bypassable TSC.

21. As Mr. Fisher explains, the overall mix of products for each procurement class

shown in the table below satisfies the Public Utility Code’s “prudent mix” requirement.

15 See Petition of PECO Energy Co. for Approval of Its Default Serv. Program for the Period from June 1, 2015 through May 31, 2017, Docket No. P-2014-2409362 (Order entered Dec. 4, 2014), p. 46.

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Residential Small Commercial Consolidated Large

Commercial and Industrial

Approximately 99% of the load is supplied by a mix of products in the following proportions:

o Approximately 38% 1-year fixed-price full requirements (“FPFR”) products with delivery periods that overlap on a semi-annual basis

o Approximately 61% 2-year FPFR products with delivery periods that overlap on a semi-annual basis

The other approximately 1% of the load will be supplied by spot purchases

All products are procured approximately two months before delivery of the product begins

50% 1-year FPFR products

50% 2-year FPFR products

Delivery periods overlap on a semi-annual basis

All products are procured approximately two months before delivery of the product begins

100% spot-priced full requirements products, with 1-year delivery periods

All products are procured approximately two months before delivery of the product begins

22. Each seller of full requirements default service supply will deliver a percentage of

PECO’s default service load pursuant to the terms of the SMA. As envisioned by the

Commission in the End State Order, PECO is proposing to continue to use the uniform SMA

developed through the Office of Competitive Market Oversight (“OCMO”) SMA stakeholder

process, which has functioned well during DSP IV, with one modification described by Mr.

McCawley. Specifically, PECO is proposing to require each wholesale supplier to submit the

information required in PECO’s annual report to the PUC on default service16 to the Company

for the energy supplied under the SMA.

B. Competitive Bid Solicitation Process And Independent Evaluator

23. As described by Mr. McCawley, PECO intends to solicit bids for default service

supply beginning in February 2021. PECO’s proposed solicitations extend over the DSP V term

16 52 Pa. Code § 54.39; see also id. at § 54.6 (requiring default service providers to file the annual licensing report required by Section 54.39 of the Commission’s EGS licensing regulations that provides information on default supply generation sources).

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and are intended to avoid problems associated with procuring significant amounts of supply at a

single point in time when prices may be highest.

24. Consistent with DSP IV, all bids for default service supply will be obtained

through a fair, non-discriminatory, and competitive request for proposals (“RFP”) process

conducted by an independent third-party evaluator, and PECO proposes to retain NERA in this

independent evaluator role for DSP V. In his testimony, Mr. McCawley describes the RFP rules

for DSP V developed by NERA, which are the same as those now used by PECO in its DSP IV

procurements.17 Mr. McCawley also discusses PECO’s proposal to maintain the DSP IV “load

cap” so that no supplier will be permitted to provide more than 50% of the default supply for any

one of PECO’s procurement classes at any point in time during DSP V.

25. As Mr. McCawley explains, PECO’s proposed competitive procurement process

complies with the Commission’s codes of conduct and includes protocols to ensure that PECO’s

wholesale generation affiliates do not receive an advantage in the bidding process or any other

aspect of PECO’s default service implementation plan. As with PECO’s prior default service

programs and in order to permit the participation of wholesale generation affiliates of PECO in

its default supply competitive procurements (as allowed by Section 54.186(b)(6) of the Default

Service Regulations, 52 Pa. Code § 54.186(b)(6)), PECO also respectfully requests that the

Commission approve the revised uniform SMA as an affiliated interest agreement under 66

Pa.C.S. § 2102.

17 The RFP Rules proposed by PECO include non-material modifications suggested by the Independent Evaluator over the course of the DSP IV procurement cycle to facilitate competition and improve bidder participation in accordance with Section I.1.12 of the RFP Rules.

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C. Consistency With Regional Transmission Organization Requirements

26. In accordance with the Default Service Regulations, PECO’s DSP V is also

“consistent with the legal and technical requirements pertaining to the generation, sale and

transmission of electricity of the [regional transmission organization] in whose control area the

DSP is providing service.” 52 Pa. Code § 54.185(e)(4). As explained by Mr. McCawley,

PECO’s SMA will continue to impose requirements on both PECO and its suppliers to maintain

specific qualifications under applicable PJM agreements and rules, as well as all other regulatory

authorizations (including those of the Federal Energy Regulatory Commission) necessary to

perform all contractual obligations. Furthermore, suppliers seeking to bid to provide default

service generation must be able to establish that they can fulfill all technical and regulatory

requirements of the SMA, including demonstrating that there is no impediment to becoming an

LSE under PJM’s rules.

