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RESA Protests New Tariff Requirement For Consolidated Billing For Rate Discount, Says Limit Not Contemplated by PUC Approval Order

June 27, 2016

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Copyright 2010-16 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

The Retail Energy Supply Association has sought rehearing of a Public Utilities Commission of Ohio order approving compliance tariffs at the FirstEnergy Ohio utilities which, for the first time, introduced a consolidated billing requirement for shopping customers to take service under Rider ELR (Economic Load Response Program).

An adopted stipulation in the FirstEnergy EDCs' recent electric security plan proceeding removed a requirement that customers must take default service to qualify for Rider ELR. Among other things, Rider ELR pays eligible customers a monthly credit, in addition to compensation for curtailments

Specifically, the adopted stipulation provided, "Rider ELR will be available to shopping and non-shopping customers. The Companies will remove from Rider ELR the eligibility requirement that 'the customer is taking generation service from the Company.'"

In adopting the stipulation, PUCO approved the revised Rider ELR and stated that the change, "remo[ves] the prohibition on shopping in order to allow all customers to participate on the Rider." [emphasis by RESA]

However, the FirstEnergy EDCs' compliance tariff included a provision that, for the customer to be eligible for Rider ELR, the customer must be, "taking generation service from the Company or a Competitive Retail Electric Service ('CRES') provider using consolidated billing." RESA noted that no such limitation was included in the stipulation to extend Rider ELR to shopping customers

PUCO approved the tariffs containing such language.

"This limitation should be stricken because it is inconsistent with the Commission’s March 31, 2016 Opinion and Order and was not presented to the Commission in the Stipulation or other materials of record in this proceeding," RESA said

"Additionally, this limitation raises questions of undue discrimination against shopping customers who choose to participate in dual billing," RESA said, noting that limiting Rider ELR to customers on consolidated billing contravenes PUCO's finding that, " all customers," should have access to Rider ELR

"There are ... situations where dual billing is the only option for a shopping customer. That may be because the supplier does not offer consolidated billing, or when, the Companies’ billing systems are unable to calculate a CRES providers’ charges using the pricing format being used by the CRES provider. The Rider ELR tariffs, would prevent those shopping customers and other shopping customers using dual billing (or that in the future would like to switch to a supplier offering dual billing) from participating in Rider ELR, and could also limit a customer’s ability to select the supplier of its choice depending on the interaction of the Companies’ billing systems and the supplier’s pricing format," RESA said

RESA noted that the Rider ELR tariff contains a minimum bill amount that each customer participating in Rider ELR must pay, and the EDCs may cite this provision for requiring consolidated billing (in order to check compliance).

However, RESA said that compliance with the minimum bill provision may still be achieved in dual bill situations.

"The Companies can just as easily require shopping customers to provide copies of their CRES invoices (read off the same meter cycle) to the Companies or alternatively, work with CRES providers to ensure the Companies receive a copy of the customer’s bill when the CRES provider issues the bill to the customer. With only a few customers able to participate in Rider ELR, these alternatives are manageable and will ensure that all shopping customers eligible for Rider ELR retain the ability and choice to elect consolidated billing or dual billing as well as the supplier of their choice," RESA said

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