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Ohio Utility Seeks Nonbypassable Uncollectibles Rider, Proposes Other Nonbypassable Rider For Legacy Fuel, Green Options Costs

December 1, 2015

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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

In a newly filed rate case, Dayton Power & Light has sought approval for implementation of a new, nonbypassable uncollectibles rider, which would recover "all" uncollectibles at the utility

DP&L said that, "it is appropriate to include all uncollectible expenses in the Uncollectible Rider, which is proposed as a distribution rider. Based on the current structure of the retail market in Ohio, DP&L, the electric distribution utility, bears the cost of non-payment of electric charges; therefore, it requires a mechanism to recover these costs of providing electric service to both shopping and non-shopping customers."

We see nothing in the DP&L tariff or Ohio code which suggests that the terms "electric charges" or "electric service" exclusively relate to distribution service

DP&L said in testimony that two items are included in the proposed Uncollectible Rider:

(1) A reconciliation of the previous period's actual uncollectible expense net of the actual recovery through the Uncollectible Rider, plus the forecasted uncollectible expense for the upcoming year.

(2) The actual Percentage of Income Payment Plan ("PIPP") uncollectible expense related to non-payment of PIPP installment amounts from November 1, 2010 to September 30, 2015 net of the actual recovery through the Uncollectible Rider, plus the PIPP uncollectible expense incurred by the company from October 1, 2015 up to the effective date of the Uncollectible Rider.

Again, under item #1, we see nothing that limits uncollectible expense to uncollectible expense related to non-generation service

Assuming that the terms "electric charges" or "electric service" are not meant to exclusively relate to non-generation service, it was not clear how DP&L bears the cost of all non-payment of electric charges. Given that DP&L does not purchase a supplier's receivables, suppliers bear the cost of non-payment. While past due CRES charges do take precedence in the partial payment priority order, current EDU charges are ahead of current CRES charges.

According to an FAQ on DP&L's supplier webpage, "Outstanding supplier charges will be removed from the account according to the timeline stated in Section 15 of the Rate Ready BSA or Section 12 of the Bill Ready BSA. At that time, the supplier will be responsible for collecting directly from the customer."

To be clear, DP&L does assume all risk for non-payment of non-generation charges, as well as SSO charges. However, it isn't clear why SSO uncollectibles should be nonbypassable if that is, in fact, DP&L's intent

The initial proposed rates for the Residential and Non-Residential Uncollectible Rider to be effective January 1, 2017 are $0.0007506 per kWh and $0.0003131 per kWh, respectively.

DP&L is also seeking to introduce a nonbypassable Regulatory Compliance Rider that would, among other things, include the following costs:

(1) Consumer Education Campaign costs;

(2) Retail Settlement System costs;

(3) Unrecovered Green Pricing Tariff (defunct REC add-on program) implementation costs;

(4) Bill Format Redesign costs incurred up to September 30, 2015;

(5) Generation Separation costs incurred up to September 30, 2015; and,

(6) Unbilled Fuel related to December 2009 under a prior ESP

The nonbypassable Regulatory Compliance Rider would initially be set at $1.08 per month for residential customers and $4.10 per month for non-residential customers

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