D. AEPS Compliance

27. As Mr. McCawley describes in his testimony, PECO will continue to satisfy its

AEPS obligations with respect to sales to default service customers by requiring each full

requirements default service supplier to transfer Tier I (including solar PV) and Tier II AECs to

PECO corresponding to PECO’s AEPS obligations associated with the amount of default service

load served by that supplier. In addition, PECO will continue to allocate AECs obtained through

its AEC procurements to suppliers in accordance with the peak load of each customer class and

the percentage of load served by each supplier.

28. In DSP IV, all procurement classes are allocated Solar Tier I AECs from PECO’s

long-term ten-year Solar AEC purchase agreements. In total, PECO has been purchasing 8,000

Solar Tier I AECs annually from various agreements that will expire on May 31, 2020 or May

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31, 2021. In light of PECO’s prior successful Solar AEC procurement in 2009 and potential

future supply shortfalls related to Act 40’s in-state requirements, PECO is proposing two annual

solicitations in the first two years of the DSP V term for delivery of a total of 16,000 Solar AECs

(i.e., 8,000 Solar AECs in each solicitation in 2021 and 2022). This amount of Solar AECs is

expected to meet approximately 25% of PECO’s increased solar AEPS requirements under DSP

V. PECO is also proposing to procure up to half of each year’s Solar AEC amount from solar

generating facilities located within its service territory consistent with a variety of stakeholder

goals, including the City of Philadelphia.

29. As explained by Mr. McCawley, the first stage of the RFP will consist of a

competitive procurement where the winning bidders will be determined by lowest Solar AEC

prices offered. The second stage will be a Standard Offer to Purchase (“SOTP”) Solar AECs at a

competitive price determined by the first stage RFP, with the requirement that the Solar AECs

from stage two bidders come from solar generation resources located in the PECO service area.

All bidders must be owners of solar PV systems, or own the rights to Solar AECs generated by

such systems, and such systems must be physically located within Pennsylvania. Both existing

solar PV systems that have achieved commercial operation and solar PV projects under

development are eligible to participate. These include grid-connected and net-metered solar PV

systems. All systems must be qualified as Tier I solar PV alternative energy systems and all

deliveries of Solar AECs to PECO must be made through the Generation Attribute Tracking

System operated by PJM Environmental Information Services, Inc. Entities who can aggregate

Solar AECs from multiple parties (“Aggregators”) will be permitted to participate in both the

RFP and SOTP.

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30. For both the RFP and SOTP stage, PECO will use a two-part, competitive bid

process in which bidders are first qualified and then permitted to submit a bid with an offer to

deliver a specific amount of Solar AECs annually, subject to a minimum bid amount (200 AECs

per year). Consistent with the competitive procurement process PECO is currently using for

Solar Tier I AECs, an independent, third-party RFP monitor (“RFP Monitor”) will participate

throughout the entire procurement process. The Commission will have ten days for review and

approval of the final results for each stage one RFP. If an RFP bid is accepted and approved, the

winning bidder will be required to enter into the Solar AEC Purchase and Sale Agreement with

PECO.18

31. Upon completion of the first solar RFP each year, PECO will publish the average

winning bid received in the RFP. This average winning bid price will be the price for the SOTP

procurement stage. For the SOTP procurement, the RFP Monitor will accept bidder applications

on a first-come, first-served basis and qualify each bidder. Once the RFP Monitor has a

sufficient list of companies, or after 90 days (whichever comes first), the RFP Monitor will

submit the list of bidders with their qualifications to the Commission for a 10-day review period.

PECO will execute a purchase agreement with each qualified and approved bidder up to the

numerical limit of Solar AECs for that procurement.

III. CONTINGENCY PLANS

32. In accordance with the Default Service Regulations (52 Pa. Code § 54.185(e)(5)),

PECO is proposing to use the same contingency plan approved by the Commission in DSP IV to

address the possibility that PECO does not obtain sufficient supply through its procurement

18 The Solar RFP includes two forms of the Solar Alternative Energy Credit Purchase and Sale Agreement that PECO will execute with each successful bidder (a Project Version and an Aggregator Version).

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processes or experiences a supplier default under the SMA. In the event PECO fails to obtain

approved bids for all offered tranches in a solicitation, the unfilled tranches will be included in

PECO’s next scheduled default supplier solicitation for that product. If necessary, PECO will

supply any unserved portion of its default service load from the PJM-administered markets for

energy, capacity and ancillary services. If the supplier default occurs within a reasonable time

before a scheduled procurement, the load served by the defaulting supplier will be incorporated

into that next procurement. Otherwise, PECO will file a plan with the Commission proposing

alternative procurement options and a request for approval on an expedited basis.

33. In the event that PECO’s proposed 2021 procurement for Solar AECs is

unsuccessful or there is insufficient participant interest, the amount of solar AECs not under

contract will be added to the amount procured in the 2022 procurement process. If PECO is

unable to obtain its full 16,000 Solar AECs after completing the 2021 and the 2022

procurements, any shortfall will be met by wholesale suppliers who are obligated to transfer

enough Solar AECs to meet AEPS requirements for the percentage of default service load that

they supply under the SMA.

IV. RATE DESIGN AND COST RECOVERY

A. Generation Supply Adjustment

34. The default service rate for each of PECO’s procurement classes consists of a

generation (GSA) and transmission (TSC) component. The GSA currently recovers generation

supply costs, AEPS compliance costs, and ancillary service costs. The GSA also includes

administrative cost and working capital factors. The TSC recovers certain PJM charges for

transmission service PECO acquires on behalf of default service customers. The GSA and TSC

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form the basis of the PTC that customers may use to evaluate competitive generation service

offerings.

35. Under DSP IV, PECO adjusts its default service rates each quarter, with semi-

annual reconciliation of the over/undercollection component of the GSA (the “E-Factor”). In

accordance with the January 2020 Secretarial Letter, PECO assessed the benefits presented by

both a three-month and six-month default supply price projection period in the context of the

Company’s PTC history. Based on this assessment, PECO believes its current approach

appropriately balances the responsiveness of the PTC to current market conditions and

fluctuations caused by billing cycle lag.

36. In DSP V, PECO proposes to maintain the same rate design approved by the

Commission in DSP IV with the addition of new, optional TOU Rates for the Residential and

Small Commercial Classes described in Section IV.B. below.

37. PECO also requests that the Commission expressly affirm PECO’s right to full

and current recovery of all costs to implement DSP V in accordance with 66 Pa.C.S. §

2807(e)(3.9).

B. Time-Of-Use Rate Options

38. In 2014, PECO offered a TOU generation rate through a PUC-approved one-year

pilot program known as the “PECO Smart Time Pricing Pilot” (“Pilot”) described by Mr. Bisti.19

19 Petition of PECO Energy Co. for Approval of its Initial Dynamic Pricing and Customer Acceptance Plan, Docket No. M-2009-2123944, (Order entered Apr. 15, 2011) (“Dynamic Pricing Order”); Petition of PECO Energy Co. for Expedited Approval of its Dynamic Pricing Plan Vendor Selection and Dynamic Pricing Plan Supplement, Docket No. P-2012-2297304 (Opinion and Order entered Sept. 26, 2012) (approving modifications to the commodity supply, dynamic rate structure, size and term of the pilot approved in the Dynamic Pricing Order to enable an EGS to provide TOU supply in lieu of PECO).

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For DSP V, PECO is proposing new TOU Rates for the Residential and Small Commercial

Classes consistent with Commission guidance on TOU rate design.20

39. As described by Mr. Bisti, the Company’s TOU Rates reflect a balance of the

following objectives: (1) simplicity and the value proposition for customer enrollment; (2) cost-

causation principles to connect the TOU pricing structure to wholesale markets and PECO’s

standard, non-time varying GSA; and (3) incentives for customer EV adoption. The key features

of PECO’s proposed TOU Rates are discussed below and in more detail in Mr. Bisti’s direct

testimony.

1. TOU Product Structure and Rate Design

40. The TOU Rates will differentiate prices across three periods (peak, off-peak and

super off-peak) that are constant throughout the year based on price multipliers designed to

motivate shifting of usage from the higher-cost peak period to lower-cost off-peak periods.

Under the Company’s proposed rate design, eligible default service customer will pay a

discounted rate for off-peak usage and a higher rate for peak usage relative to PECO’s standard

fixed-price GSA.

20 Since the conclusion of the Pilot, the scope of an EDC’s obligation to offer TOU rates to default service customers was the subject of litigation before the Commission and Commonwealth Court. See Petition of PPL Elec. Utils. Corp. for Approval of a New Pilot Time-of-Use Program, Docket No. P-2013-2389572 (Order entered Sept. 11, 2014) (holding that Act 129 did not require PPL Electric Utilities Corp. (“PPL”) to offer TOU rates directly to customer-generators); Dauphin Cty. Indus. Dev. Auth. v. Pa. P.U.C., 123 A.3d 1124, 1136 (Pa. Cmwlth. 2015) (“DCIDA”) (holding that Act 129 does not authorize default service providers to delegate the obligation to offer TOU rates to customers with smart meters to EGSs); Petition of PPL Elec. Utils. Corp. for Approval of a New Pilot Time-of-Use Program, Docket Nos. P-2013-2389572 and M-2016-2578051 (Secretarial Letter issued Apr. 6, 2017) (“April 2017 Secretarial Letter”) (proposing a TOU design for PPL in accordance with the DCIDA decision and noting that the proposed TOU design “may provide future guidance to all EDCs” for incorporation into their own TOU proposals in their individual default service proceedings).

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41. PECO’s proposed time-differentiated pricing usage periods shown in Table 1

below reasonably encompass the Company’s expected system peak usage times and take into

account the need for simplicity to encourage customer enrollment.

Table 1

TOU Pricing Period Year-Round Days/Hours Included

Peak 2 p.m. – 6 p.m.

Monday Through Friday, excluding PJM holidays

Super Off-Peak Midnight (12 a.m.) – 6 a.m.

Every day

Off-Peak All other hours

PECO defined the peak period as 2 p.m. to 6 p.m. on non-holiday weekdays based on PJM’s

PECO zonal load data and energy prices over a five-year historic period (2014-2018).

Consistent with the January 2020 Secretarial Letter, PECO’s proposed TOU Rates include a

super off-peak pricing period from 12 a.m. to 6 a.m. every day to encourage EV charging during

overnight low-priced energy hours based on PECO’s system load patterns. These TOU pricing

periods will be identical for the Residential and Small Commercial Classes.

42. PECO is proposing to set the TOU price multipliers for each procurement class

shown in Table 2 below. These multipliers will remain constant during the DSP V term. As

explained by Mr. Bisti, these multipliers reflect the ratios calculated from average PJM PECO

zone spot market prices as well as the cost of capacity during peak and off-peak hours. PECO is

proposing to allocate the cost of capacity to peak and off-peak hours only to send cost-based

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price signals and create larger price differentials that are more likely to motivate customers to

adjust the time of day they use electricity.

Table 2

TOU Pricing Period

GSA-1 TOU Pricing Multipliers*

GSA-2 TOU Pricing Multipliers*

Peak 6.5 5.1

Super Off-Peak 1 1

Off-Peak 1.5 1.7

*Ratio to super off-peak TOU price

43. PECO will source both the standard and TOU default service for residential and

small commercial customers from the same supply portfolio for each procurement class. As Mr.

McCawley and Mr. Fisher explain, any effects of TOU default service on supplier prices should

be small given the expected small level of participation relative to the overall default service

customer base and the lack of revenue risk to suppliers (who will be paid the same price for a

megawatt-hour of default service supply for customers on standard default service and those on

TOU default service). PECO will use the standard GSA as the reference price for PECO’s TOU

rate calculations.

44. PECO will calculate the super off-peak price to provide a discount from the

standard GSA price in a way that offsets the higher peak and off-peak period prices and ensures

revenue neutrality. The revenue neutral super off-peak price for each procurement class will be

derived from the portion of total system kWh usage attributable to each TOU pricing period.

PECO determined these percentages based on PJM energy market settlements over the most

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recent historical five-year period (2014-2018). The peak and off-peak TOU prices are a factor of

multiplying the super off-peak price by the multiplier for the applicable procurement class and

TOU pricing period.

45. The TOU Rates will be calculated on a quarterly basis, synchronized with the

GSA adjustment periods for the Residential and Small Commercial Classes, using PECO’s

proposed pricing methodology. TOU customer kWh sales and costs will be included in the semi-

annual reconciliation of the over/undercollection component of the GSA for the entire

procurement class (i.e., Residential or Small Commercial). PECO’s proposed reconciliation

process using a single E-Factor for each procurement class will help mitigate potential large

swings in GSA over/undercollections that could arise if customers switch between PECO’s

standard default service rate and TOU default service rate.

2. Customer Eligibility

46. Consistent with the April 2017 Secretarial Letter, PECO’s TOU Rates will be

available to residential and small commercial default service customers with smart meters

configured to measure energy consumption in watt-hours. However, PECO is proposing to

exclude CAP customers from the residential TOU Rate at this time to avoid potential adverse

impacts on CAP benefits.

47. Eligible default service customers may enroll in PECO’s TOU Rates online or

through the Company’s care center. Participating customers will remain on the TOU Rate until

they affirmatively elect to return to PECO’s standard default service rate, switch to an EGS or

otherwise become ineligible.

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48. Customers who select the TOU Rate may leave at any time without incurring

related penalties or fees. However, if those customers subsequently leave the TOU Rate for any

reason, they may not re-enroll for twelve billing months after switching off the TOU Rate.

3. Net Metering Customers

49. In accordance with the April 2017 Secretarial Letter, customer-generators, with

the exception of virtual net metering customers, will be eligible for the TOU Rates.

50. As explained by Mr. Bisti, PECO will separately track net excess generation

created by TOU net metering customers within the TOU peak, off-peak and super off-peak

periods. During any month when a TOU net metering customer consumes more power than it

generates, the excess generation in the applicable TOU rate period will be used to reduce or

offset the customer’s bill at the full retail rate, including the current TOU prices for generation,

consistent with the Commission’s guidance in the April 2017 Secretarial Letter. At the end of

the PJM planning period on May 31 of each year, PECO will compensate TOU net metering

customers for accumulated excess generation based on the applicable TOU rate and TSC in

effect at the time the excess electricity was generated.

4. Implementation Plan and Cost Recovery

51. Mr. Bisti’s testimony discusses PECO’s communications plan to inform

customers about the new TOU Rates and update enrolled TOU customers about the opportunity

for bill savings. This plan includes a webpage dedicated to the TOU Rates, a variety of other

customer education materials, and monthly e-mail communications to enrolled TOU customers.

52. PECO estimates that it will require at least twelve months to implement the final

TOU rate design approved by the PUC in this proceeding. PECO proposes to recover the costs

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to implement the new TOU rates totaling approximately $3.8 million from customers through the

administrative cost factor of the GSA as described by Mr. Bisti.

V. RETAIL MARKET ENHANCEMENTS

53. During DSP II, DSP III and DSP IV, PECO implemented a variety of programs to

support EGSs and expand retail choice. These programs include PECO’s EGS purchase of

receivables program, the Company’s Standard Offer Program, enhanced customer account

number access for EGSs, and accelerated (three-day) switching.

A. Standard Offer Program

54. As described by Ms. Reilly, since June 1, 2017, the Standard Offer Program has

resulted in over 26,000 residential customer and 500 small commercial customer referrals to

EGSs that have voluntarily chosen to offer customers a twelve-month contract priced at 7%

below PECO’s default service rate at the time of the offer. Consistent with the January 2020

Secretarial Letter (p. 10), PECO reviewed its current SOP customer scripts produced from the

PUC-approved settlement of the DSP IV proceeding and concluded that the scripts reasonably

present the SOP to customers and incorporate appropriate customer protections.

55. PECO proposes to continue offering its existing Standard Offer Program from

June 1, 2021 through May 31, 2025. Consistent with PECO’s current tariff, the Company further

proposes to continue to recover Standard Offer Program costs through an EGS participant fee of

$30 per enrolled customer, with any remaining costs recovered in the following manner: (1) fifty

percent from EGSs through a Purchase of Receivables discount; and (2) fifty percent from

residential and small commercial default service customers via the GSA.

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B. CAP Shopping Plan

56. In accordance with the universal service obligations set forth in the Public Utility

Code, PECO’s CAP assists low income customers in PECO’s service territory through

discounted energy bills. PECO’s CAP is a special rate rider for customers with an annual

household gross income level at or below 150% of the poverty level established under Federal

law. Approximately 111,000 residential customers in PECO’s service territory – almost 7% of

all PECO residential electric customers – participate in the CAP. CAP customers receive a fixed

bill credit each year for the utility service they receive based on their ability to pay regardless of

the actual amount of their utility bill. The annual cost of the fixed credits provided to CAP

customers not recovered in base rates (referred to as the “CAP shortfall”) is recovered from all

residential customers through PECO’s Universal Service Fund Charge (“USFC”).

57. PECO’s CAP customers are not currently eligible to purchase electric generation

supply from an EGS. In accordance with the Commission’s direction in its Proposed Policy

Statement Order,21 PECO’s Plan will facilitate shopping by CAP customers during DSP V.

58. An EGS serving residential customers in PECO’s service territory will have the

opportunity to enroll CAP customers and provide them with electric generation service, subject

to the Plan requirements summarized below and discussed in detail in Ms. Reilly’s direct

testimony.

21 The CAP shopping requirements outlined in the Proposed Policy Statement Order (pp. 5, 9-10) include: (1) a CAP shopping product rate at or below the EDC’s PTC for the duration of the contract; (2) a prohibition in EGS-CAP customer contracts against fees unrelated to the provision of electric generation service, including early termination and cancellation fees; and (3) the following options for CAP customers upon expiration of the current contract period: enter into another contract with their existing EGS with the same CAP protections, switch to another supplier offering a contract with the same CAP protections, or return to default service.

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59. First, consistent with the Proposed Policy Statement Order, a participating EGS

(a “CAP Supplier”) must charge CAP customers a rate for generation service that is at or below

the PECO PTC for residential customers. This will ensure that the affordability of service will

be preserved and avoids higher costs for the residential customers that fund the program. EGSs

serving CAP customers also may not enter into contracts that impose early cancellation and

termination fees or other fees unrelated to generation service. This prohibition ensures that the

overall rate charged to a CAP customer does not exceed PECO’s PTC.

60. Second, EGSs must electronically submit a notice of intent to participate or

discontinue participation as a CAP Supplier (a “CAP Notice”), at least ten days before the start

of the calendar month. EGSs that execute a CAP Notice must agree to comply with all Plan

requirements, including pricing limitations for CAP customers.

61. Third, CAP Suppliers must use PECO’s “bill-ready” EDC consolidated billing for

all shopping CAP customers. The use of EDC consolidated billing will allow the Company to

ensure that each customer’s CAP benefits are properly applied to customer charges and track

information regarding CAP customers to meet its on-going obligations to the Commission with

respect to universal service programs, including reporting on cost effectiveness and affordability.

62. Fourth, CAP Suppliers must publish their CAP rates on PAPowerSwitch.com and

in a customer mailing (upon a customer’s request via EGS call centers) to promote rate

transparency and help simplify the shopping process for CAP customers.

63. Finally, CAP Suppliers must comply with the Plan’s contract expiration and

change notice procedures described by Ms. Reilly. In accordance with the Proposed Policy

Statement Order, CAP customers will have the following options at the end of the contract term:

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renew the contract with their existing EGS at a new Plan-compliant CAP rate, switch to another

supplier offering a Plan-compliant CAP rate or return to default service.

64. As part of the Plan, the Company will implement a variety of customer education

initiatives focused on the CAP rate protections that must be included in CAP customer-EGS

contracts, the impact of shopping on CAP benefits, and tools to help CAP customers understand

and manage their energy bills. As described by Ms. Reilly, these initiatives will utilize a broad

range of communication methods, including PECO’s call center, mailings, customer outreach

efforts, web support, community workshops and advocate-sponsored events for low income

customers.

65. PECO’s existing electronic data interchange protocol includes data elements that

identify PECO’s CAP customers that will allow EGSs to tailor products and service options for

those customers in accordance with the Plan. Under the Plan, PECO will continue its current

communication practices related to quarterly changes to the residential PTC and will provide

information regarding Plan rules and procedures through PECO’s supplier bulletins and EGS

coordination web portal.

66. After Plan implementation, PECO will continue its Commission-approved

method of calculating the CAP credit amount using a twelve-month look-back period. During

the initial year that the CAP customer shops, the CAP credit will be calculated using PECO’s

PTC in effect for the twelve-month period being examined. Thereafter, the fixed bill credit for

shopping CAP customers will be calculated based on EGS charges.

67. The Company will require one year to implement the proposed Plan. PECO

estimates that the Plan implementation costs will approximate $1.2 million. The costs fall into

two categories. The first category (i.e., approximately $500,000) is related to the customer

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education initiatives described above. PECO is proposing to recover the costs associated with

the customer education initiatives from residential customers in the current Customer Education

Charge (“CEC”) approved by the Commission in Docket No. P-2011-2279773. The second

category (i.e., approximately $0.7 million) is related to training and IT changes to the Company’s

billing and customer information system to facilitate CAP shopping and to appropriately

calculate the CAP fixed credit amount. Those costs will be recovered in a subsequent base rate

case.

68. Considering the projected expense and outreach to CAP customers, PECO

proposes to begin the one-year implementation period after approval of the Plan and following

receipt of CAP Notices from at least five EGSs. While CAP Notices are not binding, the receipt

of at least five CAP Notices will ensure that there is verifiable EGS interest in serving CAP

customers in PECO’s service territory.

VI. PROCEDURAL ISSUES AND COMMISSION APPROVAL

69. In accordance with the nine-month period for approval of a default service plan

under Section 2807(e)(3.6) of the Public Utility Code, PECO proposes the following schedule

for this proceeding:

March 13, 2020 Petition Filing

April 23, 2020 Prehearing Conference

June 4, 2020 Other Parties’ Direct Testimony Due

June 25, 2020 Rebuttal Testimony Due

July 9, 2020 Surrebuttal Testimony Due

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July 15-16, 2020 Oral Rejoinder and Hearings

August 6, 2020 Initial Briefs

August 25, 2020 Reply Briefs

October 6, 2020 Recommended Decision

December 3, 2020 Commission Order

VII. NOTICE

70. In accordance with Section 54.188 of the Commission’s Default Service

Regulations, PECO is providing public notice of this filing to its customers in several ways.

First, PECO will include a stand-alone insert in all customer bills over a thirty-day period

beginning on April 1, 2020. This stand-alone bill insert will notify customers of this filing,

where they may obtain copies of the filing, and how they may participate in this proceeding by

filing comments or complaints with the Commission. In addition, PECO will publish notices

containing similar information in all of the major newspapers serving its service territory.

Finally, all notices will refer to PECO’s website, (peco.com/rates), where a copy of the entire

filing will be maintained.

71. In addition to the above notices, PECO is also serving copies of this filing on the

Pennsylvania Office of Consumer Advocate, the Pennsylvania Office of Small Business

Advocate, the Commission’s Bureau of Investigation and Enforcement, the Coalition for

Affordable Utility Services and Energy Efficiency in Pennsylvania, PJM, the Philadelphia Area

Industrial Energy Users Group, the Retail Energy Supply Association, and all EGSs registered in

PECO’s service territory.

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72. PECO respectfully requests that the Commission publish notice of this filing in

the Pennsylvania Bulletin, with a reasonable deadline for intervention in this proceeding in light

of the above notice PECO is providing and PECO’s proposed schedule. Should the Commission

conclude that further notice of this filing is appropriate, PECO will provide such additional

notice as directed by the Commission.

VIII. CONCLUSION

Based upon the foregoing, including the attached testimony and exhibits, PECO

respectfully requests that the Commission grant this Petition and enter an order, pursuant to the

requirements of 66 Pa.C.S. § 2807(e)(3.7):

(1) Approving PECO’s proposed DSP V, including its default service

procurement plan, implementation plan, contingency plan and related bidder rules, SMA, credit

documents, and other associated agreements, for all PECO customers who do not take

generation service from an alternative electric generation supplier or who contract for energy

with an alternative electric generation supplier which is not delivered;

(2) Approving PECO’s proposal to procure up to 16,000 Tier I Solar AECs

per year in 2021 and 2022 as set forth herein and the related procurement documents;

(3) Approving NERA Economic Consulting, Inc. to continue as the

independent third-party evaluator for PECO’s default supply procurements;

(4) Finding that DSP V includes prudent steps necessary to negotiate

favorable generation supply contracts;

(5) Finding that DSP V includes prudent steps necessary to obtain least-cost

generation supply on a long-term, short-term and spot market basis;

(6) Finding that neither PECO nor its affiliates have withheld from the market

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any generation supply in a manner that violates federal law;

(7) Finding that PECO’s proposed TOU rate options for the Residential and

Small Commercial Classes satisfy PECO’s obligations under 66 Pa.C.S. § 2807(f)(5);

(8) Granting a waiver of the rate design provisions of 52 Pa. Code § 54.187 to

permit PECO to continue: (a) to procure generation for three procurement classes, (b) quarterly

filing of hourly-priced default service rates, and (c) semi-annual reconciliation of the over/under

collection component of the GSA for all default service customers;

(9) Approving PECO’s proposed tariff changes related to the introduction of

the TOU Rates for residential and small commercial default service customers, and affirming

PECO’s right to recover all of its default service costs in accordance with 66 Pa.C.S. §

2807(e)(3.9);

(10) Approving continuation of PECO’s Standard Offer Program and the

associated cost recovery mechanism;

(11) Approving PECO’s CAP Shopping Plan as set forth herein and proposed

Supplier Tariff changes to implement the Plan; and

(12) Approving PECO's proposed revised uniform Supply Master Agreement

and both forms of the proposed Solar AEC Purchase and Sale Agreement under 66 Pa.C.S. §

2102.

Respectfully submitted,

e 4 / Anthony . Gay (Pa. No. 74624) Jack R. Garfinkle (Pa. No. 81892) W. Craig Williams (Pa. No. 306405) PECO Energy Company 2301 Market Street P.O. Box 8699 Philadelphia, PA 19101-8699 Phone: 215.841.5974 Fax: 215.568.3389 E-mail: Craig.Williams@Exeloncorp.com

Kenneth M. Kulak (Pa. No. 75509) Brooke E. McGlinn (Pa. No. 204918) Morgan, Lewis & Bockius LLP 1701 Market Street Philadelphia, PA 19103-2921 Phone: 215.963.5384 Fax: 215.963.5001 E-mail: ken.kulakAmorganlewis.com

Dated: March 13, 2020 Counsel For PECO Energy Company

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(12) Approving PECO's proposed revised uniform Supply Master Agreement

and both forms of the proposed Solar ABC Purchase and Sale Agreement under 66 Pa.C.S. §

2102.

Respectfully submitted,

~d-Anthon~. Gay (Pa. No. 74624)Jack R. Garfinkle (Pa. No. 81892)W. Craig Williams (Pa. No. 306405)PECO Energy Company2301 Market StreetP.O. Box 8699Philadelphia, PA 19101-8699Phone: 215.841.5974Fax: 215.568.3389E-mail: Craig.Williams@Exeloncorp.com

Kenneth M. Kulak (Pa. No. 75509)Brooke E. McGlinn (Pa. No. 204918)Morgan, Lewis & Bockius LLP1701 Market StreetPhiladelphia, PA 19103-2921Phone: 215.963.5384Fax: 215.963.5001E-mail: ken.kulak@morganlewis.com

Dated: March 13,2020 Counsel For PECD Energy Company

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VERIFICATION

I, John J. McCawley, hereby declare that I am the Director of Energy Acquisition for

PECO Energy Company; that, as such, I am authorized to make this verification on its behalf;

that the facts set forth in the foregoing Petition are true and correct to the best of my knowledge,

information and belief; and that I make this verification subject to the penalties of 18 Pa.C.S. §

4904 pertaining to false statements to authorities.

Date: March /0 , 2020

DB1/ 112900919.1